I know some in the forum have a strong opinion favoring a narrow scope, close to the original proposal, when commenting to NPRM. I respect their position, will respectfully agree to disagree, and ask them just to delete this e mail.
Others, specially sport pilots, may find my comments below appropriate, and if so, I ask them to consider submitting similar comments to the NPRM that changes several sport pilot regulations, Docket FAA-2007-29015. My only intention here is to recruit a few sympathetic supporters that may be out there, not to aggravate anyone. Thanks to all Eliacim http://www.regulations.gov/search/search_results.jsp?css=0&N=0&Ntk=All&Ntx=mode+matchall&Ne=2+8+11+8053+8054+8098+8074+8066+8084+8055&Ntt=29015&sid=11A41DD988A7 General Comment Part 43.3 (g) needs to be modified to allow sport pilots to perform preventive maintenance on ANY aircraft owned and operated by that pilot and not used under part 121, 129, or 135, and not only on those issued a special airworthiness certificate in the light sport category. The current exclusion of sport pilots has never been explained or justified and it is counterproductive to the spirit of the regulation. 1. Part 43.3 (g) allows a sport pilot to do preventive maintenance on an aircraft owed and operated by that pilot, and which has a special airworthiness certificate in the light sport category. By allowing this, the FAA recognizes that sport pilots can do preventive maintenance as well as private pilots can. Why exclude normally certified airplanes that meet light sport requirements? No explanation or justification has ever been offered and it is time to end this unnecessary and costly restriction. 2. Sport pilots operating normally certified aircraft which meet the light sport definition must incur additional expenses, hiring an A&P, to do simple maintenance tasks like changing oil, etc. This works against the spirit of the sport pilot rule, by unnecessarily adding cost to flying. 3. The lack of a medical certificate does not make a sport pilot less or more qualified to change the oil in an airplane that he/she owns. Do we require A&P mechanics to have medical certificates??? Following the above, Part 43.5 (f) needs to be modified to allow sport pilots to approve an aircraft for return to service after performing preventive maintenance under the provision of 43.3 (g). Following the above, Part 91.407 (b) needs to be modified to allow sport pilots to perform flights for operational checks of maintenance or alterations, at least in aircraft owned and operated by that sport pilot. The current exclusion of sport pilots has never been explained or justified. Thanks for your consideration
