Comments on the NPRM for Sport Pilot by Bill Watson, USUA BFI, Private Pilot SEL. Generally I am for the Sport Pilot NPRM. I have several safety related items that I am concerned about and therefore must be modified. 1) The training exemptions MUST be left in place. It is irresponsible and unsafe to remove these exemptions unless and until the Sport Pilot authorization has a history of success. One shoule NEVER remove that which works until something which is PROVEN better exists. Such is not the case here. There is no logical reason to remove these exemptions. If the SP ticket is superior, the flying public will gravitate that direction. If it is not, the SP must NOT be forced upon the public. A far superior approach would be to add the instructor exemption as is into the regulations as a SFAR, thereby removing the further need of exemptions. The entire founding purpose of these exemptions are Part 103 training. With the successful passage of this NPRM, damage is done to the training structures already available if the NPRM is left as is. 2) The Make and Model logbook signoff system is unworkable as stated in the NPRM. This is due to the logistics of getting signed off by an instructor as well as the lack of safety related need. A breakdown by 'class/category' would be appropriate where a logbook signoff is done similar to existing GA regulations. This has worked well for many years in GA and I have seen no safety data to warrant altering this for Sport Pilots. Certainly if such safety data should exist, then perhaps all pilots should be subject to make/model requirements. It is noteworthy here that the instructor workforce is expected to be downsized. Also noteworthy is the wide variety of Make/Model combinations available now, as well as can exist if this is well received. With this in mind, safety will be compromised in two ways if left unchanged. First the instructor force will be spread so thin with Make/Model specific experience that matching up will be diffilcult at best. Secondarily, finding an instructor who is expert on a particular craft will be almost impossible due to being responsible for many models in his geographic area. Consider the 'normal' case of one instructor on a given airfield. He would have to have Make/Model qualifications sufficient to give a BFR to each craft on his field that is Sport Pilot as well as enough to train the Part-103 aircraft that are there too. I am convinced this cannot work. Safety will only be compromised by forcing instructors to dilute their teaching efforts with compulsary flight requirements. 3) The carry-logbook rule is impracticle as stated. The rule that is used in Part 91 suffices. There are two typical scenerios for flight. Own it or rent it. If one is an owner, one flys his aircraft. If one rents, the rentor will (for insurance purposes if nothing else) require inspection of the pilot's logbook. This solves any need to carry a logbook as the data within is not so variable. The probability of loss of logbook would be substantially increased with no logical safety gain. 4) The minimum level flight speed alone should qualify an aircraft as sport pilot. Consider any aircraft which can maintain 44 mph or less to be Sport Pilotable. During an uncontrolled descent (crash) the rated speed will have little to do with the impact speed. We all will top out at around 120 mph vertically, given various natures of failures. The 99.9999% of operations where speed is significant to safety is landing. 5) The manufactured aircraft requirement in 3 years may be the back breaker for the entire SP proposal. The current price for a certificatable Quicksilver is 2-3 times the normal price. The manufacturers will then be financially induced to cause unnecessary over-replacement of aircraft parts ongoingly. Similarly they will blame this replacement abuse on the insurance and legal systems. Safety will be best served by spending money on training rather than on nonsense such as this. Part-103 has had such safety success because the pilots have a desire to live and take PROPER maintenance seriously. There should be nothing done to subvert this proven working system. There is no need to overregulate in this area. There are virtually no slumlord style owners of UL/SP flight schools where they hire the pilots and abuse the machine's safety for profit. The owner, maintenance person, and cheif pilot are usually the same person. The only reasonable outcome is for all manufacturers to move offshore to avoid the US court system (especially bankruptcy court!). 6) Engines... there should be little regulated here. The NPRM mandates a single engine. If safety is the issue, this directly contradicts the FAA's own guidelines for commercial aircraft which require multiple engines. Engine failures are to be planned for. If 2 engines are placed on an airframe such that the craft is controllable should one quit, then 2 are better and safer than one. Similarly, turbines are prohibited yet have significantly fewer failures (one moving part!). This flies in the face of safety. Certainly the spin up time on a turbine must be accounted for, but as well the Rotax manual requests no sudden throttle changes. There are several micro-turbines available in the radio controlled marketplace that can be upscaled a little and used here. Safety demands that the flying public be allowed to consider these as viable alternatives especially as these products advance. 7) There is no reason for a SP to land at LAX in class B airspace. None. During my GA training, my instructor felt compelled to teach me procedures for landing at LAX and we did. Though a thrill, there is no purpose. Only danger. Reduce the airspeeds to SP (picture a parachute) and now picture a DC-10 having just departed with a 757 on your tail. Nonsense. The only reason to allow this is to have stories to tell the grandkids, if you live that long. 8) Training... Unless there is something bad about training, it should be not only allowed, but encouraged at every possible point. For this reason, disallowing payment for training merely due to the technical aspects of the airworthiness certificate is wrong. If the same plane, under different paperwork can train, all should be able to train. As far as that goes, I cannot find the logic of disallowing instruction for hire in the experimental class either. If true experiments (test pilot stuff) were being carried out in 'experimental' aircraft continuously, perhaps there would be merit to the rule. Reality states that once the results of the experiments are in (50 hours successfully flown) then the plane should be proclaimed as good as any other and have training allowed. This whole 3 year death to virtually every current trainer is bad law. As the FAA admits that these aircraft both have an outstanding safety record, that is improving, why on earth destroy a perfectly working training system. 9) Flight instruments should be determined based upon the craft. An attitude indicator on a glider is almost standard equipment, while on a parachute is next to useless. At our speeds and horsepower, there is no need for a VSI for day VFR. 10) The mode-c transponder requirements are burdensome to SP for the 30 miles around many large airports. Mode-C within Class-B has purpose. Flying 500 feet up 15 miles from LAX will have no impact on the traffic there. The maintenance requirements on these transponders would be cost prohibitive and therefore deny that part of the sky to us. Perhaps a workable compromise would be to allow flights at less than 2500'AGL be free from this regulation. 11) The retractable gear option must be offered to the glider community. A logbook endorsement would suffice for safety. Similar endorsements can be considered safely in other aircraft if the aircraft demonstrates a 'gear up' landing is uneventful. If retractable is still disallowed, please consider 'ground adjustable' gear to be fixed. 12) Was the 1232# limit chosen to purposely remove the primary trainers used in GA today? Would safety be improved if the fleet of primary trainers be allowed for Sport Pilot instruction? 13) The Gross Weight limit, if it stands, needs clarification. Is this the weight of this particular flight at takeoff? Is it maximum certificated weight? If it is the latter, can the mfg adjust their weight down a little if slightly over? 14) There should be no upper 'speed limit' on Sport Piloted aircraft. If due to technical advances aircraft can go fast while still being able to go slow, why worry? It is during landing that 99.999% of speed related issues come into play. How fast you leave the earth does not matter nearly so much as how fast you return. As far as kinetic energy argument goes, that is nonsense. A fast aircraft during UNcontrolled descent will hit approximately as hard as a slow one will, on any given failure. 15) FAR 91.119 Minimum Safe Altitude requirements must be re-evaluated. 16) PAR 91.207 now applies that we MUST have ELT's? 17) FAR 91.215 now applies that we must have transponders for class B & C and the mode-C areas around large airports? 18) FAR 91.151 says that we must have 30 minute reserves? ------------------------------------------------------------------------------ Part 103 should be modified in 3 places. Denial of one would not invalidate any of the other 2. Sec. 103.1 Applicability. This part prescribes rules governing the operation of ultralight vehicles in the United States. For the purposes of this part, an ultralight vehicle is a vehicle that: (a) Is used or intended to be used for manned operation in the air by a pilot and up to one passenger; (b) Is used or intended to be used for recreation or sport or training purposes only; (c) Does not have any U.S. or foreign airworthiness certificate; and (1) Weighs less than 496 pounds empty weight, excluding floats and safety devices which are intended for deployment in a potentially catastrophic situation; (2) Has a fuel capacity not exceeding 10 U.S. gallons; (3) Has a 39 knot or less stall speed. Sec. 103.15 Operations over congested areas. No person may operate an ultralight vehicle over any congested area of a city, town, or settlement, or over any open air assembly of persons at an altitude of 1,000 feet above the highest obstacle within a horizontal radius of 2,000 feet of the aircraft. Additionally, a catastrophic recovery device must be attached to the airframe for such operations over congested areas. Sec 103.69 Flight Training. Flight instruction for compensation may be performed by those whom the FAA and it's authorized agents (EAA, USUA, ASC) have deemed competent for those purposes subject to the rules contained within Part 103. Done. Justifications: 1) pilot & passenger does not limit training versus pleasure flight. 2) rec/sport/train - append the ability to add safety to the sport and does not exclude compensation. 3) If it had an airworthiness cert, the FAA has a 'need to know' therefore no cert=no need 4) 496# - motor or not, 496 # hits the dirt the same. 5) 10 gal = 100 ish mile range. 6) 44 knots or less sustainable. From there, choose to land or fly. I have never had too much altitude or speed (VNE withstanding). Far from earth cannot hurt. Close to earth is where running out of airspeed, altitude, and ideas is possible. 7) Allow overflight of anywhere if we can land uneventfully. 2000' over one farm house must not constitute a violation. Nor should any SAFE (note the word SAFE) operation be banned. 8) As far as 'there will be no changes to Part 103', Part 103 was updated numerous times from 1985 throgh 1994; so it CAN happen. -dates available by reading 103 on usua site or I can supply.