LSA and VLA (merged)

Airborne_Again wrote:

“LSA” and “VLA” reveals that those regs have only one difference compared to CS-23 aircraft

I was under the impression that LSA were maintained more or less in the same way as gliders/TMG. May very well be Part-ML, but with simplifications regarding what can be done, and who can do it (modifications etc). I think any glider technician, or what they are called now (Part 66L ?) can maintain an LSA.

Dahlbeck wrote:

I’ve read about some kind of EASA permit-to-fly regime for LSAs. Mostly in relation to the Breezer B600. What is that all about? Some way of flying an “FAA LSA” in Europe without the CS-LSA certification?

No, only aircraft which were built according to the proposed CS-LSA standards could be given an EASA permit to fly. Initially, it was thought that these aircraft would be certified, hence EASA was responsible for the safety of the design of the aircraft. Aircraft which fell under this regime included some, but not all, Dynamic WT-9, Pipistrel Virus SW 100 and the Breezer B600 – typically UL aircraft which were designed with heavier MTOWs in mind. If the aircraft are on the German register, they will typically be D-E registered.

As far as I’m aware, the aircraft concerned were built and supplied with the EASA permit which was initially going to be an interim solution until certification came along, however then they realised that some changes required to meet certification – although not necessarily safety relevant – would be too expensive to be retrofitted to some of these aircraft hence they are allowed to continue to fly using an EASA permit to fly; FAA LSAs will typically vary from European LSAs – for example, no constant speed propeller, no retractable gear, max speed 120Kts – so EASA will not accept responsibility for the safety of the designs hence no EASA PtF – at least that’s how I understand it.

The benefit of such an aircraft is that it is not certified, meaning maintenance and parts is relatively cheap; as it’s EASA, the aircraft can be flown across the borders of EASA members without need of any approvals – unlike Ultralights or non ECAC experimental. The only downside I see, which really isn’t that big a thing, is renewing the permit once a year. This is renewed based on the Flight conditions issued by EASA. The cost of the annual renewal with the LBA is around 40€ a year and is very simple to complete, is done usually within a week to ten days, you can send off for it before the permit expires so don’t need to worry about missing flying time.

If you want to know more, please don’t hesitate to ask, especially with the registration as I helped take an EASA PtF from Swiss register and had it transferred to D-E register. Also, if anyone is interested in an EASA PtF Virus SW 100, tell me, I’ll see if my friend has sold theirs – they were looking to sell it, I did put the advert for their aircraft in the market place here but I see Peter’s removed it.

VLA does not exist anymore, it’s been folded back into CS-23 Amdt 5.
VLA’s were easier to get approved for NVFR.
But I agree, no big differences with CS-LSA except MTOW.

Yes, LSA parts and repair approval restrictions are more of a competitive issue under FAA regulations that provide a better certified GA infrastructure with FAA PMA parts, widely available FAA STCs, broader A&P mechanic authority, independent FAA DER major repair approvals etc. than is the case for aircraft under other worldwide regimes in which the certified aircraft manufacturer’s business position is more protected by government. This is on the face of it a disadvantage in the marketplace for FAA LSAs compared with FAA certified planes but as mentioned there is a solution – the owner can switch the aircraft to E-LSA after purchase and its as easy to maintain as an FAA homebuilt. The only issue is that it can no longer be used as a rental plane and the change in non-reversible. The other solution for LSA pilots looking to buy a plane is FAA certified aircraft that are LSA eligible but which operate under an FAA TC and maintenance regs regardless of who is flying them.

Peter wrote:

s that the case in Europe too?

It would be outrageous. No 3rd party parts??

Part-ML applies to CS-LSA and CS-VLA aircraft as well and a search for “LSA” and “VLA” reveals that those regs have only one difference compared to CS-23 aircraft. Engines and propellers for CS-LSA/VLA aircraft may be released to service in the aircraft after maintenance also by aircraft (not engine) rated maintenance organisations or independent certifying staff without issuing an EASA Form 1! Ref. ML.A.502(b).

Parts for LSA aircraft in the US have to come from the airframe manufacturer, and major airframe repairs/mods have be done per manufacturer engineering direction. No PMA or other third party parts and no DER repair schemes so the aircraft is largely removed from normal GA infrastructure. This would be a major issue given that most LSA airframe manufacturers eventually go out of business and many are overseas with little US representation. However, this was recognized in setting up the LSA regulations and unlike an FAA certified plane, any FAA LSA aircraft except those that are certified can easily be moved into Experimental category – which immediately makes it more practical to own.

The ‘flip-side’ of the E-LSA situation is that when a manufacturer goes out of business the aircraft automatically goes into E-LSA, which then becomes a problem for anybody who owns a rental plane of that type given that Experimental category aircraft cannot be used for rental or commercial operations. However most US LSAs are individually owned and flown.

Other than the ease of movement into E-LSA, I think the only current advantage of LSA aircraft in the US is that you don’t need a medical of any kind to fly them, or even Basic Med. All you need is a US state drivers license, with no medical exam to hold it. It is true that FAA has been talking (for a long time) about expanding LSA eligibility to a broader range of planes, and thereby eliminating medical certification for more pilots, but time will tell if that occurs.

How is this “stitch-up” worse for LSA than it is for certified aircraft? Anyone making a part after an industry standard can sell this as a “genuine part”. It’s the same with cars. Certification is much worse, because not only do you have to make the part after the industry standard, you also have to get everything verified by a third party (EASA, FAA etc). The end user is left with no option than to pay premium regardless of producer. Certification is the mother of all stitch-ups in this respect.

Now, the (original) manufacturers may tell you that only “our” parts are any good. This is a bit more tricky when anyone’s parts have to be verified by a third party. This is a well known phenomena however. Rotax use all kinds of scary language to trick people into using “official Rotax shops” and “genuine Rotax parts”. What it boils down to legally is that Rotax will replace (as per guaranties and general consumer rights) only those parts they have sold you.

LSA is bad, if experimental (or UL) is a the other option. But, if the only other option is certified, then the situation has changed.

What is bad with the US LSA, is all the restrictions. MTOW, prop, gear and so on, and MTOW in particular. Using an industry standard (with no third party verification) is seen as favorable compared with certification. It is of course bad compared with no standards at all as in experimental and UL (from a cost/bureaucratic point of view for the end user).

From what I remember, VLA is an EASA ting exclusively. LSA is in principle an international industry standard as basis, but some aspects are modified for EASA, FAA etc. Perhaps not FAA, since it is an American standard.

All references can be found in CS-LSA. The standard itself you have to purchase (again from memory).

The US-LSA has requirements for fixed pitch prop, max cruise speed, fixed gear among other things (no IFR).
The CS-LSA has none of these requirements (except no IFR), but also no acro (for some undefined peculiar reason)

I think the FAA is actually revising this, and will go several steps up in MTOW and other things. It will probably be like any other certified aircraft, but with a limit on MTOW.

The main thing about LSA is the use of an industry standard with no third party verification (no certification), just like cars or washing machines or whatever. This will (in theory) make aircraft less costly. You can say that LSA are glorified ULs. But ULs are not made designed or manufactured after any industry standard, LSA is.