Exemption/Rulemaking - Experimental Aircraft Association

March 15, 2006 U.S. Department of Transportation Docket Management System 400 7th Street, SW Room PL 401 Washington, DC 20591-0001 Dear Sirs: Reference: FAA Exemption No. 7830, Regulatory Docket No. FAA–2002-11986 EAA (Experimental Aircraft Association) is the world leader in recreational aviation. With an international membership of 170,000 people, EAA brings together aviation enthusiasts, pilots and aircraft owners who are dedicated to the continued growth of aviation, the preservation of its history and a commitment to aviation's future. EAA programs, activities and events are known throughout the world for Preserving the heritage of aviation, Promoting access to flight, Protecting the right to fly, Preparing the future of aviation, and of our Passion for aviation safety and education. EAA is requesting FAA Exemption No. 7830 be renewed for a four (4) year period. This exemption permits volunteer pilots flying EAA Young Eagles to "log flight time", a form of compensation, when flying children during these free flight experiences. The exemption also allows volunteer pilots to receive other types of compensation as noted in the February 29, 2004 FAA exemption (7830A) amending/renewal letter from AFS-1. EAA is requesting the following changes be made to the existing exemption conditions and limitations. 1.Condition and Limitation item 1c - "Have a standard airworthiness certificate." Change to: "Have a standard airworthiness certificate or a special light-sport aircraft certificate (§ 21.190). Reason: EAA is aware that aircraft created under § 21.190 requirements are generally prohibited from operating for compensation or hire. However, light-sport aircraft may be used for compensation and hire per § 91.327(a) for flight training, rental, and glider towing operations. In addition, special light-sport aircraft (§ 21.190) are produced by aircraft manufacturers in accordance with FAA "accepted" ASTM quality control and flight test consensus standards. These FAA "accepted" ASTM standards have allowed aircraft manufacturers to produce extremely safe and reliable light-sport aircraft. 2.Condition and Limitation item 2a - "Hold at least a private pilot certificate…." Change to: "Hold at least a private pilot, a recreational pilot, or sport pilot certificate with the appropriate category, class, type-rating, or logbook endorsement, if necessary, for the aircraft to be used under this exemption in accordance with § 61.31(a), (d), (e), (f), (h), (i), and part 61 subpart D, E, or J as appropriate." Reason: 14 CFR part 61.101(a)(1) authorizes a current and qualified Recreational Pilot to carry a passenger, and 14 CFR part 61.315(c)(4) authorizes a current and qualified Sport Pilot to carry a passenger. EAA contends that although the initial ground and flight training for Recreational or Sport Pilot's is less than for Private Pilots, the flight experience levels required by this exemption – 500 hours total flight time, 200 hours of flight time in the category of the aircraft to be flown, 50 hours in the class of aircraft to be flown, must have met the currency requirements of § 61.56 and § 61.57, and meet the established safety weather minimums, more than exceed the safety offset created by the initial reduced flight training requirements. The goal of the EAA Young Eagles flight experience program is, through the free flight experience, to encourage young people to become interested in all aspects of aviation education and career possibilities. This can best be accomplished by allowing the children to be exposed to all aspects of aviation – from the newly created Sport Pilot and Light-Sport Aircraft recreational activity to all levels of commercial and public service aviation activities. Finally, EAA is aware that § 61.315(c)(10) prohibits sport pilots from acting as pilot in command during passenger-carrying airlift sponsored by a charitable organizatio…