I finally got to watch the whole webinar that LT (Norway CAA) had the other week, but I was prevented from attending. It’s about new regs for ULs including 600 kg limit. Lots of it I knew, but what I didn’t know was this:
ULs below 450 kg (traditional UL) will be only UL as before. ULs above 450kg, but below 650 kg can be registered in two ways:
However, if the aircraft has a EASA type certificate, it must be EASA, and can never become anything else. Conversely, if it has an FAA type certificate (but not EASA), it can be registered as UL or national SEP (A factory built Vans RV-12 would fit into that, as well as several others). National SEP means LAPL/PPL, but also means it can be used for IFR and aerobatics for instance.
I wonder do other countries have the same. A national class that you can register ULs in, but a class that is SEP (non EASA), and not UL ? My Savannah (typical UL) is 540 kg MTOW from the factory. From this summer, I can simply install whatever needed avionics, re-register it as national SEP and fly IFR 
Not that I ever will do that, but it’s a nice thought.
Conversely, if it has an FAA type certificate (but not EASA), it can be registered as UL or national SEP (A factory built Vans RV-12 would fit into that, as well as several others)
A factory built RV-12 does not have an FAA type certificate, it’s an FAA LSA.
LeSving wrote:
I wonder do other countries have the same. A national class that you can register ULs in, but a class that is SEP (non EASA), and not UL ?
Czechia has had this dual system for sub-600 kg aircraft (either CAA or Amateur Pilot Association) since 2019.
Silvaire wrote:
A factory built RV-12 does not have an FAA type certificate, it’s an FAA LSA
OK. EASA has CS-LSA which that airplane could possibly enter (CS-LSA is just slightly modded FAA LSA specs, but allow for retract, CS prop etc). AFAIK, CS-LSA is a type certificate. Not anywhere as “strict” as CS-23, more like a “dressed up” UL, but still. But, if FAA LSA is not some kind of type certificate, then what is it?
Anyway, the RV-12 was too heavy to be a UL without the 600 kg opt out. The only way to get one was as homebuilt experimental. Now it can be imported factory built and be registered as UL or as a national registered aircraft.
Ultranomad wrote:
Czechia has had this dual system for sub-600 kg aircraft (either CAA or Amateur Pilot Association) since 2019.
Interesting. Part of the reason I’m asking is how these aircraft are supposed to be handled in Europe. We have:
Now we got these national registered sub 600 ULs. I guess they simply would be handled as any other UL? It’s that how it works in Czechia?
LeSving wrote:
AFAIK, CS-LSA is a type certificate.
Yes. EASA CS-LSA aircraft get a normal category ICAO compliant CofA.
But, if FAA LSA is not some kind of type certificate, then what is it?
An FAA LSA is not built under a Type Certificate and is therefore not an FAA certified design, and is also not built under FAA certified production. There is an FAA standard for LSA but the statement of compliance with that standard is from the manufacturer and is not guaranteed or enforced by FAA. Detailed FAA information here
FAA takes its role in light aircraft type certification and subsequent production seriously, and equally when the plane is an LSA or Experimental it is made clear to the owner that the FAA role and responsibility is very limited by regulatory design. There is little confusion.
As an aside, as mentioned indirectly by the FAA link the enhanced role of the FAA LSA manufacturer creates problems when the LSA manufacturer disappears, as they do. Unlike with an FAA certified aircraft the relationship to maintain legal airworthiness is not directly between the owner and FAA, so while there is no such thing as an ‘orphan’ certified aircraft under FAA regulations, there is for an LSA. The solution for LSA owners in this circumstance is to move the plane into E-LSA (Experimental) category which as with an FAA certified aircraft has no requirement for “continued airworthiness support by the manufacturer or other viable entity” but then because its Experimental with few restrictions on owner modification the plane cannot be used commercially.
The incoming MOSAIC regulation will much increase the size, weight and performance of what have until now been factory built FAA LSA aircraft, along with other changes. The 1320 lb (600 Kg) weight limit is slated to be eliminated entirely, replaced by performance limitations only. Other than entirely unregulated Part 103 ultralights there won’t be any ‘lightweight aircraft only’ (UL-type) category under FAA regulations.
LeSving wrote:
Now we got these national registered sub 600 ULs. I guess they simply would be handled as any other UL? It’s that how it works in Czechia?
If the sub-600 kg aircraft is registered with CAA, then it’s for all intents and purposes a regular ICAO aircraft, similar to Annex I ones.
Ultranomad wrote:
If the sub-600 kg aircraft is registered with CAA, then it’s for all intents and purposes a regular ICAO aircraft, similar to Annex I ones.
I wouldn’t imagine that, but I guess you are right, because they are registered as “normal” aircraft. They are not homebuilt, nor are they registered as ULs. Is that only within EASA, or world wide?
Is that only within EASA, or world wide?
Obviously the intent and purpose of FAA LSA includes FAA registration but does not include compliance with an ICAO recognized design certification standard, and this will be even less so when the 1320 lb (600 kg) gross weight limitation is removed from the category under MOSAIC.
