Rick and netters
I am not trying to say anyone is wrong, I have just been around the FAA for a 
long time, and I really don't care what one presenter is saying at a local 
meeting, until I see it in print in the regs, and so far it is NOT published 
concerning ELSA just LSA in Part21, I would not count on being able to certify 
my plane under that designation. No where in the rules does it say that you may 
simply apply for a Special Airworthiness Amateur Built and then after testing 
state that it complies with ELSA so it will be operated in that category and 
requires that licensure from the pilot.  It clearly states in Part 21 that to 
qualify for LSA the information and testing data that supports that must be 
submitted at the time of the application.  I find it very difficult to believe 
that IN PRACTICE the FAA will conduct Amateur Built in reverse, especally since 
this new category lowers the pilot requirements to be able to fly.  You and I 
have both seen Zodiac 601 & 701s reported to be able to qualify for the LSA & 
ELSA rules, along with the Pioneer 200 from Alpi, and offering from Wicks, and 
many others. Yet so far the partial list only includes the J3 cub types, of 
course ultralights, yet some are still not included on their list. I have 
included a brief description from the rule of the aircraft.
Light Sport Aircraft:
  a.. Light sport aircraft are defined as simple, low-performance, low-energy 
aircraft that are limited to - 
    a.. 1,320 pounds maximum certificated gross weight (1,430 lb for 
seaplane/float equipped) 
    b.. Maximum of two-occupant seating 
    c.. A single engine (non-turbine) 
    d.. Maximum airspeed of 120 knots 
    e.. Fixed landing gear 
    f.. Maximum stall speed (without lift enhancing devices) of 45 knots
  b.. Aircraft meeting the above specifications, such as a Piper J-2 or J-3, 
Aeronca Champ, or early model Taylorcraft, may be flown by sport pilots. 
It is also interesting to note that the FAA make it quite clear in the rule 
that they will use their judgement in determining whether an aircraft meets the 
ELSA criteria or not.  They also specifically prohibit the mdoification of 
existing aircraft that perform outside the parameters of the ELSA from being 
modified to qualify, stating that this is not the purpose of the rule. They 
clearly state that the purpose of the new rule is to bring under regulation 
aircraft who were previously being operated undet Part 103 without 
certification.  Be careful. If you think you can just claim your version of the 
KR complies with Sport Pilot, and so it is one, think again.  According to 
comments and explainations in the new rule, available online from EAA and AOPA, 
the aircraft must meet the same consensus standard and requirements as the LSA 
manufacturers.  As I said before, the FAA makes it clear that this rule is not 
for allowing existing designs or aircraft to be built or re-built as LSA or 
ELSA, but rather to certify aircraft previously operating under Part 103.  With 
so many flying examples of the KR already exceeding the parameters, you will 
have to significantly change this design in order to convince the FAA that it 
is LSA or ELSA.

Colin & Bev Rainey
KR2(td) N96TA
Sanford, FL
crain...@cfl.rr.com
http://kr-builder.org/Colin/index.html

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