Kickstarting a Debate

[Floatsflyer]

Now that Cessna has decided to go Primary Category Certification for its Skycatcher LSA, could the Icon A5 Amphib LSA be close behind?

Cessna is going Primary in order to seemlessly enter sales markets outside the U.S.(note: it will remain Sport Pilot eligible in the US). If Icon is not granted their LSA weight increase excemption request, would they too go Primary as a solution for currently being way outside the LSA gross weight envelope? Would such action have to seriously consider the one-third of their over 1000 deposit holders who currently hold no pilot license of any kind.

And to further muddy or muddle the waters, if the 3rd class medical exemption is granted, a Primary Category Icon could be flown by a PPL without a medical. So much for the much cheaper SPL that would render the one-third depositers SOL.

Also, could someone "truly in the know" please briefly explain exactly what Primary Category Certification is?

[Dana]

Primary Category was introduced some 20-30 years ago, basically a simpler certification process than standard category but still a Type Certificate rather than the industry certification used by LSAs, and similarly limited by size and performance. As I recall, there was also more owner maintenance allowed, and it is possible for a one way conversion of a standard category aircraft like a Cub or T-Craft to primary category so the owner could do the maintenance. I don't think many Primary type certificates were issued... the Quicksilver GT500 is the only one I'm aware of.

[cluttonfred]

Have LSA and Sport Pilot made Primary Category certification more attractive if the aircraft also meets the LSA definition like the older, lighter Cubs, Champs, Ercoupes, Luscombes, etc.?

If I understand correctly, an LSA-spec Primary Category aircraft could be used for instruction and rental, could be easily exported as a type-certificated aircraft, yet could be still be flown without a medical in the USA by any pilot exercising Sport Pilot privileges. Also in the USA, amateur-assembled kits would still be allowed if under the manufacturers supervision, would not need to meet the 51% rule and would be equivalent to factory-produced aircraft once completed. The only limitation is not being able to carry passengers or cargo for hire--not a big problem for light two-seaters in any case. Am I missing something?

[I am reviving this thread as a corollary to the Icon A5 Request For Weight Increase Exemption Status (http://eaaforums.org/showthread.php?3405-Icon-A5-Request-For-Weight-Increase-Exemption-Status/) discussion.]

[Mike M]

seems to make sense to pursue primary certification AND LSA concurrently. especially if the requirement for 3rd class for recreational pilots is dropped to "training in lieu", so to speak. and why couldn't they make separate hardware-similiar models with different paperwork certification levels? others do it.

[Joe LaMantia]

Having read a couple of articles with titles like "The Coming Shake-Out in the LSA Market", I'd say that those LSA producers who can afford the certification process will probably move in that direction. The market for a brand new airplane that meets the LSA spec's is too small to justify all the makes and models currently offered. This is a case where competition doesn't drive price down. I'd bet that those players with "deep pockets" will remain in the business but many of the little guys will dry-up. This should have been obvious at the start, a lot of "investors" jumped-in early when the "market" thought that the aging pilot population would jump on the "no medical" required thing. If the "market" would have looked at the low level of "retirement" funds available to the baby boom generation they might have had second thoughts. Now we've got too many aircraft being offered with the same performance spec's and to too few buyers. We might see a few producers like Cessna pick-up a nitche player like say Legend Cub to gain a bit of market share, but most of the players are too small to play that game. The new aircraft market for single-engine GA is still limited do in part to a big inventory of used aircraft. It will take a long time to clear out the old aircraft.

Joe
:cool:

[zaitcev]

the Quicksilver GT500 is the only one I'm aware of.

The only other one is RANS S-7. C162 is the third attempt ever. Even Champ 7EC is still made under Normal category. IIRC the Primary existed when ACA replaced its spruce spar with aluminum one, but they kept Normal certification.

One unpleasant thing about Primary certification rules is the prohibition of instruction. Basically it's the same problem that killed ultralights: they were converted into E-LSA, but one cannot instruct in E-LSA, only in S-LSA! Gotcha, suckers! FAA triumpfs again. In fact I think Cessna is going to continue to sell pink-certed 162s in U.S. just for this reason, and white-certed 162s will only be offered in Europe.

(I'm quite aware that the language of the reg allows instruction in Primary aircraft "under special circumstances". Good luck proving to FSDO that yours are.)

[Floatsflyer]

[I am reviving this thread as a corollary to the Icon A5 Request For Weight Increase Exemption Status (http://eaaforums.org/showthread.php?3405-Icon-A5-Request-For-Weight-Increase-Exemption-Status/) discussion.]

Matthew, thanks for reviving, it didn't get traction or too many eyeballs when I first posted it. Many developments have occured since in relation so perhaps more aviators are now more aware of the circumstances and implications.

I believe the Chris Heinz company from Mexico, Missouri and Ontario, Canada, name escapes me now, certified one of their models as Primary as well about 15 years ago.

[cluttonfred]

I'm quite aware that the language of the reg allows instruction in Primary aircraft "under special circumstances". Good luck proving to FSDO that yours are.)

The wording I saw is "certain circumstances." Since the Primary Category regs predate the LSA regs, and instruction and rental is allowed for LSAs, I wonder if there would be a case to be made for EAA, AOPA, etc. to petition the FAA to revisit that "certain circumstances" provision. Since the reg already allows for them to authorize those activities, it would be an easy fix and would make the Primary Category much more attractive.

[Bill]

... I believe the Chris Heinz company from Mexico, Missouri and Ontario, Canada, name escapes me now, certified one of their models as Primary as well about 15 years ago.

The name you're looking for is Zenair, LTD in Midland, Ontario, Canada and the aircraft is the ALARUS CH2000, which has an FAA production certificate. The type certificate, TA5CH, doesn't mention it being a primary category aircraft.

[Floatsflyer]

Thanks for looking that up Bill. Nonetheless another example of a major kit company going a certified route.

[zaitcev]

The wording I saw is "certain circumstances." Since the Primary Category regs predate the LSA regs, and instruction and rental is allowed for LSAs, I wonder if there would be a case to be made for EAA, AOPA, etc. to petition the FAA to revisit that "certain circumstances" provision.
Matthew, we turned out to be wrong. According to AC 21-70, the "certain conditions" are nothing more than "being maintained by an FAA-certified mechanic or appropriately rated repair station". This is because, unlike the S-LSA that came later, Primary a/c were intended to be maintained by pilots-operators. So, it turns out that Cessna Pilot Centers can instruct in white-certed Skycatchers all they want. -- Pete

[cluttonfred]

That's great news. For most two-seaters, "carriage of persons or property for hire" is not significant in terms of commercial use, but rental and instruction are key. Oddly, I can't seem to find AC 21-70 on the FAA site or via Google, but the AC 21-37 (http://www.faa.gov/regulations_policies/advisory_circulars/index.cfm/go/document.information/documentID/22264) says this about rental and instruction:


22 0 FAR Part 91 - General Operating and Flight Rules.
a. Section 91.325 lists operating limitations unique to primary category aircraft. No person may operate a primary category aircraft carrying persons or property for compensation or hire. If maintained by an FAA-certificated mechanic or appropriately rated repair station, a primary category aircraft may be rented for personal use as well as rented for flight instruction.

Cheers,

Matthew