I thank the FAA for working to reduce the regulatory burden on "low-end" general aviation while maintaining satisfactory safety standards. It’s only by making flying more affordable and accessible that the average person will be able to fly often enough to maintain proficiency – itself an important second-order effect of lowering the cost of aviation. I support the overall direction embodied by the proposed rule, and would like to offer some suggestions to improve the final outcome.
With the understanding that it is necessary to establish aircraft performance standards for light-sport category aircraft, I have several concerns about the specific standards proposed. Most of my concerns relate to the proposed Vs1 (clean) stall speed limitation of 54 KCAS:
* The NPRM states that the intent is to "retain low speeds during approach and landing", but the selection of Vs1 as the limiting speed is incompatible with stated purpose. A more suitable limitation would be Vs0, the stalling speed in the landing configuration, giving proper credit to aircraft designs that incorporate flaps or other high-lift devices.
* The proposed rule would allow a sport pilot to fly a Cessna Turbo 182 RG - a fast and complex aircraft with a controllable-pitch propeller, turbocharged engine, and retractable gear, which has a Vs1 of 54 knots. However, the same sport pilot would be excluded from flying a large number of well-regarded training aircraft, including all Piper Cherokee models, which have low stall speeds with flaps down but whose Vs1 speeds are slightly higher than 54 knots. Bear in mind that the same Piper Cherokee could legally be flown today by a solo student pilot after receiving substantially less training compared to a sport pilot.
* The fact that the stall speed limitation is specified as a calibrated airspeed poses several problems. For instance, many older aircraft such as the Cessna 140 do not have any calibrated airspeeds published. Additionally, the vast majority of experimental amateur-built (EAB) aircraft do not have calibrated stall speeds specified, due to the cost and complexity of the required flight testing, and the lack of requirement to do so. It seems that this would exclude sport pilots from flying a large number of otherwise docile and benign aircraft, such as the many various experimental Cub derivatives.
To fix the above problems, I suggest the following modifications:
* Change the stall speed limit to be 54 knots Vs0 (landing configuration) instead of Vs1 (clean). This would satisfy the stated goal of allowing sport pilots to fly aircraft with slow approach and landing speeds, without excluding aircraft that utilize high-lift devices.
* A variation of the above change would be to add the requirement to receive additional training and instructor endorsement to fly aircraft with clean stall speeds greater than 54 knots.
* If it is still desired to maintain a secondary "clean" stall speed limit, I suggest setting this to 61 knots Vs1, which would be in keeping with stall speed limitations previously established in Part 21 and Part 23.
* The wording should be changed to permit the use of indicated stall speeds for aircraft that do not have calibrated stall speeds published.
On the topic of sport pilots and experimental amateur-built (EAB) aircraft, the proposed rule leaves some ambiguities. For instance, could a sport pilot conduct the Phase I flight testing of an EAB aircraft for which stall speeds have not yet been determined?
The proposed change relating to experimental aircraft flying in congested areas leads me to urge the FAA to provide an official definition of what a "congested area" actually is, as the present state of affairs - where each FAA inspector is allowed to interpret this term as they please - leaves pilots with no definitive and deterministic way to know where they are allowed to fly.
Regarding maintenance, the proposed rule sets up a scenario where a light sport aircraft of the same size and complexity as a Cessna 182 is allowed to be maintained by a light sport repairman after a training course, but an actual Cessna 182 can only be maintained by an airframe & powerplant mechanic. I would like to see the FAA address this disparity in a way that allows the reduced cost of ownership of light sport aircraft to benefit owners of normal category aircraft with similar performance and complexity. Anything that can be done to reduce the expenses associated with preventative maintenance can only improve the safety record of the aging GA fleet.
Finally, the proposed changes to sport pilot certification will result in a pilot certificate whose privileges and limitations are largely identical to the recreational pilot certificate. As the latter has had extremely limited popularity, I suggest eliminating the recreational pilot certificate entirely, instead converting the few existing recreational certificates that have been issued into sport pilot certificates.
