EAA Sport Pilot Comments Submitted To FAA

The following paragraphs, taken from the official EAA response, are presented here because they are relevant to our recent NPRM campaign. As you can see, we have achieved our goal of gaining support from the EAA in regard to our position on landing gear and top speed. You may see their whole response at http://www.sportpilot.org/nprm/docket_comments.html

Revise the definition of a light-sport aircraft to include repositionable landing gear for all light-sport aircraft as follows:

(11) Fixed landing gear or repositionable landing gear.

Add definition of a repositionable landing gear as follows:

"Repositionable landing gear means a simple, hand-operated, mechanical system that does not have landing gear doors which open and close in connection with the landing gear repositioning. Repositionable landing gear may be not be actuated by electrical, pneumatic, or hydraulic means."

Justification: To allow repositionable landing gear for only one type of light-sport aircraft is discriminatory. If the gear is of simple enough design to be acceptable for amphibious light-sport aircraft, it is of simple enough design for all light-sport aircraft. Because of the speed limitations for light-sport aircraft, it is unlikely that new light sport airplanes will be designed with repositionable gears as there is no benefit for the added cost of such gear. However having a repositionable gear is of significance to not only amphibious aircraft but also to gliders and to at least one model vintage airplane that otherwise meet the definition of a light-sport aircraft. The allowance of repositionable landing gear for these aircraft will not decrease safety nor increase complexity if our proposed definition of a repositionable gear is adopted.

Revise section (2) of the definition of a light-sport aircraft to remove the V_H limitation.

Justification: This proposed part of the rule is simply unenforceable in the field. The proposed rule would create a situation in which two airplanes could be sitting side-by-side on a ramp with identical outward appearance and engines, however, both could not be flown by a sport pilot because one has a propeller pitched to allow a higher cruise speed. Adding this provision will not enhance safety and puts the Agency in a position of enforcing a rule that is all but unenforceable. The laws of physics will effectively limit the top speed of these aircraft through the proposed stall speed Vso and Vs₁ limitations. No other country (including Australia, Canada, Germany, New Zealand, United Kingdom) that has instituted a similar rule for light-sport aircraft have seen the need for a top speed limitation.

07 May, 2002