Light Sport Aircraft

"Ron Wanttaja" wrote

It follows, then, that ELSAs are NOT required to continue to comply to the
consensus standard, and owners can modify them once they've received their
original ELSA certification.

Ron Wanttaja


Thanks, Ron. That's a keeper.

When you gonna write your LSA repair and building book? I'll buy one to
add to my collection!
--
Jim in NC

"Ron Wanttaja" wrote in message
...
On Mon, 03 Jan 2005 23:24:21 GMT, Ron Wanttaja wrote:

It is subject to the same maintaince etc requirements as SLSA but can
not be used for instruction or rental.

Sleepy is correct.

Whoops, noticed something else. I believe ELSAs *can* be used for
instruction
and rental, through 2010. That's what's covering the two-seat ultralight
trainers that must convert to ELSA.

Ron Wanttaja

What happens in 2010?
--
Jim in NC

Morgans wrote:

Is it correct to say that the consensus standards do not apply, when i
t is a
plans built? How about kit meeting 51% self built rule?

I'm still not exactly sure I understand what an experimental LSA is, a
nd
what hoops must be jumped through.
--
Jim in NC



An ELSA is simply an SLSA that has been pulled off the production line
at whatever point the customer wants. The customer then finishes the
planes following the EXACT factory instructions but it must be
identical to the SLSA. All factory parts and no modifications at all.

It is subject to the same maintaince ect requirements as SLSA but can
not be used for instruction or rental.


Sorry, but you didn't catch what I asked. What about the plans built, or
one that has no assembly, at all? What about the guy that designs one (one
off) that fits under the specs of the rule?

Jim,

If it is a plans-built or a "one-off" design (I guess that would be
"plans built" too), forget about sLSA or eLSA. The type of aircraft
that you are describing would be built and certified under the existing
experimental/amateur-built rules and so long as it met the Sport
Aircraft specs (stall speed, gross weight, maximum level speed, etc), a
pilot could fly it with a Sport Pilot license (no medical).

Rick Pellicciotti

On Mon, 3 Jan 2005 20:21:43 -0500, "Morgans" wrote:

An ELSA is simply an SLSA that has been pulled off the production line
at whatever point the customer wants. The customer then finishes the
planes following the EXACT factory instructions but it must be
identical to the SLSA. All factory parts and no modifications at all.

It is subject to the same maintaince ect requirements as SLSA but can
not be used for instruction or rental.

Sorry, but you didn't catch what I asked. What about the plans built, or
one that has no assembly, at all? What about the guy that designs one (one
off) that fits under the specs of the rule?

Rick gave you the right answer, but let me have a crack at clarifying this.

The basic confusion here is over the term, "Light Sport Aircraft." IHMO, the
developers of the new rules made a mistake here, as they use the same term for
two separate, but related, concepts.

The first is that of "Light Sport Aircraft" as a definition. The regulation
changes added this definition to 14CFR Part 1...what us'n old timers would call
FAR Part 1. In Part 1, an LSA is an aircraft that has a gross weight of 1320
pounds or less, a stall speed less than 52 MPH, a flat-out level flight top
speed of 138 MPH or less, etc.

A person with a Sport Pilot license, or someone with a Primary, Private,
Commercial, or ATP license with an honorably lapsed FAA medical (e.g., a valid
medical that expired and was not revoked or renewal denied), can fly an aircraft
that meets the LSA definition.

This airplane can be licensed in ANY Category... Normal, utility, primary,
experimental, restricted, limited, etc. The only exceptions I can think if is
if a given aircraft has a set of operating limitations assigned by the FAA that
require a minimal set of pilot qualifications.

So, that's LSA as a definition. The FAA also instituted a *certification
category* called "Special Light Sport Aircraft," and added a new sub-category to
"Experimental" called "Light Sport Aircraft."

There are two basic kinds of Airworthiness Certificate. There is the 'Standard'
category. Once an aircraft receives a certificate in the Standard category, the
owner can operate the aircraft with no more attention from the FAA. A Standard
category aircraft can be flown for pleasure, rented, leased, or carry passengers
for hire with no additional involvement from the FAA other than the operator
ensuring the appropriate FARs for the type of operation be followed.. Standard
category includes "Normal" category, "Utility," "Aerobatic," "Commuter," and
"Transport." Each aircraft in these categories is assumed to be airworthy as
long as the appropriate inspections verify that the aircraft still meet the
description of its type certificate.

The other basic kind of Airworthiness is the "Special" category. The Special
category exists to allow aircraft that do not necessarily meet the requirements
of the Standard category to be operated to perform specific tasks. This
category includes Restricted, Limited, Experimental, and, now, the Light Sport
Aircraft category.

The Light Sport Aircraft category under the "Special" category (hence, "Special
Light Sport Aircraft") was created to allow production of ready-to-fly small
aircraft without requiring the level of design verification that Standard
category requires. To be produced on a Standard certificate, you have to meet
the FARs...and SLSAs do NOT meet the "regular" FARs. The FAA is allowing the
industry itself to define the amount of testing and validation necessary for a
SLSA airworthiness certificate.

The only things the FAA requires is that the aircraft produced must meet the FAR
Part 1 definition of an LSA, that the industry agree on the requirements *all*
SLSA aircraft must meet (e.g., the consensus standards), and that every occupant
of a SLSA aircraft be advised that the airplane does not meet FAA certification
requirements. In other words, all SLSA aircraft must include the same kind of
"Passenger Warning" that our homebuilts carry.

So, that's the production-type LSAs. As the development of the Special Light
Sport Aircraft category was ongoing, some consideration was paid to the
potential to sell kits of these SLSAs. The FAA was amenable...but the SLSA
category was designed to place the entire onus on compliance with the consensus
standards on the kit manufacturer. It was certainly possible to require the
manufacturer to inspect a customer-built aircraft prior to certification (there
have been kits of Standard category aircraft), but something closer to
traditional homebuilding was wanted.

Hence, the developers added a new sub-category under the Experimental category.
Where there was Racing, Market Survey, Amateur-Built, etc, the FAA added a new
sub-category for homebuilt Light Sport Aircraft: Experimental/Light Sport
Aircraft (ELSA).

Note that this was a *new* category under Experimental. It did not replace
Amateur-Built; it is not something that was merged under the Experimental
Amateur-Built sub-category. It is *entirely* separate, like Experimental/Racing
or Experimental/Research and Development category aircraft are.

Hence, traditional homebuilding is completely unaffected. BUT...if a
homebuilder constructs an airplane that meets the FAR Part 1 definition of an
LSA, it can be flown by a Sport Pilot. But unless it meets the specific
requirements of the Experimental Light Sport Aircraft category, it cannot be
licensed as a ELSA. It *can* be licensed as an Experimental Amateur-Built
aircraft, just like always.

But, let's look at this a different way. Let's say that I want to license a Fly
Baby in the Experimental Light Sport Aircraft category. That'll let me do all
my own maintenance, and, after taking a 16-hour course, I'll be able to sign off
the annuals, too.

First off, I *cannot* relicense my existing Fly Baby. The regs do NOT allow
relicensing existing N-numbered aircraft as either Special or Experimental Light
Sport Aircraft.

So I gotta build a new one. But to get a plane into the Experimental Light
Sport Aircraft category, I have to first certify a prototype as a SLSA. In
other words, I have to go through the ENTIRE CERTIFICATION PROCESS for a
production LSA. I have to perform the analysis/testing to verify that the
design meets the required load factors (+4G, -2G, 1.5x factor of safety, with an
additional factor of safety on critical components). I have to select an engine
that meets the engine section of the consensus standards (since it's single-seat
airplane, I only need a single-ignition engine).

I have to build the aircraft in conformance with the quality control standards
(which means a formal QC process), and develop the appropriate system for
tracking airworthiness problems over the years. I have to write up an affidavit
that certifies that the airplane I built meets the consensus standard, and have
the aircraft safety-inspected by a DAR.

As of that point, my Fly Baby has a SLSA certification. I can duplicate the
building effort and produce ready-to-fly aircraft, or I can *truncate* the
building process and sell kits. These kits can be sold at any level of
completion...no 51% rule. The builder of the kit has to *exactly* follow the
detailed assembly manual that I'm required to write. And at the end, they can
get their planes licensed as ELSAs.

But what about me? After I license my SLSA Fly Baby, I can voluntarily
downgrade it to an ELSA. At which point I can take that 16-hour course and get
the LS-I Repairman Certificate that allows me to perform ELSA annual
inspections.

A lot of work, right? Instead of going through all the SLSA certification
stuff, I could have just licensed the durn thing as an
Experimental/Amateur-Built and applied for the "regular" Repairman Certificate
that would allow me to perform that annual anyway.

The upshot is: If you are a traditional homebuilder, don't worry about the SLSA
or ELSA certification standards. If your plane meets the FAR Part 1 Definition,
you'll be able to fly it as a Sport Pilot without having to conform to consensus
standards, etc.

Ron Wanttaja

On Mon, 03 Jan 2005 19:10:45 -0600, Rick Pellicciotti wrote:

I have experience with RANS and Kitfox aircraft. I have personally
built 5 RANS kitplanes and I have known Randy Schlitter since 1988. The
airplanes are top notch, customer support and service are second to
none. RANS has a production certificate in hand and can build S-7
Couriers today. To my knowledge, this is the only LSA legal, new
airplane that is certified right now.

If I may make a slight clarification, Rick: The S-7 meets the FAR Part 1 Light
Sport Aircraft definition, and thus can be legally flown by Sport Pilots. But
as far as I know, it is certified in the Standard airworthiness category
(probably Normal or Primary), *not* as a Special Light Sport aircraft.

The S-7 must be annualed by an A&P with an Inspection Authorization, and cannot
be inspected or have major maintenance performed by a person with a Light Sport
Maintenance Repairman Certificate. Nor can it be transitioned into the
Experimental Light Sport Aircraft category to allow all maintenance by the owner
and inspections by those with an LS-I Repairman Certificate.

I'm betting RANS can have one of the first planes certified as SLSA, if they
wish. But existing Standard category S-7s won't be able to transition.

However, like you said, they *are* LSA legal...from the point of view of those
who wish to fly as Sport Pilots.

Ron Wanttaja

In article ,
says...

On Mon, 03 Jan 2005 22:30:18 GMT, (sleepy6) wrote:

In article ,
says...

Is it correct to say that the consensus standards do not apply, when
it is a plans built? How about kit meeting 51% self built rule?

I'm still not exactly sure I understand what an experimental LSA is,
a
and what hoops must be jumped through.

An ELSA is simply an SLSA that has been pulled off the production lin
e
at whatever point the customer wants. The customer then finishes the

planes following the EXACT factory instructions but it must be
identical to the SLSA. All factory parts and no modifications at all
.

It is subject to the same maintaince etc requirements as SLSA but can

not be used for instruction or rental.

Sleepy is correct. The LSA regs do not affect the classic 51% homebui
lts *at
all*. The same old process is in effect. If your 51% homebuilt meets
the
definition of a Light Sport Aircraft (gross weight, stall speed, etc.)
it can be
flown by a person with Sport Pilot privileges (either someone with an
actual
Sport Pilot license, or someone with a higher license and an lapsed me
dical) but
the licensing and maintenance regulations are the same as they've alwa
ys been.

One small point that I'll correct Sleepy on: The Experimental LSA is
not quite
subject to the same maintenance requirements of a Special Light Sport
Aircraft.

On the SLSA:

1. Preventative maintenance can be performed by the owner (just like
FAR 23
aircraft).
2. Normal/major maintenance must be performed by an A&P or a person w
ith a
Light Sport-Maintenance (LS-M) Repairman Certificate
3. Annual inspections must be performed by either an A&P or a person
with a
LS-M Repairman Certificate.

For the ELSA:

1&2. Preventative AND Normal/major maintenance can be performed by th
e owner
3. Annual inspections must be performed by an A&P, a person with a LS
-M
Repairman Certificate, or someone with the other new Repairman Certifi
cate,
Light Sport- Inspection (LS-I).

The LS-I Repairman Certificate is similar to the Amateur-Built aircraf
t
repairman certificate, with two significant exceptions:

First, the applicant must complete a 16-hour training course. You can
NOT
receive an LS-I just by assembling an ELSA. You MUST take the course.

Second, a person with an LS-I may perform the annual inspection on *an
y* ELSA
they own. Unlike the Amateur-Built Repairman Certificate, it is not a
pplicable
to only one aircraft. Once you earn the LS-I, you can buy another ELS
A kit or a
completed ELSA aircraft and perform the annual inspections on it.

Sleepy touches on one sporty item about the ELSA category. Like he sa
ys, the
ELSA kit *must* be built exactly to the LSA kit manufacturer's instruc
tions.
You cannot install an alternate engine, use a different covering syste
m, etc.
It must be built precisely to the manufacturer's callout.

However... as far as I can tell, the owner can then modify the aircraf
t however
they chose, once the plane receives its formal ELSA airworthiness cert
ificate.

Owners of SLSAs (the production LSAs) must maintain their aircraft in
precise
accordance to the manufacturer's maintenance plan and continued safety
directives to continue to conform to the consensus standard. But the
FAA also
says that owners of SLSAs can avoid having to follow the SLSA's manufa
cturer's
safety directives by changing their plane's airworthiness to ELSA.

It follows, then, that ELSAs are NOT required to continue to comply to
the
consensus standard, and owners can modify them once they've received t
heir
original ELSA certification.

Ron Wanttaja


Ron is correct about the maintaince and other details. To me the
differences between SLSA and ELSA are minor compared to the differences
between ELSA and amature built experimental.

Personally, my only reason to consider ELSA would be to avoid building
at least 51%. The restrictions and requirements associaed with ELSA
would easily outweigh that benefit in my opinion.

On Tue, 04 Jan 2005 06:12:42 GMT, (sleepy6) wrote:

Personally, my only reason to consider ELSA would be to avoid building
at least 51%. The restrictions and requirements associated with ELSA
would easily outweigh that benefit in my opinion.

The world has become a lot more impatient... in nearly every conventional
hobby, people want to buy more and do less. People buy ready-to-fly RC models,
no one builds their own stereos, those who build their own computers basically
just plug ready-to-run components together. ELSA kits won't appeal to those who
want to customize their planes, but might be a good cost-savings opportunity for
those who don't want to do a lot of work.

The aspect that intrigues me is the SLSA to ELSA conversion. The FAA says that
owners of SLSAs will be able to convert their planes to ELSAs. Once it's in
ELSA, the plane apparently no longer has to continue to conform to the consensus
standards (the FAA says one can do the conversion if one doesn't want to
implement a change required by the manufacturer).

One of the more common homebuilding questions come from guys who want to take a
stock Cessna, install an auto engine in it, and "license it as a homebuilt." As
we've discussed here many times, it's almost impossible to transfer such a plane
to the Experimental Amateur-Built category.

However, it looks to me that such a switchover WILL be possible, within ELSA.
You still won't be able to do it with a Standard category airplane, but you will
be able to buy a flying aircraft (new or used SLSA), put it into the
Experimental category (ELSA), and then perform whatever modifications you please
with no further limitations by the FAA. You'll even be able to rent it out,
until the permission to do so expires in 2010. You'll be able to maintain the
aircraft yourself, and, with the completion of that 16-hour course, be able to
sign off the annuals.

I don't know if that was the intent of the developers, it sure looks like it's a
result of the program....

Ron Wanttaja

In article ,
says...

On Tue, 04 Jan 2005 06:12:42 GMT, (sleepy6) wrote:

Personally, my only reason to consider ELSA would be to avoid buildin
g
at least 51%. The restrictions and requirements associated with ELSA

would easily outweigh that benefit in my opinion.

The world has become a lot more impatient... in nearly every conventi
onal
hobby, people want to buy more and do less. People buy ready-to-fly R
C models,
no one builds their own stereos, those who build their own computers b
asically
just plug ready-to-run components together. ELSA kits won't appeal to
those who
want to customize their planes, but might be a good cost-savings oppor
tunity for
those who don't want to do a lot of work.

The aspect that intrigues me is the SLSA to ELSA conversion. The FAA
says that
owners of SLSAs will be able to convert their planes to ELSAs. Once i
t's in
ELSA, the plane apparently no longer has to continue to conform to the
consensus
standards (the FAA says one can do the conversion if one doesn't want
to
implement a change required by the manufacturer).

One of the more common homebuilding questions come from guys who want
to take a
stock Cessna, install an auto engine in it, and "license it as a homeb
uilt." As
we've discussed here many times, it's almost impossible to transfer su
ch a plane
to the Experimental Amateur-Built category.

However, it looks to me that such a switchover WILL be possible, withi
n ELSA.
You still won't be able to do it with a Standard category airplane, bu
t you will
be able to buy a flying aircraft (new or used SLSA), put it into the
Experimental category (ELSA), and then perform whatever modifications
you please
with no further limitations by the FAA. You'll even be able to rent i
t out,
until the permission to do so expires in 2010. You'll be able to main
tain the
aircraft yourself, and, with the completion of that 16-hour course, be
able to
sign off the annuals.

I don't know if that was the intent of the developers, it sure looks l
ike it's a
result of the program....

Ron Wanttaja

I haven't researched it since the actual changes in the FARs so you
may be right ... but earlier versions allowed only the ultralight
transfers to be used as trainers and rentals for a limited period of
time. The factory kit ELSA were never allowed as trainers and rentals.

Also the factory kit ELSA and the SLSA that moved down to ELSA were not
allowed anything but factory approved modifications. We never got an
answer about modifications on the transfered ultralights. It was real
confuseing because they refered to transfered ultralights as ELSA also
and we had to see which ELSA we were dealing with as we looked up a
reference to a different section. That may have happened when they
wrote the actual FARs.

I hope your interpretation is right because ELSA kits were too
restricted for the life of the plane in the early discussions.

On Tue, 04 Jan 2005 18:55:13 GMT, (sleepy6) wrote:

I haven't researched it since the actual changes in the FARs so you
may be right ... but earlier versions allowed only the ultralight
transfers to be used as trainers and rentals for a limited period of
time. The factory kit ELSA were never allowed as trainers and rentals.

Since the transitioned two-seat ultralights get the same ELSA certificates as
the kit-built machines, I can't see how they could allow one type of ELSA to be
rented and not the other. But I think that's the reason for the 2010 expiration
date; to allow the two-seat UL trainers to continue in their present operations
for a reasonable amount of time.

BTW, Jim asked what the significance of 2010 is. It's just the date the FAA
selected at which time Experimentals will no longer be able to be used for
training purposes. No other significance, I think....

Also the factory kit ELSA and the SLSA that moved down to ELSA were not
allowed anything but factory approved modifications. We never got an
answer about modifications on the transfered ultralights. It was real
confuseing because they refered to transfered ultralights as ELSA also
and we had to see which ELSA we were dealing with as we looked up a
reference to a different section. That may have happened when they
wrote the actual FARs.

I hope your interpretation is right because ELSA kits were too
restricted for the life of the plane in the early discussions.

I have a sneaking suspicion my interpretation is wrong, just because it *would*
allow a lot more flexibility that I believe the FAA and EAA intended. I've been
given a good contact at the FAA, I'll try get a clarification.

Ron Wanttaja

The upshot is: If you are a traditional homebuilder, don't worry about
the SLSA
or ELSA certification standards. If your plane meets the FAR Part 1
Definition, you'll be able to fly it as a Sport Pilot without having to
conform to consensus standards, etc.

Ron Wanttaja



Nice write-up Ron!

John