MOSAIC NPRM

[j4cbo]

So that means one can't exercise sport pilot privileges while flying an experimental aircraft that has previously obtained a special airworthiness certificate (not in the LSA category)?

No. One can exercise sport pilot privileges in any aircraft as long as it meets the applicable performance requirements - it doesn't matter what style of airworthiness certificate it has (standard, E-AB, E-LSA, S-LSA, whatever). This is true now and will continue to be true under the proposed MOSAIC rules.

Here's what the new proposed rules are for what Sport Pilots will be able to operate. This is straight from pages 296-297 of the NPRM, except that I've edited it down to remove references to anything other than land-based airplanes:

§ 61.316 What are the performance limits and design requirements for the aircraft that a sport pilot may operate?

If you hold a sport pilot certificate, you may act as pilot in command of an aircraft that, since its original certification, meets the following requirements:
(1) A maximum stalling speed or minimum steady flight speed without the use of lift-enhancing devices (VS1) of [...] not more than 54 knots CAS at the aircraft’s maximum certificated takeoff weight and most critical center of gravity.
(2) A maximum seating capacity of [...] four persons.
(3) A non-pressurized cabin, if equipped with a cabin.
(4) [...] a fixed or ground-adjustable propeller, except as provided in paragraph (b) of this section.
(7) [...] the loss of partial power would not adversely affect directional control of the aircraft and the aircraft design must allow the pilot the capability of establishing a controlled descent in the event of a partial or total powerplant failure.
(11) [...] fixed landing gear except as provided in paragraph (b) of this section.
(b) If you hold a sport pilot certificate, you may act as pilot in command of an airplane that, since its original certification, has retractable landing gear or a controllable pitch propeller if you have met the training and endorsement requirements specified in § 61.331.

-

Or, put more simply, a Sport Pilot would be able to operate any airplane whatsoever with VS1 <= 54 KCAS, 4 seats or fewer, unpressurized, and that doesn't become uncontrollable in the event of power loss; an endorsement would be required if it has a controllable pitch (e.g. constant speed) prop or retractable gear.

The new MOSAIC rules draw a clearer divide between aircraft that a sport pilot may operate and special aircraft certification. The latter is what does not apply to existing experimental aircraft. The proposed 61.316 would let sport pilots fly many existing E-ABs, but the airworthiness certificate of those E-ABs would not and could not change.

 

[Michael Burbidge]

Vs1 is not listed in original certification documents (operating limitations, post phase two log entry) for my RV-9. I suspect that is true for many others as well. Vs0 is.

So can it be flown by a sport pilot or not under these new rules? Can I re-enter phase one resting to add a log entry containing Vs1 speed. This aspect of the ruling is under specified.

 

[lr172]

N

The new MOSAIC rules draw a clearer divide between aircraft that a sport pilot may operate and special aircraft certification. The latter is what does not apply to existing experimental aircraft. The proposed 61.316 would let sport pilots fly many existing E-ABs, but the airworthiness certificate of those E-ABs would not and could not change.

I am new to all of this and question is mostly out of curiosity. EAB special airworthiness certs DO NOT include V speeds, nor is there a type cert that specifies them. That is done via a logbook entry made after Phase I completion (not sure if VS1 was even in the required wording for that entry). So , does that log entry essentially become part of the A/W cert? How else would it be unchangeable. Why couldn't you just make a "major change," like adding vortex generators, that requires re entry into phase I, which then also requires testing and a new V speed entry based upon the results of that testing? Pretty sure that the op lim's require the entry of new V speeds if a major change affects them. In fact, that was the whole point of the major change.

Larry

 

[RV8JD]

Adding vortex generators to an RV should drop the stall speed. In my 182 it gave me about 4 knots indicated

Depends on the airplane, wing design, airfoil section, VG design, etc. Nigel Speedy did some extensive flight testing on his RV-8 to identify the effect of VG's on several different performance parameters. One thing he did not test was the chordwise location of the VG's.

On his RV-8 the wing VG's reduced the cruise speed by approximately 4 KTAS (The table below shows 5 KTAS, but 1 KTAS was due to the VG's installed on the underside of the horizontal stab).

Note that the stall speeds were unchanged.

KitPlanes article--> https://www.kitplanes.com/vortex-generators-on-an-rv-8/

 

[CF86301]

Splitting the baby

Having worked for a different three-letter agency, I recognize one of the FAA's arguments for the 54 KCAS VS1 as a classic "split the baby" argument:

"The FAA chose a VS1 of 54 knots CAS to strike a balance between allowing heavier aircraft to accommodate increased safety features, while increasing the stalling speed no more than necessary to retain low speeds during approach and landing."

To me, the fact that it's that kind of argument opens it to criticism based on lack of a good scientific rationale. Also, the phrase "low speeds during approach and landing" would seem to facilitate an argument for changing it from 54 KCAS VS1 to 54 KCAS VS0, because most of the time, you'll be using flaps during approach and landing.

 

[rmartingt]

Having worked for a different three-letter agency, I recognize one of the FAA's arguments for the 54 KCAS VS1 as a classic "split the baby" argument:

"The FAA chose a VS1 of 54 knots CAS to strike a balance between allowing heavier aircraft to accommodate increased safety features, while increasing the stalling speed no more than necessary to retain low speeds during approach and landing."

To me, the fact that it's that kind of argument opens it to criticism based on lack of a good scientific rationale. Also, the phrase "low speeds during approach and landing" would seem to facilitate an argument for changing it from 54 KCAS VS1 to 54 KCAS VS0, because most of the time, you'll be using flaps during approach and landing.

And of course it's just a total coincidence that 54kt converts almost exactly to 100 km/hr

 

[AeroEngineer]

Rian Johnson talked about this in the "What's happening at Van's" presentation at Oshkosh this week. If you watch the video that Brian 'Brantel' Chesteen was kind enough to live-stream and post, fast-forward to about 45:50...

https://www.youtube.com/watch?v=gO1pKlyPqvk#t=2750

... Rian talks about how the FAA's 54-knot VS1 is too low (in Brazil it's 61) and would take the RV-10 and -14 "out of contention", how he's talking with the FAA about it, and how Van's will write and send out a recommended message for folks to comment in the NPRM, because a unified message (he says) will be more effective than random opinions.

 

[Tacco]

No. One can exercise sport pilot privileges in any aircraft as long as it meets the applicable performance requirements - it doesn't matter what style of airworthiness certificate it has (standard, E-AB, E-LSA, S-LSA, whatever). This is true now and will continue to be true under the proposed MOSAIC rules.

Here's what the new proposed rules are for what Sport Pilots will be able to operate. This is straight from pages 296-297 of the NPRM, except that I've edited it down to remove references to anything other than land-based airplanes:

§ 61.316 What are the performance limits and design requirements for the aircraft that a sport pilot may operate?

If you hold a sport pilot certificate, you may act as pilot in command of an aircraft that, since its original certification, meets the following requirements:
(1) A maximum stalling speed or minimum steady flight speed without the use of lift-enhancing devices (VS1) of [...] not more than 54 knots CAS at the aircraft’s maximum certificated takeoff weight and most critical center of gravity.
(2) A maximum seating capacity of [...] four persons.
(3) A non-pressurized cabin, if equipped with a cabin.
(4) [...] a fixed or ground-adjustable propeller, except as provided in paragraph (b) of this section.
(7) [...] the loss of partial power would not adversely affect directional control of the aircraft and the aircraft design must allow the pilot the capability of establishing a controlled descent in the event of a partial or total powerplant failure.
(11) [...] fixed landing gear except as provided in paragraph (b) of this section.
(b) If you hold a sport pilot certificate, you may act as pilot in command of an airplane that, since its original certification, has retractable landing gear or a controllable pitch propeller if you have met the training and endorsement requirements specified in § 61.331.

-

Or, put more simply, a Sport Pilot would be able to operate any airplane whatsoever with VS1 <= 54 KCAS, 4 seats or fewer, unpressurized, and that doesn't become uncontrollable in the event of power loss; an endorsement would be required if it has a controllable pitch (e.g. constant speed) prop or retractable gear.

The new MOSAIC rules draw a clearer divide between aircraft that a sport pilot may operate and special aircraft certification. The latter is what does not apply to existing experimental aircraft. The proposed 61.316 would let sport pilots fly many existing E-ABs, but the airworthiness certificate of those E-ABs would not and could not change.

Ok...but there is something I just don't get. The LSA market essentially exists so that no-medical Sport Pilots have something to fly and maintain. If a Sport Pilot can fly any aircraft that meet the requirements above.....why would a manufacture (at least a kit manufacturer like Van's) even bother getting a new LSA approved? And...doesn't this sort of kill, or at least wound, their RV-12 line?

 

[Mel]

NOPE....It's not just about flying.....

Ok...but there is something I just don't get. The LSA market essentially exists so that no-medical Sport Pilots have something to fly and maintain. If a Sport Pilot can fly any aircraft that meet the requirements above.....why would a manufacture (at least a kit manufacturer like Van's) even bother getting a new LSA approved? And...doesn't this sort of kill, or at least wound, their RV-12 line?

A sport pilot can already fly any aircraft that meets LSA operating parameters. these parameters are simply being expanded.

A sport pilot cannot maintain any aircraft other than an S-LSA or E-LSA.

And he/she must have a repairman certificate to maintain and inspect an S-LSA, and must have a repairman certificate to sign off the condition inspection on an E-LSA.

 

[CF86301]

Don't copy and paste boilerplate comments, please.

Rian [Johnson] talks about how the FAA's 54-knot VS1 is too low (in Brazil it's 61) and would take the RV-10 and -14 "out of contention", how he's talking with the FAA about it, and how Van's will write and send out a recommended message for folks to comment in the NPRM, because a unified message (he says) will be more effective than random opinions.

I don't know how things work at the FAA, but at the three-letter agency I worked for, boilerplate cut-and-paste comments received less respect than comments people made in their own words, with their own arguments. That having been said, a consensus single number on what VS1 the FAA should adopt (or maybe the FAA should adopt a VS0 of 54 KCAS) would be very useful.

 

[Tacco]

I get that Mel but prior to LSAs, someone like Vans, or Cessna for that matter, did not have an aircraft that met LSA performance standards. Now they have several. Why produce an LSA (to new standards) when they don’t have to?

Put another way, the FAA might have saved a lot of ink in this ruling by simply expanding the Sport Pilot parameters (as they have done). Why have an LSA aircraft standard/certification anymore.

The only thing I can think of it that it may make it easier (cheaper) for aircraft manufacturers to produce aircraft under relaxed regs.

 

[gasman]

I get that Mel but prior to LSAs, someone like Vans, or Cessna for that matter, did not have an aircraft that met LSA performance standards. Now they have several. Why produce an LSA (to new standards) when they don’t have to?

Put another way, the FAA might have saved a lot of ink in this ruling by simply expanding the Sport Pilot parameters (as they have done). Why have an LSA aircraft standard/certification anymore.

The only thing I can think of is that it may make it easier (cheaper) for aircraft manufacturers to produce aircraft under relaxed regs.

Correct.................................

 

[PhatRV]

I get that Mel but prior to LSAs, someone like Vans, or Cessna for that matter, did not have an aircraft that met LSA performance standards. Now they have several. Why produce an LSA (to new standards) when they don’t have to?

Put another way, the FAA might have saved a lot of ink in this ruling by simply expanding the Sport Pilot parameters (as they have done). Why have an LSA aircraft standard/certification anymore.

The only thing I can think of it that it may make it easier (cheaper) for aircraft manufacturers to produce aircraft under relaxed regs.

This new standards open up new certifications for more variety of LSA including electric and turbine, and possibly other human rated drones. The drones fall into the psuedo-gyro-copter stuff. There is a lot more than just the 54kt stall speed.

 

[Phyrcooler]

A sport pilot can already fly any aircraft that meets LSA operating parameters. these parameters are simply being expanded.

A sport pilot cannot maintain any aircraft other than an S-LSA or E-LSA.

And he/she must have a repairman certificate to maintain and inspect an S-LSA, and must have a repairman certificate to sign off the condition inspection on an E-LSA.

I get that Mel but prior to LSAs, someone like Vans, or Cessna for that matter, did not have an aircraft that met LSA performance standards. Now they have several. Why produce an LSA (to new standards) when they don’t have to?
<snip>
The only thing I can think of it that it may make it easier (cheaper) for aircraft manufacturers to produce aircraft under relaxed regs.

This is an area of the proposed regs that nobody seems to be talking about. If I’m not incorrect, that the related “light-sport aircraft” ASTM standards will likewise be amended. Could this not mean that a new aircraft could be built having the increased accompanying performance parameters, and enjoy the advantages of ASTM certification process? Importantly also meaning no 51% and the ability to obtain an inspection or maintenance (LSRI / LSRM) certification by taking a class. (Think of all the difficulties currently discussed trying to book time with an A&P for your annual) If my assumptions are correct, i see this as an exciting thing for those on the frontlines of trying to keep GA alive.

 

[AeroEngineer]

...boilerplate cut-and-paste comments received less respect than comments people made in their own words, with their own arguments.

Ok, that's a good point. Something for us to talk about out when the FAA opens it up for comments.

...why would a manufacturer (at least a kit manufacturer like Van's) even bother getting a new LSA approved?

How many new airplanes does Cirrus sell per year? About 600 to 700, right? To me, this implies that there would be a decent market for factory-built RV-10s... especially if they could be flown without a medical.

And imagine how much fun it would be to go to your local flight school and, instead of renting a 152 or a Cherokee (with a panel that looks like something from World War 2), to rent an RV-14A and go pull some g.

Could this not mean that a new aircraft could be built having the increased accompanying performance parameters, and enjoy the advantages of ASTM certification process? (...) If my assumptions are correct, i see this as an exciting thing for those on the frontlines of trying to keep GA alive.

Exactly.

 

[N8DAV8R]

I get that Mel but prior to LSAs, someone like Vans, or Cessna for that matter, did not have an aircraft that met LSA performance standards. Now they have several. Why produce an LSA (to new standards) when they don’t have to?

For one, because there is likely to be an expanding market of pilots who choose a sport license because it will meet most people’s needs. The utility of a sport license is vastly increased.

As for ‘why an RV-12…some people want airplanes that burn less than 4gph. It’s also an incredibly affordable and modern TAA for time building.

 

[Tacco]

Yep, lots to discuss here. Going to be entertaining. Get the popcorn maker annual'd!

It hurts my head to read, but what does Cessna have to do to get the C-172 recertified as a LSA, if its even permitted.

And then...who can maintain it??

Seems like there are pathways to significantly decrease in cost of ownership here.

If I were an A&P, I'd be watching this closely. Do they have a union?

 

[Mel]

Yep, lots to discuss here. Going to be entertaining. Get the popcorn maker annual'd!
It hurts my head to read, but what does Cessna have to do to get the C-172 recertified as a LSA, if its even permitted.
And then...who can maintain it??
Seems like there are pathways to significantly decrease in cost of ownership here.
If I were an A&P, I'd be watching this closely. Do they have a union?

A Cessna is and will always be a Cessna. A Piper is and will always be a Piper.

NOTHING can be re-certificated as LSA!

This new rule is simply a broadening of the LSA parameters to expand what a Sport Pilot can fly.

 

[Tacco]

A Cessna is and will always be a Cessna. A Piper is and will always be a Piper.

NOTHING can be re-certificated as LSA!

This new rule is simply a broadening of the LSA parameters to expand what a Sport Pilot can fly.

The proposed rule is much broader than that. And I wasn’t clear about what I meant by “re-certification.” I wasn’t talking about the Cessna sitting in your hanger right now.

There is absolutely nothing in this proposed rule that would preclude Cessna from re-opening the C-152 line, convincing the FAA that they are in compliance with “consensus standards” and then producing a C-152 SLSA. In fact, it encourages it….provided Cessna thinks there is a market.

The C-152 SLSA would look like the C-152 in your hanger but this one could be maintained by an LSA Repairman (Maintenance), or inspected by and Repairman LSA (Inspection).

They could do the same with the 172. Although, I’m sure they’d innovate the heck out of the old designs.

Van’s could do the same with, say, the RV-8…an RV-8 SLSA.

At least that’s how I read the 300+ pages of the rule. This is a sweeping proposal. And no, going forward, a Cessna may not always be a Cessna. If this proposal is approved, we’ll be in a different place.

As for the Cessna in your hanger. If a Sport Pilot can fly it, if it looks just like the SLSA Cessna might be producing, why can’t it be recertified? Yes, it wasn’t built to “consensus standards”, it was built to government standards, before all this happened.

….So many questions.

 

[Jslow2]

If you have a sport pilot license and build an rv9, does someone with a PPL have to fly the entire phase 1? Or can they fly it, establish the clean stall speed and then a sport pilot can fly it?

 

[CF86301]

If you have a sport pilot license and build an rv9, does someone with a PPL have to fly the entire phase 1? Or can they fly it, establish the clean stall speed and then a sport pilot can fly it?

ROTFL... not because it's a stupid question, quite the contrary. Instead, it's the kind of question that will tie up a team of FAA attorneys for a month or two.

Proposals in complex situations such as the ones the FAA has created with multiple categories of pilots, aircraft, repairmen/mechanics, operators, and operations are full of unintended consequences. That's one of the reasons it takes decades to change the rules in the Code of Federal Regulations.

In more general terms, the losing game the FAA plays is trying to manage risk using prescriptive regulations, e.g., a stall speed of 54 KCAS will save X number of lives. This is utter nonsense, especially given the fact that technology and population density evolve much faster than the FAA's rules. The FAA could drastically simplify its rules if it simply said, if you cause x amount of societal, property, or personal injury damage, you will be held proportionately liable for that damage.

Of course, the FAA staff (which could be reduced significantly) and the trial lawyers that make their living from litigating the nuances of the FAA rules and regulations would hate that sort of outcome of this rulemaking proceeding.

Just don't ask ChatGPT or any of its ilk what it thinks about all of this. Much less how it thinks.

 

[Jslow2]

21.191 also seems to say that if Vans builds 1 rv9 and registers it as an lsa, then any rv9 kit could be registered as an elsa, similar to the rv12. Vans doing so, not necessarily selling the rv9 as an lsa like they do the 12, would help out a lot of their customers.

Lots of confusion for me, since I am building a 9, and haven't completed any pilots license yet.

 

[Mel]

21.191 also seems to say that if Vans builds 1 rv9 and registers it as an lsa, then any rv9 kit could be registered as an elsa, similar to the rv12. Vans doing so, not necessarily selling the rv9 as an lsa like they do the 12, would help out a lot of their customers.
Lots of confusion for me, since I am building a 9, and haven't completed any pilots license yet.

Not quite that simple! They would first have to build and certificate one aircraft as an S-LSA. They then would have to sell the kit as a certified E-LSA kit (Like the RV-12). Your kit would then have to built EXACTLY per the plans with no changes (Like the RV-12).

 

[Tacco]

Not quite that simple! They would first have to build and certificate one aircraft as an S-LSA. They then would have to sell the kit as a certified E-LSA kit (Like the RV-12). Your kit would then have to built EXACTLY per the plans with no changes (Like the RV-12).

Yes, that's my understanding as well.

However, if I'm reading the proposal right, and if you're just looking to fly an RV-9 as a Sport Pilot, I think Van's could provide a statement that confirms the RV-9 design meets the performance requirements of a Light Sport Aircraft. It would still have to be registered as an EAB. I think(?)

 

[Michael Burbidge]

If you're just looking to fly an RV-9 as a Sport Pilot, I think Van's could provide a statement that confirms the RV-9 design meets the performance requirements of a Light Sport Aircraft. It would still have to be registered as an EAB. I think(?)

What paragraph in the proposal gives you this idea. I couldn't find anything. I think the proposal is underspecified when it comes to whether an existing experimental can be flown by a sport pilot. Or how an experimental can meet the stall speed qualifications to be flown as a sport pilot.

 

[gasman]

Yes, that's my understanding as well.

However, if I'm reading the proposal right, and if you're just looking to fly an RV-9 as a Sport Pilot, I think Van's could provide a statement that confirms the RV-9 design meets the performance requirements of a Light Sport Aircraft. It would still have to be registered as an EAB. I think(?)

What paragraph in the proposal gives you this idea. I couldn't find anything. I think the proposal is underspecified when it comes to whether an existing experimental can be flown by a sport pilot. Or how an experimental can meet the stall speed qualifications to be flown as a sport pilot.

He has done that. It will meet the new proposed rule with a healthy margin.
It can only be registered an an EAB..... that's what it is, and IT WILL QUALIFY under the new rules. It will not be a light sport aircraft. It will meet the requirements of Light Sport, and you can fly it with a Light Sport ticket or fly it with a PP ticket under Light Sport rules that allow a drivers license to take the place of a medical........ Why is this so difficult........

Plus, if you build it, you will qualify for the repairmen's certificate that will allow you to sign off the "CONDITION inspection." You WILL NOT need this to maintain the aircraft...... anyone can do that. So, to recap.... NO MEDICAL.... NO A&P FOR sign-off.

 

[Tacco]

What paragraph in the proposal gives you this idea. I couldn't find anything. I think the proposal is underspecified when it comes to whether an existing experimental can be flown by a sport pilot. Or how an experimental can meet the stall speed qualifications to be flown as a sport pilot.

It is throughout the document. What the FAA is doing is decoupling the Sport Pilot certification requirement and Aircraft Certification requirements. They replace the limitations on Sport Pilots with performance-based criteria. (61.316)

Start here Page 47731, Para 61.301. Read the table.

Look I'm not a lawyer. I may not be interpreting this correctly, but I think that's what it says when you read it in its entirety.

 

[Michael Burbidge]

It is throughout the document. What the FAA is doing is decoupling the Sport Pilot certification requirement and Aircraft Certification requirements. They replace the limitations on Sport Pilots with performance-based criteria. (61.316)

Start here Page 47731, Para 61.301. Read the table.

Look I'm not a lawyer. I may not be interpreting this correctly, but I think that's what it says when you read it in its entirety.

I get all that.

The question that seems unspecified is how is the Sv1 stall speed for an experimental is established/documented. Typically the operating limitations for an experimental require a log entry, at the conclusion of phase 1 testing, that specifies Vx, Vy and Sv0. That's what my operating limitations required. i.e. My log entry does not specify Sv1.

I have little to no experience with an FAA proposal like this, so maybe the proposal is more about the intent of the rule, and it will be more tightly specified in the final rule.

Michael-

 

[KeithO]

I get all that.

The question that seems unspecified is how is the Sv1 stall speed for an experimental is established/documented. Typically the operating limitations for an experimental require a log entry, at the conclusion of phase 1 testing, that specifies Vx, Vy and Sv0. That's what my operating limitations required. i.e. My log entry does not specify Sv1.

I have little to no experience with an FAA proposal like this, so maybe the proposal is more about the intent of the rule, and it will be more tightly specified in the final rule.

Michael-

A new airplane model at vans doesnt appear out of a vacuum and then get handed off to an unknown builder to build and test the first sample. Of course vans builds and tests it. The data from envelope expansion probably contains all that is needed to determine VS1.

Provided you dont deviate from the plans and the specified empty/gross weights your example should fly like the factory demonstrator.

 

[z987k]

The C-152 SLSA would look like the C-152 in your hanger but this one could be maintained by an LSA Repairman (Maintenance), or inspected by and Repairman LSA (Inspection).

Rather confusingly on the FAAs part, you have that backwards. An LSRM can do annuals on any lsa. LSRI can only do their own airplane, if it's E-LSA. There's not an A&P / IA equivalency in the lsa world. Anyone with an LSRM is basically an IA, it's just a question of what aircraft they can exercise it on.

 

[Jslow2]

He has done that. It will meet the new proposed rule with a healthy margin.
It can only be registered an an EAB..... that's what it is, and IT WILL QUALIFY under the new rules. It will not be a light sport aircraft. It will meet the requirements of Light Sport, and you can fly it with a Light Sport ticket or fly it with a PP ticket under Light Sport rules that allow a drivers license to take the place of a medical........ Why is this so difficult........

Plus, if you build it, you will qualify for the repairmen's certificate that will allow you to sign off the "CONDITION inspection." You WILL NOT need this to maintain the aircraft...... anyone can do that. So, to recap.... NO MEDICAL.... NO A&P FOR sign-off.

View attachment 45827

It's difficult because:

A) Those numbers are NOT clean stall speed, most critical cg, calibrated airspeed.

B) It's hard to believe the FAA will just take the builders word for it that the plane meets requirements.

C) there is a LOT of wording in the proposal that is open to interpretation. And I feel that during the comments portion of the proposal, a lot of questions will be asked and the proposal may be amended in a not so good way for experimental builders. Multiple times in the proposal experimental aircraft safety has been brought into question. In fact the FAA seems to be trying to sell people on LSA's over experimental.

D) one could argue that 61.316 doesn't apply to experimental because, 61.316 says "since its certification...meets following requirements" you receive your airwirthiness certificate BEFORE you truly know if it meets those requirements. Again you can't go by vans numbers, they are not the numbers the FAA is looking for, and this isn't sn elsa, built exactly to plans.

I'm not trying to be negative, but this is the government were taking about.

 

[PhatRV]

It's difficult because:

A) Those numbers are NOT clean stall speed, most critical cg, calibrated airspeed.

B) It's hard to believe the FAA will just take the builders word for it that the plane meets requirements.

C) there is a LOT of wording in the proposal that is open to interpretation. And I feel that during the comments portion of the proposal, a lot of questions will be asked and the proposal may be amended in a not so good way for experimental builders. Multiple times in the proposal experimental aircraft safety has been brought into question. In fact the FAA seems to be trying to sell people on LSA's over experimental.

D) one could argue that 61.316 doesn't apply to experimental because, 61.316 says "since its certification...meets following requirements" you receive your airwirthiness certificate BEFORE you truly know if it meets those requirements. Again you can't go by vans numbers, they are not the numbers the FAA is looking for, and this isn't sn elsa, built exactly to plans.

I'm not trying to be negative, but this is the government were taking about.

Just because you built an ultra lightweight super STOL doesn't mean it will qualify as an SLA or ELSA. There are very specific standards an LSA can be "certified" under the new rules and just because you say so doesn't mean it is qualified. Trust me there will be a lot of paperwork, lots real world testing to meet the ASME standards or whatever the consensus standards from the various manufacturers. Your standards don't count, sorry. If you are building a 9 right now, chances are, it will not be qualified under the new standards even if it stall at 10mph. Just like the RV12, the only reason it is qualified because Vans had performed all the necessary design work, certification work so that Vans can market it as a LSA or ELSA. Likewise, when the rules come into effect, if Vans wants the RV9 to be a new LSA, it will have to certify it and sell you the kit that is LSA certify. Your RV9 doesn't qualify.

 

[Michael Burbidge]

Just because you built an ultra lightweight super STOL doesn't mean it will qualify as an SLA or ELSA. There are very specific standards an LSA can be "certified" under the new rules and just because you say so doesn't mean it is qualified. Trust me there will be a lot of paperwork, lots real world testing to meet the ASME standards or whatever the consensus standards from the various manufacturers. Your standards don't count, sorry. If you are building a 9 right now, chances are, it will not be qualified under the new standards even if it stall at 10mph. Just like the RV12, the only reason it is qualified because Vans had performed all the necessary design work, certification work so that Vans can market it as a LSA or ELSA. Likewise, when the rules come into effect, if Vans wants the RV9 to be a new LSA, it will have to certify it and sell you the kit that is LSA certify. Your RV9 doesn't qualify.

At least from my standpoint, this discussion has not been about whether an RV-9 will qualify as an SLA or ELSA. It has been about whether a EAB 9 can be flown by a sport pilot, just like a C172, which is not an SLA or ELSA can be flown by a sport pilot.

Michael-

 

[gasman]

Just because you built an ultra lightweight super STOL doesn't mean it will qualify as an SLA or ELSA. There are very specific standards an LSA can be "certified" under the new rules and just because you say so doesn't mean it is qualified. Trust me there will be a lot of paperwork, lots real world testing to meet the ASME standards or whatever the consensus standards from the various manufacturers. Your standards don't count, sorry. If you are building a 9 right now, chances are, it will not be qualified under the new standards even if it stall at 10mph. Just like the RV12, the only reason it is qualified because Vans had performed all the necessary design work, certification work so that Vans can market it as a LSA or ELSA. Likewise, when the rules come into effect, if Vans wants the RV9 to be a new LSA, it will have to certify it and sell you the kit that is LSA certify. Your RV9 doesn't qualify.

You can't build an SLSA for yourself unless you are going into production. You can't build an ELSA without purchasing every part from Van's for the RV12 as an example. So unless you are going into production to produce an SLSA, your entire statement is useless......

The RV 9 would qualify right now except it is too fast and a little heavy. Those issues go away with the new rule. It stalls full flaps at 38 knots. That's 16 knots under the new no flap stall speed.... It will do that.

The new rule is clean stall at 54 knots min. gross at sea level. (Max speed 250 knots.) No max speed. The top speed is controlled by stall speed. Max 4 seats. That's it. If you have a plane that matches those requirements, you can fly it as a light sport pilot.

It's not an LSA, and will never be a LSA (without Van's assistance). It just needs to meet the requirements.

As a private pilot, you can fly the RV9 under the new rules, without a medical. You only need a drivers license.

 

[RV8JD]

It stalls full flaps at 38 knots. That's 16 knots under the new no flap stall speed.... It will do that.

The new rule is clean stall at 54 knots min. gross at sea level.

Is that flaps down Vs = 38 knots IAS or CAS? I'm guessing IAS.

The MOSAIC limit is 54 KCAS flaps up. According to Van's the flaps up stall speed is approximately 48.6 KIAS (56 MIAS). If the instrument and position error at those speeds is less than 5.4 Kts, it would meet the requirement. But the instrument and position error at those speeds needs to be measured to find out what it is.

Units are important.

 

[PhatRV]

As a private pilot, you can fly the RV9 under the new rules, without a medical. You only need a drivers license.

I hope this is true but I am waiting for the final rules. I don't interprete the rules to allow non-LSA certify experimentals to be used as a light-sport capable because they are never certified in the first place. We should know when the FAA decides.

 

[Cumulo]

I hope this is true but I am waiting for the final rules. I don't interprete the rules to allow non-LSA certify experimentals to be used as a light-sport capable because they are never certified in the first place. We should know when the FAA decides.

Again, the new rules de-couple aircraft CERTIFICATION CATEGORY from what a Light Sport Pilot can fly. He can fly ANYTHING - IF the aircraft meets the new PERFORMANCE requirements of LS.

If it was demonstrated to FAA's satisfaction that a WW II Corsair could glide zero thrust, no flap at 54Kt CAS, a Light Sport Pilot could fly it. (with sign-off for retract gear and controllable prop of course)

All good news for the owner of a relic Bellanca Cruisair, a design that should handily qualify to meet the major requirement of 54Kt or less Vs1 as specified.

 

[j4cbo]

The new rule is clean stall at 54 knots min. gross at sea level. Max speed 250 knots. Max 4 seats. That's it. If you have a plane that matches those requirements, you can fly it as a light sport pilot.

Almost. The airplane must be unpressurized, and there is NO maximum speed for sport pilots. See page 296 of the NPRM PDF, where it says "What are the performance limits and design requirements for the aircraft that a sport pilot may operate?"

 

[j4cbo]

I hope this is true but I am waiting for the final rules. I don't interprete the rules to allow non-LSA certify experimentals to be used as a light-sport capable because they are never certified in the first place. We should know when the FAA decides.

This is already the case. Plenty of Sport Pilots fly Sonexes (https://www.sonexaircraft.com/sport-pilot/)

Again, the new rules de-couple aircraft CERTIFICATION CATEGORY from what a Light Sport Pilot can fly. He can fly ANYTHING - IF the aircraft meets the new PERFORMANCE requirements of LS.

They're already kind of decoupled. A Sport Pilot today can fly any aircraft that meets the definition of Light Sport Aircraft in FAR 1.1. The new rules place "what can a sport pilot fly?" in a completely separate section, and expand the limits for both. The FAA has, ever since the Sport rules were introduced in the first place, published a list of existing models that Sport Pilots can fly. These aircraft are NOT certificated as ELSA or SLSA but do meet the definition of Light Sport Aircraft in FAR 1.1: https://www.faa.gov/sites/faa.gov/files/aircraft/gen_av/light_sport/ExistingModels.pdf

 

[PhatRV]

This is already the case. Plenty of Sport Pilots fly Sonexes (https://www.sonexaircraft.com/sport-pilot/)



They're already kind of decoupled. A Sport Pilot today can fly any aircraft that meets the definition of Light Sport Aircraft in FAR 1.1. The new rules place "what can a sport pilot fly?" in a completely separate section, and expand the limits for both. The FAA has, ever since the Sport rules were introduced in the first place, published a list of existing models that Sport Pilots can fly. These aircraft are NOT certificated as ELSA or SLSA but do meet the definition of Light Sport Aircraft in FAR 1.1: https://www.faa.gov/sites/faa.gov/files/aircraft/gen_av/light_sport/ExistingModels.pdf

I am not a lawyer but I think it is an incorrect interpretation of the EAB aircraft. The list you provided are certificated aircraft which means they are are already certified and the FAA deems they met the LSA rules. The FAA never certified any of the RVs with the exception of the RV12.

 

[lr172]

Is that flaps down Vs = 38 knots IAS or CAS? I'm guessing IAS.

The MOSAIC limit is 54 KCAS flaps up. According to Van's the flaps up stall speed is approximately 48.6 KIAS (56 MIAS). If the instrument and position error at those speeds is less than 5.4 Kts, it would meet the requirement. But the instrument and position error at those speeds needs to be measured to find out what it is.

Units are important.

In the experimental world, Vans published stall speed numbers mean nothing. All that counts is what the builder declares as the stall speed in the log book entry. The builder is the manufacturer and is fully responsible for testing and setting these V speeds. Because builders (may be a few limited exceptions) don't use sophisticated pitot/static rigs when testing, stall speed decrlarations are rarely reflective of the actual speed the plane is travelling. The builder determines stall based upon testing using the installed instruments and that includes all instrumentation error present. So, the plane WILL stall at the indicated airspeed documented in the log (in theory anyways), but that stall speed is not necessarily anywhere close to an actual airspeed.

In the certified world, the mfr has to use precision instruments to determine actual stall speeds. This is why they have CAS to deal with the position error of the pitot/static systems. No such thing in EAB, as we have no idea what the true stall speed is, only that it stalls at a certain point on the installed airspeed indicator.

An example. I had to put little plates around my static ports to get close to actual in cruise. Unfortunately that also raised my indicated speed down low, so had to reset the VS0 and VS1 speeds to account for that.

 

[dave wolfe]

From the earlier EAB Light Sport times, Sonex declared that the design met the LSA stall speed with gross wt up to XXXX lbs.

It may still be as simple as that?

 

[gasman]

Almost. The airplane must be unpressurized, and there is NO maximum speed for sport pilots. See page 296 of the NPRM PDF, where it says "What are the performance limits and design requirements for the aircraft that a sport pilot may operate?"

You are correct. I went back and corrected my post..... thanks...

As was stated in the NPRM The stall speed would naturally restrict the aircraft to about 3000# gross and a top speed of about 250kts......my words.

 

[mburch]

Given the amount of activity in this thread - and, I'm sure, similar threads on other forums - I'm surprised to see that there are only 90 comments on the NPRM so far. The comment period is open until October 23, so hopefully there will be a sufficient volume of comments by the end to get the FAA's attention and get them to fix some of the rough edges of the proposed rule.

Commenting is easy, just click here. Although the instructions say that there is no maximum length for a comment, in practice the web form limits you to 5000 characters or less.

In my personal experience, a comment directed to a large agency will probably be more effective if it's phrased in a positive, constructive way, with a feeling of "wow this is great, and here's some fun ways that we can all hold hands and make it even better!" I'll share the comment I wrote in case it helps anyone with writer's block:

I thank the FAA for working to reduce the regulatory burden on "low-end" general aviation while maintaining satisfactory safety standards. It’s only by making flying more affordable and accessible that the average person will be able to fly often enough to maintain proficiency – itself an important second-order effect of lowering the cost of aviation. I support the overall direction embodied by the proposed rule, and would like to offer some suggestions to improve the final outcome.

With the understanding that it is necessary to establish aircraft performance standards for light-sport category aircraft, I have several concerns about the specific standards proposed. Most of my concerns relate to the proposed Vs1 (clean) stall speed limitation of 54 KCAS:

* The NPRM states that the intent is to "retain low speeds during approach and landing", but the selection of Vs1 as the limiting speed is incompatible with stated purpose. A more suitable limitation would be Vs0, the stalling speed in the landing configuration, giving proper credit to aircraft designs that incorporate flaps or other high-lift devices.

* The proposed rule would allow a sport pilot to fly a Cessna Turbo 182 RG - a fast and complex aircraft with a controllable-pitch propeller, turbocharged engine, and retractable gear, which has a Vs1 of 54 knots. However, the same sport pilot would be excluded from flying a large number of well-regarded training aircraft, including all Piper Cherokee models, which have low stall speeds with flaps down but whose Vs1 speeds are slightly higher than 54 knots. Bear in mind that the same Piper Cherokee could legally be flown today by a solo student pilot after receiving substantially less training compared to a sport pilot.

* The fact that the stall speed limitation is specified as a calibrated airspeed poses several problems. For instance, many older aircraft such as the Cessna 140 do not have any calibrated airspeeds published. Additionally, the vast majority of experimental amateur-built (EAB) aircraft do not have calibrated stall speeds specified, due to the cost and complexity of the required flight testing, and the lack of requirement to do so. It seems that this would exclude sport pilots from flying a large number of otherwise docile and benign aircraft, such as the many various experimental Cub derivatives.

To fix the above problems, I suggest the following modifications:

* Change the stall speed limit to be 54 knots Vs0 (landing configuration) instead of Vs1 (clean). This would satisfy the stated goal of allowing sport pilots to fly aircraft with slow approach and landing speeds, without excluding aircraft that utilize high-lift devices.

* A variation of the above change would be to add the requirement to receive additional training and instructor endorsement to fly aircraft with clean stall speeds greater than 54 knots.

* If it is still desired to maintain a secondary "clean" stall speed limit, I suggest setting this to 61 knots Vs1, which would be in keeping with stall speed limitations previously established in Part 21 and Part 23.

* The wording should be changed to permit the use of indicated stall speeds for aircraft that do not have calibrated stall speeds published.

On the topic of sport pilots and experimental amateur-built (EAB) aircraft, the proposed rule leaves some ambiguities. For instance, could a sport pilot conduct the Phase I flight testing of an EAB aircraft for which stall speeds have not yet been determined?

The proposed change relating to experimental aircraft flying in congested areas leads me to urge the FAA to provide an official definition of what a "congested area" actually is, as the present state of affairs - where each FAA inspector is allowed to interpret this term as they please - leaves pilots with no definitive and deterministic way to know where they are allowed to fly.

Regarding maintenance, the proposed rule sets up a scenario where a light sport aircraft of the same size and complexity as a Cessna 182 is allowed to be maintained by a light sport repairman after a training course, but an actual Cessna 182 can only be maintained by an airframe & powerplant mechanic. I would like to see the FAA address this disparity in a way that allows the reduced cost of ownership of light sport aircraft to benefit owners of normal category aircraft with similar performance and complexity. Anything that can be done to reduce the expenses associated with preventative maintenance can only improve the safety record of the aging GA fleet.

Finally, the proposed changes to sport pilot certification will result in a pilot certificate whose privileges and limitations are largely identical to the recreational pilot certificate. As the latter has had extremely limited popularity, I suggest eliminating the recreational pilot certificate entirely, instead converting the few existing recreational certificates that have been issued into sport pilot certificates.

...I was going to touch on the idea of a Canadian-style owner maintenance program (e.g. convert your normal category aircraft to light-sport) as well as the medical requirement for sport pilots to fly at night, but I ran out of characters!

 

[rmartingt]

but I ran out of characters!

I'm pretty sure you can write up something as long as you want and attach it as a separate file. I think I've done it before, and I know my response to this one will be that way as it'll be long enough to need it...

 

[Michael Burbidge]

Commenting for the inexperienced

I would love comment on this proposal, but I have very limited experience in terms of aircraft. I've flown exactly 3 aircraft. (1959 C172 about 100 hours, my RV-9A about 500 hours, and RV-6A 10 hours for transition training)

To comment intelligently, I think it helps to have experience with a variety of aircraft.

Matt Burch you captured many of my concerns in a very well written comment. It makes little sense to me that under the regulation I could probably fly an RV-6A, but not an RV-14A. With similar equipment, I don't believe the 14 is anymore difficult to fly safely, than the 6.

I also share the concerns about experimental aircraft not having calibrated airspeeds and not even having indicated airspeeds until after phase 1.

One additional concern is that many existing experimental aircraft, such as my RV-9A, will not even have an indicated Vs1 noted in the required post phase 1 log entry. My entry contains Vx, Vy and Vs0, as that is what was required in my operating limitations. What implications does that have for a sport pilot being able to fly my RV-9A?

Do you have any suggestions for how someone with limited experience can submit useful comments?

Thanks,
Michael-

 

[N8DAV8R]

It's worth a reminder here that Rian's advice in the Oshkosh forum was to hold comments until they could provide some guidance on what is most likely to be effective.

It's a free country and you can comment as you wish, but the 90 days is a deadline and not a race.

 

[N8DAV8R]

Time stamped from Brian's recording to the relevant comments, but scrub back for a little more from Rian on the subject. It was interesting, and he chairs the ASTM committee working on this.


https://www.youtube.com/live/gO1pKlyPqvk?feature=share&t=2801

 

[Michael Burbidge]

It's worth a reminder here that Rian's advice in the Oshkosh forum was to hold comments until they could provide some guidance on what is most likely to be effective.

It's a free country and you can comment as you wish, but the 90 days is a deadline and not a race.

Probably good advice for me. I'll wait to see wait Rian suggests.

 

[jclark]

An opportunity to improve ...

I spoke with Tian about this BEFORE the start of Airventure and to some FAA people working on this DURING Airventure.

My short take is:

1. Rian's comments or Cliff's Notes for all will be very helpful to those who wish to comment but don't have the writing expertise of Matt Burch (nice job Matt!!).

2. Rian's comments to the FAA will be VERY impactful for ALL!

3. The FAA people (seemingly nice people BTW) have NOT cast everything in concrete and they DO want meaningful commentary on this matter.

So, as someone else said, this is an opportunity for us to provide positive helpful comments to the FAA so that they can improve their "first draft" (MY WORDS) for this important effort.