LSA and Experimental Stall Speeds

Paul Hamilton is one of the first persons to become a DPE (Designated Pilot Examiner) for sport pilots. As a full-time author and sport pilot expert, he writes books and produces DVD's for Aviation Supplies and Academics (ASA). Now Paul has graciously agreed to answer your questions here. Thanks Paul! For more information about Paul, please visit www.Paul-Hamilton.com and www.Sport-Pilot-Training.com.

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srhalter58
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LSA and Experimental Stall Speeds

Postby srhalter58 » Mon Feb 14, 2011 12:38 pm

I am looking at a used experimental plane and the build specs state 45kn clean stall but the Operating limitations states 46kn as built, Does this void the LSA status?

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Postby 3Dreaming » Mon Feb 14, 2011 3:35 pm

You might need to dig into it a little farther. Most of the time when you say operating limitations for an experimental it refers to the document that goes along with the airworthiness certificate. These will state how the airplane can be operated and how it must be maintained. I doubt there would be any mention of speeds in this document. The owner builder may have made up a paper that they are calling operating limitations with speeds on it. If this is the case then you need to find out what kind of speed it is. If they are using indicated airspeed you might still bo OK, because the 45kt limit is calibrated airspeed. It takes bunch of testing to figure out what errors are in the pitot system to come with the correction to get calibrated airspeed. I think I would check with the manufactures and maybe use their numbers. Tom

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drseti
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Re: LSA and Experimental Stall Speeds

Postby drseti » Mon Feb 14, 2011 5:01 pm

srhalter58 wrote:I am looking at a used experimental plane <snip> Does this void the LSA status?


Just to clarify terminology: an experimental aircraft can be either an Experimental Light Sport (E-LSA) or an Experimental Amateur Built (E-AB). The former must be based upon an ASTM-compliant Special LSA design, and built exactly in accordance with the published design. The latter can be anything. If an E-AB happens to meet all the restrictions imposed upon an LSA (gross wt, cruise speed, and stall speed limits, as well as being fixed gear, single reciprocating engine, fixed pitch or ground adjustable prop, two seats maximum, non-pressurized cabin), then it can be flown by a Sport Pilot. This does not make it an LSA. Rather, it would be a Sport Pilot eligible experimental amateur-built aircraft.

It's a subtle distinction, I know, but one of which anybody flying a homebuilt should be aware.

More important, possibly, are the maintenance constraints. I believe that anyone who buys an E-LSA can get a repairman certificate by taking a 16 hour course. This will allow you to do your annual condition inspection yourself. In the case of an E-AB, only the original builder can get the repairman's certificate. It cannot be transferred with the plane, so unless you are an A&P with an Inspection Authorization, you will not be allowed to do your own annuals. (That might be a good reason to buy an E-LSA instead of an E-AB, or perhaps to build your own E-AB.)
The opinions posted are those of one CFI, and do not necessarily represent the FAA or its lawyers.
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bryancobb
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Re: LSA and Experimental Stall Speeds

Postby bryancobb » Mon Feb 14, 2011 6:06 pm

drseti wrote:
srhalter58 wrote:
More important, possibly, are the maintenance constraints. ... In the case of an E-AB, only the original builder can get the repairman's certificate. It cannot be transferred with the plane, so unless you are an A&P with an Inspection Authorization, you will not be allowed to do your own annuals.


You are right about the Repairman Certificate being ONLY issued to the Primary Builder and non transferable. Not True about the A.I though Doc! Any A&P can sign off the Condition Inspection on an EAB.
Bryan Cobb
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Cartersville, Ga
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drseti
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Re: LSA and Experimental Stall Speeds

Postby drseti » Mon Feb 14, 2011 6:11 pm

bryancobb wrote:Any A&P can sign off the Condition Inspection on an EAB.


Although it's true that an IA is not required in order to sign off a Condition Inspection on an E-LSA (any A&P can do so), it's not clear to me from the FARs that this is also the case with an E-AB. If you can cite a regulation that specifies this, Bryan, that would clarify the question for me, and be greatly appreciated.
The opinions posted are those of one CFI, and do not necessarily represent the FAA or its lawyers.
Prof H Paul Shuch
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bryancobb
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You Won't Find it!

Postby bryancobb » Mon Feb 14, 2011 8:54 pm

Doc,
You will not find it anywhere in the FAR's. As you probably know, FAR 91.409 spcifically EXCLUDES all experimental aircaft from requiring an annual inspection. FAR 43.1 also states that its' maintenance rules DO NOT apply to experimentals.

Now, when a DAR gives an experimental aircraft its' airworthiness inspection, he, under the authority of THE ADMINISTRATOR, types up an OPERATING LIMITATIONS LETTER, defining "additional limitations that the Administrator finds necessary," I.A.W. FAR 91.319, and FAA Order 8130-2C.

This letter typically assigns a test-flight area, Phase I and Phase II limitations that prohibit flight outside the test area or carrying passengers for the first 40 hours (uncertified engine) or 20 hours (certified engine), and spell out the requirements for an ANNUAL CONDITION INSPECTION performed by the Builder/Repairman, OR a licensed A&P Mechanic, per FAR 43 Appx D.

Here are some excerpts from an OP LIM Leter on a Mini-500 Helicopter on which I was involved in helping thebuilder get the Airworthiness Inspection.

10. This aircraft shall not be operated unless within the preceding 12 calendar months, it has had a condition inspection performed in accordance with Appendix D of part 43 and found to be in condition for safe operation. This inspection must be recorded in the aircraft maintenance records.

11. The condition inspection shall be recorded in the aircraft maintenance records showing the following statement: "I certify that this aircraft has been inspected on (insert date) in accordance with the scope and detail of Appendix D of 14 CFR part 43, and found to be in condition for safe operation." The entry must include the aircraft total time in service, the name, signature, and certificate type and number of the person performing the inspection.

12. Only FAA-certificated mechanics with appropriate ratings as authorized by 14 CFR part 43.3 may perform inspections required by these limitations.
Bryan Cobb

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bryancobb
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Original Question

Postby bryancobb » Tue Feb 15, 2011 7:48 am

srhalter58,

The simple answer, and the one you will probably want to go by, is THE PUBLISHED number that the manufacturer puts in their kit specifications. That's the number that was derrived with the most flight testing. Very few, if any, homebuilts are adequately tested during PHASE I to determine ACTUAL STALL SPEEDS.

No one would ever question that. If you were to ever be ramp-checked and asked to PROVE the aircraft met LSA criteria, I can't picture an FAA guy saying "The sales brochure says stall speed is 45 and the OP LIM letter says 46. Prove to me which one it really is."

As said above...all you would have to say is "the pitot static system is not certified and calibrated, and the OP LIM letter added 1 knot to the published number just for safety."

My humble opinion is YOU ARE GOOD TO GO to fly this plane as a Sport Pilot if you buy it.
Bryan Cobb

Sport Pilot CFI

Commercial/Instrument Airplane

Commercial Rotorcraft Helicopter

Cartersville, Ga

bryandcobb@att.net

comperini
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Re: LSA and Experimental Stall Speeds

Postby comperini » Tue Feb 15, 2011 4:29 pm

drseti wrote:This does not make it an LSA.


Why wouldn't it? 14 CFR 1.1 defines a light sport aircraft, and pretty much says that any aircraft (regardless of how its certificated) is a light sport aircraft, if it meets all the requirements as defined there.
- Bob
Commercial pilot, CFI, DPE, Light Sport Repairman/Maintenance
http://www.sportpilotinstructor.com

bryancobb
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Yup

Postby bryancobb » Tue Feb 15, 2011 8:22 pm

A Piper Cub, Taylorcraft, Ercoupe C-Model, and some Luscombs are all Light Sport Aircraft as are Kitfoxes, Avids, Rans' .... and on and on.
Bryan Cobb

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drseti
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Re: LSA and Experimental Stall Speeds

Postby drseti » Tue Feb 15, 2011 10:15 pm

comperini wrote:14 CFR 1.1 defines a light sport aircraft, and pretty much says that any aircraft (regardless of how its certificated) is a light sport aircraft, if it meets all the requirements as defined there.


I hope I'm not being overly pedantic here, but we must distinguish between the LSA (which comes in two flavors, S-LSA and E-LSA) and the sport pilot eligible aircraft. The main visible difference is the color of the airworthiness certificate (certificated airplanes have a white one, and the "special" certificate is pink).

This makes little difference to the pilot (any Sport Pilot, or higher rated pilot exercising Sport Pilot privileges, can fly either, without a current medical certificate). But it makes a big difference in the maintenance rules. Take a good look at Part 43. A Cub, Champ, T-Craft, Luscombe, or Ercoupe that meets the LSA restrictions is not an LSA. It is still a Part 23 certificated aircraft, which means it can't be worked on with an LSA repairman's certificate, and has to have its condition inspection performed by an IA.
:(

Even those preventive maintenance operations which are allowed under AC 43.13 Appendix A may be problematic with these classics. The FARs say that, to do approved preventive maintenance on his or her own certificated aircraft, an owner/operator must hold a Private Pilot or above certificate. With an S-LSA, on the other hand, the owner/operator need only hold a Sport Pilot license in order to perform preventive maintenance. (The additional training to become a Private Pilot , of course, doesn't include anything having to do with maintenance, preventive or otherwise.)

Case in point: one of my students bought a nice Ercoupe. It is emphatically Sport Pilot eligible. But, it has a standard airworthiness certificate, hence it is not an LSA. Thus, my student can't change oil or tires on his own plane, because he doesn't have a Private Pilot or higher certificate. In order to get one, he'd need to have a medical. So, it appears that the FAA believes that high blood pressure, for example, makes one unqualified to change engine oil. Go figure.
The opinions posted are those of one CFI, and do not necessarily represent the FAA or its lawyers.
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Re: Yup

Postby drseti » Tue Feb 15, 2011 10:26 pm

bryancobb wrote:A Piper Cub, Taylorcraft, Ercoupe C-Model, and some Luscombs are all Light Sport Aircraft


Watch out with the Ercoupes, guys; there's a trap in the regulations.

The Ercoupe 415C was most certainly Sport Pilot eligible, as originally built. Decades back, Univair came up with an STC raising the max gross weight to 1400 pounds. This was mostly a paperwork change, requiring little modification to the aircraft itself. Because there was no good reason not to (the LSA rule wasn't even yet a gleam in the Administrator's eye), a huge percentage of the 415C fleet got this STC, got new Operating Limitations, and flew safely at the higher weight.

The FARs specify that if an aircraft has ever had an airworthiness certificate that authorized operations out of the LSA envelope, it can never go back and become Sport Pilot eligible. So, most 415Cs can not be legally flown by Sport Pilots. End of story.

Before you buy an Ercoupe hoping to fly it under Sport Pilot rules, you need to check all of its FAA records, specifically to see if it ever received the weight increase STC. If yes, then you're out of luck.

BTW, because of this, those few truly Sport Pilot eligible Ercoupe 415Cs out there have increased greatly in value. As recently as five years ago, a nice one could be had for around $20k. They're now going for over 30.

Disclaimer: although I am a former member of the Ercoupe Owner's Club, these opinions are mine, not necessarily the Club's.
The opinions posted are those of one CFI, and do not necessarily represent the FAA or its lawyers.
Prof H Paul Shuch
PhD CFII DPE LSRM-A/GL/WS/PPC iRMT
AvSport LLC, KLHV
fly@AvSport.org
AvSport.org
facebook.com/SportFlying
SportPilotExaminer.US

comperini
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Re: LSA and Experimental Stall Speeds

Postby comperini » Tue Feb 15, 2011 11:57 pm

drseti wrote:I hope I'm not being overly pedantic here, but we must distinguish between the LSA (which comes in two flavors, S-LSA and E-LSA) and the sport pilot eligible aircraft. The main visible difference is the color of the airworthiness certificate (certificated airplanes have a white one, and the "special" certificate is pink).


Yes, I understand everything you're saying (inicluding the standard category issues with maintenance, and the Ercoupe "gotchas"), but really when we get right down to it, "sport pilot eligible aircraft" and the generic term "light sport aircraft" are one in the same (with "light sport aircraft" being the official FAA recognized term). People throw around the "LSA" abbreviation to the point where its only used in the phrase E-LSA or S-LSA, which I think is unfortunate. 14 CFR 61.315 says that a sport pilot can fly any " light-sport aircraft". When they use that term, they are referring to the generic 1.1 definition. The regulation doesn't say "sport pilot eligible".

Just my nit-picking opinion. So many people are already confused over terms, I just like keeping the number of terms to a minimum. That's my only reason for "voting" for the use of the term light-sport aircraft when referring to anything that meets that definition.
- Bob
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http://www.sportpilotinstructor.com

bryancobb
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AGREE

Postby bryancobb » Wed Feb 16, 2011 5:55 am

I agree with you on everything you say Paul, except for the "light sport eligible" term.

Also, the maintenance issues about who can perform the oil change and other maintenance on their plane, practically all disappear in real life for the following reason.

I would guess that 99 percent of aircraft pilot/owners have a close relationship with an A&P who acts as THEIR PERSONAL mechanic.

In my personal experience, a pilot/owner's PERSONAL mechanic usually has no problem SUPERVISING any maintenance the pilot/owner wants to do, and signing the logboks, so long as it is within the pilot/owner's skills and abilities. This is provided for in the regs and is fully legal.

I am not a licensed mechanic, and have done annual inspections, that included major maintenance, on certified helicopters, at my home, ten miles from the airport, under the supervision of MY PERSONAL A.I.. He of course, functioned as INSPECTOR of my work, and signed the logbook entries.

I even had an FAA Safety Inspector visit me at my home because someone filed a complaint about what I was doing. The finding was that everything was compliant so long as MY A.I. was inspecting my work "to the extent necessary."
Bryan Cobb

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Commercial Rotorcraft Helicopter

Cartersville, Ga

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drseti
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Re: AGREE

Postby drseti » Wed Feb 16, 2011 8:45 am

bryancobb wrote:I am not a licensed mechanic, and have done annual inspections, that included major maintenance, on certified helicopters, at my home, ten miles from the airport, under the supervision of MY PERSONAL A.I.. He of course, functioned as INSPECTOR of my work, and signed the logbook entries.


This is an entirely acceptable approach, Bryan (and I'm glad your FAA Safety Inspector agreed!) I am only an LSRM, not an A&P / AI. I've done exactly the same thing on certificated aircraft for decades. EAA calls this an "owner-assisted annual inspection." My IA calls it an "owner-hindered annual" but does them anyway. ;-)
The opinions posted are those of one CFI, and do not necessarily represent the FAA or its lawyers.
Prof H Paul Shuch
PhD CFII DPE LSRM-A/GL/WS/PPC iRMT
AvSport LLC, KLHV
fly@AvSport.org
AvSport.org
facebook.com/SportFlying
SportPilotExaminer.US

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A&P Verses RLSM-A

Postby roger lee » Wed Feb 16, 2011 9:05 am

Remember an A&P can supervise and inspection, but an RLSM-A can not supervise on an inspection.
Roger Lee
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