We have enjoyed almost twenty years of ultralight flying with very few restrictions . The industry has thrived for the most part due to advances in engine, gear boxes, training availability and has a good base of designs that have stood the test of time.

And while I appreciate the freedom that FAR 103 offers, I would expect that aditional empty weight and fuel will also require more demonstrated training and paperwork.

And I can not think of a better way to get many of the so called fat-uls into some sort of system than the offer of not only being 'legal' but having the option of progressing in aviation without having to make what appears to be a rather large jump in paperwork and cost to meet the Sport Pilot requirements.

The 254 pound limit in FAR 103 requires absolutely nothing as far as training, but we know that most planes would require a higher weight limit. and most people these days are availing themselves of training.

I thus propose two additional levels of single seat ultralight. The administration of the training, the testing, the oral and flight testing would be administered by either Sport Instructors or present day BFIs.

I would also like to see the exemption for two place training made a permanent part of the new regulations, again, being administered by the present organization exemption holders. I fear that they will have but a small part to play in the Sport Pilot NPRM as it is presently written as EAA has taken the lead in writing, specs, limits, comments, etc.

Thus I suggest 325 empty weight level which would cover most simple MX type ultralights. The requirements for allowing this level would be to join a national organization, get their pilots license through their training system, register the ultralight and display a UL number, and maintain a logbook for the airframe/powerplant with an annual signature that an inspection has been performed.

The owner could either do the inspection himself or have someone do it for him. It would his personnal choice as to who since this has worked rather well with present ultralights. Requiring the log be kept would be good for both the owner and a future buyer.

I would offer the next weight limt of 396 to cover almost all single place planes and the additional written testing would cover the need for calcualating CG since most kits would require additional items be added during construction to get this high of a weight. CG info would be required for the max gross with and without fuel, etc similar to GA or experimental homebuilt.

This would likely be a good learning experience for the owner and provide him with needed knowledge for allowing this extra weight.

I might also suggest a separate signoff, again by the major orgs, to allow the 5 gallon limit to be exceeded. The knowledge requirements to remove the 5 gallon limit would be a test related to cross country flight, reading sectionals, etc, and also having the above CG data for the extra fuel loads. This testing would be related more to pilotage than complicated intsrument navigation.

In this manner , the beginner can get some simple traiining, and immediately fly at least locally, under his BFIs surveillance. Exceedinjg the FAR 103 limits for fuel and weight could be signed off by the BFI for a 90 day period so a separate plane, gas tank, etc would not be required for initial solo hours.

As experience and demonstrated knowledge is gained, the addtional studying/testing could be taken that would provide permanent BFI signoffs for removal of the fuel limit, and either of the additional weight classes.

I don't think ultralighters want a free ride, and many will easily pass the required tests based on years of local and cross country experience.

I would be happy to assist in writing any formal paragraphs should the above concepts be acceptable.