I spoke with Bill Moyes a few days ago when he called from Australia to try to "clear up" any issue regarding the future of the Dragonflies as reported previously (http://ozreport.com/11.190#3). He was going to call Tracy Tillman after speaking with me to be sure he understood what he needed to do to produce an aircraft that could continue to be used for towing hang gliders. I asked Tracy what Bill had to say. Here's his report:

I gave to him to some of the FAA regulations and FAA forms for S-LSA and E-LSA kit certification, described the process for him a bit, and gave him the name of the EAA's point person on the issue. Ironically, when he called, I was in the process of helping Aerola with this too, for their Alatus and Alatus-M gliders.

Bill's previous preparation and existing documentation for certification of the Dragonfly in other countries should make S-LSA (fully complete aircraft) certification and E-LSA (kit) certification in the US much easier for him.

He may have been considering a need to develop documentation to prove that the Dragonfly would meet the 51% build rule to qualify as a legal AB-Experimental kit -- but that would not serve much purpose, as an AB-Experimental aircraft can not be used for towing. The only experimental/kit that can be used for towing is an E-LSA, and an E-LSA does not have to meet the 51% build rule, either.

I asked Tracy a few questions:

Just so I understand. In order to tow hang gliders with an aircraft manufactured after January 31st, 2008 the manufacturer needs either:

1. S-LSA certification of that aircraft.

2. E-LSA certification of the kit (and then put together by whom or does it matter?)

3. Certification as a general aviation aircraft.

Right?

It would seem that Bill is going for E-LSA certification and that then Bobby is going to put the aircraft together at the customer's site (or at Quest Air). Is this kosher?

Tracy wrote back:

Correct on # 1 and # 2, per http://www.sportpilot.org/learn/sp_rule.pdf

The builder of an E-LSA kit must complete at least 1% of the construction, meaning that the factory can do up to 99% of the work. (This is a paraphrase of Dan Johnson's article in EAA Sport Pilot Magazine, August 2005, p.38:)

The FAA will allow the factory to create factory completion centers to provide assistance to builders for the completion of their E-LSA kits. (This is a paraphrase of Dennis Demeter's article in Ultralight Flying Magazine, Nov. 2003, p. 20.)

So, it looks like it is possible for Bill Moyes to have one or more Dragonfly E-LSA factory completion centers here in the US.

Technically, for #3 if you are talking about towing hang gliders, it would be better to say: "standard category certified LSA-qualified aircraft" (not general aviation aircraft).

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