Light Sport Aircraft

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

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 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

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