Take action! MOSAIC Comment period

[Atrosa]

There are a some super intelligent folks here that can better convey why limiting to 1 pax or 54 knot VS1 is too limited. Can we get someone to eloquently write a letter so we all can speak with one voice to the FAA? My gun club has a lawyer that drafts letters for members to submit to legislators so we don't send conflicting messages.

I don't want to waste this opportunity.

[Atrosa]

Going to post this on PoA. More eyeballs.

[HornedFrogGrant]

I submitted a formal comment earlier today, pushing for VS1 to be increased to 60 knots. This would help make more PA-28s eligible for Sport Pilots, since they're the Piper equivalent of the C172 (which generally already meets the VS1 limitation).

[SportGA]

The "regulation.gov" website makes it VERY clear that a well-reasoned personal comment is more powerful than 1,000 form letters. They state several times that this is not a "vote" so numbers don't matter. So even if our comments aren't the most articulate, if you can make a rational argument for the change you want, go for it!

Also, there are commenters opposing the entire MOSAIC change. They want things as they were. So please go comment your support of the new Regulations. Imagine how disappointed we would be if they end up not being finalized!

[SportGA]

As I said above, there are some commenters in strong opposition to MOSAIC. Some are even arguing that the Sport Pilot ticket should be eliminated entirely. (GO comment your support for MOSAIC!) Here is one comment asking the FAA to eliminate the Sport Pilot ticket:

Docket No.: FAA-2023-1377
Modernization of Special Airworthiness Certification (MOSAIC)
https://www.federalregister.gov/documen ... pecial-air
worthiness-certification
Public Comments Submitted by:
Meredith Holladay, Owner
Holladay Aviation LLC
976 Charles Lindbergh Dr., Suite 3G
Jacksonville, FL 32225
July 24, 2023
To whom it may concern,
I am the co-owner and operator of a Part 61 flight school located in Jacksonville, Florida. I have
been flying since 2001 and have logged more than 5,800 hours of flight time, including more
than 5,000 hours of instruction in single engine aircraft including several makes and models of
light sport and tailwheel aircraft. I have studied the NPRM in detail and am writing today to
suggest some practical modifications to the proposal.
The stated objective of the proposed rule is to “modernize the regulatory approach to light-sport
aircraft, incorporating performance-based requirements that reflect advances in technology and
use cases for this type of aircraft. The proposal is designed to respond to the evolving needs of
this sector and provide for future growth and innovation without compromising safety.” It also
states that “the FAA bases the rigor of certification requirements and operational limitations on a
safety continuum that assesses the exposure of the public to risk for each aircraft and operation;
as the risk increases due to increased operating privileges and aircraft capability, the
requirements and corresponding rigor of requirements and procedures for certification
increase.”
However, this logic is inherently flawed and does not correlate with the FAA’s own data on
aviation accidents, as evidenced in the NTSB aviation accident database. It is widely accepted
throughout the aviation industry that the leading cause of all fatal aviation accidents is pilot error,
not mechanical failure. This is true regardless of the level of pilot certificate held or the category
and class of aircraft involved in the accident. The NPRM does not provide any statistical data to
support its claim that the risk to the flying public increases with increased operating privileges
and aircraft capability, and the limited data that is provided is skewed in an attempt to support
the proposal. The safety related data offered in the NPRM is as follows:
● “Since the 2004 rule, light-sport category aircraft have shown a lower accident rate than
experimental amateur-built airplanes.”
● “The fatal accident rate data compiled since 2011 for these aircraft show that light-sport
category aircraft fatal accident rates fall between experimental and normal category
aircraft, validating that the rigor of certification requirements and procedures of the 2004
Submitted by Meredith Holladay Page 1 of 11
Docket No.: FAA-2023-1377
Modernization of Special Airworthiness Certification (MOSAIC)
final rule falls, as intended, between experimental and normal category aircraft.” (A
footnote states “Light aircraft fatal accident trends are included on the docket at
FAA-2023-1377. These trends are shown beginning in 2011 because of limitations on
available data and since ten-year trends seem sufficient for this proposal.” )
● “The FAA has monitored the accident history of light-sport category aircraft since 2004.
As of 2021, there have been 984 accidents or incidents involving light-sport category
aircraft, with approximately half of those accidents or incidents occurring during the
landing phase. Of the 501 landing accidents, seven resulted in a fatality. The second
highest number of accidents or incidents, 164, occurred during an emergency descent.”
● “At the time of the 1989 final rule, the FAA received overwhelming support for the
four-seat occupancy limitation for recreational pilots. Since then the NTSB has only
recorded 49 accidents with a recreational pilot acting as PIC and only six of those
accidents involved a fatality over a 30-year period.”
The following image is a screenshot from the 2020 AOPA Nall Report, which is included as a
reference in the NPRM. Figure 1.8 indicates that among non-commercial fixed wing operations,
35.1 percent of the accidents involved pilots holding a commercial or ATP certificate, and 49
percent of accidents involved pilots who held an instrument rating. Those numbers seem to
indicate that the experience level of the pilot is not directly related to where the operation lies on
the FAA’s “safety continuum.”
The 2021 GA Survey, also referenced in the NPRM, does not provide any data on the total
number of flight hours flown by pilot certificate held, only by type of aircraft.
Submitted by Meredith Holladay Page 2 of 11
Docket No.: FAA-2023-1377
Modernization of Special Airworthiness Certification (MOSAIC)
I would like to address the flawed logic in considering any data related to recreational pilot
certification. According to the FAA’s 2022 U.S. Civil Airmen Statistics, there were only 79
recreational pilots among a total pilot population of 756,928. This is down from 238 in 2013, still
a low number relative to the total pilot population. Additionally, in 2022 there were only 6,957
sport pilots compared to 280,582 student pilots and 164,090 private pilots. So any conclusions
related to the operation of recreational pilots are statistically insignificant.
https://www.faa.gov/data_research/aviat ... statistics
The NPRM also states: “Specifically, based on the Practical Test Standards (PTS) for sport
pilots and for recreational pilots, the FAA finds that the knowledge and skills that a sport pilot
must demonstrate on a practical test are virtually identical to the knowledge and skills that a
recreational pilot must demonstrate on a practical test. Considering these testing similarities and
that recreational pilots have been safely operating four-seat airplanes with only one passenger
Submitted by Meredith Holladay Page 3 of 11
Docket No.: FAA-2023-1377
Modernization of Special Airworthiness Certification (MOSAIC)
since 1989, the FAA finds that permitting sport pilots to operate airplanes with four seats would
not adversely affect safety.”
A more accurate and relevant comparison can and should be made between sport pilots and
private pilots. As a flight instructor and the owner of a flight school for the last 10 years, I am
intimately familiar with the FAA Practical Test Standards and newer Airman Certification
Standards. If you compare the Sport Pilot PTS with the Private Pilot ACS, the required tasks
and standards are nearly identical. Let’s look at the practical test maneuvers that are most
closely associated with the most common causal factor of all general aviation accidents:
maneuvering during takeoff and landing.
Sport Pilot PTS (2014 update)
https://www.faa.gov/sites/faa.gov/files ... 081-29.pdf
Private Pilot ACS (2019 update)
https://www.faa.gov/sites/faa.gov/files ... acs_change
_1.pdf
Task Sport Pilot - Airplane PTS Private Pilot - Airplane ACS
Normal and
Crosswind Approach
and Landing
● Touches down at or
within 400 feet of a
specified point
● Maintains a stabilized
approach and
recommended airspeed,
or in its absence, not
more than 1.3 VSO,
+10/−5 knots, and/or
appropriate approach
attitude, with wind gust
factor applied.
Same as Sport Pilot
Short Field Approach
and Landing
● Touches down at or
within 200 feet beyond a
specified point.
● Maintains a stabilized
approach and the
recommended approach
airspeed/attitude, or in its
absence not more than
1.3 Vso, +10/−5 knots.
Same as Sport Pilot
Steep Turns ● Rolls into a coordinated
360° turn; maintains a
45° bank.
● Maintains the entry
Same as Sport Pilot
Submitted by Meredith Holladay Page 4 of 11
Docket No.: FAA-2023-1377
Modernization of Special Airworthiness Certification (MOSAIC)
altitude, ±100 feet,
airspeed, ±10 knots,
bank, ±5°; and rolls out
on the entry heading,
±10°.
Slow Flight ● Selects an entry altitude
consistent with safety,
which allows the TASK
to be completed no lower
than 1,000 feet AGL.
● Establishes and
maintains an airspeed at
which any further
increase in angle of
attack, increase in load
factor, or reduction in
power, would result in
an immediate stall.
● Maintains the specified
altitude, ±100 feet;
specified heading, ±10°;
airspeed, +10/−0 knots
and specified angle of
bank, ±10°.
● Select an entry altitude that
will allow the Task to be
completed no lower than
1,500 feet AGL
● Establish and maintain an
airspeed at which any
further increase in angle of
attack, increase in load
factor, or reduction in
power, would result in a
stall warning (e.g.,
airplane buffet, stall horn,
etc.).
● Maintain the specified
altitude, ±100 feet;
specified heading, ±10°;
airspeed, +10/-0 knots; and
specified angle of bank,
±10°.
Power Off and
Power On Stalls
● Selects an entry altitude
consistent with safety,
which allows the TASK
to be completed no lower
than 1,000 feet AGL.
● Maintains a specified
heading, ±10°, in straight
flight; maintains a
specified angle of bank
not to exceed 20°, ±10°;
in turning flight, while
inducing the stall.
● Minimum loss of altitude
appropriate for the
airplane.
● Select an entry altitude that
will allow the Task to be
completed no lower than
1,500 feet AGL
● Maintain a specified
heading ±10° if in straight
flight; maintain a specified
angle of bank not to exceed
20°, ±10° if in turning flight,
while inducing the stall.
● recover promptly after a full
stall occurs (no longer any
mention of minimum
altitude loss)
Basic Instrument
Maneuvers
● Not tested because there
is no instrument training
required for the sport
pilot certificate, even
though many LSA’s are
equipped with basic
attitude instruments.
● Maintain altitude ±200 feet,
heading ±20°, and airspeed
±10 knots.
Submitted by Meredith Holladay Page 5 of 11
Docket No.: FAA-2023-1377
Modernization of Special Airworthiness Certification (MOSAIC)
Despite the similarities between these two standards, one important distinction is evident in the
standard for maneuvering during slow flight. In 2019 the FAA changed the Private Pilot ACS to
ensure that applicants are recognizing the onset of a stall and recovering at the first indication of
a stall warning; whereas the Sport Pilot PTS requires the applicant to maintain a stall warning.
Given the NPRM’s emphasis on advanced technologies available in existing and future LSAs,
and the FAA’s stated desire to enhance safety among the sport pilot population, why did the
FAA not include in this NPRM a change to the Sport Pilot PTS to align the standard for this
maneuver with the Private Pilot ACS?
To obtain some insight into the relative number of aviation accidents involving sport pilots vs.
private pilots, I searched the NTSB CAROL database using the following criteria: Event date is
on or after January 1, 2004 (the beginning of the sport pilot rule) and factual narrative contains “
private pilot certificate” or “ sport pilot certificate.” The space before the word private or sport is
due to the fact that if you do not include the space, the search results will include the phrase
“airline transport pilot.” It is necessary to search in this way because NTSB reports do not
include a distinct data field to record the certificate level of the pilot in command at the time of
the accident. My search produced 316 records where sport pilot was mentioned in the narrative,
and 6,486 records where private pilot was mentioned in the narrative. If you divide the total
number of records by the total number of pilots in each certificate group, you get a rate of 4.5
percent for sport pilots and 3.9 percent for private pilots.
Based on this information, it is reasonable to conclude that sport pilots are not substantially
more likely to be involved in an aircraft accident than private pilots purely based on their level of
certification. This is good news, but contradicts one of the key assertions of the proposal, that
risk drops with each higher level of pilot certification (the “safety continuum” reference). This
assertion is not supported by NTSB accident reports involving general aviation aircraft. I would
suggest that the authors of this NPRM spend a few hours watching a few episodes of Probable
Cause on YouTube to gain a better insight into this issue:
https://www.youtube.com/@ProbableCause-DanGryder
Let’s take a step back and consider the motivations for the development of the sport pilot rule 20
years ago. The FAA wanted to regulate all the pilots who were flying what it considered “fat
ultralights” and aviation manufacturers saw an opportunity to broaden their market space, which
was largely stalled. The 2004 rule attempted to address both issues simultaneously by creating
a new pilot certificate and a new category of aircraft that those pilots could fly. The industry was
abuzz with promises of a “half price pilot certificate” and the opportunity to fly “simple,
affordable, new aircraft” which would offset the aging general aviation fleet. While the sport pilot
industry has produced some innovations, it has largely failed to meet its original objective for the
following key reasons:
● Even though the minimum flight time required to earn a sport pilot certificate is half (20)
of that required to earn a private pilot certificate (40), the reality is that very few pilots are
able to meet the proficiency standards for a sport pilot certificate in just 20 hours.
Submitted by Meredith Holladay Page 6 of 11
Docket No.: FAA-2023-1377
Modernization of Special Airworthiness Certification (MOSAIC)
● New light sport aircraft were not as inexpensive or as robust as promised, making them
less desirable by flight schools.
Aviation industry journalist and seasoned pilot Paul Bertorelli recently wrote an article that
echoes some of my critiques of the original light sport rule, while generally supporting the new
proposal. However, in my opinion, he fails to address the ripple effects this proposal would have
on the flight training industry, and on aviation safety in general, if the proposal were enacted:
https://www.avweb.com/insider/light-spo ... p-forward/
The FAA does not maintain a public database that tracks the total number of flight hours
reported on airmen certificate applications, even though this seemingly would be very easy to
do given the fact that all airmen certificates are processed through the online portal IACRA. The
FAA makes a reference to this on its public website but does not provide any data to
substantiate this statement: “Though the regulations require a minimum of 40 hours flight time,
in the U.S. the average number of hours for persons without a hearing impairment completing
the private pilot certification requirements is approximately 75 hours.”
https://www.faa.gov/faq/what-are-hourly ... ough%20the%
20regulations%20require%20a,requirements%20is%20approximately%2075%20hours
Without any data, it is difficult to analyze the relative success or failure of the sport pilot
certification rule that was supposed to allow a pilot to obtain a pilot certificate in half the time it
would take to earn a private pilot certificate. Anecdotally, at our busy flight school in
Jacksonville, Florida, I can attest to the fact that it takes most students 20-30 hours just to gain
the knowledge, skill and proficiency required to solo, and another 20-30 hours to complete their
solo flight time requirements and prepare for the FAA practical test. My husband and I are the
owners and operators and serve as the chief instructors. We have extensive experience over
the last 20 years flying and instructing in LSAs and we can attest to the fact that it is virtually
impossible to earn a sport pilot certificate in 20 hours, even under ideal conditions. The truth is
that most customers who come to us wanting to earn a sport pilot certificate fall into two
categories: They can’t get a FAA medical due to health complications, or they are trying to save
money. In either case, it’s a losing proposition for the customer and they probably should not be
flying airplanes, not even LSAs. Most of the training we’ve done in LSAs has been in
furtherance of a private pilot certificate, which offers more utility and opportunities for the pilot.
One has to wonder, then, if the aim of this NPRM is to “decouple” light sport aircraft from the
sport pilot certificate, why not simply sunset the sport pilot certificate entirely (along with the
mostly defunct recreational pilot certificate)? Much like the FAA forced the owners of “fat
ultralights” to either comply and register or lose the ability to operate their aircraft, why can’t the
FAA require existing sport pilots to gain the additional training necessary to obtain a private pilot
certificate?
Submitted by Meredith Holladay Page 7 of 11
Docket No.: FAA-2023-1377
Modernization of Special Airworthiness Certification (MOSAIC)
The NPRM states that “the FAA proposes to eliminate limitations on classes of eligible aircraft,
propellers, and landing gear; allow airplanes with up to 4 seats for increased utility and
improved flight training opportunities; and increase the maximum airspeed for more practical
personal travel.”
There is no data to support the assumption that carrying additional passengers increases risk by
affecting the pilot’s ability to safely operate the aircraft or exercise his or her pilot in command
responsibilities. The NPRM makes 33 references to the “safety continuum” that “assesses the
exposure of the public to risk for each aircraft and operation; as the risk increases due to
increased operating privileges and aircraft capability, the requirements and corresponding rigor
of requirements and procedures for certification increase.” This, despite there being no data to
indicate that private pilots are any more likely to be involved in an accident if they are flying a
four-seat aircraft with more than one passenger onboard. If this were the case, the aviation
insurance industry – which dictates virtually everything we do as pilots and aircraft owners –
would assess substantially higher premiums for a Cessna 172 than for a Cessna 152, but this is
not the case. Consider the commercial hull and liability policy for our flight school, which
operates a fleet of seven Cessna aircraft. The annual hull and liability premium for our each of
our two IFR certified Cessna 152s, with a stated hull value of $60,000 each, is $3,707; the
annual premium for each of our three IFR certified Cessna 172, with stated hull value of
$90,000 each, is $4,770.
The NPRM adds that, “With the increased utility because of four-seat designs, light-sport
category airplane operations by pilots holding higher levels of certification would likely increase.
The FAA anticipates an increase to the overall experience level of pilots that operate light-sport
category airplanes, and this generally would have a positive safety benefit.” Again, the FAA here
is not providing any data to support this assumption. We don’t know what percentage of light
sport aircraft operations to date are conducted by pilots holding a private pilot certificate or
higher. Also, as noted in Mr. Bertorelli’s article, light sport aircraft, specifically the S-LSA aircraft
that are legally allowed to be used for flight instruction, have been priced beyond the reach of
most flight schools. I can speak only for my flight school and the primary reason we have not
incorporated a LSA into our fleet is that they are simply too expensive and have not proven to
be as durable as certified aircraft. My two Cessna 150s have paid for themselves tenfold and
have each endured more than four decades of student pilot operations. It never made any
sense for us to own a LSA. It remains to be seen whether the market for new, four-seat LSAs
will justify their development, given the existing market for used, four-seat certified aircraft.
Regarding the proposed four-seat limitation for sport pilots, the NPRM states that “Allowing
sport pilots to operate four-seat airplanes (even with only two persons aboard) would ease
barriers in flight training for sport pilots given the availability of legacy, four-seat airplanes in
flight schools.” It is true that one of the primary drawbacks of most LSAs is their limited useful
load. Let’s face it, many of the guys who need to fly light sport for medical reasons are also
overweight. Even with our Cessna 150s, weight is a limiting factor for instruction because you
have to factor in whether the student will be able to take his practical test in that aircraft with a
230-pound DPE. Allowing sport pilots to fly heavier, four seat aircraft would solve this problem
Submitted by Meredith Holladay Page 8 of 11
Docket No.: FAA-2023-1377
Modernization of Special Airworthiness Certification (MOSAIC)
but also presents a new one which is not addressed in the NPRM. If a student pilot pursuing a
sport pilot certificate wants to fly an IFR equipped Cessna 172, it makes no sense, and is
inherently unfair, for him to be able to earn a certificate in 20 hours without a medical while
everyone else flying that same airplane needs 40 hours and a medical. Why does the NPRM,
then, not propose eliminating the FAA 3rd Class Medical Certificate entirely and allowing all
general aviation operations to be conducted with a valid driver’s license, as is allowed under the
current sport pilot rules?
It is also completely contradictory to the FAA’s alleged focus on safety to allow sport pilots to
earn certificates without any instrument training whatsoever. Most if not all of the LSAs that were
manufactured after 2004 are equipped with at least basic attitude instruments. A sport pilot is
just as likely to be involved in an inadvertent IMC encounter as a student pilot or a
non-instrument rated private pilot. If the FAA was really focused on safety, the agency would
revamp the ACS across the board to incorporate scenarios that address the primary causal
factors of general aviation accidents. This concept is known as Advanced Qualification Program
and it is standardized for Part 121 airline operations. We have incorporated this concept into all
of our training curricula from student pilot forward. For more information visit my website,
https://www.holladayaviation.com/aqp4ga/.
Finally, I would like to note that the NPRM acknowledges that one of the reasons for allowing
sport pilots to fly heavier aircraft is that “heavier aircraft tend to be more stable during turbulent
or windy conditions and, in turn, reduce the workload on the pilot attempting to maintain control
and a desired course. Specifically, lighter aircraft get jostled around more in turbulence, which
causes the pilot to work harder to maintain aircraft control.” This is exactly why I’ve said from the
beginning that the 20-hour minimum for a sport pilot certificate is absurd, given that the light
aircraft they are limited to fly tend to be less stable in all phases of flight than heavier, certified
aircraft. I have given hundreds of hours of instruction in the Czech Sport Cruiser LSA (aka the
Piper Sport) and thousands of hours of instruction in the Cessna 150 and I can say
unequivocally that the Cessna 150, even though it weighs just a few hundred pounds more than
the Sport Cruiser, is markedly more stable and can handle crosswinds better than the Sport
Cruiser. The Sport Cruiser is extremely pitch sensitive and students had much more of a
tendency to overcontrol it than the Cessna 150. However it’s also true, in my opinion, that the
Cessna 150 is more capable and nimble in strong crosswinds than its larger cousin the Cessna
172, but this has more to do with the airframe design than gross weight.
The last issue covered in the NPRM that I’d like to address is aircraft certification and
maintenance. I am not an aircraft mechanic, nor do I have any desire to ever build an aircraft
from a kit. However, as the owner of nine aircraft who writes the checks to keep these aircraft
safe and “FAA compliant” I can say that it is absurd that “FAA approved” parts cost so much
more than similar parts for a LSA. I’ll give you my classic example. It costs about $250 to
replace a simple, 2-inch, metal window latch on a Cessna 150. This is for a part that is not
critical to flight safety and could easily be substituted with a durable, functional window latch that
I could buy at my local hardware store for $10.
Submitted by Meredith Holladay Page 9 of 11
Docket No.: FAA-2023-1377
Modernization of Special Airworthiness Certification (MOSAIC)
Submitted by Meredith Holladay Page 10 of 11
Docket No.: FAA-2023-1377
Modernization of Special Airworthiness Certification (MOSAIC)
In conclusion, my recommendation to the FAA would be to abandon this NPRM and all of its
convoluted amendments to the sport pilot regulations. A simpler and more effective strategy
would be to simply sunset the sport pilot certificate and provide some period of time wherein all
sport pilots would be required to obtain the necessary training to earn a private pilot certificate.
Thank you for your time and consideration.
Meredith Holladay
[email protected]
Submitted by Meredith Holladay Page 11 of 11

[drseti]

The important part of this comment is the concluding recommendation:

In conclusion, my recommendation to the FAA would be to abandon this NPRM and all of its
convoluted amendments to the sport pilot regulations. A simpler and more effective strategy
would be to simply sunset the sport pilot certificate and provide some period of time wherein all sport pilots would be required to obtain the necessary training to earn a private pilot certificate.

By the commenter's own remarks, a significant number of those seeking a Sport Pilot rating are either unable to obtain an FAA 3rd class medical certificate, or are unwilling to accept the risk inherent in even applying for one. Therefore, IMHO, the recommendation kind if makes sense, but only if it is enacted in parallel with opening up Drivers License medicals for all Private Pilots and PP applicants.

[rcpilot]

Gee my comments weren't so lengthy.

[HornedFrogGrant]

Gee my comments weren't so lengthy.

Neither were mine. I got straight to the point.

Hopefully FAA sees-through the longwinded negative comments, such as the one from "Meredith Holladay". The people that want FAA to dial-back MOSAIC (or scuttle it entirely) seem more concerned about themselves personally, rather than the greater good of helping General Aviation as a whole.

If you read between the lines, it's clear that they either have an "axe to grind", or are fearful that MOSAIC will somehow negatively impact them personally... such as diverting business away from their flight school, to some place where Sport Pilot training is welcomed. Nevermind the fact that if they were more receptive to offering Sport Pilot training, it would actually INCREASE their business.

[drseti]

The EAA has a special webinar on MOSAIC, scheduled for Thursday night, 14 September 2023, at 8 PM EDT. You can sign up for free at:
http://EAA.org/webinars.

[AviatorCrafty]

Gee my comments weren't so lengthy.

Neither were mine. I got straight to the point.

Hopefully FAA sees-through the longwinded negative comments, such as the one from "Meredith Holladay". The people that want FAA to dial-back MOSAIC (or scuttle it entirely) seem more concerned about themselves personally, rather than the greater good of helping General Aviation as a whole.

If you read between the lines, it's clear that they either have an "axe to grind", or are fearful that MOSAIC will somehow negatively impact them personally... such as diverting business away from their flight school, to some place where Sport Pilot training is welcomed. Nevermind the fact that if they were more receptive to offering Sport Pilot training, it would actually INCREASE their business.

I read this comment and thought first "thats one flight school I'll never rent from" and "Well 98% of the other comments disagree". Ok jokes aside, I could never see the FAA reading that one comment and saying "Well, shes right, time to disqualify hundreds of pilots and tear out pages of regulations". And you're right to point out it would bring in more pilots to schools that've never catered to sport pilots before. In my personal situation if I wanted to fly LSA I would have to drive over an hour each way to the closest school that has LSA-eligible planes for rent. Theres a flight school at a Class D airport 10 minutes from my house with a fleet of mostly 172s, so this would be an awesome place to rent. However, my only concern is since they've never dealt with sport pilots they may be hesitant to sign me off to rent, or may require a third class medical because their insurance isn't up to speed on sport pilots.

[HornedFrogGrant]

Theres a flight school at a Class D airport 10 minutes from my house with a fleet of mostly 172s, so this would be an awesome place to rent. However, my only concern is since they've never dealt with sport pilots they may be hesitant to sign me off to rent,

That's a legitimate concern, at least initially. Although anyone with even a little business saavy "should" feel compelled to look into it, when a Sport Pilot is standing before them trying to give them their money.

or may require a third class medical because their insurance isn't up to speed on sport pilots.

That really shouldn't be a roadblock. From what I hear, most insurance policies nowadays include catch-all language along the lines of "FAA medical certificate, or alternate substitute deemed acceptable by the FAA" or something to that effect.

The catch-all language is typically included to encompass BasicMed, Sport Pilot "DL in lieu of medical", as well as less-common situations such as military pilots exempt from 3rd class medicals due to their military flight physical/active flight status.

[designrs]

>> A simpler and more effective strategy would be to simply sunset the sport pilot certificate and provide some period of time wherein all
sport pilots would be required to obtain the necessary training to earn a private pilot certificate. <<

Ummm. No. Absolutely not! There are plenty of Sport Pilots that invested time, money, sweat, tears and years of dedication to safely and proudly enjoy aviation. Any suggestion to “sunset” those earned privileges is not only unfair but is also severely misguided especially in context of medical certificate requirements.

Additionally, the entire history of the Sport Pilot Certificate has proven that non-commercial / recreational use / non-complex planes don’t fall out of the sky without a medical certificate, as medical incidents amongst Sport Pilots are either completely non-existent or are extremely rare.

Discrimination in any form against Sport Pilots based on the “medical certificate criteria” by any party (e.g. flight school, insurance company, etc.) should be illegal as it is in complete opposition to FAA regulations by which we comply.

Please do not propose to take away my earned privileges!

[3Dreaming]

Please do not propose to take away my earned privileges!

I don't think anyone here is suggesting that. Someone posted a person's comment from those submitted to the FAA already. It seems that person is against sport pilots.

[designrs]

I don't think anyone here is suggesting that. Someone posted a person's comment from those submitted to the FAA already. It seems that person is against sport pilots.

Understood. I’m tired of the GA community putting down Sport Pilots. Meanwhile most of them they fly these ancient and very boring aircraft (equivalent to grandma’s minivan) and then they come ogle at our sexy LSAs on the ramp. Hypocrites!

Seriously, if I had to learn to fly in a Cessna 152 or 172 I never would have taken lessons.
I wanted to fly a sexy plane!

[HornedFrogGrant]

Any suggestion to “sunset” those earned privileges is not only unfair but is also severely misguided especially in context of medical certificate requirements.

To "sunset" the Sport Pilot certificate would likely result in an uproar from more than Sport Pilots, as it would also ground an awful lot of "Private Pilot-or-higher exercising Sport Pilot privileges". I'd hazard to guess that "Private Pilot-or-higher exercising Sport Pilot privileges" far outnumber pilots with an actual Sport Pilot certificate.

I have to believe that FAA is unlikely to take the NPRM comments from one "Meredith Holladay" seriously. When you read between the lines, it's apparent that the author/flight school owner feels that the proposed regulation is some sort of threat to their flight school's well-being.