Several Sport Pilot Questions

[poadeleted20]

A doctor not say "It's Ok" is not synonimous with the doctor saying "It's Not OK".

I don't see it that way. If the doctor won't agree that he's safe for solo, why should I, who knows a lot less than the doctor, let him solo?

If the Doctor doesn't know enough to stop it, how do you?

I don't know enough to approve it. Remember, the LS Student's knowledge about what constitutes safe flying is entirely from me. If he's wrong, I'm wrong.

And thats' where you get yourself into multiple binds, because the first time you do that, you take on the roll of Medical Expert. Now, three students down the line, the one you don't refuse crashes and burns and medical considerations are found, you are being sued for 10 times your insurance policy value and the plaintiffs attorney turns to you and says "Well, if you're not a medical expert, then why did you refuse to train Mr. XXX and Mr. YYY back in.... due to their medical condition which no doctor disqualified them for either?"

Since I won't solo an LS Student who has a medical-certificate-disqualifying condition unless his doc say's he's OK to fly LS, I don't see how this could arise.

You are buying problems you don't want. If a doctor wants to disqualify them, let the doctor disqualify them. A lack of an approval certificate is not a disqualification certificate. Don't take on rolls that aren't in your pervue.

It may not be a disqualification certificate, but if the doc isn't willing to say he's medically OK to solo LS, on what basis can I say he is?

As I said originally, we CFI's have for 100 years been relying on AME's to tell us who is/is not medically unfit to fly -- no medical, no solo (at least in the airplane world -- and I suspect that the Big 15 are considered disqualifying for balloon and glider, too). Now, with LSA, we have no AME on whom to rely, just the individual and his doctor. Since the FAS has already said in writing what the standard is (that the individual and his/her physician decide that the otherwise-disqualifying condition "would (not) interfere with the safe performance of sport piloting duties,"), if the person's own doc won't agree to say that, I do not see the FAS's standard as being met. In that case, as I see it, for me to permit that person to solo would be the same as allowing someone with no medical to solo a non-LS airplane.

Perhaps I'm wrong, and I'll lose out on the opportunity to train some folks, but until the FAS changes his statement and says it's OK for me to accept "OK to operate a motor vehicle" as sufficient for someone to fly Light Sport (or the FAA Chief Counsel weighs in with a legal interpretation of 61.53(b) to that effect), I ain't stickin' my neck out.

 

[poadeleted20]

Do standard certification requirements have any bearing on LSA aircraft? No.

Correct.

Is the FAA involved when you want to modify your LSA down the road? No.

Not directly, but there are certification standards you must meet. See 14 CFR 21.190(c).

Does the FAA dictate what equipment you can put in your LSA? No.

They don't "dictate" what we can put in non-LSA aircraft, but they do have standards we must meet, and I can't find anything in 21.190 that says you can make any modification you want to an LSA. In fact, Part 43 applies (within certain limits -- see 14 CFR 43.1(d)) to LSA's.

Why would standard medical requirements have any relation to a SP?

They don't. The Federal Air Surgeon has promulgated the medical standards for LS pilots, and has stated on his web site that as regards conditions which would disqualify one from a medical certificate, "You should consult your private physician to determine whether you have a medical deficiency that would interfere with the safe performance of sport piloting duties." [emphasis added] If the physician merely says the person is "OK to operate a motor vehicle," is that the same thing? I don't know.

If a CFI knowingly sends a solo student off in a plane with a non-certified engine, non-certified instruments and with major modifications done without any input from the FAA, is the CFI liable because none of the standard certification or airworthiness requirements have been met?

I believe that CFI would be at risk of an FAA certification action. The aircraft's airworthiness certificate is not valid unless it conforms to its type certification design (or in the case of an LSA, the manufacturer's statement of compliance (again, see 14 CFR 21.190(c)). If it no longer meets those standards, then it is unairworthy unless its modifications have been performed in accordance with Part 43 (which does apply to LSA's), and I do believe the FAA would eat for breakfast a CFI who allowed a student to solo an unairworthy aircraft.

 

[bbchien]

Caution! Long and detailed! No apology given. It can't be addressed in any lesser of a post....

Now, with LSA, we have no AME on whom to rely, just the individual and his doctor. Since the FAS has already said in writing what the standard is (that the individual and his/her physician decide that the otherwise-disqualifying condition "would (not) interfere with the safe performance of sport piloting duties,"), if the person's own doc won't agree to say that, I do not see the FAS's standard as being met. In that case, as I see it, for me to permit that person to solo would be the same as allowing someone with no medical to solo a non-LS airplane.

Attaboy, Ron! (feels strange saying that to an O3). Uncharted waters indeed.

Bottom line, is that the individual CFI has to feel comfortable with the condition of the student. The CFI himself is held to a somewhat higher standard as to what it grounding- he is not the "everyman pilot" he is a knowledgable pilot, and is expected to have greater knowledge of part 67 because after all he's had to read it (god I hope so), but he is still no doc.

The strange circumstance is that I being assumedly quite knowledgeable, can't write the FAS statement even if I wanted to. After the accident, I would be hounded by, "He had a condition that you knew was disqualifying under part 67, and you considered him fit for Sport Pilot duties??!!" Whereas, I might be able to mount a scientific defense in some instances (lower airspeeds, altitudes...COPD would be a somewhat defensible one, but COPD is currently a part 67 Third Class SPECIAL ISSUANCE), the cost of such defence would be just prohibitive.

Now consider the generalist, nonpilot family doc. He writes a letter saying, "OK for performance of sport pilot duties". There's a crash. Now he's getting grilled in this manner: "What are you credentials in aviaiton medicine for that statement?" "Are you even a pilot?" "Do you even have ONE semester in Aviation medicine?" "Are you an AME?" So he looks like a horses' patoot and the insuror pays out.

That is why, multiple flight schools teaching LSA students have elected for the "OK to operate a motor vehicle" statement. This is a statement that just about every doc can make, unchallenged- we do it for State DOTs all the time. Since there is no medical standard other than the 50 state drivers' license, which is the medical standard, "OK to operate a motor vehicle" is the doc stating he meets that standard.

The Federal Air surgeon is a qualified C141 captain. Do you really think he's going to say anything less than "OK for performance of sport pilot duties"?. He's already much more knowledgable than the average student, so he has to say that. He's essentially the country's TOP AME.

Now to the reg itself:

61.53(a): Operations that require a medical certificate. Except as provided for in paragraph (c) of this section, a person who holds a current medical certificate issued under part 67 of this chapter shall not act as pilot in command, or in any other capacity as a required pilot flight crewmember, while that person (1) Knows or has reason to know of any medical condition that would make the person unable to meet the requirements for the medical certificate necessary for the pilot operation; or (2) Is taking medication for a medical condition that results in the person being unable to meet he requirements for the medical certificate necessary for the pilot operation.

Editor: where do you get the information for 61.53(a)2, the requirements? You get it from part 67, which lists the disqualifying conditions. You are held to that list, standard for certificate requiring operations. Of course CFIs, AMEs and PVT ASELs have differing detail understandings of part 67, but the CFI is held to having READ IT, and fifteen conditions are specified.

61.53(b) Operations that do not require a medical certificate. For operations provided for in 61.23(b)of this part (ed. which is sport pilot), a person shall not act as pilot in command or in any other capacity as a required pilot flight crewmemeber, while that person knows or has reason to know of any medical condition that would make the person unable to operate the aircraft in a safe manner.

(ed. Here there is ZERO statement of requirement for the medical certificate because there is no medical certificate involved. This is clearly a different, lower standard)

(c) Operations require a medical certificate or a valid US driver's license: For operations provided for in 61.23(c) a person must meet the provision of--
(1) Paragraph (a) of this section if that person holds a valid medical certificate issued uner part 67 of this chapter and does not hold a current and valid US Driver's license;
(2) Paragraph (b) of this section if that person holds a current and valid State Driver's license.

So clearly there is no applicability of the fifteen conditions stated in part 67, to the SP student. But there will be great discomforture to the CFI who has read part 67 (assumedly) and the student comes up with one of the conditions. That's because the CFI knows better.

Say he's got coronary disease, had an SI, good exercise tolerance but medicare just won't pay for a treadmill every year. Can the CFI evaluate that? Does he have a shadow of a chance of figuring out that Coreg is okay and Nitroglycerin is not?

That is why you have to let the FAMILY DOC write the letter, and he's NOT going to be writing OK for sport pilot duties, the guy has NO experience nor credentials to do so!

Bottom line: The airman has to have the motor vehicle letter AND the CFI has got to be comfortable with his level of knowledge of the Airman's health situation. It's probably better that he limits it to the fifteen part 67 conditions. You have to have BOTH or you have NO TRAINING.


Since there is no medical branch looking in on you, you'll get pretty uncomfortable with the decisionmaking of the guy with PTSD, and you'll know something is odd and you WON'T sign him off. This is where the CFI is effectively the "Operational Airman Evaluation", and like some many FSDO rides for monocularity, untreated undiagnosed ADD, if the airman can convince the CFI he can do the job, and subsequently the DPE-LSA Examiner, he's good to go.

Ron's sense is correct. They deleted the wing flight surgeon, rather than create a fourth class medical. It was one of many decisions they could have made. "OK to operate a motor vehicle" is all you're going to get.

 

[N621j]

Correct.
Not directly, but there are certification standards you must meet. See 14 CFR 21.190(c).

My point was, if you look at 21.190(c), the responsibility for for setting, changing, reviewing the standards is given to the manufacturers, not the FAA.

They don't "dictate" what we can put in non-LSA aircraft, but they do have standards we must meet, and I can't find anything in 21.190 that says you can make any modification you want to an LSA. In fact, Part 43 applies (within certain limits -- see 14 CFR 43.1(d)) to LSA's.

You can't make any modification you want, however the definition of what constitutes a major repair or alteration does not apply to an LSA, there is no such thing as an STC, and no 337 requirement. Approval for changes or alterations come directly from the manufacturer. Approval for which engine and equipment can be installed comes from the manufacturer, and requires no certification except in a few specific areas (i.e.- transponder). Again, the responsibility shifts away from the FAA to the LSA manufacturer.

They don't. The Federal Air Surgeon has promulgated the medical standards for LS pilots, and has stated on his web site that as regards conditions which would disqualify one from a medical certificate, "You should consult your private physician to determine whether you have a medical deficiency that would interfere with the safe performance of sport piloting duties." [emphasis added] If the physician merely says the person is "OK to operate a motor vehicle," is that the same thing? I don't know.

I believe that CFI would be at risk of an FAA certification action. The aircraft's airworthiness certificate is not valid unless it conforms to its type certification design (or in the case of an LSA, the manufacturer's statement of compliance (again, see 14 CFR 21.190(c)). If it no longer meets those standards, then it is unairworthy unless its modifications have been performed in accordance with Part 43 (which does apply to LSA's), and I do believe the FAA would eat for breakfast a CFI who allowed a student to solo an unairworthy aircraft.

That's correct, however my point was that the engine and equipment does not need to be certified, it needs approval from the manufacturer. In both the areas of airworthiness and medical certification for LSA and SP the FAA has made a major change from the traditional certification methods. Yes there are standards, but many of the standards come from the manufacturers, the pilot, and his personnal physician. Just as you can't say that an LSA is unairworthy because it does not have a traditionally certified engine or instrumentation, you cannot use the traditional medical requirements as a standard for determining whether you are fit to fly. It does put the physician and the flight instructor in a difficult position. Most physicians will be reluctant to risk the liability of specifically approving someone to go fly an airplane without any specific training in aeromedicine. However, physicians routinely have to make a determination of whether a person can safely operate a motor vehicle, so most are more comfortable with that determination. I believe the question to the air surgeon was essentially if a person has a medical condition, how do you determine if he is fit to fly. I don't interpret his answer to mean that all SP candidates must have a physical examination and determine with their physician that they fit to fly. That is a major distinction. There is no requirement for a SP to visit a doctor to be eligible for SP, only for him to have a drivers license. Are you going to require every potential student to have a physical exam by a physician prior to giving flight instruction? That is your perogative, as it is your ticket and assets on the line, but I think that goes beyond the FAA requirements.

 

[bbchien]

Actually, since there is no medical requirment, the Federal Air Surgeon's statement is actually irrelevant and somewhat constraining at the same time. He is correct that it is between the SP student and his personal physician. Whether it is for: "ALL the duties of a sport pilot" or "OK to operate a motor vehicle" is completely irrelevant.

However, because he said it, there is an apparent burden placed on the AME who is now operating OUTSIDE of the protection of federal rules.

"OK to operate a motor vehicle" is all you're going to get. Sigh. If a particular CFI is not comfortable with the pilot- then he's done, and has to find another CFI.

In the situation of an owner-LSA pilot, I would make my endorsement very, very short- 1 month's duration, for example, were there any, even low level doubt.

 

[N621j]

Bruce pretty much hit on the point I was trying to make in a rather roundabout way. Those looking for guidance from the FAA in the traditional sense concerning many LSA and SP issues are not going to get it; the FAA has taken themselves out of the loop.

 

[poadeleted20]

...and if the FAA doesn't want the responsibility, why should I accept it personally? Especially since the FAA can hold me responsible for my decision based on a standard that Bruce indicates no doctor will sign up to.

BTW, while it isn't an FAA Chief Counsel opinion, I consider the FAS's FAQ on the subject to be at least arguably a reliable statment of the intent of 14 CFR 61.53(b). Thus, absent that "would (not) interfere with the safe performance of sport piloting duties" statement, one is operating outside the only guidance the FAA has provided on the subject, and thus leaving oneself open to future second-guessing (if not certificate action) by the FAA and a court. Imagine the conversation during an FAA visit after your LS trainee is ramp-checked (or worse, carted off from his plane in an EMT van)...

Inspector: Mr. Levy, I see from the records that your trainee had a heart attack last year, but you signed him off for solo anyway. Did you teach him about what medical conditions might affect his ability to fly?

Mr. Levy: Yes, sir, I did. I showed him 14 CFR 61.53(b) and the list of 15 conditions the FAS considers disqualifying for all classes of medical, as well as the FAS's FAQ's on medical issues for LS pilots. He showed me a letter he got from his doctor saying that despite his heart attack last year, his condition was under control, and he was OK to operate a motor vehicle.

Inspector: Since you're aware of the FAS's FAQ's, you must know that the FAS said the LS pilot's medical condition must not "interfere with the safe performance of sport piloting duties." Your trainee told me that you taught him that if his doctor didn't feel qualified to say that his condition "would [not] interfere with the safe performance of sport piloting duties," but would say he was OK to drive, that would be enough for flying light sport. With your nearly 40 years of aviation experience, you must know that piloting is significantly more demanding than driving, and provides no opportunity to pull over and stop if you have an attack of some kind. Given the FAS's published statements on this subject, on what basis did you tell your trainee that being "OK to drive" was good enough to fly a light sport plane?

Mr. Levy: Ummm...
​

That is the conversation I wish to avoid until I have a much better answer than "Ummm..."

 

[Henning]

So basically, you're of the opinion that SP should not exist (and I don't disagree really) since the main reason it is being used (and the reason it was pressed for) if to evade the necessity of a medical by those who can't get one.

BTW, My answer would be "Well, y'all didn't want to make the guy get a medical, why the hell you trying to pass the buck on me. Straighten your own crap out. If you would have done your jobs right and written proper regulation, we wouldn't be here."

The best defense is a good offense.

 

[flyingcheesehead]

Inspector: Since you're aware of the FAS's FAQ's

Oh come on. It's a FAQ file, not a regulation. While CFI's should be held accountable to know the regs inside and out, a FAQ file is only a FAQ file and is one person's non-authoritative opinion on what the regs mean.

I like Henning's answer.

Ron, in your opinion, given what Bruce has said, why does Sport Pilot even exist? Do you think Sport Pilot is a good thing and can increase the pilot ranks, or are you being exclusionary? I sure hope someone who is interested in flying as a Sport Pilot does not come across you as their first contact with a CFI. These kinds of attitudes are harmful to GA.

 

[poadeleted20]

If you think the FAA approved the LS proposal in order to allow pilots who can't pass a medical or obtain a special issuance to fly, you haven't been talking to the folks in the FAA's LS program office (and I did talk with them during the LS proposal period). Others may have had that on their agenda, but as far as the FAA is concerned, the purpose was singlefold -- to reduce the cost of flying for fun. Period. Operate on any other assumption at your own risk.

 

[bbchien]

If you think the FAA approved the LS proposal in order to allow pilots who can't pass a medical or obtain a special issuance to fly, you haven't been talking to the folks in the FAA's LS program office (and I did talk with them during the LS proposal period). Others may have had that on their agenda, but as far as the FAA is concerned, the purpose was singlefold -- to reduce the cost of flying for fun. Period. Operate on any other assumption at your own risk.

NOOOOooooooo!. The cost of flying the >256 lb. super trikes has gone up significantly under SP. Sport Pilot exists to bring an estimated 20,000 more airmen and airframes under regulation, a bureaucratic imperative. But it also exists to make SP aircraft insurable. It was essentially uninsurable before. FAA Charter: Promote and regulate = make insureable.

Ron also has hit it on the head. The CFI must be comfortable with the student. So, if his health gives the CFI the willies, he runs the other way as in: "INCOMING!" That is how the unregulated market works.

SP is a nightmare for me because I will get held to far above the "motor vehicle" statement. Now I can argue that SP is no more demanding than driving a car- after all Federal policy only requires a drivers' license, and Ron's student has a drivers' license. So Mr. Federal Inspector, go home. There will be no regulatory problem. This is medically unregulated and we therefore accept heart attacks.

The problem for Ron is the estate's attorney: Yes, the man had a drivers' license. But what reasonable care should a veteran airman-CFI take to insure the safety of his student is at stake? Weren't you, Mr. Levy, "Careless and reckless?" That is an unwritten book. I would then engage a panel of LSA instructors and ask what their standard practice is. I would refer the defense to the several flight schools that require the "OK to operate a motor vehicle" statement. That would do it. However I would rue the $100,000 defense that I just narrated.

And that is how unregulated markets work.

 

[poadeleted20]

Bruce is correct about one unstated purpose the FAA had for the LS regulations, which was to make explicitly illegal the operation of the over-the-limit "ultralights" which were bigger/faster/more powerful than Part 103 actually permitted, but which the FAA did not have the resources to deal with. However, the FAA's sole stated purpose for LS was to make legal flying for fun cheaper, and that doesn't change my statement above that they had no intent to allow pilots medically disqualified from traditional flying to stay in the air.

As for the issue of defending myself, I don't see how applying more stringent criteria than most LS operators for soloing folks in LS aircraft could create liability for me. OTOH, given the case that broke the old Piper Aircraft's back, I cannot see how simply saying I was operating according to the accepted standards of the day would protect me. A jury is indeed entitled to determine that the "accepted standards" do not meet the test for "reasonable care" (unless you're the government or its employee, protected by the Federal Tort Claims Act), and that having followed them does not protect me from liability.

 

[bbchien]

A jury is indeed entitled to determine that the "accepted standards" do not meet the test for "reasonable care" (unless you're the government or its employee, protected by the Federal Tort Claims Act), and that having followed them does not protect me from liability.

And hey no kidding that's at YOUR expense. Personally. So you have the RIGHT to just say, "Hey, no thanks. Thanks for thinking of me, but I'm pretty busy".

that doesn't change my statement above that they had no intent to allow pilots medically disqualified from traditional flying to stay in the air.

A plaintiff's attorney would simply respond, "well their withdrawal of any meaningful supervision speaks otherwise". And that gets a big "sigh" from me. Amazing how our government gets to play both ways, leaving us hanging.....I sent the Federal Air Surgeon a nice email about his "medical condition will not interfere with sport pilot duties" statement and got.....ZERO response. I think his staff screened it out.

 

[N621j]

I understand Ron's point, and the difficult position the SP rule puts he and other instructors in. However, if you go out and make up your own standards, where does it end? How often will you require a physicians letter? Without authorization from the pilot candidate, as given on the medical certificate application, how do we suppose the FAA will legally obtain medical information about the pilot? What real value is a letter from a physician anyway, since as there is no medical required, there is no standard for what constitutes an adequate evaluation of the pilots medical status to fly, no specific standard for the physician to have any aeromedical knowledge, and no statutory requirement for the pilot candidate to be truthful to the physician. Stick to the written standards. Do the ground training concerning aeromedicine, and then ask the pilot if he has any condition which he believes may effect his ability to safely carry out the duties of a sport pilot. If he says no, and he looks OK to you, you go and fly, or you refer him to a CFI willing to train him. If he says yes, you ask him to consult his physician. As loose as that may seem, that is the standard. It works for gliders, why don't we think it will work for SP?

 

[bbchien]

The letter is becoming standard of practice. This is how it is in an unregulated environment. No federal standard? You look to industry standards.

That's how it is.

 

[poadeleted20]

However, if you go out and make up your own standards, where does it end?

I have no idea, which is exactly why I have adopted the FAS's written standard (pilot's physician's agreement that the pilot has no condition that "would interfere with the safe performance of sport piloting duties") as my own. OTOH, Bruce suggests that "OK to operate a motor vehicle" is becoming a de facto industry standard. I will wait until that looser standard is legally tested before adopting it over the FAS's published one.

 

[bbchien]

I have no idea, which is exactly why I have adopted the FAS's written standard (pilot's physician's agreement that the pilot has no condition that "would interfere with the safe performance of sport piloting duties") as my own. OTOH, Bruce suggests that "OK to operate a motor vehicle" is becoming a de facto industry standard. I will wait until that looser standard is legally tested before adopting it over the FAS's published one.

Hey no kidding.

It's a freaking minefield.

 

[Henning]

If you think the FAA approved the LS proposal in order to allow pilots who can't pass a medical or obtain a special issuance to fly, you haven't been talking to the folks in the FAA's LS program office (and I did talk with them during the LS proposal period). Others may have had that on their agenda, but as far as the FAA is concerned, the purpose was singlefold -- to reduce the cost of flying for fun. Period. Operate on any other assumption at your own risk.

Incorrect. The sole purpose of SP was to bring the maverick operators of the 2 seat "ultralights" like the Eipper MXII and GT500 under a legal fold. They left off the medical requirements because with them, they wouldn't get the result they wanted, people getting controlled training before taking up passengers.

 

[michael Killacky]

Wow! I really appreciate all the response and communication. I e-mailed my instructor with all the pertinent information on my friend. I also directed him to this site and I'm sure he'll learn as much as I did. I doubt that he'll be comfortable training my buddy, but you never know. Once again, i really appreciate all the knowledge!! I also appreciate the fact that this didn't turn into one of "those" threads that is so common elsewhwere. I'll keep y'all updated.

Mike

 

[Henning]

Wow! I really appreciate all the response and communication. I e-mailed my instructor with all the pertinent information on my friend. I also directed him to this site and I'm sure he'll learn as much as I did. I doubt that he'll be comfortable training my buddy, but you never know. Once again, i really appreciate all the knowledge!! I also appreciate the fact that this didn't turn into one of "those" threads that is so common elsewhwere. I'll keep y'all updated.

Mike

<sigh> This is what is going to make SP a failure. Here's the conversation at the Ultralight field as the Fed walks up the 2 seater: "Hello, could I see your airman's certificate please." "I don't have one, this was a training flight conducted under Pt 103" "I have trouble believing that your 9 year old passenger was your student, you have to be under SP regulations to fly with passengers" "Well, I tried to get a SP rating, but I couldn't find an instructor who would take me because I'm an insulin using diabetic." "But there isn't any medical required for SP" "Tell him that".....

 

[michael Killacky]

Henning, I agree with you to an extent, and that's the problem. I'm willing to play any game as long as I know the rules. In this case, even the AOPA doesn't know what may happen in the event of an incident. Can I assume that if you were the CFI in question that you would go ahead and train my friend? If so, then that's admirable. It seems to me that this situation needs a test case. I can certainly understand the reluctance on an instructor's part. It's awful hard to gamble your life savings on someone else and a completely untested situation. Bruce said it best when he said the CFI HAS to be comfortable with the student and the situation. For the record, the student in question shows absolutely no signs of any type of mental illness. I've worked in prisons 23 years and, although I'm no expert, I've certainly seen my share of people with mental illness in almost every degree. Like I said, I'll leave it up to my CFI, he spent a lifetime earning money, It's up to him how he wants to gamble with it.

Mike

 

[Henning]

Henning, I agree with you to an extent, and that's the problem. I'm willing to play any game as long as I know the rules. In this case, even the AOPA doesn't know what may happen in the event of an incident. Can I assume that if you were the CFI in question that you would go ahead and train my friend? If so, then that's admirable. It seems to me that this situation needs a test case. I can certainly understand the reluctance on an instructor's part. It's awful hard to gamble your life savings on someone else and a completely untested situation. Bruce said it best when he said the CFI HAS to be comfortable with the student and the situation. For the record, the student in question shows absolutely no signs of any type of mental illness. I've worked in prisons 23 years and, although I'm no expert, I've certainly seen my share of people with mental illness in almost every degree. Like I said, I'll leave it up to my CFI, he spent a lifetime earning money, It's up to him how he wants to gamble with it.

Mike

You bet I would. If the feds don't want to regulate it directly, I'm not doing what they don't want to do by proxy. If you don't make requirements clear, you can't expect clear results. Wouldn't be the first time going toe to toe with a Fed, but I've always been there with the USCG, never the FAA. Every time I've dealt with them, it was a simple and polite conversation.