All-in (all-up?) cost??

rvbuilder2002 said:

... This is the standard 100 hr inspection required for any commercial use. Even CFI's renting there RV for transition training using an LOA are required to do 100 hr inspections. I highly doubt (but I may be wrong) that the FAA would require 100 hr inspections for S-LSA aircraft being used for flight training, but not require it if it is only being used for general rental. Only glider towing and flight training is mentioned ...

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As I said earlier, it's a brave new world out there. I expect there to be changes to the FARs as errors and omissions are found. In fact, 91.327 (f) states explicitly "The FAA may prescribe additional limitations that it considers necessary".

Let's hope clarifications are also implicitly included in this sub-part.

- TT

rvbuilder2002 said:

As Mel already said, that is correct.
One thing I find interesting is that a particular issue hasn't gotten more "press" since the LSA rules came out.

The FAA order 8130.2F Change 2 (which can be found here http://rgl.faa.gov/Regulatory_and_Guidance_Library/rgOrders.nsf/0/18b1d64bc8f90136862571d40072d8e1/$FILE/Order%208130F%20with%20chg%202%20incorporated.pdf )

says that the following is one of the required operating limitations for S-LSA aircraft

(10) No person may operate this aircraft in the light-sport category for compensation or hire except to tow a light-sport glider or an unpowered ultralight vehicle in accordance with ? 91.309 or to conduct flight training.

But if you look at 91.319 - Aircraft having experimental certificates, para (f) explicitly prohibits the lease of an experimental aircraft. 91.327 does not have such a prohibition.]

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I agree that 91.327 does not prohibit it but as I quoted above from my previous post, it is a required item in the S-LSA operating limitations.
Operating limitations are issued for S-LSA aircraft as well as E-LSA or E-AB.

I have been wondering about this for a while...I think I will talk to the guys at our local FSDO next week and see what they can find out.

Primary Flight Training

I put a call into EAA just to see if we can get clarification. Should here back from them Monday.

Primary Flight Training in an Expirimental...LONG! ;-)

This morning Tim Bogenhagen from the EAA returned my call, reference primary flight training in an experimental.
For those of you who do not want to read all of this, the answer to our question is, you can certainly do primary
flight training in an experimental aircraft, with a letter of deviation. Now, for the history...

I quote from Tim "It is convoluted information, but here it is," The FAA limits within FAR 91.319, where you cannot
carry persons or cargo for compensation within an experimental aircraft. However,
91.319h DOES allow an individual, for a letter of deviation authority, to operate for compensation
for the purpose of flight training. The regulation does not limit the type of flight training you give (including primary) in any way. So according
to the regulation, if a CFI got that letter of deviation, they could use any type of experimental for compensation for flight
training transition, primary, and so on.
That came out in 2004 in a regulation. Prior to that, it was allowed in an exemption. At that time, it was limited to transition
training, which is where some of the confusion is still there today, and that exemption did limit it to transition only. In order to take the training, you had to have that category and class for that authorization.

Individuals now receive an letter of deviation. The FAA also published a bulletin, which has since
expired. In that bulletin, the FAA did spell out, that primary flight training was not a purpose allowed in expirimentals.
But that bulletin has expired. So there is no guidance, other then what the regulation says.
So bottom line is, if you go to your FSDO, and explain to them what types of training you intend to do, they have the power
to either grant or deny your request.

However, the ELSA kit it may get even cloudier, because when the FAA wrote the rules. They clearly intended
the ELSA not to be used for compensated flight training. When you make your request to the FSDO, that may
influence their decision to say no, versus yes. There really isn't clear guidance, the intention is clear that they do not want experimental
LSAs used for compensated flight training. They only want it used for transition training. But nothing
in the regulations prohibit this currently. Without good solid national guidance, each FSDO will have their
own idea, and create their own ruling on it, and that also would be by individual and plane.

I asked Tim then what were the chances of using an ELSA, such as (and he had already mention the RV-12) for training, and he said honestly
it is going to vary from FSDO. His concern is that there will not be a standard across the country.

So...yes you can provide primary flight training an experimental aircraft, with the letter of deviation. However, it sounds like it is a coin toss whether the FSDO will grant you the letter for primary flight training.

Clear as mud?

For a quicker and easier way to figure out if you're going to do it....call the insurance company about getting a quote using your ELSA for primary training. See what you get for a quote and there you have it - they may or may not insure you, and it may or may not be affordable.

Cheers,
Stein

bgrandorff said:

So...yes you can provide primary flight training an experimental aircraft, with the letter of deviation. However, it sounds like it is a coin toss whether the FSDO will grant you the letter for primary flight training.

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Interesting.
I stand (somewhat) corrected.
It sounds like there is no sure thing...nothing worse than asking the FSDO for something that is not clearly defined (its sometimes bad enough with things that are well defined).