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ELSA - passenger prhohibited?


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I think there time may well be spent updating there own tracking systems and setups when a jetliner can just dissapear........but this is our government at work huh. These light sports are extremly dangerous and the cause for sooooooo much attention.....no wait thats the "big" planes that seem to cause all the problems.

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I believe that ANN is taking the operating limitations out of context.  If you go look at the draft order (8130.2H), you'll find that the table refers to operating limitations imposed during Phase I and Phase II of the initial airworthiness certification issuance and not a blanket prohibition against those types of aircraft.

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I just sent an email to FAA's Craig Holmes who owns this proposal stating my opposition. I encourage others to do the same.

 

We had a saying where I used to work that working with the FAA can be like trying to row a boat still tied to the dock. I hope this is not one of those occassions.

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Here's a copy on an email from Bob Comperini, a light sport advocate and CFI.   In my email to Bob, I asked him if he was aware of this situation.   His answer follows:

 

Roger Kuhn

 

 

Bob wrote me:

 

"Yes, I'm aware of it.. already posted information about it on the Brian ranch list, and have already submitted my comments about it

Stupid FAA doesn't get it... The FAA actually responded to me, claiming it was all just an "editing error". Yea, right.


 

To: Bob Comperini <bob@fly-ul.com>
Subject: Re: Public Comments on Order 8130.2H
From: Craig.Holmes@faa.gov
Date: Tue, 25 Mar 2014 15:07:16 -0400

Dear Mr. Comperini,
Thank you for your comments.  I'll let you know when the order is published and how all the comments I've received were resolved.  I've gotten a lot of feedback about the application for an ELSA airworthiness certificate when the aircraft formerly held an SLSA airworthiness certificate.  During editing half the sentence was accidentally deleted.  The scope intended was related to maintenance and safety directives that were not complied with. 

Sincerely,
Craig Holmes
Manufacturing ASI, AIR-113
950 L'Enfant Plaza, SW - Suite 500
Washington, DC 20024
202-385-6353
We value your feedback.  The AVS Customer Feedback Form:

http://www.faa.gov/about/office_org/headquarters_offices/avs/stakeholder_feedback/air/air200/




From:        Bob Comperini <bob@fly-ul.com>
        AIR-113, Airworthiness Certification Section
To:        Craig Holmes/AWA/FAA@FAA,
Date:        03/25/2014 02:17 PM
Subject:        Public Comments on Order 8130.2H




I make the following comment/objections to the proposed FAA Order 8130.2H:

Appendix C, paragraph 5©(1):

I object to the new limitation that would prohibit flight over a densely populated area, and night flight and IFR flight in Experimental LSA that formerly held a Special LSA certificate, for the following reasons:

(1) There is no basis for adding this restriction. No problem exists in this category over any other form of experimental.

(2) No such limit exists on any other form of experimental aircraft. The operation/maintenance of an E-LSA is no different than any other form of experimental

(3) Experimental LSA that was formerly Special LSA were at least built to the FAA approved ASTM consensus standards, where other forms of experimental planes were not built to any standard. If anything, this makes an argument that E-LSA planes are perhaps better designed than other forms of experimental
aircraft.

While these would be appropriate phase 1 limitations, they are not appropriate phase 2 limitation.

Appendix C, paragraph 5©(1) and 5(e)(5):

I object to issuing this limitation on electric powered aircraft. Although not yet common, electric power is being developed. I suspect we will see more development in the very near future. While I understand the FAA's desire to describe "simple" powerplants, the FAA must not limit these types of powerplants to "reciprocating engines" only. Other forms of power, such as electric, and rotary engines should be allowed.




Robert Comperini
PO Box 3484
Wrightwood, CA 92397

Commercial Pilot
Flight Instructor
Designated Pilot Examiner
Light-Sport Repairman/Maintenance "

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Does anyone know what the difference is between an experimental light sport (ELSA) and an experimental air plane.  (For this purpose)

Both are piloted by certificated pilots. (Flying in conditions they were trained for)
Both can be maintained by the owner/operator. 
Both require the same annual inspection.

Why are they wanting to limit one and not the other?

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Does anyone know what the difference is between an experimental light sport (ELSA) and an experimental air plane.  (For this purpose)

 

Both are piloted by certificated pilots. (Flying in conditions they were trained for)

Both can be maintained by the owner/operator. 

Both require the same annual inspection.

 

Why are they wanting to limit one and not the other?

 

If you mean Experimental Amateur Built (E-AB) there is no essential difference, from a maintenance and airworthiness perspective.  In fact, one can strongly argue that since the ELSA is built according to ASTM standards (even the ones built by owners, since following manufacturer's build practices is a requirement for certification in that category), versus the E-AB that is built according to NO written standard, it is significantly more safe.

 

But this proposed rule change is even worse than that.  It really creates two classes of aircraft *within* ELSA.  Owner-built aircraft subject to no restrictions, and factory built aircraft subject to passenger and airspace limitations.  It makes no sense and is unenforceable as well.

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