hotrod150 wrote:

akavidflyer wrote:The actual wording is 1320# MAX TAKE OFF WEIGHT not Gross weight (for wheels). I know one person who has succesfully argued, and won the argument with the FAA allowing him to fly his KF mod 5 (with a manufactures stated gross weight of 1550) under sport pilot rules. He just has to limit his max take off weight to 1320#. ...

First of all, please tell me the difference between "maximum takeoff weight" and "gross weight".
Secondly, per FAR part 1 (definitions), 1.1 (general definitions): "light-sport aircraft means an aircraft, other than a helicopter or powered-lift that, since it's original certification, has continued to meet the following:
1) a maximum takeoff weight of not more than ...(ii) 1,320 pounds (600 kilograms) for aircraft not intended for operation on water".
Note the "since it's original certification" qualifier in the applicable FAR.
If the KF 5 in question was originally certified with a gross weight of 1550# , I think that's that-- end of story. Unless it was intended to take off at only 1320#, then be aerial-refueled to it's 1550# gross.

Maximum gross weight is a structural limitation, Maximum take off weight can be a structural limitation, but more often than not, it is imposed for other reasons (length of strip etc.)

http://www.sportpilot.org/questions/afm ... ?faqid=415

The above link should spell it out very clear for you the definition of "maximum take off weight"

I am guessing that you have not dealt much with experimental aircraft... There is NO "certified" gross weight. Gross weight is what ever you decide to call it. The manufacture may reccomend 1200 # gross for my plane, but if I feel lucky, I can legaly fly it at 1700 if I feel the need to test it that far. The weight and ballance is the only place you will ever see a "maximum weight" on an EAB. The aircraft does not have to be registered as LSA to qualify.

You could have stumped me on that one about the LSA but it makes sense. Mine is not LSA but is experimental. When doing the test flight period on my plane I limited my "maximum takeoff weight" to that GW intended and designed in by the company for the safety margins they tested at its rated g factors. The builder, me, must still demonstrate by flying the plane at a maximum weight at some point during the testing phase. Within the first 40 hrs in my case. Builders then must enter in the aircraft log the maximum flown and tested weight during the fly off period because what ever maximum takeoff weight you flew during your testing will be in writing on the aircraft operating limitations the FAA sends you. So, if you do not load it to at least the companies maximum designed weight during testing, then be prepared to live with the most you did fly with. Since you most likely did not fly with a passenger during the first 40 (there are exceptions to this no passenger thing), but instead only flew with full tanks you will not be able to have full tanks and the added weight of a passenger or baggage later even if it is a four place like mine. The DAR was VERY clear about making that point. You set the limits by what you test and enter in the log.

Likewise, during the FAA certification phase of the C150, its designed maximum was tested established and then certified. Meaning the C150's will also forever be over the present maximum allowable take off weight for LSA.

I am about ready to be committed anyway so .......Theoretically, It IS possible if you COULD take a C150 into the experimental class, the math does work, that IF you and your forever anorexic passenger would carry at least more than a half hours reserve of fuel AND could continue to weigh less than 1320 later on every flight, then you could fly off the experimental test hours within that LSA weight limit and have a C150 operated with only a sport pilot license as an experimental. The C150 is 970 empty. Holds 156#s fuel and carries 474 payload for 1600 as a certified plane.
1320 LSA limit - 970 empty wt leaves 350 to work with. Eat much?

Here is the procedure, explanation and log entry used. http://www.ruleaviation.com/experimenta ... ating_.htm

akavidflyer wrote:......
Maximum gross weight is a structural limitation, Maximum take off weight can be a structural limitation, but more often than not, it is imposed for other reasons (length of strip etc.)
http://www.sportpilot.org/questions/afm ... ?faqid=415
The above link should spell it out very clear for you the definition of "maximum take off weight".....

Did you read the whole page that you linked? Go down the page about halfway to ANSWER. And I quote:
"This verbiage clearly says that an aircraft must meet all the criteria called out in the definition of LSA at the time of it's original certification AND CONTINUOUSLY thereafter.One of the items it must meet is a maximum takeoff weight of 1320 pounds (1430 for seaplanes). Since it must meet this requirement continuously since it's original certification, it can NEVER have been operated at a maximum takeoff weight of anything greater than the weight called out in the LSA definition.If it operates at a maximum takeoff weight greater than that called out in the definition EVEN ONE TIME, it no longer meets the definition and is not eligible for operation by sport pilots forever thereafter."
Unless this KF5 being discussed was purpose-built to fall within the LSA limits, I'm betting it's been operated at a higher weight (like the factory recommended limit of 1500#) & probably has paperwork (like a W&B sheet) indicating that.

If there ever was a discussion opened up with the FAA, it would be pretty hard for anyone to argue that the Cessna 140 and 150 should not legitimately be included in LSA/Sport Pilot. Or any of the Aeroncas or T-crafts that are over the limit, etc. etc.

The most defensible argument for a weight increase is that at least two highly experienced designers (Van Grunsven, Heintz) have had extreme difficulties coming up with a simple aluminum LSA that has the structural reserves they were aiming for. Van reportedly had a hell of a time building a reserve into the RV-12, and Heintz tragically went too far when lightening the CH601 HD down to the XL, with several fatalities as a result.

It's pretty easy to build a strong LSA airplane using composite fibers, or for the lighter weight European pilots. But for us fat, well-fed Americans who are interested in building with tin snips and rivets... it is very difficult to engineer a strong conventional aircraft layout to meet LSA. You have to go to oddball configurations like flying wings or lifting bodies. Those actually work fine when done right, but most pilots can't wrap their head around it.

avidflyer and hotrod 150. I think you both are right with points you are trying to make. The way I understand avidflyers point is that he is referring to an experimental KF5 that is customer built and never flown over the 1320 limit. The plane is not an LSA but an experimental KF5 with a lower weight limit logged during the Phase one testing. Then he would be correct in that the FAA has allowed such a plane to be operated with only a sport pilot license.

If on the other hand the plane is a factory built S-LSA, (It would not be a KF5 but most likely the KF7 which is an FAA qualifiying S- LSA) then in that situation what hotrod 150 has said is correct. Whats done is done. The weight has been established and cannot change.

(But to clarify or confuse the point further)
From EAA sport pilot aviation services.

"What is a Special Light-Sport Aircraft
A special light-sport aircraft (S-LSA) is a factory-built, ready-to-fly aircraft designed in construction accordance with the ASTM consensus standards for light-sport aircraft (LSA).

In addition to recreational flying, S-LSA can be rented and used for flight instruction. They must be maintained and inspected by a certificated repairman with an LSA maintenance rating, a standard FAA aircraft maintenance rating, known as an airframe and powerplant (A&P) rating, or at an FAA authorized repair station. Pilots can perform preventive maintenance on S-LSA.

Private owners of these aircraft may change an S-LSA’s airworthiness certificate to experimental light-sport aircraft status (E-LSA). This allows the owner to perform the annual condition inspection after attending a 16-hour course to obtain a light-sport aircraft repairman’s certificate with an inspection rating. However, once an S-LSA is certificated as an E-LSA, it can no longer be used for rental or commercial flight training."

So yet another separate class of experimental LSA's exist.

I guess that my thoughts lean more towards the Sport Pilot flying an experimental ameture buil aircraft and not one that is registered as LSA. This is where everyone seems to get confused.

One other point, it was mentioned that what ever weight you document during the phase one flight testing will be issued as the gross weight of said aircraft on the operating limitations sent to you from the FAA. I sent my 10 bucks in and got every document that the FAA has for my aircraft. NO WHERE, in ANY of the documentation is there a mention of ANY weight. The other 4 people who I know that have done this and recieved the CD from the FAA also do not show any weights.

In my case, the original log books,build log etc, were destroyed in a house fire. The only documents for my plane were on file with the FAA. Nowhere is there a place in those documents that the FAA can prove the plane was EVER flown above XXXX weight (or at any weight for that matter).

You can argue back and forth on it all day long, yet the fact remains that regardless of what the EAA has published, and what the "technical counselor" with the EAA will say to your face, there are those who have approached the FAA and are indeed able to fly XX (experimental) aircraft under the Sport Pilot priveledges even though the plane has a factory reccomended "gross weight" of 1550 pounds.

It is my understanding that, certificated or experimental, all aircraft must have an "operating limitations" document which is the "O" in the old "ARROW" list of required stuff. It may be true that you don't have to submit them to the FAA when getting your homebuilt signed off, I don't know. But if someone spells out any higher than 1320 in the operating limitations or on the W&B sheets, even if he revises that down later, then that airplane is not LSA compliant per everything I've ever read about it. But if someone's doing just that & getting someone to buy into it-- more power to him.

EZFlap wrote: If there ever was a discussion opened up with the FAA, it would be pretty hard for anyone to argue that the Cessna 140 and 150 should not legitimately be included in LSA/Sport Pilot. Or any of the Aeroncas or T-crafts that are over the limit, etc. etc......

You are perfectly correct if you're talking about logic & common sense, but remember that we're dealing with the FAA-- who sez logic & common sense have anything to do with it?
I think they should leave the LSA regs alone, and instead change the sport pilot reg's so a SP can fly an LSA, AND also say any 2-place airplane with a top speed of say 150 & a stall speed of say 60. Or just go ahead & revise the reg's to eliminate the 3rd class requirement for certain (small/slow) aircraft. Or just get rid of the 3rd class medical altogether. Take your pick.
These are all logical ideas but I'm not gonna hold my breath waiting for the FAA to act on them.

As it would happen, I'm having my EAB plane inspected by the FAA tomorrow. I'll bring up some of the points I've read here regarding gross weight and see what the nice man from Fresno FSDO has to say.

svanarts wrote:As it would happen, I'm having my EAB plane inspected by the FAA tomorrow. I'll bring up some of the points I've read here regarding gross weight and see what the nice man from Fresno FSDO has to say.

I would like to know what he says, this may effect my future build plans.

Don't forget that LSA has other limitations - like max speed and max stall speed. I doubt that most aircraft in the class we're discussing would have much trouble with the max speed but the max stall speed probably would be an issue. What does a configured C150 at GW stall at?

I think that this thread is generally asking the wrong questions by trying to finagle non-LSA aircraft into the LSA envelope. The better question to ask - and this would fit right in with the OPs desire to start lobbying - is where is LSA going? If 3rd Class medicals go away the divide between LSA and PP narrows to a degree. I would expect to see some further refinement of LSA parameters at a minimum and quite possibly further significant revision of regulation for all aircraft under some cutoff (whether it's weight based or performance based). It won't happen tomorrow but LSA didn't materialize out of thin air either. Decide what it is you really want to see happen and start trying to build support for it.

Interestingy Piper just pulled out of LSA, there are a lot of factors that could have driven that decision but clearly one of the major players doesn't see sufficient potential in the market sector to compete there. Sign of things to come? The class is crowded and none of them are "affordable".

Vick wrote: Don't forget that LSA has other limitations - like max speed and max stall speed. I doubt that most aircraft in the class we're discussing would have much trouble with the max speed but the max stall speed probably would be an issue. What does a configured C150 at GW stall at?
......

Factory POH for a 1966 C150F sez stall speed is 55 mph calibrated , which is 47.7 knots, so it just misses the LSA limit of 45 knots CAS. I had assumed that at least the C150 amaong the trainer class of airplanes we're talking about would meet the stall speed requirement. Good catch, thanks for pointing that one out.

hotrod150 wrote:
Factory POH for a 1966 C150F sez stall speed is 55 mph calibrated , which is 47.7 knots, so it just misses the LSA limit of 45 knots CAS.

Dang, you're right. I had this distant hazy memory of something written being 48 miles an hour, but that is probably flaps out and the LSA rule is flaps in.

VG's might solve that if it were the only problem. I believe that the VG manufacturers did extensive flight testing which became approved data, so you could make a case for it. Or you could get all ghetto and adjust the flap stops to where "retracted" was at 10 degrees

Belite made their little plane part 103 compliant by leaving off the fabric ahead of the tail feathers. Exposing the tubing caused drag. Slowed it down enough to qualify. Engineered drag should work on others too.

For reference, Light Sport Aircraft definition from FAR 1.1:

Light-sport aircraft means an aircraft, other than a helicopter or powered-lift that, since its original certification, has continued to meet the following:
(1) A maximum takeoff weight of not more than--
(i) 660 pounds (300 kilograms) for lighter-than-air aircraft;
(ii) 1,320 pounds (600 kilograms) for aircraft not intended for operation on water; or
(iii) 1,430 pounds (650 kilograms) for an aircraft intended for operation on water.
(2) A maximum airspeed in level flight with maximum continuous power (VH) of not more than 120 knots CAS under standard atmospheric conditions at sea level.
(3) A maximum never-exceed speed (VNE) of not more than 120 knots CAS for a glider.
(4) A maximum stalling speed or minimum steady flight speed without the use of lift-enhancing devices (VS1) of not more than 45 knots CAS at the aircraft's maximum certificated takeoff weight and most critical center of gravity.
(5) A maximum seating capacity of no more than two persons, including the pilot.
(6) A single, reciprocating engine, if powered.
(7) A fixed or ground-adjustable propeller if a powered aircraft other than a powered glider.
(8) A fixed or autofeathering propeller system if a powered glider.
(9) A fixed-pitch, semi-rigid, teetering, two-blade rotor system, if a gyroplane.
(10) A nonpressurized cabin, if equipped with a cabin.
(11) Fixed landing gear, except for an aircraft intended for operation on water or a glider.
(12) Fixed or repositionable landing gear, or a hull, for an aircraft intended for operation on water.
(13) Fixed or retractable landing gear for a glider.

Tyler wrote:

svanarts wrote:As it would happen, I'm having my EAB plane inspected by the FAA tomorrow. I'll bring up some of the points I've read here regarding gross weight and see what the nice man from Fresno FSDO has to say.

I would like to know what he says, this may effect my future build plans.

Well first of all I'm proud to say that I now have an airworthy S6ES!

Secondly this only pertains to experimental amateur built aircraft.

I told him that for my particular kit, the gross weight people list for them is all over the map. Even the manufacturer changes the gross weights sometimes on the same model. Given that I'm not an engineer what determines my gross weight? His answer was that it's determined by the maximum weight I test in my Phase 1 flight testing. That's the weight that gets entered into the logbook. If I want to increase the gross weight of my EXPERIMENTAL aircraft, I have to put it back into Phase 1 testing, test that weight, and document that weight in the aircraft log.

I didn't ask about certified aircraft. I think the regs on that are pretty cut and dried.

I also asked if my plane could be flown by a light sport pilot. He said that as long as the plane met the standards (that Vic posted above) and the pilot flew in accordance with light sport regs, then it was perfectly acceptable.

That's all I remembered to ask because frankly I was too distracted thinking about the first flight.

I have his email address so if anyone has a specific question I'd be happy to email and ask him.