Integration of Powered-Lift: Pilot Certification and Operations; Miscellaneous Amendments Related to Rotorcraft and Airplanes

GAMA presents its comprehensive consensus comments on the FAA's proposed Powered-Lift SFAR, focusing on critical aspects including pilot certification, dual controls, flight simulation training devices, and operational rules. GAMA and its members strongly urge the FAA to facilitate initial pilot certification by incorporating a powered-lift type rating into existing airplane or helicopter category certificate. Furthermore, GAMA advocates for the adoption of appropriate operating rules based on each aircraft's performance characteristics, highlighting the need to modernize legacy fuel-based energy reserves and reconsider the requirement for dual control variants. The attached document outlines these recommendations in detail.

I am writing to formally resubmit into the docket the General Aviation Manufacturers Association "GAMA Manufacturer Consensus Recommendations for the FAA's Powered-Lift Special Federal Aviation Regulation (SFAR)", sent to FAA on July 21, 2022, and briefing slides from the FAA Stakeholder Listening Sessions: Powered-Lift SFAR and eVTOL Entry-Into-Service dated August 17, 2022. Upon publication of the proposed SFAR, GAMA and the entire AAM powered-lift community were disappointed that the FAA chose to not consider proactive efforts to engage with FAA to provide "improved data and information to assist the Department in making well-informed decisions" consistent with DOT guidance on the rulemaking process . GAMA respectfully requests FAA consideration of these recommendations and provide its disposition for transparency. Please note that this resubmission is separate from, yet complementary to, GAMA's specific comments to the proposed SFAR submitted to the docket reference GAMA 23-43. The following comment documents are attached: - GAMA23-45 Cover letter "Resubmission of GAMA Manufacturer Consensus Recommendations for Powered-Lift SFAR" - GAMA 23-45A1 Attachment 1: GAMA Manufacturer Consensus Recommendations for Powered-Lift SFAR dated July 21, 2023 - GAMA23-45A2 Attachment 2: FAA Stakeholder Listening Sessions: Powered-Lift SFAR & eVTOL Entry-Into-Service - agenda, industry participants and briefing slides dated August 17, 2022