LSA Values Declining?

[designrs]

Why wouldn't a manufacturer who offered dual screen options provide an LOA to an owner who wanted to add a second screen, same as they were offering from the company?

[drseti]

Some manufacturers are fine with issuing an LoA, Richard. Some never do. Some will, only if you pay them. Some do only if you pay them in Zlotys or Kronas. It's all up to the company, and there is no consistency.

[FastEddieB]

A very real problem in the SLSA world. Especially with smaller and/or struggling manufacturers.

I had a friend with a battery installed in the Sky Arrow he bought that was not covered by an LOA.

3i, the manufacturer, was going through reorganization and did not have the resources to provide any LOA's for a while.

The only approved battery was an Italian FIAMM, regular flooded lead acid battery only available shipped from Italy. Total cost with shipping in excess of $300.

It seems like many just don't worry about things like this or tires or tubes or dozens of other things that technically require an LOA. Just a matter of time before there's an issue and someone gets violated.

This whole conundrum was a major factor prompting my move to ELSA.

[Nomore767]

Why wouldn't a manufacturer who offered dual screen options provide an LOA to an owner who wanted to add a second screen, same as they were offering from the company?

Vans currently offer a single Dynon Skyview 10" screen. You can opt for the Touch screen for an additional $395.

Later this year, they indicated that they will offer a dual Skyview set-up having overcome engineering issues. Sometime after that, they indicated they will offer dual Garmin G3X Touch screens.

Under this scenario, with an SLSA, the customer could presumably opt for a single screen now and upgrade to dual screen later on, without requiring a LOA since Vans are already delivering airplanes with single and dual screens.

The customer can choose the options that best fit their needs. I chose vans because they ARE a US company and because not only do they produce an efficient airplane but they produce it at a very good price. I like the single screen for now, the extra screen, for ME, is a nice luxury. The point about having an active pilot in the other seat is well taken. There might be a flying club/partnership and so this would make more sense than say my situation, where it's me flying solo 99% of the time.

[3Dreaming]

Actually if you look at 91.327 it says that modifications need manufacturer approval or by someone acceptable to the FAA. You may have another option other than going experimental.

[MrMorden]

Some manufacturers are fine with issuing an LoA, Richard. Some never do. Some will, only if you pay them.

Honestly, this is one of the few things I really HATE about Flight Design Germany. FD USA is happy for us to make changes to airplanes, but the Germans want their pound of flesh to let you do *anything*.

Example 1: I wanted to enable the existing AOA function of my Dynon D-100. To do this required a very simple pitot change, and running a second pitot line down the wing along same path as the first one. Simple, and already done in many CTSWs. FD Germany wanted a $600 "engineering fee" to issue the MRA letter and guidelines. That made the whole idea uneconomical and it did not get done. I did not get enhanced safety, and FD got no money. If the fee had been reasonable (say, $100), it would have been win/win instead of lose/lose.

Example 2: I bought a gently used TruTrack autopilot from a friend that was factory installed in a 2007 CTSW, the same year as mine. I had the servos, head, and wiring harness AS INSTALLED BY FD. It was as "plug and play" as you could imagine. Yet FD wanted their $200 "engineering fee" to issue an MRA for my airplane to install it. I paid that one, but I did grumble. A lot.

Deutchland uber alles my behind.

[MrMorden]

Actually if you look at 91.327 it says that modifications need manufacturer approval or by someone acceptable to the FAA. You may have another option other than going experimental.

I think the problem with that is that the FAA defers to ASTM for all things LSA, and the ASTM standards don't allow for "field approvals" of any type. So unless the FAA specifically designates somebody as "acceptable", then the ASTM standards are it. Meaning nobody but the factory can approve a modification.

It would be super if the FAA would come up with a form "337-LSA" or something that allowed a rated A&P to field approve a modification or repair in the same way as they can for certificated aircraft, based on industry standard techniques.

[dstclair]

The LOA process for S-LSAs is one of those things that looks good on paper but can be a bit difficult in practice. I've been fortunate in that my particular manufacturer does, in essence, blanket approvals for equipment that becomes standard equipment or an option on their planes. They also tend to approve broad families of products. For instance, for GPS Systems they approve 'Garmin' 'Aera Series' or with Batteries where they approved Odyssey, all PC series.

Just another item to evaluate when you purchase an S-LSA.

[drseti]

Under this scenario, with an SLSA, the customer could presumably opt for a single screen now and upgrade to dual screen later on, without requiring a LOA since Vans are already delivering airplanes with single and dual screens.

Not entirely correct, Howard. Under ASTM rules, to modify an existing SLSA (even to bring it up to what's currently being manufactured), one needs either an LoA or a Service Bulletin authorizing the work (and specifying who can perform it, and how).

[drseti]

the Germans want their pound of flesh to let you do *anything*.

Technically, that's a pound of Euros. Used to be a pound of Deuchmarks, which was quite a bargain...

[drseti]

manufacturer approval or by someone acceptable to the FAA.

Tom, the only case I know of the FAA designating "someone" as acceptable is in the case of an orphaned SLSA, when somebody else assumed responsibility for support. Do you know of any other specific FAA-designated "acceptable" alternatives?

[3Dreaming]

Actually if you look at 91.327 it says that modifications need manufacturer approval or by someone acceptable to the FAA. You may have another option other than going experimental.

I think the problem with that is that the FAA defers to ASTM for all things LSA, and the ASTM standards don't allow for "field approvals" of any type. So unless the FAA specifically designates somebody as "acceptable", then the ASTM standards are it. Meaning nobody but the factory can approve a modification.

It would be super if the FAA would come up with a form "337-LSA" or something that allowed a rated A&P to field approve a modification or repair in the same way as they can for certificated aircraft, based on industry standard techniques.

Andy, the form 337 is just the vessel to report the modification, and not an approval to do it. In the case of ASTM compliant aircraft it is the responsibility of the manufacturer to keep the information, and not the FAA. Even if a modification was approved by someone other than the manufacturer they would still be required to keep track of it.

As for the FAA deferring to ASTM, I don't think that is the case. If it were the FAA wouldn't have started doing independent audits of manufacturers.

[3Dreaming]

manufacturer approval or by someone acceptable to the FAA.

Tom, the only case I know of the FAA designating "someone" as acceptable is in the case of an orphaned SLSA, when somebody else assumed responsibility for support. Do you know of any other specific FAA-designated "acceptable" alternatives?

I don't know of any, but if a manufacturer was not allowing a LOA for a safety improvement I think there would be a good case to look into it.
If it is just the fact that the manufacturer is charging for the LOA I don't think the FAA will be much help.

[CTLSi]

......

[Wm.Ince]

Why wouldn't a manufacturer who offered dual screen options provide an LOA to an owner who wanted to add a second screen, same as they were offering from the company?

Vans currently offer a single Dynon Skyview 10" screen. You can opt for the Touch screen for an additional $395.
Later this year, they indicated that they will offer a dual Skyview set-up having overcome engineering issues. Sometime after that, they indicated they will offer dual Garmin G3X Touch screens.
Under this scenario, with an SLSA, the customer could presumably opt for a single screen now and upgrade to dual screen later on, without requiring a LOA since Vans are already delivering airplanes with single and dual screens.
The customer can choose the options that best fit their needs. I chose vans because they ARE a US company and because not only do they produce an efficient airplane but they produce it at a very good price. I like the single screen for now, the extra screen, for ME, is a nice luxury. The point about having an active pilot in the other seat is well taken. There might be a flying club/partnership and so this would make more sense than say my situation, where it's me flying solo 99% of the time.

I would examine that closer.
When I was shopping for an S-LSA, I specifically inquired about LOA's with Vans.
As of late 2013, they told me they do not issue them. Period.
I ask why and they told me it was too costly and cumbersome to track LOA data for each and every S-LSA, RV-12 airplane.
For me, that was almost a deal breaker for the RV-12. Of course, the solution was to register the new airplane as E-LSA, which Van's will do at delivery (for small fee).
According to Flight Design, it is all about staying within ASTM and FAA rules.