Possible LSA weight exemption on certian legacy aircraft?

Talk about airplanes! At last count, there are 39 (and growing) FAA certificated S-LSA (special light sport aircraft). These are factory-built ready to fly airplanes. If you can't afford a factory-built LSA, consider buying an E-LSA kit (experimental LSA - up to 99% complete).

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jnmeade
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Post by jnmeade »

It will be interesting to see how the discussion about heavier LSA and the proposal for dropping the 3rd class medical for small airplanes meet, if they do at all. The FAA could go either route or neither route or even both routes.

To the extent that the FAA is worried about the economy, it is patently obvious that the FAA is concerned about Unmanned Aircraft Systems (UAS), sometimes called Unmanned Aerial Vehicles (UAV) and popularly (and incorrectly) called drones. That is where Congress and business are pushing as reported daily. The addition of a couple of hundred more LSA wouldn't seem to me to be very big on the FAA radar screen.

If Icon wants to make a 1600 lb airplane, go ahead and make one. Why not? All the rules are in place. If there is a huge demand for them and Icon doesn't want to go the standard certificated route, do like VanGrunsen and Rans and make an affordable kit plane as an E-AB.

I would like to be able to fly a bigger, faster, heavier airplane using Sport Pilot privileges, but am not holding my breath on the likelihood in the near future and am putting my emphasis on improving my CTSW and learning to fly it well.
7900
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Re: Icon and weight

Post by 7900 »

fredg wrote:Seems like a case of counting chickens before they hatch to be calling Icon "the biggest future lsa manufacturer". I think it was James Thurbur who said "Predictions are difficult, especially when they are about the future".

If I am not mistaken, Icon has not delivered a single airplane to a paying customer. Yes, they have a lot of orders, but some other manufacturers, especially those that actually have actually sold airplanes, might not think Icon is the biggest lsa manufacturer, now or in the future.
From Icon's website, "With over 1,000 delivery positions already assigned, the A5 has demonstrated unprecedented and broad market appeal."

With Cessna's 162 sales not meeting expectations ( per an article on this forum ) and Piper and Cirrus having canceled their lsas, who else has over 1,000 orders on the books ?

Like I said, Icon is the biggest "future" lsa manufacturer to come and has the orders to prove it.
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Re: Icon and weight

Post by drseti »

7900 wrote:From Icon's website, "With over 1,000 delivery positions already assigned, the A5 has demonstrated unprecedented and broad market appeal."
Yes, the A5 has broad market appeal, and I wish Icon well. But it's a long haul from orders to delivered product, and will likely be an uphill battle for Icon (as it is for all manufacturers). I hope they (and their 1000 position holders) can hang in there.
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Post by Jack Tyler »

" If there is a huge demand for them and Icon doesn't want to go the standard certificated route, do like VanGrunsen and Rans and make an affordable kit plane as an E-AB."

Yes, there's a Certification Path available. But a viable business model is something else. How many of those depositors will purchase a kit requiring (let's ballpark) 1,000 hours of build time? How suitable is the composite design for conversion to a kit, and at what price point? How is the need for the creation, editing, publishing and updating of constructions plans - and the inevitable customer support - met & what is that cost? How many kit sales/year are needed to meet the business plan vs. how many turn-key Icons must be sold? The same plane may not fit both very different business models. Vans & Rans nicely illustrate how wide the continuum is in a business sense: Rans sells relatively few a/c each year with a variable workforce from one year to the next. Vans is the unique, highly successful mfgr. rather than a representative one, and is what every kit mfgr. would aspire to if only they could. It took Vans about 30 years to get where it is today. Is that the kind of investor that's fueling Icon?

Cessna's disappointing discovery is that it was easier to pick a price point before they started manufacturing the Skycatcher and it was easy to collect deposits for a future product. Icon has a similarly sized group of depositors, also in its pre-production period and also before certification, and with the added issue that its a/c doesn't fit the LSA specs at the moment. I don't know how one weighs the significance of those 1,000 depositors. I do hope they all understand they will be far back in line if Icon isn't around to make their plane at a price they find acceptable.
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Post by Jim Stewart »

Icon's business model appears to be "sell to the people that already have a $100,000 boat, truck and trailer rig". If this is the case, those people will not be spending hundreds of hours building a kit and then getting a pp+seaplane rating.
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3-333
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Re: Possible LSA weight exemption on certian legacy aircraft

Post by 3-333 »

Jim Stewart wrote:
7900 wrote: Taking into account the enormous financial expenditures that Icon has invested into developing the A5, their huge order backlog, and the fact that they are doing this solely for safety reasons, the FAA will find it very hard to justify denying them their weight exemption.

If they did then ironically it will be the FAA itself who will be responsible for forcing Icon to go ahead and sell an LSA that isn't as safe as it could be ( spin resistant ) solely for the nonsensical reason of keeping weight down to some previously assigned arbitrary limit. Icon has painted the FAA right into a corner, good for them.

The FAA will also be to blame for what looks like the biggest lsa manufacturer to come potentially losing alot of sales in a still very depressed industry. If denied Icon will then have no choice but to go ahead and try to spin the issue ( pardon the pun ) and say the A5 is still a safe lsa, but certainly not as safe as they could of made it. This may give some buyers pause about actually taking delivery of one.

Ultimately the FAA will come out looking very bad if they deny this, after all safety is supposed to be paramount to them. They will have authorized the production of an lsa that they know isn't as safe as the designer wanted to make it, plus they may very well have contributed to killing sales in an industry that is still struggling to "get off the ground."

The financial might of Icon may be just the ticket that finally gets this ridiculous LSA weight limit issue fixed once and for all. I wish them well.
Um, no.

Icon knew the rules when they started playing the game.

They didn't ask for an exemption then. They didn't claim to be building a spin-proof plane then. All the other LSA manufacturers played by the rules and built their airplanes as safe as they could within the rules that are in place.

The FAA is not "forcing" Icon to do anything. Icon is trying to change the rules because they appear not to be able to deliver the product they promised by following the rules.

Think about this:

250lbs is a huge amount of weight in the LSA world. I doubt that both wings on my CT weight 250lbs. So here is the $64,000 question.... How do you take an aircraft design, add 250lbs to it and make it safer? Airfoil changes won't eat up 250lbs, a canard won't eat up 250lbs, flaps and or spoilers won't eat up 250lbs. Maybe I'm just a little slow on the uptake, but I can't seem to make any sense out of this.

Does anyone have a link to Icon's original petition for the additional 250lbs? All I can find is summaries and extentions.
Jim, here is a link to their petition, copy and paste the entire link as only the first part of the link was recognized http://www.regulations.gov/#!documentDe ... -0514-0001, click on the View Attachment icon to see the full PDF.
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Re: Possible LSA weight exemption on certian legacy aircraft

Post by drseti »

3-333 wrote:Jim, here is a link to their petition
Many thanks, Threes. Interesting! I'm especially curious about:
Additionally, the FAA has previously issued exemptions to permit additional S-LSA weight to safely accommodate increased product utility.
Does anyone know what previous exemptions they're referring to? I am aware of none, other than the Terrafugia Transition (which was "exempted" up to the 1430 pound limit from which Icon wants to be exempted).
Last edited by drseti on Thu Aug 16, 2012 10:35 am, edited 1 time in total.
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3-333
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Re: Icon and weight

Post by 3-333 »

7900 wrote:
fredg wrote:Seems like a case of counting chickens before they hatch to be calling Icon "the biggest future lsa manufacturer". I think it was James Thurbur who said "Predictions are difficult, especially when they are about the future".

If I am not mistaken, Icon has not delivered a single airplane to a paying customer. Yes, they have a lot of orders, but some other manufacturers, especially those that actually have actually sold airplanes, might not think Icon is the biggest lsa manufacturer, now or in the future.
From Icon's website, "With over 1,000 delivery positions already assigned, the A5 has demonstrated unprecedented and broad market appeal."

With Cessna's 162 sales not meeting expectations ( per an article on this forum ) and Piper and Cirrus having canceled their lsas, who else has over 1,000 orders on the books ?

Like I said, Icon is the biggest "future" lsa manufacturer to come and has the orders to prove it.
As for being the biggest LSA manufacture Eclipse (who had several thousand orders and over a Billion dollars in investment, that's with a Billion with a B), Adams, Flight Designs Valkyrie and even the old LSA "Mermaid" was in the same position (order-wise with hundreds of orders) and remember Icon has not produced a single Light Sport Aircraft only a +1600 pound Experimental prototype. Orders and press releases do not supplement a product. To date all they have done is make promises, take deposits, and not deliver.... everything else is fluff. In my experience that is the quickest way to ruin your reputation in aviation.

There is an old adage "those to speak the loudest have the least to say"
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Post by drseti »

Icon's petition says:
While it is beyond the scope and intent of this document to fully explain a full FAR Part 23 spin-resistance solution, a simplified, layman’s explanation is that a large portion of the outer wing sections must be protected from ever stalling by, among other things, reducing maximum lift well below the wing’s capability. Given the maximum stall speed (45 knots) required by the LSA definition, this loss of maximum available lift requires significantly increased wing area. The increased wing area then in turn requires increased tail size for stability along with the corresponding increase in internal structure, as well as proportional accommodation factor weight – at a minimum.
It seems to me they'd be far more successful requesting an exemption from the 45 kt stall speed restriction than they will be at getting so substantial a weight increase.
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Post by Jim Stewart »

Very interesting document. I'll make the popcorn while we wait.

I found item 10 of the proposed aircraft limitations interesting:

10. Each ICON A5 must have onboard an ICON Aircraft owned Flight Data Recorder (FDR) that operates in accordance with the provisions of the ICON A5 operating manual for the purpose of continued airworthiness.
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Post by c162pilot »

Remember Cessna also had 1,000 deposits and had assigned delivery positions for their aircraft, most that have now been refunded.
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Post by drseti »

I salute Cessna for actually having promptly refunded those deposits. Quite a few other manufacturers over the years have left their customers out in the cold.
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Re: Icon and weight

Post by 7900 »

3-333 wrote:As for being the biggest LSA manufacture Eclipse (who had several thousand orders and over a Billion dollars in investment, that's with a Billion with a B), Adams, Flight Designs Valkyrie and even the old LSA "Mermaid" was in the same position (order-wise with hundreds of orders) and remember Icon has not produced a single Light Sport Aircraft only a +1600 pound Experimental prototype. Orders and press releases do not supplement a product. To date all they have done is make promises, take deposits, and not deliver.... everything else is fluff. In my experience that is the quickest way to ruin your reputation in aviation.

There is an old adage "those to speak the loudest have the least to say"
Do you always root against everyone who has the guts to bring a new product to market and try to make it as good as it possibly can be ? What incredible negativity from you, kill joy.

I'll put the management, design team, and financial backing Icon has up against everyone of those companies you listed any day. Break out the salt and pepper cause you're going to eat your words, "fluff" and all.
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Re: Icon and weight

Post by drseti »

7900 wrote:Do you always root against everyone who has the guts to bring a new product to market and try to make it as good as it possibly can be ?
Nobody on this forum is rooting against Icon, 7900. We all want to see them succeed, for the greater good of General Aviation and the Sport Pilot movement. To borrow a nautical phrase, a rising tide lifts all boats. We are merely pointing out the challenges that they face, and trying to realistically assess their chances of success.
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7900
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Post by 7900 »

Icon said it perfectly in their petition by reminding the FAA of their very own rules and objectives regarding Lsas:

"In the LSA final rule, the FAA asserts in Section II, “Purpose of This Rule” (P.44774), that “The FAA intends this rule to – increase safety in the light-sport aircraft community by... accommodating new advances in technology. The addition of spin-resistance technology is directly aligned with this FAA goal.

It is also apparent throughout the preamble of the final LSA rule, that simplicity and ease of use were the key criteria in the formation of the LSA category. Adding a Spin-Resistant Airframe is exactly aligned with the spirit of the original rulemaking by providing an aircraft that is even simpler and easier to use than traditional, non spin-resistant aircraft.""

By including spin-resistance technology in the model A5, ICON will address the primary cause of fatal accidents in light aircraft: loss of control. Additionally, since S-LSAs are primarily operated at lower altitudes and speeds, where unintentional stall/spin entries are far less forgiving, the safety benefits of spin resistance will be even more pronounced.

Furthermore, given that LSAs can be flown by newly certificated, entry-level sport pilots, and considering the significant safety benefits this exemption creates, ICON believes enabling the inclusion of spin-resistance technology in the ICON model A5 by granting this exemption is the responsible regulatory decision."
Last edited by 7900 on Thu Aug 16, 2012 2:27 pm, edited 1 time in total.
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