June 19, 2012

Re: Docket Number FAA-2012-0350

To whom it mayconcern:



### Iam a private pilot with an airplane single engine land rating. I have 1150 hours total flying experience; most all of itflying for pleasure in my 1969 Cessna 172K aircraftthat I own. I am also an aircraft mechanic, possessing both Airframe and Powerplant licenses. I am 73 yeas ofage and retired, but I maintain my own aircraft as well as offer my help and guidanceto others with maintenance issues in orderto help promote aviation safety and enjoyment ofthe sport.

I am writing to express my supportforthejointAOPA 

### I EAA Medical Exemption request, Docket Number FAA-2012-0350.

Ifeel thatthe AOPA 

### I EAA Medical Exemption request, ifapproved, will at least maintain and possibly improve the level ofgeneral aviation safetyforthe following reasons:

1. Several years ofaccident 

### I incident statistics have been accumulated to date in Light SportAircraftwith"pilots certified as a Sport Pilotwhere only a current and valid U.S. drivers license is required for operation without the requirement of periodic FAA Medical examinations. The chiefconcern ofsafety mjnded individuals with this change ofpilot requirements is thatthere mightbe an increase ofpilot sudden incapacitation due to medical related issuesthat could result in injury or death ofpassengers or people on the ground. TheAOPA Foundation's Air Safety Institute recently conducted a.studythat showed thatto date, there has been NO Sport Pilot incidences ofpilot incapacitation at ail dueto medical deficiencies; zero
- NONE. Ref (page 12): http:llwww.eaa.orglnews/20121petition for exemption.pdf

Pilot sudden incapacitation is an extremely rare event. Ref (3rd paragraph): http:llwww.aopa.org/whatsnewlregulatorvloperation-safe-pilot.html
According to another source, "The FAA/NTSB hasfound that the incidence of sudden in-flight medical incapacitation ofan aircrewman is so 

### smallas to be statistically insignificant, and when occurring, almost neverthe result ofany known pre-existing condition." · Ref (last paragraph): http://www.navlog.orglmedicals.html

2. Worry about medical qualification leads many pilots to keep·secrets from theirdoctors, Many pilots fearand hesitate reporting genuine medical symptoms to their personal doctorforfearthat the reporting 

### will lead to FAA medical disqualification and end theirflying days. Keeping secrets from yourdoctorwill
never improve aviation safety. This reluctance to report and resolve medicalissues while the problem is in the earlier stages, is more easily dealtwith and with a much greater chance ofsuccessful outcome, can have lethal consequences to the pilot ifthe problem is ignored. In addition, the greater cost ofattempted a cure in the advanced stage of.disease is a hardship to the family involved. The personal and economic consequences ofignoring health related symptoms can be devastating; butthe greater cost is often borne by taxpayers when insurance, if indeed any health insurance exists, is exhausted.

3. My present personal aircraft, a Cessna 172 has the greatest safety**r~cord** of any aircraft ever built. In addition, the engine that powers my 172, a Lycoming 0320-E20 has probablythe best record for reliability ofany engine ever produced by Lycoming. This engine shares the same major components with many other higher horsepowerfour cylinder engines within the Lycoming line. The E2D has a lower compression ratio and lower horsepower rating than most others in the series and components are more lightly stressed. For example,Jhe engine crankcases, while having different part numbers signifying some machining and preparation differences; many ofthe higher horsepowerfour cylinder engines begin from the same raw crankcase casting as myown beloved Lycoming 0-320-E20. Well, forgive me forthe beloved part, as I am a mechanic who loves his work. Anyhow, to be forced to give up my Cessna 172, along with its enviable safety and reliability record makes absolutely no sense to me. Ref: http://www.172guide.com/librarv/landsberg.aspx http://www.aopa.org/asf/asfarticles/sp9512.html

On the other hand, the new restrictions and requirements to exercise recreational pilotflying privileges as proposed bythejointAOPA 

### I EAA Medical Exemption request; such as additional recurrent aero-medical training, limitation to one passenger, daytime operation only and visual flight rules (VFR) operation only, appearwell thought out, should enhance aviation safety and the exemption proposal as a whole makes awhole lot ofsense to me.

4. Recreational and private pilots need to better understand the effects of
common health conditions and the hazards oftaking over-the-counter medicine priorto flight. The increased mandatory education about medical factors in order to qualifyforthe exemption would definitely promote aviation safety. I self-certify that I am fit to fly before everyflight. Increased awareness about health issues through training will enable pilots to make a betterdetermination abouttheir fitness and lead to an overall improvement in safe flying. The periodic recurrent training, as proposed, should keep this knowledge as well as new developments and new lessons learned by the aviation communityfresh in the aviator's mind.

The AOPA Foundation's Air Safety Instituteweb site already has an excellent selection ofexisting interactive on-line aviation safety related courses and offers these courses free ofcharge. The mechanism is already in place to offerthe additional required recurrent training to qualify pilots forthe medical exemption.5. Currently, the FAA routinely issues special issuance medical waivers which
are available to those pilots having a disqualifying medical condition for FAA medical certification. I have manyfriends who have gone this route in an attempt to restore theirflying privileges. I can tell you for sure thatthis is usually a frustrating, time consuming, and very expensive process that is full ofendless processing delays. So challenging is the waiver process that in most cases it is advisable and almost necessaryto hire one ofthe firms, such as Pilot Medical Solutions, Inc. to help guide you through and expedite the process. Such help does not come cheap and is completely unaffordable to someone like myselfof moderate means, retired and living on fixed income.

The statistics page of leftseat.com's web site http://www.leftseat.com/sistats.htm maintains a list of medical conditions togetherwith the number ofpilots within each certificate class that have successfully achieved medical waivers forsome quite serious medical conditions, up to and even including hearttransplant. To
even be considered forwaiver, any such medical conditions mustfirst be "stabilized" and proven so by endless medical reports and documentation. The message is clear: ifyour condition is stable and you possess enough patience, time and especially money, you can restore your medical certificate regardless of most any medical problem.
Exceptfor the frustration and delays involved, the medical waiver process is a good one ifyou can afford it. I am, though, questioning its need; especiallyfor pilots with a stable health condition that on the margin might barely keep them from qualifying ontheir NEXT medical exam. I am thinking as an example, slightly elevated blood pressurethat generally accompanies an aging pilot population. Blood pressure tests test results are a good example, because the results are normally inconsistent and varywidely depending on a variety of factors. Trying to meetan arbitrarystandard and worrying about it (white coat syndrome) has sent many pilots to the sidelines.

I am fortunate that I do not have a blood pressure problem, but manyofmy friends have marginally disqualifying high blood pressure and have either sought the refuge of Light Sport aircraft ofhave given up on flying altogether.

6. If I were required to move to a Light Sporttype airplane, myaircraft ofchoice would be the Cessna 162 Skycatcher. The 162 is powered by a Continental 0- 200 American made engine that has a long and excellent repair history and reputation for robustness and reliability. The only problem is Cessna's price tag at $149,900 as typically equipped. As a retiree, living on fixed income, I don't
seem to have that kind ofcash laying around. Ref- page two: http

### :1 lwww.cessna.com/single-engine/skycatcher/skycatcher -pricing.htm

### I#

Other competing Light Sport aircraft are mostly offoreign manufacture, still cost
over $100,000 and are powered by a less reliable engine. 

### /' 1A few older certified aircraft still exist thatfall within the light sport definition that could be legally flown by a Sport Pilot, but most all are oftailwheel variety which require additional training and pilot rating, but are still more accident/incident prone and ground loop easily.
Light SportAircraft, by theirdefinition, have a large wing area, are much lighter than my present Cessna 172, not as stable and all are more easily upset by gusts and therefore require a greaterdegree ofskill to operate, especially under crosswind landing conditions. A very high percentage of Light sport accidents have resulted during the initial flight orduring transition training.

None ofthe new Light Sport aircraft are as safe or as easyto operate as my old reliable Cessna 172. Ref:http://www.planeandpilotmag.com/pilot-talklmore-pilot-talk/light-sport-chroniclescsi-insurance-excogitations-on-lsa-crashes-part-1.html

In conclusion, I have a suggestion that is guaranteed to improve aviation safety, at least as it concerns myown small world.

Let me invest money in my own personal aircraftwithout fear oflosing myflying privileges everytwo years at FAA medical examination time.

· Let me enjoythis fine sport withoutforcing me to move to a Light Sporttype

aircraftthat I considerto be less safe than my own Cessna 172. ' My personal aircraft is a 1969 Cessna 172. It is a fine flying aircraftthat is maintained by myselfas I am qualified to do so. Myairplane engine is; however, getting tired. The engine has accumulated hours beyond the normal time recommended for overhaul (TBO), and I would like to install a fresh engine to restore renewed climb performance and insure that I can safely make it overthe trees atthe south end ofmy home airportfully loaded even on a hotday.

The current Lycoming Aftermarket Engine Price List, effective January 1, 2012, statesthat a New Exchange engine is $42,782; a Rebuilt Exchange is $28,103 and an Overhauled Exchange is $24,444. Ref (page 11): http://www.lycoming.textron.com/utilitv/globalresources/Lycoming%20Aftermarket%20Engine%20Price%20List%202012.pdf
Unfortunately, the value of myairplane today is roughly $20,000 and itwould not be increased very much, even with a newor overhauled engine. Because of economic conditions as well as greatly increased aviation fuel prices, it currently makes NO ECONOMIC SENSE to invest orspend money on myairplane above what is required for normal maintenance items. 

# r.+Even if Iwere to overhaul the engine by myself, parts alone would cost in excess of$8,000. Make no mistake; IWANTTO SPEND THIS MONEY. This investmentwill help the growth ofgeneral aviation. Iwant to make my airplane safer as well as more enjoyable; but it makes little economic senseto doso unless I can be reasonably assured that Iwill be able to continue to enjoy my airplane for years to come and spread the expense over manyyears free from the threat ofarbitrary medical disqualification. Please allow me to doso by approving thejointAOPA 

### I EAA Medical Exemption request as submitted.

Thank you for allowing meto express my opinion on this subject.
Sincerely,

.•

# ~~,?~- Gerald N. King /

--

# J

61 East 8th Street Deer Park, NY 11729
gki@ suffolk.lib.ny.us