Over 2 years ago my friend started to build an airplane; he followed the ASTM standards so our aircraft would comply with the new letter of deviation regulation 91.319(h) which allows certain experimental light-sport airplanes to be utilized for aviation schools.
This March he applied for the letter of deviation and found out that it would not be approved due to the fact that there is no policy to manage the regulation. To date the FAA has not finalized a policy. Several months ago he learned that the policy is being created in such a way if there is already a S-LSA in the area, other applications will be automatically denied. This is not in the regulation!
He even started an aviation business to bring light sport aviation to his area thru flight school and aircraft sales. He had 5 employees making sales to support the business. He ran radio ads that generated six students in the first few weeks; but not having a LODA he had to turn the students away.
He has had to let his employees go. And if the policy isn't finalized soon, hundreds of flight schools will go bankrupt.
Having this LODA policy in place will help our country. It will create jobs from advertising, gas sales, and airplane manufacturing and maintenance. Nationally this could open a huge number of jobs.
Get involved by calling your congressman. Attached is a letter that you can copy and paste to use. Go to www.senate.gov or www.house.gov to find your representatives. Please do this, it will take less than five minutes and could make a huge difference!
To whom it may concern,
I am writing you in regards to the need for a policy regarding FAA regulation 91.319(h) and FAA Order 8900.1 Volume 3, Chapter 11, Section1, Letter of Deviation Authority (LODA) for the purpose of conducting flight training in an experimental light - sport aircraft per Part 61 Subpart J and K, and 61.56.
Early this year, this regulation was put in place to allow certain experimental light-sport aircraft to be used for flight training as long as the aircraft was built according to ASTM standards.
However, when they created the regulation, they did not create a policy by which the LODA could be managed. By March of this year, the FAA field offices had received numerous LODA requests. Most requests stayed in limbo not being approved or denied. Other requests which had been approved were rescinded. At that point the whole LODA process came to a halt. To date the FAA has not finalized a policy. I have since learned that the policy is being written to not allow a LODA if there is an existing S-LSA in the area. This is not in the regulation, and is unfair business practice. It will simply create a monopoly by larger flight schools, not allowing for small flight schools to compete.
I would like you to request that the FAA provide a policy that supports the regulation and get it done as soon as possible! In speaking with people in the EAA (Experimental Aircraft Association), I have been told that there are thousands of small flight school owners across the country waiting for a LODA. The aviation businesses and flight schools which would have made use of this regulation have been forced to close because of this situation.
Having the LODA approval process in place will help the Country. It will create jobs from advertising, fuel sales, and aircraft manufacturing and repair. Nationwide this could create 100,000 jobs in fewer than three months. With our nation facing such high unemployment, I would think the government would do everything possible to create jobs.
I greatly appreciate your willingness to investigate this situation.
Thank you,
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