Bill,

 

You make the case cogently.

 

I think, and a few FAA rulings given to Ercoupe owners concur, that the
regulation has to be talking about the certified gross weight of the
aircraft and not whether a given aircraft has ever, even once, flown one
pound over its certified gross weight.

 

A few owners have contacted the FAA.  One has a letter saying his aircraft
meets the LSA requirement because it never was properly upconverted (even
though the prior owner thought he had).  Another was told that the governing
document is the airworthiness certificate - if that hadn't been updated, the
plane's certified gross weight was never changed and it is legal as an LSA.

 

Many of us worry that if a form 337 was filed with the FAA and signed off by
them, then the conversion was legal enough to be binding.  This has not yet
been adjudicated but I'd hate to buy a plane thinking that the filed and
approved form 337 wasn't enough to cause problems then find out I was wrong.
These may be the ones in the "status ambiguous" category in the ads.

 

I think the FAA might, eventually, come down on the side that it is the
airworthiness certificate that governs.  For the definitive answer, we'll
have to watch the FAA rulings.  I think Skip Carden, executive director of
the EOC, is working this issue and pushing for the airworthiness certificate
interpretation.

 

It seems that you and Harry are suggesting that if the plane was illegally
flown over its certified gross weight and that flight's actual gross weight
exceeded 1320 pounds, then the plane is invalid as an LSA.  I interpret the
words of the regulation as referring to the certified gross weight of the
aircraft.  (Just what is the penalty for flying over gross weight?)

 

The FAA set the gross weight bar where it did specifically to exclude the
mass of Cessna trainers so that there would be a revitalization of the
American light plane manufacturing.  This is now acknowledged to be a
failure.  The qualifying aircraft have almost all been foreign from
countries that already had easier certification for light/ultralight
aircraft.  The number of Coupes affected by this debate is so miniscule, the
FAA really doesn't care.

 

Perhaps the FAA will give up on the idea of U.S. manufacturing and raise the
gross weight limit on LSA to 1600 or 1700 lb.  But, I don't think the
chances are all that great and near-term chances are, I think, very low.

 

Your words of caution for buyers are appropriate.  I hope I'm right and
you're wrong on this.  We'll have to wait and see how the rulings shake out
and, we should keep in mind, this may never be definitively resolved by the
FAA.

 

Ed

 

Ed Burkhead

http://edburkhead.com/Ercoupe/index.htm 

ed -at- edbur???khead.yyy       change -at- to @, remove the ??? and change
yyy to com

 

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