A030

OTHER: Regulations

Sections:

United States - FAA ~ Ultralight (part 103)

United States - FAA ~ Sport Pilot / Light Sport Aircraft

United States - FAA ~ Experimental - Amateur Built FAR Part 21.191(g).

Canada - TP10141 Design Standards for Advanced Ultralight Airplanes See RAA binder.

Britain - BCAR-S (Britain's Civil Airworthiness Requirements Section S-Small Light Airplanes)

European - JAR - VLR (Very Light Rotorcraft)

General:

United States - FAA ~ Ultralight (Part 103)

http://rgl.faa.gov/Regulatory_and_Guidance_Library/rgAdvisoryCircular.nsf/0/8CF133AD5A5BA4B3862569DE005BD75A?OpenDocument

 

None of the following material has been updated since August 1, 2005

 

See Ultrasport booklet 'FFA Advisory Circular Concerning Amateur-Built Aircraft Policy and the Eligibility of the Ultrasport as a Amateur-Built and Ultralight Rotorcraft'.

and also Ultrasport booklet 'Airworthiness Standard for the Ultrasport amateur Built Helicopters'. This seems to follow FAR part 27.

"The FAA has ruled that the maximum speed of 63 mph normally applied to fixed wing ultralights does not apply to helicopters due to their unique power curve."

Have any of the FAA representatives or the EAA commented about the possibility of the FAA eventually canceling FAR Part 103 and have all light aircraft come under Sport Pilot/Plane? No

It just seems that light aircraft manufactures will have strong reasons to stop producing Part 103 compliant craft, since;

1/ They will no longer have to meet a difficult weight restriction.

2/ Their craft will have less limitations, such as fuel and speed.

3/ They are assured that those that fly their craft have a minimal level of competence.

 

United States - FAA ~ Sport Pilot & Light Sport Aircraft

SYNOPSIS

SPORT PILOT / LIGHT SPORT AIRCRAFT NPRM

The following is intended to outline the major elements of the NPRM and to provide insights to gyroplane issues with the NPRM. There are three major elements to the NPRM: ~ March 21, 2002

1) Pilot Certification - Sport Pilot

2) Aircraft certification - Light sport

3) Repairman certification - for both ready-to-fly and kit built under Light sport rules

 

Light Sport Aircraft: April 19, 2001 from PRA Rotorcraft publication.

The FAA has specifically excluded helicopters from this NPRM for complexity reasons. "Complex" aircraft, such as with variable pitch propellers or retractable landing gear are specifically excluded for the same reasons. Also the quality and tolerance precision standards for helicopter components and kits are considered beyond the proposed simplicity of standars for the new sports aircraft. The door is open however, for inclusion of such "complex" aircraft in the future under the flexibility allowed in SFAR rule-making procedures. (Underlining by DBJ)

Comment by DBJ ~ It would appear that even if a helicopter (or any type of aircraft) could be made that was the easiest thing in the world to fly, it will still not be included into Sport Plane/Pilot because of the complexity of the building and maintaining the craft. The one possable opening is the last sentence in the previous paragraph. Perhaps complex components could be included in the craft if the components were certified and the owner could only check and replace them, not work on them. For the UniCopter this will probably consist of the rotor hub, flight controls and rotor governor. Another thought is that if may of the components have 'unlimited life' or are 'on-condition', then the craft might be accepted into Sport Plane.

An alternative might be to forget Sport Aircraft and go for an experimental (then fully certified?) craft, which incorporates the ABC features plus.

Latest Information:

http://www.aerosports.org/sport_pilot_summary.htm ~ August 1, 2005

http://www.sportpilot.org/ ~ January 31, 2002

www.eaa.org January 31, 2002

http://www.faa.gov/avr/arm/sports013001.htm February 1, 2002

http://www.pra.org/ February 1, 2002

http://www.faa.gov/avr/afs/sportpilot/ ~ February 11, 2002

 http://www.pra.org/NPRM/man_instr_.htm ~ March 13, 2002

Posting to rec.aviation.rotorcraft ~ March 26, 2002

I communicated with Ms. Sue Gardner at FAA a year ago, to discuss the apparent exclusion of helicopters, and also to discuss the future possibility of including new types of aircraft, should they prove to be safe. She said that the potential for future additions is definitely part of the Sport Pilot / Plane.

 

This *may* be good for rotorcraft since it will cause developers to focus on safety. However, it will be a large leap, because an airplane with a variable pitch prop or a retractable landing gear is currently excluded.

 

My feelings are that it might be possible to produce a much safer helicopter, for [Aircraft Certification]. It may then be possible for this helicopter to result in a simpler license, for [Pilot Certification]. However, it is questionable whether the design and construction of this helicopter can be simple enough to allow for a [Repairman Certification].

 

One hope is that specific component assemblies of the craft might be certified and sealed. The pilot / repairman is then only allow to inspect and replace these complete assemblies. This could be a compromise between today's uncertified craft and a fully certified craft. An example of this might be a helicopter that has unlimited-life composite blades and fuselage while the rotor hub and transmission are certified and sealed.

 

This will result in a helicopter and pilots license that is expensive from a homebuilt/ultralight perspective, but inexpensive from a 'real' helicopter perspective.

 

Dave J.

 

The following is a potpourri of rough old information and maybe misinformation related to current and future Regulations and Licensing.

Working Papers:

Licenses: (airman certificate)

Sport Pilot Certificate:

SUMMARY: This notice proposes to establish a new kind of airman certificate called a sport pilot certificate and new eligibility requirements appropriate to the proposed new certificate. This proposed new airman certificate would be intended for persons who wish to fly aircraft of simple design intended exclusively for recreational and sport flying. The sport pilot certificate is necessary to provide a reasonable and appropriate means of certification for pilots that wish to operate certificated lightweight, uncomplicated, slow speed, and very diverse types of aircraft. These aircraft would be two-place or less, have a maximum certificated takeoff weight of 1,232 pounds or less and a maximum stall speed of 39 knots (airplanes only).

License ~ U.S. ~ Recreational Pilot Helicopter - Initial

 Postings:

Date: September 13, 2000 09:38 AM
Author: Don Parham (
rfi@galstar.com)
Subject: Weight

Dave, You mentioned the weight problem. For us here in the USA that problem will be going away in 2001. The FAA is generating a new experimental category which will encompass all "overweight" ultralights and two place ships under 1232 lbs. (allowable gross weight) and the customer can buy the ship fully assembled and will not be required to meet the 51% rule. Also, the Sport Pilot rating is being implemented which will allow pilots to fly without a class 3 medical. A valid drivers liscense is all that will be required. The NPRM is scheduled to be published in January 2001 and the FAA expects to have it completed by the Oshkosh flyin in July/August 2001. They have given this project top priority. What is taking place is the USA is coming in line with the Canadian Advanced Ultralight and European Microlight rules.


Date: September 13, 2000 10:56 AM
Author: John Uptigrove (
fun@mosquitoheli.com)
Subject: That's big news!

Don,

Can you give details? In Canada you still need an "ultralight" pilot's license to fly a Canadian ultralight. Also, gyro's and choppers don't fit into this category in Canada. You have to still get a chopper or gyro rating. Do you know what the situation will be down there? Will there still be an ultralight category? What's the difference between a sport pilot and a private pilot down there?


Date: September 13, 2000 01:59 PM
Author: Don Parham (
rfi@galstar.com)
Subject: Sport Pilot rating

John,

The Sport Pilot rating has been in the works for over three years and is finally coming to a head. The EAA announced in their publications, Experimenter and Sport Aviation that the Sport Pilot rating and light aircraft certification categories are on "fast track" by the FAA. The FAA has assigned the highest priority possible to the project which will allow a Sport Pilot to operate "light aircraft" that are powered or unpowered, single engine, 1232 lbs. gross weight, and two occupants or less. The proposed ruling will allow ultralight pilots and instructors to credit their flying experience toward a Sport Pilot rating. Basically, it looks like the feds will "grandfather" in ultralight AFIs and BFIs into the Sport Pilot and Sport Pilot instructors and examiners ratings. Sport Pilots have to be 16 years of age and have a class 3 medical or a valid driver's license. They are also working on a repairman's certificate for "light aircraft". The FAA is also working on certification and training requirements for trikes and powered parachutes. I am only assuming that "light aircraft" will include gyroplanes and helicopters since it will be an experimental category. It should include all types of flying machines and since they are working on requirements for trikes and powered parachutes, they more than likely will include other types also. That is the feedback I received a couple of years ago from a representative of the ARAC working group that was outlining the basic requirements for the Sport Pilot rating and Sport Plane category. I realize that Canada does not have the same regs as we, but the EAA is working with Transport Canada to allow US Sport pilots to operate in Canada since Canadian ultralight pilots can fly in the US. There are still a lot of "ifs" but the NPRM is supposed to be published in the National Register in January 2001. So, we will have to just wait and see what happens.


Date: September 13, 2000 10:52 PM
Author: Dave Jackson (
jackson.dave@shaw.ca)
Subject: Categories

The following two web sites appear to cover the subjects of Categories and Licenses.

Primary Category - Sportplane Certification Benefits and Options

"Sport Pilot" Proposed Rule

It looks, to me, like the Ultralight Category (Part 103) may just disappear into the Primary Category. Anyone know or think otherwise?

Dave J


 Date: September 14, 2000 08:11 AM
Author: Chuck Roberg (
GyroBfi@email.com)
Subject: Sport Pilot

The two organization's pushing for Sport Pilot are the EAA and ASC (Aero Sports Connection). USUA (United States Ultralight Assn.) is not supporting Sport Pilot but they said they will not opose it either. USUA wanted a change to part 103 to increase the ultralight limits.

*Part 103 will be left unchanged and left in it's present form. So for those who want to stay ultralight there will be no change.*

It would be in the best interest of anyone flying ultralight and who has no pilot certificate to get with a BFI or AFI and get registered as an ultralight pilot with either ASC or EAA. This will help you to get grandfathered in under Sport Pilot by only needing a check ride and a written test.

I have been to 3 seminars on Sport Pilot and if it becomes a rule it should give a shot in the arm to general aviation.

Here's a summary of the Osh Kosh 2000 briefing.

EAA

Sport Pilot Proposal Officially Given to the FAA

ASC

The Sport Pilot Proposal Explained

EAA

Chuck Roberg,


Date: September 14, 2000 11:11 AM
Author: Dave Jackson (
jackson.dave@shaw.ca)
Subject: Sport Pilot Certificate & Primary Category Aircraft

I don't know what the h--- I'm talking about, but have just spent 8-10 hours researching this subject on the Net. The following is a summation of this search.

_____________

It appears that the Sport Pilot Certificate and the Primary Category are two separate, but related subjects.

re: Sport Pilot Certificate

The latest and greatest coverage of this subject appears to be The Sport Pilot Proposal Explained [EAA] ,as mentioned in Chuck Roberg's posting. Rotorcraft are included.

Some quotes are;

"It is important to understand that this proposed rule would establish a new AIRMAN certificate. It DOES NOT address any new AIRCRAFT category"

"An overall goal of this proposal is to enhance safety by providing a pilot certificate for persons who have outgrown the limitations of present part 103 without making the requirements for that certificate so stringent as to be economically impractical, at least for the larger market segments. (emphasis added) This goal would be achieved by tailoring sport pilot rating requirements to the specific category and class aircraft to be flown."

re: Primary Category Aircraft

There does not appear to be any reference to rotorcraft. There is an attempt to have this category compatible with the European and Canadian ones.

The Europeans currently have a (JAR-VLA) (Joint Aviation Requirements - Very Light Aircraft) category and are looking at creating a (JAR-VLR) (Joint Aviation Requirements - Very Light Rotorcraft) category. The Canadians currently only have a (JAR-VLA) category, basically identical to the Europeans.

The initial push for the European (JAR-VLR) is by the Italians. There is a publication called Registro Aeronautico Italiano - Very Light Rotorcraft (RAI VLR). It describes the requirements for the release of the certificate type for single-engine helicopters having no more than 2 seats and a maximum take-off weight 600 Kg.

A Web page on this subject is; Masquito page on Regulations Go to [Sales Information] then [Regulations]. There is a section at the end of this page on the US "Primary Category" for Very Light Helicopters.

Question

What reason is there to manufacture rotorcraft in the Ultralight Category instead of manufacturing them in the Primary Category - Experimental - Amateur Built (Experimental Homebuilt category), if one excludes the pilot's licensing requirement?

Dave J


Date: September 14, 2000 02:56 PM
Author: Chuck Roberg (
GyroBfi@email.com)
Subject: Category

Actually there WILL be a new category of light aircraft. I don't have my notes with me so I don't have the new FAR part number.

This IS NOT going to be done over night even if it's approved. There is a provision for a three year Implementation plan in order to get the infrastructure in place.

Chuck Roberg,


Date: September 13, 2000 02:29 PM
Author: Dave Jackson (
jackson.dave@shaw.ca)
Subject: re: Weight

Don; Thanks for a very interesting posting. It is certainly going to cause John and myself to reassess our helicopter projects. It might also have quite an effect on the marketability of American SportsCopter's 254.

Any answers to John's questions will be of much value. Particularly the one where he asks if this new category is going to replace or compliment the existing Part-103.

It probably goes without saying, that there will be a very interesting article coming up in 'Homebuilt Rotorcraft'

Dave J


Date: 20-Feb-01 01:40
Author: Gyro Guy (
"Kerry Cartier )
Subject: Sport Pilot proposal CONTENT

TO: Rotorcraft Conference participants

FROM: PRA Safety Coordinator

DATE: 2/19/2001

The proposed Sport Pilot/Aircraft FAA rules would not include rotorcraft and hovercraft, and the exemption for ultralight two-place training would be discontinued -- if the FAA rules were adopted as discussed at the Air Sports Expo in Indianapolis.

This information came from a Feb. 15, 2001, e-mail from Larry Burke, president of the Light Aircraft Manufacturing Association, to companies that manufacture gyro kits. On Feb. 19, 2001, Sue Gardner of FAA confirmed it is part of the content of the upcoming Notice of Proposed Rulemaking (NPRM).

MAJOR SAFETY ISSUES

There are tremendous safety issues here, if the FAA adopted the Sport Pilot rules as described.

First, any rotorcraft that are being flown as "heavy ultralights" would not be able to become legal under the Sport Pilot/Aircraft rules. Their pilots would not be able to fly these rotorcraft under the same rules. "Heavy ultralight gyros" would need to be licensed as Experimental aircraft, and a minimum of an FAA student pilot's license with FAA Certified Flight Instructor training would be required to be legal.

Second, all of the current gyro flight instructors who teach under the Aero Sports Connection exemption and use ultralight two-place gyros weighing under 496 pounds -- would disappear. It would even be illegal to fly their former-ultralight two-place gyros for instructional purposes, or for any other purposes.

Obviously, if gyros were included in the Sport Pilot/Aircraft rules, it wouldn't matter if the ultralight two-place trainers disappeared. They'd reappear as Sport Pilot trainers.

As you know, no flight training is required to fly an ultralight gyro. Though FAA would still require no training, to attempt to fly any gyro without training is tantamount to suicide. Under the proposed FAA rules as described, the only place that ultralight pilots could get gyro flight training would be from FAA Certified Flight Instructors. Typically they fly heavier, faster gyros than those used by current ultralight instructors. Transition from the heavier gyros to ultralight gyros would probably be more difficult.

The most unsafe aspect of the new rules as described is that the number of gyro CFIs is very small. Not all gyro CFIs train students on a regular basis. Those that do are booked far in advance. For the budding ultralight pilot, the temptation to self-train would be tremendous... and the result would likely be an increase in gyro fatalities because a whole tier of gyro instructors would have been eliminated by the proposed FAA rules as described.

WHAT "ROTORCRAFT" MEANS

Mike Solano of Air Command says he is convinced that the FAA lumped everything with rotorblades into "rotorcraft and hovercraft." He says that he believes the framers of the proposed FAA Sport Pilot/Aircraft rules do not know the operational differences between gyroplanes and helicopters. This is probably true, as it is unrealistic to expect FAA rule designers to be all-knowing when it comes to gyros. From what Mike has found out, it appears that FAA's concern with rotorcraft is with the mechanical complexity of small helicopters and the difficulty of flying them safely. If this is true, FAA's lack of knowledge about gyros is what makes them want to throw out the baby with the bathwater... they don't know any better. Mike, if I have misstated this, please post a message to clarify it.

Of the estimated 4,000 members of PRA, I would be surprised if 20 actually are flying ultralight helicopters. The only ultralight helicopters I have ever seen fly are the American SportsCopter Ultrasport 254 and the Japanese four-engined Gen H-4, which is still under development. On the other hand, I can think of at least 10 gyros that might satisfy the ultralight requirements, including the venerable Bensen B8-M with a Mac engine. These are owned and flown by hundreds of people.

DIRECTION TO BE TAKEN BY PRA SAFETY PROGRAM

My recommendation, from a flight safety viewpoint, is to include gyroplanes as part of the NPRM.

I decided the best use of my efforts was to show the FAA why gyros were potentially safer than small helicopters. If you'd like to do this -- or show why small helicopters are safe to fly and safe to learn to fly -- now's the time to say something.

In the e-mail from Sue Gardner of FAA, she wrote to me on 2/19/01: "The FAA will not only consider, but requests, all of your comments during the NPRM comment period. The FAA will evaluate all the comments and make modifications to the NPRM for the final rule as necessary. I am asking that you help us in the collection of these comments, by consolidating your responses so that we do not spend our time answering many of the same comments, but instead are responding to the direction that the gyroplane industry sees as the safest and appropriate direction that the FAA should take."

Because this is a SAFETY ISSUE, I am sending this message to all the PRA Safety Reporters on the PRA Safety Net. I am also posting it on the Rotorcraft Conference. I'd like you to circulate this information to gyro people in your chapters and elsewhere -- and ask them to send their comments to me at gyroguy@mail.com.

Sending comments directly to Sue Gardner will only clog her e-mail system. Due to the potentially explosive impact of the FAA interpretation regarding rotorcraft, it is likely that FAA, and possibly Ms. Gardner, will be receive e-mail messages couched in inflammatory terms. Some people may see FAA as "the enemy" and write things which they would never say face-to-face. I do not think that messages like that help the cause... and if the FAA thinks we are a bunch of jerks, there goes the credibility of anything we say.

TAKE ACTION NOW!

In your comments to me, please address ONLY safety issues. I cannot not speak for the leadership of the Popular Rotorcraft Association, for the leadership of any PRA chapter except Chapter 007, or for any of the rotorcraft manufacturers. If your comment is not safety-related, I will not pass it on. I will not include accusations about the FAA or anyone else. Keep your comments businesslike, back your statements up with facts if needed, and recommend what you think FAA should do to change the rules as described in this message.

A copy of Larry Burke's letter is on the Rotorcraft Conference under "Sport Pilot" if you want to read it. It tells much more about the Sport Pilot proposal than the two items I have selected.

If you want a copy of my 2/18/01 e-mail query to the FAA on the Sport Pilot content, or of Sue Gardner's 2/19/01 e-mail reply, please let me know by direct e-mail.

Last thing, the public comment period for the Sport Pilot/Aircraft Notice of Proposed Rulemaking has NOT opened as of 2/20/01. It may not open until April 2001, or perhaps later. Regardless of when it opens, send me your comments as soon as possible. I will consolidate them, and I will e-mail a copy of my summary to you when it is sent to the FAA.

I don't regularly check Rotorcraft Conference, so please send your comments directly to in addition to posting them here for all to see.

Thank you,

Kerry Cartier

National Safety Coordinator

Popular Rotorcraft Association

P. O. Box 303

Red Oak, Texas 75154

(972) 617-3901

gyroguy@mail.com

(http://www.rotorcraft.com/forums/Index.cfm?CFApp=2&Message_ID=37260)

 

to rec.aviation.rotorcraft;  September 14, 2000

A couple of questions, to anyone who might know the answers.

1/ Does the current FAA Primary Category encompass helicopters?

2/ If it does, then considering this in conjunction with the proposed Sport
Pilot Certificate; What reason(s) will there be for a company or individual
to manufacture a helicopter to Ultralight (FAR Part 103) compliance, when it
could be manufactured to Primary Category - Experimental - Amateur Built
(experimental homebuilt) compliance?

Thanks,

Dave J

United States - FAA ~ Experimental - Amateur Built

Notes:

FAR Part 21.191(g).

British ~ Very Light Helicopter

Notes:

CAP 750: British Civil Airworthiness Requirements Section VLH - Very Light Helicopters

http://www.caa.co.uk/publications/publicationdetails.asp?id=1457

View file; http://www.caa.co.uk/docs/33/CAP750.pdf

Excerpt;

1) is designed to carry not more than two occupants;

2) has a maximum weight not exceeding 750 kg;

3) is restricted to day/VMC operations in non-icing conditions;

4) is of orthodox design incorporating:

i) a single main rotor; See b) below.

ii) a skid, ski or fixed float landing gear;

iii) a single engine spark or compression ignition; and

iv) a simple fuel system. See b) below.

5) The design is to exclude:

i) hydraulic systems; See b) below.

ii) boosted flight controls; See b) below.

iii) combustion heaters;

iv) external loads; and

v) emergency flotation gear.

(See AMC VLH 1 a).)

b) Where these requirements are inappropriate to particular design and construction

features, it will be necessary to reconsider the validity of the requirements for each

particular case and the Civil Aviation Authority (CAA) must be consulted as to the

applicable requirements.

 

European JAR ~ Very Light Rotorcraft

The initial issue of JAR-VLR Very Light Rotocraft. Sept./01/2003 ~ Have hard copy in thin blue binder.

All the current JAA codes can be downloaded for free at... http://www.jaa.nl/section1/jarsec1.html

Joint Aviation Authorities

"Incidentally we're no better off in Europe; the JAA is currently hawking JAR-VLR (Very Light Rotorcraft) about the bazaars, yet if you read the draft it says it includes gyros, but in the text permits only a skid undercarriage. There is no gyro theory within the text, it's all entirely written around helos." ~ Genghis the Engineer, PPRuNe, November 5, 2001

The Dragon Fly is a factory-built model being certified under Italy's new Very Light Rotorcraft specifications. Certification of the helicopter's Hirth piston engine is expected imminently, with certification of the model by year end. With a max weight of just 992 pounds (450 kg), the helicopter features a two-bladed main and tail rotor, skids, high visibility bubble canopy, and traditional cyclic and collective controls.

very light rotorcraft (VLR) whose mass does not exceed 600 Kg.

 

The following as a translation of http://www.rai-enac.it/volabilita/precedenti/35-36/art10.htm

It continues the European way




JAR-VLR

Filippo Sergio De Florio
Aeronautical Director Material Certification
Amedeo Marzano
Aeronautical Direction Material Certification
RAI



S ta in order to take off the JAR-VLR. In fact norm VLR - Very Light Rotorcraft adopted from RAI in national within in 1996, and turns to overwhelm an existing gap to international level in the field of the light helicopters, is next to one adoption from part of the Joint Aviation Authorities.
The work group constituted from the JAA in the within of the Helicopter Airworthiness Study Group - whose presidency has been entrusted Francisco Napodano, specialist of great value of RAI - has recorded also the participation of an observer of the Federal Aviation Administration - Scott basandosi Horn- and is predisposing the European norm just on text RAI-VLR.
The group counts to introduce the text of the JAR-VLR within next January for one European adoption within the end of 1998.
Norm RAI-VLR contains of simplified requirement of certification applicable to helicopters of not advanced weight to 600 kg; it traces the same philosophy of already existing regulations JAR-VLA applicable to aircrafts of inferior weight to 750 kg.
We publish in purpose the version original of the introduced participation the slid september to 23° the European Rotorcraft Forum di Dresda of the Ing. Amedeo Marzano of the Aeronautical Direction Material Certification of RAI


RAI-VLR: TO NEW AIRWORTHINESS TAILS
FOR VERY LIGHT ROTORCRAFT


Abstract

Scope of this article is to illustrated the contents of to new airworthiness tails, RAI-VLR, specifically oriented to very light rotorcraft (VLR) whose mass does not exceed 600 Kg.
One regulatory novelty introduced by RAI-VLR is the possibility to install on the VLR rotorcraft, piston engines that not necessarily meets the
33 JAR E/FAR requirements as they must comply with the Appendix B of RAI-VLR, whose contents to are essentially identical to those outlined in Subpart H of JAR 22, with these loads essential integration to account for the peculiar utilisation of engines on rotorcraft such as the double ignition system.
More Based on the assumption that to VLR rotorcraft is much similar to to Very Light Aircraft from the powerplant, accessories and equipment point of view, the most of the regulatory matter introduced in the RAI-VLR, as to make these disciplines to are concerned, was taken directly form the JAR-VLA requirements.
However, for same specific areas such as the dynamic landing conditions and fatigue evaluation the RAI-VLR requirements to are essentially based on JAR/FAR 27, even though the JAR/FAR 27 amendments taken as reference to are not the present ones but those considered more suitable for to regulation tails dealing with very simple design and little manufacturer companies.

Introduction

In these last years we have witnessed in attractive Italy an increasing activity related to the production of very light rotorcraft, whose low cost makes them particularly for recreational flying or to operators involved in simple aerial works, such as natural Park surveillance, or training.
This expanding market prompted RAI to think about to new regulation developed to ensure an adequate level of safety to the relatively simple these design of rotorcraft.
It is worth pointing out that in Italy all the flying vehicles (including rotorcraft) whose mass does not exceed 450 kg must comply with very simple, essentially operating, rules but to are not bound to meet any technical requirements as those stated in ICAO Annex 8 Part II
On the other hand the JAR/FAR 27 requirements to are excessively demanding for the simple VLR rotorcraft design.
Because of this, in many cases one of the main 450 designs constraint of the VLR rotorcraft is limiting the overall mass to Kg in order not to be subjected to to JAR/FAR 27 certification, this approach might raise loads safety related concerns especially when the VLR designers I give not necessarily belong to the aerospace community.
Acknowledging that meeting the TO MAKE 27/JAR 27 requirements would have implied, for generally simple designs and production organisations, as those represented by the manufacturer of VLR rotorcraft, an economic burden in terms of technical solutions and costs associated to the certification tests, not compatible with the low market prices of the VLR, and recognising the necessity to introduces to technical regulation for the VLR rotorcraft, RAI decided to review the contents of the present JAR/FAR 27 requirements and adapt them to the VLR rotorcraft, following to similar approach adopted by JAA to develop the JAR-VLA tails for the very light aircraft starting from TO MAKE 23.
The result of this reviewing process is the RAI-VLR which, as being to significant improvement to the safety of the VLR rotorcraft in Italy, might be considered an useful opportunity for the manufacturers as well, in view of the inherent value related to to certified product obtained at expense of reasonable certification costs.

Applicability

The RAI-VLR airworthiness tails prescribes standards for issuance of to type certifyd for to rotorcraft with to single more engine having not than 2 seats and with to maximum take off weight of 600 Kg.
While limiting the applicability of this tails only to the single engine piston driven engines is mainly two to the need of considering very simple design, the 600 Kg maximum weight is mainly aimed to account for the following factors:

  • Rotorcraft configuration that, consistently with JAR-VLA, might envisage 2 occupants.
  • Rotorcraft designs meeting loads basic airworthiness requirements without adopting unusual or not well proven engineering solutions.
  • More three fuels tank installation of suitable capacity to allow flight duration of hours or.

Currently the weights of potential RAI-VLR rotorcraft, including home-built helicopter, 250 ranges between Kg of the simplest single seat configurations and 500 Kg for the two occupant versions with engine power below 100 HP.
However, as it can be seen in the following figures, which are plotted the weight and engine power of the most popular ultralight rotorcraft, an increase of the installed engine power, typically more than 140 HP, causes the maximum take off weight to be well above 600 Kg, even for home-built rotorcraft. (Figures 1).
As to consequence, considering that meeting the RAI-VLR requirements might imply an increase of the initial not certified rotorcraft weight that varies between 10-20 %, the 600 these Kg upper limit represents to good margin considering the possible developments and changes of rotorcraft configuration ounces they to are granted with to VLR certification (e.g engine power increase).

Flight

Subpart B of RAI-VLR is similar to JAR/FAR 27.
Obviously *** TRANSLATION ENDS HERE *** differences arise in order to account for the different types of usage of VLR rotorcraft as well as the limited performances of powerplant systems installed.
Because of that, one of the basic assumptions taken in RAI-VLR is that an adequate and complete performance assessment can be conducted at sea level conditions.
As a matter of fact a long and very time consuming flight test campaign in correspondence of all altitudes for which certification is requested, as suggested in JAR/FAR 27, beyond representing an excessive economic burden for the manufacturer, might not be very meaningful, with respect to the data acquired at sea level, in view of the low altitudes which these very simple rotorcraft can fly.
It is worth pointing out that this same consideration are assumed in JAR-VLA.
Obviously for such specific topics such as take-off or hovering capabilities a deeper investigation must be conducted; particularly paragraph RAI-VLR 73 prescribes a minimum altitude of 3000 ft in correspondence of which hovering performances should be demonstrated.

http://babel.altavista.com/urltrurl?lp=it_en&url=http%3A%2F%2Fwww.rai-enac.it%2Fvolabilita%2Fprecedenti%2F35-36%2Fimages%2F1001.gifhttp://babel.altavista.com/urltrurl?lp=it_en&url=http%3A%2F%2Fwww.rai-enac.it%2Fvolabilita%2Fprecedenti%2F35-36%2Fimages%2F1001.gif

It is our opinion that 3000 ft might represent a very reasonable assumption when compared to the 4000 ft value, as suggested in FAR/JAR 27, which is considered a suitable minimum altitude for rotorcraft by far more powerful than the VLR ones.
Similarly as far the height-speed envelope is concerned, RAI-VLR 79 states a reference altitude of 6000 ft instead of 7000 ft as suggested in FAR/JAR 27.
Additional main differences with JAR/FAR 27 can be found in controllability and manoeuvrability section.
In JAR/FAR 27 143 (c) is explicitly required a minimum wind velocity of 17 knots to be considered for near ground operations; conversely in RAI VLR 143(c) this minimum wind velocity is not prescribed but it should be determined on a case by case basis through flight test.
Even though RAI-VLR is a simplification of JAR/FAR 27 , there are some requirements such as RAI-VLR 143(d), concerning the controllability after an engine failure, that are fully taken from JAR/FAR 27, which results particularly critical for the VLR rotorcraft.
As a matter of fact, being the VLR rotorcraft pilots not necessarily very experienced, it is important to assure that the controllability of the rotorcraft must be granted even in the case of a complete engine failure, this point might be stressed even further in view of the fact that the VLR rotorcraft are generally powered by fully rated engines and possible rotors with low inertia.
Because of this latter consideration RAI-VLR, includes a specific Advisory Circular in which is required that compliance should be demonstrated by considering a corrective action time delay for the cruise failure not below 1 second or normal pilot reaction time, whichever is greater.
Additionally, based on similar formulations found in [1] and [2], before starting flight tests the rotorcraft design must be such that the following parameter, which represents a measure of rotor speed decay after that engine power is lost , must be at least
equal to 1.3 seconds.

Subpart C Structure

RAI-VLR Subpart C requirements are fundamentally the same as in JAR 27.
The main differences can be found in the evaluation of the emergency landing condition loads, the fatigue substantiation of structures and the introduction of new coefficients for the limit torque, to include also the two-strokes engines, taken directly from JAR-VLA 361.
With reference to the emergency landing condition accelerations, RAI-VLR 561, it should be considered that in these last decades the applicable requirements have been considerably modified in all airworthiness codes.
The adoption in RAI-VLR of values currently used in JAR/FAR 27 would have meant, for the design of a light helicopter, emergency landing loads higher than those against which most of the present operating helicopter were certified.
As a consequence, intermediate values between the present values of JAR/FAR 27 and those in force in CAM6 or FAR 27 before amendment 25
( see tables below ), has been adopted.

Table 1

 

Supporting Structure

VLR

CAM6

JAR 27

 

up

1.5

1.5

1.5

fwd

8

4

8

side

2

2

2

down

4

4

4

Table 2

 

Occupant & Item of mass

VLR

CAM6

JAR 27

up

3

1.5

4

fwd

9

4

16

side

3

2

8

down

9

4

20

In addition the crashworthiness/dynamic conditions prescribed in JAR/ FAR 27.562 were not deemed appropriate for the design of this class of helicopter and not introduced in RAI-VLR.
Nevertheless, RAI intend to issue some advisory material regarding this latter subject whose main task is to provide, following the same approach adopted in the glider regulation JAR 22, the basic design criteria to ensure safety levels of crashworthiness; these criteria might include also static test.
Finally as far structure fatigue evaluation is concerned, it was deemed appropriate, irrespective of weight and operative limitation, to follow as much as possible the contents of JAR/FAR 571.
Namely a flight test campaign must be conducted for the determination of flight loads and special care should be given to the assessment of the GAG cycles.
The only difference from JAR/FAR requirements is that the current damage tolerance criteria have not been included in RAI-VLR 571 because it is assumed that the level of engineering background lying behind such kind of analysis is generally far beyond the capabilities of VLR designers.

Subpart D Design and Construction

Subpart D of RAI-VLR is similar to JAR/FAR 27 as far peculiar helicopter components such as fasteners, rotors, landing gear, control system are concerned.
Conversely, RAI-VLR requirements dealing with fabrication methods or material allowable determination are taken directly from JAR-VLA.
The reason leading to that decision is based on the small industrial organisation of VLR helicopters manufacturers who, under this respect, are very similar to the VLA aircraft manufacturers.

Subpart E Powerplant

Because of the type of engine used on VLR helicopters, in Subpart E the main differences between RAI-VLR and JAR/FAR 27 can be found.
The first important novelty of RAI-VLR is in RAI-VLR 903, where the installation of engines certified according the requirements reported in appendix B of RAI-VLR regulation is permitted.
From a practical standpoint these requirements are the same as Part H of JAR-22 regulation with some differences related to the driven shaft configuration and from the different usage of these engines with respect to the VLA aircraft.
Double ignition and, consistently with the requirements of FAR 33.49 for engines to be installed on helicopters, an integration of the engine endurance test with the conditions and additional time of operation as outlined in RAI-VLR 923, are required.
The contents of RAI-VLR 923 are identical to JAR/FAR 27.923 requirements.
It is evident that the possibility of adopting these types of propulsion system involves some design simplification that, apart from obvious considerations related to the piston single engine, must be necessarily reflected at regulation standard too.
Particularly as regards tanks, filters of the fuel system and engine control system, RAI-VLR requirements take their inspiration from JAR-VLA requirements which are deemed more adequate than JAR/FAR 27 for this type of installation.
However it should be pointed out that implementation of JAR-VLA requirements is essentially limited to the above mentioned areas of the engine system, while it was considered advisable to keep paragraphs of JAR/FAR 27, suitably adapted, for all that concerns specific problems of helicopters ( rotor drive system, gear box, powerplant fire protection, induction system, engine vibration ).
Finally as regards the certification of the engine itself the requirements of Appendix B of RAI-VLR are based on the assumption that an adequate investigation of the engine performances might be carried out without using very complex and costly test procedures, as in FAR 33, that, although deemed necessary on more sophisticated and powerful engines, add an unduly burden to the certification of these simple engines.

Subpart F Equipment

RAI-VLR Subpart F is based on the consideration that many instruments installed on JAR 27 certified helicopters are not essential for VLR helicopters, because of the greater simplicity of the systems as well as to the limited performance of these rotorcraft: relatively low speed, low ceiling and short flight time. In view of the above, JAR-VLA requirements were deemed to be more adequate to be implemented in RAI-VLR. Nevertheless, for those particular instruments and components typical of helicopters, JAR 27 requirements have been adopted in RAI-VLR. The differences between RAI-VLR and JAR 27 for this subpart are mainly restricted to the powerplant instruments, batteries installation and test and electrical equipment.
In particular in RAI-VLR, for powerplant instruments, these indicators are not required :

  • Cylinder head temperature; a minimum-maximum cylinder head temperature warning device is needed
  • Fuel filter contamination indicator

Given the similar characteristics of the battery installation systems, the requirement dealing with this area ( RAI-VLR 1353) has been taken directly from JAR-VLA. However, demonstrations of correct functioning under the conditions shown in JAR-VLA 1353 b(1), b(2), b(3) are not included.
In a similar way, as for static pressure sources, magnetic direction indicators and gyroscopic instruments, the applicable RAI-VLR requirements ( 1325, 1327, 1331 ) are the same as in JAR-VLA.
The same approach has been followed in RAI-VLR to set the standards for switches and electric cables (see RAI-VLR-1361, 1365, 1367), safety equipment (RAI-VLR-1413) and miscellaneous equipment (RAI-VLR-1431, 1436).
However, among the miscellaneous equipment of FAR/JAR 27, there are some which are peculiar for helicopters such as the JAR/FAR 27.1436
( high energy rotors) in this case these requirements were entirely embodied in RAI-VLR.

Subpart G Operating - Limitations and Information

The requirements included in this part are basically the same as those in JAR/FAR regulations with obvious exemptions of those sections covering turbine engines, multi-engine configurations or retractable landing gear.

Conclusion

RAI-VLR is a new airworthiness code that fully comply the ICAO Annex 8 part II standards.
RAI would be legitimated to issue Standard CoA for VLR rotorcraft, certified against RAI-VLR, however RAI interpretation of the " Arrangements concerning the development and the implementation of Aviation Requirement " , through which a number of Authorities ( RAI included) committed themselves to adopt the present and future JAR ' s as their only codes, is that such Authorities cannot issue a Standard CoA for a product, whose certification basis is not a JAR code, when the application date has been made after the adoption of JAR ' s as codes.
Finally RAI-VLR has been taken as reference code by the JAA Subgroup, set up by the JAA HASG, whose objective is the drafting of a new JAA-VLR code to be submitted to the JHWG members for evaluation by the end of 1997.

References

1. Johnson, W., " Helicopter Theory " , Princeton, USA, Princeton University Press, 1980

2. Newman, S., " The foundations of helicopter flight " , Bury St.Edmunds, UK, Edward Arnold, 1994

Acknowledgement

We would like to thank all those who participated and contributed during these last 3 years to make the idea of an airworthiness code for ultralight rotorcraft a reality, in particular we would like to thank our unforgivable friend and colleague Mario Aonzo, whose high competence was determinant in the successful outcome of this task; to his memory this report is dedicated .

 

 

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