CTSW classification and SEP revalidation
 

Hi all,

I've found a lot of opinions on the internet suggesting that hours in a microlight may not count towards those needed for PPL(a) revalidation. Indeed, last year there are opinions on the Internet that this may be (or has since been) changed.

According to the new revised ANO, according to table 1 here - http://www.legislation.gov.uk/uksi/2016/765/schedule/8/made - the following statement is made regarding revalidation requirements for SEP (land):

"FCL.740.A (b)(1) and (4) of Part-FCL, provided a SEP aeroplane with three axis control system is used."

Would I be correct in interpreting this to mean that hours in a CTSW would count? Or would a CTSW not be counted as "SEP aeroplane" - I think it would be as it does not meet the criteria for being classed as a microlight - https://www.caa.co.uk/General-aviation/Aircraft-ownership-and-maintenance/Types-of-aircraft/Microlights/

On this basis, I believe I would be legally able to count hours in this aircraft towards my PPL revalidation, and fly legally into IMC (with IMC rating).

Would anybody disagree?

Thanks!

The CTSW is unambiguously a microlight.

That it is more sophisticated and outperforms many SEPS is, sadly, irrelevant.

G

But from the CAA web page on microlights:

"A microlight is an aeroplane designed to carry either one person or two people (and not more) and which has a maximum total weight authorised (MTWA) not exceeding:

300 kg for a single seat landplane.
390 kg for a single seat landplane for which a UK Permit to Fly or Certificate of Airworthiness was in force prior to 1 January 2003
450 kg for a two seat landplane
330 kg for a single seat amphibian or floatplane
495 kg for a two seat amphibian or floatplane
A microlight must also have either a wing loading at the maximum weight authorised not exceeding 25 kg per square metre or a stalling speed at the maximum weight authorised not exceeding 35 knots calibrated speed.

All UK registered aeroplanes falling within these parameters are Microlight aeroplanes."

Regarding the part in bold ("either/or") -

*Stall speed (according to the manual which I found on the Internet) of 39kts with 40 degrees of flaps, obviously greater with wings clean.

*wing loading - wing surface area is 9.98m2. At max weight of 450kg, makes it roughly 45kg per m2.

Does this not convince you, from a legal/technical standpoint, that the CTSW is not in fact a microlight?

I just looked up a handful of CTSWs on G-INFO and they all came as Microlights. If you find one that is not listed as such let us know....................................

http://www.bmaa.org/files/bm72_1_flight_design_ctsw.pdf

Indicated and calibrated airspeed are of course not the same thing.

G

[hypothetical] Now if I were to come up with a CTSW with a MTOW of 600 kg?

Not sure if this is possible for this particular airframe, but AIUI several CZ-made airframes are available with MTOW of either 450/472,5 kg or 600 kg.

More generally, I think one cannot speak of "THE" CTSW but ought rather to consider individual airframes, each with their own paperwork.

Ah good one G! So it is indeed a microlight owing to the calibrated and not indicated stall speed.

Yes according to the manual, the max weight seems to vary depending on some kind of registration? I don't really understand though.

Just a final quick one as I can't remember the rules - can such a microlight legally enter controlled airspace (excluding class A) in VFR so long as it has a radio and transponder (and clearance!)?

Thanks guys, just the discussion/clarification I was after!

Re: licensing / revalidation, I had exactly this issue when I joined a CT syndicate.

As an ATPL holder, I could fly the CT using the PPL privileges of the licence, but only with differences training, and the hours accrued would not count towards the PPL reval every two years.

In the end, I went the NPPL route, where I did training required on type up to, and including the skills test.

Now I'm on a keyboard not my phone, I can answer a bit more fully.

Firstly, the CTSW is a super little aeroplane, with sparkling performance, and don't let me talk you out of flying one. If you've not flown anything that slippery, do get a checkout from an instructor familiar with the type, as it has a few interesting characteristics, mainly to do with energy management, that can catch the unwary.

The current microlight definition is 300kt / 450kg, allowing another 5% for a ballistic parachute system and another 10% for floats (both have to be fitted for that to count). So the CTSW actually has an MTOW of 472.5kg so long as the optional BRS is fitted, which it usually is in my experience. The old 25kg/m^2 wing loading limit was based upon the very early very crude aeroplanes, and hasn't been in routine use since about 1999. Pretty much anything since then, when the UK converged with the European norm for microlight definition, has used the Vso<=35kCAS definition, and it's worked well enough - but there was no reason to remove the old version, since there are still a fair number of old aeroplanes flying safely, and nobody's life is going to be improved by flight testing them to find out what the calibrated stall speed really is.

Some other countries may have different numbers for their microlight definition, and for example the Germans apply lower structural safety factors than the British so the same aeroplane can be certified there to a higher MTOW than in the UK. Is that wise? Well, I'll just say that it's the British who are copying the international norms for larger aeroplanes, and the Germans who are reducing the safety margins.

In the UK, use the BMAA TADS or HADS - they're all on the BMAA website to download, and those are definitive information (along with the approved POH - something downloaded from the net may not be the approved version of course).

A microlight can potentially enter any airspace, with permission and the right equipment on board. What it can't do of course is fly IFR, so trying to enter class A airspace on any terms than SVFR is probably going to end in tears and I really wouldn't recommend trying. Entering class D on the other hand, microlight pilots do all the time, and even the transponder is just "nice to have", just 2-way VHF.

Certified part 23 aeroplanes have a requirement that the ASI must be within 3 knots or 5% of CAS. Microlights have no such requirement, so the ASI can be quite a long way off. This really isn't a safety issue, as the manual and placards will be written in IAS, not in CAS and you just fly it to the numbers in the POH.

G

Great, very helpful responses, many thanks.

So yes I think my issue would be about PPL revalidation. The attractiveness of joining a CT group is clearly the cheap flying, and in a lovely little plane. But this is negated by the hours I would still need to put in a regular SEP aircraft to keep the license valid, or the skills test I would need to do every two years (not necessarily a problem, still thinking about it!).

Hmm.. I asked at the Flyer exhibition in Telford last year, whether one would be able to maintain a PPL(A) on an SSDR. The answer was 'no' but that this may shortly be changed. Coming from somebody who was trying to sell SSDRs that should perhaps be taken with a pinch of salt, but I wonder whether there are any signs that this may change for microlights as well?

This looks interesting. I wonder if it will ever go into production, at a sensible price.
https://www.youtube.com/watch?v=MitadcbEijk

You have to remember that an SEP Class Rating is just that! It gives pilots the privileges to fly any SEP Class aircraft with very simple familiarisation or differences training.

Hence keeping an SEP Class Rating valid on Microlight flying alone is unlikely to be acceptable to a competent authority - which is why the consolidated NPPL revalidation criteria for NPPL holders with Microlight and/or SLMG and/or SSEA Class Ratings allows them to complete their total flight time requirements in any of the classes for which they hold a rating, but they must fly at least one hour in each of such classes.

Which has proved perfectly safe; no-one is going to rent out an aircraft to a pilot without any recency in the class and any owner will probably fly rather more than 1 hour every 2 years in the aeroplane.

IAOPA(Europe) has proposed something similar in its NPA 2014/29(A) response (18 months ago....), but we are still waiting for EASA to release the Comment Response Document, which is long overdue.

I don't dispute that that's the legal position - but in a world that contains the CTSW and the Evans VP1, it is nonetheless silly !

G

Why?


................

Because you can maintain your SEP rating on a VP1, with three steam driven instruments and performance that just about out-climbs a bicycle up a hill, and can't on a CTSW with 120kts cruise, a suite of electronic instruments and a good enough climb rate to give most helicopter pilots a nose bleed.

(And equally a microlight pilot can fly the CTSW with no additional training, but needs a whole extra rating to fly the VP1).

G

Would you prefer that the CTSW should be regulated as an SEP Class aeroplane?

If not, I suggest that you simply accept the status quo and encourage microlight designers to achieve the best they can within current rules...

Don't kill the golden goose!

I know and accept the system (well, more or less), but it doesn't stop me pointing out the absurdities of it. You could certainly make a strong case for allowing SEP ratings to be maintained on some microlights, or hours on those aircraft to be as valid towards professional licences as on, say, a C150.

G

I asked the CAA head of GA at Aeroexpo last year and was told they were going to make some changes so the microlight hours would count, but they said that this could present problems with pilots flying to europe to a country which does,nt allow microlight hours to be counted. CAP804 us to say that hours flown in microlights did not count towards SEP but CAP804 has now been cancelled.
So the only thing left is the new ANO which as you said "FCL.740.A (b)(1) and (4) of Part-FCL, provided a SEP aeroplane with three axis control system is used."

I have also seen this mentioned in another forum that microlight 3 axis hours now count towards SEP....

But I don't think a microlight is an "SEP aeroplane" (correct me if I'm wrong) so technically the revised ANO effectively says those hours still do not count. I have actually emailed the CAA for clarification so when I get a response I'll update the thread (though apparently it may take weeks!)

I think that those changes may only apply to UK / NPPL licences, not to EASA licences, where this isn't in the CAA's gift - but I've certainly heard similar suggestions.

G

When I applied for a stand alone FAA licence and asked if the hours in my microlight CH601UL counted, the response was "It's an airplane, isn't it?". I was left in no doubt that it was a stupid question.

I suppose that would perhaps open up a route where you could keep current on an SSDR then painlessly go back to flying a group A permit aircraft?

When we heard that EASA hadn't changed its views concerning microlight / ultralight aeroplanes in its NPA 2014/29 proposals, IAOPA (Europe) proposed an amendment to FCL.010, introducing a formal definition of a '3-axis' control system as well as associated amendments to FCL.035 and FCL.740.A.

Our proposal is that flight time in certain microlight / ultralight aeroplanes should be allowable towards revalidation of SEP Class Ratings, provided that the aircraft is fitted with a three-axis control system, a non-flexible wing and is not foot-launched, also that at least 1 hour of PIC time and 6 take-offs and landings are completed in the validity period in aircraft of the same class which are not microlight / ultralight.

I just hope that the CAA won't blunder ahead with another poorly thought out 'national' proposal before the Comment Response Document for NPA 2014/29 is published - otherwise they'll simply cause even more confusion than they already have with their medical declaration system....:ugh:

Well yes - I have two different totals in my logbook - the EASA total and FAA total. It keeps the world happy.

G