GA Experimental flying
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GA Experimental flying
There's a lot of ideas being thrown about at present in the UK about experimental flying on light or microlight aircraft / SLMG. The basic premise is that people who want to be able to experiment with changed engines, instruments, flying controls, etc. should be allowed to. The concept is quite widely supported, but when you get down into the detail it starts to get very complicated - what sort of operating restrictions should apply?, who should be allowed to fly (or fly in) the aircraft?, how much evidence from uncontrolled experimental flying could be accepted towards subsequent approval?, should the limits of experimentation be agreed in advance with a "grown up"?, should first flights be conducted by a qualified TP?
My own views are that the idea is sound, but such flying should be limited to named crew and airfields, and the range of experimentation agreed in advance by a competent person with the authority to say yes or no to what is done (such as the PFA's Chief Engineer for example). I think that this is broadly the way the FAA work, but suspect that what it says in their documents and what actually happens, may not strictly co-incide.
Does anybody have any thoughts or experiences of an experimental system within GA, and how it does, could or should work?
G
My own views are that the idea is sound, but such flying should be limited to named crew and airfields, and the range of experimentation agreed in advance by a competent person with the authority to say yes or no to what is done (such as the PFA's Chief Engineer for example). I think that this is broadly the way the FAA work, but suspect that what it says in their documents and what actually happens, may not strictly co-incide.
Does anybody have any thoughts or experiences of an experimental system within GA, and how it does, could or should work?
G
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Thread Starter
Being cynical about this (and incidentally, I have perfectly good design approvals and B-conditions of my own thanks, this is on my own behalf only insofar as I have been dragged kicking and screaming into the debate and am not being allowed to ignore it) the people pressing for it wish to avoid the cost of going through a formal design review before trying something out.
My personal instincts are initially that the whole idea is daft, and that anything leaving the ground should go through a formal design investigation, then be properly test flown by a competent TP. A lot of people in the GA community are telling me I'm wrong, and really I'm trying to either (a) find out I am, and why, or (b) confirm my prejudices with evidence I can use to prove the point.
What I suggested above is my best stab at, if it's going to happen, how to minimise the risks.
G
[ 29 December 2001: Message edited by: Genghis the Engineer ]</p>
My personal instincts are initially that the whole idea is daft, and that anything leaving the ground should go through a formal design investigation, then be properly test flown by a competent TP. A lot of people in the GA community are telling me I'm wrong, and really I'm trying to either (a) find out I am, and why, or (b) confirm my prejudices with evidence I can use to prove the point.
What I suggested above is my best stab at, if it's going to happen, how to minimise the risks.
G
[ 29 December 2001: Message edited by: Genghis the Engineer ]</p>
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My first reaction is that this sort of stuff is best left to pros, like Genghis and myself. Having said that, I know that in North America the EAA offers some guideleines about what simple tweeking and testing a home builder can safely do, and how to do it. I'm not real familiar with their work, maybe someone else from North America can help here?
[ 30 December 2001: Message edited by: Weight and Balance ]</p>
[ 30 December 2001: Message edited by: Weight and Balance ]</p>
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I'm not a TP or FTE, but I've been involved in experimental test flying of helicopters (MoD) and much more recently, gyroplanes (for CAA). I've directed two gyroplane campaigns in the last nine years and on both occasions hired a professional team of two TP's (one non-flying in support) and an FTE. The value added is immesurable, both in terms of safety and technical input.
I know that CAA have been considering for a number of years (and it hasn't come to fruition yet, if it ever will) a scheme for the UK gyroplane community where a select few would attend a seminar (only days long) covering test methodology and philosophy, report writing etc. These individuals would then be type-rated for experimental work (the VPM M16 guy couldn't do RAF 2000's for example).
I've got very direct experience of one gyroplane type that passed BCAR Section T's dynamic stability requirements when test flown by a CAA-approved pilot (not a TP, but a guy I have a very high regard for in the UK gyro community). When flown by a TP, the result was a fail (AND the TP's kneepad data was almost spot-on with the on-board recording system). I'm not saying that the TP will always get it right, but my experience is that our man always did. And we got beautiful post-flight reports from him as well.
I imagine the number of caveats/restrictions/limitations likely to be placed on non-professionals by the CAA is likely to undermine any campaign to the point where it becomes of questionable value.
I know that gyroplanes are a tiny fragment of the GA scene, but I think my experience is transferrable and I'm afraid, my experience is a negative one. If you're going to do experimental work, you need a TP/FTE.
Hope this is of some use to the debate.
I know that CAA have been considering for a number of years (and it hasn't come to fruition yet, if it ever will) a scheme for the UK gyroplane community where a select few would attend a seminar (only days long) covering test methodology and philosophy, report writing etc. These individuals would then be type-rated for experimental work (the VPM M16 guy couldn't do RAF 2000's for example).
I've got very direct experience of one gyroplane type that passed BCAR Section T's dynamic stability requirements when test flown by a CAA-approved pilot (not a TP, but a guy I have a very high regard for in the UK gyro community). When flown by a TP, the result was a fail (AND the TP's kneepad data was almost spot-on with the on-board recording system). I'm not saying that the TP will always get it right, but my experience is that our man always did. And we got beautiful post-flight reports from him as well.
I imagine the number of caveats/restrictions/limitations likely to be placed on non-professionals by the CAA is likely to undermine any campaign to the point where it becomes of questionable value.
I know that gyroplanes are a tiny fragment of the GA scene, but I think my experience is transferrable and I'm afraid, my experience is a negative one. If you're going to do experimental work, you need a TP/FTE.
Hope this is of some use to the debate.
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So TP/FTE are needed for experimental work even in GA. My problem is to get the training. The National Test Pilot School, NTPS, in California is offering some specific courses for light aircraft testing (LBA-TB2 course)
Would it be a good start to learnt the job?
Does the CAA will accept this training?
more info on <a href="http://www.ntps.com" target="_blank">www.ntps.com</a>
happy new year to all!
stardust
Would it be a good start to learnt the job?
Does the CAA will accept this training?
more info on <a href="http://www.ntps.com" target="_blank">www.ntps.com</a>
happy new year to all!
stardust
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NTPS runs good courses .. top value but don't expect them to come cheaply ...
New Year good wishes to SR, the Velvet Hammer, RL, and WS.
[ 01 January 2002: Message edited by: john_tullamarine ]</p>
New Year good wishes to SR, the Velvet Hammer, RL, and WS.
[ 01 January 2002: Message edited by: john_tullamarine ]</p>
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Thread Starter
ITPS (if they are still in business) and ETPS also offer short courses in the UK, but none are cheap. Also, I'm quite certain that ETPS knows very little about light aircraft testing, and ITPS not that much more.
The CAA will accept the training of any of these schools, or the French school EPNER in the majority of roles for TP/FTE. However, it's not really something that you can "self-improve" through, the costs are VERY steep.
If you want to get into the field, particularly in GA, the best way is to get a job within an organisation that does that sort of work, and learn on the job. That is how the majority of people working in GA FT came into it. However, this is a tad off-track, so I shall stop here.
G
The CAA will accept the training of any of these schools, or the French school EPNER in the majority of roles for TP/FTE. However, it's not really something that you can "self-improve" through, the costs are VERY steep.
If you want to get into the field, particularly in GA, the best way is to get a job within an organisation that does that sort of work, and learn on the job. That is how the majority of people working in GA FT came into it. However, this is a tad off-track, so I shall stop here.
G
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One reason GA people want some sort of procedure is to take advantage of technical or noise-reduction progress elsewhere, approved by a reputable authority, but nit yet approved by CAA and too expensive for a small outfit to duplicate all the testing cost etc.
One example: Pawnee for glider towing in Sweden, modified to take Volvo 6-cylinder engine and 1:3 reduction gear big propellor - about 60 percent improvement in fuel consummption and much lower noise.
Total success in Sweden, approved years ago on experimental basis by their Authority, collecting more practical experience daily etc.
No chance of Piper applying for UK certification. Volvo helped the Swedes, but won't do anything official for fear of legal liability issues - a few aviation conversions are too much trouble/too little revenue for a car company.
We can't even get one started in the UK to demonstrate its potential.
One example: Pawnee for glider towing in Sweden, modified to take Volvo 6-cylinder engine and 1:3 reduction gear big propellor - about 60 percent improvement in fuel consummption and much lower noise.
Total success in Sweden, approved years ago on experimental basis by their Authority, collecting more practical experience daily etc.
No chance of Piper applying for UK certification. Volvo helped the Swedes, but won't do anything official for fear of legal liability issues - a few aviation conversions are too much trouble/too little revenue for a car company.
We can't even get one started in the UK to demonstrate its potential.
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Be it flying machines, watercraft or bicycles, there is an inherent arrogance in the state deciding which are worthy of having an uninvolved professional perform an independent evaluation before ANY operations are permitted. I shudder to think how the Wright brothers or Frank Whittle would have fared! Public endangerment is the issue, and that can be controlled by test area and test plan appproval. As experience is gained, then one can decide if (certification is desired) how to accomplish the validation tests using standard test instrumentation and methods.
I am a TP with almost three decades of actual development (a subject that most military TP's are totally unfamiliar with). In the States, an experimental airworthiness certificate, with test limits and area designation, is almost assured unless the aircraft is patently unsafe (unflyable is not an issue, believe it or not).
I am a TP with almost three decades of actual development (a subject that most military TP's are totally unfamiliar with). In the States, an experimental airworthiness certificate, with test limits and area designation, is almost assured unless the aircraft is patently unsafe (unflyable is not an issue, believe it or not).
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It seems to me that individuals, unable to find what they want from a reputable manufacturer, are experimenting with 'new ideas' on individual bases.
This suggests that the difficulty lies in the manufacturers' failing to provide what the market wants, (coupled with a little desire to muck about by owners of small aircraft).
Others feel the same way, perhaps.......?
Really, if someone wants to build a 'quiet' light aircraft, they MUST spend their time and efforts convincing regulators and manufacturers to MOVE WITH THE TIMES. Mucking about yourself to find a one-off answer, achieves nothing but the launch of a potentially unsound, untested, and deadly design.
When that design claims a life, the public will not have any interest in its genealogy. They will simply see another 'small aircraft has crashed' and all our reputations will have been damaged as a result.
Sorry, Genghis et al, but I don't believe that aircraft design and manufacture should, in 2002, be in the hands of wealthy individuals with big garages and time on their hands.
This suggests that the difficulty lies in the manufacturers' failing to provide what the market wants, (coupled with a little desire to muck about by owners of small aircraft).
Others feel the same way, perhaps.......?
Really, if someone wants to build a 'quiet' light aircraft, they MUST spend their time and efforts convincing regulators and manufacturers to MOVE WITH THE TIMES. Mucking about yourself to find a one-off answer, achieves nothing but the launch of a potentially unsound, untested, and deadly design.
When that design claims a life, the public will not have any interest in its genealogy. They will simply see another 'small aircraft has crashed' and all our reputations will have been damaged as a result.
Sorry, Genghis et al, but I don't believe that aircraft design and manufacture should, in 2002, be in the hands of wealthy individuals with big garages and time on their hands.
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Thread Starter
I really appreciate the comments everybody has made - I have to say that by and large people have confirmed my own prejudices. The exception is Nick Lappos, who obviously has a fairly libertarian view on this.
So, from Nick or anybody else who agrees with him, what in your opinion is the practical justification for allowing experimentation without design and testing control?, does it allow a better design to be reached quicker?, what is the safety record like? does the FAA accept data from unqualified individuals in final approval of a mod or whole aircraft type?
Or is it really a plea from people who won't admit that they simply don't have the ability to comply with safety regulations?
To an extent I am playing devils advocate in asking these questions. I freely admit that I am personally in the same camp as I-M or NorthernSky, but I really do want to see the point of view of those who disagree with me (and outside this forum, there are quite a few, and they are very vocal). At the moment I don't really understand that viewpoint, and would like to.
G
So, from Nick or anybody else who agrees with him, what in your opinion is the practical justification for allowing experimentation without design and testing control?, does it allow a better design to be reached quicker?, what is the safety record like? does the FAA accept data from unqualified individuals in final approval of a mod or whole aircraft type?
Or is it really a plea from people who won't admit that they simply don't have the ability to comply with safety regulations?
To an extent I am playing devils advocate in asking these questions. I freely admit that I am personally in the same camp as I-M or NorthernSky, but I really do want to see the point of view of those who disagree with me (and outside this forum, there are quite a few, and they are very vocal). At the moment I don't really understand that viewpoint, and would like to.
G
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One concern which supports a conservative approach to these matters relates to background knowledge.
The well-intentioned experimenter (and hapless third parties) may be exposed needlessly to unnecessary risk of a greater or lesser extent due to the simple fact that his/her technical background does not encompass lessons learnt earlier by the design and test industry.
Even those who ought to know better sometimes can fall foul of this trap. I recall one fatal test accident within a factory program some years ago where an ill-considered modification was being tried out as a hoped-for solution to an ongoing handling difficulty. The result ? ... two dead and one very seriously (and permanently) injured.
To me, if there is not some sort of sensible and competent peer-review assessment done prior to development, then the risk of mishap goes up unacceptably.
While I do not support the idea of excessive and oppressive paternalism in the process, there ought to be a balanced middle ground which protects most of the various stakeholders' desires and interests.
Or do we simply wish to enshrine the right of the individual occasionally to be stupid, wilfully reckless, negligent, or just unfortunately in the wrong mod at the wrong time ... ?
[ 06 January 2002: Message edited by: john_tullamarine ]</p>
The well-intentioned experimenter (and hapless third parties) may be exposed needlessly to unnecessary risk of a greater or lesser extent due to the simple fact that his/her technical background does not encompass lessons learnt earlier by the design and test industry.
Even those who ought to know better sometimes can fall foul of this trap. I recall one fatal test accident within a factory program some years ago where an ill-considered modification was being tried out as a hoped-for solution to an ongoing handling difficulty. The result ? ... two dead and one very seriously (and permanently) injured.
To me, if there is not some sort of sensible and competent peer-review assessment done prior to development, then the risk of mishap goes up unacceptably.
While I do not support the idea of excessive and oppressive paternalism in the process, there ought to be a balanced middle ground which protects most of the various stakeholders' desires and interests.
Or do we simply wish to enshrine the right of the individual occasionally to be stupid, wilfully reckless, negligent, or just unfortunately in the wrong mod at the wrong time ... ?
[ 06 January 2002: Message edited by: john_tullamarine ]</p>
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It's quite amazing how this topic has developed into a political/philosophical discussion.
Yes, I think it is one’s right to be “stupid, willfully reckless, negligent, or just unfortunately in the wrong mod at the wrong time.” The best thing government regulation can do in these situations is to make sure that the individual who undertakes a risky project does so without harming (or threatening to harm) others. In this respect, the FAA leads the world, and should be commended.
Nick, I understand your attitude towards government intervention. It’s pretty common in the aviation community. But you may not realize how good you have it working with the FAA. Try some other country sometime. (Of course, here in Canada we love the TC guys. They’re here to help us.)
Getting back to the original topic, the FAA offers several useful resources for the do-it-yourself flight tester. These have also been used by many a professional over the years. I suggest you read AC90-89A for example. You can find it at <a href="http://av-info.faa.gov/dst/amateur/" target="_blank">http://av-info.faa.gov/dst/amateur/</a> along with many other good documents.
<img src="wink.gif" border="0">
Yes, I think it is one’s right to be “stupid, willfully reckless, negligent, or just unfortunately in the wrong mod at the wrong time.” The best thing government regulation can do in these situations is to make sure that the individual who undertakes a risky project does so without harming (or threatening to harm) others. In this respect, the FAA leads the world, and should be commended.
Nick, I understand your attitude towards government intervention. It’s pretty common in the aviation community. But you may not realize how good you have it working with the FAA. Try some other country sometime. (Of course, here in Canada we love the TC guys. They’re here to help us.)
Getting back to the original topic, the FAA offers several useful resources for the do-it-yourself flight tester. These have also been used by many a professional over the years. I suggest you read AC90-89A for example. You can find it at <a href="http://av-info.faa.gov/dst/amateur/" target="_blank">http://av-info.faa.gov/dst/amateur/</a> along with many other good documents.
<img src="wink.gif" border="0">
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Ghengis the engineer wrote (excerpted, capitolization is Nick's for emphasis):
what in your opinion is the practical JUSTIFICATION for ALLOWING experimentation without design and testing control?, does it allow a better design to be reached quicker?, what is the safety record like? does the FAA accept data from UNQUALIFIED individuals in final approval of a mod or whole aircraft type?
Or is it really a plea from people who won't admit that they simply don't have the ability to comply with safety regulations?
Nick answers:
I certainly understand the wish to save people from their own stupidity (I support helmet laws and seat belt requirements, for example). I do oppose the concept of R&D being controlled by an august board of "esxperts" who know more than anyone else how and where to search for new answers. The capitolized words illustrate how deeply into the problem Ghengis's thoughts are.
Note the need to ALLOW someone to build something. Note that the burden of JUSTIFICATION is on the individual to show why he should be foolish enough to even dream of being smarter than the GOVERNMENT. Note the need to prove one's QUALIFICATIONS before one can be fortunate enough to actually practice any research! Neat concept.
Ghengis asks if this novel idea of free thought could lead to better R&D. I note that Igor Sikorsky, Art Young and Frank Whittle were thought a bit bonkers when the started out. The innovators in medical, communications, computer and many other scientific fields are too often not "expert" enough. Please review the Wright brothers detractors, as an example. It is human nature to explore, to innovate, and to risk where the rewards and challenges are great.
I believe one needs the Government's permission to build a flying machine only to the extent that it might become a public endangerment. One need not have to expose the design to any group of experts for other reasons, and it would be a terrific damper on our technological growth if that attitude were allowed to exist everywhere.
Once the design has matured, if it is to be sold for public consumption and at public risk, it must be independantly tested and approved, I certainly agree, but while it is in the hands of its inventor, let he or she bear some risk, as long as I don't have to involuntarily share it!
This seems to me to be not particularly libertarian, it is simply a basic tennent of government - govern only where needed.
what in your opinion is the practical JUSTIFICATION for ALLOWING experimentation without design and testing control?, does it allow a better design to be reached quicker?, what is the safety record like? does the FAA accept data from UNQUALIFIED individuals in final approval of a mod or whole aircraft type?
Or is it really a plea from people who won't admit that they simply don't have the ability to comply with safety regulations?
Nick answers:
I certainly understand the wish to save people from their own stupidity (I support helmet laws and seat belt requirements, for example). I do oppose the concept of R&D being controlled by an august board of "esxperts" who know more than anyone else how and where to search for new answers. The capitolized words illustrate how deeply into the problem Ghengis's thoughts are.
Note the need to ALLOW someone to build something. Note that the burden of JUSTIFICATION is on the individual to show why he should be foolish enough to even dream of being smarter than the GOVERNMENT. Note the need to prove one's QUALIFICATIONS before one can be fortunate enough to actually practice any research! Neat concept.
Ghengis asks if this novel idea of free thought could lead to better R&D. I note that Igor Sikorsky, Art Young and Frank Whittle were thought a bit bonkers when the started out. The innovators in medical, communications, computer and many other scientific fields are too often not "expert" enough. Please review the Wright brothers detractors, as an example. It is human nature to explore, to innovate, and to risk where the rewards and challenges are great.
I believe one needs the Government's permission to build a flying machine only to the extent that it might become a public endangerment. One need not have to expose the design to any group of experts for other reasons, and it would be a terrific damper on our technological growth if that attitude were allowed to exist everywhere.
Once the design has matured, if it is to be sold for public consumption and at public risk, it must be independantly tested and approved, I certainly agree, but while it is in the hands of its inventor, let he or she bear some risk, as long as I don't have to involuntarily share it!
This seems to me to be not particularly libertarian, it is simply a basic tennent of government - govern only where needed.
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A subject like this can not help but become a political / philosophical discussion. That is because it comes down to what the government should do to protect its citizens from themselves. At my EAA chapter one of our members built a beautiful two place airplane that he had placed a placard into which said , " Don't do anything stupid." Shortly after he flew the aircraft for the first time , he put a person in the back seat who was at least 290 pounds when there was a placard in the aircraft that stated "The limit of the rear seat is 165 pounds." Guess what? Stalled , Crashed , Two people dead. What government could have prevented this? Yes, the one that prevented flying of homebuilt aircraft. I am against helmets for mototcycles . I think its stupid not to wear one but if an unhelmeted person has an accident it didnt hurt someone else because that person didnt wear a helmet. Im against a law against unprotected sex. I think its stupid not to wear a (helmet ) and in this case it could hurt someone else but it is not a law that a government could enforce. So If a government cant enforce it they should not make laws against it. Basically its about freedom. I do realize that there is a basic attitude in Europe that governments should protect the citizens from themselves. That is the reason that so many of my friends who immigrated from Europe to the USA love it here .
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Yet, we have laws about wearing helmets and seatbelts, the risks of which are easy to understand. But it is proposed that there shouldn't be rules about aircraft design, the risks of which are very complex and need some expertise to understand.
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?
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Hoo boy are we getting off topic. But polzin has hit on a favorite topic of mine, and I just have to reply.
In an earlier post, I said that best thing for a government to do is to prevent one individual’s expression of free will (stupid or otherwise) from harming others. I would agree to no helmet laws, if I didn’t pay large taxes to support the medical treatment of people who don’t use helmets, or seatbelts, or who still smoke. It really pisses me off every pay stub when I think about how much of the money goes to keeping idiots on life support. I would support a law that allowed you to ride without a helmet as long as you opted out of government funded health care.
The FAA, and even TC, try to keep homebuilders from harming themselves, but they don’t make any judgement about what is a “useful” or “meaningful” test program. Useful and meaningful to who? That’s for the experimenter to say, not the government.
In an earlier post, I said that best thing for a government to do is to prevent one individual’s expression of free will (stupid or otherwise) from harming others. I would agree to no helmet laws, if I didn’t pay large taxes to support the medical treatment of people who don’t use helmets, or seatbelts, or who still smoke. It really pisses me off every pay stub when I think about how much of the money goes to keeping idiots on life support. I would support a law that allowed you to ride without a helmet as long as you opted out of government funded health care.
The FAA, and even TC, try to keep homebuilders from harming themselves, but they don’t make any judgement about what is a “useful” or “meaningful” test program. Useful and meaningful to who? That’s for the experimenter to say, not the government.
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I hate being coaxed to unlurk.
I think that there is some confusion here which needs to be addressed.
The Boeing 777 was an experimental. This allowed the development to occur with only engineering considerations at play. when these had honed down the best solution to a dilema the verification paperwork could then be commenced toward the final certification. this achieved economies by allowing paperwork only on the final design solutions.
Experimental Amateurbuilts are a whole 'nuther field. The basic tennet is that it is your personal right to build an aircraft and to test fly it, then go on to use it for enjoyment.
The amateur test flying will usually only lead to one aircraft beng involved and personal knowlege gain.
In dununda the ABAA streamlined certification for amateurbuilts saw almost no new designs. Of the hundred or so designs that have an ABAA (amateur built aircraft approval) most were american "experimental" designs accepted on the basis of safe history. dununda finally moved to experimental because the ABAA system was dead.
I think mixing the test flying considerations for commercial experimentals and for amateur experimentals is flawed. They have different purposes and outcomes as regards the number of produced aircraft and thus the public risk is different.
I have no problems with either occurring.
I have modified the homebuilt I fly, improved it and test flown the mods.
I think that there is some confusion here which needs to be addressed.
The Boeing 777 was an experimental. This allowed the development to occur with only engineering considerations at play. when these had honed down the best solution to a dilema the verification paperwork could then be commenced toward the final certification. this achieved economies by allowing paperwork only on the final design solutions.
Experimental Amateurbuilts are a whole 'nuther field. The basic tennet is that it is your personal right to build an aircraft and to test fly it, then go on to use it for enjoyment.
The amateur test flying will usually only lead to one aircraft beng involved and personal knowlege gain.
In dununda the ABAA streamlined certification for amateurbuilts saw almost no new designs. Of the hundred or so designs that have an ABAA (amateur built aircraft approval) most were american "experimental" designs accepted on the basis of safe history. dununda finally moved to experimental because the ABAA system was dead.
I think mixing the test flying considerations for commercial experimentals and for amateur experimentals is flawed. They have different purposes and outcomes as regards the number of produced aircraft and thus the public risk is different.
I have no problems with either occurring.
I have modified the homebuilt I fly, improved it and test flown the mods.
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In my EAA chapter there are two tech reps that will come out to view you project at any time. If they sign a statement at various stages of completion, then you get a discount from the insurance company. The FAA does require a final inspection by them or by a designee. Most often the FAA doesnt know what to look for and most of us use a designee especially if he has done inspections on similar aircraft. When I was building my homebuilt I listened to every comment and criticism of every person who walked into the shop. Even got the Fex EX truck driver interested.! If your curious........ My aircraft weights 1140 pounds empty and has a 310 HP engine. Even at the high elevation here in Denver it goes up quickly.