Anonymous

Document ID: NHTSA-2010-0154-0004
Document Type: Public Submission
Agency: National Highway Traffic Safety Administration
Received Date: December 15 2010, at 12:00 AM Eastern Standard Time
Date Posted: December 16 2010, at 12:00 AM Eastern Standard Time
Comment Start Date: November 16 2010, at 12:00 AM Eastern Standard Time
Comment Due Date: December 16 2010, at 11:59 PM Eastern Standard Time
Tracking Number: 80bb6d25
View Document:  View as format xml

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To specifically answer the request for comments regarding the Terrafugia transition, 1. NHTSA specifically seeks comments on whether the safety benefits of reducing weather-related accidents for flights of the Transition in inclement weather outweigh the safety risks associated with road use of the Transition in inclement weather. The Sport Pilot rule states that a LSA (light sport aircraft) piloted by a sport pilot can only be flown in Day VFR conditions which is 3 mile visibility. So to clarify the question, is driving the Transition on the road in inclement weather with the exemptions, safer than flying in inclement weather? First it depends on the weather. But seeing that the Sport Pilot rule limits the flying to 3-mile visibility during the Day, the pilot should not even see inclement weather if he/she is flying legally. The driving portion is just a convenience to get through the approaching weather and take off again to continue flying or to get the plane from an airstrip to a destination on land. VFR Pilots in a normal aircraft would either not fly, fly around the weather, or land and wait until the bad weather passes. These options will always be safer than flying or driving in bad weather. That said, driving a Transition in (car mode) that has no electronic braking stability system, non-DOT car tires and rims, no laminated safety glass, and no advanced airbags) would certainly be less safe than flying legal (good weather) in the Transition in (airplane mode). The question wants to compare driving the Transition in bad weather to flying illegally (in inclement weather). I think a more valuable question would be weather or not the exemptions would increase the risk of accident and injury to driver/passenger over that of a motor vehicle that meets all of the regulations. All of these factors seem to be verifiable with tests similar to that of cars.

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