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

Are you building/buying/flying an Experimental Amateur-Built (E-AB) or Experimental Light Sport (E-LSA) aircraft? Converting an S-LSA to E-LSA? Changing or adding equipment, or otherwise modifying an S-LSA? Need help with Letters of Authorization? Or maybe designing your own aircraft? This forum is the place to discuss All Things Experimental.

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

Post by drseti »

Warmi wrote:GA should operate like the automotive industry.
Ah, but the automotive industry has one advantage that GA will never enjoy: massive economies of scale.
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Re: Limit to 120 KCAS at sea level only with custom EMS - still an LSA?

Post by Warmi »

drseti wrote:
Warmi wrote:GA should operate like the automotive industry.
Ah, but the automotive industry has one advantage that GA will never enjoy: massive economies of scale.

That is true unfortunately but ... I was talking from the regulatory point of view.
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Re: Limit to 120 KCAS at sea level only with custom EMS - still an LSA?

Post by 3Dreaming »

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.
Actually it is not that it couldn't be certified at 1320, but that it could never be a light sport aircraft
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Re: Limit to 120 KCAS at sea level only with custom EMS - still an LSA?

Post by 3Dreaming »

Warmi wrote:
drseti wrote:
Warmi wrote:GA should operate like the automotive industry.
Ah, but the automotive industry has one advantage that GA will never enjoy: massive economies of scale.

That is true unfortunately but ... I was talking from the regulatory point of view.
I'm pretty sure the automotive industry has some pretty significant regulations that they have to follow.
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Re: Limit to 120 KCAS at sea level only with custom EMS - still an LSA?

Post by drseti »

3Dreaming wrote: Actually it is not that it couldn't be certified at 1320, but that it could never be a light sport aircraft
Point taken.
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Re: Limit to 120 KCAS at sea level only with custom EMS - still an LSA?

Post by Warmi »

3Dreaming wrote:
Warmi wrote:
drseti wrote:
Ah, but the automotive industry has one advantage that GA will never enjoy: massive economies of scale.

That is true unfortunately but ... I was talking from the regulatory point of view.
I'm pretty sure the automotive industry has some pretty significant regulations that they have to follow.
They do but that’s not what I am talking about.

We could be arguing here all night long but why ... just go to any automotive forum and see the type discussions they are having - it is is all about... should I do this and how do I do this, none of the regulatory “how many FAA angels can fit on the head of a pin” we see discussed here and on other ga aviation forums.
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Re: Limit to 120 KCAS at sea level only with custom EMS - still an LSA?

Post by MrMorden »

The 120kt CAS limit is a limit for *manufacturers* to design to, not for pilots to abide by. Once an airplane is accepted by the FAA as an LSA, you as a pilot can wring whatever performance out of it that you can. If the aircraft type regularly and easily exceeds LSA performance limits, that's a problem between the FAA and the manufacturer, and the pilot need not be concerned at all (unless the FAA revokes the LSA designation for all existing airframes of that type...but then you have a pretty nice lawsuit against the manufacturer).
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Re: Limit to 120 KCAS at sea level only with custom EMS - still an LSA?

Post by fatsportpilot »

MrMorden wrote:The 120kt CAS limit is a limit for *manufacturers* to design to, not for pilots to abide by. Once an airplane is accepted by the FAA as an LSA, you as a pilot can wring whatever performance out of it that you can. If the aircraft type regularly and easily exceeds LSA performance limits, that's a problem between the FAA and the manufacturer, and the pilot need not be concerned at all (unless the FAA revokes the LSA designation for all existing airframes of that type...but then you have a pretty nice lawsuit against the manufacturer).
I'm pretty sure sport pilots can't modify an E-LSA to exceed speed limitations that the pilot also has to obey. Just like a sport pilot can't climb above 10,000 MSL even if the plane has a higher service ceiling.
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Re: Limit to 120 KCAS at sea level only with custom EMS - still an LSA?

Post by Scooper »

fatsportpilot wrote:I'm pretty sure sport pilots can't modify an E-LSA to exceed speed limitations that the pilot also has to obey. Just like a sport pilot can't climb above 10,000 MSL even if the plane has a higher service ceiling.
Sport Pilots can legally fly up to 10,000 ft MSL, or 2,000 ft AGL, whichever is higher. The FAA doesn't want you to fly into high terrain; it could ruin your day.
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Re: Limit to 120 KCAS at sea level only with custom EMS - still an LSA?

Post by fatsportpilot »

Scooper wrote:
fatsportpilot wrote:I'm pretty sure sport pilots can't modify an E-LSA to exceed speed limitations that the pilot also has to obey. Just like a sport pilot can't climb above 10,000 MSL even if the plane has a higher service ceiling.
Sport Pilots can legally fly up to 10,000 ft MSL, or 2,000 ft AGL, whichever is higher. The FAA doesn't want you to fly into high terrain; it could ruin your day.
I know. I mentioned that in a post one page ago but I was giving a fast example and didn't think it was necessary to be that specific.
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Re: Limit to 120 KCAS at sea level only with custom EMS - still an LSA?

Post by 3Dreaming »

fatsportpilot wrote:
MrMorden wrote:The 120kt CAS limit is a limit for *manufacturers* to design to, not for pilots to abide by. Once an airplane is accepted by the FAA as an LSA, you as a pilot can wring whatever performance out of it that you can. If the aircraft type regularly and easily exceeds LSA performance limits, that's a problem between the FAA and the manufacturer, and the pilot need not be concerned at all (unless the FAA revokes the LSA designation for all existing airframes of that type...but then you have a pretty nice lawsuit against the manufacturer).
I'm pretty sure sport pilots can't modify an E-LSA to exceed speed limitations that the pilot also has to obey. Just like a sport pilot can't climb above 10,000 MSL even if the plane has a higher service ceiling.
There is no speed limit for the pilot! The limit is for the airplane. If the airplane is modified to where it is to fast, then it can no longer be a LSA. If it is no longer a LSA, then it can't be flown by a by a sport pilot.
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Re: Limit to 120 KCAS at sea level only with custom EMS - still an LSA?

Post by drseti »

fatsportpilot wrote: I'm pretty sure sport pilots can't modify an E-LSA to exceed speed limitations
Not just Sport Pilots. Nobody can modify a E-LSA to exceed the 120 knot Vh limitation, or the 45 knot clean calibrated stall speed limitation, or add a retractable landing gear, or install a third seat, or constant-speed prop, or a second engine, or cabin pressurization, or anything else that would void its Special Airworthiness Certificate. If it's an E-LSA, it has to stay an E-LSA, no matter who is flying it.
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Re: Limit to 120 KCAS at sea level only with custom EMS - still an LSA?

Post by ShawnM »

I guess as long as there are rules to follow someone will be out there trying to circumnavigate those rules. If 120 kts isn't fast enough for you then go get your private pilot rating and buy a Mooney or something even faster. :mrgreen:
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Re: Limit to 120 KCAS at sea level only with custom EMS - still an LSA?

Post by 3Dreaming »

drseti wrote:
fatsportpilot wrote: I'm pretty sure sport pilots can't modify an E-LSA to exceed speed limitations
Not just Sport Pilots. Nobody can modify a E-LSA to exceed the 120 knot Vh limitation, or the 45 knot clean calibrated stall speed limitation, or add a retractable landing gear, or install a third seat, or constant-speed prop, or a second engine, or cabin pressurization, or anything else that would void its Special Airworthiness Certificate. If it's an E-LSA, it has to stay an E-LSA, no matter who is flying it.
Actually I'm pretty sure that a ELSA could be modified with any of those items. It of course could no longer be a ELSA, but it could be changed to experimental exhibition.
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Re: Limit to 120 KCAS at sea level only with custom EMS - still an LSA?

Post by drseti »

3Dreaming wrote: Actually I'm pretty sure that a ELSA could be modified with any of those items. It of course could no longer be a ELSA, but it could be changed to experimental exhibition.
I think Experimental R&D is a possibility. Maybe even Experimental Exhibition. Both of those come with significant operating limitations. Certainly could no longer be an E-LSA (or any other kind of LSA). I doubt it could be approved by a DAR for an E-AB airworthiness certificate, unless it was completely disassembled down to raw materials, rebuilt from the ground up, and a proper build log generated. But, if you're going to do all that, why not just start from scratch?
The opinions posted are those of one CFI, and do not necessarily represent the FAA or its lawyers.
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