Doc Holliday
En-Route
It was resolved, just not to your personal likes.
Sorry, the world does not revolve around you.
FAA guidance on Flight instruction LODA in category aircraft. . . update July 8th
- Thread starter skyking3286
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It was resolved, just not to your personal likes.
Sorry, the world does not revolve around you.
I understand the need to resort to insults, you got nothing else other than to admit this was a monumental screwup.
Doc Holliday
En-Route
LOL. Keep digging that hole.
Only a true fanboi could see this situation as anything but a catastrophe.
Stewartb
Final Approach
Salty, do you own and fly an experimental airplane? I'm thinking not, because those of us who do understood and resolved the problem very quickly and easily. Why do you persist with the toxic BS? You must have better things to do.
It is not resolved. Asking for extra permission to train in your experimental aircraft is NOT GOOD. Sorry you don't agree, but this is not toxic BS, it's sanity. Ignoring how horrible this situation is, is the toxic situation. The LODA is just the tip of the iceberg in the issues this thing is causing and will cause. Normalizing deviation is a bad thing. I'm flabbergasted that anyone owning an experimental aircraft can ignore this.
Pretending like this is not a huge bureaucratic screwup and being ok with a colossally moronic workaround is opening the door for more of this insanity.
It's ok if they muddy the waters, change the rules overnight with no warning, and take 4 years to figure out how to fix it for real. la la la
Stewartb
Final Approach
The LODA has been a requirement for a lot longer than I’ve had an experimental. I knew about it and assumed it wasn’t a big deal to the FAA, which it wasn’t until the famous court ruling, and then my FAA fixed my deficiency. All in all? Pretty cool. ***** all you want but all you gain is the title of *****. *****.
Job security?
if I had an E-AB and a piece of FAA paper that says I’m allowed to get training in it, should I not get training?
Why is this an actual problem to me even if the cause is a foul up?
The effect is I a get a piece of paper I didn’t need before to do what I need to do and life goes on.
Cheers
Daleandee
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Stewartb
Final Approach
Drama Queens seek drama where there is none. Say goodnight, Gracie.
steingar
Taxi to Parking
The rules haven't been changed in many years. You should perhaps learn what they are before making such erroneous statements.
The FAA thinks it's abnormal for you to build an airplane in your shed. That's why they have the "experimental" designation, and special rules surrounding it. Experimental aircraft have never been treated like their certificated brethren. You're in the midst of building one. Are you only now waking up to this fact?
The rules did change. That’s what we are discussing here.
again, you’re ok with scary experimental being flown by people with no training, but a piece of paper that anyone can get is necessary to keep us safe from people training in them? Nonsense.
three months ago the piece of paper wasn’t necessary, now it is, but the rules didn’t change. Wake up.
Capt. Geoffrey Thorpe
Touchdown! Greaser!
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Light and Sporty Guy
And, in general, that's a good thing as far as I am concerned.
The idea that paying an instructor to give me instruction in my own airplane somehow becomes "Carrying persons or property for compensation or hire." seems a bit over the top. But, then, it's the FAA.
wsuffa
Touchdown! Greaser!
To be accurate, the rules (as in "the rules and regulations") did not change.
The interpretation of said rules did change as ordered by the court.
Yeah, in know, head of a pin and all that - blame it on the English language.
If we're going to be pedantic (of course we are), I didn't say the regulations changed. They didn't. But the "rules" we play by did.
Previously people trained without a certain piece of paper.
Now they do.
This is terrifying to someone. I have yet to hear what should be done to remove this “scary” situation except post repeatedly it is “scary”, “wrong” etc. The rest of the world accepts the current situation. If there’s a better solution to continue to train in an E-AB, I’d like to hear it.
Cheers
Now they do.
This is terrifying to someone. I have yet to hear what should be done to remove this “scary” situation except post repeatedly it is “scary”, “wrong” etc. The rest of the world accepts the current situation. If there’s a better solution to continue to train in an E-AB, I’d like to hear it.
Cheers
steingar
Taxi to Parking
Let's keep in mind that when the rules concerning this were written there were no kits. There was no internet. There were some plans and some folks that thought they knew better. The rules were written he way they were for darned good reason.
Actually, that was a judge somewhere. Always risky going to court. Never know what you're going to get. A Court of Law is no place for an honest man in the Book of Steingar.
Count the FAA Administer as one of those that aren't the "rest of the world". But, you guys know better.
"This letter of deviation authority situation has been on my mind, and I’m not any happier about this situation than any of you are." - Dickson
Just another reminder. "the rules" have no problem with me flying my experimental plane over top of you without a bit of training or a LODA. Trying to pretend this is a safety feature is nothing short of insane. It's exactly the opposite. Requiring MORE paperwork to learn to fly an experimental than is required to fly WITHOUT training is NOT safety, it's a screwup.
He's right. With all of the man-hours issuing rubber stamp LODAs so people can get training in their own aircraft, how is the FAA going to find time to check to make sure pilots aren't offering rides to people in exchange for goodwill?
If The Administrator didn’t accept the current situation of issuing the LODA’s, why did he approve it? You don’t have to be happy about accepting a solution to a problem. He and others aren’t happy, but there is an acceptable solution and he approved it.
if you have a better one the rest of the world including I, The Administrator, the Judge and I’m sure The Chief Counsel of the FAA would be interested in hearing it.
Cheers
Honest question, what is the purpose behind considering the provision of flight training to be transportation of passengers for hire?
So, it's ok for them to colossally screw up as long as they have a ridiculous workaround? No, it's not. They should be held to task for the screwup. Either they've screwed the pooch for decades in not properly responding to requests for clarification and in their enforcement, or they screwed up with their recent actions. Either way, they screwed up and should have their feet held to the fire over it. When I screw up I don't get a pass if I come up with some idiotic way for YOU to get around MY screwup and tell you I'll fix it in 4 years.
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i have zero idea. It defies logic but logic is often lacking in regulatory or legal matters
Cheers
Doc Holliday
En-Route
The screwup was acknowledged by the FAA. Had you actually read the policy letter you would have seen that. They offered a simple email system to comply with the regulation that uses minimal information and minimal effort, and gave a LODA for a duration of 4 years. So far everyone who has asked for the LODA have came back with positive results.
But anything short of the agency just deleting 14 CFR 91.319 won't satisfy you.
The FAA has admitted they screwed up. They provided a temporary fix. What more is required, a public flogging?
ETA. Again if you have a better approach than the “idiotic way” to fix the admitted screw up, please advise.
Cheers
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1) change the regulations such that providing training in an aircraft is not considered carrying passengers for hire, if such an interpretation really serves no purpose
or in the alternative
2) include an exception in the regulation to exclude the operation of such aircraft to conduct flight training from the general prohibition of operating the aircraft for hire:
The temporary fix is EXTREMELY distasteful. It's illogical. It contradicts decades of guidance. It still doesn't clarify many other areas of potential fallout. It normalizes deviation. It defines training as abnormal. But you guys act like it's awesome. It's awesome compared to not being allowed to train at all. Otherwise, it stinks to high heaven.
Otherwise, it stinks to high heaven.
I believe 1) or 2) is exactly what the FAA has said they are going to do. They have also said it will take four years to accomplish that (which is a typical time AND excessive IMNSHO) so the LODA good for four years.
Cheers
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The temporary fix is EXTREMELY distasteful. It's illogical. It contradicts decades of guidance. It still doesn't clarify many other areas of potential fallout. It normalizes deviation. It defines training as abnormal. But you guys act like it's awesome. It's awesome compared to not being allowed to train at all.
And so, your alternative is exactly what?
Cheers
I’m not going to stop calling it bad just because I’m not in a position to fix it. It’s still a bad situation and I refuse to pretend like it’s not.
Has anyone at the Faa suffered any consequences for this travesty? Has anybody been fired, or even held to task?
nobody is safer from these actions, and the staff is distracted from their duties.
If that is what they will do, then great. I understand that takes some time under the rules for issuing regulations.
bflynn
Final Approach
Not yet. Here:
Somehow, the term "as clear as mud" comes to mind. . . need LODA (letter of deviation authority) producing 30,000 forms for the FAA to process starting July 12th.
https://www.eaa.org/eaa/news-and-pu...imental-primary-and-limited-category-aircraft
That was the original post. Now it can start going in circles if it hasn't already.
Somehow, the term "as clear as mud" comes to mind. . . need LODA (letter of deviation authority) producing 30,000 forms for the FAA to process starting July 12th.
https://www.eaa.org/eaa/news-and-pu...imental-primary-and-limited-category-aircraft
That was the original post. Now it can start going in circles if it hasn't already.
Is the thread going in circles yet?
Until the last post by salty, I participated because I a had a very slim hope that salty might have a better idea than the current solution. Since this hope as vanished, no need to hear any more repetition of how horrible the FAA has acted and how “EXTREMELY distasteful” it is.
Cheers
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Llewtrah
Remember, this all started because a Warbird company selling bucket-list rides in warbirds, which aren’t certificated aircraft, did so by calling it “flight instruction”. THEIR lawyers took a scorched-earth approach trying to justify it in a way which dragged a number of other legitimate training activities into the discussion/decision, from what I understand.
People can gripe about too much gubmint, too many laws, etc. all they want. The reality is, most laws come into existence because someone somewhere pushed the envelope on reasonableness so hard that a law ended up being the way to enforce common sense, IMHO - not because someone somewhere got bored and decided to write a law. Just my non-lawyer, non-politician opinion.
Sorry, I don’t own a time machine.
Doc Holliday
En-Route
There is a process to rewriting a regulation. In a nutshell the process will allow for public comment, good or bad, and also allow for the lobbying groups to provide input. What is initially proposed then gets modified, another comment period then publication.
Of course, congress could act by simply passing a bill to change the language of USC49 subtitle VII in which would force the FAA to rewrite the regulation to conform with USC49. How many here have contacted their representatives to do that? I doubt very many.
And don't hold your breath that the various aviation organizations are gonna jump all over this. They will use it for fundraising (which they are currently doing) but they know full well how the process works. They'll milk it out.
IMO I don't believe it will take 4 years. But giving a LODA with a long time frame will lessen the paperwork burden.