Bill, Excellent suggestion and I agree; we may not have a better opportunity. Let's get our Ercoupes in a row before moving ahead with a specific suggestion to the FAA (perhaps solicit support & assistance from the EAA / VAA too, if they are willing?).
I think Ed Burkhead had suggested something similar a few months back....here's a portion of what I believe to be Ed's prior comments (Ed?); ***************************************************************************************** "What I’d like to do would be to get an official document from the FAA saying that any aircraft whose airworthiness certificate never allowed a gross weight higher than 1320 lb. (600 Kg.) is eligible as an LSA and that no other documents override this. This will bring in a bunch of Coupes for which people never changed the airworthiness certificate. <<<<<<<<<<<<<<<<<<<<<<<< I’ve added a new thought. I still think the FAA will not, for anything, change the gross weight limit. But, in addition to what I’ve written above, I’d suggest we also try for a change in the actual regulation stating that: Whereas a certificated airplane (note that word is NOT “certified”) is fully regulated in its structure, performance, maintenance and condition. If it is eligible under its type certificate at a gross weight not exceeding 1320 lb. (600 Kg.), it may revert to that model and gross weight limit even if it has, at some time previously, been certificated at a higher gross weight. Note that this may get through the Feds. It is still a regulation change but it’s small enough, is tightly restricted by the word certificated, and is loosening the regulation, not tightening it. They may be able to do the change without an NPRM like they did with the repositionable landing gear on the amphibians. Also, this might be claimed to affect a similar number of planes to the amphibians for whom they have made a similar small regulation change. The downside is that while the amphibian change fosters new manufacturing, our change does not." ******************************************************************************** Ed suggested that the Sport Pilot authority office, AFS-610 would probably be the place that would have to work on it @ http://tinyurl.com/bnjug Mark Hardin suggested that the VAA may be of some assistance too. Regards, Dan Hall N3968H ----- Original Message ----- From: WILLIAM BIGGS To: [email protected] Sent: Wednesday, April 16, 2008 10:33 AM Subject: [ercoupe-tech] Proposed rule changes ie is it a C or a D All, Since the FAA is taking suggestions for possible changes to the regulation concerning Light-sport, this may be an opportunity to request a clarification as to "is it a C or D" and make suggestions. "Light-sport aircraft means an aircraft, other than a helicopter or powered-lift that, since its original certification, has continued to meet the following: (1) A maximum takeoff weight of not more than–– (i) 660 pounds (300 kilograms) for lighter-than-air aircraft; (ii) 1,320 pounds (600 kilograms) for aircraft not intended for operation on water" We must be very carefull in our wording, we could shoot some in the foot. I think we should suggest that if the original Airworthiness certificate was never changed to a D or later then FAA regulations were not complied with completely and the original Airworthiness certificate should stand. What are your suggestions? Bill ------------------------------------------------------------------------------ Going green? See the top 12 foods to eat organic. ------------------------------------------------------------------------------ No virus found in this incoming message. Checked by AVG. Version: 7.5.519 / Virus Database: 269.23.0/1382 - Release Date: 4/16/2008 5:34 PM
