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Am i legal as an LSA?

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Jeff Fontenot

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This question is asked because of the issue brought up on another thread regarding Cubs used as dusters and sprayers may have had a gross weight change that would disqualify them from being flown as an LSA.

I think I am ok. As I study the logs a little closer My PA11 was sold to Cardwell Flight Academy in Bryan Texas (for $2445) on a mortgage along with several other airplanes in July of 1947. In January 1951, ACA form 305, it is still standard category. In June 1951 Mr Cardwell had it converted to Restricted category with a form ACA305 to be recertified under CAR 8. A form ACA-337 put a C85-12 (less starter and generator) and another form ACA-337 states “this aircraft has been modified in accordance with CAR 8” (over) with the following on the backside

“rear seat removed and 51 gallon tank for insecticide spraying installed. Wind driven pump installed on left landing gear. Tank placarded for capacity in pounds for 423 and 51 gallons. Aircraft marked “RESTRICTED” at entrance of cockpit. Modified aircraft flight checked on June 1, 1951 by Earl Burch commercial pilot # xxxxxx and found to safely controllable and to operate satisfactorily.” Then it has the signature of Earl Burch.

Then there is a Form ACA-309 with only the engine make and model and aircraft make, model, serial number and Registration number as N78629 Restricted and Type certificate indicated as 691 modified.

The speeds and weight sections of the form are all blank.


Then the reverse side says :

This aircraft has been modified under the provisions of CAR 8 as a special purpose agricultural and pest control aircraft.
(1) this aircraft shall not be operated in a manner which will endanger public life and property. The operator shall adjust the take-off weight to provide a safe margin of performance for the existing operating conditions, considering the take-off area, altitude, temperature and terrain for maximum capacities of hoppers and spray tanks and placards.
(2)Maneuvers shall be limited to those normally performed in agricultural operations.
(3) Agricultural and pest control operations shall not be conducted over denselt populated areas, in congested air lanes, or in the vicinity of busy airports where passenger transport operations are being conducted, unless the administrator finds it in the public interest to authorize such operations and has issued Certificate of Waiver or Authorization Form ACA663, permitting such operation
(4)Persons or cargo shall not be carried for compensation or hire.
(5) Persons other than the minimum required crew necessary for the agricultural operation shall not be carried during those operations.
(6) All crew members and passengers shall be provided with seats and safety belts installed in accordance with good aeronautical practices.


From the type certificate, the only spray option with a tank placard listed in pounds and gallons is option *613

*613. Crop spraying installation (Models J3C-65 and PA-11 only) +56 lb. (+23)
Martin Airways Model A in accordance with Martin Airways, Inc., Municipal Airport,
Monmouth, Illinois, Installation Instructions dated March 1, 1949.
The following placards are required:
(a) On instrument panel in full view of pilot: "All acrobatics including spins prohibited
when spray equipment is installed."
(b) On tank "Maximum capacity ____ gal. water or ____ lb." Values to be determined from
weight and balance of aircraft.
Eligible for certification in Normal and/or Restricted Category (See NOTE 6).
When certificated in Restricted Category in accordance with NOTE 6, the C. G. range is
(+11.5) to (+19.4) and the following static r.p.m. limits at maximum permissible throttle
setting apply (no additional tolerance permitted):
(a) With Items 311C (1 through 6) and Item 311D (1 through 3) engines and Items 2, 4, and
101 propellers: Not over 2250, not under 2000.
(b) With Item 311C(8) engine and Items 6 or 101 propellers: Not over 2425, not under 2000.
(c) With Item 311C(7) engine and Items 6 or 101 propellers: Not over 2100, not under 2000.

No where do I see any thing that specifically increased the gross weight. The Operation Limitations implies the operator is responsible to load to insure a safe margin of performance.

There are no maintenance records between 1951 and 1960 when it shows up in the Normal Category again. Evidently the rear seat was re-installed since it was sold to a flight school.

The registration path has some information. In May of 1953, Mr. Cardwell sold the aircraft to an individual in Wichita Fall, Tx. Then it was sold again in Jan. 1954 back to an individual in Bryan, Tx. Then it was sold to flight school in Dallas, Tx in March 1957. In May of 1960 sold to an individual again and it has been in private hands ever since.

I do not know any thing about CAR 8. Could this have any impact in the gross weight? If it does not specify a gross weight increase, I think I am still legal to fly as an LSA.


Jeff Fontenot
 

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