Shark

“Airplanes should cost less.” It’s one of the few topics that seems to unite the aviation industry—even north-up and track-up pilots can agree that a new Cessna 172 shouldn’t cost over $400,000. But while it’s easy to identify the problem, solving it has proven to be much more difficult. Light Sport Aircraft (LSA) are now over 15 years old, but have not revolutionized general aviation. A rewrite of the Part 23 certification rules first started over a decade ago, yet the casual observer would be hard pressed to notice. Even experimental aircraft, increasingly popular and capable machines, seem like a partial solution at best.

New Cessna 172

Do they have to cost so much?

But hope springs eternal, so a few years ago the FAA launched its Modernization of Special Airworthiness Certification program, or MOSAIC (a better marketing name than ADS-B, if you ask me). In many ways this is an attempt to fix some of the mistakes of the LSA rule, by raising performance limits and allowing for different types of powerplants.

The updates have been infrequent, but there are rumblings of an important announcement this summer, perhaps at Oshkosh. The headline is expected to be a new group of airplanes, somewhere between an LSA and a traditional Part 23 airplane, to be called Light Personal Aircraft (LPA). This would offer a major boost in performance, allow higher gross weights, more powerful engines (perhaps up to 200 hp), and the option for retractable gear.

There are tradeoffs, including a prohibition on commercial operations, a requirement to use an A&P for maintenance (not a Light Sport Repairman), and the need for a Private Pilot certificate (not a Sport Pilot certificate). These are all merely proposals at this point and the situation is changing, but the broad outlines seem to be fairly clear. For the latest details, read Dan Johnson’s excellent site.

What makes an airplane safe?

Pilots can (and should) nitpick any proposal this sweeping, but the starting point seems sensible: take the best of the experimental world and the best of the certified world and try to meet in the middle. LPAs would still be approved by consensus standards, like LSAs, which should keep certification costs down. BasicMed makes the Private Pilot certificate limitation less of a deal-breaker now than when the LSA rule first came out. Even the limitation on commercial flights is in line with the FAA’s longstanding “separation of church and state” when it comes to Part 91 vs. Part 135 operations.

The real progress here relates not to the type of operation, but to the performance of the airplane. Most obviously, raising or even eliminating the arbitrary 1320 lb. maximum gross weight for Light Sport Aircraft would be significant, a tacit admission that this number was set far too low in the original rule. Right now it appears the LSA limit would go up a bit, while the LPA limit would be higher still. Both are good moves.

This would do more than just help pilot egos—it would also be good for safety. While written with good intentions, the current weight limit (one that’s over 1000 lbs. less than a Cessna 172) has probably made LSAs less safe, not more. That 172 is easier to fly, especially in a crosswind, and can also accommodate additional safety features like a parachute, something most LSAs cannot.

X-Cub

You can’t tell if it’s an LSA or a Part 23 Cub, and that shouldn’t matter.

For all the attention the weight increase will receive, the potential lifting of cruise speed limits would be even more transformative—if the FAA is bold enough. Consider the CubCrafters Carbon Cub: in LSA form, the SS model carries 24 gallons of usable fuel, weighs 1320 lbs. at takeoff, and cruises at 110 mph; the Part 23 certified X-Cub carries 46 gallons of fuel, weighs 2300 lbs. at takeoff, and cruises at 145 miles per hour. Is the latter model really any more complicated or dangerous because it carries more fuel or cruises 35 mph faster? Hardly—the main reason the SS model cruises slower is an artificial limitation that requires the 180 hp engine to run at 80 hp for max continuous power. You can guess why that’s in place.

For a more direct comparison, consider the Cessna 162 Skycatcher (an LSA) and the 172 Skyhawk (a traditional Part 23 airplane). The faster, heavier 172 actually has a significantly better safety record than the 162. It might feel counterintuitive, but lower speed and weight do not seem to equal higher safety.

Such comparisons are a hint that the important limitation is not weight or cruise speed, but stall speed. A slower stall speed—and benign stall characteristics in general—leads to more manageable landings, better runway manners, and ultimately a safer airplane. The Lancair IV, at the opposite end of the performance spectrum from the Carbon Cub, is a hot rod of an airplane that cruises at over 200 knots. But cruise speed rarely figures in the airplane’s checkered accident history; it’s the 62-knot stall speed and the resultant fast approach speeds that often lead to trouble.

The maximum stall speed for LPA is rumored to be 52 knots, which is in line with popular four-place airplanes like the Skyhawk (around 40 knots) and the Piper Archer (49 knots). Both of these have good runway performance and predictable flying qualities.

Unfortunately, there’s also talk about a power index. This would seek to limit performance, perhaps based on a ratio of engine horsepower to wing area. The concept of such a sliding scale is appealing, but this rule could quickly become restrictive and lead to bad tradeoffs, just as the LSA weight limit did. One of the key complaints about LSAs, especially in the training environment, was their kite-like performance in windy conditions, a mistake that should not be repeated.

The FAA has also suggested that, while the 120-knot maximum cruise speed will be increased, there will still be a limit for both traditional LSAs and the new LPA. That seems like a rule created simply to make a distinction between airplane types, one that has little grounding in safety statistics.

Less is more

It’s important to remember the point of this mind-numbing reform process: reduce certification costs and more easily accommodate new technology, while maintaining safety. It sounds like a tall order, but it is possible. The first two priorities are in fact directly related, while the third has to do with pilots more than airplane design.

The starting point for any LPA rule should be the fewest possible limitations, accompanied by a paranoia about unintended consequences. This “less is more” bias is based not on a deeply held political philosophy but on recent experience. Consider electric powerplants, the most painful example of what can go wrong when regulators write overly specific rules. One of the main goals of the LSA effort was to encourage innovation, and yet the text ended up prohibiting electric motors, perhaps the critical innovation of the decade. The timing could hardly have been worse, and today the nascent electric airplane industry is chafing against a limitation nobody ever intended to write.

Shark

The Shark is just one of many sleek European airplanes with impressive performance.

“Fewer limitations” does not mean LPA pilots would be completely unregulated. In fact, while new airplane designs obviously need to meet a basic level of safety, the biggest safety improvements come from the pilot, not the airplane. And here there are plenty of guardrails already in place. Remember, the FAA has requirements for high performance, complex, and tailwheel endorsements as pilots check out in different airplanes. At the extreme, there’s a maximum speed of 250 knots below 10,00 feet and 200 knots in Class C and D airspace. Jets require a type rating, no matter what the weight.

I’m not suggesting that an LPA rule have zero limitations. A low stall speed is a must, and a maximum horsepower limit might also make sense. But the power index approach seems destined to create problems, and a maximum speed limit goes against everything general aviation stands for. Those should be resisted.

This isn’t all a dream. For a hopeful example of what might be possible, look at the burgeoning European microlight market. Airplanes like the Shark, Blackshape, and Tarragon offer impressive performance at reasonable prices. Stall speeds in the 30s and cruise speeds in the 160s are not unusual, and all this on 5-7 gph of mogas. Retractable gear and constant speed props are an option, and notably there is no speed limit on the 600kg class of airplanes. The airplanes also look great, unlike most of the rather homely LSAs in America.

Will new FAA rules spark a similar wave of innovation in the US? Pilots should remember two lessons from previous reform efforts: these processes always take longer than expected, and the results are always less revolutionary than boosters hope. The same is likely to be true with any potential revision to the LSA rule or the implementation of an LPA rule. A notice of proposed rulemaking probably won’t happen until 2023, and even once that is out it will be a long time before airplanes hit the market. Most importantly, the business case will have to catch up with the regulatory environment.

That doesn’t mean the MOSAIC process is a waste of time—especially if the FAA dreams big.

31 replies
  1. Dave Anderson
    Dave Anderson says:

    Leave it to the FAA to completely screw up a good thing. The medical side is still ridiculous and dates to the 60’s. We have data that proves the drivers license in lieu of a medical works for GA

    Reply
  2. john
    john says:

    … One more wrinkle in the existing process they ought to deal w/ now is the fact that Mx and likely other countries dont accept (recognize) the “spec. air-worthy certs” of LSA and experimental.
    The result is many pilots like myself w/ the time & $$$ are not able to fly a plane, legal in LA bravo air-sp., over the ranchlands of mexico … Is this the best the bureaucracies can do … really ?

    Reply
  3. RichR
    RichR says:

    How about we let A&P’s professionally build kits and/or assist beyond 49%? Those aircraft should be certified differently than experimental, with commercial use ban and pax limits. Would need to be carefully considered so as not to endanger experimental builders or industry (liability issues?), but by the time another round of certification and industry/market response takes effect, there wont be anyone left flying GA anyway!

    Reply
  4. Dennis
    Dennis says:

    US government can’t massage a small set of rules that would increase life fulfillment of many citizens, create jobs, support municipal and other infrastructure, stimulate economies, increasing tax revenues, etc in a reasonable time BUT they can over react to a flu in an instant to bankrupt small businesses, trigger mass layoffs, stifle all economic metrics, compromise public mental health with damaging ‘social’ rules– all causing a significant increase in suicides. Disappointing

    Reply
    • I read Air Facts for insight into aviation topics, not unrelated political rants. Please limit comments specifically to aviation issues raised in the article.
      I read Air Facts for insight into aviation topics, not unrelated political rants. Please limit comments specifically to aviation issues raised in the article. says:

      Brian L

      Reply
      • Mark
        Mark says:

        The article is specifically about govt regulations & impacts on our activities and you’re upset about political comments?? Go find some safe space…

        Reply
    • john gunn
      john gunn says:

      … & mebbe save a little indignation & disapointment for 1/2 million of our countrymen and their families …

      Reply
  5. Tony
    Tony says:

    Just like Reagan said : government is not the solution it is the problem. Overregulation like higher taxes only stifles innovation.

    Reply
  6. Daniel
    Daniel says:

    The F.A.A. priced most people out of being able to fly. They don’t want people to fly. safety is important, but it does no good if no one can afford to fly because of over-regulation. they are behind the times.

    Reply
  7. T. H. Holmes
    T. H. Holmes says:

    I noticed there was no mention of LAMA, who I suspect is fighting against any change. An increase in weight limits would destroy their market, as we Sport Pilots could suddenly purchase any number of existing aircraft–the venerable 152 would see a surge in buyers–at affordable prices. I could finally buy the biplane I’ve been dreaming about at a reasonable price.

    Reply
  8. Chris
    Chris says:

    In Canada we are eagerly awaiting the results of Mosaic! Our similar category was obsolete the day LSA came out, and we’ve been in a death spiral for the last 15 years. There are only 3-5 new aircraft registered per year in this country, and only if they can squeeze into our 1232 lb gross weight limit, and 832 lb max empty weight. Go America – we’re counting on you!

    Reply
  9. Joe K.
    Joe K. says:

    When these LSA and LPA changes go thru, Cessna should either restart production of the 150 and 152, or sell the patents to another manufacturer. These planes were the best trainers ever made.

    Reply
  10. Barry Gloger
    Barry Gloger says:

    The FAA need do only two things to save GA:
    Driver’s License Medical for Private Pilot
    Consensus Part 23 Airplanes

    Reply
  11. Joe Dickey
    Joe Dickey says:

    Perhaps a sweeping house cleaning at DOT and FAA with a replacement by a common sense mind set and term limits in Congress would be helpful.

    Reply
  12. John S
    John S says:

    Not mentioned in the article is LSA’s use of ASTM for certification for SLSA designs vs the classic FAA Part 23 certification for most GA aircraft. While an FAA Part 23 aircraft certification program for a new design is expensive, that is not the cause of a new Cessna 172 coming in at $400K+, which was certified a long time ago. $50K for an engine and prop, $50K+ for avionics, and a labor intensive construction process result in an expensive product that has a low demand no matter what the certification process is. Until someone figures out how to build LPA aircraft for the cost of a high-end family car/SUV, the market dynamics will never change.

    Reply
  13. Larry
    Larry says:

    As you said, the Light Sport Rules came out 15 years ago yet despite initial fanfare hasn’t reinvigorated GA to any great extent. A $150K + LSA is still both unaffordable as well as unjustifiable for the reasons you espouse despite the glowing reports of that LAMA guy. The five years of work of the people doing great work on the FAR Part 23 Rewrite ARC recommendation resulted in only something called NORSEE by the time the FAA got done with it. (The Primary Aircraft category which would have GREATLY helped was on the FAA’s cutting room floor). Big Deal! So I can put a few things in my Cessna 172 because it makes it safer. Basic Med DID provide a big boost (IMHO) but let’s not forget that it WASN’T the FAA who came up with that, it was a certain astute Senator – pilot from Oklahoma who capitalized on the rare timing of funding legislation for the FAA and forced it upon them legislatively. I know for a fact that some Aeromedical sectors are fighting against it tooth and nail; it isn’t safe from future meddling. A handful of doctors with self-preservation parochial interests in OKC could muck it up overnight.

    I have a friend who is buying used C182’s, fixing them up and reselling them for prices well below what a new LSA sells for. There are “food fights” as soon as a new listing for one shows up for sale. In this month’s AOPA Pilot editorial, Mark Baker stated, “Good luck finding a good clean C172.” So there IS a market for airplanes with the right performance and at the right price. Unless a miracle happens, I doubt seriously if MOSAIC will establish an environment to do much of anything unless an equivalent airplane at an affordable price can be produced.

    I summer at a small airport just west of Mecca — um, Oshkosh — that is absolutely beautiful. I often say that if God had an airport, it would look like ours. Yet, ALL the local pilots are now falling off the far end for various reasons. There hasn’t been but one new guy establish residence in the 20 years I’ve been there. And if the IA goes away … the airport will die instantly. I’m an A&P and COULD have done annual condition inspections on airplanes relicensed in the Primary Category but it didn’t get invented. I doubt if MOSAIC will allow relicensing of existing certificated airplanes into Special so it isn’t going to do anything for us. I’ve owned my 172 for 36 years now … I’m not selling it to buy an expensive airplane that doesn’t do more for me. I’ll give up aviating first … and likely will.

    If you go to an airshow — I attend both SnF and Airventure annually — what do you see. Older men with grey hair (if that) for the most part. There are a few younger people but not many. Very few of the younger people are actually pilots and even fewer still own an airplane. Unless MOSAIC does something for them, it — too — is destined for failure to provide a fertile new environment for aviators. A few new ones here and there isn’t enough to keep the aviation infrastructure healthy.

    I’m 73 years old, have been an aviator and maintainer for 50+ years and have now arrived at the point where I’m asking myself how much longer do I want to keep hitting my head against the wall in order to legally fly a dwindling number of hours annually. I’m actually operating now — in my thoughts — on less than a five year remaining time span. I can drive a 45′ motorhome towing a 30′ trailer down the interstate with just a driver’s license yet have to be the equivalent of a 20 year old fighter pilot to fly my C172. Phooey. Good job, FAA. I can’t wait until 2023, et sub, to see how much you’ve screwed up MOSAIC and implement it, too.

    “An Elephant is a mouse built to bureaucratic specifications” — Long’s Axiom

    Reply
  14. Stephen Phoenix
    Stephen Phoenix says:

    I don’t believe that cost is the problem. If airplanes were offered for free, there would not be that many takers. What we should have learned in the Great American Aviation Experiment is that about 99.8% of the people have no use for an airplane. So rather than beat our heads against the wall, perhaps we should concentrate on figuring out just what an airplane might be good for amongst a larger number of people.

    Reply
    • John Zimmerman
      John Zimmerman says:

      I tend to agree. There have been $100,000 LSAs but everyone ends up choosing the loaded ones with all the options for $150,000. I’m not sure anyone has stopped to ask why.

      Reply
      • RichR
        RichR says:

        John, follow the passion. The people who buy the loaded airplane are buying a shiny toy they can show off until they tire of it. The passion is in the folks who buy the clapped out production plane and keep it going with gas/oil/maint or build their own. If the shiny object crowd goes away tomorrow, I could care less. If the passionate ones hanging on go, or get pushed, away, that will be the sad end of GA.

        Reply
      • RichR
        RichR says:

        …the shiny object crowd does have one useful contribution…subsidizing creation of more future used airplanes.

        Reply
  15. mike
    mike says:

    You can’t expect Cessna to be able to compete with aircraft mechanic loophole Larry pumping out “amateur” built RV-6s out of his garage only to make a profit all while completely avoiding all the hoops Cessna has to go through to make an airplane.

    Reply
    • RichR
      RichR says:

      I don’t, nor do I care if Cessna stays or goes…Textron will cut bait soon anyway or sell out various lines to PRC. If Larry is pumping out RV-6s in a responsible manner that everyone knows what it is and there’s an agreed structure maybe this gets some blood pumping for the low end passionate flyer crowd.

      Reply
  16. Larry
    Larry says:

    I’m not “pumping” anything out of my hangar for anyone else … never did. As I see it, a low end certificated airplane relicensed into the Part 23’s proposed Primary category would only have enabled an A&P to do condition inspections on it just like an E-AB. The reason this is of concern is that finding IA’s do do annuals is getting harder and harder around here. Finding ANY mechanics in rural areas is a problem. I’m fortunate … I do my own maintenance but cannot do my own annuals. I guess I could go get an IA but I don’t want to have to deal with the FAA in that official capacity.

    “Loophole Larry” … that’s good .. I like it :-)

    Reply
  17. Ron Blum
    Ron Blum says:

    Instead of blaming someone else (FAA) for all of your problems, join ASTM and voice your opinion. Make a difference. ASTM used to have many “users” (non-FAA and non-OEM) personnel on the committees. Not any more.

    Airplanes cost so much because it is easier to certify products that are made by someone else. A $15K, OEM-specified, landing gear actuator is really a $300 off-the -shelf part. The avionics are $100K, but there are less expensive options.

    Today’s standard of mass production will never happen in aviation again. So, $40K second display screen (MFD) or $600 iPad? That’s why airplanes are sooooooo expensive.

    Reply
    • Larry
      Larry says:

      Maybe you all are missing my point, Ron. ALL owners of the (EAA proposed, as I understand it) “Primary Aircraft” category would have benefited GREATLY from it’s institution. Imagine an aviation world where you relicense your certificated airplane in a “special” category just like an E-AB airplane with all the benefits that entails. An owner could have installed any equipment they wanted … your $300 actuator, for example. And … if desired, the airplane could revert to certificated status after a ‘survey’ to determine it again meets its original Type Certificate.

      Canadians — as I understand it — have some sort of airworthiness category that low end GA airplanes can be relicensed in. Perhaps someone from Ceh Neh Deh can expound?

      At my stage of the game, I have no interest in building an E-AB or buying a factory built “heavy” LSA built to some purported new MOSAIC standard which will probably be instituted after I hang up my A20’s. I’ve owned my C172 for 36 years now and I know every rivet in her … no interest in anything else although IF I was younger, I might.

      ALL of you that fly certificated airplanes would have benefited from institution of the Primary Aircraft category … which would have allowed deeper owner involved maintenance than the currently allowed Preventative maintenance list. Further, finding A&P’s and IA’s is getting to be a bigger and bigger problem in some parts of the Country. And when you do, bring your checkbook.

      Finally … yes … after 50 years of dealing with them, I DO have a bad taste in my mouth for the people at the ‘Top’ of the FAA who can’t see the forest for the trees and act at the speed of molasses off a Maine tree in winter. Removing their second Mission statement to “promulgate aviation” in the 90’s was a giant mistake. Rank and file FAA types are generally a decent lot … it’s the people running the show that I have heartburn with.

      Reply
  18. mike
    mike says:

    “Loophole Larry” was just a generic term, not aimed at anyone. Problem is if no one buys new C-172s there won’t be any used ones for future generations, not everyone wants a homebuilt.

    Reply
  19. Ed
    Ed says:

    Regulation is a big part of the issue, that is true, but there are others. Aircraft manufacturers are still recovering from the manufacturing moratorium caused by the lawsuit/liability crisis of the ’90s. Stopping production, along with the subsequent development crippled the industry. Tort reform has helped, but product liability is still for most in manufacturers, and importantly the investors minds Manufacturers have also fallen into a behavior that we see in Automotive sales as well. Every car today must have power-everything, computer assisted functions, loaded with gadgets. There are no “cheap” options, as even Air-conditioning is standard, you pay more for a car with fewer options, as manufacturing one is now a ‘special’ order. So the price of automobiles has increased greatly, even with the economy of scale that industry has. Aircraft manufacturers are doing the same thing, loading aircraft with technology, with no inexpensive options. Piper’s newest addition to the training fleet for example- is very well equipped, but is far from affordable for all but the biggest flight schools, whom dominate because they have capital to spend. Piper has created an aircraft no one can afford, but has great marketing appeal. Poor sales also drive costs up as R&D needs to be paid for, and manufacturing costs increase with lower production rates. That’s simply not sustainable. The Cessna 162 Skycatcher failed, in large part because it couldn’t hit a price point that generated sales. Poor performance and a laudable but misguided attempt to create a 21st century 152 didn’t help, packing too much into the concept, maybe if performance had been better, sales would have appeared… maybe. Meanwhile, flight schools and the everyday private pilots are looking at 40-60 year old aircraft, because they can still fulfill the mission and can be had for the price of a well equipped pickup truck. At any given moment there are about 2000 or so used aircraft available on the used market, light twins through piper cubs. All available at a fraction of the cost of a brand new version, so the used aircraft market remains strong. There used to be a saying, what this country needs is a good 10 cent cigar, today, we should be saying, there needs to be a good $60,000.00 aircraft.

    Reply
    • Tom Yarsley
      Tom Yarsley says:

      “…there needs to be a good $60,000.00 aircraft.”

      You could build one. As long as it had no engines and no avionics.
      Or was a 1980s-era ultralight.

      Reply

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