Tuesday, August 3, 2010

Light Sport Aircraft category potentially hinders pilot starts

An Editorial by James Wiebe, CEO, Belite Aircraft

© 2010 by James Wiebe, all rights reserved.  Linkage to this website is acceptable.  Republication, except for short citation, is not.

I want to examine how the attention which has been given to Light Sport Aircraft over the last 6 years has potentially hindered the grass roots of aviation, by cutting off the low end of pilot instruction and flying.

My reasoning is simple.  Light Sport Aircraft, created by the FAA in 2004, has created a segment of aircraft, generally priced over $100K, which are expensive to own.  This has displaced another segment of aviation, which used to be known as ‘ultralights’, which were far less expensive to operate and experience aviation in.

Let’s start this discussion by considering the number of pilots in the country.

There is no argument that there used to be more pilots:  everyone knows that the head count of pilots, over the last few years, has been in a general state of malaise.  Consider the following statistics, which are taken from the FAA’s research:

CATEGORY    2008    2007    2006    2005    2004    2003    2002    2001    2000    1999   Pilot--Total    613,746    590,349    597,109    609,737    618,633    625,011    631,762    612,274    625,581    635,472

                            Source:  www.faa.gov/data_research/aviation_data_statistics/civil.../08-air1.xls

The undeniable nugget of information is that pilot head count was higher 10 years ago.  When the economic effects of the 2009 mini-depression are factored in, it would be surprising if the number had moved in a positive direction in 2009, or, for that matter, in 2010.

There are three interesting trends which must be considered against the pilot trends of the last 10 years:

1)    General Aviation aircraft production was revitalized – this started in 1996, and continued strongly through the last decade.
2)    Light Sport Aircraft, as a category, was authenticated, and began affecting aircraft sales in 2004. 
3)    Ultralight Aircraft traditionally had extended into the weight and operating capabilities of what are now Light Sport Aircraft.  Their capabilities were hindered by the LSA ruling of 2004.

Let’s consider each of these 3 trends in turn.

General Aviation Revitalization

I have personally enjoyed the benefits of GA revitalization, having flown a 2003 T206H built by Cessna for a period of years.  While it was a direct benefit to my computer business, I believe these new Cessnas have had little impact on new pilot starts.  The reasoning is simple economics.  Cessna’s top singles at the time (the Skylane 182 and the Stationair 206, which I flew) are extremely expensive for individuals to own, fly, or rent.  My calculated operating expenses per hour were somewhere in the neighborhood of $200 for my T206H, as I recall.  The Skylane would not have been far behind.

This leaves the 172, and it is arguably one of the most popular trainers in flight school fleets today.   Long before I bought a T206H, I had been a partial owner of a 172, and I have no argument as to is benefits to individuals and small businesses.   But let’s consider the economics:  a 172 for training rental in the Wichita area ranges from $90 to $140 wet, and as a result, a private ticket costs around $8000 and up.

I will not belabor the impact of these planes on general aviation:  if you cut me, I bleed Cessna.  (And I realize that other aviation enthusiast have different colored blood.  Some bleed Piper… or Beechcraft.  All good brands, and there are many more.)  I love the Cessna product line.  I just don’t think Cessna’s product line has provided an increase in pilot starts over the last 10 years.

So let’s consider the second trend.

Light Sport Aircraft

The LSA category was supposed to save the bottom end of aviation, entice increased pilot starts, and be an all around panacea for general aviation.  Here’s the premise:

“In 2004, the aviation industry, EAA, other associations, and the FAA produced new regulations to promote aviation activity, creating a new pilot certification called "sport pilot" and a new aircraft category called "light sport aircraft" or LSA.  Sport pilot training, thanks to a combination of compressed training requirements and restrictions compared to traditional certified pilot, plus cheaper training aircraft, can be accomplished at nearly half the cost of a traditional pilot's license.  Light sport aircraft operating costs will probably end up about half the cost of the least expensive production non-LSA aircraft as well.  This allows pilots to exercise their privileges quicker, and more often, than those operating non-LSA aircraft.  This will enhance safety (builds experience) and allow pilots to afford higher ratings and certifications.”

                                  Source:  http://waltl.spaces.live.com/blog/cns!BCA7C2445E36861F!1056.entry

Undeniably, it has produced a vital submarket within general aviation, and around 1,800 LSA aircraft have been registered through April, 2010.
                            Source:  http://www.bydanjohnson.com/Sidebar.cfm?Article_ID=1274

These aircraft come with significant price tags:  the average aircraft cost within the category is probably well over $100,000.   (The CTLS, which is the top selling US LSA aircraft, starts at about $120K).

Cessna, my favorite aircraft company, is now (barely) delivering Skycatchers at around $110K.  They are already available for rental in the Wichita area for $98, wet.  A private ticket in the Skycatcher will cost around $6500, if you scoot through the program.  A light sport ticket will be less, if you are unrealistically proficient.

That’s neither cheap, nor free.  In fact, it’s expensive.  (My ticket, earned in 1978, cost me about $800.)

The LSA rulings had some side effects.  One was the elimination of ‘fat ultralights’, which had operated for around 20 or 25 years, with minimal oversight from the FAA.  Some of the ‘fat ultralight’ owner/pilots were offered the opportunity to license their aircraft as Experimental Light Sport Aircraft. 

“There has been a lot of talk about this one-time ELSA conversion.  It really hits a hot button for ultralight flyers that have enjoyed extremely light regulation for a quarter of a century.  And it puts them in a bind, despite the relative ease provided under the conversion.  The certification process for other experimental aircraft involves an extensive paper trail that includes proof of construction, inspection during construction, prior owners, airframe modifications, kit factory bill of sale, and similar things.  I understand that the paperwork for the ELSA conversion is minimal, and the inspection is very basic.  The bind is this: if they are ultralight pilots they won't be able to legally fly their aircraft after January 31.  Even if they are willing to get a Sport Pilot license, it may take months.  Since there aren't many Sport Pilot instructors or schools yet, it may not even be practical to get the license without significant travel, time away from a job, or other extraordinary expense.  It's no wonder so many ultralight pilot aircraft owners are in denial about the whole thing.”
                      Source: http://waltl.spaces.live.com/blog/cns!BCA7C2445E36861F!1056.entry

And so, in hindsight, the LSA rulings gave us a new aircraft category, which has produced around 1,800 new airplanes.

And with the same legislation, it outlawed thousands of aircraft that were being used for pleasure or for a low level of flight instruction. 

Was this a fair exchange?  For the low end aspiring pilot, definitely not.

Ultralight Aircraft

An ultralight aircraft operates under Part 103 of the Federal Aviation Regulations.  This segment, given up for dead by most, was nearly killed by the LSA legislation of 6 years ago.  Now, thanks to efforts of Belite Aircraft and other companies, it is turning around.

It used to be more – far more. 

All of the instructors who used to instruct in ultralights were forced to move up to Light Sport Instruction.  Here's some of the rules which offered a path for ultralight instructors to move up:

If you are registered as an Ultralight Basic Flight Instructor with an FAA-recognized ultralight registration program before September 1, 2004:

• Applicant must be at least 18 years of age.
•Must be able to read and speak the English language.
• Applicant must meet medical eligibility: Either a third-class medical or current and valid U.S. driver's license.
• Sport Pilot certificate or higher.
• CFI or CFI-SP recommendation.
•Successful completion of FAA-administered Fundamentals Of Instructing (FOI) written test.
• Successful completion of Sport Pilot CFI Knowledge and Practical tests.
Flight experience requirements are waived for BFIs registered with an FAA-recognized ultralight registration program before September 1, 2004. An ultralight instructor must transition to sport pilot instructor by January 31, 2008 if he or she wants credit for his or her ultralight flight time.
                       Source: http://www.ultralightflying.com/qanda.html

In simple terms, this meant that ultralight instruction and experience was no longer available, replaced by sport pilot instruction, at a higher economic rate.

The economic effects of this were noted by the USUA, in a barely noted plea, from earlier this year:

The United States Ultralight Association (USUA) is concerned that industry safety is at risk because the FAA is not allowing a way for their own CFI's to train in experimental light sport aircraft (E-LSA's). On January 31st, 2010, the "final" deadline for transition to the Sport Pilot/Light Sport Aircraft rules passed. Until then, flight instructors were able to provide students primary training using E-LSA equipment. With the passing of the deadline, many CFI's will be forced out of the training business since it will not be financially viable for them to purchase newer S-LSA aircraft as is currently being demanded by the FAA. The resulting loss of practicing instructors will reduce opportunities for those wanting to learn to fly light sport aircraft as well as ultralight aircraft
                  Source:  http://www.usua.org/

And so now, hopefully, I have made my point.


a) General Aviation revitalization has helped aircraft companies and business GA interests, but has not generally benefitted the average person seeking a pilot experience.

b) Light Sport Aircraft has produced a new category of aircraft, with a substantial economic impact.  The resulting product is priced out of the range of most individuals, whether for ownership or rental.  This category of aircraft is now used for personal flying (for which it is excellent) but does not provide a cost effective path for expansion of aircraft instruction.

c) Old ultralight aircraft were once capable of providing low cost introductory aviation experiences, training, and rental, but have been eliminated by FAA decree.  Modern ultralight aircraft (such as www.beliteaircraft.com) are bringing back the grass roots aviation experience for single pilot operation, but the ability to introduce individuals to aviation as been neutered by the LSA legislation.  As a result, the ability of the industry to attract new pilots, who would eventually step up to more ‘serious’ aircraft, has been hindered.

As my Blog says, I believe in flight.  I hope to help others achieve their flight as well.

I told my wife what I was writing my Blog post on today.  She reacted with some surprise -- and then we concluded that some people would agree with me.  What do you think?


Harold Bickford said...

I'd agree with your perspective on the LSA situation as it relates to new aircraft. The cost aspect is simply higher in real terms than in years past.

For my purposes it simplifies the process as regards a homebuilt design such as a Pietenpol.

FAR 103 is an area I've been looking at for some time as a means of being able to fly at least cost.

At the least potential for flying activity is increased with LSA and FAR 103. Beyond that folks need to act on the opportunity.


woody said...

Interesting that the planes you promote the most are not ultralight by your own definition.
I think that reveals the state of the market.

Wm. Bernan said...

I was looking forward to Sport Pilot when it was a proposed rule...I was under the impression that it would promote flying an ultralight-like aircraft for more than an hour or two (some utility), and bring a friend along without the expence and medical hassles of a PPL. To an extent it did - but then those planes mostly went away. The industry somehow perverted that. Something along the lines of a Flighstar II SC should be the icon of Light Sport...not the CT LS. We need a new Poster Child.

Spoken by a newcomer having just completed my first few lessons in a J3 pursuing my Sport Pilot Cert.

James W: I love what you are doing with Ultralights. I would also look forward to a double wide BeLite...not a Kitfox...perhaps something closer to the J6 Karatoo...straight tubes and easy maintenance...if you ever jump into the LSA arena...but cheap. Even the X-Air LS at 60K is twice a much as it should be.

Good Blogging. Good catching you on message boards as well. Keep up the good work.

Larry said...

James W: I’ve been following your blog for quite some time now. I really appreciate all the work you are doing for the light spectrum of sport aviation.

I am a strong believer in the idea behind Light Sport Aircraft. I fly a modified Kitfox Lite that I registered ELSA back during the one-time conversion period. I have a private pilot license; though I choose to exercise my privileges under Sport Pilot rules by virtue of not keeping a current medical (out of choice). I took the 16 hour ELSA repairman class that allows me to do the annual condition inspection. My goal is to keep the act of flying as simple as possible. In the past I have owned certificated aircraft. I am a working person of considerable means, but frankly I found the whole system surrounding private ownership of a certificated aircraft to be unworkable for me.

In the area I live, many of the “fat ultralight” operators did choose to take advantage of the conversion period to convert to ELSA and have are actively flying today. There were some who did not take the steps to do so and it’s common to see their aircraft languishing in decay. If I had to generalize I’d say that many of those who did not transition their craft to ELSA were less active as pilots and usually were advancing in years.

Around here I have observed a steady and marked decline in the interest in a once vibrant part 103 aviation scene for at least the last two decades. This occurred long before any possible quelling affects of increased regulation fallout from the new Light Sport Aircraft category. And for me most tellingly, I have never seen a young person even come near a part 103 ultralight. I just don’t see the future of grass roots aviation being much affected by ultalight aviation. This is just an opinion.

I remained excited over the potential and the promise offered by the new Light Sport Aircraft category. It is there I believe opportunity exists to create an environment that can produce the new younger pilots we need. However the reality of the present development of the state of light aviation also disappoints me constantly. The market place response to all of these rules changes has brought forth a bewildering cornucopia of new light sport aircraft models. Though not one of them would I consider purchasing. Having 100+ manufactures each producing a very low volume of aircraft priced at over $100,000 does not in my mind meet the needs of grass roots aviation. They all cost far too much and have features that are not needed for either typical sport flying or the training required to prepare pilots for light sport flying.

What do I think a possible successful light sport aircraft would look like? Think two place tandem or side by side seat reminiscent of early Piper Cub or Taylorcraft being built using the modern means and methods that James W at Belite is advancing so effectively. They should be certified as SLSA which allows for many ownership and operating situations. This then allows a subsequent option to private owners to optionally convert registration to ELSA as current regulations allow for more and better maintenance options. I believe such craft should have the minimum creature comforts and eschew unnecessary avionics or instrumentation to keep costs down. I believe that honest simple aircraft as described would do much to realize the promise of revitalizing light sport aviation. Thanks for the privilege to comment here. – Larry Jackson