People,
A new NPRM (Notice of Proposed Rule Making) is out with regards to FAA 61.58. The inclusion of Experimaental Exhibition Jets was put in as an afterthought and the results are catastrophic to operating them.
Essentially, the FAA proposed annual proficiency checks for VLJs (Very Light Jets) under 61.58 guidleines. While this part may be OK, the FAA included in a parathetical statement that EEJs would be part of this, without regard to Operating Limitations or type certification.
This was almost certainly an error by FAA, but that is besides the point. It must be commented on formally or it will go into law.
This is the site for making comments on the 61.58 NPRM. PLEASE don't allow this to into law as it will trickle down through all warbirds and could very effectively ground us all. (See CJAA website at classicjets.com)
http://snipurl.com/t5h9u
Here is my response below. Please write your OWN and submit. Be respectful and don't castigate the FAA. If we get enough people to ask for the non-standard aircraft to be removed we may jsut get it done:
Begin Narrative:
Response to FAA NPRM 61.58 to include Experimental Exhibition Aircraft
The FAA’s inclusion of EXPERIMENTAL EXHIBITION JET (EEJ) in the rule changes in this 61.58 NPRM should be removed. It clearly can be seen in the published NPRM that the parenthetical note adding EEJ to the NPRM was an afterthought. The wording within of NPRM is clearly shows it was written for the Very Light Jet (VLJ). This inclusion of a non-standard certificated aircraft did not consider:
1. A VLJ and EEJ are two completely different types of aircraft, flown for different purposes. The VLJ will fly unrestricted and in all classes of airspace within the ATC system, sharing the complex airspace environment with air carriers and corporate jets where proficiency and currency with their avionic and autoflight systems are what the FAA wishes to oversee. The EEJ only flies within the limits of his/her “Operating Limitations”, something the VLJs do not have in type-certificated aircraft.
2. EEJs are only flown for proficiency, flight training, and traveling to/from demonstrations and exhibitions. They are NOT flown as personal transportation or for compensation or hire.
3. EEJs are restricted from airspaces that are available to the VLJ.
4. The NPRM states it wrote the NPRM because of the expected proliferation of VLJs. This has not happened.
5. The skill sets required by the EEJ pilot is much less perishable than those required for the VLJ pilot, whose pilot cognitive skills will center on complex avionics, auto-flight systems, and integration of their systems with ATC. The VLJ pilot will be required to show proficiency with his “computer”, the EEJ will fly to show proficiency with his ability to handle his high-performance aircraft. The skills and abilities to handle the EEJs are much less perishable than the VLJs cognitive integration-of-system skills. The EEJ pilot’s skills are best maintained by the pilot’s own regular proficiency program or through the CJAA Safety Program.
6. EEJ pilot qualifications are a MINIMUM of 1,000 hours, 500 as PIC, instrument rated rather than the 125 hours and non-instrument rating required by VLJ. Most EEJ pilots are multi-thousand hour pilots with significant complex-aircraft experience. (The NPRM rule change was written for “newbies”, while it envelopes pilots who have “been there, done that”.) There is a huge difference in experience levels and qualifications to fly the EEJ types.
7. VLJ pilot’s proficiency flight review will center on systems manipulation in aircraft that are regulated by FAR Part 23 and Part 25. (This demonstrates that the practical test standards in FAA-S-8081-5D for EEJ would not be valid). It would better serve the EEJ pilots to participate in periodic training events in their qualified aircraft. Such periodic training events would improve the EEJ pilots flying skills and knowledge in any particular EEJ.
8. The FAA’s cost analysis of an annual proficiency flight review for VLJs may be as little as the $600 to $2000 per flight hour. However, the EEJ will be many times that figure, probably exceeding $6,000 per hour for small aircraft and significantly more in larger more complex aircraft. This puts a huge financial burden on the EEJ pilot.
The “Benefit-Cost Analysis Summary” in this NPRM states that “Pilots are not entities so there would not be a small entity impact with regards to pilots.” This statement is completely false and without merit. This statement clearly demonstrates that the writers of this NPRM are completely ignorant of the cost impact on the EEJ pilots.
9. EEJ pilots are often rated in more than on type of aircraft. To force the EEJ pilot to do multiple, annual proficiency flight reviews under 61.58 would be, probably, financially impossible. Example: If a pilot were to hold five (5) ratings in EEJs, he would probably spend a minimum of $50,000 annually for compliance.
10. The FAA did not take into account that there are limited EEJ instructors, and fewer Experimental Aircraft Examiners, available for the proposed annual proficiency rides. This would make it logistically impossible for all EEJ pilots to comply.
11. If this NPRM is enacted the EAEs, CFIs and AIs within EEJ community would NOT be able to maintain their qualifications in PIC proficiency in the rated aircraft in order to provide instruction in preparation to recommend a candidate for an FAA practical exam. This will remove EEJ instructors and EAEs from the system as it would be unaffordable.
12. The FAA NPRM for VLJ was written for certificated aircraft. It was clearly NOT written for non-standard airworthiness certificated aircraft.
13. It would be impossible to meet NPRM 61.58 annual standards in single seat EEJ aircraft.
SUMMARY AND CONCLUSLION
The FAA should remove the EEJ from this NPRM ((Pilots operating single piloted, turbojet-powered airplane with an experimental airworthiness certificate also would be affected.), and replace the wording to state pilots who serve as PIC in single piloted, type certificated turbojet-powered airplanes.
Thereafter, the FAA (AFS-800) should work with industry (CJAA, AOPA, EAA) to continue to develop a periodic proficiency training program that will enhance the skills and abilities in flying the experimental exhibition jet aircraft safely. This approach would most certainly be of higher value to the EEJ pilots than the proposed NPRM.
If the FAA wishes for the EEJ community to enhance the proficiency training in non-standard aircraft, it would best be done with the continued development of the Safety Program as written by the Classic Jet Aircraft Association and the Experimental Aircraft Examiners and CFIs within their respective organization. These programs are designed to address and promote positive attitudinal issues that enhance safety of the experimental jet community. These programs have shown that there is a much greater opportunity to influence safety in the operation of high-performance aircraft.
End Narrative
Charlie Largay
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