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MarkH

MarkH

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MarkH
I just commented on MOSAIC, https://www.federalregister.gov/doc...zation-of-special-airworthiness-certification

In my opinion, the NPRM has many positives, but this is a chance to address the issues before they become rules.

Please take some time to comment.

For some inspiration (and possibly to start a conversation), here is my comment:

First I would like to applaud this work for addressing what is (in my opinion) the greatest limitation of sport pilot adoptions: the fact that a new pilot cannot obtain the rating flying the legacy training fleet. Almost 20 years after approval, it is still difficult to rent a sport pilot qualifying plane in many markets in the US, but one can rent a Cessna 150 almost anywhere.

This NPRM is a significant step in making flying more accessible, and the FAA should be proud of the steps it is taking.

Having said that, I see 3 areas I would like to see improved.

First is the impact (and lack of impact) STCs have on eligibility. Not allowing changes impact sport pilot eligibility artificially limits airplanes that can qualify, and (in my option) goes against the aviation standard of encouraging safety. If sport pilot limitations are written to limit sport pilots to the safest aircraft and modern technology can make an older aircraft conform to these safer standards then logically the regulations should encourage the existing fleet to conform to this safer standard.
§ 61.316 (a) and (b) both contain the language "an "airplane that, since its original certification..." with regard to stall speed and inclusion of retractable landing gear or a controllable propeller. This requirement should be removed does nothing for safety; the current configuration of the aircraft is what matters. For example, a Piper Cub that once briefly had an Aeromatic adjustable propeller installed 70 years ago but has had a fixed pitch propeller ever since... 61.316(a)(4) would make this aircraft inaccessible to a sport pilot for no good reason... or leads to the absurdity of a pilot needing to get training and endorsements for a component that is no longer installed on the aircraft.. Similarly, an aircraft that originally had a stall speed slightly higher than 54 knots but has since been permanently modified (with vortex generators or STC'd STOL kit, for example) to have a lower stall speed.

Second is the 54 knot stall speed. While I am sure there was discussion that lead to the 54kt, the NPRM does not cite it, making the 54kt stall speed seem arbitrary. For example, the 54kt stall speed allows a Bellanca Cruismaster to qualify while disqualifying aircraft such as the Piper Cherokee 140, one of the most popular trainers ever, and the Mooney M20 series.

Last, I am discouraged that this proposal does not alleviate maintenance challenges for legacy aircraft. Mechanic shortages are making it difficult for private owners to keep legacy aircraft safe and flying. The LSRM and LSRI maintenance pathways of the SLSA and ELSA airworthiness certificate have proven to be safe pathways for LSA owners avoid the challenges that the mechanic shortage has created for legacy aircraft owners. The NPRM, as it stands now, misses the opportunity to offer that proven safe maintenance pathway to the current legacy fleet.
 
Looks like your first point was a cut and paste from my comment... :D
 
The low stall speed is going to cut out some Debonairs and Bonanzas. I am hoping that the Beech owners are able to successfully lobby for at least a 63Kt speed. This would make my Arrow eligible.
 
Haven’t commented and don’t plan to. MOSIAC does nothing that interests me.
 
Dana said:
Looks like your first point was a cut and paste from my comment... :D
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It was, you worded my primary concern so well, I decided to take the "repetition= important" approach.
 
I hope they up the stall and allow STCs, even a small bump to 56kts + STCs opens a lot of doors.

I know they make reference to 4 seat aircraft, but is four seats a limit? If I recall correctly, the V tails are TC with 5 seats, so without an STC provision I don't think most Bonanzas could qualify. (This is from memory, I may not be correct)

At the very least, I would like to hear the justification. Because I can't see an argument that a Cruisemaster is safer or easier to fly than a Cherokee.
 
Remember this is the government. They care about safety. Less about the pilot.

I’m still working though my second read and will be framing comments around changes that affect safety. Such as removing the phrase “since originally certificated” as that precludes lower stall speeds provided by STC or other emergent technologies that improve safety.
 
MarkH said:
I just commented on MOSAIC, https://www.federalregister.gov/doc...zation-of-special-airworthiness-certification

In my opinion, the NPRM has many positives, but this is a chance to address the issues before they become rules.

Please take some time to comment.

For some inspiration (and possibly to start a conversation), here is my comment:

First I would like to applaud this work for addressing what is (in my opinion) the greatest limitation of sport pilot adoptions: the fact that a new pilot cannot obtain the rating flying the legacy training fleet. Almost 20 years after approval, it is still difficult to rent a sport pilot qualifying plane in many markets in the US, but one can rent a Cessna 150 almost anywhere.

This NPRM is a significant step in making flying more accessible, and the FAA should be proud of the steps it is taking.

Having said that, I see 3 areas I would like to see improved.

First is the impact (and lack of impact) STCs have on eligibility. Not allowing changes impact sport pilot eligibility artificially limits airplanes that can qualify, and (in my option) goes against the aviation standard of encouraging safety. If sport pilot limitations are written to limit sport pilots to the safest aircraft and modern technology can make an older aircraft conform to these safer standards then logically the regulations should encourage the existing fleet to conform to this safer standard.
§ 61.316 (a) and (b) both contain the language "an "airplane that, since its original certification..." with regard to stall speed and inclusion of retractable landing gear or a controllable propeller. This requirement should be removed does nothing for safety; the current configuration of the aircraft is what matters. For example, a Piper Cub that once briefly had an Aeromatic adjustable propeller installed 70 years ago but has had a fixed pitch propeller ever since... 61.316(a)(4) would make this aircraft inaccessible to a sport pilot for no good reason... or leads to the absurdity of a pilot needing to get training and endorsements for a component that is no longer installed on the aircraft.. Similarly, an aircraft that originally had a stall speed slightly higher than 54 knots but has since been permanently modified (with vortex generators or STC'd STOL kit, for example) to have a lower stall speed.

Second is the 54 knot stall speed. While I am sure there was discussion that lead to the 54kt, the NPRM does not cite it, making the 54kt stall speed seem arbitrary. For example, the 54kt stall speed allows a Bellanca Cruismaster to qualify while disqualifying aircraft such as the Piper Cherokee 140, one of the most popular trainers ever, and the Mooney M20 series.

Last, I am discouraged that this proposal does not alleviate maintenance challenges for legacy aircraft. Mechanic shortages are making it difficult for private owners to keep legacy aircraft safe and flying. The LSRM and LSRI maintenance pathways of the SLSA and ELSA airworthiness certificate have proven to be safe pathways for LSA owners avoid the challenges that the mechanic shortage has created for legacy aircraft owners. The NPRM, as it stands now, misses the opportunity to offer that proven safe maintenance pathway to the current legacy fleet.
Click to expand...

Yep, I commented immediately on 07/23/2023, the first day of the comment period.

Htaylor said:
The Cherokee 140's published stall speed is well below 54 knots.
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VS0 perhaps, but not VS1, according to publications I've seen. The NPRM uses VS1 for determining stall speed.
 
The section requiring basic med for night is a mess - what they say does not make it clear what they want. I suspect they want the sport pilot limitations to prevail over the basic med limits (5 passengers) but...

In the proposed 61.329(d) there is the sentence "If you are satisfying this by meeting the requirements of § 61.23(c)(3), if there is a conflict between the requirements of this section and § 61.113(i), this section controls." As worded, this would seem to imply that 61.23(c)(3) would "control" which I suspect was not the intent. The discussion states that 61.315(d)(4) would "take precedence", however, 61.315(d)(4) does not seem to appear in the proposed regulations
I suspect that the intent is to limit the sport pilot to operate under the performance limits and design requirements of 61.316 and not the broader limits in 61.113(i) which allow additional seats and passengers. Assuming this to be correct, replacing "this section" with "61.316" would add a lot of clarity. I would note that there are limits in 61.113(i) [6000 pounds, 250 knots IAS] which are not limitations in, but do not "conflict" with, 61.316. I suggest clarifying the intent here.
Further, unlike other proposed changes, the rational for requiring an FAA medical or basic med to operate at night is lacking in the discussion. Some clarification here would also be in order.
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Commented on the good stuff, asked for increase in stall speed, and just a passing snipe about the requirements for basic med after one of the disqualifying medical issues requiring a one time SI even though my cardiologists, heart surgeon , family Dr and every other "Medical Professional" I have contacted says I have no problem now.

If it goes into effect as written, I'm ok with it but increasing the stall speed is a simple fix to add more opportunities to use PA-28 series aircraft.
 
I wrote a comment to lay out the safety benefit of using Vs0 versus Vs1, and also in support of removing the restriction on applicability of approved modifications e.g. variable pitch props and lift enhancing devices.
 
An aerodynamics question - if VS1 stall is a proxy for weight, doesn't that mean that it emphasizes aircraft with really bad L/D ratios? Is that safer?
 
bflynn said:
An aerodynamics question - if VS1 stall is a proxy for weight, doesn't that mean that it emphasizes aircraft with really bad L/D ratios? Is that safer?
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VS1 may be a proxy for weight, but it’s not a proxy for L/D.
 
I'm waiting for the various alphabet groups to weigh in to see what they propose so I can include anything they have included in my comment that I think is worthwhile and had not considered...
 
MauleSkinner said:
VS1 may be a proxy for weight, but it’s not a proxy for L/D.
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Help me understand that. They’ve already stated the limit of 3000 pounds. So why would they need a proxy for weight? Would it then be a proxy for wing loading? Higher wing loading equals higher stall speed.
 
Morgan3820 said:
Help me understand that. They’ve already stated the limit of 3000 pounds. So why would they need a proxy for weight? Would it then be a proxy for wing loading? Higher wing loading equals higher stall speed.
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There is no weight limit. A 3000# limit was considered, but they decided to limit stall speed (and thus wing loading) instead.
 
Morgan3820 said:
Help me understand that. They’ve already stated the limit of 3000 pounds. So why would they need a proxy for weight? Would it then be a proxy for wing loading? Higher wing loading equals higher stall speed.
Click to expand...
I don't think an actual weigh limit is in the proposed language. They couldn't possibly have made it something that is that simple to interpret.
 
Dana said:
There is no weight limit. A 3000# limit was considered, but they decided to limit stall speed (and thus wing loading) instead.
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I stand corrected. Which actually works for me because if there’s no actual weight limit and it is based on stall speed, the bonanza crowd are gonna be pushing really hard. And they have a lot more influence than I have. I’ll just come along for the ride. I need a bump up to 62 kts for my Arrow II to qualify. Which is just under a Bonanza
 
MauleSkinner said:
VS1 may be a proxy for weight, but it’s not a proxy for L/D.
Click to expand...
So you're saying lift has no effect on stall speed? An aircraft that has worse lift/drag won't stall earlier? later? Am I backwards?
 
bflynn said:
So you're saying lift has no effect on stall speed? An aircraft that has worse lift/drag won't stall earlier? later? Am I backwards?
Click to expand...
Increasing drag by, say, towing a big bucket behind the airplane will give a worse L/D without changing the lift or stall speed.
 
bflynn said:
So you're saying lift has no effect on stall speed? An aircraft that has worse lift/drag won't stall earlier? later? Am I backwards?
Click to expand...
I’m saying there is no direct correlation between stall speed and L/D.

a 172 has an L/D of, what, 12:1, with a Vs1 in the low 40s.
A Falcon 20 has an L/D of 20:1, and a Vs1 do somewhere around 110-120 knots.
A Schweitzer 1-26E has an L/D of 23:1, and stalls somewhere in the mid-30s.
 
MauleSkinner said:
I’m saying there is no direct correlation between stall speed and L/D.

a 172 has an L/D of, what, 12:1, with a Vs1 in the low 40s.
A Falcon 20 has an L/D of 20:1, and a Vs1 do somewhere around 110-120 knots.
A Schweitzer 1-26E has an L/D of 23:1, and stalls somewhere in the mid-30s.
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Boeing B707-320 L/D 19.4 dunno the stall speed, but I'm sure it's well over 54 knots. https://aerodyn.org/ld-tables/
 
The stall speed thing is a concern for me because it disqualifies my Tampico (Vs1 of 58 knots). Hard to believe that a Tampico wouldn’t be an ideal plane for a sport pilot. Docile, tough as nails, juuussstttt faster than a 152 on 33% more fuel burn. ;)
Not getting to use the lower Vs1 from an STC would be a concern, but the flap & aileron gap seal STC I have doesn’t take credit for lowering the stall speed, AFAIK.
 
Does higher stall speed make it a more difficult aircraft to fly? Is there a difference between say 56kts, 65kts or even 75kts? You need to keep faster than the stall speed so you have less time for planning / thinking, but other than that, any factors to be aware about?
 
Kiddo's Driver said:
The stall speed thing is a concern for me because it disqualifies my Tampico (Vs1 of 58 knots). Hard to believe that a Tampico wouldn’t be an ideal plane for a sport pilot. Docile, tough as nails, juuussstttt faster than a 152 on 33% more fuel burn. ;)
Not getting to use the lower Vs1 from an STC would be a concern, but the flap & aileron gap seal STC I have doesn’t take credit for lowering the stall speed, AFAIK.
Click to expand...

Many of the STCs out there that reduce stall speed are documented as a "no change in performance" STC because it made the certification easier at the time and there was no real gain from the additional investment at the time.

In the case of the MicroAero VGs for the Mooney M20C, they are STCed as "no change in performance" but advertise an up to 8% reduction in stall speed. If they reduce the stall by 8%, that would put it below 56kts if it was documented and STCs were allowed. I believe that if STCs could bring it under 56kts, it would not take long for someone to come up with an STC that documents it. In fact, I expect it would lead to developments of many STCs for planes that sit near, but not under, the stall speed requirement.
 
Most of the gains on TB9 from the gap seal STC are when dirty. You can get well below the published Vs0 and still have full control.
I’m sure it helps on the clean side based on the increased climb rates we get, but you don’t operate clean and power off around the bottom end unless you specifically doing it to see how it behaves.
Power on while clean & power off while dirty are common training configurations. Power off while clean? Not so much. :)
 
Is it really that big a deal? How many pilots who could benefit from this change can’t just get Basicmed?
 
ateamer said:
Is it really that big a deal? How many pilots who could benefit from this change can’t just get Basicmed?
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I’m on Basic Med so it won’t effect my flying, but it may effect the resale value of my plane. 4-seaters like mine will likely be more valuable if they’re eligible for LS.
 
ateamer said:
Is it really that big a deal? How many pilots who could benefit from this change can’t just get Basicmed?
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Nobody knows.

Nobody knows how many pilots are currently flying under the sport pilot rules who are not eligible for Basicmed (no prior medical, or last medical was too long ago (my case)).

Basicmed only really benefits a limited number of pilots who already have a medical and are just trying to avoid renewing a special issue.... Does no good at all for the kid who really wants to fly but was diagnosed with ADHD (or whatever) when he was 6. Or the guy who commented on one of my videos that he has DOT medical and drives a semi, but the FAA has been messing with him for 7 months and counting. etc.
 
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The discussion says "the FAA proposes in § 61.316(h) that a person with a sport pilot certificate may only act as PIC for those powered aircraft (which could include multicopters) whereby the loss of partial power would not adversely affect the directional control of the aircraft."But in the proposed regulations, 61.316(H) does not exist. In the proposed 61.316(a) (7) it says "For powered aircraft other than balloons or airships, the loss of partial power would not adversely affect directional control of the aircraft and the aircraft design must allow the pilot the capability of establishing a controlled descent in the event of a partial or total powerplant failure." Which would suggest multi engine would be OK. However, In the proposed 61.313 it just says "(1) Airplane category and single engine land or sea class privileges," and further on 61.321(e) they talk about adding "single engine land or sea". But nowhere do I find anything about the requirements to obtain or add a multi-engine class to a sport pilot certificate. Does this mean that a Sport Pilot can somehow operate a multi engine aircraft with just a single engine class? Or is there a disconnect between the discussion and the actual proposal? I don't know.
 
ateamer said:
Is it really that big a deal? How many pilots who could benefit from this change can’t just get Basicmed?
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Me (and others like me). Held a Class III within the time limit, then had an event that would require an SI. The Cardiologists, Surgeon, Family Physician all say everything is fine. Dr Bruce also said all is ok but the FAA would almost certainly reject and I’d be grounded. So rather that go thru the time and cost only to be grounded, I fly light sport with my DL and CDL with semi annual checkups with my Docs. Which BTW is more than is required for Class III.
 
ateamer said:
Is it really that big a deal? How many pilots who could benefit from this change can’t just get Basicmed?
Click to expand...

The stated purpose of the LSA regs was to get new pilots into flying and revitalize the new small plane market (and lower the cost of new small planes)

It did a lot for the small plane markets (though less than expected), but it didn't do a great job bringing in new pilots (which is why the small plane market did not grow as expected).

BasicMed has a lot of overlap with what the sport pilot medical was actually used for, but the initial medical hurdle stops it from accomplishing what Sport Pilot set out to do.

At the bare minimum (in my opinion), making Cessna 150s and 152s sport pilot eligible will solve the biggest failure of the intial LSA/Sport Pilot rules - the lack of trainers.
 
Initial Fix said:
Remember this is the government. They care about safety. Less about the pilot.

I’m still working though my second read and will be framing comments around changes that affect safety. Such as removing the phrase “since originally certificated” as that precludes lower stall speeds provided by STC or other emergent technologies that improve safety.
Click to expand...
If they care about safety, why not allow a sport pilot to get an IFR certification or rating. Perhaps a light version, statistics show it makes safer pilots and lower insurance.
 
Dave Anderson said:
If they care about safety, why not allow a sport pilot to get an IFR certification or rating. Perhaps a light version, statistics show it makes safer pilots and lower insurance.
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Or, we could start actually teaching VFR skills.
 
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