LSA 'Maximum Empty Weight' clarification

[Crash]

Stewart..I think several of us would just like to know if this guy is for real or not.

I have read all the posts and he's not answering the basic questions being asked.

I have no axe to grind for either Legend or Cub Crafters.

Why didn't you jump on Steve when he asked the exact same questions and again got no answers?

Just trying to "Snope" it before it gets out of hand.

Crash

 

[StewartB]

My bigger point is that dskseller presented a situation that fueled the discussion. The discussion never attacked Legend, it was simply a discussion. Many good questions were asked by many posters and Joe has answered all, and even commented that the dskseller post was suspicious in nature. So what? Maybe the guy isn't real. But the topic is, and Joe has validated that overweight S-LSA aircraft received airworthiness certificates. I now know a great deal more about the LSA regs than I did before. Factual information provided by the preeminent expert in the field.

My response to who is dskseller? Who cares?

Stewart

 

[Steve Pierce]

Someone heard that Legend Cubs were overweight and someone else says theirs is overweight and now all the Legend Cubs are overweight. :roll: Oh yea, and the Sport Cub discussed on the previous link I posted was within .5 lbs of the legal maximum empty weight.

 

[S2D]

Very interesting !!
someone brings an S-LSA aircraft to me, Cubcrafters or Legend, or any others for that matter, the first thing I'm gonna do is have it weighed, cause it has to meet the Regs it was Certified under and if its empty weight is now over 890, I will consider it not airworthy, and I will write that in the logbook as I sign off the annual as airworthy except for the following discrepancy: (Aircraft exceeds maximum empty weight).

But in actuality, what an AI should do is call the Company and have them get a letter from the FAA stating the aircraft is legal as certified and put it with the permanent records.

If Cubcrafters is penciling their weight and balance sheet, I don't think they are any farther out of the woods than Legend is on this snafu

 

[willyb]

Lsa maximum weight clarification

Stewart I wholeheartedly agree that the technical information that Joe has provided made the thread worth reading and I too learned more about LSA.

I responded the way I did because mudslinging does not belong here.

In response to CC jumping all over it,Who made the first post?

I also agree with not caring who dskseller is.It doesn't matter.

The empty weight issue was addressed months ago through the proper forum,the parties directly involved.It is old news.

 

[StewartB]

Willy,

I believe the initial post on this thread was made in response to the confusion over the matter on another thread. I believe the second post on this thread acknowledges that.

Steve,

Maybe stevensonJr's Sportcub really does weigh 889.5#. After all, Centmont's weighs 870# on big tires. I'm waiting for one Legend owner to report a legitimate weight. I'd think somebody would be proud to do so. Like I said, don't answer the topic with useful info to dispell the rumor about Legend, just discredit the competition. Mudslinging 101.

S2D,

Any manufacturer that exceeds the weight limit should be subject to the same criticism. I doubt any owner of an overweight plane will confess to it now, given the criticism they'd likely endure here.

Joe Norris,

I've never applied for an airworthiness certificate and don't know what's involved in doing so. Is there an application process that requires an applicant to sign an acknowledgement or affidavit that the subject airplane complies with the rules applicable to the certificate? You had said earlier that the FAA has played a role and bears some responsibility for the improperly certified airplanes. I can't remember ever seeing a credential application that didn't tie compliance responsibility to the applicant. Perhaps the S-LSA airworthiness certificate process is different.

Stewart

 

[jnorris]

As I type this, I'm sitting in the back of the room at an FAA workshop in Oklahoma City, OK. The workshop is specifically to train FAA personnel on Light Sport Aircraft certification. The original subject of this thread has already come up. That is, should a mechanic have to worry about signing off a condition inspection on a SLSA if the aircraft does not meet consensus standards. Here's what was said....

It is not the job of the inspecting mechanic to decide whether or not the aircraft meets the consensus standards. The mechanic is only responsible to inspect the aircraft in accordance with the manufacturer-supplied inspection requirements as called out in the maintenance instructions provided with the aircraft. The mechanic is not responsible to check the aircraft against the consensus standards, nor is he/she required to have or know the consensus standard. So long as he/she inspects the aircraft in accordance with the manufacturer-supplied inspection requirements and finds the aircraft in a condition for safe operation, he/she has met his/her responsibility and can sign off the aircraft.

Compare this to an IA doing an annual inspection on a type-certificated aircraft. Is that mechanic required to know the entire scope of FAR Part 23 and compare the aircraft to the entire scope of that regulation? No! The mechanic uses the aircraft's type-certificate data sheet and the manufacturer's maintenance instructions and the general guidance of FAR Part 43 appendix D. For SLSA you simply replace the Type Certificate Data Sheet with the manufacturer's inspection instructions and maintenance manual and you perform the inspection.

The operating limitations issued by the FAA to the aircraft in accordance with its airworthiness certificate contain the inspection requirement. An excerpt from the operating limitations reads as follows:

"condition inspection performed in accordance with the manufacturer’s maintenance and inspection procedures, and was found to be in a condition for safe operation."

Note that the only requirement is that the aircraft be inspected in accordance with "manufacturer's maintenance and inspection procedures". It does not call out any requirement that the aircraft be confirmed to meet any consensus standard.

So long as the mechanic performs the inspection in accordance with the aircraft's operating limitations, and thus in accordance with the manufacturer's instructions, and finds the aircraft to be in a condition for safe operation, there's no reason not to sign off the inspection. (The operating limitations even provides the appropriate verbiage for signing off the condition inspection.

 

[S2D]

As I type this, I'm sitting in the back of the room at an FAA workshop in Oklahoma City, OK. The workshop is specifically to train FAA personnel on Light Sport Aircraft certification. The original subject of this thread has already come up. That is, should a mechanic have to worry about signing off a condition inspection on a SLSA if the aircraft does not meet consensus standards. Here's what was said....

It is not the job of the inspecting mechanic to decide whether or not the aircraft meets the consensus standards.

Note that the only requirement is that the aircraft be inspected in accordance with "manufacturer's maintenance and inspection procedures". It does not call out any requirement that the aircraft be confirmed to meet any consensus standard.

So long as the mechanic performs the inspection in accordance with the aircraft's operating limitations, and thus in accordance with the manufacturer's instructions, and finds the aircraft to be in a condition for safe operation, there's no reason not to sign off the inspection. (The operating limitations even provides the appropriate verbiage for signing off the condition inspection.

Did you get that in writing and signed by the FAA?
Are you comfortable signing it off if you know it doesn't meet some standard. Does your liability insurance cover you when you "knowingly" sign something off that doesn't meet its standards. Or is the FAA now just trying to CIA.

I think that gets back to the old Compass card inspection argument during an annual. Nobody bothers to check it if a card is in it. But if you know it is 40 deg off, are you comfortable signing it off as airworthy.

 

[JimC]

I'm curious about why some of the new clones are 160 to 190 pounds heavier than an original PA-11. That's a LOT of difference.
JimC

 

[bob turner]

Starter, generator, battery, relays and switches, metal prop, possibly more steel and surely more aluminum, bigger wheels and tires, bigger tailwheel(?), better interior, lights and strobes, radios and transponder, -

On the negative side, surely the fabric/paint weighs less.

 

[jnorris]

Are you comfortable signing it off if you know it doesn't meet some standard.

That's a decision that each mechanic would have to make. Most mechanics faced with doing a condition inspection on these aircraft aren't going to know what the standard says. They'll look at the operating limitations, the maintenance manuals, and they'll do the inspection. They'll sign it off in accordance with the operating limitations and watch the owner/operator fly it away. Good to go!

Does your liability insurance cover you when you "knowingly" sign something off that doesn't meet its standards.

Liability insurance! What's that??

I think that gets back to the old Compass card inspection argument during an annual. Nobody bothers to check it if a card is in it. But if you know it is 40 deg off, are you comfortable signing it off as airworthy.

This is a whole different discussion, but I'll take the bait! The first thing I'd do is check the certification basis and see if a correction card is even required in the aircraft. (I've already been down this road with the FAA.)

 

[behindpropellers]

Two more questions:

1. If you build an ELSA does it have to conform the to ASTM standards?

2. Todd- I noticed you guys just came out with the "Sport Cub S2", were the previous sportcubs within the weight regulations?

Tim

Todd-

Can you answer my question?

 

[Sam Beckett]

New posters...and you know who you are...
Simple rule..If you are going to participate here, participate..Don't throw your frigg'n grenades and disappear into the darkness and protection of the cyber world...


Sam



8)

 

[ksecub]

I am fairly confident (like 99.99%) that all Sport Cub models and serial numbers meet the ASTM regulations when they leave the factory. The owners may add things to them that take them out of regulation but that is clearly out of Cub Crafters control. Again I am not a Cub Crafters employee so don't take my word for it.

Doug

 

[StewartB]

The last line of the fourth paragraph of the first post of this thread provides the answer.

Stewart

 

[Crash]

delete

 

[Steve Pierce]

Does someone have a Legend Cub without an airworthiness certificate? Does anyone have one that is over weight? Talked to the MIDO today. Seems we are on change 7 of the ASTM standards. They just made a standard for propellers. Are the LSAs that were certified before the standards for propellers that do not have ASTM compliant propellers going to have their airworthiness certificates revoked? No, they were compliant when the aircraft was certified. The MIDO said that the initial S-LSA standard was that the initial prototype meet the maximum empty weight. That has now been revised that all the airplanes must meet that criteria. They have no intention of revoking any airworthiness certificates. LSA is in it's infancy. Like anything there will be growing pains. This clears up some stuff for me.

 

[Sam Beckett]

Bravo Steve Pierce!



Sam


8)

 

[jnorris]

The owners may add things to them that take them out of regulation but that is clearly out of Cub Crafters control.

Doug,

That can't happen (at least not legally). EVERYTHING that is done to, added to, or taken out of a SLSA MUST be done so in accordance with instructions from the manufacturer. There are no "field approvals", no "STCs", no modifications of any kind done to a SLSA except in accordance with manufacturer's instructions and documentation. Anything done without manufacturer's support on an SLSA is in violation of FAR 91.327(b) and would place the operator in a position where they could be cited by the FAA for said violation.

Further, any modification of the aircraft without manufacturer's instructions would be in violation of the aircraft's operating limitations, which would render the airworthiness certificate invalid (Ref; FAA Order 8130.2F Change 3, paragraph 126b, item (6)).

This applies to ALL aircraft certificated in the light-sport category, so it dosen't matter whether it's Cub Crafters, American Legend, Zlin, Jabiru or whoever. This is the world of light-sport aircraft, which is definitely a brave new world for manufacturers, owners, mechanics, and the FAA.

 

[Frank T]

Joe

So without a factory approval, if a guy wanted to change out a piece of radio equipment at some point in time, he'd have to change to ESLA to stay legal? Nor could you add say floats later to a SLSA!

 

[jnorris]

So without a factory approval, if a guy wanted to change out a piece of radio equipment at some point in time, he'd have to change to ESLA to stay legal? Nor could you add say floats later to a SLSA!

You're absolutely correct Frank. The only way to make any modification to an SLSA without factory approval and support is to re-certificate the aircraft as ELSA. The only way to stay in Light-Sport category (aka "SLSA") is to do everything in accordance with manufacturer's instructions.

 

[StewartB]

Joe,

Forgive me for going backwards a bit. What maintenance and repairs are allowed by a non-A&P owner in the S-LSA category? How about the E-LSA category? Do amateur homebuilt standards follow into the E-LSA category if the plane is home built? Is there a difference in owner maintenance restrictions between a factory built experimental LSA and an amateur built LSA?

The factory S-LSA category doesn't look very attractive to me. I'm surprised at the popularity considering the restrictive nature of the rules.

Stewart

 

[willyb]

LSA maximum Empty Weight

Steve did you get any information regarding the propellor standard?I'd like to know what they came up with.
Bill

 

[jnorris]

What maintenance and repairs are allowed by a non-A&P owner in the S-LSA category? How about the E-LSA category?

Stewart,

ELSA is easy (with a slight twist). FAR 43, the maintenance rules, start out with 43.1, Applicabilty. Section (b) of 43.1 states:

(b) This part does not apply to any aircraft for which the FAA has issued an experimental certificate, unless the FAA has previously issued a different kind of airworthiness certificate for that aircraft.

Since most ELSA (except those converted from SLSA) have always been experimental aircraft and have never held a different type of airworthiness certificate, 43.1(b) tells us that part 43 does not apply. That means that ANYONE can perform maintenance, repair and modification on the ELSA. You don't have to be the builder. You don't have to be the owner. You don't have to hold any FAA certificate of any kind.

The twist is those aircraft that started out as SLSA and have been re-certificated as ELSA. These aircraft HAVE held a different type of airworthiness certificate (SLSA is not an experimental certificate) so Part 43 DOES apply to these aircraft. This is an issue that the FAA is working to fix, so that an ELSA that used to be an SLSA would be treated the same as an aircraft that was ELSA from the start. No telling how long it will take for this fix to be in place though.

For SLSA we again look at 91.327, which requires the aircraft to be operated and maintained in accordance with manufacturer's instructions. The consensus standard for the maintenance manual requires that the manual call out who is authorized to perform each individual maintenance function. So the owner/operator may only perform those maintenance functions allowed by the manufacturer, per the maintenance manual.

 

[behindpropellers]

So if a guy buys a CC sport cub off of the line and then goes through the process of turning it into an ESLA....

Then he puts an IO-720 on the front, and crashes it. Is CC the builder (holder of liability) still or the guy who converted it?

Tim

 

[jnorris]

So if a guy buys a CC sport cub off of the line and then goes through the process of turning it into an ESLA....Is CC the builder still or the guy who converted it?

Tim,

The builder of the aircraft does not change. The aircraft will always show the original SLSA manufacturer as the builder, even if it's re-certificated as ELSA.

 

[mvivion]

Whoa!!!! I'm liking this IO-720 concept :lol: .

MTV

 

[behindpropellers]

Whoa!!!! I'm liking this IO-720 concept :lol: .

MTV

Yeah... "solo from back seat only"

 

[redrooster]

more like "solo sitting on the horizontal"

 

[CarlM]

Regardless of whether the original poster actually exists or however suspicious his motives, this has been a great discussion.

It's interesting to note that both CC and Legend have worked to lighten their aircraft, presumably in response to the changing rules as Joe so clearly elucidated. Base Legends are now 800-845 lb depending on engine and cowling. CC is offering a significant weight reduction in their S2 option package. The cynics amongst us might say the reductions are just to allow the manufacturers to install more expensive options, regardless, it has to be a good thing.

Comparing weight with PA-11's? A more accurate comparison would be with a widebody PA-18-95. Anyhow, 800 lb, 120 hp, full electrics; that seems to be a pretty respectable package.

Carl