Exemption/Rulemaking - United States Ultralight Association, Inc. (USUA)

August 15, 2005 U.S. Department of Transportation Docket Management System 400 7th Street, S.W. Room PL 401 Washington, DC 20591-0001 Dear Sir: Reference: Comments to United States Ultralight Association (USUA) Petition for Rulemaking, Docket No. FAA-2005-21671-1 EAA (Experimental Aircraft Association) is the world leader in recreational aviation. With an international membership of 170,000 people in more than 112 nations, 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 supporting aviation safety and promoting personal enjoyment and responsibility within an aviation lifestyle. These efforts are made possible through massive volunteer involvement in support of the organization, as well as EAA's special interest Divisions, and a global network of nearly 1,000 local Chapters and the affiliated National Association of Flight Instructors (NAFI). EAA understands the USUA's effort to help the ultralight community fully transition to the Sport Pilot & Light Sport Aircraft rules by requesting a 2-year extension to various transition deadline dates. However, the EAA does not feel enough time has lapsed since the new rules became effective on September 1, 2004 to know if an additional two years is appropriate to facilitate the transition process. At this time it is unclear what additional time, if any, is needed to facilitate the transition of ultralight vehicles and pilots to the Sport Pilot & Light Sport Aircraft rules. The Sport Pilot and Light-Sport Aircraft rule, DOT Docket No. FAA-2001-11133-2712 as amended, is the largest general aviation revitalization act in over 30 years. There truly has been no other act in the history of the FAA/DOT that simultaneously created new categories of both airmen and aircraft, that also allowed civilian industry partners to create aircraft and product production standards. With the rule effective date of September 1, 2004, all partners in the rule implementation are working feverishly to meet all public demands. Thus, it is very impressive that after only 11 months: ·Newly created aircraft manufacturers have received 13 Special Light-Sport Aircraft (SLSA) category and class certificates; ·93 Sport Pilot Examiners (SPE) have received category and class endorsements; ·49 Sport Pilot Instructor Examiners (SPIE) have received category and class endorsements; ·400+ individuals have taken the SP airman knowledge test; ·137 initial Sport Pilot Instructors have received category and class endorsements; ·450+ individuals have been issued Sport Pilot Student Certificates; ·30+ individuals have received NEB approval and been trained as Light-Sport Aircraft DAR's; and ·Approval has been granted to two entities to conduct LSA Repairman – Inspection qualification courses – 8 students graduated from the first course. Despite the huge inroads mentioned above, there remain two significant obstacles for ultralight owners and operators to transition to the Sport Pilot & Light Sport Aircraft rules. First, after an ultralight vehicle is registered and the FAA issues the aircraft an N-number, it cannot be legally flown until the airworthiness certificate is issued and the pilot is FAA certificated. Second, a practical test for issuance of an FAA certificate cannot be administered in an aircraft unless it is registered and airworthiness certificated. EAA suggests the following solutions to reduce the obstacles and make it more likely that ultralight owners and pilots will participate in the transition process of obtaining FAA-issued pilot certificates and registering and certificating their ultralights as FAA registered aircraft. 1. EAA strongly encourages the FAA to allow owners of ultralight vehicles to register their aircraf…