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FAA Ready to Issue Flight Training LODAS for Experimentals

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 govt@eaa.org.

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.

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