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Pros and cons changing to E-LSA


Al Downs

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But you can fly E-LSA in furtherance of your own business. And you can legally operate in IMC if you get the normal boilerplate oplims like most other experimentals end up with.

 

This is related to pilot certificate limitations, and not aircraft limitations. For example, sport (and recreational) pilots aren't even allowed to fly in furtherance of their own business, incidental or not. They can ONLY fly for recreational use.

 

Source: http://www.faa.gov/a...erpretation.pdf

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Not anymore.

 

 

This practice is strongly discouraged by the FAA now, and not worth mentioning. It's extremely hard to receive a LODA for an E-LSA, and was meant only to help in the transition and adoption of LSA aircraft in areas that do not have S-LSAs available. The moment an S-LSA becomes available in a region, it's impossible to then get a LODA. There's S-LSAs almost everywhere now.

 

In fact, that is what this provision was related to:

 

-->

§91.319(e)(2) Conduct flight training in an aircraft which that person provides prior to January 31, 2010.

<--

 

The LODA is goverened here:

 

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§91.319

 

(h) The FAA may issue deviation authority providing relief from the provisions of paragraph (a) of this section for the purpose of conducting flight training. The FAA will issue this deviation authority as a letter of deviation authority.

 

(1) The FAA may cancel or amend a letter of deviation authority at any time.

 

(2) An applicant must submit a request for deviation authority to the FAA at least 60 days before the date of intended operations. A request for deviation authority must contain a complete description of the proposed operation and justification that establishes a level of safety equivalent to that provided under the regulations for the deviation requested.

<--

 

 

Also gentlemen, there's one thing I need to put out there. E-LSA is not a total free ticket to do whatever you want. There are certain major alterations that will require a DAR to inspect and re-issue the experimental certificate.

 

That may be, but I saw just last month on another forum where someone had received a LODA for transition training in a RV12.

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This is related to pilot certificate limitations, and not aircraft limitations. For example, sport (and recreational) pilots aren't even allowed to fly in furtherance of their own business, incidental or not. They can ONLY fly for recreational use.

 

Source: http://www.faa.gov/a...erpretation.pdf

That's true. That and night and even marginal VFR are technically out if you operate as sport pilot.

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There's nothing technical about it. A Sport Pilot cannot fly at night and must have 3 miles visibility and visual contact with the ground.

Actually, it's not Sport Pilot but exercising sport pilot privileges. An ATP flying on his driver's license is still and ATP (as he will find out if he is violated, as he will be violated as an ATP, not a Sport Pilot), but he is exercising sport pilot privileges.

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61.315

"(13) Without visual reference to the surface."

 

It looks like the EAA text, which is

"Fly during the daytime using visual flight rules (VFR). Three statute miles visibility and visual contact with the ground are required."

 

was the result of paraphrasing the FAR, as it is not the exact wording of the FAR.

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Who said anything about quoting an FAR?

Huh? In post #32 you made a statement that said an SP cannot operate with visual contact with the ground. The FARs are where one goes to determine pilot privileges. The FARs mention visual reference but jot visual contact. I have no idea what visual contact even means.

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Read what I posted. It is the EAA definition of Sport Pilot privileges and limitations. I did not say or imply I was quoting an FAR. What is wrong you some of you people here?

I'm probably wasting electrons but my correction was meant to be mostly in jest.

 

Without a doubt post 32 did not claim to quote the FAR nor did it claim to quote EAA. This you clarified in post 35. Unfortunately, both your original statement and the EAA narrative are inconsistent with the wording of the FAR. Is it material? Probably not since over on sptalk we couldn't agree what visual reference meant :)

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As a Sport Pilot I wonder how I would inadvertently find myself on IFR conditions. I guess the one way I can imagine is getting caught in snow which can cause very quick deterioration. I have diverted because my reference to the ground was disappearing and I would have been scud running to go below.

If I maintain visual reference to the ground and 3 miles visibility, unless I do something dumb (not ruling it out) living here in the flatland I am trying to think of a situation where I would be caught.

Maybe I am too cautious and haven't put myself in situations that would lead to VFR into IMC. Or am I being naive?

(I realize that it is different in the mountains.)

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It helps being retired. If I need to be on time I won't fly, and I never need to be back at a particular time. If the weather is marginal or if I think I might be entering marginal I don't go.

I have had a bit of foggle training for the express purpose of accidental VFR into IMC. (Disorientation, flight by reference to instruments only, 180° turns by instrument.)

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As an aside, if I ever misspell a word or use it incorrectly, please correct me. I will thank you.

 

My momma and grandma were both "comma hounds" that would point out every little spelling or grammatical mistake - that helped turn me into the flawed human being I am today.

 

In any event, if I do point out a consistent misspelling or misuse - "peddle", "flair", "yolk", "break", and "hanger" all come to mind, it is meant to edify, not mock or criticize. I would assume pilots want to seem professional and both use and spell terms correctly.

 

If I'm wrong on that, or have unintentionally struck a nerve with anyone, I apologize.

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I think I'll probably move on.

 

Please don't.

 

There's good stuff, both here and SportPilotTalk and Pilots of America and, in my case, COPA.

 

Like with spelling or grammar, I actually like being able to say, "I stand corrected". It means I've learned something. It's happened numerous times on each of those sites. For instance, I honestly thought Cheetahs had 160 hp from the factory and was corrected on the PofA site. Live and learn.

 

Then again, the ability for a relatively simple thread on instrument instruction or this thread to devolve into the tiniest details and technicalities is a bit depressing to me. When I sold my Cirrus, I freed myself of all sorts of burdens - no longer have to worry about TKS fluid or SkyWatch malfunctions or hunting autopilots, that sort of thing. And when I fly my last flight (hopefully by choice), it will honestly be such a relief to never have to read, interpret or otherwise worry about FAR's again.

 

But That's Just Me™!

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I think I'll probably move on.

 

No need to move on. You bring some experience to the table from the days before light sport. The thing to remember is that while you have a bunch of knowledge about aviation, some of the people here might have a better understanding of the sport pilot and light sport aircraft rules. I know I have been dealing with light sport for about 7 years now and some of the people around here have been dealing with it longer.

The other thing is some of the people here can be quite head strong and opinionated, myself included. I think you might fit into that group as well. All I can say is hang around you might be able to teach something to somebody, or the tables might be turned.

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I understand the light sport rules. They have created some inconsistencies with previously written FAR's that need to be resolved by the FAA. As a result, there can be and are sometimes several interpretations, none of which are totally correct within the context of all the applicable FAR's.

 

I didn't mean to imply that you don't understand the rules. The new light sport and sport pilot rules while intending to be simple, added a bunch of complexity to many different regulations. It effected parts 1,21,43,45,61,91, and 103.

I have been working with light sport aircraft and sport pilots on a daily basis since 2006, and I doubt I understand all the rules. I do know that I am always looking to the regulations for guidence for all kinds of aviation related questions. I have the link for the electronic federal Aviation regulation saved in my favorites, and use it weekly and sometimes it seems like daily.

 

Here is one simple question where the anwser is not so simple. Who can perform the annual inspection on a light sport aircraft?

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If that question is directed at me, I have never even read the maintenance rules because I don't own one, I rent.

 

I thought you said you understand the light sport rules. I guess you meant to say you understand the sport pilot rules instead.

 

OK, can a sport pilot perform preventive maintenance on a light sport aircraft?

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Preventative maintenance may be performed by a sport pilot only on an S-LSA in which he/she owns or operates. (Experimental can be done by anyone). This is in contrast to standard aircraft, which require at least a private certificate.

 

Additionally, S-LSAs do not have required annuals, they have condition inspections, but annuals can be used instead if so desired. These inspections require an A&P, or an LSA repairman with an inspection rating. Maintenance may only be performed by an LSA repairman with a maintenance rating (or A&P). All LSA repairman ratings are aircraft class specific.

 

EDIT as pointed out below: Non-rated mechanics can also do basic maintenance when supervised, and there are also a bunch of other little nit-picks.

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Anticept,

 

That looks exactly right.

 

Now, to pick nits, can the manufacturer limit or put additional qualifications on what preventive maintenance items can be performed by an owner/operator?

 

My Sky Arrow AMM is quite restrictive in that regard. That was one of the factors that led me to go Experimental (though not the only).

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Hi Eddie,

 

The MFG may put that in the book, but the MFG can not make additional policies or rules above what the FAA has in place. So the SLSA owner/pilot may do any preventive maint. that is listed under the FARs and in this particular case same as a GA pilot.

Here is another rub that I helped correct in some 4 manuals years ago related to SLSA. The LSA MFG must list specifically who can do the work on their SLSA. Example: If they only list that an A&P can do the work LSRM-A is out and same in reverse. This happened with Remos at first. The nice thing about Remos was after I talked with them they made a few corrections within 8 hrs. FD at first wrote that an LSRM-A or higher certificate could do the work. There is no higher certificate in the maint. world only the pilot side so FD had to change the wording and list both.

 

Some MFG's may have some things in writing, but aren't legally binding or correct.

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