CAA CONSULTATION: CAP 482, British Civil Airworthiness Requirements (BCAR) – Section S – Small Light Aeroplanes

UK CAA CONSULTATION:
CLICK HERE TO RESPOND

Introduction

The UK CAA wants to know what you think about the proposed changes in BCAR Section S mainly relating to 600kg Light Sport Microlights. There are a multitude of improvements allow you to fly heavier, faster and likely further than ever before, but without losing sight of our roots and heritage. This article outlines the collaborative project, highlights the key changes and most importantly explains how you as a pilot, owner and enthusiast can have your say on the proposals as well as making some of your own.

The Project

The project was fronted by the CAA and the working group mainly consisted of Thomas Weir CAA (editor), Jonathan Howes CAA (who was involved in the original formation of Section S) and Ewan Weston CAA (current BMAA Design Surveyor), Roger Pattrick (BMAA Chief Technical Officer), Ben Syson (LAA Head of Design) and also received input from manufacturers and subject matter experts.

BCAR Section S (Small Light Aeroplanes) is the main certification code for microlight aeroplanes in the UK and specifies the initial airworthiness requirements as well as acceptable means of compliance. The codes technical requirements have been revised to reflect the increased maximum take-off mass and stall speed limits brought into UK law following the 2021 revision of the UK microlight aeroplane definition

What are the changes?

  • Higher MTOW (600kg landplane, 650kg amphibian) and corresponding empty weights
  • Regulated single-seaters for aircraft with a stall speed >35 knots or MTOW over 300kg up to the same MTOW limits as two-seaters
  • Higher stall speed, now up to 45 knots
  • Increase cockpit loadings. Designers should now work to at least 100kg per seat (was 86kg) and 200kg (from 172kg) total for two-seaters
    → Single-seaters for a pilot weight range of between 70kg and 110kg
  • New minimum pilot weight not above 70kg, rather than 55kg.
    → Designers can still opt for 55kg or lower of course.
  • Gust loading requirements for A/C heavier than 475kg and Vd (Design Dive Speed) greater than 140 knots.
  • Firewalls now have to be fireproof (1100°C for a minimum of 15 mins), previously 5 mins.
  • Spinning has changed, led by the LAA, and some new requirements for EASA CS-23 proposed
  • Composite Super factors now have a different AMC (Acceptable Means of Compliance) and are specifically listed in paragraph S619.
  • Ground loads (undercarriage) are now the same as EASA CS-VLA. 
    → Most manufacturers were using this rather than the previous Section S.
  • Fuel strainer requirements clarified (same as CS-VLA).
  • Engine installation in the airframe should now also meet the engine manufacturer's requirements.

 

To align with Czech (UL-2) and German (LTF-UL):

  • Minimum stick forces and gradient reduced.
  • Flap load factor reduced to 0G & +2G (limit load) 0G & +3G (ultimate load), previously this was normal range (-3G to +6G ultimate).
  • Flutter prevention/damping can still be demonstrated by flight or analysis/ground testing, the latter common in Europe.
  • Airframe mounting points for BPRS (Ballistic Parachute Recovery System) or AMTPRS (Airframe Mounted Total Parachute Recovery System) installations must demonstrate sufficient strength to react to deployment loads. Falling attitude 'on the chute' must be assessed as suitable. → Seat & harness shock loads – ensure the seat can cope with the deceleration.
  • The Max error of Air Speed Indicator showing Indicated Air Speed (IAS) +/- 8km/h or +/- 5%, when compared to Calibrated Air Speed (CAS).


A highlighted (red underline indicates change) and full copy of the new consultation edition is available here (1.4mb download):

British Civil Airworthiness Requirements Section S - Small Light Aeroplanes Issue 8 Consultation Edition


Thoughts & ideas for consultation feedback

  • BMAA did suggest changing the name of Section S from Small Light Aeroplanes to Microlights, but it was not accepted.
  • A significant BMAA aim was to increase alignment with Czech (UL-2) and German (LTF-UL). A key remaining area where the UK differs is spinning (neither of the mentioned European Microlight codes require spin testing).
    • Development of other and new Acceptable Means of Compliance.
  • Max empty weight and BPRS:
    • For future purposes, it might be handy to have the ability to increase Max empty weight (not MTOW) if an owner wishes to fit or upgrade their BPRS.
    • BMAA also prefers the previous section text for BPRS testing compared to the new wording (see S2085).
  • Lower Max seat load of say 90kg from 472.5-525kg MTOW, alleviating issues for designers in this sweet spot.

 

BMAA thanks CAA for collaborating with us on this project. It is paving the way for UK Microlight expansion without impacting previous or current certifications and, at the same time, making future ones easier


When does the consultation close?

 On the 19th of August 2022, so if you wish to help improve the future of the UK Microlight industry, please respond now.

 How to respond?

1.    Use the online form here Online Survey

2.    Simply email your comments to ga@caa.co.uk with 'CAP 482 consultation response' as the subject line.

If you choose to respond to the CAA consultation by email, please also CC technical.office@bmaa.org so BMAA can also gather feedback and gauge opinion of the proposed changes.


EASY OPTION FOR RESPONDING:

If you agree with the section above labelled 'Thoughts & ideas for consultation feedback' you can simply click the link below for a template email ready to send to the CAA:

TEMPLATE EMAIL READY TO SEND

Even if the deadline expires, we still recommend sending a response.