KenB
Active Member
Folks,
I've been noodling alot on the MOSAIC NPRM, which I'm mostly delighted to see.
As I see it, the proposed rule would be a great thing for me personally. My Piper Pacer, my Pietenpol, and my (not yet completed) RV-9 would all fit within the new rule, if adopted as proposed. My concern is about the altitude restrictions, which are being carried over from the old Sport Pilot language.
Below is draft language that I'm working on to submit to the FAA. I'd appreciate your feedback, suggestions, etc. And, of course, if you want to add your voice, I'd also appreciate your sending something similar to the FAA during the current comment period:
"My understanding is that the Mosaic NPRM maintains the current rule about flight up to 10,000 feet above mean sea level (MSL) or 2,000 feet above ground level (AGL), whichever is higher. I would strongly recommend that this restriction, as currently conceived, be reconsidered.
"For the majority of pilots that might be affected by MOSAIC this altitude restriction is likely to have no real world impact. Most pilots fly where MSL is within a couple thousand feet of sea level.
"This is not true for those of us that live in the mountain west. I live and mostly fly in Colorado, where there are 58 mountains in excess of 14 thousand feet, 638 mountains between 13 and 14 thousand feet, and countless mountainous areas above 10 thousand feet. The restriction, as currently written, requires that pilots fly a sort of nap of the earth profile when crossing over peaks in excess of 10 thousand feet as they attempt to maintain no more than 2000 AGL. Worse, between mountains, when the ground below drops more than 3k below cruise altitude, if complying with FAR 91.159, it requires descent to 8500' or 9500', depending on the heading. Such rapid altitude changes are dangerous, as density altitude combined with diminished capabilities of naturally aspirated engines reduces the ability to out-climb rising terrain of virtually all airplanes that would fit within MOSAIC. This problem is not limited to Colorado, of course. Most of the states in the western third of the country have terrain that challenges the climb capabilities of naturally aspirated aircraft. This problem will be worsened with the adoption of MOSAIC, as it will sweep many legacy Cessnas, Pipers, and other airplanes into potential compliance with Sport Pilot privileges. As currently conceived, the rule will inevitably lure some pilots into engaging in behaviors that are inherently dangerous, even though required by FARs and MOSAIC.
"I would encourage FAA prior to final passage to modify MOSAIC to incorporate the logic of many of the new parts of the rule with respect to high altitude flight, which is to require instruction and endorsements for aspects of flight that Sport Pilots would not have encountered in their initial training, such as the use of retractable gear or controllable pitch props. I would recommend that Sport Pilots intending to fly above 10 thousand feet be required to receive instruction and logbook endorsement from a CFI on high altitude flight. With such endorsement, pilots exercising Sport Pilot privileges would be permitted to fly up to 18 thousand feet without AGL restrictions. High altitude instruction should include topics such as density altitude, engine, prop, and airfoil efficiency losses at high altitude, effects and recognition of hypoxia, requirements for oxygen for pilots and passengers, and best practices for navigating mountain areas. Such instruction would enhance safety by allowing pilots exercising Sport Pilot privileges to follow accepted practices when navigating through mountainous areas of the country.
"With respect, Ken Bickers"
I've been noodling alot on the MOSAIC NPRM, which I'm mostly delighted to see.
As I see it, the proposed rule would be a great thing for me personally. My Piper Pacer, my Pietenpol, and my (not yet completed) RV-9 would all fit within the new rule, if adopted as proposed. My concern is about the altitude restrictions, which are being carried over from the old Sport Pilot language.
Below is draft language that I'm working on to submit to the FAA. I'd appreciate your feedback, suggestions, etc. And, of course, if you want to add your voice, I'd also appreciate your sending something similar to the FAA during the current comment period:
"My understanding is that the Mosaic NPRM maintains the current rule about flight up to 10,000 feet above mean sea level (MSL) or 2,000 feet above ground level (AGL), whichever is higher. I would strongly recommend that this restriction, as currently conceived, be reconsidered.
"For the majority of pilots that might be affected by MOSAIC this altitude restriction is likely to have no real world impact. Most pilots fly where MSL is within a couple thousand feet of sea level.
"This is not true for those of us that live in the mountain west. I live and mostly fly in Colorado, where there are 58 mountains in excess of 14 thousand feet, 638 mountains between 13 and 14 thousand feet, and countless mountainous areas above 10 thousand feet. The restriction, as currently written, requires that pilots fly a sort of nap of the earth profile when crossing over peaks in excess of 10 thousand feet as they attempt to maintain no more than 2000 AGL. Worse, between mountains, when the ground below drops more than 3k below cruise altitude, if complying with FAR 91.159, it requires descent to 8500' or 9500', depending on the heading. Such rapid altitude changes are dangerous, as density altitude combined with diminished capabilities of naturally aspirated engines reduces the ability to out-climb rising terrain of virtually all airplanes that would fit within MOSAIC. This problem is not limited to Colorado, of course. Most of the states in the western third of the country have terrain that challenges the climb capabilities of naturally aspirated aircraft. This problem will be worsened with the adoption of MOSAIC, as it will sweep many legacy Cessnas, Pipers, and other airplanes into potential compliance with Sport Pilot privileges. As currently conceived, the rule will inevitably lure some pilots into engaging in behaviors that are inherently dangerous, even though required by FARs and MOSAIC.
"I would encourage FAA prior to final passage to modify MOSAIC to incorporate the logic of many of the new parts of the rule with respect to high altitude flight, which is to require instruction and endorsements for aspects of flight that Sport Pilots would not have encountered in their initial training, such as the use of retractable gear or controllable pitch props. I would recommend that Sport Pilots intending to fly above 10 thousand feet be required to receive instruction and logbook endorsement from a CFI on high altitude flight. With such endorsement, pilots exercising Sport Pilot privileges would be permitted to fly up to 18 thousand feet without AGL restrictions. High altitude instruction should include topics such as density altitude, engine, prop, and airfoil efficiency losses at high altitude, effects and recognition of hypoxia, requirements for oxygen for pilots and passengers, and best practices for navigating mountain areas. Such instruction would enhance safety by allowing pilots exercising Sport Pilot privileges to follow accepted practices when navigating through mountainous areas of the country.
"With respect, Ken Bickers"
