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LODA Process forp lan es, Powe redTrikes and

ltral ig hts Exp lained

Obtaining training in gyroplanes, weight shift control tril

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But the real crunch came inJanuary 20.10 when all of thetransitionecl Experimental Light Sport Aircraft uainers couldno longer be used for flight instruction' That was a regulatorybuilt-in date that the FAA, flight instructors, and the alphabetorganizations were well aware of, In fact in 2009, the EAA andUSUA were both pointing out to the FAA that a problem wason the horizon and that the FAA would have to get to workon providing acceptable LODA guidance to their inspectors inorder to avert a wholesale loss of practicing flight instructors'And late in 2009, a solution was due to be published' Therewere assurances that there would be a proper pathway for lightsport instructors to continue to instruct' Unfortunately' some-oneorsomeofficewithintheFAAworkedtosabotagetlrenewguidance and it was never published in a form that was useful'Finally, in 2011, we have the guidance that was promised inZOOS. fhe intervening time has been destructive and manyinstructors have sold their equipment in the meantime' That isan important point since the FAA requires in this guidance tl'ratinstructors foi sport pilot training can only use equipment thatthey owned in 2010 when the FAA had already ruined chancesfor a smooth transition.

Nevertheless, we now have LODA guidance that is viable focertain sorts of fligl'rt training. It partially undoes the damagecaused by the FAAs failure in 2009' What we will do now iswalk through critical points in the guidance so that you canboth understand it and be able to apply for a LODA yourself iyou are a flight instructor.Overview

The complete LODA guidance can be accessed on theinternet. It is part of the Flight Standards lnformation System(FSIMS) and the current one as of this writing includes Changiss. (No kidding) We are concerned with Volume 3, Chapter11,,,tJse 0f Aircraft lssued Experin'rentsl Airworthiness Certif;catesFlight lnstruction For Compensation 0r Hire".It includes three main ParagraPhs:3-291 Background

3-292 Flight Tiaining In Experi mental Aircraft3-293 lssuance of a LODA for the Purpose of Conducting

Flight Training Under S91.319(h)We have already covered a lot of the background material'but of course there is more in 3-291 . Where we are going tostart is with the second paragraph, 3-291' Here it is:

3-292FLIGHTTRAININGINEXPERIMENTALAIRCRAFT.A. Use of Experimental Aircraft for Flight Training. Persons may receive, andprovide compensatiori for, flight training in an aircraft holding an experimental certificate issuedfor any of the purposes speciied in $ z t-. t o t . other than the person receiving flight training, theop.ruiion -.rrt not involve the carriage of persons or property for compensation or hire or be

piohibited by the aircraft's operating limitations'B. Flight lnstructors. Flight instructors may receive compensation for providing flight

training in an Jxperimental aircrafl,but may not receive compensation for the use of the aircraftin whiJh they pr-ovide that flight training unless in accordance with a LODA issued under$ 91.3 19(h) and as described in paragr aph 3-293. An experimental aircraft owner may not rent an.*p.rm#al LSA to a person for the pulpose of conducting solo flight'

C. Experimental Aircraft Owners. Owners of experimental aircraft may receive, and -provide compensation for, flight training received in their aircraft. An owner of an experimentalaircraftmay not receive comiensation fir the use of their aircraft to provide flight trainingexcept in accordance with u iooe issued under $ 91.3 19(h) and described in paragraph 3-293 'An owner of an experimental LSA may not lent the experimental LSA to a person for thepurpose of conducting solo flights'

D. Flight in Experimental Aircraft. The FAA does not require flight instructors, pilotexaminers, and aviation safety inspectors (ASD to fly in experimental airctaft' The decisionwhether or not to provide night training oi conduct a check in an experimental aircraft is left tothe discretion and judgment of the individual'

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lmportance of 3-292It is important to review 3-292 before )'ou get too far intoLODA process because your training operation may not re-a LODA in the first place. Here's rvhl'.

3-292lays out some basic guidelines about training in exper-aircraft. Paragraph A confirms that people may receiveprovide compensation for flight training in an experimen-

aircraft. It does not limit the ownership of the aircraft tostudent as some people assume.

Paragraph B confirms that flight instructors may receivefor flight training in an experimental aircraft.big limitation in Paragraph B is that it also confirms that anaircraft may not be compensated for unless the

is working with a LODA. That simply means that younot charge for the aircraft unless you are operating under aI(eep in mind that even under a LODA, an instructor can

rent an aircraft for a student's solo flight. However, if yourpolicy is to provide the aircraft for free for both flightand solo requirements, then it would appear that it isthis policy with or without a LODA.

If this is a way you would like to go as an instructor, consis-is going to be your best policy. The way it would work

that whatever you charge for flight training, the aircraft isPeriod. That means that you should not offer 'discounts'

a separate training rate for students providing their ownOr if you have a standard category or an SLSA as well

an experimental aircraft, your pricing for training shouldconsistent with both. That means all of your aircraft are pro-

free for training and solo work. That can make thisvery unattractive for many flight instructors. At thetime it could be just the thing for a one-instructor opera-

tion, which most sport operations are. But you should discussthe method with an aviation attorney before you plrt it intopractice since it is not a common approach to the issue.

Paragraph C focuses on experimental aircraft owners, It saysthat if you own your own experimental aircraft, you can paysomeone to provide you with flight instruction in your aircraft.It also says that an aircraft owner can't rent their aircraft outfor flight training unless it is done under the auspices of aLODA. Even then, tl're aircraft can't be rented for solo flight.

Paragraph Djust says that no one can require an instruc-tor to instruct in a particular experimental aircraft. This is animportant safety (and common sense) point.Procedures for Getting a LODA3-293 lays out the specific guidance for getting a LODA. The

section is geared towards Flight Standards Service (AFS) fieldinspectors, the men and women you find staffing your local,neighborhood Flight Standards District Office (FSDO).

The guidance tells the field inspectors what kind of trainingoperations can get LODAs, what a LODA application shouldinclude, what the limitations should be on a specific LODA andfinally, what kind of standardized system the inspector shoulduse to issue the LODA. A lot of the information in that guid-ance is very useful to a flight instructor actually applying for aLODA. It makes sense that if you know what the inspector islooking for, then you can make sure it is part of your applica-tion package.

The procedures aren't just for sport aviation. In fact LODAsare very important for much of the warbird, high performance,and other kinds of experimental aircaft. But for our purposes,we're going to try to focus on what matters most in the avia-tion world, our l

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Who Gan Get a LODA and forWhat?il;;to."ce spends a lot of time explaining to Aviationt"f"it i*o"..rs (ASls) what LoDAs can be issued for' Thatmakes sone of the guidanle particutarly contorted' especially*ll"r" ,Por, aviation is concerned'""'i'nt"".t'"aining' The FAA doesn't want to. pernit flight,.ui,'ti-ng ,"hu, leads "towsrd the issuance of a pilot certificate'rating, or operatirtg p'iuitr:S:l."' That means any training towardsanything as simple u' u tlil*ll""I endorsement or training to-wards a powered parachute license' Fortunately this version ofthe orcler does proviclJ i;; t;*" exceptions.' Earlier versions ofthe LODA order left ttrings rigttt there and that made the LODAvirtually useless for sport aviation'

Wtrat t-OOAs Gan Be lssued For:Fliqht training lor the operation ol aspicitic maki and model ol exPeri-mental aitcralt.

Training lor the opetation ol ultralightvehicles.

Or-re exception for primary training allows, for gyroplane,ru"ining ui u,'ty ancl ail levels' which means that the LOD] 1?::. gr".,':"f, oimeeting the needs of the gyroplane communrty'The other exception is training towards a sport pilot certificateor operating privilege' But as lou will see s^oon' the guidance i;;;;;;;V ;t'clea. ir helpful ior the rest of the sport aviation;;t"t*tt*t The table bel'ow gives details o1*" sport aviationil;;;;;;h" FAA allows LoDAs to be issued for'ThetableshowsseveraldifferentpurposesforaLODAthatapply to nany sport uuitiion instructors ar-rd it is recommend-ecl that cFls request each one ofthese purposes that apply toan instructor', purtitutu,. op"'utio'-'' Eaih of the purposes stan.i",t", *fttat means if an instructor doesn't qualify for one pupose, it does not nrean that l-re or she doesn't qualify for onemore other PulPoses'

Traininq lor a llighileview in a spe-iiri, *itt and model ol expstimentalaircralt.fraining tor a rotorcralt gyroplane tat-ing or ceililicate.Tiaining lot a Sport Pilot Certilicate oropetating Privilege'

Other specilic training approved byttt -Ottittaf Aviation and CommercialDivision, AFS-800.

ExPlanationThis is a big purpsse lor LSDAs. tt i company sells an aircrait kit lo i customer' it is good l0r the custgmro oet some rransirion ,ruinini in'ir,uiroi.i ir rirrtutlh;l;ii;iitt is that the.student alreadv has to berarid lor that category or uirl",uit. io, example, ir to*.on. uuvt uliitt tno is alteady an airplane singleenqine land pilor, rhey .un,igri'ihri, tiile tiansition tttititiiiiirtlt'ii p"pott' Althoush limited' nearlv#Hffiiin;;lip*iirrnui ui*uft ,un apply tor a L0DA with this purpose.This has recently been added to tne tisi ot puiposes..This works lor the same kind

ol aircralt that used toooerale under rhe uftarigniexempiion, io i,,*il. ,ft;iig'hii;ilils' ine pitot still needs to be a GFI olcburse and rhe onty ui,r,ulinui'r'r n, opiiut.o unoei'iilit ioon pltpotd are the low'mass' high'dtagaircratt with an empty *rigni';r, thin soo pounos uto . ttiittit spee! in level lliqht with maximumconrinuous power (vH) rrr'Jr# B;'K;oir cliinia.o nitip..i ixCnsj (too mp6') The purpose is notcateqory specilic ,o ui'pfuntt' p**O parachutel and ttikes may all apply'

, This is ctosety related to the lirsi purpoi, lisl;d. ff a.pilot purchises a Quicksilver airplane andgets com

, tortable flying il, tnar pirorwourd i-iiliirl| pirrrr g.ttid tiltitliiqht 'enie* in that same kind ol airylaneThis purpose anows cFrs ilffi1;;i'lltitiliil tffi '"* ui"'itt t'1.:1t':: lrrhe aircraft'llvouareagyroplaneinstructor,thisdoesnearlyeverythingyouwantittod-o..foucanprovideprimarytriininq t01 srudent pitob il;;;';;iiirirut. irurr urd ;it;;;; itilhe use ol vour svroplane' lt still does nallow you to renr your gyrrpdlii i ituoenr so ilra1 tnry tun meet their solo requirements'

, The FAA made this one contusing. cil,r rin f*uirle training towards the i::!ay ol a sport Pilot certi care 0r LSA operating prii'i'r'ege,'bui unine nir om.t p*potltloiiioon' the air$aft has to meet a loni list ol conditions. TheY rel, . The airfiait has to have been issued an experimenlal certilicate under s21'191{ixl)' That means, onlv ultralight tt.inti*inuiitu*itioneO to btsl trom belore 2008'. There can't be an ELSA 0r standard categ0ry airfialt available lor the conduct ol this training in tI ;iili iianuaru Dislricl0llice's tFS00) seosmphic area', . The aircralt used to prouide the training mu{_have been owned by the person providing ihe tminiprior to January er,loro and that p.oon rurinru. n*n ipptopriateiy certilicated ot otherwiseauihorized ro p'ou'i' tnut training prior to January 31 ' 201 0', . L00As lor persons conducting this training.will have a maximum duration ol 24 months and will, timited m he geograptric atei o{ the FSDO's responsibility'. FSD0s may terminate a L0DA tor sport pilot trainins at its discretion'

:, You justhave to wonder at how nuch the FAAseem$ f0 dlstike spgrt pila"!:*''!'rnii is the catch-att category. ll a cFl's trainins 10.:: not lit rhe f urf oses.anwe' the cFl can ask AFSto authorize a specitic t-oiin tor the training operation'"s'eioi, gyioilunt instructors were

specilicallyii.riiiJi. die botictt, that is how thev received theit L0DAs'

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for a LODAPutting together a LODA application package does not havebe that involved, but it does have to contain some critical

Primarily, the ASI is going to be looking for the docu-that shows that the CFI has the tools to provide theinstructor is requesting a LODA for.An applicant should be ready to provide the following:. Deviation Request Letter. Tiaining Course Outline. Copies of the following documents for the aircraft to be

used for training:. Registration Certificate. Airworthiness Certificate. Operating Limitations. Copies of Instructor Certificate and applicable sport pilotlogbook endorsementsThe FSDO review of the training program(s) will be looking. A description of each type of audiovisual aid, mockup,chart, aircraft component, and other special training aids

used in any associated ground training (if applicable). A description ofany special equipment used for eachphase oftraining. The qualifications and ratings for each instructor providingflight training or ground training. Of course flight instruc-tors must hold a flight instructor certificate appropriate tothe flight training to be conducted or be otherwise autho-rized to conduct flight training in the specific aircraft.. A training outline that includes the following information:. The prerequisites for persons receiving ground andflight training, to include minimum pilot certifi-

cate, ratings, endorsements (for example, tailwheel)training, experience, and knowledge requirements.Normally for ultralight training, gyroplane training orsport pilot training, the answer is 'None.". A description of each unit of instruction, including theobjectives, standards, and planned time for comple-tion. The expected accomplishments and the standards foreach stage oftraining.. Ifthe application package and training program are ac-

ceptable, the FSDO will review the experimental aircraft'soperating limitations to ensure that the proposed trainingwill not be contrary to any limitation other than those forwhich relief is granted under the LODA. An applicant mayalso request that the operating limitations for the aircraftintended to be used for flight training be amended toconform to the relief provided by the LODA.. Aircraft not inspected in accordance with an FAA-approvedinspection program must have an operating limitationrequiring a condition inspection within the preceding 100hours of time in service.

LESSON OBJECTIVEThe student will learn to control lor wind drift.COMPLETION STANDARDSThe sludent will demonstrate the ability to consistently control for wind drift in a safeand effective manner within a specified limit ol heading, altitude, and airspeed.SCHEDULE {Ll Prellight Discussion :15{ lnstructor Demonstrations :15Ll Student Practice :45$ Postflight Critique :15CONTENTPreflight Discussion:

Lesson objective and completion standardsNormal checklist proceduresWeather analysisHeadingSpeedAngle of bankAltitudeTerrainWind direction plus velocity

* Aerodynamics Demonstrationi. Turns around a pointii. S-turns across a road

6 Critique student performance, preview next lesson, andgive study assignment

Example ol a traditional training lesson plan lrom the FAAsAviation lnstructor's Handbook with additional inlormationrequired lor a L0DA application

If you are a USUA member and would like assistance in put-ting together a LODA package, please contact the USUA officeat (717) 339-0200. People have successfully applied for LODAsand if you would like to provide the critical service of flighttraining, we want to help you succeed.

Many thanks to Greg Gremminger, who has worked forLODAs for the gyroplane community, and to David Oord of theEAA for working on the ELSA and ultralight LODA issues. lt isclear that without their help and assistance we would not havethe LODA order we have today.

Also thanl