New FAA proposals?

[RyanShort1]

http://www.psfmagazine.com/2014/03/more ... aa-policy/

Ryan

[zaitcev]

this was discussed here:
http://sportpilottalk.com/viewtopic.php?f=1&t=3575

[Jack Tyler]

Perhaps we need to shift the 'new proposal' topic to the PNC (Primary Non-Commercial) Aviation Rule Committee recommendation that was recently announced. You'll find an overview of it, done by J. Mac McClellan, discussed here:
http://macsblog.com/2014/03/could-your- ... -be-a-pnc/

Haven't a clue about its probability of adoption. In fact, the FAA has recently acted so consistently, illogically anti-aviation that it takes a quantum shift to believe they would approve it. But OTOH it would IMO clearly change the face of recreational aviation for the better.

[MovingOn]

.......

[Merlinspop]

If the issue has to do with avoiding manufacturers' recommended maintenance items, why don't they just say you must comply with those to carry passengers?

A "from the get go" E-LSA wouldn't have the same limitations, only converted ones. Illogical.

[MovingOn]

.......

[MrMorden]

I don't follow what you are saying, but rather than say a converted S-LSA can't carry a passenger, why don't they simply say a converted S-LSA must continue to follow the manufacturers' recommended maintenance procedures if they want to continue to carry passengers? That's more logical than saying they can't carry passengers.

As long as they say the same thing about owner-built ELSA...having two arbitrarily different rules for aircraft that are in the same category is asinine.

[MovingOn]

.......

[Jack Tyler]

[From my Friday morning email box]
EAA Steps Up to Protect Amateur-Builts, LSA, Others
Working with FAA to Amend Order 8130.2H

March 26, 2014 - For the past two months, EAA has been working with the FAA to eliminate or mitigate potential problem language in the draft of FAA Order 8130.2H, which regulates aircraft airworthiness certification and operating limitations. EAA advocacy staff and the EAA Homebuilders Advisory Council identified several issues with the proposed language that would have had negative effects for the certification and flight of experimental aircraft. Many of the objectionable changes were found in the draft order's Appendix C, a totally new section of 8130.2 designed to streamline the process of assigning operating limitations to experimental aircraft.

An EAA government team traveled to Washington, D.C., to bring EAA's concerns with the proposed changes to the attention of senior officials in the FAA's aircraft certification and flight standards divisions. That team included Joe Gauthier of EAA's Homebuilt Aircraft Council, EAA Warbirds of America board member Jack Harrington, and Sean Elliott, EAA vice president of advocacy and safety.

"EAA has significant issues with many parts of the draft order, and we received verbal assurances from FAA officials that they were receptive to changes to the language that would maintain the intent of the previous order [8130.2G], while streamlining the document and making it more user-friendly," Elliott said. "We want to prevent any potential problems for aircraft owners and builders before these FAA order updates are finalized. We will continue to work with FAA officials until we have a draft that is acceptable to our community."

EAA is also finalizing its official comments to the draft order, which will address all areas of concerns regarding electric, S-LSA, E-LSA, E-AB, and E-exhibition aircraft certification and operating limitations. The comments will be posted at www.eaa.org as soon as they are submitted to the FAA later this week.

[Merlinspop]

I don't follow what you are saying, but rather than say a converted S-LSA can't carry a passenger, why don't they simply say a converted S-LSA must continue to follow the manufacturers' recommended maintenance procedures if they want to continue to carry passengers? That's more logical than saying they can't carry passengers.

Say you and I both want a Fabulous Flying Flivver light sport. You want yours to be factory built, but I go with a kit. Remember there is NO 51% rule for E-LSAs; it can be as complete as the customer is willing to pay for. You get 100 (S-LSA) and I get 101 (E-LSA) on the same day. All I have to do to complete my 'kit' is install one screw (yes, I'm using an extreme example). We BOTH decide that we would like to have a Squawker 330ES transponder rather than the standard 330, so to be ready for ADS-B down the road. The two units are slide in replacements, weigh essentially the same, and most certainly have no effect on the flight qualities of the FFF. I make a log book entry and revise the W&B and equipment list BUT, for you to have that transponder, you have to convert to E-LSA or get a LOA from the factory (for the sake of the example, let's say the factory went bankrupt the day after delivery so that LOA won't be forthcoming any time soon). Our two airplanes are identical.

If the draft document were approved in it's current state, YOU would have the limitation against carrying passengers and overflying densely populated areas while I would not.

[MovingOn]

.......

[Merlinspop]

I understand all that. Would you rather have to follow the manufacturers' maintenance requirements or not be able to carry passengers? I'm not arguing that the rule makes sense. But, never mind.

Well, you said you didn't follow what I was saying, so I expounded on it.

Why the change? To me, it seems practical and prudent apply those limitations on an E-LSA temporarily IF a major change is made (i.e.an engine or airframe change) during a flight test period. Isn't this the case with E-AB aircraft? Are converted E-LSA's experience issues at a higher rate than (nearly) identical S-LSAs? There probably aren't a whole lot of LSA models around in a statistically significant number of E-LSA, S-LSA AND converted S- to E- versions of the same airframes to do a meaningful analysis.

The ability to convert to E-LSA is important in cases where the factory is no longer in business (as just one example). Not that it's likely to happen, but if Evektor, FD, Tecnam or Czech Sport Aircraft went belly up (LSA certification requires an active factory for service bulletins, safety notices, keeping maintenance manuals up to date, issue LOAs, etc) and no one picked up the responsibility, a lot of owners would be screwed big time. That would kill values pretty quickly.

[MovingOn]

.......

[3Dreaming]

I understand all of that and agree. Obviously, you totally missed the entire point of my post. I give up.

I understand the point of your post. You are suggesting throwing a bandaid fix on the problem. Others want it changed, so there is no problem.

[MovingOn]

.......