Detailed Response Gives Level Headed Approach to Rulemaking for Sport Aviation

Like the EAA, Van's Aircraft finds the FAA's proposed clean stall speed of 54 Vs1 a bit constrictive, noting that the limit "defines which legacy aircraft will meet the definition of light-sport". As such, it's the "single most important parameter that will determine the success or failure of this category".

Van's quotes the FAA itself while talking about the thinking that goes into setting a max LSA stall speed, noting that a "stall speed in the mid-fifties is not enough and would leave out airplanes appropriate for 21.190 and for operation by sport pilots". A lower stall speed would also jeopardize international harmonization." The FAA goes on to note that "higher stall speeds with a crashworthiness requirement" would not be doable within the current framework, since the industry "does not want a new dynamic test requirement."

Van's says they find the 54 knots calibrated airspeed Vs1 to be "arbitrary and too restrictive", calling it "overly restrictive". Instead, they proposed a twin-pronged approach, looking at different requirements for the aircraft themselves and the required specs for a sport pilot to fly them.

"The FAA is silent in the connection of 54 KCAS Vs1 to the limitation of what a sport pilot may fly. In this regard, we would like to see an increase in the stall for aircraft that may be flown by a sport pilot to at least a minimum of 58 KCAS as proposed by other organizations. This would allow more legacy aircraft (including many Piper training models) to be included within the legacy fleet that meet the definition of light sport. We believe that while this speed may set a useful minimum for what a sport pilot can fly, it should not limit the stall speed of a light sport aircraft. The NPRM allows expansions of a light sport aircraft that would only be available to a sport pilot, or private pilot for that matter, through endorsements."

"Therefore," Van's Adds, "we have separated the scope of what a sport pilot can fly from the definition of a light sport aircraft. We feel strongly that two stall speeds should be established, one as a limitation for sport pilot privileges, and a second limitation for a light sport aircraft."

Their proposition: Increase the maximum stall speed to 61 Vso, which they note was already deemed safe in the preamble for Primary Category years earlier. That speed is already used by foreign countries with MOSAIC standards in place, further aiding harmonization. The company has many other ideas pertaining to stalls, exception criteria, and regulation. Overall, Van's takes a realistic, grounded approach to their suggestions, keeping an eye on what is feasible in the real world of flight training and private operation. MOSAIC is largely a gift to the industry that could help to unlock a wide range of livable aircraft to the average sport pilot, and Van's is careful to safeguard that. Pilots want capability, and that often comes down to speed and capacity - and they want to leave the field of aircraft as wide as they can.

FMI: www.vansaircraft.com