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A humble plea: stop saying "LSA"!

j4cbo

Well Known Member
Patron
MOSAIC is in the books, and we're all working on figuring out what it means. It seems super confusing, which is expected for a 700-page government document, but I think there's one big thing that's causing a lot more confusion than it has to: the term "LSA".

Just like the original sport pilot / LSA rule from 2004, MOSAIC is really about two completely different things:
  • A simpler path to getting pilots into the air, with fewer, more modular training requirements and without them ever having to darken an AME's doorstep; and
  • A simpler path to getting airplanes into the air: airworthiness certification via existing ASTM standards that other countries have been using for years, instead of the extensive and arcane 14 CFR Part 23.
The thing that's been messing with everyone's head for the past 21 years is that the original sport / LSA ruling mixed those two things together, defining both of them in terms of a single concept called a "Light-Sport Aircraft". This was defined in FAR 1.1 for a variety of categories and classes, and included various limits on max gross, stall speeds, cruise speed, and so on. Then the sport pilot certificate was defined in terms of being able to fly "LSAs", and the ASTM-based airworthiness standard was also defined for "LSAs", with two new certification types that we call "E-LSA" and "S-LSA". These brought in some neat new features like being able to convert a factory-built aircraft to an experimental, and the ability to have a kit-built aircraft with no 51% requirement.

So LSA has always meant two completely different things: an aircraft that a sport pilot can fly, and an aircraft that can get an ASTM-based airworthiness certificate. They happened to share the same performance requirements, and every ASTM-based aircraft was also flyable by a sport pilot, but the reverse was not true: a sport pilot has always been able to fly any airplane that meets the requirements, like certain Cubs, Champs, Ercoupes, and E-ABs like the Sonex.

MOSAIC has completely split apart these two concepts - they're in different pieces of the regulations (FAR 61 and 91 vs. the newly-created FAR 22). And we have some new terminology too. 61.316 uses the phrase "aircraft that a sport pilot may operate", which is a bit wordy, but oh well. For the ASTM stuff, the new term is "light-sport category aircraft", as used in the new FAR 22. There will be aircraft that a sport pilot may operate, and independently, there will be light-sport category aircraft. Some will fall under neither (a Baron, a Velocity XL, a Cherokee Six), some will be both (the existing fleet of E-LSAs and S-LSAs and surely many new ones over the coming years, like the RV-15). Some are operable by a sport pilot but not light-sport category (the aforementioned Cubs, Champs, Ercoupes... and now, most of the GA fleet, including your everyday Cherokee and Skyhawk and a lot of existing RVs). And in the future, manufacturers may introduce light-sport category airplanes that sport pilots can't fly (because they're too fast, or multi-engine, etc). They're totally unrelated issues.

(Again, "light sport" extends beyond just airplanes, but to keep things simple I'm not talking about any other category here.)

So when someone asks "will this be an LSA", it's hard to tell which definition they're talking about, and it's easy to start looking in the wrong section of the regs. In fact, the old FAR 1.1 definition is scheduled to be deleted completely in 2026. No more LSAs!

Instead, ask:
  • "Can a sport pilot fly this?" - which matters to sport pilots or people considering operating under sport privileges. The answer is pretty simple: check if the clean stall speed is <= 59 kcas plus a few other limitations. This tells you nothing at all about the certification basis or maintenance requirements for that airplane.
  • "Is this, or will this be, a light-sport category aircraft?" - which matters a whole lot to aircraft manufacturers and people doing maintenance, and not much if you just care about flying the thing.
    • For an already-flying airplane, the answer is very simple: check the airworthiness certificate. Does it say 'light sport'? If so, yes; if not, no.
    • For a future design, that's where the 61 kcas dirty figure starts to matter.
 
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