LODA - Could not be simpler - nor quicker.

Arnold

Arnold

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Arnold
1) Sent email to FAA at address shown on EAA website.
9-AVS-AFG-LODA@faa.gov Last night 2309 UTC

2) Received email acknowledging receipt of my email at 2317.

3) Received email with ,pdf form to complete. Form included clear instructions. This AM.

4) Completed form and sent via email to stated address.

5) Two minutes later received electronically signed approval from FAA.

Now qualified to instruct in all experimental aircraft.
 
Arnold said:
Now qualified to instruct in all experimental aircraft.
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Are you also able to RENT any experimental aircraft for training, or can you only instruct in any aircraft owned by the student?
 
So what you're saying is this is so quick a process it can't possibly be adding to safety since they don't take any time to do any actual review? Sounds like it's an administrative waste of time, money, and effort, if it literally only takes a few minutes/hours to complete.
 
Arnold said:
1) Sent email to FAA at address shown on EAA website.
9-AVS-AFG-LODA@faa.gov Last night 2309 UTC

2) Received email acknowledging receipt of my email at 2317.

3) Received email with ,pdf form to complete. Form included clear instructions. This AM.

4) Completed form and sent via email to stated address.

5) Two minutes later received electronically signed approval from FAA.

Now qualified to instruct in all experimental aircraft.
Click to expand...

I didn't know about the pdf form. I simply sent an email with my informtion, and it came filled out and signed.
 
JVerb said:
So what you're saying is this is so quick a process it can't possibly be adding to safety since they don't take any time to do any actual review? Sounds like it's an administrative waste of time, money, and effort, if it literally only takes a few minutes/hours to complete.
Click to expand...

I think it is the FAA saying the alphabets forced them to deal with the issue, the court decision was B.S. and they put in place a system that essentially returns things to the status quo with the least hassle for everyone.

I think this a minimal intrusion, minimal admin waste solution to a problem that was forced on them by a) idiotic warbird operator, b) court, c) alphabets. I am very pleased with the solution.

[Edit] I think whinging about this will only make things more difficult next time. This is the FAA doing its job properly not improperly.
 
JVerb said:
So what you're saying is this is so quick a process it can't possibly be adding to safety since they don't take any time to do any actual review? Sounds like it's an administrative waste of time, money, and effort, if it literally only takes a few minutes/hours to complete.
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I respectfully disagree. Seeing this thread, I just went online and filled one out for my experimental gyro so I can get flight reviews, etc. in it. It literally took 5 minutes and nothing more than double-checking my pilot's license number in my wallet.

The wording in the document included, among other things: "Owners of experimental aircraft and flight instructors exercising the privileges of this LODA are restricted from advertising or broadly offering the use of their aircraft for flight training. Operations of that nature would require a LODA in accordance with FAA Order...".

Seems to me they're taking a very sound, simple approach: make it very simple for people with their own Experimental aircraft to get the LODA for their own personal training and make it easy for CFIs to train people like me while requiring more scrutiny for those who want to offer their aircraft for training. Seems like they don't need to do much, if anything, of a "review" - just file away my attestation that that's all I want to do. Now, if they find me renting my gyro out in the future, I'll be spending some money on an attorney because of this....

It also says it's good for 48 months. I just need to put this on my list for my Annual to check and make sure it's current, since my Annuals are in August, by coincidence.

With this approach, I'm not even sure I see much of a need for a "regulatory fix".
 
Llewtrah381 said:
I respectfully disagree. Seeing this thread, I just went online and filled one out for my experimental gyro so I can get flight reviews, etc. in it. It literally took 5 minutes and nothing more than double-checking my pilot's license number in my wallet.

The wording in the document included, among other things: "Owners of experimental aircraft and flight instructors exercising the privileges of this LODA are restricted from advertising or broadly offering the use of their aircraft for flight training. Operations of that nature would require a LODA in accordance with FAA Order...".

Seems to me they're taking a very sound, simple approach: make it very simple for people with their own Experimental aircraft to get the LODA for their own personal training and make it easy for CFIs to train people like me while requiring more scrutiny for those who want to offer their aircraft for training. Seems like they don't need to do much, if anything, of a "review" - just file away my attestation that that's all I want to do. Now, if they find me renting my gyro out in the future, I'll be spending some money on an attorney because of this....

It also says it's good for 48 months. I just need to put this on my list for my Annual to check and make sure it's current, since my Annuals are in August, by coincidence.

With this approach, I'm not even sure I see much of a need for a "regulatory fix".
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I’m sorry you feel that way. Seriously.
You are ok with

1. considering training in your personal aircraft to be a deviation from normal behavior
2. Wasting people’s time filling out and approving forms that provide no purpose whatsoever and make nobody safer. Time that could be used actually implementing and performing safety functions that serve a purpose.
 
Arnold said:
1) Sent email to FAA at address shown on EAA website.
9-AVS-AFG-LODA@faa.gov Last night 2309 UTC

2) Received email acknowledging receipt of my email at 2317.

3) Received email with ,pdf form to complete. Form included clear instructions. This AM.

4) Completed form and sent via email to stated address.

5) Two minutes later received electronically signed approval from FAA.

Now qualified to instruct in all experimental aircraft.
Click to expand...
This covers you for all experimentals and for all time?
 
AggieMike88 said:
This covers you for all experimentals and for all time?
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Not exactly sure which you mean. For aircraft, it's for all the ones you list by N number (for your own aircraft). For CFIs, it's just their name, address, email, and license number and, once approved, they're then "...authorized to exercise the privleges of this LODA in any experimental aircraft for which he or she is qualified to provide flight training." It's good for 48 months.
 
Salty said:
I’m sorry you feel that way. Seriously.
You are ok with

1. considering training in your personal aircraft to be a deviation from normal behavior
2. Wasting people’s time filling out and approving forms that provide no purpose whatsoever and make nobody safer. Time that could be used actually implementing and performing safety functions that serve a purpose.
Click to expand...

No need to feel sorry. Seriously.

What I'm OK with is:
1. Considering training in my own personal experimental aircraft to be a deviation from the Court's decision - not "normal behavior". And let's not forget that even "experimental" is a wink and a nod: we're not "flight testing" anything, in 90+% of the cases.
2. A literally 5-minute task to satisfy the purpose of showing I'm exempt from the Court's decision for my situation.

Let's not forget: had Warbird Adventures not poked the bear with their blatant bucket-list-rides-disguised-as-training scheme, the FAA seemed perfectly willing to leave things as they were. Blame Warbird Adventures - not the FAA - for their misuse of the otherwise reasonable rules.

Fly safely!
 
Llewtrah381 said:
No need to feel sorry. Seriously.

What I'm OK with is:
1. Considering training in my own personal experimental aircraft to be a deviation from the Court's decision - not "normal behavior". And let's not forget that even "experimental" is a wink and a nod: we're not "flight testing" anything, in 90+% of the cases.
2. A literally 5-minute task to satisfy the purpose of showing I'm exempt from the Court's decision for my situation.

Let's not forget: had Warbird Adventures not poked the bear with their blatant bucket-list-rides-disguised-as-training scheme, the FAA seemed perfectly willing to leave things as they were. Blame Warbird Adventures - not the FAA - for their misuse of the otherwise reasonable rules.

Fly safely!
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No. Your letter is an authorization to deviate from the defacto standard that training is not allowed. You can fly your experimental without any training at all and no letter of authority. Faa is fine with that. But you are not allowed to train in your own experimental aircraft without special authority to deviate from the standard of not training. It’s insane. Completely upside down, and nobody should be happy about it.
 
Salty said:
No. Your letter is an authorization to deviate from the defacto standard that training is not allowed. You can fly your experimental without any training at all and no letter of authority. Faa is fine with that. But you are not allowed to train in your own experimental aircraft without special authority to deviate from the standard of not training. It’s insane. Completely upside down, and nobody should be happy about it.
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I own an Experimental and am therefore affected by this - and it doesn’t bother me in the least.

Haven’t met you and don’t know what you fly and/or instruct in. Can you tell me how this affects YOU, so I can better understand your anger with this? Thanks.

>>Edit: The "de facto standard that training is not allowed" is not correct. It IS allowed - and requires a LODA. The Court decision didn't create that - it clarified it. The guy I trained with has had a LODA for years, both for himself and his training aircraft. And I received my initial training in the same model gyro before I built and flew mine. The only flying I've done in my gyro that would be affected by all of this is my Flight Review a year and a half ago - and if I really wanted to avoid this issue, I'd just go do it in his gyro.

And, no, actually I CAN'T fly my Experimental "...without any training at all and no letter of authority". I need a license (or at least a Solo sign-off). That hasn't changed either.

Again, this is ENTIRELY WARBIRD ADVENTURE's FAULT. They could have applied for a LODA for exactly what they were doing. It probably wouldn't have been approved, but it was definitely possible. LODAs aren't new.
 
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Nope, if you don’t see why training ina plane you own being considered deviation is a bad thing, I can’t help you.
 
Salty said:
Nope, if you don’t see why training ina plane you own being considered deviation is a bad thing, I can’t help you.
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Thanks but no help needed! Appreciate the concern, though!

…and I take it you don’t have a dog in the fight…
 
Llewtrah381 said:
…and I take it you don’t have a dog in the fight…
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You take it wrong. Salty's interest in this is not as a bystander.

I agree with the idea that the fact this is just a paperwork drill in order to do what we could all do 6 months ago means it is doing nothing for the safety of aviation.
 
Salty said:
Wasting people’s time filling out and approving forms that provide no purpose whatsoever and make nobody safer. Time that could be used actually implementing and performing safety functions that serve a purpose.
Click to expand...
We're talking about the FAA. That's what they do.
 
bflynn said:
You take it wrong. Salty's interest in this is not as a bystander.

I agree with the idea that the fact this is just a paperwork drill in order to do what we could all do 6 months ago means it is doing nothing for the safety of aviation.
Click to expand...

Do you think it is detrimental to safety to authorize officially the previous practice? Just curious.

Cheers
 
bflynn said:
You take it wrong. Salty's interest in this is not as a bystander.

I agree with the idea that the fact this is just a paperwork drill in order to do what we could all do 6 months ago means it is doing nothing for the safety of aviation.
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Exactly what was the FAA supposed to do - ignore the court? Ignore the Rule of Law?

Their “fix” is simple and commendable - coming from someone who actually has a dog in the fight. No exaggeration - the amount of time you, Salty, and I have spent on this thread is well over ten TIMES what it took me to do the form. Now - what value was added by all THAT?!?

The problem is - some people aren’t happy unless they’re unhappy.

Cheers!
 
Arnold said:
Now qualified to instruct in all experimental aircraft.
Click to expand...

Actually, you're not. You're qualified to instruct in any experimental aircraft that the student also has a LODA for.
 
Exactly what was the FAA supposed to do - ignore the court? Ignore the Rule of Law?
Click to expand...
That's not what the court decision says. First off, the court deferred (obligatorily) to the FAA's interpretation of their own poorly crafted rule.
Second, the ruling was that offering flight instruction in an experimental is carriage of passengers for hire. That doesn't address inane requirement for LODA when a PILOT seeks instruction in his OWN aircraft.
 
flyingron said:
That's not what the court decision says. First off, the court deferred (obligatorily) to the FAA's interpretation of their own poorly crafted rule.
Second, the ruling was that offering flight instruction in an experimental is carriage of passengers for hire. That doesn't address inane requirement for LODA when a PILOT seeks instruction in his OWN aircraft.
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14 CFR 91.319
 
flyingron said:
Actually, you're not. You're qualified to instruct in any experimental aircraft that the student also has a LODA for.
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I think you're wrong on this one. My understanding is that for paid instruction to occur in an E-AB,

EITHER the owner has to have a LODA OR the CFI has to have a LODA. Both aren't required.

As a CFI, I got mine and it was painless. What I can't do under my LODA is offer up my own E-AB for paid instruction (if I still owned one). I'd need a special, super-duper LODA for that.
 
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flyingron said:
That's not what the court decision says. First off, the court deferred (obligatorily) to the FAA's interpretation of their own poorly crafted rule.
Second, the ruling was that offering flight instruction in an experimental is carriage of passengers for hire. That doesn't address inane requirement for LODA when a PILOT seeks instruction in his OWN aircraft.
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The court decision does not mention experimentals.

https://www.pilotsofamerica.com/community/attachments/warbirdsdecision-pdf.95714/

As far as I can see, the reason experimentals are impacted is that 91.319(a)(2) specifically says that they can't be used to carry persons or property for hire.

https://www.ecfr.gov/cgi-bin/text-i...74b6d62d&mc=true&node=se14.2.91_1319&rgn=div8

I agree that the concept of a person being carried for hire in his own aircraft doesn't make any sense.
 
Palmpilot said:
The court decision does not mention experimentals.

https://www.pilotsofamerica.com/community/attachments/warbirdsdecision-pdf.95714/

As far as I can see, the reason experimentals are impacted is that 91.319(a)(2) specifically says that they can't be used to carry persons or property for hire.

https://www.ecfr.gov/cgi-bin/text-i...74b6d62d&mc=true&node=se14.2.91_1319&rgn=div8

I agree that the concept of a person being carried for hire in his own aircraft doesn't make any sense.
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It is the instructor who is being carried for hire.

The full explanation of the a) the disconnect between part 61 and part 91 AND 2) the contradiction between old guidance and new regulatory consistency is found in the Federal Register

https://www.federalregister.gov/doc...olicy-for-flight-training-in-certain-aircraft

The explanation that both the owner and the flight instructor require a LODA is found in footnote 4

Whether or not one thinks this a good idea is irrelevant to the fact that it is the law of the moment.

I'm still waiting on regulations congress told DHS to promulgate when it was still INS a couple of decades back, so this strikes me as incredibly fast on the part of the FAA and my hat is off to them for an easy solution to a problem foisted on them by the warbird folks.
 
Arnold said:
It is the instructor who is being carried for hire.
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As I read it, the instructor is operating the aircraft for compensation no matter who owns or pays for the aircraft.

Arnold said:
The explanation that both the owner and the flight instructor require a LODA is found in footnote 4
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"Given the broad definition of “operate” in § 1.1, both the owner of a limited category aircraft seeking flight training and the flight instructor providing the training are considered to be operating the aircraft."
 
And if I transfer money from my left pocket to my right pocket, both my left hand and my right hand need a commercial certificate, an operating certificate, and a LODA. ;)
 
FWIW, and as someone who actually owns an Experimental aircraft and is actually affected by this, I submitted my application on line on Saturday afternoon after literally 5 minutes of “work” and my approved LODA was in my email this morning before 7. This was less involved than the AD about me having to document my Warrior’s fuel selector labeling was correct.

I encourage anyone who hasn’t done so to actually look at the PDF to see how simple it is AND to see that it’s attesting to reasonable things. As with many things, like documenting IFR currency, VOR checks, etc., (all of which take more time and do so repeatedly) it will only be a player if something “unusual” happens.

And again, thank you, Warbird Adventures, for making us do this.
 
And thank you FAA for screwing up so badly that you had the opportunity to respond so admirably. :rolleyes:
 
Seems to me this whole discussion is missing one big point: a court ruled that flight instruction is carrying persons for hire. The FAA accepted that. What makes us think that logic only applies to experimentals, warbirds, etc.? Think about the definition creep of "compensation". This has implications beyond where we are now.
 
DoubleD said:
Seems to me this whole discussion is missing one big point: a court ruled that flight instruction is carrying persons for hire. The FAA accepted that. What makes us think that logic only applies to experimentals, warbirds, etc.? Think about the definition creep of "compensation". This has implications beyond where we are now.
Click to expand...
I think what makes us think that is that the FAA seems to be treating it that way.
 
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