Flying and owning an OK-registered ultralight with Polish PPL(A) licence

LSA are not ultralights, they are LSA according to EASA regulations. LSA can only be flown on at least LAPL. Ultralights are not EASA at all, but national registered according to national regulations. They could or could not be flown with just a LAPL/PPL depending on the country. Having a foreign registered ultralight in another country sounds like lots of nuisance, and will in most cases not be possible on a permanent basis.

On ultralights you usually do all the maintenance yourself. But, you have to check the national regulations. Ultralights are max 2 seat and max 600 kg MTOW. If you need more, you have to go to EASA or experimental/homebuilt.

At LFFK the gliding club now has a WT9 Dynamic as a glider tow. It is a ULM as it is registered with the DGAC as having a maximum take off weight of 525kg (it has a parachute.)
The advantages of this is that the club can do it’s own maintenance and can be flown on a ULM licence with self declared medical. Hours flown can be recorded towards a PPL by experience revalidation. It can be used for ULM pilot licence training but not for PPL or LAPL training.
Our club might well soon be getting a WT9 Dynamic which will be registered as LSA.
This means it will have a MTOW of 600kg(?) and can be used for PPL and LAPL training. But maintenance has to be carried out by at least a Part66 engineer and all other EASA requirements followed.
This aircraft will also be EFIS and a VP prop so difference training will have to be carried out before the PPL can fly it, solo.
If the glider clubs WT9 had EFIS and VP they would not need to undergo difference training, except for their own peace of mind of course.
However, as Le Sving wrote this is very much country dependent where the ULM is concerned but is EASA european wide where the LSA is concerned.
They are 2 different regimes.

No, it’s not that simple. An LSA must be designed and built according to CS-LSA. An UL that looks identical (and actually is identical for what it’s worth) is usually designed and built according to UL design standards. An UL can in general not be re-registered as an LSA and vice versa. It’s definitely not up to you to decide In general, if it’s an UL, it will always be an UL and if it’s a LSA it will always be an LSA.

There are exception to this, but you will usually never get a factory approval for any of that, and since these are factory built aircraft, you will have a very hard time registering it as anything without factory approval. You then have to go to some experimental register, which means saying goodbye to factory specs. Either experimental normal plane or experimental UL, but then we are heading into even “more national” regulations than the national UL regulations.

In the case of the Dynamic, the Bristell the CT and many other they are factory produced and can meet ULM regs maybe by simply taking out the carpets and can be registered as such.
But these aircraft are also certified under EASA CS23. As such they are registered as LSA’s and with that they get the carpets back because they have increased MTOW. It is in fact the same aircraft with the same engine.
These aircraft were always built for the LSA market and then slightly altered to suit ULM regs. But having flown both Dynamics there is scarcely any difference at all. Except that I can rent the ULM for around €100 an hour whereas the LSA is €145 ph.
I can of course reflect on the situation here in France.

gallois wrote:

In the case of the Dynamic, the Bristell the CT and many other they are factory produced and can meet ULM regs maybe by simply taking out the carpets and can be registered as such.

Practicalities and realities are two different things here. I have been in contact with several manufacturers about the recent 600 kg MTOW (recent in Norway, a few years back in Germany/Cz) trying to get existing 450 MTOW planes up to potentially 600 kg. The main problem with this, is not the aircraft, but factory approved documentation. It’s dead easy if the aircraft (your serial number aircraft) already is “certified” according to several standards, and they have been issued for your serial number when new. This was the case with the Savannah, but if it’s not, it’s literally impossible.

When you buy an UL, the design specs are according to UL specs. This means the POH and every other documentation and “certification documents” are UL specs. A LSA aircraft is of course according to CS-LSA.

Now, as you say, the actual difference may generally speaking only be different colors of the carpets. However, a factory built aircraft, is not just the aircraft. It is the aircraft + documentation and certification according to some standard. Neither CS-LSA or UL (any kind of UL standards, there are many) are certified standard, and the same aircraft could also be certified according to CS-23. All three aircraft may literally be identical. This means nothing wrt the factory though. The factory will not approve any changes on the documentation for a particular aircraft. For you to register the aircraft as UL, LSA or CS-23, you will need the appropriate documentation/certification regardless. When the factory is not willing to “pick and chose” for your existing aircraft, where are you going to get the documentation needed to register it?

I guess you could in theory send it back to the factory and let them “re-build” it with new documentation, but so far my experience is the factory simply slams the door in your face. It’s not something they do. The only other option is some sort of experimental registration. The UL regulation in one particular country may already be “some sort of experimental registration”. Then there’s no particular rules against modifying the aircraft. However CS-LSA and CS-23 is definitely not, and taking a LSA or a certified aircraft and “de-certify” it on your own, is not something you can just do.

Then again, national regulations are different from country to country. Perhaps the “competent authority” in your particular country have no problems “de-certifying” EASA aircraft, but I don’t know which countries do that, if any at all. Going the other way is impossible without the factory approval, which you prob 100 won’t get.

The only thing that is possible (at least in Norway) is putting an UL on an experimental register, either as a normal aircraft or as an UL. Doing that also means you cut the ties with the factory. That’s the main reason to do it anyway. You want to modify it beyond anything the factory can approve as coming from them.

sharko21 wrote:

Please correct me if I am wrong – same aircraft (let’s say Viper SD4 for example) can be registered as ultralight or as LSA

What this normally means, is you can purchase the same new factory built aircraft either as UL or as LSA. It’s up to you. However, it does usually not mean that an existing aircraft can be swapped into on or the other later. You never know though. Perhaps in Poland this can be done? I highly doubt it though.

sharko21 wrote:

I know in Poland an ultralight can be flown with PPL license but not aware of the revalidation process…is it also country-specific?

It’s all in the details of each country’s regulation. The basic principle is usually that PPL/LAPL incorporates an UL license also.

sharko21 wrote:

If an aircraft is an LSA in country A (for example France) it will be also LSA in a country B (for example Germany).

Yes

sharko21 wrote:

If an aircraft is an UL in country A (for example France) it will be also UL in a country B (for example Germany)

Not necessarily. France does not accept a 600 kg MTOW UL as a “normal” UL for instance. In general yes.

sharko21 wrote:

In general LSA cannot become UL and vice-versa. But what if on certified aircraft(LSA) a constant-speed propeller and autopilot will be installed? It will become non-certified anymore…but can it become UL then or this is just not legal and it will just become non-airworthy?

You cannot in general simply modify an EASA aircraft outside the specs. If it’s an LSA makes no difference wrt EASA. An UL on the other hand.

sharko21 wrote:

LSA can be flown anywhere in the world while for UL each country has a specific regulation which should be followed (I guess here is a document which contains country-specific requirements for UL in Europe)

No. EASA LSA can only be flown in EASA-land without explicit permission.

sharko21 wrote:

LSA can be used for PPL/LAPL training while UL not. UL can be used only for country-specific ultralight license training

Yes

sharko21 wrote:

On UL maintenance should be done following local regulations. There are also no mandatory overhauls (15 years/2000h for Rotax)

Is there mandatory overhauls on EASA LSA? Don’t know. Overhauls are much cheaper on Rotax than on Lycoming anyway. This isn’t really much of an issue for most people.