Finally: FAA Issues LODA Guidance

PW_Plack

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Thanks to Chuck Roberg for posting this! I copied it here to give it a new thread all its own:

Still not what Gyro CFI's need...

http://www.eaa.org/news/2010/2010-09-16_lodas.asp

Barriers increase for E-LSA instruction
David Oord
EAA Government Specialist David Oord

September 16, 2010 — The long-awaited guidance for LODA or Letter of Deviation Authority has finally been published by the FAA, but the guidance does very little to improve training availability for E-LSA aircraft. The various FAA branches have been debating for quite some time the final guidelines that Flight Standards offices would use to issue these authorizations. As part of a new push by the FAA to encourage transition training for experimental aircraft, the new guidance facilitates this aim by permitting flight training for compensation through the LODA process. The new LODA procedures, however, appear to increase the barriers to training for E-LSA aircraft by limiting LODAs to areas where certified LSA are not available and by not allowing the use of E-LSA trainers for the purpose of attaining ratings, certificates, or other flying privileges.

“We are fearful that existing CFIs that have been banking on the ability to continue to offer primary training will cease offering instruction since only transition training is allowed under a LODA,” said EAA Government Specialist David Oord. “This will deepen the training vacuum in the E-LSA segment and will have an impact on safety.”

FAR 91.319(h) permits the FAA to issue a LODA to an applicant for the purpose of conducting flight training in experimental aircraft. Most experimental aircraft have different handling characteristics when compared to type certificated aircraft, thus necessitating the need for transition training. A LODA would allow that transition training to be for compensation.

Flight training considered acceptable for the issuance of a LODA consists of:

1. Initial flight training for the operation of specific make and model of experimental aircraft.
2. Recurrent flight training for the operation of a specific make and model of experimental aircraft.
3. Primary flight training for the operation of ultralight vehicles only when conducted in low mass, high drag vehicles with an empty weight less than 500 pounds and a maximum speed in level flight with maximum continuous power (VH) less than 87 knots calibrated airspeed (CAS).
4. Jet unusual attitude and upset training.
5. Instrument competency training for specific make and model of experimental aircraft.
6. Training for a flight review in a specific make and model of experimental aircraft.
7. Formation training for specific make and model of experimental aircraft.
8. Other specific training approved by the General Aviation and Commercial Division, AFS-800.

A LODA for primary flight training for the operation of an ultralight vehicle will only be granted if an S-LSA is not available for flight training in the Flight Standards District Office’s (FSDO) geographic area. Additionally, the aircraft must have been owned by an appropriately rated CFI before January 31, 2010. If granted, the LODA will have a maximum duration of 24 months and be limited to the geographic area of the FSDO.

The guidance states that a LODA cannot be used for flight training leading toward the issuance of a pilot certificate, rating, or operating privilege. It has been EAA’s position that, until a sizable and available fleet of S-LSA is realized, in order to grow the sport, E-LSA that were previously allowed to give primary instruction under FAR 91.319(e)(2) should be allowed to continue to do so under a LODA. Unfortunately, the guidance does not allow for such instruction, shrinking the size of available training aircraft even further.

Although the policy guidance is finally out, questions still remain, particularly in the gyro community. EAA is compiling a list of questions for submittal to the agency and will share those answers once received. If you have questions, please forward them to [email protected].

Ultimately it has been previously stated that “it is the policy of the FAA to foster and promote general aviation while continuing to improve its safety record. These goals are neither contradictory nor separable. They are best achieved by cooperating with the aviation community to define mutual concerns and joint efforts to accomplish objectives.” EAA feels the LODA guidance for E-LSA neither fosters or promotes that segment of general aviation and will further reduce the number of aircraft available for primary training.
 

PW_Plack

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The FAA again seems to have failed to offer any legal path to new CFIs seeking to offer primary instruction for its own Sport Pilot, Recreational, Private, Commercial or Instructor gyroplane certificates.
 

PW_Plack

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Sure...for all those people who buy used two-place machines before they take instruction. The machine would have to have its 40-hour phase-1 requirement flown off before it could be used for dual instruction, so it wouldn't work for anyone looking for instruction in a machine he just built.
 

Russ Hobbs

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There you go Paul, just bust my bubble. I thought if I ever finished my 2 place, I'd be able to still get instruction. Damn if timing is everything huh. Looks like the market for gyroplanes might be in trouble.
Russ
 

scottessex

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What a bunch of POOP! all to help make aviation more accessable to more people, yeah whatever! Thanks for the help. NOT!
 

Gyro28866

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FAA - We are here to HELP!

H - Hinder
E - Exacerbate
L - Limit
P - PREVAIL
 

Brent_Brown

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You can get your fixed wing cert. them fly off the 40 hours or 20 hours if you used a certified AC engine solo. then get CFI to train in your gyro to get an rotorcraft add on and then you can carry someone in your 2 place. yes it is more time and money but doable. That is my plan. I already have a FW cert.
 

Doug Riley

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Instruction in the student's craft is step backwards in safety.

Common sense suggests that an instructor who spends long hours in his own machine will know it inside and out, will catch problems early and will keep the machine attractive because it's good business to do so. As an experienced owner-pilot, the instructor presumably knows how to maintain a machine properly.

Used, student-owned aircraft are going to be much more of a mixed bag.

I'm still very sad at the loss of dear friend Mark Reese, who was instructing in a student's trike when it literally came apart in the air. An investigation revealed that it had previously been damaged and not repaired completely, leaving a slew of concealed, sheared rivets at the end of the critical front lift strut.
 

PW_Plack

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You can get your fixed wing cert. them fly off the 40 hours or 20 hours if you used a certified AC engine solo. then get CFI to train in your gyro to get an rotorcraft add on and then you can carry someone in your 2 place. yes it is more time and money but doable. That is my plan. I already have a FW cert.
If fixed-wing pilots with zero gyro experience build their own two-place gyros and fly 40 or 25 hours solo before taking any dual instruction, how many will make it without destroying the machine and/or themselves?

(A certificated engine and prop drops the requirement to 25 hours.)
 

Chuck Roberg

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I regret posting that information about the LODA's with out first getting a little more information.

I think we need to not start a flame war with the FAA. All that will do is jeopardize the efforts of those people who are trying to work in our best interests.

I hope some of the post here do not alienate those who are only trying to help.

Let's not get inpatient. It will take time.
 

gyrogreg

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Hold on - not so bad!

Hold on - not so bad!

I am very reluctant to get involved in any forum discussions right now - I don't have the time for a lot of conversation. so that this subject doesn't get blown out of porportion, I will try to answer your concerns in a couple of posts. Please don't ask for more - I don't have more information at this time. But, it is not so bad!

The new FAA guidance lists 8 things a LODA may be used for. Number 8 says "8. Other specific training approved by the General Aviation and Commercial Division, AFS-800."

The EAA has confirmed with the FAA that this specifically applies to gyroplane training. We are not sure of the process yet, a LODA request may have to specifically request approval from AFS-800, but we are assured that gyroplane CFIs will be able to get new LODAs now.

The EAA has requested a list of questions they can submit to the FAA. I have provided them with a list of questions pertaining to gyroplane issues - summarized in next post below.

There is one gyroplane concern I still have with this LODA guidance: It is not clear if the FAA will allow gyroplane CFIs to use an ELSA gyroplane. This is one of thequestions we have asked the EAA to resolve with the FAA. The same arguments for which the FAA included number 8 above, are also valid for training in ELSA under a LODA - we will fight for this.

- Thanks, Greg
 

gyrogreg

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Questions for FAA

Questions for FAA

The EAA has requested specific questions they can pursue with the FAA. The EAA is very aware the peculiar situations with gyroplanes and of the unintended consequences that FAA rules and guidance can have on gyroplanes. Below is the list of gyroplane LODA questions I have submitted to the EAA - Greg Gremminger:


1. Will our gyroplane CFIs be able to obtain LODAs to provide Primary training (Sport Pilot, Recreational and/or Private) for hire in the Instructor’s experimental trainer gyroplane? The new guidance appears to not allow “primary training”. I assume flight training for higher gyroplane ratings or for students who already hold another pilot certificate would be allowed to receive training for Gyroplane Commercial and Instructor ratings under the LODAs issued under these newly released guidelines. There are no certificated gyroplanes available for primary flight training other than E-AB or ELSA. SLSA gyroplanes are not allowed and are therefore not an option for training.

2. Will our gyroplane CFIs be able to “rent” their experimental trainer gyroplanes for student solo requirements?


3. Can our CFIs with ELSA gyroplanes obtain or use an existing LODA to provide primary rating flight training, or other training (make/model transition, recurrent, flight review, etc.) for hire? Gyroplane instructors are at a premium – for safety! We have very few gyroplane CFIs, but what we do have need to be able to make flight training accessible. There are still a few gyroplane CFIs that have ELSA gyroplanes – transitioned from previous 2-place ultralight trainers, or others certificated ELSA before the transition deadline.

4. The gyroplane community is negotiating with the FAA to get ASTM “compliant” gyroplanes in service in the U.S. The intent of this is, per the original SP/LSA rules, to collect safety data to confirm that “compliant” gyroplanes are safer – for future consideration of SLSA gyroplanes. The FAA had directed us to petition for an ELSA exemption that would allow factory-built ASTM “compliant” gyroplanes to be sold in the U.S. – for the purpose to collect this safety data. These aircraft would necessarily be on the high end of the price range, and the market for such aircraft would be mostly for CFIs. Early on, Sue Gardner had told us that such ELSA gyroplanes could receive a LODA to provide flight training – improving the numbers of “compliant” gyroplanes in service, while also addressing the severe shortage of gyroplane Instructors. Would our gyroplane CFIs be able to get or use a LODA to provide (primary and other) flight training for hire in an exempted ELSA gyroplane if such exemptions are issued?

5. Will gyroplane CFIs be able to get LODAs to provide flight training for hire for ultralight gyroplane pilots?

6. What will the process for application for gyroplane LODAs be?
The same as before – Deviation Request letter and Training Course Outline to individuals FSDO? Will there need to be coordination with AFS-800 or other FAA departments, and will the FSDOs know to do so?[/b]

7. Will previously issued LODAs for gyroplane instruction still be valid? Numbers of our CFIs had successfully requested and been issued LODAs several years ago. Those LODAs specifically listed allowance to provide training for all gyroplane ratings – Sport Pilot through Instructor.
 

gyrodeputy

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Greg,

This is why you truely are a champion of the industry...promoting safety.

You are my hero. Thank you for all you do.

Stay safe.
 
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