What defines Ultralight V. LSA

[puddles_7]

Guys, it may have escaped you, but nothing about the four CASA audit failures was resolved at the recent General Meeting, just a mexican stand off with one group having collected more votes than another.What is still hanging over our heads is the cost of the four audit results to date, and no guarantee, given the gentle and slow effort to meet compliance, that a fifth audit might not put a rocket into the scene which will affect pilots, owners and importers even more severely.

 

Under those circumstances making up your own version of what an LSA is, could do more harm than good.

 

What counts is what CASA thinks it is, and what the rules are, and it's obvious from this thread that CASA needs to tighten the reins even more, so let's not encourage that by posting more ambiguity.

Turbs

 

Does this mean the rules are set by CASA and not RAA - Andy@Coffs suggested I go straight to Lee Ungerman, starting to look like the case

 

puddles

 

 

[greybeard]

I thought the rules were set by an expert panel on an internet forum, same as the accident investigation reports

 

 

[turboplanner]

TurbsDoes this mean the rules are set by CASA and not RAA - Andy@Coffs suggested I go straight to Lee Ungerman, starting to look like the case

puddles

Not only do I agree with contacting Lee Ungermann, but suggest you put it in writing.

 

 

[Yenn]

Makes me wonder!

 

 

[David Isaac]

What it is registered as and what I like to call it are two different things. Some people give their aircraft names, like boats but I don't. It doesn't fit the category rules but it is light, and it is a sports aircraft just like an MX5 is a sports car.

Kev, I guess that is what is unfortunate when the regulators categorise aircraft registration classes by generic terms used in a prescriptive manner.

Yes I agree that a simple description of the typical high performance Ultralight could be a 'Light Sports Aircraft' or 'Recreational Aircraft'.

 

It is really unfortunate when we add to the confusion by using a prescriptive term in a generic manner, the effect of which may be to misrepresent in a legal sense the prescriptive category of the aircraft we refer to; even though that may not be our intention. That is why I politely suggested not to do that. Personally I would prefer to use the term 'Recreational Aircraft', but that is just my preference, even though I understand your point.

 

 

[David Isaac]

TurbsDoes this mean the rules are set by CASA and not RAA -.....

The Rules have always been set by CASA and are enshrined in the CARs and CAOs. Certain CAOs refer to the RA Aus technical and operational rules which as referenced become a part of the CASA regulations. Essentially we operate under significant dispensations offered in the CAOs relevant to our class of operations which are further defined in our operational rules which also had to be approved by CASA. We cannot amend our Operational rules without approval from CASA.

[Mriya]

That's as good a definition as any. rgmwa

Apart from the fact that it is wrong

LSA describes a specific certification process under which a Certificate of Airworthiness is granted. This process also comes with strict rules regarding modifications or repairs (especially for factory built aircraft).

 

As for the question regarding what is an ultralight, I'd have to say anything which can be registered under RAAus could be classed as ultralight. Obviously we could further sub-divide this category into different types of ultralights (minimum, weight-shift, LSA, High Performance, Powered-parachute, etc).

 

 

[Mriya]

PS. Not aiming to offend in my last post. Hope my comment is taken in the spirit that I intended. I wouldn't claim to be an expert either and so am also happy for anyone to highlight any errors in my understanding.

 

I think the thread does demonstrate that there is a high level of confusion regarding the different categories of aircraft and maintenance options/requirements that exist.

 

The bottom line regarding factory LSA aircraft is that ANY mods done without factory authorisation compromise the Certificate of Airworthiness. I see some people suggesting that a prop substitute can be easily reversed, however this does not take into account potential harmonic damage to the crankshaft/drivetrain when operating it with an untested/unapproved prop. Simply putting the approved prop back on can't garuantee full restoration of the original CofA configuration, which then opens a can of worms regarding what maintenance work is needed to properly restore original factory LSA design once you start tampering with any aspect of a LSA.

 

 

[Guest Andys@coffs]

....... Simply putting the approved prop back on can't garuantee full restoration of the original CofA configuration, which then opens a can of worms regarding what maintenance work is needed to properly restore original factory LSA design once you start tampering with any aspect of a LSA.

Actually I think just putting the Original configuration prop back on does exactly restore the aircraft to the special CoA requirements. If I operate the LSA aircraft exactly as the aircraft was delivered its still the case that the aircraft can become unserviceable, and that restoration by an approved person who will restore IAW manufacturers instructions or in the abscence of those IAW higher level standards that apply to aircraft maintennce, doesnt damage that Special CoA.

 

Your point that operating an aircraft outside of the Special CoA configuartion, apart from being not IAW your obligations, may intorduce other damage is a fair point, but I dont think of itself destroy the validity of the special CoA that Im aware of. The question then becomes does the Special CoA cover a specific serial No Aircraft (that is if the manufacturer builds 1000 LSA aircraft are there 1000 unique Special CoA's or is there only 1 Special CoA for all Aircraft manufactured to the same design and configuration by the same manufacturer (with a copy of that 1 included in each POH) . I think its the later not the former. If its the former then your point may well be valid.

 

Andy

 

BTW Im not trying to be definitive in my statements, I'm not an expert and for my trike the CoA was issued by CASA not the manufacturer (so primary aircraft certification not LSA) and in my 230 being 19 registered its only of peripheral interest.....

 

 

[rgmwa]

Apart from the fact that it is wrong

I know, and no offence taken. The official definition of an LSA is in an earlier post. But I think 80kts is a fair distinction in terms of my own perception of the performance difference. Others may disagree of course.

 

As for the question regarding what is an ultralight, I'd have to say anything which can be registered under RAAus could be classed as ultralight. Obviously we could further sub-divide this category into different types of ultralights (minimum, weight-shift, LSA, High Performance, Powered-parachute, etc).

I guess it depends on what you think `Ultralight' means. There is an RAA registered RV9 for example, which I wouldn't think of as an Ultralight, even though it is lightweight.

rgmwa

 

 

[dazza 38]

Well, I have come to the conclusion, me included that nobody really has any farking idea what is LSA or what isnt to the letter. Just goes to show how complicated all the RAA crapp (sic) has become.

 

 

[djpacro]

A CofA applies to one specific aircraft.

 

 

[Guest Andys@coffs]

So google is my firend and I should have read before posting (Sorry Mriya! you were right!)

 

Before anyone else posts, I suggest you read this:- http://flysafe.raa.asn.au/regulations/LSA_explained.html

 

And to Mriyas point:-

 

<Extract from above, bolding/underline is mine>

 

Certificate of Airworthiness for LSA

 

There are two types of Certificates of Airworthiness for LSA. These are Special Certificates of Airworthiness and Experimental Certificates.

 

The Special Certificate of Airworthiness for LSA is for production ready-to-fly aircraft. These aircraft may be used for hire, flying training and towing gliders. The Special CoA remains valid provided the aircraft is maintained in accordance with the requirements of the manufacturer and the aircraft has not been modified unless approved by the manufacturer.

 

However, if the aircraft is not maintained in accordance with the manufacturer, or the manufacturer can no longer provide the continuing airworthiness, or the aircraft is modified without the manufacturer's approval, the Special CoA will no longer be in force and, to operate the aircraft, the owner will need to apply for and receive an Experimental Certificate.

 

An Experimental Certificate for LSA is available for kit built LSA and for aircraft that no longer satisfy the requirements of the Special CoA. Before an Experimental Certificate can be issued to a kit built aircraft, the manufacturer should have produced a production aircraft of the same model issued with a Special CoA. Unlike the amateur built aircraft, there is no requirement that the owner must build 51% of the aircraft.

 

The Experimental Certificate also provides an avenue for operating aircraft that no longer comply with the requirements of the Special CoA for LSA. There are a number of circumstances where this could arise such as the aircraft has been modified without the manufacturer's approval or has not been maintained in accordance with the manufacturer's requirements. Another circumstance may be that the manufacturer has gone out of business and no suitable persons or organisations have taken over the continuing airworthiness functions for the aircraft.

 

For more information see Advisory Circular 21-41, Light Sport Aircraft Certificate of Airworthiness.

 

 

[damkia]

Well, I have come to the conclusion, me included that nobody really has any farking idea what is LSA or what isnt to the letter. Just goes to show how complicated all the RAA crapp (sic) has become.

What is needed?

"Add lightness and simplicate"

 

Forget the current weight/power/performance limits

 

Above 1500kg gross = GA, or RPL (with excess seats removed to two seats maximum)

 

Below 1500kg = LSA (2 seat maximum)

 

Split by amateur built and factory built only

 

This then nicely coincides with the CASA Recreational Pilots License weight limit, and could incorporate their seating limits too.

 

Three types of licences - PPL, RPL, LSA

 

PPL can fly GA/LSA/RPL aircraft

 

RPL can fly RPL/LSA aircraft

 

LSA restricted to LSA aircraft

 

Simple really - such a pity it will never eventuate.

 

 

[David Isaac]

Trouble with all that Damkia is they are all 'High Performance' ... where does the 95-10 category fit, the category this all started from?

 

 

[Guest nunans]

What it is registered as and what I like to call it are two different things. Some people give their aircraft names, like boats but I don't. It doesn't fit the category rules but it is light, and it is a sports aircraft just like an MX5 is a sports car.

If you think "ultralight" or "microlight" sounds to peasant or agricultural for your liking and you really want to impress your mates then call it a LEARJET ffs... It won't change the fact that you're flying an ultralight kitplane that'll still have to wear the "I'm made of match sticks and could crash at any time" sticker.

 

 

[winsor68]

SThe Special Certificate of Airworthiness for LSA is for production ready-to-fly aircraft. These aircraft may be used for hire, flying training and towing gliders. The Special CoA remains valid provided the aircraft is maintained in accordance with the requirements of the manufacturer and the aircraft has not been modified unless approved by the manufacturer.

However, if the aircraft is not maintained in accordance with the manufacturer, or the manufacturer can no longer provide the continuing airworthiness, or the aircraft is modified without the manufacturer's approval, the Special CoA will no longer be in force and, to operate the aircraft, the owner will need to apply for and receive an Experimental Certificate.

Based upon this and the recent Audit report supplied by CASA ... many LSA factory built aircraft modified etc etc etc will these aircraft in time no longer be certified as suitable for training?

For instance from my recall (I can't be bothered going back in to read the audit again) the Savanah Aircraft were fitted with a non-certified Brolga prop by the importer... is this going to be a can of worms in the coming months for many of the Ra-Aus training fleet?

 

 

[Mriya]

Based upon this and the recent Audit report supplied by CASA ... many LSA factory built aircraft modified etc etc etc will these aircraft in time no longer be certified as suitable for training?For instance from my recall (I can't be bothered going back in to read the audit again) the Savanah Aircraft were fitted with a non-certified Brolga prop by the importer... is this going to be a can of worms in the coming months for many of the Ra-Aus training fleet?

From my understanding regarding LSA's, the question should be did the factory provide an approval for a particular prop to be fitted with their airframe/engine combination? If not, then the aircraft should be operating in an experimental category.

 

Over the years we have actually had a number of very good articles written by various RAAus Technical Managers who go to pains to highlight the pitfalls associated with modifications to LSA aircraft. I know my propeller example used earlier will 'get the attention' of people, and many would consider it 'over the top', however I was just trying to use an example which many people can relate to (because that type of thing happens all the time). Yes a CofA does get issued to an aircraft. In the case of a factory built LSA CofA, it confirms conformance with the original Type Design. Use of non-approved parts (should always be documented) require conversion to an experimental category. Additionally, once non approved items have been used, in order to then restore an aircraft to factory type design conformity requires full consideration of any 'knock-on' effects that the use of 'un-approved' may have had, thus in the case of props, the potential for harmonic imbalance and stress needs to be considered. Aircraft manufacturers go to a lot of trouble to prove that particular airframe/engine/propeller combinations are compatible (thus the reason why Jabiru for many years have not approved other props for their aircraft (although this seems close to changing)).

 

Bottom line is anyone considering making ANY changes to a factory built LSA (or other Type Certificated factory built aircraft for that matter) needs to very carefully consider the possible implications including the difficulty in restoring factory Cof A status.

 

Having said all this I know that what happens in reality is often quite different to what I have described, which may well explain some of why CASA is showing much more interest in how RAAus is administering its 'patch'.

 

 

[David Isaac]

Based upon this and the recent Audit report supplied by CASA ... many LSA factory built aircraft modified etc etc etc will these aircraft in time no longer be certified as suitable for training?For instance from my recall (I can't be bothered going back in to read the audit again) the Savanah Aircraft were fitted with a non-certified Brolga prop by the importer... is this going to be a can of worms in the coming months for many of the Ra-Aus training fleet?

To answer your question Don, it already is a can of worms. Any modification not approved by the factory WILL invalidate the Special Certificate of Airworthiness (note the word 'Special', it is NOT a normal C of A to which DJPACRO was referring to in an above post).

Once the Special C of A is invalidated, the aircraft can no longer be used for training. It has already impacted on several well known brands of aircraft in the Australian RAA fleet.

 

 

[dazza 38]

What is needed?"Add lightness and simplicate"

 

Forget the current weight/power/performance limits

 

Above 1500kg gross = GA, or RPL (with excess seats removed to two seats maximum)

 

Below 1500kg = LSA (2 seat maximum)

 

Split by amateur built and factory built only

 

This then nicely coincides with the CASA Recreational Pilots License weight limit, and could incorporate their seating limits too.

 

Three types of licences - PPL, RPL, LSA

 

PPL can fly GA/LSA/RPL aircraft

 

RPL can fly RPL/LSA aircraft

 

LSA restricted to LSA aircraft

 

Simple really - such a pity it will never eventuate.

I like it.

Just add to the LSA certificate- LP for low inertia minimum aircraft.

 

ALL 3 PPL/RPL/LSA still need endorsements like TW. With the RPL/LSA just add a Navigation endorsement.

 

 

[turboplanner]

Not much point coming up with dream concepts when the real thing is coming towards you like a freight train out of a tunnel ready to destroy our future.

 

Interesting that as much as many people are critical of the executive and board members for failing the audits, most posts here are echoing their lack of action, and denial.

 

The problem is very real, and it is not going away without some serious heavy work.

 

Ozzie, maybe you should be saying something after all.

 

 

[damkia]

Not much point coming up with dream concepts when the real thing is coming towards you like a freight train out of a tunnel ready to destroy our future.Interesting that as much as many people are critical of the executive and board members for failing the audits, most posts here are echoing their lack of action, and denial.

The problem is very real, and it is not going away without some serious heavy work.

 

Ozzie, maybe you should be saying something after all.

If you didn't realise, all that I am suggesting is the removal of some overcomplicated regulations back to some already existing basics. There is nothing new to be added simply a reorganisation of existing structures.

 

I like it.Just add to the LSA certificate- LP for low inertia minimum aircraft.

ALL 3 PPL/RPL/LSA still need endorsements like TW. With the RPL/LSA just add a Navigation endorsement.

I would give a separate endorsement to LP flyers for all classes of licence as the aircraft can be significantly different to fly.

 

Agree with the TW endorsement and Nav endorsement.

 

 

[rankamateur]

Based upon this and the recent Audit report supplied by CASA ... many LSA factory built aircraft modified etc etc etc will these aircraft in time no longer be certified as suitable for training?For instance from my recall (I can't be bothered going back in to read the audit again) the Savanah Aircraft were fitted with a non-certified Brolga prop by the importer... is this going to be a can of worms in the coming months for many of the Ra-Aus training fleet?

I believe they were Bolly props, approved by the factory but not included in the paperwork. Good job these little planes don't have to carry all this paperwork or they would never get off the ground.

 

 

[Mriya]

It would appear that this thread has split into at least two different discussions. One relating to aircraft certification and another relating to pilot certificate endorsements.

 

With regards to pilot certificates, I see very little wrong with the current structure. Starting with a basic pilot certificate and adding on endorsements with regards to LP/HP/TW/NAV/etc.

 

With regards to aircraft CofA options, we need to remember that the LSA category was created to allow designers to 'innovate' without the complication of seeking a full type certificated design, endorsed and controlled by the national regulator (ie CASA). Of course given that this was the original purpose of the LSA category, you should expect restrictions regarding how continuing airworthiness is controlled. Thus the situation where as soon as you step away from the 'factory approved' design or repair, you need to recognise that the aircraft now rightly fits into an experimental category, with all the extra restrictions that come with that status.

 

 

[Doug Evans]

how can a carbon cub be classed as an ultralight ?

 

theres no way it could come under the 600 kg limit with full fuel & two people .......????

 

I saw one flying under 24 reg two days ago wth a full load !