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MOSAIC draft released


Warmi

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5 hours ago, FlyingMonkey said:

I think the 10,000ft limit is pretty reasonable in that generally people with a DL are okay up to that altitude (after all, airliners are pressurized to 8000), but above that might be iffy if they have underlying issues.

The night thing makes less sense...people don't turn into pumpkins when the sun goes down, and if they have a DL without a day-only restriction they should be safe to operate at night.

Toward the end of the NPRM, they have all the regs written out.  Night flying for a Sport Pilot requires 3 hours of training and an endorsement, 10 takeoffs and landings, a night x-c with one landing 25 miles from the departure airport and he/she must be flying with a Class III or Basic Med.  (It's the FAA's way of "continuing to protect the public".)

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17 minutes ago, Andy said:

If you're exercising sport pilot privileges (regardless of your certificate level), it's 1 pax.

Not saying you’re wrong, but that doesn’t follow the logic in the discussion of the proposed rule. 
 

the discussion argues that a sport pilot may only have one passenger due to level of training. A private pilot cert holder has met this level of training. They don’t forget what they were taught just because of an expired medical and the decision to fly with sport pilot privlages on a DL. 
 

it sounds like the FAA just needs to come out and say if you fly on a DL you only get 1 pax because we want it that way. 

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2 hours ago, kinoons said:

Not saying you’re wrong, but that doesn’t follow the logic in the discussion of the proposed rule. 
 

the discussion argues that a sport pilot may only have one passenger due to level of training. A private pilot cert holder has met this level of training. They don’t forget what they were taught just because of an expired medical and the decision to fly with sport pilot privlages on a DL. 
 

it sounds like the FAA just needs to come out and say if you fly on a DL you only get 1 pax because we want it that way. 

Actually, that is exactly what flying under Light Sport rules has meant and still means; you can just do it in a 4 seater now.  If you have a PPL or higher and a Class III or Basic Med, you can throw 3 more people into that 4 seater.  If you have a PPL or higher and are flying on your DL, you're limited to one...just as you would be if flying an LSA.  From the NPRM: "

"This proposal would also expand what aircraft sport pilots can operate. Under this proposal, sport pilots could operate heavier aircraft than currently allowed under the § 1.1 definition and airplanes with up to four seats, even though they would remain limited to carrying only one passenger. This one passenger limitation would also apply to a flight instructor with a sport pilot rating conducting flight training in a four-seat airplane."

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5 hours ago, Andy said:

Actually, that is exactly what flying under Light Sport rules has meant and still means; you can just do it in a 4 seater now.  If you have a PPL or higher and a Class III or Basic Med, you can throw 3 more people into that 4 seater.  If you have a PPL or higher and are flying on your DL, you're limited to one...just as you would be if flying an LSA.  From the NPRM: "

"This proposal would also expand what aircraft sport pilots can operate. Under this proposal, sport pilots could operate heavier aircraft than currently allowed under the § 1.1 definition and airplanes with up to four seats, even though they would remain limited to carrying only one passenger. This one passenger limitation would also apply to a flight instructor with a sport pilot rating conducting flight training in a four-seat airplane."

When all light sport eligiable aircraft were two seats there was no need to address the possibility of having more than one pax.

earlier in the proposal document the FAA specifically stated that…

“In establishing the 2004 final rule, the FAA intentionally established a rigor of certification for light-sport category aircraft between normal category aircraft and aircraft holding experimental certificates in view of intended operating privileges and aircraft capability. This preamble uses experimental amateur-built aircraft for the safety continuum discussions since they are similar to light-sport category aircraft in this proposal. Amateur-built aircraft are largely used for recreational purposes, are flown by sport pilots and pilots with higher grade certificates, and generally have the same flight envelope and occupancy limits. Amateur-built aircraft are below light-sport category aircraft on the safety continuum because of their lower safety assurance for aircraft design and being subject to stringent operating limitations.”


this certianly implies that the limitation to two pax total was not due to a lack of a medical or to the limited training of a sport pilot, but instead the certification process of light sport aircraft was seen as the weak link. With traditionally certified aircraft now becoming available that weak link would be removed.  Therefor light sport pilots should be permitted to fly with additional pax.

 

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My primary attraction to LSA is the Experimental side / ability to maintain & inspect what I own.  I'm willing and able to have class 3 medical (with PPL rating), and when the market starts bringing over more of the advanced machines that qualify, I just might eat the words of never owning a low wing.  Something with retracts, turbo 915, constant speed, cruising with 02 in low flight levels - damn that's appealing to me over any certified GA stuff. 

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56 minutes ago, airhound said:

FAA now uses 190/195 for standard PAX weight. Shouldn’t this increase be Refactored into gross weights for all manufactured Acft, if original design allows, by the MFG? 

190 is the weight used by ASTM for certification, at least as it applies to useful load.

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Right….but for older ACFT manufactured when 170 was the factor which are now being considered for LSA?

When FAA approves pax weight change, could the process for preexisting certified ACFT like a 62 172 gain some gross weight, per seat, if part of the process indicates no re-engineering or authorizes STC airframe upgrades like 20 pds per seat? 

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3 hours ago, airhound said:

Right….but for older ACFT manufactured when 170 was the factor which are now being considered for LSA?

When FAA approves pax weight change, could the process for preexisting certified ACFT like a 62 172 gain some gross weight, per seat, if part of the process indicates no re-engineering or authorizes STC airframe upgrades like 20 pds per seat? 

For standard category I don't thin seat weight is a factor in the design strength of the aircraft, unless there is a published max seat weight of the design.

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I’ll apologize in advance, but this may be a little long. It’s just what I think of a few areas of the NPRM. I’m only writing this because I’m really curious about what others think. I’m sure some comments will make me second guess my current thoughts.

First, I won’t get into the certification for maintenance persons as I don’t know enough about it. From this forum, allowing it seems to have been a benefit for those doing their own maintenance after the appropriate training. Something I’ll consider for myself in the future, but not now, so I haven’t kept up to date.

Next, continuing with utilizing ATSM standards seems to be successful, safe, and cost effective. This is another area I don’t know the details about, but I’m glad it is continuing. By opening this up to larger aircraft, I think (hope) we will see more new aircraft options become available.

Allowing sport pilots to fly 4 seat airplanes, heavier aircraft and faster aircraft is a huge benefit to sport pilots, training facilities and clubs. Finding rental LSAs can be tough. Also, several training facilities or clubs are willing to rent aircraft to sport pilots, but don’t currently have aircraft meeting the requirements. Training in a 172 or archer can be easier than many current LSAs. They may also be safer for low time or rusty pilots with their additional weight and generally better stability. Some current LSAs aren’t built to withstand the punishment of training. Without a weight limitation, LSAs can be built stronger. Four seats can allow additional cargo capacity for certain situations, such as camping for a week at Oshkosh. I can’t find much of a drawback to allowing four seats or heavier aircraft and I’m ok with limiting it to 4, not more. Continuing to get bigger, faster and more powerful than the new recommendations can probably be handled with additional training and experience, but leave that up to a ppl. For sport pilots wishing to purchase their own aircraft, their options just increased dramatically.

I’m happy about an increase is speed, but I think a max of 250 knots is to much. I realize there aren’t many, if any, 4 seat airplanes that stall at 54 and can do 250 knots, but I feel there should be a lower limit. A low time, or pilot that doesn’t fly regularly, probably doesn’t need to be going 190 knots. Give a speed that opens up opportunity to a sport pilot without putting them in danger. They make it clear that a sport pilot is below a private pilot, so this is a good spot to show a limit indicative of the lower rating. Though some of the RV home built planes are genuine rockets, I think most are 175 knots or less. Maybe around 180 knots should be a limit. It would still keep pilots on their toes and may still be too fast. This is still a huge increase for those that have only flown LSA or current certified trainers, but still makes an impressive cross country plane.

They mentioned a recreational pilot being one step above a sport pilot. With the new privileges allowed to a sport pilot, and less restrictions on a sport pilot compared to a recreational pilot, I definitely think it should put sport pilots a step above recreational pilots. Recreational pilots do require more initial training, but to use some of the new privileges afforded a spl, it would eventually require more total training than required to get a recreational license. I do support the additional training and endorsement requirements for additional privileges. Also, I think using crash stats for recreational pilots is silly due to the low number of recreational pilots, limited hours they fly, and limitations.

If you agree that sport pilots should be above recreational pilots in the FAA line up, why not let sport pilots fill the four seats? Allowing 3 passengers is a nice fit between recreational pilot and private pilot. I know that a lot of people flying as a sport pilot don’t need more than one passenger, but a lot do. Even if you only need to carry one passenger personally, do you feel others should be able to carry up to three passengers? Why or why not? Those that want or need a few more passengers are probably families more than anything else. A family trip seems to fit the purpose of sport pilot pretty well. I can see a lot more people utilizing the sport pilot rating if they could carry their family. Some training outfits also put a second trainee in the back seat to observe and learn. Keep this option available.

I also don’t really see the safety justification for only one passenger. It’s no longer a weight or seats available issue (unless you have a larger family that won’t fit in 4 seats). We obviously want to reduce the number of injuries or deaths in an accident, but is this really a reasonable way to do it? Saying it’s ok to put one passenger at risk, but not 3 doesn’t make any sense. It doesn’t decrease the danger to those on the ground in case of an accident.  Wouldn’t a different tactic, such as requiring a ballistic chute reduce the danger more than just reducing passenger capacity to one person (no, I don’t want chutes to be required)? Most PPLs still fly with only one or two people in the plane, so most flights would still be at the lower safety factor of zero or one passenger, but occasionally flying with two or three passengers adds a ton of flexibility.

The sport pilot license weighs heavily on the driver’s license/self evaluation aspect. A number of PPLs have chosen to fly under SPL limits to avoid dealing with medicals. Let’s keep it that way and not require a medical for night flight or 3 passengers. Since 2004, medical issues have not shown to be a big issue for sport pilots. With this success, don’t add additional medical requirements to the sport pilot. In the NPRM, they discuss current sport pilots creating a safety issue by flying during darkness due to lack or daylight in certain locations and times of year, or simply “get there” issues. They are adding the ability to fly at night for safety, but are requiring the medical. That leaves a majority of sport pilots, who will choose to forgo the medical, in the same safety situations the FAA was describing by by the pilot flying at night anyway (FAAs basic description, not mine). some medical issues can be an issue just because it’s night, most aren’t. Self evaluation is still required for sport pilots. Even though it’s often not addressed on drivers licenses, limits such a restriction from driving at night due to vision issues, should be noted on a driver’s license. If there is a restriction, or requirement on the driver’s license such as “must wear glasses”, it must be followed during flight for sport pilots.

I appreciate a higher stall speed, and I realize they wanted a limit somewhere, I just wish they would have looked at Vs1 for more of the current certified aircraft currently available. So many certified 4 seat planes are just a knot or two above 54. An example is the PA-28 series. I believe the tapered wing fits, but the Hershey bar wing is just a knot over, depending on year and so on. The Hershey bar PA-28s are great trainers and personal airplanes, I think they would be a great sport pilot option.

Again, this is just thoughts I have after reading the document. I’m really curious to hear other views, agreements, or ideas.

Thanks!

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Speaking as someone who has flown fast aircraft, there's a point where extra training helps to think tens of miles ahead, but once you have that training, the difference between 150 and 250 knots isn't really a big difference vs going from a trainer to 150 knots.

I imagine the high performance endorsement is still going to apply here. To hit 250 knots though... I really wonder what is being envisioned there because it would have to be a turboprop at the least.

Regarding LSRM: lotta good, but there is some not so great things I've seen. That applies to all sides of the coin, but there's been some pretty basic stuff that I have seen cheap corner cutting owners do. I approve raising the bar, and there should be currency requirements involving FAA FAAST team courses. Not just for LSRM but also A&Ps who I have also seen shit work from.

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If I remember correctly, I believe the document said there is one aircraft that can do 220 knots and fits the standard, and others that can do 190 and fit the standards. Not sure and I need to re-read to verify though.


Anyway, if flying in the middle of nowhere, speed isn’t as much as an issue. Speed on long trips can make weather more of a issue, but it can also help to stay out of the weather.

Flying around class B airspace in a fast plane, especially if you aren’t cleared into the class B, sure makes things a lot busier for me. It could be easy to get behind. The fastest planes I’ve flown in busy airspace were only good for about 170 cruise, but it was a big change when moving up from my first plane, a Cherokee. Of course you can slow down, but I’m afraid some may push it and break some airspace they aren’t cleared into or cause other issues. A ppl can go over the top , but a spl will have to go through or around the class B to get to the other side. I fly out of an uncontrolled airport without much controlled airspace in the area. When I occasionally fly to the L.A. or San Francisco area, I really have to stay sharp even in my CT. Probably different for those that trained or regularly fly in this type of airspace.

A buddy of mine learned to fly here in a musketeer. We don’t use the radio much except for calls in the blind to uncontrolled airports. Even though he had flown into the LA class B with me a few times, he finally went on his own. He had so much trouble with airspace issues and the crazy radio traffic, he scared himself enough to sell his plane. A faster airplane just seems like it would make flying in this environment much tougher. This is when it would be nice to be on an IFR flight plan.

Most training for controlled airspace here is done at Fresno. It’s a really simple and slow class C and isn’t preparing local students for more advanced airspace.

I realize reaching the new speed limit and having a 54 knot stall speed probably won’t happen for a long time. I can see new aircraft being designed to fit LSA that are going to be substantially faster than a 182 though.
 

A number of newer designs are already making our current certified aircraft in the US look slow, but I’m unsure of what their stall speeds are. The Pipistrel Panthera claims a cruise of 198 knots. Its current clean stall speed is 60. It’s probably a poor example because I realize dropping 6 knots off of the stall speed is a huge amount, but I’m sure it can be done, even if giving up some of the cruise.

Interesting to see that it doesn’t seem like the speed increase is much of a concern for you guys, which is why I like the feedback! While I occasionally fly locally with other pilots, I’m normally the only pilot in the plane on longer trips or into busier airspace. Input from others like you can give me a different aspect.

Cory, again I don’t know much about LSRM, but your opinion of this area carries a lot of weight with me. Thanks for the input.

Thanks again!

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10 hours ago, Madhatter said:

Don't get too excited. 250kt aircraft do not have stall speeds of 54 kt's, unless you are going straight down😁

Agreeing with you, however some are pushing towards that upper boundary and compliant to 54 kts stall.  Swap a small turbine in place of rotax, and climb to 18k instead 9k these numbers are at, might be 250 zone:

Link: Risen 912iS | Fly Risen

175 kts at 9k feet max cruise

38 kts stall (with flaps)

I'd not want a turbine for my type of flying, but someone will build such a design in coming years.  Won't be a sport pilot at the controls but machine will be a sport plane.

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Put a 914 and constant speed prop on a CT is probably reasonable. 100hp turbine technology is minimal at this time, I've looked at several attempts, a lot of issues to solve. Also fuel consumption is horrible at low altitudes and over 18k is IFR only, plus cost. "A" model turbines are not for me, I've seen too many failures as a turbine test engineer. Small turbines have very high rpm and containment is an issue during a failure.

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I think overall the FAA has the right idea regarding speeds.  The fact is cruise speeds between 120kt and 250kt are not really different except in how far ahead the pilot needs to be looking, and that's a pretty easy change to master.  The stall speed is what determines landing speed and thus "difficulty to fly", since most accidents happen in the landing phase. 

I do think 54kt is too restrictive when you compare airplanes...why a 172 but not a Cherokee?  Very arbitrary.  I think 60kt is better.  They could also scrap an absolute stall speed and go for some measure like wing loading, max AoA, or some formula involving measures like those or combined with stall speed.

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I generally agree on a low stall speed being a big safety benefit, but at the same time, current LSAs have a very low stall speed.  Even though we have a slow landing speed, many LSA are very “touchy” at these low speeds, which I think contributes to landing accidents. 

I agree with bumping up the stall just a bit, but only to make a few more planes available to sport pilots.

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1 hour ago, Towner said:

Kinda curious, does anyone else feel that with the new privileges, the sport pilot certificate should be moved ahead of the recreational certificate?

Does it even matter ..there are like what .. 25 recreational pilots in the whole country ? 

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38 minutes ago, Warmi said:

Does it even matter ..there are like what .. 25 recreational pilots in the whole country ? 

That’s kinda why I think it matters. In the NPRM, the FAA specifically talks about sport pilot being below a recreational pilot. In other areas it also talks about rankings of pilot certification and clearly uses the steps or rankings as justification for additional privileges, such as number of passengers. By sport being below a recreational pilot, I think it might be hindering any chance we have of changing the NPRM to allow additional passengers, or maybe even fly at night without a medical ( though I think they are using other justifications for that).

It also uses accident data and fatality numbers from recreational pilots. With the low pilot numbers, low flying hours and a limited range of 50 miles, I don’t think using these crash stats in any type of comparison should be done.

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Requiring a low clean stall speed might accelerate possible technological advancement to achieve high cruise. Competitive markets will look to capitalize on new idea's. I had worked for a company that makes engines for cruise missles that had a problem  with the fuel system.  It was solved by one engineer at his home. His hobby included high speed photography and was used to solve the issue. You never know where it will come from. Just remember Burt Rutan put his idea on a napkin at a restaurant for the round the world flight.

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16 hours ago, Towner said:

That’s kinda why I think it matters. In the NPRM, the FAA specifically talks about sport pilot being below a recreational pilot. In other areas it also talks about rankings of pilot certification and clearly uses the steps or rankings as justification for additional privileges, such as number of passengers. By sport being below a recreational pilot, I think it might be hindering any chance we have of changing the NPRM to allow additional passengers, or maybe even fly at night without a medical (though I think they are using other justifications for that).

It also uses accident data and fatality numbers from recreational pilots. With the low pilot numbers, low flying hours and a limited range of 50 miles, I don’t think using these crash stats in any type of comparison should be done.

You raised an interesting point about numbers so I went to the FAA website to see what I could find.  The latest numbers from a 2022 spreadsheet there shows 79 active recreational pilots (down from a maximum of 238 in 2013) and 6,957 sport pilots (up from a low of 4824 in 2013).  There's no category and class ratings associated with a sport pilot certificate (it's controlled by endorsement) so I can't specifically tell how many are fixed-wing, but I believe it's safe to say that there are a lot more fixed wing sport pilots than rec.  I agree with you about using the accident statistics to tell much; certainly, if I was presenting that data, I'd caveat it.  I feel like this change may automatically move things in the direction you're suggesting (i.e., an upward movement of sport pilots in the "safety continuum") unless we see an uptick in accidents once flying in the 4 seaters starts.  The actual flight training between sport airplane and PPL airplane is almost identical and this will make it more so, making me think that at some time in the future the two ratings might merge or at least be seen as equivalent for most GA single engine aircraft.

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