h. CAS versus Indicated Airspeed (IAS)
A few commenters requested the stall speed be specified in IAS rather than CAS. One commenter stated this rule should be rewritten to accommodate the commonly accepted practice of using IAS in the aircraft. CAS is the speed at which an airplane is moving through the air. IAS is displayed on the airspeed indicator and is read by the pilot. IAS differs from CAS in that IAS includes any installation (or position) and instrumentation errors. For example, the accuracy of IAS may be affected by minor misalignment of the airplane’s pitot tube; whereas CAS testing traditionally uses properly calibrated instruments and a test airspeed system independent of the aircraft’s installed equipment. The installation and instrumentation errors are greatest at slow speeds and higher angles of attack, i.e., approaching or at stall speed, and can result in CAS differing from IAS by several knots or more. For example, the stall speed of an airplane may be 50 knots IAS, but 56 knots CAS.
Position corrections vary among airplane models and can even vary among individual airplanes of the same model. As a result, defining stall speed in IAS would yield gross inconsistencies when determining whether an airplane meets an eligibility requirement for design stall speed. Because of these concerns, FAA disagrees with the comments suggesting the design stall speed criterion be specified in IAS rather than CAS. FAA requires CAS for determining whether an airplane meets the design stall speed because it represents the airspeed that would be measured by an airspeed system without position and instrumentation errors. This ensures all airplanes meet the same standard. Regardless, for newly manufactured light-sport category airplanes, the stall speed will be determined by the aircraft manufacturer and verified during ground and flight testing as required by § 22.195.5