Dan Johnson On LSA Rule Changes

Discussion in 'Home Builders and Sport Pilots' started by Stephen Poole, Jul 20, 2019.

  1. Clip4

    Clip4 En-Route

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    Did you view the avweb video I posted. LSA crash a lot.
     
  2. tspear

    tspear Pattern Altitude PoA Supporter

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    Consider the items asked, many of which have no dependency on each other. I am curious why the FAA does not take a more incremental approach.
    e.g. Do a minor update for the electric/hybrid power plant. Do a second one on Gyro planes....

    Tim
     
  3. wanttaja

    wanttaja En-Route

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    Got better uses of my time than watching every single second of every single video people post to aviation forums. Post a time on the video when that claim about the Tecnam accident rate is made and I'll skim to it and check out what they say.

    Where did Avweb get the estimate? Is it based on fleet rate? If it's based on accidents per 100,000 flight hours (a typical metric), what is the source of the hour estimation? I've never seen any sources for hour estimates for individual aircraft types. Is the number on all light sport or does it exclude ELSA?

    If the claim is based on fleet rate (ratio of accidents vs. number of aircraft), the data I posted pretty much indicates the 4x worse claim doesn't hold.

    The Nall report says homebuilts have a nine-times higher accident rate than typical GA aircraft. Your claim would thus imply that the Tecnam is much safer than the typical homebuilt. I do have problems with some of the Nall report methodology....

    Ron Wanttaja
     
    Last edited: Jul 24, 2019
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  4. RyanShort1

    RyanShort1 En-Route

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    I watched the whole thing and something you might have missed is that the Pipistrel I want to use for aerial photography is by their (AVWeb) standards (although I think I trust @wanttaja and his efforts more since I can see how he arrives at his numbers) safer than a 172... and trust me, we wouldn’t pick just ANY SLSA to use, but one we’d had a chance to evaluate, just like any other certified aircraft. Are the LSA standards a bit different? Yes, but the FAA still is holding them to standards and they are safe enough for instruction, which is more demanding on the airframe than flying point to point and turning circles or flying grid lines.
     
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  5. Capt. Geoffrey Thorpe

    Capt. Geoffrey Thorpe Touchdown! Greaser! PoA Supporter

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    You get some geezer with a bazillion hours in his Bo that don't need no stinken instruction to land some POS lightweight LSA.



    Clearly, changing the rules so other existing part 23 aircraft will qualify as an LSA will raise the accident rates in those also.
     
  6. RyanShort1

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    I'm quite certain that a closer look would show this to be fairly common. I know personally, and I suspect my experience isn't too uncommon, of two vintage taildraggers in the last 6 years that were wrecked within the first 15 hours by an older pilot who thought he was didn't need any training to fly them. One was the first airplane I owned. I offered the guy a pretty good deal to help him transition but he refused it (penny cheap) and I heard nearly ground-looped it twice before getting it home, then wrecked it within a month or so. There was basically nothing wrong with that plane: https://aviation-safety.net/wikibase/160871 The other was a sweet Aeronca that had just been ferried to him in the Boerne area.
     
  7. FastEddieB

    FastEddieB Final Approach

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    I think that’s key.

    I moved from a 3,400 lb Cirrus to a 1,320 lb Sky Arrow. The biggest adjustment I had to make was realizing that wind limitations largely relate to the plane, not the pilot. What I mean is in the Cirrus if I was approaching an airport with a direct crosswind of 12G18, I would pay attention, but not probably not consider going elsewhere where the crosswind would be less of a factor. The danger is I might subconsciously transfer wind limits over to my new plane. But a 12G18 crosswind in a Light Sport could present a serious challenge to even a skilled pilot. In my Sky Arrow, those winds would have me seriously considering choosing to proceed to an alternate.

    What is significant is that many, if not most, landing accidents in Light Sports result in little or no injury. This is due to the lower approach and landing speeds of Light Sports. Which was the impetus to establish lower stall speeds on Light Sport in the first place. I am in favor of expanding the definition of Light Sport aircraft, but if that new definition includes increasing the stall speed, I think we need to anticipate that the severity of injury in landing accidents may likely increase.
     
    Last edited: Jul 24, 2019
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  8. FastEddieB

    FastEddieB Final Approach

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    As an exercise, would anyone like to calculate the percentage increase in kinetic energy between an accident at 39 kts and one at 50 kts? I have a spreadsheet that calculates it for me, but don’t have ready access to it right now. It’s a worthwhile exercise regardless.
     
  9. Clip4

    Clip4 En-Route

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    And the FAA doesn’t allow homebuilts in commercial operations either.


    METHODS:
    To calculate accident rates, personal flying hours were obtained from the annual FAA General Aviation and Part 135 Activity Surveys, and numbers of personal flying accidents were obtained from the NTSB accident database. Overall and fatal personal flying accident rates for the SLSA and ELSA groups and other GA aircraft were calculated and accident rates were compared.

    RESULTS:
    The overall personal flying accident rate for SLSA and ELSA was found to be 29.8 per 100,000 flight hours and the fatal accident rate was 5.2 per 100,000 flying hours. These are both significantly greater than the overall personal flying rate of 12.7 per 100,000 h and fatal rate of 2.6 per 100,000 h for other GA aircraft.

    The LSA accident rate is 234% greater.
     
    Last edited: Jul 24, 2019
  10. RyanShort1

    RyanShort1 En-Route

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    Why the burr in the saddle? If I want to fly a Pipistrel, which is considered safe even in your video, how does that hurt you?
     
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  11. RyanShort1

    RyanShort1 En-Route

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    The FAA's already made the decision to allow people to use SLSA factory-built aircraft to teach in commercially (that's actually fairly stressful on planes) and tow gliders (structural). Maybe you don't like that, but it's legal. It's not a huge leap from there, or a significantly more dangerous (I'd argue less dangerous) deal to allow for flights involving orbits and straight lines. Do you consider your aerial photography missions more stressful on an aircraft than a student doing multiple touch and goes @Clip4 ???
     
  12. FastEddieB

    FastEddieB Final Approach

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    I believe it’s been established that instructing is not a commercial operation. The instructor is being compensated for his or her instruction, but is not commercially “for hire”.
     
  13. RyanShort1

    RyanShort1 En-Route

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    Then why do flight schools have to do 100 hour inspections and such?

    https://aviation.stackexchange.com/questions/44955/what-is-the-faas-definition-of-for-hire

    This is why I personally think an SLSA that is owned and operated by the company that is using it for aerial photography, should be allowed to use it under part 91 with a hired commercial pilot on board.
     
    Last edited: Jul 24, 2019
  14. Capt. Geoffrey Thorpe

    Capt. Geoffrey Thorpe Touchdown! Greaser! PoA Supporter

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    How much of that is due to the S-LSA/E-LSA consensus standards vs. Part 23?
    How much of that is due to the fact that medicals are not required?
    How much due to poorly trained Sport Pilots (lower minimums).
    How much due to the bar being lowered for Sport Pilot Instructors?
    How much of that is simply due to the fact that LSA's are light aircraft and require a pilot to actually fly them to the runway?
    How much is due to differences in "mission"?

    Saying that they have twice the accident rate means nothing without having a root cause. Pilots? Planes? or Physics?
    Which will be the issue if 172's fall under a new "LSA" definition?

    "More Doctors smoke Camels than any other Cigarette"
     
  15. wanttaja

    wanttaja En-Route

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    Thank you, this is useful information. But, unless there was something else, this was not the "4x higher" rate you posted earlier, nor is it, apparently, specifically for Tecnam aircraft. For example, I find a wide variation in accident rates among EAB aircraft of similar types (Kitfox vs. Avid, for instance).

    In any case, I have posted in length my objections to combining the results of the FAA General Aviation survey and the FAA registration database in a de-registration environment, though I suspect the problems are reduced in the Special Light Sport and Experimental Light Sport areas (i.e., not as many old SLSAs and ELSAs being deregistered).

    However, what I call the "Comparable Use" problem continues. Looking at Table 3.2 in the 2017 FAA GA Survey ("TOTAL HOURS FLOWN BY ACTUAL USE BY AIRCRAFT TYPE"), we note the following:

    Fixed Wing Hours, personal use: 6.5M
    Fixed Wing Hours, business/other use: 11.7M

    So only about 36% of the overall fixed wing hours is personal use.

    Contrast that with the numbers for Light Sport:
    Personal Use: 120K
    Business/Other use: 83K

    Fifty-Nine percent...a much greater percentage...of Light Sport hours are flown for recreation and pleasure. This is not comparable use, and it's not fair to Light Sport (or EAB) to compare them to production aircraft this way.

    As others have mentioned, the experience level of the pilots must be factored in as well. The FAA survey did surprise me a bit with its estimate of the average yearly flying time... 83 hours for SLSA, vs. 101 hours/year for 4+ seat GA aircraft). But it's just 37 hours/year for ELSA, which, again, would reflect personal flying vs. business flying.

    But the overall GA hourly rate is affected by the deregistration effort, where the inactive aircraft removed by the deregistration process are not reflected in the GA survey results. In a period where nearly 1/4th of all EAB aircraft were removed from the registry, the FAA Survey estimate of active EAB aircraft rose by just two percentage points. Light Sport, being a recent innovation, isn't affected as much, and its hour prediction is more accurate.

    I explained the problem in another post recently, but let me recap. The FAA survey determines the percentage of active aircraft by responses received to its mailed survey. It then multiples that percentage by the number of aircraft listed in the registry to determine the number of active aircraft, and multiplies THAT number by the average number of flight hours reported in the *received* surveys to compute the total flight hours.

    The problems is, the FAA is removing inactive aircraft from the registry if they don't reply to a SEPARATE mailing. Since the owners of those inactive aircraft weren't likely to respond to the survey, either, their aircraft did not affect the Survey results but the loss of the aircraft on the registry skews the computed results.

    Here's an example of the problem: If a person owns a Cessna 172, the FAA Survey says he flies it 101 hours a year.

    But if he sells the 172 and builds an RV-10, the FAA Survey says he now flies only 47 hours a year.

    So I'm not too confident in accident analyses that combine the NTSB data, the FAA registry, and the FAA survey results.

    Ron Wanttaja
     
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  16. EdFred

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    And still managed to screw it up
     
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  17. Palmpilot

    Palmpilot Touchdown! Greaser!

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    Did they fail to copy the legislation into the regs correctly?
     
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  18. Salty

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    I could be wrong, but I don't believe you have to do 100 hour inspections for training unless you are renting out the aircraft, IE: It's not the training, it's the rental that requires the inspection. I can give instruction in my plane without 100 hour inspections as long as I don't charge for the plane, or I can give instruction in your plane, and you don't need to do 100 hour inspections.
     
  19. RyanShort1

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    If you provide instruction for hire in an aircraft you supply it is commercial and you have to do the 100-hr inspections. And that goes for SLSA’s currently, too.
     
  20. Salty

    Salty En-Route PoA Supporter

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    Can you cite reg? That's not my understanding.
     
  21. RyanShort1

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  22. Salty

    Salty En-Route PoA Supporter

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    14 CFR § 91.409(b)
    You’re faster than me, but you’re right. I was forgetting that you can’t charge for the instruction either. If I don’t charge you for the instruction AND don’t charge you for my plane, then I don’t need the inspection, except for having my head examined.
     
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  23. Clip4

    Clip4 En-Route

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    If you want to fly one, have at it, bit when you advocate approval for a commercial operation that is a different story.
     
  24. RyanShort1

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    I plan on it... the Pipistrel in particular is already in commercial and LE use in Europe and it’s plenty capable and as your video mentioned, also safe statistically. Advocating against it is an affront to those manufacturers (Especially those in Europe like Pipistrel) who’s aircraft are being safely operated elsewhere commercially without reasonable evidence against them. If you ever get the chance, you should fly a Pipistrel with an open mind!
    SLSAs are already bouncing around patterns for hire and you have yet to show that that a photo mission with a more experienced pilot is realistically more dangerous. It’s also different when it’s being flown by it’s own owner / operator per Part 91 with a hired commercial pilot vs running a Part 135 charter operation, which I am NOT advocating. Keep in mind that right now, a private pilot with less hours (150) than ANY commercial pilot can theoretically get a sport CFI cert. and jump in an SLSA and fly a student cross-county pretty much anywhere.
    I’ve already done the SLS-A flying deal, along with a ton of grandfathered legacy LSA-qualified taildraggers, have the t-shirt from the experience over 5 years ago with a bunch of hours in an Apollo Fox and I’d do it again with no reservations. I’d swap a Cardinal RG for a Virus SW in a heartbeat and I think I mentioned in another thread that I came to prefer the Apollo for night flights over anything else in the fleet.
    Blue skies for your photo missions!
     
    Last edited: Jul 24, 2019
  25. EdFred

    EdFred Touchdown! Greaser! PoA Supporter

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    They (the gov't) couldn't even get the legislation right.
     
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  26. Clip4

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    Brush up of your French and German and you will do fine.
     
  27. hindsight2020

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    Ah yes, the if you dont love it leave it trope. That's back en vogue apparently.
     
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  28. Palmpilot

    Palmpilot Touchdown! Greaser!

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    Amen to that.
     
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  29. FastEddieB

    FastEddieB Final Approach

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    I guess no one likes homework!

    upload_2019-7-25_20-53-47.jpeg

    Energy increases as the square of the increase in velocity, and its the dissipation of that energy that injures and kills. I know most here know that, but there are always newbies and it’s a good reminder regardless.
     
  30. Clip4

    Clip4 En-Route

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    That might be his only option as the FAA is not likely to change the reg.
     
  31. RyanShort1

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    Stranger things have happened. Like pilots who hate on airplanes!
     
  32. Clip4

    Clip4 En-Route

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    Or pilots who have regard little for the safety of employees or paying passengers they would fly in airplanes that have rather high accident rates.
     
  33. Warmi

    Warmi Pre-takeoff checklist

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    Then don’t fly them if you don’t like them or don’t trust them... what’s the big deal ?

    You don’t need the FAA to tell you that , do you ?
     
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  34. Capt. Geoffrey Thorpe

    Capt. Geoffrey Thorpe Touchdown! Greaser! PoA Supporter

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    What is it about the airplane that is causing this higher accident rate?


    I recall an IIHS study years ago comparing driver fatalities by make and model - the Mercury Grand Marquis had something like a 175% higher fatality rate than the Ford Crown Victoria.

    Same car.
     
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  35. RyanShort1

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    Well, last I checked, I was arguing that the FAA should consider allowing for a Part 91 style deal where an owner operator could hire a pilot to fly them on a mission. That’s already legal in something like a Cessna 150-210 or all the way up to a jet and that’s how the better operators roll. I know of one aerial photography crash so far since I’ve been doing it for a living. Thankfully it wasn’t in my circles, but it was in Texas and it was in a 172.

    I'm NOT advocating the following practice, but I know of people in the aerial photography world that hire a rental fleet airplane and a CFI and calling it "training." I don't condone that, but it happens and it could be happening in an SLSA if people are ignoring the rules. Didn’t we even have a poster on here talking about an outfit hiring for aerial photography in an RV-6 earlier this year? People are going to play by the rules or not, but that is not an SLSA vs Certified issue.

    I also specifically did not include pax for hire. The pilot has a choice to fly or not in a Part 91 situation with the owner of an aircraft just like any CFI has the right to fly in an experimental with some owner or decide they don't want to set foot in it. You also consistently ignore the basic concept that Part 91 operators are going to evaluate any option like that for safety and mission capability. Even the worst operators out there aren't PLANNING on losing a load of skydivers, but we all know that restricting them to certified aircraft keeps that from happening, right? :rolleyes: Specifically you brush aside the specific airplane (although I’m sure we could find others) that I actually advocated for that actually has a good safety record by even the standards of the video you brought to the discussion. Where does it sound like I don’t have regard for my pilot or camera guy?

    I’ve thought for a long time that the restrictions to legacy aircraft like the Cardinal that so many of my colleagues fly because it is still the best certified aircraft for the job is actually the safety bottleneck. Did you see that Cessna 210 that crashed on survey in May triggering the spar inspections in the 210 and 177 fleet? A 1975 Cardinal is pushing 45 years old at this point (the 1970 one will be 50 years old next month) and while we chose to do the recent Cessna SB on the spar and I’m putting a new engine on an aircraft in the $35-45k range (because our company DOES care) and we maintain them as carefully as possible, there are still ways that opening up the Regs to Part 91 style SLSA (factory-built) usage, which again SHOUlD be less stressful on the aircraft than the SLSA flight training which is already legal, and reasonably safe, would be a possible safety improvement.

    I think the chances of structural failures and fatigue issues in high-usage survey and photography aircraft are going to get a lot higher as the legacy certified fleet gets older. Allowing for reasonable SLSA options - even if some higher inspection requirements were involved as a compromise - and especially if they open the margins up a bit as the opening post of this thread is talking about, would lessen the likelihood of those failures and also mean that if they did happen, the energy involved in a crash, or the option (looking at that Pipistrel) to pull a chute is a safety improvement. A bonus in the Pipistrel world is that the SW can go almost as fast as a Cardinal on less fuel and fixed gear which means less likelihood of a gear failure (something I’ve actually experienced).
     
    Last edited: Jul 26, 2019
  36. Capt. Geoffrey Thorpe

    Capt. Geoffrey Thorpe Touchdown! Greaser! PoA Supporter

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    "Making big conclusions about small numbers is fraught with problems"

    upload_2019-7-26_9-29-21.png

    Ain't many total aircraft out there to draw conclusions about.

    "Obtaining accurate fleet hours is impossible"

    upload_2019-7-26_9-32-48.png

    212 accidents over a 3 year period - ain't much to work with...
    upload_2019-7-26_9-34-26.png

    "Light Sport skeptics warn that the low wing loading and light control forces would be a factor in accidents and it appears that they may be right"

    Conclusion:
    Obviously, the solution to this accident problem is to do your aerial photography in a Cub or Champ to avoid the risk to your photographer.