The Puzzle's Missing Pieces FAA has proposed NPRM 11133 without the meaty text that really defines what one must do to comply with the airman certificate requirements and the aircraft airworthiness and maintenance requirements. Recently FAA provided a draft Advisory Circular to a few of the associations and manufacturers with a request that it go no further for now. It contains more detail about the certification of light sport aircraft and repairman. It will ultimately have details of the sport pilot requirements, but none are in the current draft. So let's stand back and look at the overall picture for a moment. NPRM 11133 FAA proposes that sport pilot applicants (including existing ultralight pilots and instructors) must take a knowledge test (written test). The test will cover a very wide range of topics—basically the same as for an FAA private pilot certificate minus instrument flying and night flying. But there are no specific questions yet, so it is impossible to evaluate the level of appropriateness of FAA's intentions. Keep in mind that it is FAA who will write the questions. FAA also proposes an oral and flight (practical) examination, and describes the privileges of this new pilot, but does not provide the all-important Pilot Testing Standards (PTS). This is a list of the areas of knowledge and skill for which a pilot applicant will be tested by the FAA inspector or FAA designated examiner. Therefore it is impossible to evaluate the level of appropriateness of FAA's intentions here, either. FAA proposes "industry consensus" airworthiness standards for trainers and pre-fabricated light sport aircraft. But those standards do not yet exist. When they do, you can rely on the fact that they will be at the level FAA determines is appropriate, not the manufacturers. So, the huge waterfall of words and thoughts about FAA's proposal is taking place by those of us who care, and will be affected. In the distant mist is only a vague outline of what the end product would actually look like. The missing pieces are very large. This situation is either a simple, unfortunate quark of the regulatory process in attempting to create a great new rule; or a brilliant marketing scheme by FAA to sell more than you think you are buying.