It will be interesting to see how this all pans out. I'm trying to be optimistic, but after seeing how the Part 23 rewrite fell out and comparing it to the Part 23 Reorganization ARC report, and seeing how the rewrite is failing even by the FAA's own metric of "number of new designs certified"... I don't want to get too excited.
It should be noted that from the FAA's own statements in the Federal Register, this was what they pictured most LSA's looking like:
FAA said:
As stated in the proposal, the FAA intended to limit the definition of light-sport aircraft to primarily address the population of ultralight-like aircraft that are being operated under exemptions to part 103 to conduct flight training.
FAA said:
Most light-sport aircraft do not have transponders or the capability to conduct radio communications, reducing their ability to coordinate their operations with ATC and be easily identified to ensure collision avoidance.
FAA said:
Also, in establishing the light-sport aircraft, FAA did not intend to promote existing certificated aircraft. When the FAA initially set the proposed limits for the light-sport aircraft definition, the FAA did not look at currently built aircraft, either with type certificate approval or in the amateur-built aircraft marketplace. The FAA's proposed definition was to address aircraft to be designed and built for the sport pilot, rather than addressing existing aircraft for currently certificated pilots.
They truly, honestly expected that the vast majority of LSA's would be simple, no-electrical-system, open-frame or tube-and-rag ultralight-looking aircraft used primarily for training people to fly ultralights or conduct that kind of flying. They really believed that existing certified aircraft, or new-build airplanes at the top of the performance limits that were equipped with full glass cockpits etc., would be rare exceptions rather than the norm, and they expected that most people operating under LSA rules would be specifically licensed as Sport Pilots, rather than Private Pilot or higher.
Of course, as everyone else other than the FAA knew right from the beginning, LSA was just going to be a way to fly "real" airplanes without a medical.
My guess from the outside is that someone in the FAA is finally realizing that the full-blown certification and conformity requirements--not really the design standards (Part 23, or the equivalent industry standards for LSAs and Part 23 means of compliance), but rather Part 21 and parts of Part 43--are overkill for light aircraft.
All that said, my (maybe optimistic?) prediction based on what I've seen so far:
- An additional Light Sport category will be created (I'll call it LSA/H, for "heavy"), covering aircraft beyond those currently allowed as LSAs. I expect a weight limit somewhere between 1650 to 3000 lb, single non-turbine propeller (thus allowing electric aircraft), fixed gear (except amphibians), unpressurized, four seats. Perhaps a max level speed of 200kt or so, but quite possibly lower.
- Existing certified aircraft meeting this requirement will be allowed to irreversibly convert from a standard airworthiness certificate to E-LSA/H category, possibly through a time-limited amnesty program. Through this conversion, LSA maintenance rules will apply and owners will be able to obtain a repairman certificate for their aircraft after taking the appropriate courses. The aircraft will then be limited to LSA operating rules (i.e. no commercial operations except flight training).
- New aircraft meeting that performance category can be "self-certified" as S-LSA/Hs (using Part 23 and/or the current industry consensus standards instead of the current ASTM light sport standards) and produced under the same rules, rather than through the traditional certification path.
- IA E-LSA/H category for homebuilts will be created just like the existing E-LSA cagetory that lots of RV-12s are built under. Thus, one could build an RV-14 exactly to plans, lets say, and get the short flyoff time etc.
- Operating under LSA/H will be similar to existing LSAs--day VFR, 10,000ft, no commercial use. Pilot qualification will be something like "Private Pilot or higher, or Light Sport (heavy) Pilot" where the qualifications for the latter are essentially the same as Private Pilot, except for the night flying time. Driver's license medical will apply to LSA/H.
Why do I think this? Consider:
- The E-AB and LSA safety records are decent and improving, and are not indicative of systemic fundamental flaws in design, maintenance, or operation. (Keep this up y'all!)
- Self-certification of LSAs to consensus standards has not led to glaringly unsafe designs.
- FAA brass finally realize (see Mr. Dye showing them his airplane at Oshkosh, for example) that safety-beneficial equipment and technology is widely available at much cheaper prices on the non-certified market.
- Sport pilot operation on a drivers-license medical, and recent application of BasicMed, have shown no adverse safety impact.
- Relatively few commercial operations outside of flight training are being conducted with aircraft in the above noted size/performance categories.
- The FAA is swamped just trying to handle certification of larger aircraft and helicopters, modernize ATC, and regulate commercial operations. They barely have the time, manpower, and funding to handle the few light aircraft cert projects that are rolling now.
By pursuing a path as I described in my prediction, it achieves the following:
- Alleviates the burden on certification for new, improved designs, and further reduces barriers to installation of new technology in existing aircraft, without concerns about the non-certified aircraft/equipment being used for commercial operations.
- Further relieves the burden on medical office staff for low-risk operations.
- Encourages more standardized (and thus theoretically safer) "homebuilt" aircraft, through either building exactly to plans and/or being professionally built.
- Makes maximum use of existing rules and regulations; changing limits and expanding categories is much easier than creating new regulations out of whole cloth.
- Addresses the issues of maintenance costs and potential A&P shortages in a controlled manner, again leveraging existing rules.
Edit: It also just occurred to me that, in doing what I've proposed above, the FAA pretty much implements the Primary Non-Commercial proposal from the 2013 Part 23 ARC report, except the "convert back to standard category" clause that nobody would follow anyway--and does so with a whole lot less rule-changing than it would otherwise require.