Looking again

[stearman3]

Re: Looking again

The whole thing from the begining is about Ryan's Taylorcraft that had a Beech Roby prop installed on it at one time. EO said, that since a Ryan's Taylorcraft is a normal category aircraft that the definition doesn't apply. He then went on to say that the part of the definition about "since its original certification, has continued to meet the following:", doesn't apply, and since it doesn't have that propeller on now it can be flown by a sport pilot. I say the definition does apply and since the Beech Roby prop was installed in the past it can not be flown by a sport pilot. Ryan's conversation with the FAA confirmed this.
I agree that the airplane must meet the requirements, all of them, in part 1 to be flown by a sport pilot. What I meant by no guide line is that unlike category and class which have different meanings for pilot certification and aircraft certification that light sport aircraft does not, and IMO it should. Just because the Taylorcraft is a light sport aircraft that a sport pilot can fly it is not from a certification and maintenance stand point.

I was an FAA A/W inspector for 20 years,and I've thought about the Beech Roby issue also.

I know what the intent is with the prop issue ,but just to give em a hard time, I would argue that the Beech Roby is adjustable on the ground...and without the engine running!

I also promise to NEVER adjust it in mid air! Thereby, staying in compliance with the 'ground' adjustable language in Part!

[3Dreaming]

Re: Looking again

I was an FAA A/W inspector for 20 years,and I've thought about the Beech Roby issue also.

I know what the intent is with the prop issue ,but just to give em a hard time, I would argue that the Beech Roby is adjustable on the ground...and without the engine running!

I also promise to NEVER adjust it in mid air! Thereby, staying in compliance with the 'ground' adjustable language in Part!

I guess that you could argue the point that it is ground adjustable, but when you lose the arguement you can no longer fly the airplane as a sport pilot the way I see it.

I want to try a different way of describing it for EO and Flyguy. The CFR 1.1 definition for a "Light Sport Aircraft" applies to any aircraft regardless of how it was manufacturered or the type of airworthiness certificate issued. An aircraft that is issued a special airworthiness certificate in the light sport category is not a light sport aircraft because of that. It is a light sport aircraft because it meets the CFR 1.1 definition.
From the certification side they are aircraft that are issued an airworthiness certificate in the light sport category. If the certificate is issued under CFR 21.190 the the aircraft must be built to consensus standards. The standards used are ASTM standards. While the airplane must continue to meet the standards through out its life it is still maintained under the CFR's just like any other aircraft.
CFR 21.191 covers experimental light sport airworthiness certificates.
So if you see an aircraft with the "LIGHT SPORT" on the side it was built to ASTM standards, issued an airworthiness certificate under CFR 21.190, maintained under the CFR's, and is a light sport aircraft because it meets the CFR 1.1 definition.

[stearman3]

Re: Looking again

I guess that you could argue the point that it is ground adjustable, but when you lose the arguement you can no longer fly the airplane as a sport pilot the way I see it.

I want to try a different way of describing it for EO and Flyguy. The CFR 1.1 definition for a "Light Sport Aircraft" applies to any aircraft regardless of how it was manufacturered or the type of airworthiness certificate issued. An aircraft that is issued a special airworthiness certificate in the light sport category is not a light sport aircraft because of that. It is a light sport aircraft because it meets the CFR 1.1 definition.
From the certification side they are aircraft that are issued an airworthiness certificate in the light sport category. If the certificate is issued under CFR 21.190 the the aircraft must be built to consensus standards. The standards used are ASTM standards. While the airplane must continue to meet the standards through out its life it is still maintained under the CFR's just like any other aircraft.
CFR 21.191 covers experimental light sport airworthiness certificates.
So if you see an aircraft with the "LIGHT SPORT" on the side it was built to ASTM standards, issued an airworthiness certificate under CFR 21.190, maintained under the CFR's, and is a light sport aircraft because it meets the CFR 1.1 definition.

You are correct. This is just me with several axes to grind with todays FAA............Knowing all the time ,it's not productive. It just appears that there are very few ,if anyone in the FAA that care about our old airplanes anymore.

[flyguy]

Re: Looking again

If it were me and it was my airplane I would fight them tooth and nail over it, mainly because it is so stupid, and perhaps because I have had some really insanely dumb experiences with FSDO people when writing repair manuals. Then I would move to another district (state?) if I was going to continue to fly. Chuckle

Extra: Fortunately around here it is somewhat like the Chinese saying "God is far above and the Emperor is far away."

[Hank Jarrett]

Re: Looking again

Not all of the FAA guys are so messed up. I worked with a bunch of folks at the Small Aircraft Certification Directorate in Kansas City who were small plane guys themselves and were great. What we need is to tie in with the good ones and work WITH them through the system. The problem is with the system. Even the good guys are frustrated with it. There are good and bad people in all large organizations. If we go in with an adversarial attitude, we will almost always loose (sometimes we will loose even when we are right AND have insiders on our side). It is just way too easy for lazy people to say no.
First we need to find the allies, then we need to make agreeing with our positions easier than saying no.

Hank

[RyanShort1]

Re: Looking again

If it were me and it was my airplane I would fight them tooth and nail over it, mainly because it is so stupid, and perhaps because I have had some really insanely dumb experiences with FSDO people when writing repair manuals. Then I would move to another district (state?) if I was going to continue to fly. Chuckle

Extra: Fortunately around here it is somewhat like the Chinese saying "God is far above and the Emperor is far away."

I fought this as far as I could and was told that my only further recourse is to make an appeal on the Federal Registry.

Ryan

[Hank Jarrett]

Re: Looking again

That is the only way left for YOU to change it. We need for THEM to change it, and for that you need someone on the inside to petition for a new interpretation.
We are all in an adversarial position with the FAA on this. They can still change their minds based on a good argument from the inside. We just need to make it easier to say yes than no.
Hank

[RyanShort1]

Re: Looking again

That is the only way left for YOU to change it. We need for THEM to change it, and for that you need someone on the inside to petition for a new interpretation.
We are all in an adversarial position with the FAA on this. They can still change their minds based on a good argument from the inside. We just need to make it easier to say yes than no.
Hank

I agree Hank, and I personally think that if a number of us got together and all put our names on a petition of some sort, that there are reasonable people (even including my FSDO manager) who would be generally in favor of the change. It's really an elephant in the closet anyway, since most people aren't in my position of showing examiners a logbook for a checkride. My aircraft was flown for 6 years by a sport pilot who likely didn't even know he was not operating it legally.
If no one looked at the logbook (or saw on the internet that I knew it had previously had a Beech Roby prop installed) then probably even a good examiner wouldn't look at it with a critical eye, just looking for the last annual and 100 hour inspections, etc... It currently has a McCaulley prop on it and looks like a stock aircraft.

Ryan

[jim cooper]

Re: Looking again

Hank has this nailed. Exactly correct IMHO. My Cessna 195 was beautiful. I just had to have it. The airworthy cert. was not in its holder in the cabin but rather in the papers with the logs, etc. I had a good AI go over it....not an annual but rather a prebuy. First mistake!( The AI admitted later that he flew down in his Pitts and after looking it over, seeing as it might rain he cut it short and left. Did NOT do a compression check.) so I bought it.( dumb move!) When I flew it up to this same AI, we went for a ride and the prop gov. Allowed the engine to runaway. The AI chopped the power, dead sticked it back to the runway. Landed without problem. I called wife, she picked me up, AI would go over the airplane and call me. Finally, 3 cylinders later etc., 3000 .00 later he called to tell me the airworthy certificate was invalid as the proper paperwork had not been filled out in 1956 (1956!) When this change took place. He had his pal, AN FAA INSPECTOR come to the airport. The inspector called me after going over the airplane carefully. He said " I can make you take this Cessna back to Factory standard due to this paperwork foul up." God! Can you help me.?..said I .Yes I have already approved it and its good to go. So, there are good and bad, not only in the FAA but in private industry as well. The former owner, an airline captain was , shortly after I bought it from him ,retired for alcoholism. He lied to me about many things pertaining to the airplane. So you must find a decent FAA type and they are around. The airline pilot flew it, not much , for five years before selling it to me! In the meantime, I personally would bolt the correct prop on yours, provided everything else checks out, and go flying! . My thinking: " After all, he's an AIRLINE CAPTAIN. It must be a great airplane. AI thought this way too! After 8000.00 and never flying more than an hour,it I sold it to a fellow who had called the airline pilot and believed him! I warned him! BUT, I got all my money back. The next owner should have listened to me. He spent LOTS more, then parked it. it never flew again to the best of my knowledge. My ownership was in 1985. It's Dale Carnegie time!

[Edwin Otha]

Re: Looking again

Ryan,
You took the Fed's out of their comfort zone. If you try to explain the addition and subtraction of equipment that was done to the Taylorcraft they will reject it based on all of the interpretations we have on this thread. I try to make it short and sweet when working with the Fed's. My choice would have been to explain that "the Taylorcraft currently meets the criteria for Sport Pilot operation, could I continue to operate it as such" and leave it at that.
I once installed a strobe light in place of a rotating becon on a Comanche. The 337 bounced twice before I changed the wording. They both became "anti-collision" lights and the 337 sailed through. Many times it is all in the approach.
EO

[3Dreaming]

Re: Looking again

EO, I know you probably haven't read any of my recent post, but I was wrong in the way that I was trying to explain it.The discussion we had forced me into the regulations to look for answers. I have looked in parts 1,21,43,61,and 91 where there is talk of light sport aircraft and aircraft issued a airworthiness certificate in the light sport category.
The 1.1 definition for a light sport aircraft is simply for aircraft that meets the requirements of the definition. The type of airworthiness certificate carried doesn't matter.
The FAA was pretty clear that they would not allow a deviation from the CFR 1.1 definition. Since it has not continued to meet the requirements from the begining, means it can not meet the requirements ever again. Unless the FAA changes the requirements.

[Edwin Otha]

Re: Looking again

I still disagree.
Using your interpertation a Taylorcraft with incomplete logs would not be able to operate as a Sport Pilot eligible aircraft. There would be no way to show conformity. I don't think the FAR means that. This is the problem with lumping the Standard Catagory in with the Light Sport aircraft.

[Hank Jarrett]

Re: Looking again

Ed, that isn't what it says either. If the logs show it was configured so that it did not meet the requirements at any time in its history it can never qualify again, even if changed back.
If the FAA records show it was modified to be out of conformance for a sport pilot it can also never be used under sport pilot again, no matter what its current configuration is.
If there is NO RECORD of it ever being modified is is good to go. It doesn't matter if it WAS modified some time in the past, all that matters is if there is a record of it. If there is no record, it never happened. If the plane has a change that isn't in the records anywhere, then the plane is out of configuration and legally can't be flown by ANYONE.
It doesn't have to make sense, it's rules. We need to get them to change the rules because the way they are is stupid and NOT what was intended.

Hank

[3Dreaming]

Re: Looking again

I still disagree.
Using your interpertation a Taylorcraft with incomplete logs would not be able to operate as a Sport Pilot eligible aircraft. There would be no way to show conformity. I don't think the FAR means that. This is the problem with lumping the Standard Catagory in with the Light Sport aircraft.

I don't see how not having logs would create a problem, in fact I would think it would be the opposite. Proving that it is not eligible when you have records that say the equipment was installed is easier that trying to prove that it is not eligible with no records or no proof.

A light sport aircraft is simply an aircraft that meets the CFR 1.1 definition. If the Taylorcraft meets the requirements then it is a light sport aircraft. If it doesn't it is not a light sport aircraft it is that simple. This is just like any aircraft with more than one engine is a multi engine aircraft, and any airplane with 2 wings is a biplane.

The FAA did create a new airworthiness certificate and added a new purpose for issue of an experimental certificate. CFR 21.190 provides a way to issue an airworthiness certificate to a light sport aircraft that has not been issued some other type of airworthiness certifcate before as long as it meets the requirements.

How the airplane is maintained is determined by the airworthiness certificate and not the fact that it is a light sport aircraft. A light sport aircraft that has a special issue airworthiness certificate in the light sport category will be maintained different than one with a standard category airworthiness certificate.

[stearman3]

Re: Looking again

I still disagree.
Using your interpertation a Taylorcraft with incomplete logs would not be able to operate as a Sport Pilot eligible aircraft. There would be no way to show conformity. I don't think the FAR means that. This is the problem with lumping the Standard Catagory in with the Light Sport aircraft.

What constitutes 'complete' logs. Our airplanes don't every entry from day one to be legal.

All we have to have is tthe minimum required by FAR 01.417