LSAs for IFR? Why Not?
Last weekend, a rep from Flight Design, Brian Boucher was in town with Dan Johnson to demo the CTLSi, with Rotax's new 912 iS engine. During the course of shooting video, something came up in the discussion that frequently does: Can you and should you fly LSAs under IFR? On the trip down from New England, Boucher told me he had run into a bit a weather and had to scud run under it for a while before eventually parking it. Like many of us, he's not comfortable filing and driving the thing through the clouds, although it's lavishly equipped enough to make child's play of such an effort.
I've had the same discussions with a number of people in the LSA community, from owners, to sales reps, to interested bystanders. This time, we decided to push to test, so we got out the CTLSi's POH. This is always amusing exercise because LSA POHs are world-class studies in equivocation. They give the word dissembling a bad name. The CTLSi's POH has words to this effect: "Flying it in IFR without the necessary training is extremely dangerous. As the pilot in command, you are responsible for the safety of your passenger as well as for your own safety. You are also responsible for the safety of uninvolved third parties. Avoiding dangerous situations is a pilot's first duty." However, a careful reading of the engine limitations reveals that Rotax prohibits IFR for the 912 engines.
I don't know about you, but I'm way good with the foregoing. It's essentially telling me not to do anything stupid and it's leaving it up to me to determine how to define stupid. Since I do not define flying in IMC within reason in an LSA as stupid, you can see where I'm going with this, which is that I wouldn't hesitate to fly in the clouds with a properly equipped LSA. Unfortunately, Rotax spoils the fun by requiring a Part 33 engine.
Otherwise, as I read it, properly equipped means it's supposed to have certain TSO'd equipment including basic radio navigation gear and gyros. Eastman Aviation, which makes a line of LSAs based on the Zenith line, agrees with this interp and will sell you an IFR-capable LSA, but it will have steam gauges instead of the very capable Dynon glass that's also available because the gyros are TSO'd and the glass isn't. If I were equipping an LSA specifically for IFR, I'd put the glass on the left and a TSO'd electric gyro on the right and probably never look at it.
When I covered the Renegade LSA a year ago, Doc Bailey, who runs the company, had the same outlook. Although ASTM recently issued guidance that new designs aren't to be approved for IFR, manufacturers of older ones are left to their own devices to approve IFR or not. Bailey's idea—a good one—is to simply amend the POH to approve IFR for the specific buyer of the airplane, contingent on training from the company. Perfectly sensible, no?
Then there's the ever-annoying "spirit" argument. The spirit being that LSAs were never intended for IFR flight, but are meant for sunny day excursions across down. Evolution is rapidly rendering this argument even more moot than it was the moment it was first advanced. For a sunny day excursion, why are we seeing $170,000 LSAs with dual-redundant glass, autopilots and traffic systems? Is all this going to dissolve if flown into a cloud? I doubt it.
Obviously, there are limits to what kind of weather an LSA can fly in and that requires judgment to negotiate, but that's no different than flying a 172 or a Cirrus in weather. You can't fly either of those in just anything. My idea of LSA IMC is no chance—or low chance—of icing or lightning and nothing too low. For me, that would be about 500-foot ceilings and at least 3 miles of visibility. I'm not too interested in a long slog in IMC, either, so low tops that I could get above would be another requirement. There are plenty of days that meet that requirement, but probably more that don't.
I actually like the POH's reminder to "avoid dangerous situations," which it leaves up to me to determine. That's the essence of being PIC. It further points out the responsibility to uninvolved third parties, which is a legalistic way of saying don't do anything that would put your little airplane into someone's living room. That's a good rule to live by; flying in a cloud of itself doesn't necessarily have any bearing on it.
I don't have a sense how many people are flying LSAs under IFR using these mushy, gray-as-a-ghost rules, but I suspect some are. If it's done sensibly and with restraint, why not?
The blog will be taking a little hiatus until after Christmas. I wish everyone the best for the holidays.