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PUFA NEWSLETTER
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January 18, 1998
Beverley Lawrence, President
Tobias Kreisz, Vice-President
Mario LeBel, Treasurer
Debbie Major, Secretary
Mail to: Pacific Ultralight Flying Association
102-16071 82 Avenue
Surrey, B.C. V3S 2L6
PUFA Newsletter published by Glenn Ursel
From The President
by Beverley Lawrence
PUFA members are telling me what a good job Jeff did as President of PUFA. That's a fine accolade and I hope to earn the same comments at the end of my term of office. Thank you to those members who gave me their vote of confidence and, for those who did not, I hope you won't be too disappointed.
I would like to hear from you, as members, how you would like to see your club develop and incorporate those ideas into plans for the coming year.
In the distant past PUFA was involved in planning many more social events,
and a number of non
members have expressed their interest in joining the association, if
there was more to hold their interest. Would the present members
like to see more flying events? Come to the meeting on the 28th and
share your ideas.
There is a lot of information to absorb in this newsletter about the comparisons between the various suggestions for the proposed Passenger Carrying regulations. Kathy Lubitz has taken a lot of time and trouble to make the comparisons easier to absorb. The tables showing the safety record of ultralights versus conventional aircraft, clearly identifies how much safer it is to fly ultralights. They don't show how much more fun it is!
Happy flying for 1998!
Editorial Note
by Glenn Ursel
At the last meeting in November, the PUFA Committee on the Ultralight Pilot Passenger Carrying Endorsement issue presented a recommendation for the endorsement requirements. As those of you who attended the meeting will recall, this recommendation was discussed at great length but eventually accepted by the membership.
This recommendation was later faxed to CARAC, UPAC and COPA on November 29th, 1997. We immediately received a protest from Kathy Lubitz that PUFA had undermined the ultralight postion by this proposal. The gist of her complaint was that our proposal was a copy of the RPP requirements, not the ICOA proposal that had been accepted at the COPA meeting at Ottawa on September 27th.
Jeff Rochon and myself reviewed the matter and concluded that she was right. Subsequently, we faxed another endorsement which was essentially the same wording as the ICOA proposal I published in our October PUFA Newsletter.
On December 4th, 1997 Kevin Psutka of COPA faxed their draft proposal to all ultralight contacts that had attended the COPA Ottawa meeting. This was shortly followed up by Kathy Lubitz’ alternative proposal on December 10th.
I have included both these proposals in this newsletter along with Past President Jeff Rochon’s reply for your information and discussion at the January meeting.
To: Ultralight Contacts
From: Kevin Psutka, COPA
Date: December 4, 1997
Re: Ultralight Passenger Carrying Proposal
Attached are the draft proposal for passenger carrying as well as the requirements for an instructor to conduct the training. This proposal was developed during a meeting at COPA on 3 December, using input from the various proposals and advice from the following participants in the meeting: Marlene Gill, Mike Fothergill, Claude Roy, Bruce Carter, Ralph Svendsen, Herb Cunningham and Lindsay Cadenhead.
The general thrust of the proposal is get something in place as soon as possible. This is best accomplished by using, wherever possible, existing items such as the PPR examination. After the program is in place, we can refine it if necessary to be more ultralight unique. All participants felt that any more refinement at this time would only unacceptably delay the introduction.
The proposal will be submitted in time to meet the CARAC schedule. Before it can be submitted, however, we want to publish it in the COPA newspaper for wide distribution to our ultralight pilot members for their feedback. Before this happens, we would like your feedback on the proposal:
Passenger Endorsement - Pilot Permit - Ultralight Aeroplane
(1) Age
An applicant shall qualify for or hold a Pilot Permit - Ultralight
Aeroplane.
(The “shall qualify” is to permit the endorsement to take place during the flight training for a Pilot Permit - Ultralight Aeroplane)
(2) Medical Fitness and Validity
An applicant shall meet the same Medical Certificate requirement as
for a Pilot Permit - Recreational
Aeroplane.
(3) Knowledge
An applicant shall have obtained a minimum of 60% in each of the following
four mandatory areas as well as in the overall written examination Pilot
Permit - Recreational Aeroplane (RPPAE):
(a) Air Law - regulations, rules and orders, air traffic services, practices
and procedures and licensing requirements relevant to the permit;
(b) Navigation - navigation, radio aids and electronic theory;
c) Meteorology; and
(d) Aeronautics - General Knowledge - airframes, engines and systems,
theory of flight, flight
instruments, flight operations and human factors.
(In order to permit rapid introduction of the passenger carrying privilege, the existing PPR examination should be used. One of the next projects could be the development of an examination specific to ultralights.)
(4) Experience
An applicant shall have completed a minimum of 25 hours of flight time
aboard ultralight aeroplanes.
The flight time shall include a minimum of:
(a) 15 hours dual instruction flight time, including a minimum of 2
hours cross-country flight time with at least two cross country legs consisting
of a minimum of 30 minutes each, and
(b) 5 hours solo flight time.
(5) Skill
An applicant shall complete a flight test in an ultralight aeroplane
to the standard outlined in the Flight Test Standard - Recreational Pilot
Permit - Aeroplane (TP12475E).
(Using an existing standard permits rapid introduction and acceptance of the passenger carrying endorsement.)
(6) Credits
(a) The Knowledge requirement shall be deemed to have been met if the
applicant has within the preceding five years passed a written examination
for a Pilot Permit or Pilot Licence in the aeroplane category. (This provision
covers those who have started a flying course in the past but never finished
the flight training.)
(b) The Knowledge and Experience requirements shall be deemed to have been met if the applicant has previously held a Pilot Permit or Pilot Licence in the Aeroplane category and has passed the PSTAR examination or equivalent pre-solo examination and has completed a flight test on an ultralight aeroplane.
Flight Instructor Rating - Ultralight Aeroplane Authorization to Conduct Passenger Carrying Training
(1) Prerequisite
An applicant shall hold a valid Flight Instructor Rating - Ultralight
Aeroplane.
(2) Medical Fitness
An applicant shall hold a Category 3 Medical Certificate.
(3) Knowledge
If the applicant has not already done so, he/she shall pass a General
Aviation Ground School Course or a written examination for a Pilot Permit
or Pilot Licence.
(4) Experience
The applicant shall have acquired no less than 100 hours of flight
experience aboard ultralight aeroplanes of which 50 hours experience shall
be instructing in the air.
5) Skill
An applicant shall have his/her logbook certified by the holder of
a Flight Instructor Rating - Ultralight Aeroplane who is authorized to
conduct passenger carrying endorsement training certifying that the applicant
has demonstrated the ability to perform and instruct both normal and emergency
maneuvers appropriate to the passenger carrying endorsement.
(6) Credits
(a) The knowledge requirement shall be deemed to have been met if the
applicant holds, or has held within the preceding 5 years, a Pilot Permit
or Pilot Licence in any other aeroplane.
(b) The Knowledge and Experience requirements shall be deemed to have
been met if the applicant holds, or has held within the preceding 5 years,
a Pilot Licence - Aeroplane or Helicopter and has a minimum of 50 hours
of instructional flight time in ultralight aeroplanes.
(c) The Knowledge and Experience requirements shall be deemed to have
been met if the applicant has held within the preceding five years a Flight
Instructor Rating - Aeroplane or Helicopter and has successfully passed
a flight test. (Example: a current Class IV instructor does not require
anything extra.)
(7) Period of Validity
(a) The authorization to conduct passenger carrying endorsement is
maintained by a valid Instructor Rating - Ultralight Aeroplane, and (b)
A logbook certification for renewal of the Instructor Rating - Ultralight
Aeroplane shall be performed every 30 months.
In order to meet COPA’s January publication deadline, we need your written feedback by 10 December.
Kevin Putsutka
Executive Vice-President
To: Kevin Psutka, COPA
From: Kathy Lubitz
Date: December 10, 1997
Re: Ultralight Passenger Carrying Proposal
General Comments:
The following is my reaction to the COPA proposal of Dec. 4, 1997. Because of your deadline, we have not had time to develop an official UPAC response.
I have collected some ultralight statistics and compared them to equivalent statistics for general aviation activity. The data was from Transport Canada Safety and Security and the Transportation Safety Board of Canada. The data demonstrates that ultralight activity is safer than general aviation and that ultralight pilots with the present required training are causing fewer ultralight accidents than are general aviation pilots. General aviation pilots are allowed to fly ultralight aeroplanes as a privilege of their license without the requirement to get checked out in ultralight aeroplanes. General aviation pilots already have 'more' knowledge, experience, and skill than current ultralight pilots. The data shows that 'more' knowledge, experience, and skill that is not relevant to ultralight operations will not change the current risk of accidents. The pilots that already have 'more' are causing the majority of ultralight accidents. (I have included this study as an attached Word file, ulrisks2.doc.)
"To satisfy the Government of Canada's regulatory policy for the imposition of additional regulations, a clear problem or risk must exist and the benefits of the regulation must outweigh the costs...:" (from the draft report of the Category IV Medical Standards Working Group, prepared by Larry Cundy, Chief Personnel Licensing).
According to the statistics, ultralight operations do not have a higher degree of risk than general aviation operations. The data does show a clear problem when higher licensed pilots fly ultralight aeroplanes. Ultralight pilots flying ultralight aeroplanes are safer than general aviation pilots flying general aviation aircraft and they are safer than general aviation pilots flying ultralight aeroplanes. In light of the statistics, I do not see a clear problem or risk in the operation of ultralight aeroplanes. Since there is less risk of accidents when ultralight pilots fly ultralight aircraft, there would also be less risk of injury to any passenger in those aircraft.
There is a problem with "getting something in place as soon as possible" because once something is in place, it will be difficult to change later. Any change to the regulations after they are in place will have to go through the same CARAC process with the same players that we are going through now. If we can't get it right this time, we have little chance of changing it later. For that reason, the proposals should be right the first time.
From the time any proposal is accepted at CARAC, there will be a minimum three month process before implementation in the CARs. That should be ample time to "refine" appropriate material rather than plugging in RPP requirements "because they're there."
Comments on the proposal:
Since the risk of accidents is less in ultralight aeroplanes than for general aviation, the risk of injury to the occupants of the ultralight is also less, whether the occupants are pilots, students, or passengers. The data does show that more experience in ultralight aeroplanes should be required for higher licensed pilots and instructors to operate ultralight aeroplanes.
Since there is not a clear risk or problem, Transport Canada cannot show the benefits of the proposed requirements to the general public (passengers) or to the pilots. Because of this, I feel that the extra requirements and associated costs, both to the ultralight pilot and to Transport for administration, for ultralight pilots to carry passengers should be minimal and should be relevant to the operation of ultralight aeroplanes.
Therefore:
PASSENGER CARRYING ENDORSEMENT - PILOT PERMIT - ULTRALIGHT AEROPLANE
(1) Prerequisite
An applicant shall qualify for or hold a Pilot Permit - Ultralight
- Aeroplane.
(The "shall qualify" is to permit the endorsement to take place during the flight training for a Pilot Permit - Ultralight Aeroplane)
(2) Fitness and Validity
An applicant shall meet the same Medical Certificate required for a
Pilot License - Glider
(A glider pilot is allowed passenger carrying with a Category 4 medical, self declared. - KL)
(3) Knowledge
An applicant shall have taken a Transport Canada approved course
of instruction based on TPxxxx (the Ultralight Ground School Syllabus)
and have passed a Transport Canada written test (to be developed
from existing tests). The test shall cover:
(a) Air Law -regulations, rules and orders, air traffic services,
practices and procedures and licensing requirements relevant to the permit;
(b) Navigation, radio aids, and applicable electronic theory;
(c) Meteorology appropriate to the permit;
(d) Aerodynamics - General Knowledge - airframes, engines and systems
relevant to ultralight aeroplanes, theory of flight, flight instruments,
flight operations and human factors.
(Rational - Ultralight pilots are already required to attend a Transport Canada approved ground school course similar in content to the RPP. A 1986 document developed jointly by TC and the ultralight community detailed an ultralight ground school course which includes ultralight specific subjects such as 2-stroke engine operation and ultralight airframe maintenance as well as the subjects listed above. We propose that the Transport Canada Ultralight syllabus be formalized and given a TP number. Since this is not new, it can be done quickly. This will formalize a standard across the country.
A side by side comparison of the ultralight syllabus and the RPP study guide shows the similarity between the knowledge requirements of the two permits. I have included this comparison as a Word document attachment, compulrp.doc The comparison show that the current ultralight knowledge requirement is already similar to that for the PPR.
Our pilots already take a test on the four knowledge areas using a Transport Canada approved pre-solo test. The test is not standardized nationally; it is approved at the regional level. Since it appears that Transport wants a national standard and wants to monitor the knowledge requirement, I propose that the current test ULTRA be combined with the current test HAGAR. (HAGAR is the test required for hang glider operations in controlled airspace.) Using these tests as a base, it should be possible to refine a test specific to ultralights during the time between CARAC acceptance and implementaion in the CARs. I maintain that most ultralight pilots can pass this test after they complete the ground school requirements for the PP-UL.- KL)
(4) Experience
An applicant shall have completed a minimum of 25 hours of flight time
aboard ultralight aeroplanes. The flight time shall include a minimum of:
(a) 15 hours dual instruction flight time, including
(b) a minimum of at least two cross country legs consisting of a minimum
of 30 minutes each, and
(c) 5 hours solo, flight time.
(5) Skill
Using the standard outlined in the Flight Test Standard -Recreational
Pilot Permit - Aeroplane (TP12475E), an applicant shall complete a check
ride in an ultralight aeroplane given by the holder of a Flight Instructor
Rating - Ultralight Aeroplane Authorized to Conduct Flight Training for
the Passenger Carrying Endorsement. Where the applicant successfully
completes the check ride, the instructor shall so endorse the applicant's
personal log.
(Using an existing standard permits rapid introduction and acceptance of the passenger carrying endorsement.) (The phrase 'flight test' was changed to 'check ride' so that the flight test requirements in CARs and the associated administrative burden and costs are not invoked -KL.)
(6) Credits
(a) The Knowledge requirement shall be deemed to have been met if
(i) the applicant has within the preceding five years passed a written
examination for a Pilot Permit or Pilot License in the aeroplane category
and
(ii) has within the preceding 12 months passed the PSTAR examination
or equivalent pre-solo examination
(This provision covers those who have started a flying course in the past but never finished the flight training)
(b) The Experience requirement may be reduced for the applicant who
is the holder of, or has held a pilot license or permit within the preceding
5 years to a minimum of 5 hours of flight time on ultralight aeroplanes
including
(i) a minimum of 2 hours of dual flight instruction on ultralight aeroplanes
and
(ii) a minimum of 2 hours of solo flight time on ultralight aeroplanes
(iii) a minimum of 20 takeoffs, full circuits and landings , including
10 as sole occupant of the ultralight aeroplane
(This experience credit is the same as now applies to the holder of a higher pilot license to obtain a PP-UL. This should help mitigate the identified risk of higher licensed pilots causing more ultralight accidents than ultralight pilots.- KL.)
(c) The Knowledge, Experience, and Skill shall be deemed to have been
met if the applicant
(i) holds a Flight Instructor Rating - Ultralight Aeroplane and
(ii) has his personal log endorsed by the holder of a Flight Instructor
- Ultralight Aeroplane Authorized to Conduct Passenger Carrying Endorsement
training.
(This allows Ultralight Instructors to carry passengers - KL)
FLIGHT INSTRUCTOR RATING - ULTRALIGHT AEROPLANE AUTHORIZATION TO CONDUCT PASSENGER CARRYING ENDORSEMENT TRAINING
Based on the statistics, the current Flight Instructor - Ultralight
Aeroplane should be Authorized to Conduct Passenger Carrying Endorsement
Training. This mirrors the glider world in which the
Flight Instructor - Glider may, as a privilege of the rating, in
CARs 410.82 (f) "certify the competency of the holder of a Pilot License
- Glider to carry passengers in a glider. " - KL
Therefore:
(1) Prerequisite
The applicant shall hold a valid Flight Instructor Rating -Ultralight
Aeroplane.
(2) Medical Fitness
An applicant shall hold a Category 3 Medical Certificate. This is satisfied
by the prerequisite.
(3) Knowledge
This is satisfied by the prerequisite.
(Rational - Currently, flight instructors for gliders are authorized to conduct flight training for passenger carrying without additional knowledge requirements.- KL)
(4) Experience
In addition to the minimum 50 hours flight time in ultralight aeroplanes
required for the Flight Instructor Rating - Ultralight Aeroplane,
the applicant shall have acquired a minimum of 10 hours flight time as
an ultralight flight instructor during the preceding 12 months.
(It is appropriate to require the instructor to have actual time in the air instructing. The rational for 10 hours is from the NPA 97-218, approved by the CARAC Part IV Technical Committee in May, 1997: reference 421.89 (2) Flight Instructor Rating -Ultralight Aeroplane - (2) Renewal (a) (i) "completed a minimum of 10 hour flight time as an ultralight aeroplane instructor during the preceding 12 months; or..." The rational for this NPA was "to make the renewal similar to the Flight Instructor - Glider" - KL)
(5) Skill
An applicant shall have his/her logbook certified by the holder of
a Flight Instructor Rating - Ultralight Aeroplane Authorized to Conduct
Passenger Carrying Endorsement Training certifying that the applicant has
demonstrated the ability to perform and instruct both normal and emergency
maneuvers appropriate to the passenger carrying endorsement.
(6) Credits
(a) The Knowledge and Experience credits for the Flight Instructor
Rating - Ultralight Aeroplane shall apply to an applicant who holds or
has held within the preceding five years, a Pilot Permit or Pilot License
in any other aeroplane category.
(b) The Knowledge requirements shall be deemed to have been met if
the applicant holds, or has held within the preceding five years
a Flight Instructor rating Aeroplane or Helicopter.
(c) The Experience requirements for the applicant who holds, or has
held within the preceding two years a Flight Instructor rating Aeroplane
shall be reduced from the 50 hours of flight time in ultralight aeroplanes
required for the Flight Instructor - Ultralight Aeroplane to:
(i) 20 hours of flight time in ultralight aeroplanes with 10 as sole
occupant and
(ii) shall successfully passed a check ride in an ultralight aeroplane
given by the holder of
an Flight Instructor rating - Ultralight Aeroplane Authorized to Conduct
Passenger Carrying Endorsement Training.
(This addresses the risk of general aviation pilots causing ultralight accidents. This requires the Class 4 and higher rated instructors to have actually flown ultralight aeroplanes before they can endorse an ultralight pilot to carry a passenger. - KL)
(7) Period of Validity
The authorization to conduct the passenger carrying endorsement is
maintained by a valid Flight Instructor Rating - Ultralight Aeroplane.
(This mirrors the Flight Instructor -Glider)
Notice: The above comments are mine and have not been endorsed by the UPAC Board of Directors.
Signed,
Kathy Lubitz
Pacific Ultralight Flying Association
102-16071 82 Avenue
Surrey, B.C. V3S 2L6
December 18, 1997
Faxed to: CARAC 613-990-1198
UPAC 519-684-7009
COPA 705-426-5613
Dear Sirs:
Since our fax dated December 2nd, 1997 in which we voiced our support of the International Challenger Owners Association (ICOA) proposal for the Ultralight Pilot Permit endorsement for carrying passengers, we have received two further proposals - one dated December 4th, 1997 from COPA and another from UPAC dated December 10th, 1997.
While there were several nuances in the COPA proposal that we liked, chiefly those elements that mirrored the ICOA version, we believe that the current UPAC proposal best meets the expectations of our membership with regard to minimizing the imposition of additional regulations and which appears to be supported by the data on comparable accident statistics cited by UPAC.
The UPAC proposal has accomplished this by:
1. leaving the Category 4 Medical, self declared, in place for the PP-UL;
2. proposing a knowledge requirement for the PP-UL based on the formalizing
the existing
Ultralight Ground School Syllabus that was developed
in 1986 and is considered more relevant
to the ultralight pilot than that for the Recreational
Pilot Permit (RPP) designed for conventional
aircraft;
3. reducing the requirements for a PP-UL having a flight instructor
rating to a simple endorsement of
his personal log by the holder of a Flight Instructor
- Ultralight Aeroplane Authorized to Conduct
Passenger Carrying Endorsement Training; and by
4. tying the experience requirement for the Flight Instructor - Ultralight
Aeroplane Authorized to
Conduct Passenger Carrying Endorsement Training
to the 10 hours of ultralight flight instructor
time in the previous 12 months already approved
by CARAC as a criteria for renewal of the
flight instructor rating rather than the arbitrary
100 hours of flight time
proposed by COPA.
Accordingly, please be advised that I wish to support the UPAC proposal cited above on behalf of the Pacific Ultralight Flying Association.
Yours truly,
Per Jeff Rochon
President
JR/gru