Certification Of Aircraft and Airmen for the Operation of Light-Sport
AircraftThe referenced proposed rule represents revolutionary actions
toward regulating GeneralAviation Sports and Recreation flight. The
safety concerns addressed in the proposed ruling are highly commendable.
The recognition of a DL medical has been a long time coming, and should
energize private aviation in the Sports and Recreation. Although the
proposal indicates that it leaves Part 103 intact, it calls for the
discontinuance of existing trainer exemptions and subjects thousands of
slightly over-weight, overpowered and additional fuel capacity
ultralight-type (referred to as "fat UL’s") vehicles to certification and
airworthiness rules of General Aviation aircraft. In 1982 the FAA
discovered a nation-wide attempt to motorize hang-gliders. The FAA, at
that time, obviously recognized that a new category of flying machine was
being born. This category would be simple structured, powered and
controlled. It would fly low and slow, utilizing backyards and pasture
fields for landing strips and be basically used for fun flying, not
another mode of transportation. Thus, FAR Part 103 was established as a
rule governing the new........ flying  machines..ultralight"vehicles".
The ink was hardly dry on Part 103 when manufacturers began to experiment
with different types of ultralight vehicles. By the late 80’s several
types of wings, to include both 0ne, two and three control axis
ultralight were being marketed. More reliable power sources were being
developed and marketed. The ultralight vehicle was taking shape with more
stability, stronger structures, more reliable and powerful engines,
mechanical brakes and some instrumentation . . . ..a11 of these things
creating a safer and more reliable ultralight vehicles. From the mid-80’s
through the entire decade of the 90’s it appeared the FAA looked upon all
these ultralight vehicle improvements as beneficial to stability and
flight safety. They were everywhere at fly-ins and air shows. By the mid
90’s the FAA had recognized the need for ultralight pilots training
programs.. . .endorsing non-FAA training programs and publishing a
temporary exemption rule for two-place ultralight trainers of similar
construction, power and speed of existing single-place ultralight
vehicles. It was more than obvious that Part 103 limitations (other than
single occupant and possible power-off speed) were being exceeded by
numerous kit options being offered by kit manufacturers and appearing on
completed ultralight vehicles, (by the thousands). It wasn’t until
apparent gross violations in utilization of the two-place trainer
exemption were observed did the FAA openly announce there was an issue
with the "fat UL" situation. Even now, in this proposed ruling, that
issue is mainly identified as being with the rules-abuse of the exempted
two-place ultralight trainers. This proposal often refers to "fat
ultralights" as synonymous with exempt two-place ultralight trainers.This
brings me to my primary concern with this proposal.....that being the
forcing of anyand all single-place "fat UL’s" into the General Aviation
Light-Sport aircraft category, and without a stroke of a pin that
actually deals with these flying machines. Granted, they are(and always
have been) flying outside the limits of Part 103. However, it would be
very difficult to dispute the fact most of these "fat UL’s" are ten-times
more stable in flight and safer flying machines than the FAA ever
perceived of any ultralight vehicle flying our skies, low and slow back
in 1982, when the Part 103 rule was written. Still these little flying
machines maintain the rule of single occupant, can takeoff and land in
backyards safely, and (by all available statistics) possibly have a safer
flying record than any General Aviation category. These machines carry
instruments graduated in miles per hour, rather than in knots, they often
are totally non-electric (rope pull-started engines), and can rotate off
of 75 feet of grass runway, coming to a dead stop in 100 feet from
landing touchdown. How can these little flying machines ever qualify, or
even be welcomed, into the certificating arena of General Aviation
airworthiness standards and maintenance technology. There is not two
AnP’s in the country that know anything about repairing a Rotax 447 or
503 engine, much less one that will volunteer to learn the skill. The
problem has already surfaced relative to authorizing these flying
machines to over-fly congested areas, under this proposal. That is only
one of many such problems that will surface, if the single-place "fat UL"
is forced into the Light-Sport Aircraft category, under this proposal.
I ask that you revisit Part 103 in conjunction with the very valid and
hopefully improvements provided in this proposal.. . to make room in Part
103 for the single-place "fat UL" that for over a decade has proven its
stability and safety in the air as an improved ultralight vehicle who’s
time has come. Look at what modem ultralight flight (what we refer to as
"flying for fun") has brought to grassroots seat-of-your-pants low and
slow flying this past decade. Look at it’s contributions to upward
mobility into the General Aviation categories. Bring Part 103 into the
21st century with a simple stroke of the FAA rules pin. It will be good
for American aviation. It will be in the public interest. Only in America
can such aviation succeed, with such limited regulatory authority
governing it.
It has already been proven as success. What public interest could
possibly be served in destroying it. . . . which is highly possible if
nothing more than this proposal is ruled on related to our beloved "fat
UL’s" that just fly for fun.
Joe Griffey