I may be mistaken but I don't think the airworthiness certificate specifies 
gross weight. It does however specify the model number and that is were we have 
concerns, the 415D and above being certified at over 1320 lbs.
 
In my case, a former owner thought that because the C-75 in his 415C was 
converted to a C-85 it converted it to a 415D and he filled out his 
registration and his bill of sale to the next owner as a 415D. There is no 
documentation on file with the FAA of this change and no airworthiness 
certificate change. A later owner registered it as a 415C and it was sold to me 
as such, long before the light-sport issue arose, and it is registered as such.
 
Bill


To: [email protected]; [EMAIL PROTECTED]: [EMAIL PROTECTED]: Wed, 16 
Apr 2008 20:01:12 -0700Subject: Re: [ercoupe-tech] Proposed rule changes ie is 
it a C or a D





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. 



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