June 19, 2012 

Re: Docket Number FAA-2012-0350 

To whom it may concern: 

I am a private pilot with an airplane single engine land rating. I have 1150 hours 

total flying experience; most all of it flying for pleasure in my 1969 Cessna 172K 

aircraft that I own. I am also an aircraft mechanic, possessing both Airframe and 

Powerplant licenses. I am 73 yeas of age and retired, but I maintain my own 

aircraft as well as offer my help and guidance to others with maintenance issues 

in order to help promote aviation safety and enjoyment of the sport. 

I am writing to express my support for the joint AOPA I EAA Medical Exemption 

request, Docket Number FAA-2012-0350. 

I feel that the AOPA I EAA Medical Exemption request, if approved, will at least 

maintain and possibly improve the level of general aviation safety for the 

following reasons: 

1. Several years of accident I incident statistics have been accumulated to date 

in Light Sport Aircraft with" pilots certified as a Sport Pilot where only a current 

and valid U.S. drivers license is required for operation without the requirement of 

periodic FAA Medical examinations. The chief concern of safety mjnded 

individuals with this change of pilot requirements is that there might be an 

increase of pilot sudden incapacitation due to medical related issues that could 

result in injury or death of passengers or people on the ground. The AOPA 

Foundation's Air Safety Institute recently conducted a .study that showed that to 

date, there has been NO Sport Pilot incidences ofpilot incapacitation at ail due to 

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 has found that the incidence of 

sudden in-flight medical incapacitation of an aircrewman is so small as to be 

statistically insignificant, and when occurring, almost never the result of any 

known pre-existing condition." · 

Ref (last paragraph): http://www.navlog.orglmedicals.html 

2. Worry about medical qualification leads many pilots to keep·secrets from 

their doctors, Many pilots fearand hesitate reporting genuine medical symptoms 

to their personal doctor for fear that the reporting will lead to FAA medical 

disqualification and end their flying days. Keeping secrets from your doctor will 

never improve aviation safety. This reluctance to report and resolve medical 
issues while the problem is in the earlier stages, is more easily dealt with and 

with a much greater chance of successful outcome, can have lethal 

consequences to the pilot if the problem is ignored. In addition, the greater cost 

of attempted a cure in the advanced stage of .disease is a hardship to the family 

involved. The personal and economic consequences of ignoring health related 

symptoms can be devastating; but the 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 probably the best record for reliability of any engine ever 

produced by Lycoming. This engine shares the same major components with 

many other higher horsepower four 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 of the higher horsepower four 

cylinder engines begin from the same raw crankcase casting as my own beloved 

Lycoming 0-320-E20. Well, forgive me for the 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 

pilot flying privileges as proposed by the joint AOPA 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, 

appear well thought out, should enhance aviation safety and the exemption 

proposal as a whole makes a whole lot of sense to me. 

4. Recreational and private pilots need to better understand the effects of 

common health conditions and the hazards of taking over-the-counter medicine 

prior to flight. The increased mandatory education about medical factors in order 

to qualify for the exemption would definitely promote aviation safety. I self-certify 

that I am fit to fly before every flight. Increased awareness about health issues 

through training will enable pilots to make a better determination about their 

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 community fresh in the aviator's mind. 

The AOPA Foundation's Air Safety Institute web site already has an excellent 

selection of existing interactive on-line aviation safety related courses and offers 

these courses free of charge. The mechanism is already in place to offer the 

additional required recurrent training to qualify pilots for the 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 many friends who have gone this route in an attempt 

to restore their flying privileges. I can tell you for sure that this is usually a 

frustrating, time consuming, and very expensive process that is full of endless 

processing delays. So challenging is the waiver process that in most cases it is 

advisable and almost necessary to hire one of the 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 myself of 

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 together with the number of pilots within 

each certificate class that have successfully achieved medical waivers for some 

quite serious medical conditions, up to and even including heart transplant. To 

even be considered for waiver, any such medical conditions must first be 

"stabilized" and proven so by endless medical reports and documentation. The 

message is clear: if your condition is stable and you possess enough patience, 

time and especially money, you can restore your medical certificate regardless of 

most any medical problem. 

Except for the frustration and delays involved, the medical waiver process is a 

good one if you can afford it. I am, though, questioning its need; especially for 

pilots with a stable health condition that on the margin might barely keep them 

from qualifying on their NEXT medical exam. I am thinking as an example, 

slightly elevated blood pressure that generally accompanies an aging pilot 

population. Blood pressure tests test results are a good example, because the 

results are normally inconsistent and vary widely depending on a variety of 

factors. Trying to meet an arbitrary standard 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 many of my 

friends have marginally disqualifying high blood pressure and have either sought 

the refuge of Light Sport aircraft of have given up on flying altogether. 

6. If I were required to move to a Light Sport type airplane, my aircraft of choice 

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 of cash laying around. 

Ref- page two: 

http :1 lwww .cessna. com/single-eng ine/skycatcher/skycatcher -pricing. htm I# 

Other competing Light Sport aircraft are mostly of foreign manufacture, still cost 

over $100,000 and are powered by a less reliable engine. 

/' 1 
A few older certified aircraft still exist that fall within the light sport definition that 

could be legally flown by a Sport Pilot, but most all are of tailwheel variety which 

require additional training and pilot rating, but are still more accident/incident 

prone and ground loop easily. 

Light Sport Aircraft, by their definition, 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 greater degree of skill to operate, especially under 

crosswind landing conditions. A very high percentage of Light sport accidents 

have resulted during the initial flight or during transition training. 

None of the new Light Sport aircraft are as safe or as easy to 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 my own small world. 

Let me invest money in my own personal aircraft without fear of losing my flying 

privileges every two years at FAA medical examination time. 

· Let me enjoy this fine sport without forcing me to move to a Light Sport type 

aircraft that I consider to be less safe than my own Cessna 172. 

' 

My personal aircraft is a 1969 Cessna 172. It is a fine flying aircraft that is 

maintained by myself as I am qualified to do so. My airplane 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 over the 

trees at the south end of my home airport fully loaded even on a hot day. 

The current Lycoming Aftermarket Engine Price List, effective January 1, 2012, 

states that 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 my airplane today is roughly $20,000 and it would not 

be increased very much, even with a new or overhauled engine. Because of 

economic conditions as well as greatly increased aviation fuel prices, it currently 

makes NO ECONOMIC SENSE to invest or spend money on my airplane above 

what is required for normal maintenance items. 

r.+ 
Even if I were to overhaul the engine by myself, parts alone would cost in excess 

of $8,000. Make no mistake; I WANT TO SPEND THIS MONEY. This 

investment will help the growth of general aviation. I want to make my airplane 

safer as well as more enjoyable; but it makes little economic sense to do so 

unless I can be reasonably assured that I will be able to continue to enjoy my 

airplane for years to come and spread the expense over many years free from 

the threat of arbitrary medical disqualification. Please allow me to do so by 

approving the joint AOPA I EAA Medical Exemption request as submitted. 

Thank you for allowing me to express my opinion on this subject. 

Sincerely, 

.• ~~,?~- Gerald N. King / --J 

61 East 8th Street 

Deer Park, NY 11729 

gki@ suffolk.lib.ny.us