Dan Johnson on LSA Proposed Rule Changes - Latest Update

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PagoBay

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See the link here on HBA to Dan's latest update:

Be sure to read the comments. Valuable Q&A there.
 

proppastie

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Mike Stewart

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Dan Johnson is a force of nature. I've been reading him since his early reviews and reports on hang gliders . . . this must be going back to the 70's. He's stayed on top of the HG's and everything that has come along since in the world of Experimental Aviation or LSA. He's current, accurate, entertaining and accurate and outstandingly informative. Like I said . . . a "force of nature".

Thanks Dan. I hope you've somehow made a living out of your in-depth involvement in the less pricey segments of aviation where you specialize. You're a marvel.
 

PagoBay

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I think Dan's comments have now closed after a couple days.
I don't see any indication the comments are closed. Go ahead and post. On Dan's last article I had to wait a long time for my question to post but eventually it came up along with a very detailed reply from Dan. I am guessing he moderates questions so he can prepare replies that appear along with the post.
 

gtae07

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Dan’s focus seems to be primarily on the LSA side of things, and some of his posters are very, very concerned about what will be flown with an existing Sport Pilot certificate, but there’s (supposed to be) more to MOSAIC than that.

At least as of the last time I spoke to some EAA high-ups involved in the process, some of the other things under consideration/being pushed-for are:
  • Allowing more commercial assistance beyond 49%, but with limitations (e.g. no automatic repairman cert.) if you choose to use that approach
  • Adding a task-based option for Phase I testing
  • Updating a few of the operating limitations issued for E-AB and LSA
  • An alternative way of obtaining a repairman certificate on an E-AB
  • Some way of implementing a form of the Primary Non-Commercial proposal from several years ago
Don’t get me wrong; I’m happy to see that LSA privileges may well be expanded to more aircraft, but I also don’t want to lose focus on the other potential gains.
 

PagoBay

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At least as of the last time I spoke to some EAA high-ups involved in the process, some of the other things under consideration/being pushed-for are:
  • Allowing more commercial assistance beyond 49%, but with limitations (e.g. no automatic repairman cert.) if you choose to use that approach
  • Adding a task-based option for Phase I testing
  • Updating a few of the operating limitations issued for E-AB and LSA
  • An alternative way of obtaining a repairman certificate on an E-AB
  • Some way of implementing a form of the Primary Non-Commercial proposal from several years ago
Very good to see these points. This is my wish list. Regarding #1 and #3 , I asked Dan Johnson about these in his update previous to this one. His reply was not so encouraging, as I recall.

On #1, is the "majority portion" requirement really doing anything in substance? Shouldn't the objective focus be on a safe aircraft, not who built it? After all, and in an apparent contradiction, any one person participating in a team build of an E-AB can be awarded the Repairman's Certificate. That was discussed here on HBA some weeks back. Lots of latitude on how much build time that person actually had to qualify. I spoke with Honolulu FSDO long back. They indicated no special concerns about a % of work in choosing the person to get the RC.

Another interesting case is Chip Erwin's Merlin PSA. This aircraft comes assembled with soft rivets. The builder takes the airplane apart and puts it back together. Completion of 51% of the tasks is done and Chip has the FAA approval of the kit to prove it. In a video interview, Chip emphasizes that the 49/51 rule is based on "tasks" not on "hours".

Further, airworthiness is already the FSDO / DAR responsibility and is a well established process. I understand the "majority portion" had some logic, but seems outdated now. Maybe fuel and electrical installations warrant a higher inspection standard as these two are too often a cause of trouble in an E-AB's early flights.

Others thoughts?

@gtae07 -- Please clarify #5. What is the "Primary Non-Commercial proposal" and does it relate in any way to the #1 in this list?

Thanks.
 

Daleandee

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Maybe fuel and electrical installations warrant a higher inspection standard as these two are too often a cause of trouble in an E-AB's early flights.

Others thoughts?
I would only add that I believe that inspections for airworthiness certificates for builders and those seeking repairman certificates for such builds demonstrate that they thoroughly understand CG & weight and balance of the aircraft at the time of certification. During my last inspection I was given the task of proving how I arrived at every set of numbers on my W&B sheet and what different loadings and CGs would do to aircraft handling and performance. It wasn't enough to throw a spreadsheet at it as I was made to do the calculations by hand. It's not that difficult yet I'm stunned sometimes at the number of people I meet flying airplanes that can't even tell you the empty & gross weights of the plane they fly.

I agree that fuel systems & electrical systems need to be carefully inspected. When it comes to these some builders forget KISS and build in so much redundancy that they have actually lost the safety they thought they had achieved. Sorry to rant on about this ...

Dale
 

Turbine Aeronautics

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TurbAero joined LAMA about 6 months ago and I have sent 2 emails to Dan about representation by LAMA to allow the use of turbines in LSAs. Essentially, instead of seeking an approval for electric powerplants, I have suggested to simply seek to remove the word ‘reciprocating’ in reference to the engine from the definition of an LSA. This would then allow the use of any powerplant (that has a relevant ASTM) to be used including electric and turbine. Clearly turbines are of interest to my business. I have also posted a question about turbines to Dan on the above mentioned website, but it is still indicating that it is being moderated and has not yet been posted publicly. Unfortunately, and I find this a bit frustrating, Dan has not responded to the 2 emails that I have sent to him in relation to seeking approval to use turbines in LSAs. I am feeling that my support of LAMA is not being reciprocated in my case. Still, I shall plug away to campaign to obtain regulatory approval to use turbines in LSAs.
 

gtae07

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The 51% rule is indeed task-based, and IMHO is heavily tilted towards structure over systems. Granted, yes, a simple airplane won’t have much in the way of systems... but I’m a systems guy by profession, and most of the maintenance you’ll do after the build is finished is systems work, not structural.

@gtae07 -- Please clarify #5. What is the "Primary Non-Commercial proposal" and does it relate in any way to the #1 in this list?
PNC was a proposal in the 2013 Aviation Rulemaking Committee’s report on Part 23. It would allow Part 23 aircraft older than 20 years to be treated more like a homebuilt—no commercial use, but allowing non-certified equipment etc. and provisions for owners to much more of the maintenance (IIRC it had something like the Light Sport Repairman process). You’d have to read the report for full details (search for “Part 23 ARC report”). I think the proposal could be better, but that’s just me.

Still, I shall plug away to campaign to obtain regulatory approval to use turbines in LSAs.
I really doubt they’ll go for it. Personally I think LSA should be power source agnostic, but the regulatory types are really really wound up on the idea that turbines take special skills to fly (umm, yes, they’re a little different, but the scope of those differences isn’t that large compared to all the various combinations of piston engines and airframes around) and they’re also really concerned about rotor burst and the engine grenading itself. It’s for those reasons I don’t expect turbines to be allowed.
 

PagoBay

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Thanks BJC - Not sure what was wrong, as you don't explain what you found misleading. I certainly did not intend and I don't think Chip Erwin intended to mislead anyone.

My point and as gtae07 mentions, is that the 49/51 calculation is based on how much of the particular task was done by factory/commercial assist/builder. It does not consider how many hours were required to do a given task. Simply because, I am thinking, the time needed will vary greatly depending on skill and experience of the builder, or lack thereof.

For the example given, Chip's Merlin PSA kit starts at 48.99% for manufacturer. So it is pretty obvious the builder must do the rest. Similar for other kits that offer Quick Build or Fast Build kits that I have inquired about. The quick build option pushes right up to the 49% of TASKS as already completed by the factory.

I, for one, would like this "majority portion" rule changed and the focus for amateur built aircraft placed on the structure and all systems being completed according to long established standards. If this happens, maybe the "two weeks to taxi" programs can expand to many E-AB kits.
 

BJC

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Thanks BJC - Not sure what was wrong, as you don't explain what you found misleading. I certainly did not intend and I don't think Chip Erwin intended to mislead anyone.
Just that it is not as simple a calculation as saying "There are 100 tasks required to build this kit airplane, and I completed 51, so it qualifies as E-AB". The FAA form (linked) explains their method.


BJC
 

TFF

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The FAA does nothing for free. I can see them allow more professional help. I would imagine the trade would be no repairman certificate. I don’t think they care about a Cub being produced as much as an off the shelf homebuilt Lear45. There is plenty of money out there to jump on an open loophole. There are certain planes that would be a natural for some special commercial operations that no certified aircraft are quite right for. Everyone wants what they want, Duh.
 

rv7charlie

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To the question about who among multiple builders gets the Repairman's certificate, and percentage of work he does:

My understanding is that there is no percentage, and more specifically, it is *not* automatic. As someone indicated, the FAA gets to decide whether the builder is competent to *inspect* the a/c, independent from their judgement on whether the a/c met the paperwork & condition requirements to issue the original a/w cert. Evidence is the fact that a DAR can issue the a/w cert, but cannot issue a Repairman's Cert. It may be more 'automatic' in some FSDOs than others, but it's technically supposed to be based on whether the FAA believes that the builder of record listed on the a/w cert has the knowledge and experience to inspect the a/c for safe operation.

Charlie
 

PagoBay

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It may be more 'automatic' in some FSDOs than others, but it's technically supposed to be based on whether the FAA believes that the builder of record listed on the a/w cert has the knowledge and experience to inspect the a/c for safe operation.
Correct. That why I wrote: "Lots of latitude on how much build time that person actually had to qualify [for the RC]. I spoke with Honolulu FSDO long back. They indicated no special concerns about a % of work in choosing the person to get the RC." I was focused not so much on the RC but on how this aspect compares and runs in contradiction to the "majority portion" requirement. Thanks for keeping the record clear and more complete.
 
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