ASC, PO Box 589, Marshall, MI 49068 phone 269-781-4021 fax 269-781-7400 email kimojim@aol.com
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ASC, PO Box 589, Marshall, MI 49068 phone 269-781-4021 fax 269-781-7400 email kimojim@aol.com
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FAA Docket FAA-2000-8425 14C
FR 21.191(i)1 AND 14 CFR 61.431PETITION FOR EXEMPTION TO EXTEND THE ALLOWED TIME FOR
TRANSITIONING OPERATING FLEET AIRCRAFT AND EXISTING INSTRUCTORS. Dear
Sirs: 14
CFR 11.81 Provided guidance on submitting for an exemption.
The following data is provided in that format.: (a)
James G. Stephenson, acting for, and President/CEO,
of Aero Sports Connection, Inc., PO Box 589, Marshall, MI 49068.
269-781-4021, 269-209-1466
fax 269-781-1400 (b)
We are seeking an exemption to extend the transition by two years to (c)
We are seeking a two year extension to the transitional activities of
Light-Sport Aircraft and Sport pilot instructors coming in from the exemption. (d)
This request is in the public interest as shown by the enclosed data sheet.
While this exemption will not solve all losses to the community, it will
certainly bring in a much larger number of the aircraft that will otherwise
become illegal. A very
conservatively low assessment indicates that at least $60 million worth of
private individual value can be protected.
More than 4,000 additional pilots could be better trained and contribute
to flight safety. ASC
is in the best position to assess this “Hidden Airforce” in that we have
managed the largest exemption in the nation.
At one time, more people flew under ASC exemption than any other civilian
signature in history. We also
have good assessments of the extent of the aircraft that were neither under an
exemption or the We
further request this exemption based on significant mis-steps by the FAA.
These include over-stating examiner and DAR availability, diverting
manpower from these time critical tasks, and discarding community/FAA
transitional plans. (e)
Granting the exemption will not adversely affect safety, the exemption will
provide a greater level of safety than that provided by the rule by allowing a
large number of aircraft to become part of the system and allowing their owners
to get and prove a higher level of training.
This
request will extend the time to complete as many aircraft as possible in a way
that is already being done safely. The delays in getting structure in place, and
difficulties in getting the examiners approved, have made this extension
necessary. By extending the
time over which existing exemption instructors my fly and use their time to
become CFIs, we will be expanding the instruction base and allowing more flight
training hours. This is critical
because we have not had planes and examiners available until now to get these
instructors approved. The detail exemption
requests made by Aero Sports Connection, Inc. are as follows: 1)
Change 14 CFR 21.191(i)1 date
from 2)
Re-release Exemption 6080 to expire 3)
Change 14 CFR 61.431 date from 4) Change 14 CFR 21.191(i)1 date for training allowance as shown in Order 8130.2F CHG 3, from 1/31/2010 to 1/31/2012 Data
to support exemption request 1) Only 19 PPC examiners , of which only 11 can do Instructors 2) Only 18 WSC examiners, of which 12 can do instructors. 3) 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 likes or travel much further to get an examiner. 4) FAA has examiners listed that are not allowed examine, the lists are inflated. 5) The three year transition was hobbled by a very slow start. Nearly a year and ½ were lost simply because the systems were not in place to handle the needs. 6) 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. 7) Larry Clymer informs me that as of 6/15: a. 1157 ELSA aircraft had been inspected b. 1938 more registrations had been completed but not yet inspected c. 102 DARs of classifications existed d. Absolute best hope is 4,000 in by the deadline. (would require every DAR to inspect 30 aircraft in 6 months, their average has been 6 in 6 months!) 8) The transition plan developed between FAA and the community was discarded by the LSAB. 9) To come up with a conservatively low estimate of potential aircraft needing to be inspected; a. Every exemption holding BFI has on average of two aircraft (low average) and there are 3000 (ASC), 700 (USUA) and 1300 (EAA) minimum. b. Each instructor has had at least one student that has an aircraft c. 5000 x 3 = 15,000 minimum number of aircraft to bring in. d. PPC and WSC will not be able to become amateur built’ e. 11,000 aircraft will miss the date. f. Half will become worthless costing the individuals $75,000,000 in value. 10) A more realistic estimate we should look at all BFIs and estimate non-BFI numbers: a. Numbers who have ever been BFIs are 5,000 (ASC), 8,500 (USUA) and 2,000 (EAA). b. On average there are 2.5 aircraft per BFI. (I have 4) c. Each instructor has had at least 2 students. d. Aircraft count is then 14,500 x 4.5 = 65,000 aircraft. e. The ARAC estimated 30,000-40,000 aircraft. f. PPC and WSC will not be able to become amateur built’ g. 36,000 aircraft will miss the date. h. Half will become worthless costing the individuals $270,000,000 in value. 11) A 2 year extension will not bring in all outstanding aircraft, but it will bring in some additions aircraft: a. At the current rate of about 2,000 in 6 months we could bring in up to 8,000 more aircraft. b. This would save individuals a total of $60,000,000 of otherwise lost value. 12) 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 the problem children will be a major hit to FAA budgets. Note: FAA does not receive fines to aid its budget. Jim Stephenson |
Copyright all rights reserved, ASC(r)
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