AOPA has told the FAA that the agency's sport pilot and light sport aircraft proposed rule is a needed step forward to provide a lower cost alternative to the current private pilot certificate. AOPA said that the FAA should accelerate issuing and implementing a final rule on the airman portion of rule, permitting sport pilots to fly some seven existing certificated aircraft (like a Piper Cub) that meet the light sport aircraft definition, using a driver's license for a medical certificate.
"AOPA believes this rule could help many lapsed pilots return to flying," said AOPA President Phil Boyer. "Many have quit aviation due to aircraft rental and ownership costs, as well as the expense and difficulty of maintaining a current medical certificate. The rule could also have a meaningful, positive effect on the cost of learning to fly, bringing new people into flying."
In its comments on the rule, AOPA said the agency should go even farther and extend sport pilot privileges to recreational pilots. That would mean that recreational pilots could use a current driver's license to meet the medical requirements and that they could fly in Class B, C, and D airspace with the proper flight instructor endorsement. AOPA's proposal would effectively extend the benefits proposed in the sport pilot certificate to a much larger group of aircraft such as a Cessna 172 or a Piper Warrior.
"The driver's license medical is a reasonable and safe standard for both sport and recreational flying," said Andy Cebula, AOPA senior vice president of government and technical affairs. "Only one fifth of one percent of GA accidents were caused by medical issues, and glider pilots have been flying for years without medical certificates or problems."
AOPA suggested that once the FAA has gained experience with sport and recreational pilots flying on a driver's license, the agency should, within three years, work toward using a driver's license instead of a third class medical certificate for private pilots as well.
The association advocated creating a separate category for reporting accidents and accident statistics for light sport aircraft. "The general aviation community, in partnership with the FAA, has worked diligently to reduce accident rates, and it is unclear how including the new light sport pilot and aircraft accident data would affect traditional general aviation statistics," AOPA told the FAA. "Because the new light sport category is administered under a different standard, it is appropriate to clearly define the category as separate from the general aviation category."
AOPA did not offer specific comments on the proposed certification requirements for light sport aircraft. That's because those standards are to be developed by industry consensus.
"Without a complete understanding of the full scope and nature of light sport aircraft consensus design, certification, and continued airworthiness standards, a reasonable and thorough evaluation of the light sport aircraft initiative is not possible," AOPA said. "That is why we are recommending accelerated implementation of the pilot portion while implementation of the aircraft certification standards are developed. Objective comments regarding the utility and impact of the light sport aircraft portion of this proposal depend on a complete evaluation of final industry consensus design, certification, and continued airworthiness standards."
So that passengers would clearly understand that they were flying in an aircraft that didn't meet conventional FAA certification standards, AOPA said that the final rule should include a requirement that sport aircraft be marked on the outside with the words "Light Sport Aircraft" (similar to the markings for experimental aircraft), along with a placard in the aircraft directly in full view of the passenger.
"AOPA believes that the sport pilot rule and our suggested revisions to the recreational pilot certificate better meets the needs of the sport and recreational flying community and provide a safe and attractive entry-level certification for pilots who may ultimately choose to pursue advanced ratings," said Boyer.