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FAA MOSAIC for trikes
Ok trikers, microlight, ultralight, powered hang glider and/or weight-shift-control pilots – your chance to help the future development of our beloved sport is here. The new FAA MOSAIC (Modernization of Special Airworthiness Certificates) is proposing big changes to pilot and airplane LSA and here is our chance to expand our possibilities for triking. They have basically ignored us and appears they do not want much WSC trike advancement. Following are my two specific WSC trike comments to help us expand our possibilities. It would be helpful if you could also provide similar recommendations or what ever recommendations you have. Obviously, change your commenter qualifications as needed to “an active pilot, CFI or want to be pilot (as an example is fine). The FAA reads and must respond to all comments so here is your chance to be heard. Details of the MOSAIC and how to comment are at: https://www.federalregister.gov/documents/2023/07/24/2023-14425/modernization-of-special-airworthiness-certification
Commenter Qualifications:
Paul Hamilton Private Pilot WSC, CFI WSC, LSRM WSC and DPE WSC
Over the past two decades, have been a FAA weight-shift-control industry expert advisor for the development and safety of weight-shift-control. Specifically:
· During the initial development of the sport pilot/LSA rollout in 2004, participated in the development of the WSC Practical Test Standards.
· Wrote your FAA WSC Flying Handbook FAA-H-8083-5, every chapter/page (with a coordinated effort with FAA), under Safety Research Corporation of America in 2007-2008.
· Researched, pushed and accomplished, through my retired FAA POI Mike Sees, PTS change 4 released 7/12/2017 for WSC spiral recovery which has reduced the WSC fatalities since it’s incorporation.
· First FAA WSC DPE as Sport/Pilot/CFI was initially rolled out and still one of the few FAA WSC DPE. Private pilot weight-shift-control pilot rating and Light-Sport Repairman Maintenance with airplane, weight-shift-control, glider, powered parachute Light-Sport Repairman Maintenance categories.
Personally, and professionally, an expert in weight-shift-control design and training. Specifically:
· Designed, built and taught myself how to fly a Hang Glider in 1975 (it must be noted that the current weight-shift-control aircraft evolved when the “trike” undercarriage was put under a hang gliding wing. Reference FAA WSC Flying Handbook FAA-H-8083-5 Chapter 1. My first wing I designed, tested and flew is shown in FAA WSC Flying Handbook FAA-H-8083-5 as Figure 1-7.
· Through designing and building Hang Gliding wings 1975 through 1978, obtained US Patent # 4116406 which was developed to be a faster and more efficient wing, which sparked the double surface evolution of the faster weight-shift-control wings of today. Reference: my double surfaced wing is show in FAA weight-shift-control Flying Handbook FAA-H-8083-5 Figure 1-8
· As a college graduate BSME specializing in aeronautics, and a registered Professional Engineer in California and Nevada, my professional aviation career was working with Lear Fan in the Aerodynamics department with performance improvements and Aerion Corp on the supersonic aircraft. This practical experience allowed me to write the FAA WSC Flying Handbook FAA-H-8083-5 Chapter 2 Aerodynamics, to explain the weight-shift-control flying wing concepts to experts as well as new pilots.
· Finally, I have been training, designing, tuning and doing maintenance on weight-shift-control starting before the ultralights were actually called ultralights per FAR Part 103.
· Have thousands of hours in weight-shift-control, all makes and models. Large slow wings, small fast wings, ultralights, LSA including test flying, tuning, rebuilding, training and checkrides, full time at my flight school.
In summary, an FAA and industry time tested, reliable, unbiased weight-shift-control expert who has and will continue to support the safety and development of weight-shift-control aircraft.
MOSAIC Topics Background;
There are two opposing speed safety theories for weight-shift-control (and for that matter this can be applied to all aircraft).
· First: Slow theory. The slower the aircraft and/or lower the wing loading, the safer the aircraft because you cannot get going fast enough to hurt yourself. This is a valid point.
· Second: Fast Theory: The faster the aircraft and/or higher the wing loading, the safer the aircraft is because they are not thrown around as much in turbulence, especially near the ground, and you can safely fly and land in higher winds. Generally higher speed weight-shift-control, as well as airplanes does require a higher pilot skill level, as well as airplanes.
It is interesting that some camps believe in the first, slow is safer, others in second, fast is safer. Both camps have merit. However, to take one side verses the other, is not in the best general interest of aviation\.
Currently, the FAA Sport Pilot speed endorsement, FAR 61.327, accounts for the faster and the slower. Most weight-shift-control are currently in the slower below 87 knots and 61.327 (a), clearly accounts for this. 61.327 (b) brilliantly accounts for aircraft (weight-shift-control) above Vh 87 knots. As the FAA has acknowledged, the endorsement process works.
There are huge potential developments in weight-shift-control wings on the horizon. One obvious example is the variable geometry/twist used in hang gliders for about two decades now. There are plenty of advances to the weight-shift-control wing that can make it more efficient and thus faster.
Specific 14 CFR recommendations for MOSAIC – Weight-shift-control STALL SPEED.
Simply, keep the same stall speed limitations as proposed for airplane.
There is no logical reason for this limitation except the “slow camp” single sided listed above. For the FAA to not allow faster weight-shift-control/flying wings, is not practical or productive. There is no reason to increase the stall speed for airplanes and not weight-shift-control. This would be unnecessarily discriminatory against the weight-shift-control category with no logical basis. Listen to the industry leaders who have experience in this category. Do not stifle the development of weight-shift-control. The flying wing concept is confusing to most aviators, but you must let the weight-shift-control evolve in efficiency and speed like the airplanes.
Part 22 Design, Production, and airworthiness requirements for non-type certificated aircraft.
Specifically: 22.100 (a) (3) last sentence simply get rid of the last words “or 45 knots CAS for weight-shift-control”.
Part 61 CERTIFICATION: PILOTS, FLIGHT INSTRUCTORS and GROUND INSTRUCTORS
61.316 (a) (1) Add and Weight-Shift Control to read ….. except for airplanes “and weight-shift-control”
Specific 14 CFR recommendation for MOSAIC – Raise WSC SEATING CAPICITY to three.
Simply, allow three seated, including the pilot for weight-shift-control aircraft.
There are three seated WSC trikes built in the world today. Just as safe as the two seaters. As with two place, the one or two passengers sit at the center of gravity. A simple addition of weight. There is no reason why three people, including pilot, should not be allowed for weight-shift-control. The sport pilot could fly with only one passenger, similar to the proposed rules for airplane with four seats. A private pilot weight-shift-control could operate with 3 people, pilot and two passengers. Again, no reason to limit the number of seats when the airplane is proposed to have four.
Part 22 Design, Production, and airworthiness requirements for non-type certificated aircraft.
22.100 (a) (1) Except for an airplane and weight-shift-control, ……… Add the three seats for weight-shift-control along with the airplane or add a new number 22.100 (a) (X) For weight-shift-control, have a maximum seating capacity of three, including the pilot.
Part 61 CERTIFICATION: PILOTS, FLIGHT INSTRUCTORS and GROUND INSTRUCTORS
61.316 (a) (2) Add at the end of the paragraph ……and Weight-Shift Control which may have a maximum seating capacity of three persons.
Part 91 General operating and Flight Rules
91.327 (f) add new number (x) more than three occupants including the pilot if a weight-shift-control.
Change 91.327 Special Light Sport (f) add at end of (2) ….other than an airplane “or weight-shift-control.”
Note for 91.319 Experimental
Do not see two and four passenger for updated two and 4 light sport which should be added as needed. Experimental weight-shift-control should also be able to carry three occupants including the pilot.
NON MOSAIC but clean up for Part 61
61.409 What flight proficiency requirements must I meet to apply for a flight instructor with a sport pilot rating?
Additionally, since spiral recovery was added to the PTS as a unique requirement, similar to spins for airplane, and tuck/tumble for weight-shift-control, it should be added to (r) Spiral Recovery for weight-shift-control.
61.311 should add (m) Tuck/tumble awareness and spiral recovery (weight-shift-control)
This will close the loop, and fix it so there is no misunderstanding about this recent important safety requirement and clean up now in the PTS.
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