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

 

ASC Submits Transition Extension Request

 

ASC has now submitted an exemption request to extend the time allowed to transition to Sport Pilot and Light-Sport Aircraft.  As you can see below, this is a critical request and driven by failure to develop the necessary infrastructure.  From the beginning, ASC has expressed concern for getting examiners and inspector in place.  Now, this is the driving issue.

 

The detailed exemption requests are as follows:

 

  1. Change 14CFR 21.191(i)1 date from 1/31/2008 to 1/31/2010 .

  2. Change Order 8130.2F CHG 2 training allowance date for Operating Fleet ELSA from 1/31/2010 to 1/31/2012 .

  3. Change 14CFR 61.431 date from 1/31/2008 to 1/31/2010

  4. Re-release Exemption 6080 to expire 1/31/2010

 

By the time you read this, there will be a docket number assigned.  You will be able to go to www.aerosports.org and see how you can comment in support to the docket.  Here is supporting data that you can use to comment to the docket.

 

Extension request supporting data:

 

  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.

 

  1. 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 ½ 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 Light-Sport Aviation Branch. 

 

  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 estimate 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.

 

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.  Why is FAA ignoring this obvious benefit?

 

We need this extension.  It is time for FAA to recognize the need and act.  This exemption is the simplest way.

 

Jim Stephenson

President/CEO ASC

 
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Last updated: July 05, 2008.