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www.PSFmagazine.com | December 2016-January 2017 | 3 2 | December 2016-January 2017 | Powered Sport Flying Executive Editor Subscriptions Classified Sales Vickie Betts (800) 867-5430 E-mail: vickie@easyflight.com Web site: www.psfmagazine.com Technical Editor Layout & Design Display Ad Sales Roy Beisswenger PO Box 38 Greenville, IL 62246 800-867-5430 roy@easyflight.com Publisher Sport Aviation Press, llc 16192 Coastal Hwy Lewes, DE, 19958 Photography Valerie Layne Jim Smith Cliff Tucker Graphic Artist Tim Dilliner FeatureWriters Zen Boulden Kai Bode Dr. Bruce H. Charnov John S. Craparo Phil Dietro Jeff Goin Greg Gremminger Michael Hudetz Jeff Hamann Geoff Hill Dan Johnson Doug Maas Ira McComic Jim Smith Marion Springer Jim Sweeney © 2016 Sport Aviation Press llc Powered Sport Flying™ Magazine is published monthly by Sport Aviation Press llc, PO Box 38, Greenville, IL 62246, (800) 867-5430. All rights reserved. Reproduction in whole or in part without the written permission of the publisher is prohibited. The publisher assumes no responsibility for any mistakes in advertisements or editorials. Statements/opinions expressed herein do not necessarily reflect or represent those of this publication or its officers. While every effort has been made to ensure the accuracy of the information contained in this publication, Sport Aviation Press llc: Powered Sport Flying™ Magazine disclaims all responsibility for omissions and errors. Periodicals Postage Paid number 000228 at Greenville, IL, 62246 and at an additional mailing office. postmaster: send address changes to: Sport Aviation Press, PO Box 38, Greenville, IL 62246. Volume 23, Number 7. Subscription Rates Annual subscription rates: $36.95 U.S. $48 Canada $90 International All monies US Funds Subscribe online at: www.PSFmagazine.com For more information call: (800) 867-5430 Welcome to the last issue of Powered Sport Flying Magazine for 2016! Before I get to the contents of this issue, I have a very important request to make of everyone. If you move, please – let me know so that I can get your correct address into my system. You see, it has turned out that the usps has not been doing its job properly. Not the little local post offices, but the big centers where they are supposed to be forwarding mail and returning new addresses to any periodical who pays for the service, as I do. Someone with some power must have complained, because all of a sudden, with the November issue, I (and most other periodicals) have been getting back the covers with the address label either with a new address or the notation that they can’t give me a forwarding address. As of this writing, I’m nearing 100 returned address labels! So if you didn’t get a copy of psf in November, and you’ve moved any time this year, that’s why. Frankly, I have absolutely no idea how far back in time the usps has not been doing its job, but I’m guessing it’s been a while. With some addresses, they’re telling me that suddenly they are not able to be mailed to at all; for example, insufficient address or no mail receptacle. You can use the contact form at psfmagazine.com, you can call me, or you can drop me a note in the mail (I haven’t moved, so it should get to me!). Just remember, if you move, unless you tell me, I probably won’t know about it and you won’t get your magazines! As you can see by the cover, this is a special issue. I’ve mentioned before that Roy, as President of the United States Ultralight Association (usua), and Dan Johnson, as President of the Light Aircraft Manufacturers Association (lama), have been making trips to Washington, DC, to have meetings with the faa. The three big things that they’ve been concentrating upon have been gyros, electric aircraft, and aerial work for lsa. In this issue, we’ve reprinted the three papers that Roy and Dan presented to the faa in their final meeting of the year in November. Both men do this as volunteers, for the love of aviation. For those of you who have wondered what your usua or lama membership does for you, well, this advocacy is a big part. Have you ever been confused by the different levels of altitude? If so, then your questions should be answered in this issue. Roy has written a very good article on the subject. While he wrote it with powered parachutes as his specific aircraft to talk about, it holds true for everyone. He’s created some very good graphics to help explain, too! Hopefully, everyone is having a safe and happy holiday season. From me, Roy, and Moral Support Canines Cody and Caitlyn, our best wishes for this coming year! Editorial
www.PSFmagazine.com | December 2016-January 2017 | 5 4 | December 2016-January 2017 | Powered Sport Flying Press Pass Illinois Ultralight and Light Plane Symposium The Illinois Ultralight and Light Plane Safety Seminar received a reboot this fall. Originally founded by the Illinois Ultralight Advisory Council, the purpose of the event was to “Educate, not Regulate” by bringing ultralight pilots together for annual seminars featuring a variety of speakers. The event grew into the largest event of its kind in the Midwest and possibly the country. However, changes in mission and in the management of the event seemed to affect the size of the crowds and the vendors. The event was then combined with a general aviation safety seminar. The change in topics to accommodate both groups meant that both groups were giving up something they enjoyed. In the meantime, the facility that the event was held in fell into disrepair. In fact the auditorium portion of the Illinois building was condemned over a year ago. Which leads to an honest question. How does one condemn just half a building? In any case, the event is getting a reboot in 2017 with a program more like programs in the past, but in a new location and with a new name. The Illinois Ultralight and Light Plane Symposium will be held at the traditional time for the event, the last Saturday in February. The event is still a free one and vendors are still invited to participate at no cost. Of course donations are more than welcome to help defray expenses. This year’s event is to be considered a mid-winter meeting for all of those interested in light aircraft, ultralights, paramotors, gyroplanes, trikes, and powered parachutes. The focus will be a series of aviation presenters. Aviationoriented vendors welcome! Free admission. Details are: (New) Location: Bond County Memorial vfw Post 1377, 204 4th St, Greenville, IL 62246 (about an hour from St. Louis and less than 5 minutes from exits off of I-70). If you’d like to fly in to the Greenville Regional Airport, we’ll have a shuttle service available for you. Date for Set-up for Vendors: Friday afternoon, February 24, 2017 after 4:00 pm. (Also available immediately before the event Saturday Morning.) Pre-Symposium Social: Friday evening February 24th, 2017 at the vfw Hall. Date of Symposium: February 25, 2016. Registration at 8:00 am, Event begins at 9:00 am. Web site: www.safety-seminar.com.
www.PSFmagazine.com | December 2016-January 2017 | 7 6 | December 2016-January 2017 | Powered Sport Flying Press Pass Dynamic Lineup of Speakers and Guests Set for Sebring's U.S. Sport Aviation Expo This January 25-28 Sebring’s U.S. Sport Aviation Expo will feature multiple speakers and notable aviation guests. “We’re incredibly excited to bring this innovative group of individuals to Expo 2017 not only for their accomplishments in aviation, but because of their roles as humanitarians as well,” says Mike Willingham, Executive Director of both the U.S. Sport Aviation Expo and Sebring Regional Airport. Below are four of this year’s notable guests: James Fallows , noted national correspondent for The Atlantic, is well known for his extensive reporting from outside the United States. Fallows' most recent book is entitled China Airborne. In addition, Fallows along with Debra Fallows and John Tierney embarked on a journey in a little Cirrus SR-22 propeller plane visiting some of America’s smaller towns and cities not typically covered by the national media to investigate how people are responding to today’s economic and technological challenges and opportunities. Their popular stories about this ‘air road trip’ are featured on TheAtlantic.com and on the website “American Futures.” Shaesta Waiz , the woman behind the Dreams Soar initiative was born in a refugee camp. Waiz and her family fled Afghanistan to America in 1987 to escape the SovietAfghan war. Growing up in a poor family in Richmond, California, Shaesta became the first certified civilian female pilot from Afghanistan. She created the Women’s Ambassador Program— an initiative that seeks to mentor and support young women pursuing an education in aviation and engineering. She then founded Dreams Soar to share her story with women around the world, and to partner with strong female role models at the 31 stops along the route and together, share and promote the importance of stem (Science, Technology, Engineering, and Mathematics) education. Kevin Coleman is the first American ever to compete in the Challenger Cup, and the youngest pilot to compete in the 2016 Red Bull Season. Performing in air shows since he was 18, Kevin earned a spot on the U.S. Advanced Aerobatic Team that competes at the fai World Aerobatic Championships. Kevin is a regular air show performer, a contract pilot, maintains a competitive career in aerobatics—and, is now entering the world of racing. Coleman founded the Marion Cole Memorial Scholarship that provides aid for young people interested in aviation. Stewart Hammel , creator of SkyRunner®, a new innovative recreational sports vehicle dubbed, “One of the World’s Greatest Adventure Vehicles” by Red Bull, will also be in attendance. SkyRunner provides a low-cost, lowmaintenance ‘go anywhere’ asset appealing to large landowners, sportsmen, ranchers, emergency medical teams, film, media, aerial survey companies, bush pilots, border security, police, military, and search and rescue. Invitation for AmateurBuilt Aircraft The U.S. Sport Aviation Expo has also rolled out the red carpet for Homebuilt aircraft for January—free exhibit space, discounted tickets, and customized signage for each homebuilt exhibitor. People for whom this is not a professional activity construct Homebuilt aircraft, also known as amateur-built aircraft or kit planes. These aircraft may be constructed from ‘scratch,’ from plans, or from assembly kits. Expo is encouraging people with amateur-built aircraft or kit planes to fly in to Sebring Expo and show off for four days. Sebring Expo is creating a special display space for all homebuilt aircraft. All one needs to do is register their aircraft by filling out the homebuilt form online and purchase a discounted four-day event pass. Expo will create a display sign for each aircraft with their specific information. The 2017 Expo is scheduled for January 25-28. To learn more, visit www.sport-aviation-expo.com.
8 | December 2016-January 2017 | Powered Sport Flying Light Sport Aircraft Support Our Advertisers Updated Airplane Flying Handbook from the FAA asa is now offering the faa’s latest edition of the Airplane Flying Handbook in print. The faa’s Airplane Flying Handbook has been required reading for all pilots for over 40 years, and introduces the basic pilot skills and knowledge essential for piloting airplanes. It benefits student pilots just beginning their aviation endeavors, as well as pilots preparing for additional certificates and ratings or who want to improve their flying proficiency, and flight instructors engaged in teaching pilots of all skill levels. This handbook provides information and guidance on the procedures and maneuvers required for pilot certification. Chapters are dedicated to ground operations, basic flight maneuvers, slow flight, stalls, spins, takeoff and departure climbs, performance and ground reference maneuvers, airport traffic patterns, approaches and landings, night operations, emergency procedures, and transitions to different types of aircraft including complex, multi-engine, tailwheel, turboprop and jets. The latest edition expands and updates the material that is a key reference in faa testing and Airman Certification Standards (acs), and it incorporates new areas of safety concerns and technical information such as loss-of-control upset prevention and recovery training, and transitioning to light sport airplanes (lsa). The Airplane Flying Handbook is the official faa source for learning to fly and for many of the test questions in the faa Knowledge Exams for pilots. The publication comes complete with chapter summaries and the 352-page book is illustrated throughout with detailed, full-color drawings and photographs. It also includes a glossary and index. The Airplane Flying Handbook is now available in print as well as an eBook and eBundle from asa. Visit asa at www.asa2fly.com. You can also download a free pdf version of the document from www.faa.gov. Fatal Accident Total is one of Lowest in the History of FAA Record Keeping Fatal accidents in experimental category aircraft continued their decline in the 12-month period ending September 30, as focused programs and efforts by the Experimental Aircraft Association (eaa) and others continue to enhance safety. The totals, which include fatal accidents during the 2016 federal fiscal year (October 2015 through September 2016), showed that fatal accidents in amateur-built aircraft in the Federal Aviation Administration’s experimental category fell 17 percent from the previous 12-month period. The specific totals indicate 33 fatal accidents in those aircraft during the period, compared to 40 during the prior year and 51 for the 2014 federal fiscal year. In addition, fatal accidents for the experimental category overall, including racing aircraft, those used for exhibition only, research-and-development, and some types of light sport aircraft, also fell. Those fatal accidents fell from 61 to 49 during the 12-month measurement period. The fiscal year 2016 totals also bettered the faa “not-to-exceed” goal of 60 for that period. It also marks one of the lowest single-year fatal accident totals since the faa began keeping records. “This is tremendous news and this multiple-year trend is a credit to all aviators who are focusing on safety,” said Sean Elliott, eaa’s vice president of advocacy and safety. “The fatal accident numbers again remain lower than other types of popular recreational pursuits, such as paddle sports, horseback riding, and driving all-terrain vehicles. While we can never rest in pursuit of safety, these lower numbers – even with a rising number of flight hours in recent years – show that eaa’s programs, outreach and advocacy is making a difference.”
10 | December 2016-January 2017 | Powered Sport Flying Ultralight & Light Sport Advocacy Volume and Power Comparisons for Electric Ultralights Introduction This white paper discusses the potential benefits of electric ultralights and a viable way for the Federal Aviation Administration to update policy regarding electric ultralights without going through a rulemaking process. The Light Aircraft Manufactures Association (lama) and the United States Ultralight Association (usua) both recognize that rulemaking is costly and resource intensive. Moreover, the ultralight community does not desire a change to the ultralight regulations. CFR Part 103 has been an incredibly successful regulation. It has allowed the owners of hang gliders, paragliders, powered airplanes, hot air balloons, powered parachutes, powered weight shift control trikes, gyroplanes, seaplanes, amphibians, and even helicopters to take to the skies as long as the vehicles meet the basic definition and operating rules of the regulation. And in the nearly 34-year history of the regulation, no one (outside an actual ultralight operator) has been seriously injured or killed by a flight operation of a legal ultralight. Innovations in battery technology have created opportunities for electric aircraft, but cfr Part 103 and a letter from the faa’s Office of Chief Counsel have actually penalized electric powered ultralights. That is the issue we shall address. Background The faa issued Advisory Circular No. 60-10, entitled “Recommended Safety Parameters for Operation of Hang Gliders” on May 16, 1974. With the growth of ultralight-type aircraft after that circular was published, and importantly, with the introduction of gasoline powerplants to the very light aircraft, “Part 103 -Ultralight Vehicles” was drafted and became effective October 4, 1982. The ultralight regulation proved to be very successful and led to advances in technology, which ultimately led to the Sport Pilot Rules which were published in 2004. Electric powered ultralights were not envisioned when cfr Part 103 was drafted. Even when the Sport Pilot and Light Sport Aircraft rules were published, electric aircraft weren’t important enough to address in the definition of a light sport aircraft. Instead, the faa had the goal to write a definition for light sport aircraft that prevented the use of multi-engine, turbine engine, and rocket propulsion. Both the rule and the preamble to the rule are silent on electric power; however the very definition of an lsa is for a single-reciprocating engine. Those understandable regulatory oversights have created a situation that is making it burdensome to introduce ultralight electric aircraft, and electric-powered light sport This is one of three presentations made by USUA and LAMA to executives at FAA Headquarters in Washington DC in November of 2016 A White Paper by & aircraft are prohibited by regulation. Meanwhile, electric propulsion is gaining popularity in ground transportation, particularly automobiles and motorcycles. Battery technology is continuing to improve, if not as quickly as many would hope. Industry leaders believe that electric ultralights could provide a real public benefit by interesting more people in aviation, much like electric aircraft have revolutionized aero modeling and have virtually created the uas industry. Benefits of Electric Ultralights The promise of electric ultralights is very bright and offers many features that appeal to existing pilots, Millennials, and aircraft makers. Quiet. Electric motors make an open-cockpit experience that much better for the pilot and makes for happier airport neighbors. Low Maintenance. Reciprocating engines, particularly two-stroke engines, require constant maintenance. Many young people, women, and professionals are put off by the idea of having to work on engines when that hasn’t been part of their life experience. Fuel Handling. Most ultralight aircraft burn autofuel which normally is purchased and carried to the airport. It is smelly, heavy, and potentially dangerous when spilled. The Environment. There are real and perceived benefits to the environment with electric aircraft. Both make flying more appealing to the non-flying and flying public alike. Problem There are actually a couple of closely related problems. Neither has to do with Part 103 itself. Even though the regulation is old, it is sound and has stood the test of time. Both lama and usua acknowledge that many people would like to see the regulation updated to increase empty weights, but we don’t believe that it is necessary or wise. The issue can be viewed as defining what ‘fuel’ is for an ultralight. cfr §103.1 defines an ultralight as an aircraft having “a fuel capacity not exceeding 5 U.S. gallons.” However,
www.PSFmagazine.com | December 2016-January 2017 | 13 12 | December 2016-January 2017 | Powered Sport Flying LAMA & USUA electricity is not typically measured in gallons. Neither are electrons, for that matter. In 2012, a legal interpretation was requested regarding batteries and fuel by Brian Carpenter. The main thrust of the request was that: “In summary, our current interpretation of both the letter of the law as well as the intent indicates that there is no restriction on the amount of batteries that may be carried on board the aircraft as part of the aircraft useful load. And that the empty weight of the aircraft without batteries remains at 254 pounds.” The Office of the Chief Counsel did not agree. In fact, the occ had a completely opposite opinion, stating that batteries did not count as fuel, but instead counted against the empty weight of an ultralight. The official faa response is included with this white paper. It would seem that both sides staked out extreme positions on this issue. The language in the request was extreme because it claimed there should be no limits of any kind on the number of batteries on board an ultralight. That, in spite of the fact that the faa made it clear in the preamble to Part 103 that some kind of limitation on both empty weight and fuel capacity was necessary in the definition of an ultralight. For its part, the Office of the Chief Counsel seemed to ignore the fact that the source of energy for an electric aircraft (its fuel) is the batteries themselves. Their argument was confusing in that they seemed to believe that it was relevant that thermal fuels were expended during flight, when that is not spelled out in Part 103, the preamble to Part 103, or in any other obvious faa documentation. That extreme position makes sense since the Office of Chief Counsel was only asked to interpret the rule in a narrow sense. And perhaps the perceived risk of unlimited battery power tainted the process. This leaves electric aircraft in a unique position of having a definite source of power that seems to have an unclear status in the regulations. And in fact this newer, cleaner source of energy is penalized for not having the exact same nature as fossil fuels. That is because a completely ‘fueled’ Part 103-legal electric ultralight may only weigh 254 pounds compared to the completely fueled thermal engine weighing 284 pounds or more. Nominally that is a difference of 30 pounds. A gasoline-powered ultralight may weigh almost 12% more than an electric-powered ultralight. The other part of the problem is that the energy density of batteries is far lower than that of carbon-based fuels. Fred Schlachter, writing for the American Physical Society’s aps News 1 stated: “Stored energy in fuel is considerable: gasoline is the champion at 47.5 MJ/kg and 34.6 MJ/liter; the gasoline in a fully fueled car has the same energy content as a thousand sticks of dynamite. A lithium-ion battery pack has about 0.3 MJ/kg and about 0.4 MJ/liter (Chevy VOLT). Gasoline thus has about 100 times the energy density of a lithium-ion battery.” Mr. Shlachter goes on to say that there are some efficiencies to be had in electrical power systems, but that we are nowhere near attaining the effective range of gasoline 103.1 Applicability This part prescribes rules governing the operation of ultralight vehicles in the United States. For the purposes of this part, an ultralight vehicle is a vehicle that: (a) Is used or intended to be used for manned operation in the air by a single occupant; (b) Is used or intended to be used for recreation or sport purposes only; (c) Does not have any U.S. or foreign airworthiness certificate; and (d) If unpowered, weighs less than 155 pounds; or (e) If powered: (1) Weighs less than 254 pounds empty weight, excluding floats and safety devices which are intended for deployment in a potentially catastrophic situation; (2) Has a fuel capacity not exceeding 5 U.S. gallons; (3) Is not capable of more than 55 knots calibrated airspeed at full power in level flight; and (4) Has a power-off stall speed which does not exceed 24 knots calibrated airspeed. The current interpretation of the regulations means that the difference in the legal takeoff weight (minus pilot) for a ‘thermal’ powered ultralight (one that burns a fuel) vs. an electric powered ultralight is striking. Support Our Advertisers powered engines. That means that in order to attain similar performance numbers, more weight for electric-powered ultralights is justified, not less. The graph above shows that there are a variety of allowed weights for legal ultralight aircraft, depending on their configurations. It is important to understand that these configurations are allowed for both in the regulations and in AC 103-7. Allowing for greater empty weights for powered ultralights would require at least an exemption from the rules, or in the long term a regulation change. Regulation change is not an approach that usua or lama recommends. Possible Solutions There are a number of possible solutions for addressing the disparity between electric and thermal engine ultralights: Regulation Change is the least favored approach. It seems unnecessary and is a difficult process with little chance of success. Manufacturer Exemptions could be applied for on a model-bymodel basis. This would increase the burden on both manufacturers and the faa. Organization Exemptions could be applied for and administered by member organizations. This is a viable route and might be a valid approach. This could offer more indirect control by the faa for either the manufacture or the training (or both) for electric aircraft. However, a good approach would be to go back to the black letter of the law. The regulation says specifically “Has a fuel capacity not exceeding 5 U.S. gallons.” Understanding that the reality is that batteries are indeed the fuel source for an electric aircraft, it seems to make sense to address that reality and simply use 5 U.S. gallons of batteries as the fuel limit for an ultralight. Doing this would add clarity to a confusing situation. Prior to 2012, the faa actually made a statement at AirVenture saying that 5 gallons of batteries would be considered 5 gallons of fuel and electric ultralight builders have been using that as the standard since then. The overreach built into the request for a legal interpretation and the resulting overreaction to that overreach has confused designers and pilots alike. 5 U.S. gallons of batteries does not give the industry everything that they want or need, but it gives the This bar graph illustrates that the on-the-runway, ready-tofly legal weights for ultralights vary quite a bit depending on how they are equipped and what kind of fuel they use. The current legal interpretation for electric ultralights puts electric ultralights at the lowest maximumweight for a powered ultralight.
www.PSFmagazine.com | December 2016-January 2017 | 15 14 | December 2016-January 2017 | Powered Sport Flying LAMA & USUA industry a beginning and clarity. Since the technology is still in its relative infancy, greater volumes of batteries might be considered by the FAA on a case-by-case basis. LAMA/USUA Proposal Our proposal is to recognize that batteries are the fuel that powers electric aircraft and to allow for 5 U.S. gallons by volume of batteries. That could be done by: An update to AC 103-7 which could go into detail about what exactly 5 U.S. gallons of batteries mean. For example, does it count the case? What about air spaces between cells for cooling? The usua and lama position would be just to count the cells or the electrolyte itself. Perhaps an option could be offered for aircraft designers. A policy statement would be a simple approach to the issue, which would provide clarity and allow designers to produce viable ultralights. Conclusion The ultralight regulations have proven to be very successful, allowing inexpensive flight for thousands of people. Moreover, the regulations have allowed innovation and the creation of sports like powered paragliding and even new categories of aircraft such as powered parachutes and weight shift control aircraft. Part 103 has even been the model for other countries such as the United Kingdom’s Single Seat DeRegulated (ssdr) initiative and Germany’s Sub-120 kg class. Now is the time to begin embracing a new technology. Beginning the process with the lightest of aircraft makes the most sense. • “Moore’s Law” for Batteries? Isn’t there some kind of “Moore’s Law” for batteries? Why is progress in improving battery capacity so slow compared to increases in computer-processing capacity? The essential answer is that electrons do not take up space in a processor, so their size does not limit processing capacity; limits are given by lithographic constraints. Ions in a battery, however, do take up space, and potentials are dictated by the thermodynamics of the relevant chemical reactions, so there only can be significant improvements in battery capacity by changing to a different chemistry.1 Support Our Advertisers Sources 1. Fred Schlachter, “Has the Battery Bubble Burst?”American Physical Society 21, no. 8 August/September 2012 2. 14 CFR Part 103, ULTRALIGHT VEHICLES 3. Letter from the FAA’s Office of the Chief Counsel dated September 4, 2012 (Reproduced beginning on page 22) 4. Discussion on the Tesla battery system, https://en.wikipedia.org/wiki/Tesla_Model_S 5. Rotax 447 specs and weight from Rotax’s Operators Manual for engine types 447 UL SCDI, 503 UL DCDI, 582 UL DCDI mod. 90 and 582 UL DCDI mod. 99, September 1, 2010 6. Geiger Engineering HP25D specifications found at http://www.geigerengineering.de/
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www.PSFmagazine.com | December 2016-January 2017 | 19 18 | December 2016-January 2017 | Powered Sport Flying SLSA Aerial Work Aerial Work for Light Sport Aircraft Introduction In 2004, as the new Sport Pilot/Light Sport Aircraft (sp/ lsa) regulation was announced and made effective, the focus of these new pilot certificate and aircraft categories was fully on recreational use. While such aircraft could travel and while they would advance quickly in capabilities – adding such things as digital instrumentation, autopilots, crush-zone designs, and much more – the primary purpose of Light Sport Aircraft was flying for pleasure, not work. Wisely, allowances were made in the interest of safety. Flight instruction is vital to make flight in Light Sport Aircraft a safe and successful pursuit. Even experienced aviators (overwhelmingly of heavier, faster aircraft) required transition training. Thus, compensated flight instruction has been part of the Special lsa mission since day one. Renting these aircraft was also part of introducing them to a pilot population that initially knew little or nothing about Light Sport Aircraft. Towing gliders with light aircraft, an activity that long predated sp/lsa, was also allowed. Towing Part 103 hang gliders with light aircraft designed expressly for the purpose was sensible. During a dozen years of field operation, Light Sport Aircraft have proven to be capable machines with an acceptable safety record. From the very beginning lsa have been allowed to perform missions well beyond sport or recreational flying. Flight instruction, rental, and glider towing are all forms of aerial work that require better capability, durability, and safety than might be needed for purely fly-for-fun aircraft. Because these were expected activities from the beginning, structure and flight characteristics for such aerial work have been built into the designs using appropriate and highly-functional consensus standards. Through detailed faa field audits, industry’s ability to comply with these standards has been significantly verified. In fact, the entire activity has proven sound enough that astm established the F44 committee to take lessons learned from lsa to buttress the Part 23 rewrite project. Outside of the sp/lsa regulations, Light Sport Aircraft have been deployed in the usa to several public-use functions. One of the most obvious uses is law enforcement work in various capacities. Less obvious is the military’s regard for the value of light, far-lower-cost aircraft. In several cases, law enforcement agencies or military departments have found Light Sport Aircraft efficient enough that repeat orders have been achieved. (See Note #7 on the survey for more details.) In other countries, the value of such light aircraft has additional verification. This is one of three presentations made by USUA and LAMA to executives at FAA Headquarters in Washington DC in November of 2016 Aerial Work In Other Countries lama and usua coordinated to conduct a survey of industry contacts to discover the many different functions that can be achieved by Light Sport Aircraft. Because aerial work is not permitted under sp/lsa regulations – other than flight instruction, rental, and glider towing – a 2014 survey asked experts in light aviation to report on how lsa or lsa-like aircraft are used in other countries. Since this survey was completed, additional functions have been proposed, for example, tree surveying in Oregon. Like many of the aerial work activities referenced in the survey, most flying activities can be performed over areas of minimal or no population. Public Interest This white paper is not a formal petition for exemption. However, it is useful to observe how this might benefit the public interest (defined here as other than the industry’s or pilot’s interest). Drones have captivated pilots and the general public via faa regulatory work, media reporting, and marketing promotion by companies such as Amazon, Dominoes Pizza, Google, and Facebook, among others. Certainly, drones can do much useful aerial work. Future technology will surely advance this success; however, some work applications are best accomplished with a human on board. Drones are less desirable for many kinds of aerial work that might be done with a manned lsa. Two examples include pipeline patrol or searching for a lost child. In the former case, mile after mile must be flown. While technology may one day permit fully autonomous inspection via drone with no real-time human involvement, that activity remains over the horizon. Until then, a human pilot on board, perhaps accompanied by a pipeline expert, is a presently unbeatable combination. When searching for a lost child (or a fugitive criminal) the tight interaction of an on-board human with ground personnel is essential. Drones may eventually be capable of this purpose but today such real-time, person-to-person communication is essential. Manned operations are better accepted by law enforcement personnel tasked with this duty than autonomous or semiautonomous air vehicles. Operation Migration, an organization that used light sport aircraft to assist migratory flocks, could not have done the work with either drones or general aviation aircraft
www.PSFmagazine.com | December 2016-January 2017 | 21 20 | December 2016-January 2017 | Powered Sport Flying SLSA Aerial Work For many tasks, the public’s interest is well served by having an accountable, responsible human aboard an aircraft. Even a “man-flown” drone (operated by someone on the ground with a controller unit) does not put the ‘pilot’ at risk the same way a manned flight does. This is the surest way to avoid that air vehicle creating damage or injury on the ground. By creating specific aerial work functions, the public can be protected by keeping lsa away from large gatherings, delicate infrastructure, or sensitive areas. However, even should violations occur, the human on board can be more directly held to account for such failure than when an unmanned drone is used. Especially for public use aircraft, the public greatly benefits when their tax dollars are used more widely by lowering the cost of many functions. Like drones, helicopters are also immensely useful but their cost is so many multiples of a Light Sport Aircraft that the cost savings are large. Given the present populist mood of the public, conservative use of taxpayer funds is smart. Finally, while drones are fuel-efficient, helicopters are not and neither are single- or twin-engined piston or turbine aircraft. Light Sport Aircraft with conventional engines are vastly more fuel efficient and less polluting, making them more acceptable to a public concerned with environmental impact. In addition to their fuel efficiency, most lsa are also demonstrably less noisy than other aircraft, making them less annoying to the public; in fact, the public may hardly be aware of their operation even at heights as low as 500 feet above ground. About the Survey Light Sport Aircraft go by other names in many countries, so our survey includes aircraft with similar weight, certification standards, performance, and capabilities. These include aircraft Americans know as European ultralights or microlights (different from American ultralight vehicles), Very Light Aircraft, Experimental Amateur Built aircraft… perhaps summarized as “lsa-like” aircraft. Information was provided by 14 experts from the U.S. and other countries. All names and contacts are presented in the survey. The solicitation for input was distributed widely via email and the responses collected, tabulated, and reported by lama, the Light Aircraft Manufacturers Association. The survey was done in 2014. Defining Aerial Work What aerial work IS NOT – Aerial work is not commercial use. No hauling of passengers or cargo is envisioned. Flight over areas of dense population is not requested. Night and IFR operations are not contemplated. Aerial work performed in LSA are not expected to exceed any operation parameters of such aircraft accepted as compliant with ASTM standards. What aerial work IS – Where Light Sport Aircraft can be deployed efficiently and efficaciously, their use is easily justified. Such work focuses on functions where a human in the cockpit is helpful, even essential. Specific potential activities are listed within the accompanying survey. Worldwide Aerial Work Survey Responder Responder Email Type of Work Use Country Type of Aircraft Dale Faux antiqueairways@aol.com Glider towing Germany European UL Phil McCoy mccoyphil@aol.com Pipeline survey Border patrol South Africa European UL Phil McCoy mccoyphil@aol.com Aerial application (ag use) “Africa” European UL Bill Patton Billy.Patton@usaig.com Law enforcement Germany European UL (gyro) Ole Hartmann (see comment #1) aircraftkits@bigpond.com Aerial spotting Mustering (herding) Livestock Property management Pipeline inspections Game control Shark patrol Crop inspections Aerial seeding Glider towing Australia & New Zealand LSA, Experimental, Restricted categories 1.“From our experience and interaction with the industries we know uavs have a place in specific roles. However, they will never be able to replace a human operator doing the same job in an aircraft. There will always be the human operator that will ultimately have to control the uav as well as all the back up and support equipment required. So cost-wise uav are not in front, not to mention insurance requirements for flying over [populated] areas. “It ’s a common thought by many services seeking operations, that certain aerial work has to be completed by heavy, toofast, fuel guzzling GA aircraft with high end maintenance bills attached. We have proven here in Australia that even with the large scale distances we have and the harsh operating environment, certain lsa-type aircraft are more successful and safer in many roles mentioned above than even the rotorwing aircraft. Operating costs for rotary-winged aircraft are multiples higher. “In Australia the governing/licensing body for operations in lsa type aircraft has even introduced pilot endorsements for certain type of operations such low-level flying endorsements. Examples include: mustering (basically herding using slow speed aircraft); towing endorsements [proving the pilot can] properly control and provide adequate skill, knowledge, and proficiency for pilots in the field using lsa-type aircraft in other roles than recreational or flight training.”
www.PSFmagazine.com | December 2016-January 2017 | 23 22 | December 2016-January 2017 | Powered Sport Flying SLSA Aerial Work Responder Responder Email Type of Work Use Country Type of Aircraft Randy Schlitter (see comment #2) rjs@rans.com Law enforcement Border inspections Crop spraying Herd management Crop surveillance Surveying Pipeline inspections Power line inspections Aerial photography Glider towing Banner towing USA (Public use DOJ border patrol) China (Crop dusting) Brazil (Paid aerial photography) “Europe” (Banner towing) Experimental Amateur Built (EAB) Milan Mach (see comment #3) mmach@EVEKTOR.CZ Law enforcement Aerial photography Glider towing Banner towing Czech Republic Germany Austria Canada and Australia (Glider and banner towing ) Italy (Law enforcement) Eurostar (European UL) is used for towing activity in Europe and law enforcement SportStar (LSA-type) is used for glider towing in Australia and Canada. John Whitish (see comment #4) john.whitish@cubcrafters.com Crop spraying (Farmer’s land only) Australia LSA 2. “[Rans] sold a S-6els to the doj to patrol the Mexican border. An S-6ES was used to photograph the amazon jungle, took three months. Two S-6ES are used in China for crop dusting. Several S-6ES, and S-7S are used in Europe for banner towing.” 3. “Please understand that in Europe, according to law, it is not allowed to use an ultralight for paid work. Another limitation is vfr operation only.” 4. [relayed from Australia] “Operating limitations and requirements for lsa with a Special Certificate of Airworthiness are found here: http://flysafe.raa.asn.au/regulations/lsa_explained.html. The main commercial use is flight training, and the hiring of lsa planes by flight schools for students to use, farmers can use their lsa planes to work on their own properties only.” [from U.S. respondent] “I’m still waiting for responses from Brazil and EU. I’m sure you are familiar with the easa regs in EU, but my dealer there also has substantial experience in the eastern markets (Russia, etc.).” Responder Responder Email Type of Work Use Country Type of Aircraft Wolfgang Nitschmann (see comment #5) wsn@wsn-aero.com Crop spraying Herd management Crop surveillance Pipeline inspections Power line inspections Wind turbine inspection Aerial photography Glider towing Banner towing Germany European UL Matthias Betsch (see comment #6) matthias.betsch@flightdesign.com See comment Germany European UL Roger Crow (see comment #7) roger@echoflightresources.com Law enforcement Pipeline patrol USA (public use; see comment) — in following states: AL, CA, GA, KY, MD, NC, OK, TX 7 LSA; 1 gyroplane; 6 powered parachutes 5.“German law strictly exempts ultralights from the commercial air work prohibition using ppl (Private license) and certified aircraft. Therefore it is legal to offer commercial service inside the weight limits and flight conditions. lsa is under ppl regime so we see all the restrictions on commercial use as any other ppl pilot will see. At this moment, the Permit-to-Fly aircraft in Germany are only granted permission if the manual says: no commercial operation.” 6.[Note similarity of comment to #5] “In Germany commercial work is not forbidden with Ultralights so it is allowed. As flights over congested are not allowed, you cannot do so for commercial works. Under easa, CS-lsa does not limit use; commercial flights must conducted within a commercial organization, so at the end no limits.” 7.“Seven fixed wing lsa, one gyro-copter and six powered parachutes have been purchased as part of a Department of Justice program and are flown in law enforcement. Apart from the doj work, There are currently two Flight Design ctle’s and soon to be four ctle’s being used for airborne law enforcement this year. One ctle in Oklahoma is being used for more than just patrol flights. It flies counter drug and drug interdiction operations, Homeland Security missions over critical infrastructures, interstate pipelines, and Port Security and water navigation ways supporting the US Coast Guard. The OK ctle is also performing fire patrol missions and disaster recovery missions for state/county emergency management (fema). Aircraft include: Flight Design ctls and the ctle; Magnaghi Sky Arrow; Rans S6; World Aircraft Co. Savannah VG; Tecnam Eaglet; Magni Gyro mto Sport Gyroplane; Buckeye Breeze Power Parachute. [Further info on law enforcement use of lsa] “The Airborne Law Enforcement Association (alea) has the “alea Standards for lsa in Law Enforcement.” These special standards give agencies who are operating lsa in law enforcement guidelines for a safe and functional aviation unit. It allows agencies to have alea accreditation like those agencies flying certified fixed wing and rotor wing operations. More info: www.alea.org.”
www.PSFmagazine.com | December 2016-January 2017 | 25 24 | December 2016-January 2017 | Powered Sport Flying SLSA Aerial Work Responder Responder Email Type of Work Use Country Type of Aircraft Matt Litnaitzky with information from South African national, James Pittman (see comment #8) matt@airplanefactory.com and James@airplanefactory.co.za Acrobatic operations Advertising operations Aerial patrol observation Aerial survey Aerial photography Agricultural Cloud spraying operations Seeding operations Dusting operations Emergency medical service Fire spotting Fire control Fire fighting Game and livestock: Selection Culling Counting Herding; Skydive operations Tug operations “Flipping,” i.E. Carriage of passengers without landing anywhere other than point of departure. South Africa LSA and all noncertified (called “noncertificated” in South Africa) planes Galen Geigley galengeigley@comcast.net Law enforcement USA Saudi Arabia Powered parachute Dan Johnson Dan@ByDanJohnson.com Banner towing Mexico (Cancun) UL-like EAB 8.“I think the [listed] activities are the ones allowed by a ‘Class iii license issued by the Domestic Air Service License’.”
www.PSFmagazine.com | December 2016-January 2017 | 27 26 | December 2016-January 2017 | Powered Sport Flying What Is Happening Where One of the best ways to get started with flying is to visit others already involved in the sport. And one of the most relaxed ways to do that is by participating in fly-ins and other events. You can normally find someone there who will be glad to help you and get you started in the right direction. If you would you like to see your event listed here, visit www.psfmagazine.com/list-your-flying-event. Calendar
www.PSFmagazine.com | December 2016-January 2017 | 29 28 | December 2016-January 2017 | Powered Sport Flying What Is Happening Where
www.PSFmagazine.com | December 2016-January 2017 | 31 30 | December 2016-January 2017 | Powered Sport Flying Unfortunately, the sport pilot rules were being developed at the same time that a very heated discussion within the community was taking place between those who advocated for centerline thrust (for gyrocopters) and those who advocated for placing the empennage of the aircraft further back (gyroplanes). And of course this heated discussion took place on an internet forum which some people within the faa noticed. Between the heated discussions and the obviously high accident rate, the faa decided to wash their hands of the entire class of aircraft. The Sport Pilot Rule and Preamble Just as there was disagreement within the flying community over gyroplane stability, there was a similar disagreement within the faa over whether or not gyroplanes belonged in the sport pilot rule. Ultimately, there never really was agreement within the faa, either. Those writing the pilot rules included ratings for gyroplane sport pilots and instructors. Those writing the rules for aircraft certification excluded gyroplanes from being included in the rule. In fact, the crux of the problem are four words at the end of §21.190(a): “§21.190 Issue of a special airworthiness certificate for a light-sport category aircraft. (a) Purpose. The faa issues a special airworthiness certificate in the light-sport category to operate a light sport aircraft, other than a gyroplane.” The following is the critical discussion about gyroplanes found in the preamble to the sport pilot rule. FAA Comments from the Sport Pilot Rule Preamble Many of the commenters who called for the special light-sport aircraft airworthiness certificate for gyroplanes referred to the simple design and operation of flight controls. The faa acknowledges that this is a reason for permitting sport pilots to fly gyroplanes, and for that reason the faa included gyroplanes in the light sport aircraft definition. However, the faa does not agree that this operational simplicity would apply to design and performance criteria for the light sport aircraft gyroplane design. Complicating design factors for gyroplanes include the location of thrust and lift lines with respect to the center of gravity; horizontal and vertical stabilizer size and location; and effects of turbulence. Larger gyroplanes have greater inertia, which makes the aircraft less sensitive to the relative effects of these factors. The faa believes that the dynamics of a rotary wing aircraft and the light weight of existing two-seat ultralight gyroplanes require a design standard for structural integrity and aircraft stability that may add prohibitively expensive costs to gyroplanes. One commenter expressed doubt that the ultralight gyroplane industry would agree upon a design standard. The faa reviewed gyroplane accident statistics in the ntsb’s electronic database. The data show 70 fatal accidents in the years 1983 through 1994 with mechanical failures accounting for 12 of those accidents. Data show 20 fatal accidents in the years 1995 through 2001, and mechanical failures accounting for two of those accidents. This data tends to support those commenters who state that gyroplane safety is better served by increased availability of training rather than different standards for design and performance of gyroplanes. Refer to the discussion under “VI.5.A.viii. Gyroplanes” for details on how this rule proposes to assure better training for sport pilots seeking a gyroplane rating. To summarize, the faa stated in the nprm that, for sport pilots flying light sport aircraft, the continued use of exemptions A White Paper by & Gyroplane Advocacy Introduction When the Sport Pilot/Light Sport Aircraft (sp/lsa) regulations were being created over twelve years ago, the rules were designed to work not only for airplanes, but for nearly all forms of simple flight that sport aviators participated in. In fact, with very little practical experience with two forms of flight, two entirely new categories of aircraft were created with supporting classes. Powered parachutes and weight shift control trikes were brought into the lsa rules with aircraft definitions, pilot ratings, and even a path to Special Light Sport Aircraft certification. This was despite the fact that the faa had no real safety data on those forms of flight. Powered parachutes and weight shift control trikes have enjoyed all the benefits of the slsa rules, including the ability to manufacture and design factory-built aircraft which can be immediately sold and flown for recreation, rental, and (importantly!) flight instruction. However, while gyroplanes were recognized as part of the sport pilot world, the faa (with what one might consider an interesting twist of logic) decided that the class of aircraft was too dangerous to be regulated like other sport aircraft. The purpose of this document is to present the history of the lsa gyroplane issue, identify the areas that the faa identified that industry needed to meet, and then show that the data indicates that it is time to create a framework to begin producing and certifying slsa gyroplanes. Gyrocopters vs. Gyroplanes To be certain, gyros were going through a transition at the same time that sport pilot rules were being developed. Smaller gyrocopters had been designed and sold as experimental kits in the decades prior to sport pilot. Those aircraft did not have the inherent stability that is desirable in an aircraft and pilots of those machines paid the price in injuries and fatalities. The rotorcraft community was painfully aware of the issue and debated within itself about the causes and possible remedies. Initially, the sport thought that the problem was simply a lack of training. The faa granted exemptions to train in the experimental aircraft and cfi’s attempted to train students to avoid flying in ways that would get them in trouble. However, it is difficult to train people to fly an unstable aircraft. In fact, with larger aircraft, capable of carrying more than one person, it is possible that even more people were hurt since stability issues remained. The next idea that gained popularity within the rotorcraft community was the idea of placing engine thrustlines higher in order to avoid the pilot-induced oscillation. This became known as ‘centerline thrust’ and there were many strong adherents to the concept. However, issues remained, particularly when engines failed. In the meantime, our friends in Europe were taking a different approach. Approaching it as engineers, they discovered that if they increased the size of the empennage and displaced it further back behind the center of gravity, that the overall stability of the gyroplane increased dramatically. This is one of three presentations made by USUA and LAMA to executives at FAA Headquarters in Washington DC in November of 2016
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