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LODA Reform for Experimental, Limited, and Primary Category Aircraft Flight Training & Expansion for Ultralight Training

On June 22, 2023, the FAA released the “Public Aircraft Logging of Flight Time, Training in Certain Aircraft Holding Special Airworthiness Certificates, and Flight Instructor Privileges” Notice of Proposed Rulemaking (NPRM). This NPRM formally restores flight training in experimental, limited, and primary category aircraft without any further FAA authorization when the use of the aircraft is not being offered for hire to a third party as part of the instruction.

Under the proposed rule, Letters of Deviation Authority (LODAs) would continue to permit certain types of training where the aircraft is offered for hire. This has allowed and would continue to allow training operations to offer transition training to appropriately rated members of the flying public where the use of an experimental aircraft is compensated.

Another significant rule change proposed in the NPRM is the removal of a prohibition on experimental light-sport aircraft to be used in compensated training operations. Over the years, this restriction has severely limited the availability of suitable aircraft for ultralight training. With an appropriate LODA, these aircraft would once again be legal for training prospective ultralight pilots. This is a long-awaited change first proposed in 2018 in an NPRM that was later withdrawn and combined with this new rulemaking initiative.

The NPRM, like most rulemaking documents, is complex. EAA is reviewing the document in detail and will provide appropriate comments. The comment period will end August 22, 2023.

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