Limit to 120 KCAS at sea level only with custom EMS - still an LSA?

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Re: Limit to 120 KCAS at sea level only with custom EMS - still an LSA?

Post by drseti »

FastEddieB wrote: allows full power to be used up to five minutes in takeoff and climb and limits pilots to just 80 horsepower in cruise flight. The manufacturer relies on the honor system for compliance,
In other words, "wink wink, nudge nudge". This is really no different from the marketing guy for a very heavy SLSA, who responds to queries about the extremely limited useful load by saying, "in Europe, the same plane is rated at 1600 pounds MTOW. It can handle it."

There are always those who will game the system, and blanantly encourage their customers to ignore (or deliberately violate) the regs.
The opinions posted are those of one CFI, and do not necessarily represent the FAA or its lawyers.
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Re: Limit to 120 KCAS at sea level only with custom EMS - still an LSA?

Post by drseti »

fatsportpilot wrote: From my understanding there are some limitations that are of the aircraft (or POH) itself like the MTOW, number of seats, SLC for power, fixed pitch or ground adjustable prop, fixed landing gear, and etc.
These are not POH limitations (though they may be cited in the POH). Rather, these are legal limitations that come either from the FAR definition of what constitutes an LSA, or the ASTM consensus standards under which they are designed and built. Anyone who doesn't like the rules is certainly entitled to petition FAA or ASTM for a rule change. But those pilots who don't believe these restrictions apply to them have no business flying!
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Re: Limit to 120 KCAS at sea level only with custom EMS - still an LSA?

Post by fatsportpilot »

drseti wrote:
FastEddieB wrote: allows full power to be used up to five minutes in takeoff and climb and limits pilots to just 80 horsepower in cruise flight. The manufacturer relies on the honor system for compliance,
In other words, "wink wink, nudge nudge". This is really no different from the marketing guy for a very heavy SLSA, who responds to queries about the extremely limited useful load by saying, "in Europe, the same plane is rated at 1600 pounds MTOW. It can handle it."

There are always those who will game the system, and blanantly encourage their customers to ignore (or deliberately violate) the regs.
I think there is some good that can come from getting a plane that can safely handle a higher weight than its current artificially-restricted MTOW (like the Jabiru J230 which is the same as the 4-seater but with 2 seats removed and the stated MTOW reduced): future-proofing.

I've been looking for an LSA to buy and one of the big things I'm looking for is the ability to safely fly at a higher than currently legal MTOW. Not because I plan to break any rules but because the upcoming LSA changes might make it suddenly legal to fly heavier (ie with more fuel or a large passenger) and I wouldn't need to sell it and buy a "LSA 2.0" plane. I could just make use of the new regs with the plane I have.

So some people who sell a heavy plane and say "in Europe, the same plane is rated at 1600 pounds MTOW. It can handle it." might not be geared towards people who want to violate regulations and instead to people who want something that is future-proofed for new regulations.
drseti wrote:But those pilots who don't believe these restrictions apply to them have no business flying!
Unless the pilots have a PPL and a current medical then they have reason to believe the sport restrictions don't apply to them. ;)
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Re: Limit to 120 KCAS at sea level only with custom EMS - still an LSA?

Post by 3Dreaming »

FastEddieB wrote:
drseti wrote: Maximum continuous power is maximum continuous power, regardless of altitude.
Just to muck things up, how does that jibe with this AOPA review of the Carbon Cub LSA:

"The Carbon Cub SS’s pilot operating handbook allows full power to be used up to five minutes in takeoff and climb and limits pilots to just 80 horsepower in cruise flight. The manufacturer relies on the honor system for compliance, however, and there’s nothing about the engine or airframe to prevent pilots from flying at higher power settings (and greater speeds) than the POH dictates. The Super Sport Cub is limited to the LSA maximum 120 KIAS in level flight—and the tundra tires on the aircraft I flew were terrific speed brakes. At 2,500 engine and propeller rpm, the aircraft showed no inclination to go beyond that limit in level flight."

Bear in mind this is with "a four cylinder, 340-cubic-inch Lycoming engine with dual electronic ignition that produces up to 180 horsepower."
Have you even looked at the specifications for the Carbon Cub SS? The VNE is 141 MILES PER HOUR! That is only 3 MPH above the 120 knot limit. Do you really think that power restriction is about speed?

I have explained this for you before, and I have confirmed it with Cubcrafters at their booth in Oshkosh. The power restriction has nothing to do with speed! It has to do with useful load and being able to meet the ASTM limitations on empty weight.
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Re: Limit to 120 KCAS at sea level only with custom EMS - still an LSA?

Post by 3Dreaming »

fatsportpilot wrote:
drseti wrote:
FastEddieB wrote: allows full power to be used up to five minutes in takeoff and climb and limits pilots to just 80 horsepower in cruise flight. The manufacturer relies on the honor system for compliance,
In other words, "wink wink, nudge nudge". This is really no different from the marketing guy for a very heavy SLSA, who responds to queries about the extremely limited useful load by saying, "in Europe, the same plane is rated at 1600 pounds MTOW. It can handle it."

There are always those who will game the system, and blanantly encourage their customers to ignore (or deliberately violate) the regs.
I think there is some good that can come from getting a plane that can safely handle a higher weight than its current artificially-restricted MTOW (like the Jabiru J230 which is the same as the 4-seater but with 2 seats removed and the stated MTOW reduced): future-proofing.

I've been looking for an LSA to buy and one of the big things I'm looking for is the ability to safely fly at a higher than currently legal MTOW. Not because I plan to break any rules but because the upcoming LSA changes might make it suddenly legal to fly heavier (ie with more fuel or a large passenger) and I wouldn't need to sell it and buy a "LSA 2.0" plane. I could just make use of the new regs with the plane I have.

So some people who sell a heavy plane and say "in Europe, the same plane is rated at 1600 pounds MTOW. It can handle it." might not be geared towards people who want to violate regulations and instead to people who want something that is future-proofed for new regulations.
drseti wrote:But those pilots who don't believe these restrictions apply to them have no business flying!
Unless the pilots have a PPL and a current medical then they have reason to believe the sport restrictions don't apply to them. ;)
First there is no guarantee that older airplanes will be able to fly at the new gross weight assuming it eventually happens.

Also the restrictions we have been talking about deal with the aircraft and aircraft certification. They apply to all pilots flying the said aircraft, it is not a sport pilot verses private pilot thing.
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Re: Limit to 120 KCAS at sea level only with custom EMS - still an LSA?

Post by fatsportpilot »

3Dreaming wrote:First there is no guarantee that older airplanes will be able to fly at the new gross weight assuming it eventually happens.
Airplanes that are currently not flyable by sport pilots might fit under the LSA definition when MOSAIC is finalized (which is mandated by congress and the FAA has to finish it by 2023). Thinking of things like the 4-seater Jabiru or the Sling4/Sling TSi. It's also possible that companies behind existing LSAs like the Sling2 might re-certify it as a higher MTOW which is up to them but I think will happen for some of them especially if they are already certified with a higher weight in Europe.

What we do know is that the weight will increase for LSA (and a few other things are on the table but not guaranteed, like 4 seats or constant speed props), but we don't know for sure by how much it will be raised. The exact amount is speculative but LAMA working with the FAA thinks it will be in the 2000 to 3000 range, depending on wing size.
Also the restrictions we have been talking about deal with the aircraft and aircraft certification. They apply to all pilots flying the said aircraft, it is not a sport pilot verses private pilot thing
A private pilot with a current medical could fly an LSA at night even though a sport pilot couldn't. That's what I was getting at.
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Re: Limit to 120 KCAS at sea level only with custom EMS - still an LSA?

Post by 3Dreaming »

fatsportpilot wrote:
3Dreaming wrote:First there is no guarantee that older airplanes will be able to fly at the new gross weight assuming it eventually happens.
Airplanes that are currently not flyable by sport pilots might fit under the LSA definition when MOSAIC is finalized (which is mandated by congress and the FAA has to finish it by 2023). Thinking of things like the 4-seater Jabiru or the Sling4/Sling TSi. It's also possible that companies behind existing LSAs like the Sling2 might re-certify it as a higher MTOW which is up to them but I think will happen for some of them especially if they are already certified with a higher weight in Europe.

What we do know is that the weight will increase for LSA (and a few other things are on the table but not guaranteed, like 4 seats or constant speed props), but we don't know for sure by how much it will be raised. The exact amount is speculative but LAMA working with the FAA thinks it will be in the 2000 to 3000 range, depending on wing size.
Also the restrictions we have been talking about deal with the aircraft and aircraft certification. They apply to all pilots flying the said aircraft, it is not a sport pilot verses private pilot thing
A private pilot with a current medical could fly an LSA at night even though a sport pilot couldn't. That's what I was getting at.
What I said was not about pilots being able to fly heavier airplanes. It is about taking an airplane that has already been certified, and increasing the gross weight after the fact. The FAA may not provide an avenue for increasing the gross weight of an airplane that has already been issued an airworthiness certificate. Buying a SLSA with a gross weight of 1320 with the hope that when and if the rule goes into effect that you can increase the gross weight of the airplane is a pretty big gamble in my opinion.

When the original sport pilot rules went into effect the FAA was adamant that an airplane that had previously been certified at a weight above 1320 could not be re certified at 1320. There were several aircraft that could have benefited from such a change.
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Re: Limit to 120 KCAS at sea level only with custom EMS - still an LSA?

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fatsportpilot wrote: A private pilot with a current medical could fly an LSA at night even though a sport pilot couldn't.
Yes, but only if the LSA is equipped for night flight (position lights) and the manufacturer's Operating Limitations permit it.
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Re: Limit to 120 KCAS at sea level only with custom EMS - still an LSA?

Post by fatsportpilot »

Ok that makes sense.
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Re: Limit to 120 KCAS at sea level only with custom EMS - still an LSA?

Post by drseti »

3Dreaming wrote: When the original sport pilot rules went into effect the FAA was adamant that an airplane that had previously been certified at a weight above 1320 could not be re certified at 1320.
And not just "could not be." Could never be.
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Re: Limit to 120 KCAS at sea level only with custom EMS - still an LSA?

Post by fatsportpilot »

drseti wrote:
3Dreaming wrote: When the original sport pilot rules went into effect the FAA was adamant that an airplane that had previously been certified at a weight above 1320 could not be re certified at 1320.
And not just "could not be." Could never be.
Could they certify it as a new plane entirely and sell new ones at a higher MTOW? They basically did that in reverse with the Jabiru by removing the two back seats and certifying it as a new plane with a lower max weight so it would be LSA.
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Re: Limit to 120 KCAS at sea level only with custom EMS - still an LSA?

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fatsportpilot wrote: Could they certify it as a new plane entirely and sell new ones at a higher MTOW?
Probably, if they were willing to go through ASTM conformance testing. Of course, all that assumes that ASTM comes up with a new set of consensus standards that match whatever the FAA ultimately approves.
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Re: Limit to 120 KCAS at sea level only with custom EMS - still an LSA?

Post by fatsportpilot »

drseti wrote:
fatsportpilot wrote: Could they certify it as a new plane entirely and sell new ones at a higher MTOW?
Probably, if they were willing to go through ASTM conformance testing. Of course, all that assumes that ASTM comes up with a new set of consensus standards that match whatever the FAA ultimately approves.
There's a lot more ifs involved in this than I had thought. :(
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Re: Limit to 120 KCAS at sea level only with custom EMS - still an LSA?

Post by drseti »

fatsportpilot wrote: There's a lot more ifs involved in this than I had thought. :(
Never underestimate the perils of bureaucracy.
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Re: Limit to 120 KCAS at sea level only with custom EMS - still an LSA?

Post by Warmi »

drseti wrote:
fatsportpilot wrote: Could they certify it as a new plane entirely and sell new ones at a higher MTOW?
Probably, if they were willing to go through ASTM conformance testing. Of course, all that assumes that ASTM comes up with a new set of consensus standards that match whatever the FAA ultimately approves.
I am always wondering if this is bureaucrats or lawyers or both behind this never ending bureaucratic masturbate-a-thon ... we are talking here about machines that are much simpler than great majority of cars - leave the complicated rules and regulations where they belong , in the commercial and airline industry - GA should operate like the automotive industry.
Flying Sting S4 ( N184WA ) out of Illinois
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