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ASC, PO Box 589, Marshall, MI  49068    phone 269-781-4021   fax 269-781-7400  email kimojim@aol.com

 

Date:

 

Dear Administrator Blakey,

Federal Aviation Administration
 800 Independence Avenue , SW
Washington , DC 20591

 

In July of 2004, the Federal Aviation Administration released a new set of rules for light aviation.  These are commonly referred to as Sport Pilot and Light-Sport Aircraft.  The rules provide a better framework for light aviation and I support them.  My concern for these rules is the extremely limited transition time to shift the existing community.

When initially released, it was thought that 3 years would be sufficient to complete the transition.  That time was based on many assumptions that have not proven to be true.  The enclosed data sheet reflects many of these concerns.  As it is now clear, the interaction of requirements for this transition makes 3 years an insufficient time for transition.   We need more time and are asking the FAA for a two year extension in Docket 8425, “The ASC Request of Extension”.

Without this extension, you will be leaving 36,000 aircraft in the field un-registered.  The FAA will be tripping across problems at many turns.  They will no longer be able to ignore these aircraft and the labor to handle these aircraft will be a major hit to FAA budgets. 

One might ask, why is an airworthy aircraft that is appropriate to register today, not appropriate to register tomorrow?  The transition has only now, after 2 ˝ years, begun to function.  To then stop the effort because of an arbitrary deadline, seems wrong.

It is estimated that over $60,000,000 in light aircraft value can be saved by this two year extension.   And while there will never be a time when every aircraft will transition, adding these to the successful group makes a great deal of sense.

I am asking that your active support of “The ASC Request for Extension, Docket 8425”.

 

Sincerely,

 


Extension request supporting data:  As of this date,

  1. Only 17 Powered Parachute examiners , of which only 11 can certify Instructors
  1. Only 18 Weight-Shift Control examiners, of which 12 can certify instructors.
  1. While a larger list, the airplane examiners often will not examine in light types.  This means more time is needed to either transition to the aircraft the examiner prefers or travel much further to locate  an examiner.  

  4.   FAA has examiners listed that are not allowed to examine, that is, the lists are inflated.

 

  1. The three year transition was hobbled by a very slow start.  Nearly a year and ˝ were lost simply because the systems were not in place to handle the needs.

 

  1. Early DPE numbers were so few that most pilots had to travel distances of 500 miles or more.   Some had to travel 2,000 miles.

 

  1. Per Larry Clymer, Manager of the Light-Sport Aviation Branch (LSAB) of the FAA, as of 6/15:

1157 ELSA aircraft have been inspected

1938 more registrations have been completed but not yet inspected

102 DARs of various classifications existed

Absolute best hope is 4,000 aircraft will be inspected by the deadline. (This would require every DAR to inspect 30 aircraft in 6 months; where their average has been 6 in 6 months!)

 

  1. The transition plan developed between FAA and the community was discarded by the LSAB. 

 

  1. To come up with a conservatively low estimate of potential aircraft needing to be inspected;

    1. Every exemption holding BFI has on average of two aircraft (low average) and there are 3000 (ASC), 700 (USUA) and 1300 (EAA) minimum BFIs.

    2. Each instructor has had at least one student that has owned an aircraft

5000 x 3 = 15,000   minimum number of aircraft to convert to ELSA

    1. PPC and WSC will not be able to become amateur built.

    2. 11,000 aircraft will miss the date. 

    3. Half will become worthless costing the individuals $75,000,000 in value.

 

  1. To obtain a more realistic estimate we should look at all BFIs and estimated non-BFI numbers:

    1. Numbers who have ever been BFIs are 5,000 (ASC), 8,500 (USUA) and 2,000 (EAA).

    2. On average there are 2.5 aircraft per BFI.

    3. Each instructor has had at least 2 students.

    4. Aircraft count is then 14,500 x 4.5 = 65,000 aircraft.

    5. The ARAC estimated 30,000-40,000 aircraft.

    6. PPC and WSC will not be able to become amateur built.

    7. 36,000 aircraft will miss the date. 

    8. Half will become worthless costing the individuals $270,000,000 in value.

 

  1. A 2 year extension will not bring in all outstanding aircraft, but it will bring in some additional aircraft: At the current rate of about 2,000 in 6 months we could bring in up to 8,000 more aircraft.

 

  1. This would save individuals a total of $60,000,000 of otherwise lost value.

 

  1. Leaving 36,000 aircraft in the field un-registered will leave the FAA tripping across problems at many turns.  They will no longer be able to ignore these aircraft and the labor to handle these aircraft will be a major hit to FAA budgets.  Note:  FAA does not receive fines to aid its budget. 

 

 

  Your careful consideration of this matter is needed.

 

 

 

 

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Last updated: July 05, 2008.