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Did we over-react to the LODA requirement?

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Ed_Wischmeyer

Well Known Member
Now that folks are receiving LODAs via email very promptly, it seems to me that the whole LODA fiasco was really not that much of a big deal. Spend two minutes sending in an email, get a LODA. No, mine hasn't come yet, either, and some folks will probably have quite a wait, depending on the FSDO.

My reaction, and it seems to have been widely shared, was that the FAA was going to require voluminous paperwork and that things would be shut down forever, waiting on the FAA. Neither of those seems to be true.

Given past history with the FAA, it was reasonable to expect the worst from them. It now seems plausible that the LODA requirement was to satisfy some internal conflict and that the rules of bureaucracy prevented them from a clear language explanation.

So time to for us all to be big boys and girls, email in the LODA request and get on with more important things, of which there are many.
 
Exactly! Based on some posts, I almost think some people will get their LODA and will still want to argue with the FAA over the whole issue.
 
I did not jump on the bandwagon till a few days after the thread got started here. I do not require a Flight Review for 11-months but if I want to do an IPC, that could generate some flight instructor hours sooner. Figure I would rather get in line and have the paperwork when I need it instead of start the request when I need the paperwork.

I try to follow the rules or at least not intentionally violate them. Typically I look at what the FAA wants as a MINIMUM standard and my preference is to be better than minimum standard.
 
I guess I'd like to understand why the FAA didn't avail themselves of a process that is open to any litigant in any case: appeal. ALJs aren't the final word on anything, if someone appeals the decision. Why did they roll over so quickly?
 
I guess I'd like to understand why the FAA didn't avail themselves of a process that is open to any litigant in any case: appeal. ALJs aren't the final word on anything, if someone appeals the decision. Why did they roll over so quickly?

Apparently the FAA’s legal department agreed with the judge’s interpretation.
 
Now that folks are receiving LODAs via email very promptly, it seems to me that the whole LODA fiasco was really not that much of a big deal. Spend two minutes sending in an email, get a LODA. No, mine hasn't come yet, either, and some folks will probably have quite a wait, depending on the FSDO.

Ed,

I quite agree with you, and I am among those who probably overreacted. There is a part of me that suspected this may equate to nothing more than "speed bump", which is why I twice urged a little patience in the long panic thread over the weekend, but there was another part of me that was afraid I'd never be able to pursue further ratings in the only aircraft I can fly solo under the terms of my hard earned SODA an the associated waiver that requires hand operated brakes.

As my father often says after a long and distinguished career in aviation, "Flying is a series of mistakes consistently corrected correctly." I try to apply that principle not just in aviation, but in all areas of my life.

Incidentally, I don't have my LODA yet, after sending the requisite email on Thursday morning but my FSDO is infamously not among the most responsive. The duty officer extension always goes straight to voicemail, and there is no other way to make it through the electronic phone maze. No office visits are allowed. So... I'm trying to be a little bit more patient.
 
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Appeal?

I guess I'd like to understand why the FAA didn't avail themselves of a process that is open to any litigant in any case: appeal. ALJs aren't the final word on anything, if someone appeals the decision. Why did they roll over so quickly?

Why on Earth would the FAA appeal a court decision that was in their favor? The court decision at the heart of this upheld the FAA's emergency cease and desist order against Warbird Adventures. This judgement possibly came with some unintended consequences to the FAA, but it was a ruling in their favor.

Skylor
 
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What would happen if the FAA were to deny one of these requests? On what would they base that paperwork exercise? Then what?
 
I think that the FAA probably preferred the old interpretation as it applied to E-AB aircraft, but could not have two separate interpretations of 91.315; one for E-AB and another for war birds. Well, at least not after Warbird Adventures took them to court over it..... Which is really what created the issue. The FAA was really given the choice at that point to provide their blessing to war bird joy rides with a new precedent that would accept the argument that taking non pilots up on paid flights in warbirds was instruction, or to apply an equal standard to all holders of a limited AW certificates which prevented it. I think it was a pretty easy choice for them given the publicity over the nine-O-nine accident and the Avenger ditching. I am disappointed that warbird adventures was unable to see the predictable result of their lawsuit. It hurts them, and everyone else.

It seems to me that the FAA understands that owners training in their own E-AB aircraft enhance safety and that the policy makes that scenario an automatic issuance of the LODA.

I did worry some about whether what I saw as reasonable intentions would become impossible due to unintended (but insurmountable) inefficiency, but so far the news is encouraging. I'm very glad to see that LODAs are showing up already. Lets hope it continues.

It is also worth noting that the policy does say that this is a temporary solution, and that a more permanent solution is being developed. I don't know the future but my best guess is future E-AB operating limitations will have the LODA baked in.
 
I have a question about this LODA. If I get one for myself and my RV, how long is it good for? Will I have to get one for every Biennial or anytime I want some training or will it be good for a certain time span?...... Sorry if this has been covered on another thread.
 
A question I have for those who are familiar with LODA’s, are they airplane specific, pilot specific, or both? If I’m granted a LODA in order to receive instruction in my RV8, but then later sell it and either buy or build another experimental airplane, what then? Would I have to apply for another one?
What if you have more than one experimental airplane?
Thanks-
J. Baker
 
I guess I'd like to understand why the FAA didn't avail themselves of a process that is open to any litigant in any case: appeal. ALJs aren't the final word on anything, if someone appeals the decision. Why did they roll over so quickly?

I posted in another thread what I think are the relevant sections of the FARs. It seems pretty clear to me that the LODA requirement has existed in the regs for some time, so it felt to me like the FAA was stretching their own rules by not requiring it in the past. I suspect they were called out on it, and realized they didn't have a leg to stand on.

Honestly, this whole thing seems to me like the FAA was trying to be helpful, then someone abused the rules, the FAA was embarassed, and had to backtrack, but now their trying to keep the peace by fast-tracking LODAs. (The regs say apply at least 60 days before the LODA is needed, so a 1 week turn-around is way above expectations.)

Maybe I'm giving them too much credit, but in this one case it sure seems like they're trying to help pilots out within the constrants of the system.
 
Deep Breath!

I have a question about this LODA. If I get one for myself and my RV, how long is it good for? Will I have to get one for every Biennial or anytime I want some training or will it be good for a certain time span?...... Sorry if this has been covered on another thread.

The answer is in reading the actual document that the FAA posted (here was the draft that EAA re-posted last week, and I think it is what was made final over the weekend): https://www.eaa.org/~/media/1091C7E251904915BBF431FC3EB9B628.ashx

The actual answer is 48 months, but I think that they intend to have a more permanent process before then.

I sure like the tone of this thread better than the things I was seeing over the weekend! Yes, I think the FAA is actually trying to provide a service that they know is important (training in E-AB’s), and are trying to work around the some recently found “bugs” in the rules. No rule making process is perfect, there are always going to be seams that things can fall through, and this is one of them.

I seriously doubt they will bust anyone for this violation while they are waiting for the LODA’s to catch up, honestly (they don’t appear to have any criteria for issuing the LODA’s other than that you have to own and airplane and apply….) - they just want to make sure that all the collars and cuffs match as best they can.

Paul
 
Received my LODA!

I must say I'm pleasantly surprised. I recently began instrument training in my RV-7A and was concerned that a wait for the LODA would delay that.

I emailed the request Thursday night at 9 PM and received the LODA today (Tuesday) at 4 PM. Kudos to the FAA for being on top of this.

To answer some of the questions from above in the thread:
1. The LODA is good for 48 months
2. For an owner, the LODA is specific to the airplane. Trade airplanes, you need a new LODA.
3. For a CFI, the LODA applies across any(?) EAB they may be asked to teach in.
4. To get instruction in your EAB, either you need a LODA for the plane, or the CFI needs one. Both are not required.

You can read the details here in the LODA template:
https://www.faa.gov/licenses_certificates/vintage_experimental/examiners/media/LODA_Template.pdf
 
I received my LODA from the North Texas FSDO today! The way I read the LODA, since I have a LODA for my plane, any CFI qualified to instruct in my plane is authorized to receive compensation for providing the training. Doesn't sound to me like the CFI has to have a LODA too.. That would only come into play, if the plane didn't have a LODA.
 
I received my LODA from the North Texas FSDO today! The way I read the LODA, since I have a LODA for my plane, any CFI qualified to instruct in my plane is authorized to receive compensation for providing the training. Doesn't sound to me like the CFI has to have a LODA too.. That would only come into play, if the plane didn't have a LODA.

The rest of the story is that if you have a LODA for your plane and you should happen to get violated, or if your CFI gets violated, send in a NASA ASRS report -- "get out of jail free." More realistically, if you've got the LODA, you're showing good faith in attempting to comply. Even more realistically, unless you're doing some egregious, the FAA will have less than no interest in doing all the paperwork of an enforcement action.
 
Who knows

Did we over react? Who knows, But, I applied, they replied, I submitted, just waiting for the approval.
Private owner, operator, no CFI's of any sort.
Cover my bases Art
Update: 3 day turn around and it's in my hand. Crazy fast.
 
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Could it be the reason the FSDO is handing out LODA so quickly on the Vans RV is because maturity of the fleet? If you have a much small fleet, or a one off Reno Racer, I wonder how quickly LODA are issued for them.
 
Could it be the reason the FSDO is handing out LODA so quickly on the Vans RV is because maturity of the fleet? If you have a much small fleet, or a one off Reno Racer, I wonder how quickly LODA are issued for them.

I highly doubt the FAA wants anyone to not be able to get training in their own aircraft. That would go against their #1 goal of safety. I also suspect they badly want to close up loopholes that allow otherwise undesired activity being done under the umbrella of training. We could argue about their methods on this issue, but it appears from the outside that they are doing the right things for people operating within their guidelines and you have to be impressed with their speed in dealing with this.

If you are looking for a LODA on a warbird, I would expect a longer review. I would guess that warbird adventures has already applied for one.:rolleyes:
 
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Could it be the reason the FSDO is handing out LODA so quickly on the Vans RV is because maturity of the fleet? If you have a much small fleet, or a one off Reno Racer, I wonder how quickly LODA are issued for them.

I don’t think so. The FAA has been pretty clear, they mis-wrote the rules, they meant to prohibit EAB owners from receiving compensation for the use of their aircraft, but never intended for EAB owners to be prohibited from receiving training for hire. The faa policy statement simply says that they have determined that any EAB owner meets the criteria to be given a loda for training purposes.
 
What are you going to do if they decide not to give you the LODA? And if you say, why wouldn’t they, then my question is why require a LODA if everyone will get one?

Secondly, I’m concerned about the ramifications of this on instructors with no commercial or 2nd class medical. In my opinion, removing the long standing assumption that instruction is not flying for hire means you need a commercial and a 2nd class to instruct.

And thirdly, I’m concerned that the extra headache of pointless paperwork might induce some to not get training they would have if it were more straightforward.
 
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W

And thirdly, I’m concerned that the extra headache of pointless paperwork might induce some to not get training they would have if it were more straightforward.

It took me 2 minutes to write the email and a couple of days later the LODA showed up. Can't see how 2 minutes of effort is going to keep someone from getting training. Let's try to be reasonable here. I am certain the FAA had reasons for doing it this way and they have really stepped up being sure the burden didn't fall upon pilots. I am actually impressed with how easy they made it and it could have been a lot worse for us.
 
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What are you going to do if they decide not to give you the LODA? And if you say, why wouldn’t they, then my question is why require a LODA if everyone will get one?

...

And thirdly, I’m concerned that the extra headache of pointless paperwork might induce some to not get training they would have if it were more straightforward.

I think this is the concern from the perspective of the EAA regarding the arbitrariness of how quickly the LODA rules and approval process are changed. It is easy this week but will the next FAA administrator be as EAB friendly? So if the rules continue to be influx, the next potential owner/builder of EAB will just skip the whole thing and purchase an older C172 knowing the uncertainty down the road.
 
It took me 2 minutes to write the email and a couple of days later the LODA showed up. Can't see how 2 minutes of effort is going to keep someone from getting training. Let's try to be reasonable here. I am certain the FAA had reasons for doing it this way and they have really stepped up being sure the burden didn't fall upon pilots. I am actually impressed with how easy they made it and it could have been a lot worse for us.

They made it easy to get authority to do something you previously had authority to do, does nothing to make anyone safer, and possibly has wider ramifications as I mentioned in point 2. Yay Faa!
 
I think this is the concern from the perspective of the EAA regarding the arbitrariness of how quickly the LODA rules and approval process are changed. It is easy this week but will the next FAA administrator be as EAB friendly? So if the rules continue to be influx, the next potential owner/builder of EAB will just skip the whole thing and purchase an older C172 knowing the uncertainty down the road.

I think the EAB fleet is too large and with a good enough safety record for a new administrator to just pull the plug on EAB. Without justification, they can't just do an about face on a multi-decade policy without serious blowback.
 
I'm still on the edge of my seat...

  • I'm in the "middle" of some important training.
  • I fly on a waiver which means I can only fly PIC in one particular aircraft, which is equipped accordingly.
  • I was among the earliest applicants as I had seen the guidance early on Thursday and immediately sent the required information via the published email.
  • My local FSDO does not answer the phone, nor return voicemails, and they have posted guidance that says the cannot accept in person traffic due to national security concerns. (I think this last bit is probably not legal, but I don't want to get sideways with the FSDO.)
So, by making it impossible to communicate with them, my local FSDO apparently does things according to their own timelines, if at all.

I guess I can only continue to wait, and lose at least some of the benefit of the training I've already completed in the meantime.
 
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This thread has, I think run its course, to put it politely. Excessively politely.

Time for some kindly moderator to stop the discussions.
 
I think the EAB fleet is too large and with a good enough safety record for a new administrator to just pull the plug on EAB. Without justification, they can't just do an about face on a multi-decade policy without serious blowback.

The point I was trying to make is the how quickly the FAA pivot on the LODA rules after agreeing to another interpretation it for many years. If it had done it today, there is no stopping it from changing the rules to something else, with no input from the public and other representative organizations. Now if there is a regulation that says "EAB owner shall be permitted to use own aircraft for training.... " then it will be a lot tougher to change. We never had it and we don't have it today.
 
[*]My local FSDO does not answer the phone, nor return voicemails, and they have posted guidance that says the cannot accept in person traffic due to national security concerns. (I think this last bit is probably not legal, but I don't want to get sideways with the FSDO.)

So, by making it impossible to communicate with them, my local FSDO apparently does things according to their own timelines, if at all.

I guess I can only continue to wait, and lose at least some of the benefit of the training I've already completed in the meantime.


Now if there are some concrete regulations saying EAB owner can use own aircraft for training, we can all tell the FAA to pound sand; instead of waiting for permissions that can be revoked at any time.
 
What are you going to do if they decide not to give you the LODA? And if you say, why wouldn’t they, then my question is why require a LODA if everyone will get one?

Secondly, I’m concerned about the ramifications of this on instructors with no commercial or 2nd class medical. In my opinion, removing the long standing assumption that instruction is not flying for hire means you need a commercial and a 2nd class to instruct.

And thirdly, I’m concerned that the extra headache of pointless paperwork might induce some to not get training they would have if it were more straightforward.

1. The loda is the quickest fix to what the faa acknowledges was their mistake. They will now take their time to get the rule re-written as was always intended.
2. (A) All CFIs hold at least a commercial license.(b) I don’t think the court ruling went that far. It basically said that no one on board could be paid, regardless of whether they were PIC or not, or even if they had no medical. (C) Basic med came from Congress - it’s the law - and that law reinforced the idea that instruction is not flying for hire. I’m not too worried, but of course, you never know.
3. Turns out the faa did a good job, and all that is needed is an email account and two minutes of your time.
 
1. The loda is the quickest fix to what the faa acknowledges was their mistake. They will now take their time to get the rule re-written as was always intended.
2. (A) All CFIs hold at least a commercial license.(b) I don’t think the court ruling went that far. It basically said that no one on board could be paid, regardless of whether they were PIC or not, or even if they had no medical. (C) Basic med came from Congress - it’s the law - and that law reinforced the idea that instruction is not flying for hire. I’m not too worried, but of course, you never know.

All CFI’s do not hold commercial licenses. Sport CFI does not require it.
 
I'm still on the edge of my seat...

  • I'm in the "middle" of some important training.
  • I fly on a waiver which means I can only fly PIC in one particular aircraft, which is equipped accordingly.
  • I was among the earliest applicants as I had seen the guidance early on Thursday and immediately sent the required information via the published email.
  • My local FSDO does not answer the phone, nor return voicemails, and they have posted guidance that says the cannot accept in person traffic due to national security concerns. (I think this last bit is probably not legal, but I don't want to get sideways with the FSDO.)

A little patience was indeed the order of the day. I received my LODA early this morning. It contained one error, which was quickly addressed with a couple of emails. My CFI also received his LODA today.

I would suggest that now that there is a "template" available, new applicants use it. Had it been available when I applied, the opportunity for error would have been reduced.

Anyway, it took a tad longer than some, but my FSDO district is comparatively large. I suspect they're working through a good sized backlog.

Today is a good day, and while arguments can be made as to the policy, I think the FAA is doing a good job addressing the gap until it can be closed in the regulations directly.
 
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Did we over-react to the LODA requirement

I will admit that I overreacted in one sense. I got my LODA today and would have bet good money last week that no one would see LODA's for weeks. So I was wrong about the timing and the FAA gets my compliments for responding so quickly.

But my understanding of that court case is that the way it was published, it was not precedent for other cases. That the ruling only applied to that one operator.

So I still see this as a lot of wasted effort on the part of the FAA and effort that has no real benefit. But that is just my opinion.

Again I congratulate the FAA on their timely response and issuance of LODA's.
 
I don't think we are over reacting. Federal Register 21-14765 states:

...The FAA generally limits LODAs to training that can only be accomplished in aircraft with experimental certificates and directs its inspectors that, with a few exceptions, LODAs should not be issued to permit flight training in experimental aircraft leading toward the issuance of a pilot certificate, rating, or operating privilege... (emphasis added)

The approved LODA template received this week by one of my friends starts out:

Letter of Deviation Authority
Deviation Authority for Conducting Flight Training in
Experimental Category Aircraft (14 CFR Section 91.319 (h))


A. The owner (or delegate) or authorized instructor listed at the bottom of this document is authorized this Letter of Deviation Authority (LODA) in accordance with the provisions of Title14 Code of Federal Regulations (CFR) Section 91.319(h) to the extent necessary to receive or provide aircraft-specific training in an aircraft certificated in the experimental category in accordance with the limitations and provisions of this LODA....


Thus, in my understanding, training for a SEL Private pilot license, or IFR training is NOT "aircraft specific". That is, the training is good in airplanes besides the one being trained in. Therefore, the LODA will not allow me to obtain IFR training in the IFR capable EAB aircraft that I recently completed.

I applied for a LODA so I can get transition training, even during phase 1, but I think its no good for IFR training (??)

Thats a big deal to me!
 
I don't think we are over reacting. Federal Register 21-14765 states:

...The FAA generally limits LODAs to training that can only be accomplished in aircraft with experimental certificates and directs its inspectors that, with a few exceptions, LODAs should not be issued to permit flight training in experimental aircraft leading toward the issuance of a pilot certificate, rating, or operating privilege... (emphasis added)

The approved LODA template received this week by one of my friends starts out:

Letter of Deviation Authority
Deviation Authority for Conducting Flight Training in
Experimental Category Aircraft (14 CFR Section 91.319 (h))


A. The owner (or delegate) or authorized instructor listed at the bottom of this document is authorized this Letter of Deviation Authority (LODA) in accordance with the provisions of Title14 Code of Federal Regulations (CFR) Section 91.319(h) to the extent necessary to receive or provide aircraft-specific training in an aircraft certificated in the experimental category in accordance with the limitations and provisions of this LODA....


Thus, in my understanding, training for a SEL Private pilot license, or IFR training is NOT "aircraft specific". That is, the training is good in airplanes besides the one being trained in. Therefore, the LODA will not allow me to obtain IFR training in the IFR capable EAB aircraft that I recently completed.

I applied for a LODA so I can get transition training, even during phase 1, but I think its no good for IFR training (??)

Thats a big deal to me!

By your interpretation, a BFR is also not allowed, as that also could be done in a different plane.

First "Aircraft Specific" is not defined in the LODA and therefore doesn't really have a lot of merit. Legal docs need to be specific and unambiguous, that is why they are so long in most cases. If a reasonable person can't understand what is allowed or denied in a regulation or contract, few courts would rule against them. Second, it goes on to state in accordance with the limitations of this LODA. Nothing in those limitations prevents training by type or category, nor does it only allow specific types or training. Your welcome to your interpretation, but the way this is worded, the FAA has no case against you if you do IFR training under this LODA, IMHO.

If the FAA truly wanted to prevent you from doing IFR or PPL training under this LODA, I have all confidence that it would have been explicitly limited or excluded in the LODA itself. Not saying they won't go there some day, but it is clear that is not their intent in the LODA. It's unlikely that their attorneys were too inexperienced to miss that.

Larry
 
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I am very sure you are over-reading the wording. Mine says ""The owner or operator is authorized to receive flight training in the following aircraft" and mine is listed. Training to me means anything the flight instructor wants to teach me or provide advice on my performance; or any other interpretation of training. It goes on to explicitly state that I can pay my instructor market rate but nothing for the plane itself.

It would be nice if it said the words check ride (or similar), but since every inspector for one is an instructor first, I would have no problems interpreting for that purpose. I would pay them market rate for the check ride and off we go.

It's pretty obvious the FAA wants us to get instruction in our experimental aircraft. The LODA actually gives them formal control to have insight to who is operating outside the intent.
 
The fact that the FAA considers flight training in an experimental to be a deviation from accepted standards is problematic.

Sending out hundreds if not thousands of deviations is problematic. A deviation is not supposed to be the defacto standard. The fact that the FAA's wonderful quick fix is to normalize deviation is a problem.

Are you comfortable with the FAA considering your getting training in your own aircraft to be a deviation? I'm not.

The LODA is giving you authority to do something you're normally not supposed to do. Are you really ok with looking at training that way?
 
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Yes for the time being. Laws and regulations can take years to change. They came up with a very short term fix to what is going to be a long problem. So I'm satisfied.

Let me give you another example: flight simulator use for IFR proficiency, without an instructor present. Getting this fixed took 4-5 years.

Who wants to wait 4-5 years for a legal entanglement on instruction to get sorted out? I'll take the LODA, thank you.
 
FAA

The fact that the FAA considers flight training in an experimental to be a deviation from accepted standards is problematic.

Sending out hundreds if not thousands of deviations is problematic. A deviation is not supposed to be the defacto standard. The fact that the FAA's wonderful quick fix is to normalize deviation is a problem.

Are you comfortable with the FAA considering your getting training in your own aircraft to be a deviation? I'm not.

The LODA is giving you authority to do something you're normally not supposed to do. Are you really ok with looking at training that way?

Thank you to someone who UNDERSTANDS the problem, a voice of reason among hundreds of sheeple.This is just the beginning of very bad problems for EAB.
 
The fact that the FAA considers flight training in an experimental to be a deviation from accepted standards is problematic.

Sending out hundreds if not thousands of deviations is problematic. A deviation is not supposed to be the defacto standard. The fact that the FAA's wonderful quick fix is to normalize deviation is a problem.

Are you comfortable with the FAA considering your getting training in your own aircraft to be a deviation? I'm not.

The LODA is giving you authority to do something you're normally not supposed to do. Are you really ok with looking at training that way?

An Experimental aircraft already gives you the authority to do things you "Normally" aren't supposed to do. Maintenance on EAB is one example. So yes, I'm comfortable with the situation. It's not a deviation" from accepted standards, but rather permission to use EAB in a way that is normally prohibited. It's the best of both worlds!

-Marc
 
An Experimental aircraft already gives you the authority to do things you "Normally" aren't supposed to do. Maintenance on EAB is one example. So yes, I'm comfortable with the situation. It's not a deviation" from accepted standards, but rather permission to use EAB in a way that is normally prohibited. It's the best of both worlds!

-Marc

Way to bend over backwards to find the half full glass.

You have accepted that training in your own aircraft is "normally prohibited". This is a bad idea. Bad for you, bad for the FAA, bad for GA, bad for EAB, bad for the public in general.
 
If I understand this LODA issue correctly I can receive my BFR and IPC in my aircraft, an RV9, without a LODA so long as no compensation is being offered to the CFI.
Is this the consensus?
 
If I understand this LODA issue correctly I can receive my BFR and IPC in my aircraft, an RV9, without a LODA so long as no compensation is being offered to the CFI.
Is this the consensus?

Just the opposite.
https://www.aopa.org/news-and-media/all-news/2021/july/11/aopa-blasts-faa-flight-training-directive

Following lines are Copy/Paste from above link:

FAA prosecutors pursuing CFIs providing training for ‘free’

Anyone giving or receiving instruction in a limited, primary, or experimental category aircraft is at risk

The FAA alleged volunteer instructors received compensation by “accumulating flight time” and “generating goodwill.” In other words, the FAA believes giving away your time and talent equates to compensation.
 
Just the opposite.
https://www.aopa.org/news-and-media/all-news/2021/july/11/aopa-blasts-faa-flight-training-directive

Following lines are Copy/Paste from above link:

FAA prosecutors pursuing CFIs providing training for ‘free’

Anyone giving or receiving instruction in a limited, primary, or experimental category aircraft is at risk

The FAA alleged volunteer instructors received compensation by “accumulating flight time” and “generating goodwill.” In other words, the FAA believes giving away your time and talent equates to compensation.

Thank you for sharing that link. However, I do not interpret the article as you do. Nor can I find that “copy and paste” you mention or the other quotations you site immediately above.
I guess I’ll have to do further investigation to satisfy myself of the intention of this FAA policy.
 
You have accepted that training in your own aircraft is "normally prohibited". .

This is simply not true. The FAA has openly said that they screwed up, they think training is a good idea, they never intended to prohibit it. Until a month ago they encouraged it. The LODA process is a quick fix until the FAR can be re-written. In an ideal world, there would be no LODA, the FAR itself would be re-written as originally intended and approved in two hours. But of course such speed rarely happens in government. The FAA is to be congratulated for moving as fast as it did, even if not perfect.

As to those worried about the phrase ‘aircraft specific training’, it simply means training in a specific aircraft, nothing more or less. I hold one of the older LODAs which allowed me to charge for the airplane: it says, “…aircraft specific TRANSITION TRAINING ONLY…” (emphasis added). See the difference?
 
This is simply not true. The FAA has openly said that they screwed up, they think training is a good idea, they never intended to prohibit it. Until a month ago they encouraged it. The LODA process is a quick fix until the FAR can be re-written. In an ideal world, there would be no LODA, the FAR itself would be re-written as originally intended and approved in two hours. But of course such speed rarely happens in government. The FAA is to be congratulated for moving as fast as it did, even if not perfect.

As to those worried about the phrase ‘aircraft specific training’, it simply means training in a specific aircraft, nothing more or less. I hold one of the older LODAs which allowed me to charge for the airplane: it says, “…aircraft specific TRANSITION TRAINING ONLY…” (emphasis added). See the difference?

You just said it’s not true, and then proceeded to agree with me. The situation we are in right now, since “a month ago”, is that training in experimental aircraft is not approved, it is considered a deviation. We must petition for a waiver to train in them.

Let’s hope they fix it, but we shouldn’t be pretending like it’s not a screw up, we should be continuing to press for a proper fix.

They could have dealt with the p-40 operator without creating this mess. He was violating the rules as they were, there was no need to change them on everyone else to stop him.

But, if we don’t object to having training in our personal aircraft being considered abnormal, then we are fools that deserve what we get.
 
So when I receive training in my EAB should I write in my log book Aircraft specific training and then what we did?
 
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