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Regulatory Brief
Repositionable Gear on Light Sport Aircraft
Contents:
- Summary
- The Issue
- Recommendation
- Update
Summary
Because of what the FAA has verbally characterized as an error, the Light Sport (LS) rules released in 2004 prohibit the
in-flight repositioning of landing gear on seaplanes. The effect of this error is that amphibious operations are
not permitted in LSA aircraft. Although the FAA has repeatedly promised that it intends to allow the amphibious
operation of LS designs, to date no action has been taken to formally amend the rules.
The Seaplane Pilots Association favors permitting amphibious gear on Light Sport aircraft, and has supported
industry efforts to effect a rule change. At present, Czech Aircraft Works has applied for a waiver to receive certification
of its Mermaid aircraft with amphibious landing gear. The Seaplane Pilots Association takes no position
on the Mermaid specifically, but supports Czech Aircraft Works' effort to obtain a written commitment from the FAA to permit
repositionable landing gear. It is the opinion of the Seaplane Pilots Association that the Mermaid petition will advance the
interests of everyone seeking approval of amphibious landing gear on Light Sport aircraft.
The Issue
When the FAA released the Light Sport Aircraft rules in 2004, it defined "repositionable" landing gear for seaplanes, but clearly
prohibited the repositioning of repositionable gear in flight. As a result, Light Sport rules effectively prohibit amphibious
aircraft. Following the release of the Light Sport rules, it was widely believed and communicated, even by FAA spokespersons, that
repositionable gear could be used to enable amphibious operations. The Seaplane Pilots Association, concerned that buyers and
investors could be left holding the bag if the FAA didn't recognize that the rule prohibits amphibious operations until months or
years later, questioned FAA officials, and received confirmation that the rule in fact does prohibit amphibious operations.
The FAA has since characterized the original rule language as an error, and indicated that the rule will be changed in the future.
Initially, the future was said to be the first quarter of 2005, and is now said to be "later" in 2006.
The Seaplane Pilots Association favors permitting amphibious gear on Light Sport aircraft, and has been supporting
industry efforts to effect a rule change. In 2004, the organization drafted and submitted a position/suggestions whitepaper to the
FAA proposing definitions and solutions to FAA concerns. More recently the organization commissioned a simple study of gear-down
water landing accidents, forwarding the results to the FAA.
Czech Aircraft Works recently applied for a waiver to receive certification
of it's Mermaid aircraft with amphibious landing gear. The Seaplane Pilots Association takes no position
on the Mermaid specifically, but supports Czech Aircraft Works' effort to obtain positive, binding action on the part of the
FAA towards approving amphibious gear on Light Sport Aircraft. It is the opinion of the Seaplane Pilots Association that
the Mermaid petition will help keep the pressure on the FAA to resolve the issue, and, if the petition is approved, clear the
way for other manufacturers to apply for similar waivers.
Recommendation
The Seaplane Pilots Association supports the efforts of the Light Sport industry to obtain acceptance for amphibious landing gear within the Light Sport rules. Members are encouraged to join the Seaplane Pilots Association in commenting favorably on Czech Aircraft Works' petition for S-LSA approval of their amphibious Mermaid design.
Update
The Mermaid was granted S-LSA approval shortly after the petition comment deadline by a designated inspector in Florida. The FAA
has not responded to the petition, and may not at this point since the petition is now moot.
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