Looking again

[RyanShort1]

Re: Looking again

Because it can be adjusted in flight.

Ryan

[stearman3]

Re: Looking again

Here is a redacted portion of a letter from the Light Sport Aircraft Program Manager...

That's how they view it...

I also had a separate effort going with the SAT FSDO, and got this response:

I am willing to pursue the petition for a change in the regulations, but would need some support in the effort as I think it's above my pay grade, time, and abilities to make that kind of effort to challenge the existing rule.

Ryan

You might ask why the Beech Roby prop is an issue. It's adjustable on the ground, and the engine doesn't have to be running!!

[3Dreaming]

Re: Looking again

This definition is for light sport aircraft,period. The original certification for a light sport aircraft is either ELSA or SLSA. Since they use the sky that the FAA thinks they own, they need to address the air machines that use it. If you prefer a definition of LSA, as this, so be it. But to say that IF an aircraft fits this criteria it is an LSA aircraft by default, is wrong. These guidelines assist a Sport Pilot in selection of aircraft elegible for them to operate, not a certification basis.
We tend to be our own enemy on these issues, most of these concerns are from tribal knoweldge and interpretation fitting what direction we want to take it. And thanks to the FAA the FAR's will support either side.
Until the head of the light sport division imlements a FAR to support their opinion, that's all it is.
EO

EO, I am a dealer for a light sport airplane I know how they are certified. I am also an A&P and understand standard aircraft certification. I agree with you 100% on the way these airplanes are certified and the differences between the two as aircraft. From this side a Taylorcraft is not an LSA and can not be maintaind like one. This all comes from the mechanic side.
I am also a CFI teaching both private and sport pilots. I have studied the regulations regarding sport pilot from the begining. The Taylorcraft may not be a LSA in your eyes, but for it to be eligible for a sport pilot to fly it must meet the CFR 1.1 definition. That is the only place in the regulations that show qualities an aircraft must have to be flown by a sport pilot.

[RyanShort1]

Re: Looking again

This definition is for light sport aircraft,period. The original certification for a light sport aircraft is either ELSA or SLSA. Since they use the sky that the FAA thinks they own, they need to address the air machines that use it. If you prefer a definition of LSA, as this, so be it. But to say that IF an aircraft fits this criteria it is an LSA aircraft by default, is wrong. These guidelines assist a Sport Pilot in selection of aircraft elegible for them to operate, not a certification basis.
We tend to be our own enemy on these issues, most of these concerns are from tribal knoweldge and interpretation fitting what direction we want to take it. And thanks to the FAA the FAR's will support either side.
Until the head of the light sport division imlements a FAR to support their opinion, that's all it is.
EO

Here is a redacted portion of a letter from the Light Sport Aircraft Program Manager...

After discussion with XXX, I understand that your letter was simply to
request information regarding the possible scenarios for a sport pilot to
be able to operate Taylorcraft BC12D, serial number XXXX, and not an
official request for deviation or exemption to 14 CFR 1.1. As you have
already identified, the definition for light-sport aircraft contains the
phrase "since its original certification, has continued to meet the
following:" Since the subject aircraft did not meet the definition for LSA
at one point in its history and therefore has not "continued to meet" the
definition, it no longer is eligible to be flown by a sport pilot. The FAA
has not allowed any aircraft to be modified to meet the definition either
by simple modification or through an STC. The FAA will not grant a
deviation or exemption to any definition in 14 CFR part 1.

However, it is possible for the pilot that is concerned with this issue to
submit a formal request (in accordance with 14 CFR part 11) for exemption
from 14 CFR 61.315(a) to allow a sport pilot to act as pilot in command of
an aircraft that is not a light-sport aircraft (i.e., Taylorcraft BC12D,
serial number XXXX). Not sure if it will be granted or not, but at least
this would be an appropriate request where it is not appropriate to request
an exemption from any definition in 14 CFR part 1.

Otherwise, anyone can petition the FAA (in accordance with 14 CFR part 11)
for rulemaking to change the definition for LSA.

Let me know if you need further clarification.

XXX

Light-Sport Aircraft XXXXX XXXXXXXX
Small Airplane Directorate
Programs and Procedures, ACE-114

That's how they view it...

I also had a separate effort going with the SAT FSDO, and got this response:

After receiving and reviewing the correspondence from TC it is clear that my direction to you is in conflict with his. I have spoken to him and AFS-610 and they have explained the reasons behind the wording "has continued to meet" in 14 CFR 1.1. The end result is that your aircraft is not eligible to be operated in the Light Sport category because the installation of the Beech-Roby propeller in the past broke the chain of the aircraft continuing to meet 14CFR 1.1. The petition for exemption that you submitted to this office needs to be submitted in accordance with 14CFR Part 11.63. The web site for this CFR is attached below.

http://rgl.faa.gov/Regulatory_and_Gu...6?OpenDocument

I am willing to pursue the petition for a change in the regulations, but would need some support in the effort as I think it's above my pay grade, time, and abilities to make that kind of effort to challenge the existing rule.

Ryan

[Edwin Otha]

Re: Looking again

This definition is for light sport aircraft,period. The original certification for a light sport aircraft is either ELSA or SLSA. Since they use the sky that the FAA thinks they own, they need to address the air machines that use it. If you prefer a definition of LSA, as this, so be it. But to say that IF an aircraft fits this criteria it is an LSA aircraft by default, is wrong. These guidelines assist a Sport Pilot in selection of aircraft elegible for them to operate, not a certification basis.
We tend to be our own enemy on these issues, most of these concerns are from tribal knoweldge and interpretation fitting what direction we want to take it. And thanks to the FAA the FAR's will support either side.
Until the head of the light sport division imlements a FAR to support their opinion, that's all it is.
EO

[M Towsley]

Re: Looking again

I think this may be the key from the above: since its original certification, has continued to meet the following

[3Dreaming]

Re: Looking again

Part 61 discribes the catagory of aircraft a sprot pilot can fly and does not limit them. If you return to CFR 1.1 for the definition of catagory it gives you all kinds of catagory's. Normal, which the Taylorcraft is, and Provisional, that covers the LSA. There is no reason that the FAA would have definitions of LSA, they don't regulate them. The ATSM has a decree that covers all of that.
I try to avoid the use of "Light Sport Aircraft" when talking about Standard Catagory aircraft. I will use the term Sport Pilot eligible. The onus is on the pilot to be sure he is operating an aircraft that he is certificated to operate.
Now, back to the "once out always out", this would apply to LSA as only the manufacturer can approve the increase GW. A Standard catagory aircraft can be modified per an STC by the FAA for increased weight and modified for a reduction in weight per the same proceedures. But, a Sport Pilot can only operate the plane at the lower GW. So if you install a hopper to spray bugs with a GW of 1400, no Sport pilots. Pull the hopper and return to 1200 GW, go fly with your Sport Pilot licence

EO, you just brought up an other word, category, that has 2 meanings with the FAA. They are different in regards to certification of aircraft and pilots. This is from CFR 1.1.

Category:

(1) As used with respect to the certification, ratings, privileges, and limitations of airmen, means a broad classification of aircraft. Examples include: airplane; rotorcraft; glider; and lighter-than-air; and

(2) As used with respect to the certification of aircraft, means a grouping of aircraft based upon intended use or operating limitations. Examples include: transport, normal, utility, acrobatic, limited, restricted, and provisional.

and here is the one for light sport aircraft, and notice it doesn't say anything about ASTM.

Light-sport aircraft means an aircraft, other than a helicopter or powered-lift that, since its original certification, has continued to meet the following:

(1) A maximum takeoff weight of not more than—

(i) 1,320 pounds (600 kilograms) for aircraft not intended for operation on water; or

(ii) 1,430 pounds (650 kilograms) for an aircraft intended for operation on water.

(2) A maximum airspeed in level flight with maximum continuous power (VH ) of not more than 120 knots CAS under standard atmospheric conditions at sea level.

(3) A maximum never-exceed speed (VNE ) of not more than 120 knots CAS for a glider.

(4) A maximum stalling speed or minimum steady flight speed without the use of lift-enhancing devices (VS1 ) of not more than 45 knots CAS at the aircraft's maximum certificated takeoff weight and most critical center of gravity.

(5) A maximum seating capacity of no more than two persons, including the pilot.

(6) A single, reciprocating engine, if powered.

(7) A fixed or ground-adjustable propeller if a powered aircraft other than a powered glider.

(8) A fixed or feathering propeller system if a powered glider.

(9) A fixed-pitch, semi-rigid, teetering, two-blade rotor system, if a gyroplane.

(10) A nonpressurized cabin, if equipped with a cabin.

(11) Fixed landing gear, except for an aircraft intended for operation on water or a glider.

(12) Fixed or retractable landing gear, or a hull, for an aircraft intended for operation on water.

(13) Fixed or retractable landing gear for a glider.

The Taylorcraft is an aircraft that isn't a helicopter or powered lift, so it must be a light sport aircraft if it meets the other requirements in CFR 1.1. This is for what a pilot can fly and not how aircraft were certified.

[RyanShort1]

Re: Looking again

And the head of the light sport division does not agree with you on that interpretation. They even went so far as to reeducate the local FSDO about that.

Ryan

[Edwin Otha]

Re: Looking again

Part 61 discribes the catagory of aircraft a sprot pilot can fly and does not limit them. If you return to CFR 1.1 for the definition of catagory it gives you all kinds of catagory's. Normal, which the Taylorcraft is, and Provisional, that covers the LSA. There is no reason that the FAA would have definitions of LSA, they don't regulate them. The ATSM has a decree that covers all of that.
I try to avoid the use of "Light Sport Aircraft" when talking about Standard Catagory aircraft. I will use the term Sport Pilot eligible. The onus is on the pilot to be sure he is operating an aircraft that he is certificated to operate.
Now, back to the "once out always out", this would apply to LSA as only the manufacturer can approve the increase GW. A Standard catagory aircraft can be modified per an STC by the FAA for increased weight and modified for a reduction in weight per the same proceedures. But, a Sport Pilot can only operate the plane at the lower GW. So if you install a hopper to spray bugs with a GW of 1400, no Sport pilots. Pull the hopper and return to 1200 GW, go fly with your Sport Pilot licence

[3Dreaming]

Re: Looking again

I still disagree. FAR 61.5 give the certification proceedures for the pilots. FAR 61.317 explains the Catagory and Class of aircraft. Now, jump to 21.190 and it tells you how to get a special A/W certificate. Next we go to 21.175 (a) and see that the Taylorcraft is a Standard Catagory but a LSA aircraft is not. They are covered by 21.175 (b) as a Special Catagory. The duration of the A/W is covered in 21.181 para.(1) for the Standard catagory and 21.181 (3) for the LSA (Special Catagory).
If the FAA has gone to these steps to seperate the Catagory of these aircraft,I don't think a general discription is the best way to determine anything regulatory.
EO

EO, nowhere in 61 sub part"J" does it say that a sport pilot can fly anything other than a light sport aircraft, nor does it give a difinition of what a light sport aircraft is. The definition in CFR 1.1 defines the aircraft that can be flown by a sport pilot. This has has nothing to do with how the airplane is certified, but is the requirements that is must meet for a sport pilot to be able to fly it.
The bigger problem is the FAA uses 'LIGHT SPORT AIRCRAFT" in 2 different ways and this is where the confusion comes into play. One use is for the purpose of aircraft certification and the other for pilot certification. While the Taylorcraft does not meet the requirements for light sport aircraft from the certification stanpoint it does from the pilot standpoint. This brings us back to the fact that the airplane must meet the requirements of the CFR 1.1 for a sport pilot to fly it.

[Edwin Otha]

Re: Looking again

I still disagree. FAR 61.5 give the certification proceedures for the pilots. FAR 61.317 explains the Catagory and Class of aircraft. Now, jump to 21.190 and it tells you how to get a special A/W certificate. Next we go to 21.175 (a) and see that the Taylorcraft is a Standard Catagory but a LSA aircraft is not. They are covered by 21.175 (b) as a Special Catagory. The duration of the A/W is covered in 21.181 para.(1) for the Standard catagory and 21.181 (3) for the LSA (Special Catagory).
If the FAA has gone to these steps to seperate the Catagory of these aircraft,I don't think a general discription is the best way to determine anything regulatory.
EO

[3Dreaming]

Re: Looking again

A light sport aircraft is not directly regulated by the FAR's. So following that CFR would mean that you need to maintain your Taylorcraft to the ASTM specs and not the FAR's. And we don't do that. The manufacturer is the only person that can approve a major repair that would take the LSA out of it's specification. This CFR is in place to prevent the manufacturer from building an aircraft to LSA specs and then blanket approve a weight increase, skirting all of the requirements of Part 23.
The FAR's are not an easy read, and open to many differing ideas. I think this is by design, they only tell you what is prohibited never what is allowed.
Your local ASI can tell you that a frog has wings so it doesn't bump its ass when it lands, but with no regulation it's just an opinion.
EO

If the CFR 1.1 definition doesn't apply to the Taylorcraft, then how can it be flown by a sport pilot?
The problem is the FAA use light sport aircraft in 2 different ways. The first is in SLSA and ELSA and the other is what a sport pilot can fly. In CFR 61 it says a sport pilot can fly a light sport aircraft. You have to look to CFR 1.1 to find out what the definition is, and it says,
"Light-sport aircraft means an aircraft, other than a helicopter or powered-lift that, since its original certification, has continued to meet the following:". Note it just says AIRCRAFT and not an aircraft issued a special light sport airwortiness certificate. This has nothing to do with the rules the airplane was manufacturered under, or how it is to be maintained. It is just a definition of what a sport pilot can fly.

[RyanShort1]

Re: Looking again

EO - it hangs on the definitions in 14 CFR 1.1, and any standard category aircraft that a sport pilot wants to fly, MUST meet the definition there.

Ryan

[Edwin Otha]

Re: Looking again

Ryan,
I would say he is trying to create regulation by opinion. The FAA likes you to believe that what they say is gospel. When pressured, they cave in, the FAR's can work for you as well as the FAA.
These little planes were Standard Catagory for the last 70 years and they would like you to believe they now are something different. I don't believe it and until I see some regulations saying all Standard Catagory aircraft, fitting the reqirements, are now considered LSA aircraft. This is the same line the EAA wanted go to 10 years ago. The AAA steped in and told the FAA to do their job, not sluff it off on a user group.
EO

[RyanShort1]

Re: Looking again

Now the way it's writen this rule applies to the LSA certificated aircraft,NOT Standard catagory. If the plane was properly modified and exceeded the Sport Pilot operation limitations it could no longer be operated by a Sport Pilot. If it is modified back to the operation limitations it is again able to be operated by a Sport Pilot. The Taylorcraft is not a LSA aircraft and no LSA specifications apply.
The FAA did publish a document, not a ruling, that they would not allow a decrease in certificated gross weight to meet any LSA/Sport Pilot requirements.
EO

That's not accurate per the head of the FAA's Light Sport division...

Ryan