Sport Pilot cuts off special issuance at the knees

Todd Pattist wrote in
:

I disagree. "Expiration" is different from "revocation."
The latter implies affirmative action by the issuing
authority to withdraw the medical, presumably for cause.
The former does not carry that implication.

If you let it expire you did not meet the requirements to have the medical,
so by definition it is either revoked or suspended. You can't use it. For
the purposes of the LSA that is how it can be interpreted. It is one thing
to allow a normal medical to expire, but anyone who has a special issuance,
by definition, does not qualify for a normal medical certificate. The
letter that you are sent when you receive a special issuance medical is
VERY specific: "You are ineligible for third-class medical certification
under Title 14 of the Code of Federal Regulations (CFR's)," blah blah...

"Not have had his or her most recently issued medical
certificate (if the person has held a medical certificate)
suspended or revoked or most recent Authorization for a
Special Issuance of a Medical Certificate withdrawn;"

Nowhere does the rule mention "expired." It refers
throughout to affirmative actions by the FAA such as
"suspended," "revoked" and "withdrawn."

Todd, if you do not follow the requirements to renew your special issuance
medical, the issue doesn't just lie in limbo, What makes you think it does?

The FAA goes on to say:
"These revisions are based on the FAA's concern that pilots
whose airman medical certificates have been denied,
suspended, or revoked or whose Authorization for Special
Issuance of a Medical Certificate (Authorization) has been
withdrawn would be allowed to operate light-sport aircraft"

It seems clear to me that expired medical certificates, even
ones under Special Issuance, are not going to prevent use of
the DL as a medical.

Yes, they will be. The paragraph above is part of the explanation of why
the change was made at the last minute, without giving anyone a chance to
have an opinion or complain!!!

I don't have a special issuance medical, but even if I did,
I'm comfortable that they would have said "expired" if they
meant that everyone with a current medical had to keep
getting one.

That's not what they say either.

Juan