Ultralight instructor advocacy

[Bill Berson]

Does anyone know what the timeline is for the EAA ultralight training reform? Or the date EAA posted this message on the website? https://www.eaa.org/en/eaa/aviation-advocacy-and-safety/aviation_advocacy/top-aviation-issues/loda-reform

I was thinking about getting my Sport Pilot Instructor certificate if my 600 pound Avid Amphibian could get the required FAA Letter of Deviation Authorization or exemption for primary new student training.

[martymayes]

No idea what the current status is but EAA published this update ~2 yrs ago:

https://www.eaa.org/en/eaa/eaa-news-and-aviation-news/news/10-20-2016-faa-releases-revised-loda-policy-for-public-comment

[Bill Berson]

Good news Marty.
So it said it was released for public comment in Oct 2016. What happened?
Maybe they are waiting for the 2019 LSA revamp?

[Tom Charpentier]

Hi folks,

As usual, FAA timelines can be frustratingly long, but an important update came across the wire just a few hours ago - the FAA finally published an NPRM to remove the E-LSA training restriction, per our request: https://www.federalregister.gov/documents/2018/10/24/2018-23270/removal-of-the-date-restriction-for-flight-training-in-experimental-light-sport-aircraft

The original plan was to move ahead with the final publication of the LODA policy after this rule was finalized (since some of the activities permitted by the policy were enabled by the rule change), but since the rulemaking has dragged on, we have been working with FAA to get the policy published as soon as possible, hopefully within the next few months.*

Good timing on this thread - hopefully more good news soon. This is thus far NOT tied to MOSAIC (the rulemaking package including LSA reform), and we're looking to keep it that way for the sake of expediency.

Tom

*For those not familiar with the difference between rules and policy, policy administers a rule. In the case of LODAs, 14 CFR 91.319(h) allows the FAA to issue LODAs. The policy in FAA Order 8900.1 defines under what circumstances LODAs may be issued. Unfortunately, 91.319(e)(2) prohibits E-LSA from being used to provide training. With several E-LSA owners still out there seeking to provide training, we're looking to change the rule as well as the policy. Rules are MUCH harder to change than policy because of the complicated rulemaking process mandated by law.

[Bill Berson]

Hello Tom,
I just read the FAA proposal. Can you clarify what "ELSA" is?
My concern is that if "ELSA" is only an aircraft built before 2010 then I would have no way to use this rule change since I don't own an old 2010 two seat ultralight. Or would this proposal allow a newly built EA-B to somehow qualify as an ELSA?

From FAA proposal: "This proposed rule removes a date restriction imposed by the 2004 Certification of Aircraft and Airmen for the Operation of Light-Sport Aircraft Final Rule which prohibited the use of experimental light sport aircraft (ELSA) for compensation or hire flight training after January 31, 2010. Removing the date restriction allows owners, operators or training providers of ELSA that were eligible to conduct flight training prior to the cutoff date to do so again."

thanks
Bill

[Tom Charpentier]

Bill, E-LSA is "Experimental Light-Sport." If you don't have one, you don't need this rule change. The new policy change (again, this is separate from the rule change) will allow your E-AB to be used for Sport-Pilot primary training as long as the Vh (max sea level cruise) is <87. Hopefully, this policy change will be out soon. The rule change will enable relief for E-LSA owners whose aircraft are no longer eligible to provide training, but it's just a part of the overall reform package that we're working on.

I know this stuff can get confusing - feel free to give me a call if you want to discuss this in more depth: 920-426-4800 and ask for me.

[Bill Berson]

Tom, if you can get the rule changed so I can use an EA-B for primary training without a LODA, I might then be interested.
Otherwise, It appears it would be too much money and effort to apply for a LODA, that can be revoked any time.
I will wait for news about the rule change.
thanks

[martymayes]

It looks like a LODA will be required, otherwise it would be a free-for-all which would be hard for the FAA to monitor.

[Bill Berson]

It looks like a LODA will be required, otherwise it would be a free-for-all which would be hard for the FAA to monitor.
Do they generally issue one exclusive LODA per region?

[martymayes]

Do they generally issue one exclusive LODA per region?

Not aware of any such limitation.

[Tom Charpentier]

The current policy (again, this is a separate document from the rule that is currently out for comment) for E-LSA does limit operators to one per FSDO area, and they are only eligible if they have been providing training since 2010. This was done to grandfather a few existing E-LSAs despite the fact that the rule didn't allow them to provide training. Other LODAs, such as E-AB transition training authorizations, have no such restrictions.

The NPRM changes the rule to make training in E-LSAs legal again, and the policy revision (at least if it is published as drafted) will allow ALL experimentals with a Vh of <87kts to be used in primary sport pilot training, with no geographic or duration restrictions. The FSDO will still have some discretion, but in our experience the vast majority of qualified LODA candidates are successful in applying.

So if you're basing your understanding of the process off the current policy, found here: http://fsims.faa.gov/wdocs/8900.1/v03%20tech%20admin/chapter%2011/03_011_001.htm, just know that the policy should be changing to something significantly different soon.

[Dana]

The NPRM changes the rule to make training in E-LSAs legal again, and the policy revision (at least if it is published as drafted) will allow ALL experimentals with a Vh of <87kts to be used in primary sport pilot training, with no geographic or duration restrictions. The FSDO will still have some discretion, but in our experience the vast majority of qualified LODA candidates are successful in applying.

Including LSA compatible EAB's would make it a lot more useful.

I've been thinking for awhile about getting my SP-CFI. I was looking at an EAB registered Quicksilver at one point in conjunction with that. I could have gotten the plane dirt cheap, but the cost of hangar rent (and unavailability of hangars) at my local field made it unfeasible.

When I was looking at the LODA thing, it looked like they required a lot, including a complete course syllabus, lesson plans, etc. It's a pity one of the former BFI providing groups (USUA, ASC, EAA) doesn't provide that (for a fee, of course) just like they sold the BFI stuff. Of course a CFI who did put such a syllabus together could be the next Gleim for ultralights...

[1600vw]

Including LSA compatible EAB's would make it a lot more useful.

I've been thinking for awhile about getting my SP-CFI. I was looking at an EAB registered Quicksilver at one point in conjunction with that. I could have gotten the plane dirt cheap, but the cost of hangar rent (and unavailability of hangars) at my local field made it unfeasible.

When I was looking at the LODA thing, it looked like they required a lot, including a complete course syllabus, lesson plans, etc. It's a pity one of the former BFI providing groups (USUA, ASC, EAA) doesn't provide that (for a fee, of course) just like they sold the BFI stuff. Of course a CFI who did put such a syllabus together could be the next Gleim for ultralights...

There is a way around having to get this LODA to start a training club. I have been thinking about doing this myself.