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EAA’s efforts in support of amphibious aircraft operations, especially in the new area of light-sport aircraft (LSA), has led FAA to clarify its position on the use of such aircraft.

As the sport pilot rule is currently written, LSA certification is prohibited for any aircraft with “repositionable landing gear”, which allows a pilot to change the position of the landing gear for land or water operations while the aircraft is airborne. The ability to reconfigure the gear for land or water operations while the aircraft is on the ground or in the water, however, is acceptable.

EAA is urging FAA to further clarify the rule, as EAA identified inconsistencies in various FAA and industry communications regarding amphibious LSAs. This hinders creation of clear and acceptable standards for light-sport aircraft, and the development of a sound training curriculum for LSA-designated airworthiness representatives (DARs).

"EAA believes this situation demands a solution, and we will work toward that end," said Earl Lawrence, EAA's vice president of industry and regulatory affairs. "An aircraft-certification limitation would limit light-sport aircraft access to people who believed, based on earlier communications from the FAA, that their aircraft qualified under light-sport aircraft standards, but now find that their aircraft does not qualify."

FAA’s intent is clear: maintain the operational simplicity of sport pilot aviation by ensuring that the takeoff and landing for each sport-pilot flight will use the same medium (land or water). The FAA believes this will help prevent gear-down landings on water and gear-up landings on runways. EAA acknowledges that the final rule's preamble prohibits the repositioning of a gear while in flight; however, EAA also supports allowing a sport pilot to fly an aircraft that allows for gear repositioning in flight and that complies with all other LSA specifications.

According to Charlie Becker, EAA executive director of aviation services, "Good training and pilot discipline can overcome the FAA's safety concerns regarding operational complexity."

The FAA’s upcoming Advisory Circular on sport pilot and light-sport aircraft is projected to include clarification of this issue. In the meantime, EAA will continue to advocate that all amphibious airplanes meeting the other performance and specification parameters, regardless of gear-repositioning features, be included among LSA-eligible aircraft.

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