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Light Sport Aircraft

The Sport Pilot Rule refers to "Special"  Light-Sport Aircraft and "Experimental" Light-Sport  Aircraft.

Although the FAA does not clearly  distinguish it, there are two types of "Experimental" LSA.

The first type of Experimental  LSA are the ultralights which undergo an inspection by a DAR and are  transformed into an "Experimental Light-Sport Aircraft," which is a  new category of "Experimental" under FAR 21.191. If you will  allow me, I shall refer to this type of Experimental LSA as the "Former  Ultralight E-LSA."

Although normally an experimental  aircraft cannot be used commercially, a sport pilot instructor  may instruct in a Former  Ultralight E-LSA until September 1, 2009.  After that date, a person may  only fly a Former Ultralight E-LSA for his personal pleasure and may no longer  instruct in it for hire.

The second type of Experimental LSA are  those aircraft which are shipped from a manufacturer as a kit. This kit  must conform to the same "industry consensus standard" as a factory-built  ready-to-fly light-sport aircraft. However, the recipient of the kit does NOT  have to build 51% of the aircraft. The factory may deliver the kit in any  state of completion that it desires--from one percent complete to 99 percent  complete. In addition, the buyer may pay someone else to complete the kit for  him, whether it be a dealer, an airplane mechanic, or a neighbor. After the  kit is completed, the buyer must have it inspected by a DAR and it will be  placed into the "Experimental Light-Sport Aircraft" category. For  clarification in this discussion, I'll refer to this type of Experimental LSA  as the "Kit" Experimental LSA (as opposed to the Former Ultralight  Experimental LSA.)

Unlike the Former Ultralight E-LSA, the  Kit E-LSA may NOT be used for commercial training. Only the Former Ultralight  E-LSA may be used for commercial pilot training, and even the Former  Ultralight E-LSA may only be used commercially until September 1, 2009.  

Please note that a factory must build at  least ONE ready-to-fly Light-Sport Aircraft before it will be allowed to  deliver the light-sport aircraft kits.

The "Special" Light-Sport Aircraft  (S-LSA) are the turn-key ready-to-fly aircraft manufactured in accordance to  an industry consensus standard. The S-LSA does not have a normal aircraft type  certificate issued under FAR 23, so that's why the  airworthiness certificate which is issued to a light-sport aircraft will  be a "special" airworthiness certificate, and not a "standard" airworthiness  certificate.

The Special LSA (S-LSA) may be used for  commercial training. After September 1, 2009 it will be the ONLY light-sport  aircraft that can be used for commercial training. Because these LSA have a  "Special" airworthiness certificate instead of a "Standard" certificate (such  as a Cessna 150,) the ONLY commercial use of a S-LSA is for training sport  pilot students. A S-LSA cannot be used for other commercial purposes, such as  sightseeing, traffic reporting, fish-spotting, crop dusting, etc.

As stated in the Sport Pilot Rule, the  last day that an ultralight instructor may teach in a two-seat ultralight  trainer is January 31, 2008. By that date, if an ultralight instructor wants  to continue teaching, he must obtain an FAA sport pilot instructor's  certificate. He may teach in a Former Ultralight E-LSA until September 1,  2009. After September 1, 2009 he may only teach in a Special LSA.  

In addition to Experimental Light-Sport  Aircraft the Experimental Amateur-Built aircraft will continue to exist. The  difference between an Experimental LSA and an Experimental Amateur-Built  aircraft (E-ABA) is that an E-ABA does NOT have to conform to an industry  consensus standard. Another difference is that the buyer of an E-ABA must  construct at least 51 percent of the kit aircraft, whereas the buyer of an  E-LSA does not have to build any specified percentage of the aircraft.  

Neither the E-LSA or the E-ABA may be  used for commercial flight training.

It is quite conceivable that a  manufacturer may offer all three types of flying machines: Special LSA,  Experimental LSA, and Experimental Amateur-Built aircraft.  

Why would a manufacturer offer an  experimental amateur-built kit in addition to an experimental light-sport  aircraft kit? The reason is because the E-LSA is restricted to certain  features whereas the E-ABA is not. For example, an experimental amateur-built  aircraft may have more than two seats, may have retractable gear, may have an  in-flight adjustable propeller, may have more than one engine, and it may  weigh more than 1,320 pounds--all of which are not available to light-sport  aircraft.  Please note that if an amateur-built aircraft has any of the  features mentioned above, it CANNOT be flown by a sport pilot. It could only  be flown by a person with a private pilot certificate or higher. Also, the  person who flies an experimental amateur-built aircraft must have an FAA  medical certificate if the amateur-built aircraft has features that  exceeds that which an LSA may have.


Jon Thornburgh


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Last modified: 07/23/09