(USA) 2010 Program Letters (have FAA requirements changed?)

[Tuno]

I recently submitted my 2010 Program Letter to my local FSDO, and he
replied with "In reviewing your program letter it was determined that
it needs to be revised", followed by excerpts from 8130.2F 11/5/2004
(page 166). (Alas he did not get specific wrt the needed revisions.)

All I did was take my 2009 program letter and revise it with my 2010
schedule, but with more detail, including place names, locations, and
dates. (I have, of course, requested additional guidance.)

Has anyone else experienced stricter program letter requirements from
their FSDO?

ted/2NO

[Frank Whiteley]

On Feb 4, 8:51*am, Tuno > wrote:
> I recently submitted my 2010 Program Letter to my local FSDO, and he
> replied with "In reviewing your program letter it was determined that
> it needs to be revised", followed by excerpts from 8130.2F 11/5/2004
> (page 166). (Alas he did not get specific wrt the needed revisions.)
>
> All I did was take my 2009 program letter and revise it with my 2010
> schedule, but with more detail, including place names, locations, and
> dates. (I have, of course, requested additional guidance.)
>
> Has anyone else experienced stricter program letter requirements from
> their FSDO?
>
> ted/2NO

When I brought my glider into this region, the DAR provided me with a
Form letter he said was used by Denver FSDO. I've been completing one
annually. However, I know other pilots that are submitting other
formats.
http://www.coloradosoaring.org/docs/program_letter_den_fsdo.pdf

Frank Whiteley

[Renny[_2_]]

On Feb 4, 8:51*am, Tuno > wrote:
> I recently submitted my 2010 Program Letter to my local FSDO, and he
> replied with "In reviewing your program letter it was determined that
> it needs to be revised", followed by excerpts from 8130.2F 11/5/2004
> (page 166). (Alas he did not get specific wrt the needed revisions.)
>
> All I did was take my 2009 program letter and revise it with my 2010
> schedule, but with more detail, including place names, locations, and
> dates. (I have, of course, requested additional guidance.)
>
> Has anyone else experienced stricter program letter requirements from
> their FSDO?
>
> ted/2NO

Ted,
Here the URL for some info on this subject from our May 2009
"Towlines" newsletter that might be helpful! Please see page 2...

http://www.abqsoaring.org/news/Towlines_09_05.pdf

Thanks - Renny
Albuquerque Soaring Club

[Chuck]

Hi Ted,
Something is going on. I have submitted program letters to the
Nashville FSDO for 8 years running without hearing a word. This
January, within minutes of faxing it I got a call back from a guy at
the FSDO saying he had reviewed the letter and it needed changes.

This guy was very specific. He wanted all references to flying at
'sanctioned events' either removed or the specific dates of the
event(s) added.

I removed the offending wording and refaxed it. No more call backs.
Hope that ends it.

Regards,
Chuck

[kirk.stant]

What a waste of time (ours and the FAAs) and money. I'm sure glad my
glider is old enough to not need an annual program letter!

Wonder if there is any chance the SSA could convince the FAA that
eliminating this bull**** (along with the external number plate
exemption requirement) would be a worthwhile contribution to reducing
the deficit and national debt.

Quick, somebody text Obama!

Kirk
66

[zulu]

Ted et al

Your FSDO dude is a bit behind the times as the most current FAA order
is 8130.2F Change 5 dated 01/15/2010. Check out para. 161 in order to
get started.
I've been told by our local FSDO that older gliders can no longer use
their old "one time" program letter and that the operations
limitations need to reflect the airport from which the glider is flown
and that a yearly program letter must be submitted.
HOWEVER, the local feds have not as yet quoted me book, chaper and
verse of the reg/order that supports their statement. I'm still
working on that but I suspect it can be found in the above mentioned
order.

Zulu

[kirk.stant]

On Feb 4, 1:30*pm, zulu > wrote:
> Ted et al
>
> Your FSDO dude is a bit behind the times as the most current FAA order
> is 8130.2F Change 5 dated 01/15/2010. *Check out para. 161 in order to
> get started.
> I've been told by our local FSDO that older gliders can no longer use
> their old "one time" program letter and that the operations
> limitations need to reflect the airport from which the glider is flown
> and that a yearly program letter must be submitted.
> HOWEVER, the local feds have not as yet quoted me book, chaper and
> verse of the reg/order that supports their statement. *I'm still
> working on that but I suspect it can be found in the above mentioned
> order.
>
> Zulu

Yeah, I can see that coming!

Maybe time to put bogus N numbers on the glider - different on each
side?

But more seriously, has anyone out there been checked by the FAA to
see if they are complying with their program letter? I can just see a
ramp check at a big Sports Class contest!

And what is the penalty? "You can't fly it here." "OK, where's the
Fax machine?".

Speaking of Faxing - what's with that? Can't the FAA handle an email
attachement of a Word doc or a PDF file?

Sheesh....

Kirk

[kirk.stant]

A little more seriously, looking at 8130.2F (change 4), Section 10,
para e, it states:

Effectivity. Aircraft that received original airworthiness
certification before July 9, 1993, are NOT affected by this order
unless the original airworthiness certification purpose changes, for
example, from R&D to exhibition. Those aircraft, except for purpose
changes, will not be affected until the FAA works with the public to
determine the best strategy to certificate all experimental exhibition
and/or air racing aircraft in accordance with the new policy. The
policy established in this order will not be used in these cases
unless specifically requested by the applicant.

So it looks like older gliders should be safe. For now. Maybe....

See: http://www.faa.gov/documentLibrary/media/Order/8130.2F%20Ch%204.pdf,
page 166.

Kirk
"Fingers crossed"
66

[T8]

On Feb 4, 2:46*pm, "kirk.stant" > wrote:
> A little more seriously, looking at 8130.2F (change 4), Section 10,
> para e, it states:
>
> Effectivity. Aircraft that received original airworthiness
> certification before July 9, 1993, are NOT affected by this order
> unless the original airworthiness certification purpose changes, for
> example, from R&D to exhibition. Those aircraft, except for purpose
> changes, will not be affected until the FAA works with the public to
> determine the best strategy to certificate all experimental exhibition
> and/or air racing aircraft in accordance with the new policy. The
> policy established in this order will not be used in these cases
> unless specifically requested by the applicant.
>
> So it looks like older gliders should be safe. *For now. *Maybe....
>
> See: *http://www.faa.gov/documentLibrary/media/Order/8130.2F%20Ch%204.pdf,
> page 166.
>
> Kirk
> "Fingers crossed"
> 66

Well, if the FAA really does intend to "work with the public" on a new
policy, perhaps that's the SSA's opportunity to work out a sensible
policy for all experimental sailplanes. Preferably a one time letter
that places no geographic restrictions. Would that common sense
prevail for once....

-Evan Ludeman / T8

[Tuno]

I just got off the phone with my FSDO.

I made the mistake of stating on my program letter that, in addition
to the specific contest-oriented dates, places & locations already on
the letter, I would also conduct flights "for my own enjoyment".

He pointed out to me that flights "for my own enjoyment" are not
authorized by my aircraft limitations. Only actual racing, and
proficiency flights in preparation thereof, are permitted.

Well, I sit corrected! No more fun flights in my glider. Serious ****
only!

(Mr M, if you troll this web page, please understand I don't blame
this on you -- I know you're just following the rules. But the
situation is, well, laughable. My letter will be revised and
resubmitted with unseen winks and nudges.)

ted/2NO

[Renny[_2_]]

On Feb 4, 4:15*pm, Tuno > wrote:
> I just got off the phone with my FSDO.
>
> I made the mistake of stating on my program letter that, in addition
> to the specific contest-oriented dates, places & locations already on
> the letter, I would also conduct flights "for my own enjoyment".
>
> He pointed out to me that flights "for my own enjoyment" are not
> authorized by my aircraft limitations. Only actual racing, and
> proficiency flights in preparation thereof, are permitted.
>
> Well, I sit corrected! No more fun flights in my glider. Serious ****
> only!
>
> (Mr M, if you troll this web page, please understand I don't blame
> this on you -- I know you're just following the rules. But the
> situation is, well, laughable. My letter will be revised and
> resubmitted with unseen winks and nudges.)
>
> ted/2NO

Ted,
"Enjoyment" is totally unauthorized! You should have known better. In
fact, you are not even allowed to smile during your "racing" and
"proficiency" flights. Now, go forth and fly, get ready for the
contest season, but remember.....DO NOT enjoy it! ;-)
Renny

[T8]

On Feb 4, 6:15*pm, Tuno > wrote:
> I just got off the phone with my FSDO.
[...]

> Well, I sit corrected! No more fun flights in my glider. Serious ****
> only!

Some truths, we hold to be self-evident :-).

-T8

[V1]

>
> Speaking of Faxing - what's with that? Can't the FAA handle an email
> attachement of a Word doc or a PDF file?
>
> Sheesh....
>
> Kirk

A inquiry to your friendly FSDO might be in order. Electronic is
easier for both parties.

The Houston (TX) FDSO accepted my program letter (and other's)
electronically this year. Understandably, they want a signature, so a
plain Word file is generally not going to cut it. I printed the
letter, signed it, scanned it to a pdf, and submitted.

Based on a recommendation I saw some months ago (in Soaring mag or
ras, I don't recall) to ask for receipt confirmation, I asked for a
return email stating they received it, which they did. I realize
that's not legally definative, but it's an easy step to at least
confirm they read it and felt it was acceptable.

While the whole program letter idea for sailplanes does seem a bit
pointless, I did feel that our local FDSO was trying to make the best
of the existing requirements and very willing to work with pilots.

- Frank

[Frank Whiteley]

On Feb 4, 4:15*pm, Tuno > wrote:
> I just got off the phone with my FSDO.
>
> I made the mistake of stating on my program letter that, in addition
> to the specific contest-oriented dates, places & locations already on
> the letter, I would also conduct flights "for my own enjoyment".
>
> He pointed out to me that flights "for my own enjoyment" are not
> authorized by my aircraft limitations. Only actual racing, and
> proficiency flights in preparation thereof, are permitted.
>
> Well, I sit corrected! No more fun flights in my glider. Serious ****
> only!
>
> (Mr M, if you troll this web page, please understand I don't blame
> this on you -- I know you're just following the rules. But the
> situation is, well, laughable. My letter will be revised and
> resubmitted with unseen winks and nudges.)
>
> ted/2NO

That is quite correct.

More specifically from FAA Order 8130.2

(31) All proficiency/practice flights must be conducted within the
geographical area described
in the applicant’s program letter and any amendments to that letter,
but no portion of that area will be
more than 300 nautical miles from the aircraft’s home base airport. An
exception is permitted for
proficiency flying outside of the area stated above for organized
formation flying, training, or pilot
checkout in conjunction with a specific event listed in the
applicant’s program letter (or amendments).
The program letter should indicate the location and dates for this
proficiency flying.
(Applicability: Group I; group III under 800 horsepower)

(35) Proficiency flights are authorized without geographical
restrictions when conducted in
preparation for participation in sanctioned meets and pursuant to
qualify for Federal Aeronautique
International (FAI) or Soaring Society of America (SSA) awards. These
flights may only take place as
defined in the applicant’s program letter, and prior to the specific
FAI or SSA event. The pilot in
command must submit a description of the intended route and/or
geographical area intended to be flown
to the local FSDO.
(Applicability: Group I, gliders only)

[Andy[_1_]]

On Feb 5, 12:06*am, Frank Whiteley > wrote:

> (35) Proficiency flights are authorized without geographical
> restrictions when conducted in
> preparation for participation in sanctioned meets and pursuant to
> qualify for Federal Aeronautique
> International (FAI) or Soaring Society of America (SSA) awards. These
> flights may only take place as
> defined in the applicant’s program letter, and prior to the specific
> FAI or SSA event. The pilot in
> command must submit a description of the intended route and/or
> geographical area intended to be flown
> to the local FSDO.
> (Applicability: Group I, gliders only)

What does "local FSDO" mean in this context? It could be either local
to the glider home base, or it could mean local to the planned area of
the flight.

The rule is rather strange in either event. It seems to say you can
fly anywhere without geographic restriction as long as you tell them
before hand exactly where you are going to fly. (Joseph Heller would
have enjoyed this one).


Andy

[Frank Whiteley]

On Feb 5, 7:13*am, Andy > wrote:
> On Feb 5, 12:06*am, Frank Whiteley > wrote:
>
> > (35) Proficiency flights are authorized without geographical
> > restrictions when conducted in
> > preparation for participation in sanctioned meets and pursuant to
> > qualify for Federal Aeronautique
> > International (FAI) or Soaring Society of America (SSA) awards. These
> > flights may only take place as
> > defined in the applicant’s program letter, and prior to the specific
> > FAI or SSA event. The pilot in
> > command must submit a description of the intended route and/or
> > geographical area intended to be flown
> > to the local FSDO.
> > (Applicability: Group I, gliders only)
>
> What does "local FSDO" mean in this context? *It could be either local
> to the glider home base, or it could mean local to the planned area of
> the flight.
>
> The rule is rather strange in either event. *It seems to say you can
> fly anywhere without geographic restriction as long as you tell them
> before hand exactly where you are going to fly. (Joseph Heller would
> have enjoyed this one).
>
> Andy

Good question, though amendments to the program letter go to the base
FSDO (which is why their FAX number is on my pdf example).

Frank

[Bruce]

kirk.stant wrote:
> On Feb 4, 1:30 pm, zulu > wrote:
>> Ted et al
>>
>> Your FSDO dude is a bit behind the times as the most current FAA order
>> is 8130.2F Change 5 dated 01/15/2010. Check out para. 161 in order to
>> get started.
>> I've been told by our local FSDO that older gliders can no longer use
>> their old "one time" program letter and that the operations
>> limitations need to reflect the airport from which the glider is flown
>> and that a yearly program letter must be submitted.
>> HOWEVER, the local feds have not as yet quoted me book, chaper and
>> verse of the reg/order that supports their statement. I'm still
>> working on that but I suspect it can be found in the above mentioned
>> order.
>>
>> Zulu
>
> Yeah, I can see that coming!
>
> Maybe time to put bogus N numbers on the glider - different on each
> side?
>
> But more seriously, has anyone out there been checked by the FAA to
> see if they are complying with their program letter? I can just see a
> ramp check at a big Sports Class contest!
>
> And what is the penalty? "You can't fly it here." "OK, where's the
> Fax machine?".
>
> Speaking of Faxing - what's with that? Can't the FAA handle an email
> attachement of a Word doc or a PDF file?
>
> Sheesh....
>
> Kirk
Regrettably we may as well get used to this.

We have had a full ramp check for the entire grid at a regional contest-
29 aircraft -(2009 Gauteng regionals - that is in South Africa for the
rest of the world)

All documentation - glider and pilot, weight and balance etc.
Contest check - Briefing, tasking, airspace ad turnpoint files, safety
documentation and policies the whole nine yards. Kept the contest
directors busy the whole day.

Fortunately no major problems - except the time consumed.

Bruce

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