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New LSA rules
I thought that I understood the new Sport Pilot/Aircraft rules (first
mistake) until I came across the fact that apparently you can buy a ready to fly CH601HD made by Zenair in the US that is registered as a sLSA, or you can buy the same ready to fly plane built by Czech Aircraft Works and register it as an eLSA. The only difference seems to be that the US built plane uses a Lycoming engine, the Czech one uses a Rotax. Do the rules really give you the option of registering a factory built, ready to fly plane as an experimental LSA? Frank Laczko |
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"Frank" wrote in message ... I thought that I understood the new Sport Pilot/Aircraft rules (first mistake) until I came across the fact that apparently you can buy a ready to fly CH601HD made by Zenair in the US that is registered as a sLSA, or you can buy the same ready to fly plane built by Czech Aircraft Works and register it as an eLSA. The only difference seems to be that the US built plane uses a Lycoming engine, the Czech one uses a Rotax. Do the rules really give you the option of registering a factory built, ready to fly plane as an experimental LSA? Frank Laczko Don't think it would be registered as experimental, just certified. |
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On Sat, 30 Jul 2005 11:57:47 -0500, "Frank" wrote:
I thought that I understood the new Sport Pilot/Aircraft rules (first mistake) until I came across the fact that apparently you can buy a ready to fly CH601HD made by Zenair in the US that is registered as a sLSA, or you can buy the same ready to fly plane built by Czech Aircraft Works and register it as an eLSA. The only difference seems to be that the US built plane uses a Lycoming engine, the Czech one uses a Rotax. Do the rules really give you the option of registering a factory built, ready to fly plane as an experimental LSA? Yep. The new 21.191, "Experimental Certificates," says that an Experimental certificate can be issued to a plane that "...Has been previously issued a special airworthiness certificate in the light-sport category under §21.190." The owner of a production LSA (Special LSA) can decide to re-register the aircraft as an Experimental LSA, AFTER WHICH the plane no longer has to comply with the consensus standard. I'm not surprised that the FAA lets them avoid the intermediate process. Notice the emphasis on "AFTER WHICH". A non-conversion LSA (e.g., a plane not formerly operated under Part 103) *must* comply with its certification configuration at the time the application is made for an Experimental LSA certificate. After the owner has the Experimental certificate, he or she can modify the aircraft as they wish. The same holds true for building an ELSA kit. You must build it *exactly* to the manufacturer's instructions, but after you have the certificate, you can make whatever changes you like. Major changes will require FAA notification, just like a Experimental/Amateur-Built aircraft. Ron Wanttaja |
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#8
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In article ,
says... On Tue, 02 Aug 2005 05:21:29 GMT, (sleepy6) wrote: In article , says... Experimental LSAs, like Experimental Amateur-Built aircraft, are gov er ned by the operating limitations issued at the time the plane is certified. Th e ELSA operating limitations specified in 8130-2F Change 1 certainly imply th at major changes may be performed ("All major changes or modifications will b e listed in the aircraft records...") but make no stipulation on the minimum req ui rements necessary to perform such a modification. It's not in the operating limitations, it's in the repairman certification. When you get the repairmans certificate for your amature built experimental it gives you certain privleges. The LSA repairmen certificates give them a different set of privleges . For instance, you can attend a 16 hour school to get a LSA repairman certificate with an inspection rating. That allows you to perform th e annual condition inspection but does not allow you to perform any wor k. But neither does the Repairman Certificate for an Amateur-Built aircra ft...see 65.104 (b): "(b) The holder of a repairman certificate (experimental aircraft buil der) may perform condition inspections on the aircraft constructed by the holde r in accordance with the operating limitations of that aircraft. " That's all that the Amateur-built aircraft Repairman Certificate cover s. It does not authorize the holder of the Repairman Certificate to maintain the aircraft, nor does it authorize him or her to modify it. There *are* no regulations specifying who may maintain or modify an Ex perimental Amateur-Built aircraft. Hence, anyone can. I maintain my Fly Baby, d espite holding neither an A&P license or Repairman Certificate. The same regulatory void exists for Experimental Light Sport Aircraft. Yes, FAR 65.107 specifies that the older of an LS-I or LS-M Repairman Certifica te *may* perform the annual inspection. But FAR 65 does not apply to aircraft; its topic is certification for airman other than flight crew members. And read 14CFR Part 1.3 to see what 'may' means. Look at the "Light-Sport Aircraft Maintenance and Certification Requir ements" table in the FAA's initial Sport Pilot release (page 27 of the Word do cument) it clearly states that ELSAs are owner-maintained. Not regulatory, of co urse, but it clearly indicates the FAA's intent, and there are no regulations th at contradict it. You can attend a 120 hour school to get an LSA repairman certificate with a maintaince rating. That allows you to do certain work but states "(excluding a major repair or a major alteration..." Pardon me, but you didn't finish the quote: "(excluding a major repai r or major alteration ON A PRODUCT PRODUCED UNDER FAA APPROVAL)" (emphasis added) . In other words, if the LSA mounts a certified O-235, a person with an LS-M cann ot perform major repair or alteration on it. But the airframe of an LSA, and the engine (if it was certified as conforming to the consensus standard) are NOT produced under FAA approval. Hence the exception does not apply. It may be possible for an A&P to make modifications to ELSA but the L SA repairmen can't do it themselves. Sorry, but as indicated above, I see no such prohibition in the regula tions. Ron Wanttaja I see it a little different Ron. Instead of an FAA written approval process, the FAA approved and accepted the procedures in the consensous standards for LSA. The FAA had to publish that official approval in the federal register. They have also stated that if other consensous standards from other sources were written, the FAA could approve or not approve those standards for the design and construction of LSA as well. Without that FAA approval, the consensous standards (and standards approved by other countries) mean nothing. In other words, I think the planes produced under the consensous standards are "produced under FAA approval" the same as type certified planes are produced under FAA approval. Not just the airframe either. There is a consensous standard for the design and testing of engines for LSA planes. That also was approved by the FAA. |
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#10
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In article ,
says... On Tue, 02 Aug 2005 18:53:26 GMT, (sleepy6) wrote: I see it a little different Ron. Instead of an FAA written approval process, the FAA approved and accepted the procedures in the consenso us standards for LSA. The FAA had to publish that official approval in the federal register. They have also stated that if other consensous standards from other sources were written, the FAA could approve or n ot approve those standards for the design and construction of LSA as wel l. Without that FAA approval, the consensous standards (and standards approved by other countries) mean nothing. In other words, I think the planes produced under the consensous standards are "produced under FAA approval" the same as type certifie d planes are produced under FAA approval. Sorry, can't agree. In the initial publication of the LSA/Sport Pilot Rules and the logic behind them, the FAA has this key statement: "The use of Form 337 is not required because special light-sport aircr aft will be built to a consensus standard "accepted" by the FAA, but not "appro ved" by the FAA." (page 136 of the Word document). There is a lot in that document that isn't anything like the present rules so I don't put much faith in it anymore. Also the statement you quote could be interpreted as saying that because the planes are built to the consensous standards, no changes are permitted. There are now provisions where all changes must be approved by the manufacturer. There is also a system simular to ADs that the manufacturer handles instead of the FAA. This is echoed by FAA Order 3120-2F Change one, Paragraph 121 d: "d. Light-Sport Aircraft Construction. The manufacturer of an aircraft for airworthiness certification in the light-sport category must manufactu re the aircraft to the design requirements and quality system of the applicab le consensus standard that has been accepted by the FAA and published thr ough a notice of availability in the Federal Register." "Accept" is not the same as "Approve." Imagine your best friend sayin g to you, "I'm gay." Responding, "I accept" is a HECK of a lot different than s aying "I approve." :-) Ron Wanttaja You are correct about the gay part but you might be splitting hairs when it comes to the FAA. There must be other references in the FARs and 8130. I hope you are right Ron but I'm gonna reserve judgement until I see it in operation. The FAA has continued to make changes and clarifications as the problems have shown up. This issue just hasn't been in the spotlight yet because the last I heard, there has only been one 16 hour class and no 120 hour classes yet. Blakely has talked about 44 sport pilots so far and another source said 100. Either way it's gonna be a while before this becomes an issue. As long as a SP can fly the lighter weight experimental amature built planes, I don't expect to ever get involved with the consensous standards planes anyway. |
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