Malcolmbru(at)aol.com
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 Posted: Mon Apr 17, 2006 5:56 pm Post subject: sport pilot anfib malcolm |
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We=E2=80=99ve been Duped, =E2=80=9CAmphibians Need Retracts=E2=80=9D
The committees worked vary hard to get Sport Pilot and Light-Sport Aircraft
right the first time. As with all complex rule changes, we missed the mark.
But, it is not our fault! Really!
There were many discussions on retracts for amphibious aircraft. We knew we
had to have something that worked. The answer seemed easy. Call them=20=E2=80=9C
repositionable gear=E2=80=9D. After all, that is what happens. These gear are not
changed just after takeoff or just before landing. They are never changed=20just
for performance improvement. They are changed to get to a new mode of
interface with the earth, both wet and dry.
How can you say the Buccaneer pilot who leans out and hangs his gear up on=20a
hook, stretching the bungee cord that keeps it attached to the socket, is
doing a complex job?
We thought we had our FAA counterparts convinced. I briefed hundreds of
people, =E2=80=9Cnot to worry=E2=80=9D FAA understands and we will get it done. While in
reality, =E2=80=9CWe=E2=80=99ve been duped!=E2=80=9D
What happened? How could this be? It was a simple change just one to thing
to understanding. For us =E2=80=9Crepositionable means simple
non-performance-enhancing gear moved in-flight.=E2=80=9D
But for =E2=80=9Csomeone=E2=80=9D in FAA, repositionable means, =E2=80=9Ccannot change in flight=E2=80=9D.
See the Federal Register, 69 FR 44801, it reads,=E2=80=9D Repositionable=20landing
gear remains fixed in its position from takeoff through landing=E2=80=9D. =20That is
all it took!
Everyone, including the government, knows that an amphibian is safer to
emergency land gear up. Everyone, including the government, knows that=20the
reason to carry gear is to use it. A wheeled carriage will achieve the same
thing as government=E2=80=99s definition of =E2=80=9Crepositionable=E2=80=9D. Everyone, including the
government, knows that a Sport Pilot can handle distractions such as radios,
flaps, fuel valves and GPS, but somehow moving a lever is too much.
But, wait, there is hope. FAA personnel have promised that this is being
addressed with all haste. Read, =E2=80=9Cat the speed of government.=E2=80=9D That means a
least a year, maybe more. Meanwhile, manufacturers are dying while they
wait to sell their product. Worst yet, pilots go untrained because we cannot
bring in legitimate ELSA amphibian trainers. Owners cannot fly legitimate
Amateur Built amphibians because their training as Private pilots cannot be
applied to their Sport Pilot privileges.
How do we fix this NOW, before it is too late? The answer is a bridge
exemption that will let us function now and the rule can catch up at the=20=E2=80=9Cspeed
government=E2=80=9D. Mermaid was the first to apply. On April 4th they were granted
the exemption. FAA personnel have said =E2=80=9Ceveryone should file individually
for the exemption=E2=80=9D. Right! Three hundred new exemptions moving=20through the
Federal Register at the =E2=80=9CSpeed of government=E2=80=9D, not my idea of a good plan
If that is what they want, OK. We can follow direction. ASC and SAFE=20=C2=AE
have already filed over 24 exemption requests in support of manufacturers and
individuals.
But, there is an easier answer. ASC has filed two =E2=80=9Ccommunity exemption
requests=E2=80=9D that will be administered by ASC for =E2=80=9Cfree=E2=80=9D. One will allow
manufacturers and owners to certify Special Light-Sport Aircraft (SLSA) and Operating
Fleet Experimental Light-Sport Aircraft (ELSA) which are amphibious. The
other will allow Amateur Built Experimental Aircraft (AB) which are amphibians
to be used by pilots operating under the limitations of Sport Pilot
privileges.
You can help. Please comment in support of the exemption requests. It is=20
easy. Just got to _http://dms.dot.gov_ (http://dms.dot.gov/) . First
download and read the lead docket letters. Then go back and submit a supporting
comment to the dockets:
Community SLSA/ELSA with retracts Docket 24241
Community AB amphibians a LSA Docket 24468
Other individual dockets 24129, 24434-36, 24469-82
The community needs your help. The FAA needs to move on these =E2=80=9Cbridge=E2=80=9D
exemptions quickly. Tell them that. Write and help.
Jim Stephenson
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