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hawk(at)compuplus.net Guest
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Posted: Fri May 11, 2007 8:53 pm Post subject: RV-9 Certified As E-LSA |
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A current thread in Doug Reeve's VAF Forums (and a First-Flight report on Van's site) concerns the certification of an RV-9 in the ELSA Category. I can't find any reference to the mechanism of such a certification in the Final Rule on SP/LSA published by the FAA. Indeed, all the references I have run across support Ron Wanttaja's summary in his May 2005 'Kitplanes' article:
"There are three basic ways an aircraft can receive an ELSA airworthiness certificate: (1) conversion of a former two-seat ultralight trainer (through early 2008), (2) construction of the aircraft from an ELSA kit or plans, and (3) conversion of an existing SLSA.
It takes no FAA approval to put together an Ex/AB kit to sell to other builders. A potential ELSA manufacturer, however, must build a prototype aircraft, ensure it meets the LSA concensus standards, pass the FAA inspection and receive the SLSA certificate. At that point, the manufacturer can either begin producing ready-to-fly SLSAs or ELSA kits."
Can anyone comment on this apparent discrepancy, particularly from the Fed side?
Hawkeye Hughes
RV-3 Skyote
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mrobert569(at)hotmail.com Guest
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Posted: Mon May 14, 2007 12:30 pm Post subject: RV-9 Certified As E-LSA |
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Hawk,
it is not supposed to be a discrepancy. Category 1 that you talk about is for existing light-sport aircraft. That has created somewhat of a loophole. It was designed for existing ultra-lights, but also was meant to include those folks already building an otherwise amateur-built aircraft at the time this new rule took effect that have not had the chance to get a letter of compliance from the manf. but otherwise met the rule/definition of a light-sport aircraft. If the builder of an RV-9 was able to convince an inspector that his aircraft could not/would not go faster than 120 kts in cruise and could stall at 39 knots or less then he was eligible for an experimental light-sport certificate. The up side is he can operate it with only a driver's license instead of a medical and will get away with a few less flight test hours. The down side is he will have to go to a 16 hour school somewhere in order to qualify for the repairman cert.
Mike Robertson
Das Fed
Quote: | From: hawk(at)compuplus.net
To: rv-list(at)matronics.com
Subject: RV-9 Certified As E-LSA
Date: Fri, 11 May 2007 22:49:50 -0600
A current thread in Doug Reeve's VAF Forums (and a First-Flight report on Van's site) concerns the certification of an RV-9 in the ELSA Category. I can't find any reference to the mechanism of such a certification in the Final Rule on SP/LSA published by the FAA. Indeed, all the references I have run across support Ron Wanttaja's summary in his May 2005 'Kitplanes' article:
"There are three basic ways an aircraft can receive an ELSA airworthiness certificate: (1) conversion of a former two-seat ultralight trainer (through early 2008), (2) construction of the aircraft from an ELSA kit or plans, and (3) conversion of an existing SLSA.
It takes no FAA approval to put together an Ex/AB kit to sell to other builders. A potential ELSA manufacturer, however, must build a prototype aircraft, ensure it meets the LSA concensus standards, pass the FAA inspection and receive the SLSA certificate. At that point, the manufacturer can either begin producing ready-to-fly SLSAs or ELSA kits."
Can anyone comment on this apparent discrepancy, particularly from the Fed side?
Hawkeye Hughes
RV-3 Skyote
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jbker(at)juno.com Guest
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Posted: Mon May 14, 2007 1:59 pm Post subject: RV-9 Certified As E-LSA |
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Mike,
I was given the opinion at SnF by both the FAA and EAA that there was no distinction on FAA records whether an amateur built exp was an airplane or a LSA. Also that there was nothing that a kit builder did to say which is was and it was up to the builder to decide if it qualified as an LSA to be flown by a driver's license medical pilot.
Was I mislead??
Bernie Kerr, selling 9A and waiting on 12A. [quote][b]
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mrobert569(at)hotmail.com Guest
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Posted: Mon May 14, 2007 2:34 pm Post subject: RV-9 Certified As E-LSA |
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Bernie,
You were not mislead under the current rules. BUT, after January 31, 2008 there is going to be some changes. On that date the category 1 existing aircraft certification possibilities will go away. After that date you will have to prove that the aircraft is LSA compliant, be it a kit or pre-built, via a letter of compliance from the aircraft manufacturer. So if you have an aircraft you want to get into LSA, you better get on the stick.
Now, with that being said, that will not change anything about operating an aircraft under the LSA rules, just the certification rules.
Mike Robertson
Quote: | From: jbker(at)juno.com
Date: Mon, 14 May 2007 21:57:08 +0000
To: rv-list(at)matronics.com
Subject: RE: RV-9 Certified As E-LSA
Mike,
I was given the opinion at SnF by both the FAA and EAA that there was no distinction on FAA records whether an amateur built exp was an airplane or a LSA. Also that there was nothing that a kit builder did to say which is was and it was up to the builder to decide if it qualified as an LSA to be flown by a driver's license medical pilot.
Was I mislead??
Bernie Kerr, selling 9A and waiting on 12A.
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khorton01(at)rogers.com Guest
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Posted: Mon May 14, 2007 4:21 pm Post subject: RV-9 Certified As E-LSA |
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Where did the 39 kt stall requirement come from? The light sport
aircraft definition in FAR 1.1 says 45 kt stall, without the use of
lift-enhancing devices.
Kevin Horton
On 14 May 2007, at 16:30, Mike Robertson wrote:
Quote: | Hawk,
it is not supposed to be a discrepancy. Category 1 that you talk
about is for existing light-sport aircraft. That has created
somewhat of a loophole. It was designed for existing ultra-lights,
but also was meant to include those folks already building an
otherwise amateur-built aircraft at the time this new rule took
effect that have not had the chance to get a letter of compliance
from the manf. but otherwise met the rule/definition of a light-
sport aircraft. If the builder of an RV-9 was able to convince an
inspector that his aircraft could not/would not go faster than 120
kts in cruise and could stall at 39 knots or less then he was
eligible for an experimental light-sport certificate. The up side
is he can operate it with only a driver's license instead of a
medical and will get away with a few less flight test hours. The
down side is he will have to go to a 16 hour school somewhere in
order to qualify for the repairman cert.
Mike Robertson
Das Fed
From: hawk(at)compuplus.net
To: rv-list(at)matronics.com
Subject: RV-9 Certified As E-LSA
Date: Fri, 11 May 2007 22:49:50 -0600
A current thread in Doug Reeve's VAF Forums (and a First-Flight
report on Van's site) concerns the certification of an RV-9 in the
ELSA Category. I can't find any reference to the mechanism of
such a certification in the Final Rule on SP/LSA published by the
FAA. Indeed, all the references I have run across support Ron
Wanttaja's summary in his May 2005 'Kitplanes' article:
"There are three basic ways an aircraft can receive an ELSA
airworthiness certificate: (1) conversion of a former two-seat
ultralight trainer (through early 2008), (2) construction of the
aircraft from an ELSA kit or plans, and (3) conversion of an
existing SLSA.
It takes no FAA approval to put together an Ex/AB kit to sell to
other builders. A potential ELSA manufacturer, however, must build
a prototype aircraft, ensure it meets the LSA concensus standards,
pass the FAA inspection and receive the SLSA certificate. At that
point, the manufacturer can either begin producing ready-to-fly
SLSAs or ELSA kits."
Can anyone comment on this apparent discrepancy, particularly from
the Fed side?
|
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ceengland(at)bellsouth.ne Guest
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Posted: Mon May 14, 2007 4:24 pm Post subject: RV-9 Certified As E-LSA |
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Hi Mike,
The info below seems to imply one of two things. Either there's an easy
out, since the builder is the manufacturer, or we are sliding down that
slippery slope where parts sellers become manufacturers, with all the
legal/liability ramifications.
If I build the a/c, shouldn't I, as the manufacturer, be the one to
supply the letter of compliance?
If I scratch build a Cub or Taylorcraft-like plane from plans, who will
be able to supply the letter of compliance?
Or are you saying that the plane would simply be an experimental
(instead of E-LSA) with gross weight & top speed set to comply with the
LSA limits, then we can operate that plane under LSA rules?
Thanks,
Charlie
Mike Robertson wrote:
Quote: |
Bernie,
You were not mislead under the current rules. BUT, after January 31,
2008 there is going to be some changes. On that date the category 1
existing aircraft certification possibilities will go away. After that
date you will have to prove that the aircraft is LSA compliant, be it a
kit or pre-built, via a letter of compliance from the aircraft
manufacturer. So if you have an aircraft you want to get into LSA, you
better get on the stick.
Now, with that being said, that will not change anything about operating
an aircraft under the LSA rules, just the certification rules.
Mike Robertson
------------------------------------------------------------------------
From: jbker(at)juno.com
Date: Mon, 14 May 2007 21:57:08 +0000
To: rv-list(at)matronics.com
Subject: RE: RV-9 Certified As E-LSA
Mike,
I was given the opinion at SnF by both the FAA and EAA that there
was no distinction on FAA records whether an amateur built exp was
an airplane or a LSA. Also that there was nothing that a kit builder
did to say which is was and it was up to the builder to decide if it
qualified as an LSA to be flown by a driver's license medical pilot.
Was I mislead??
Bernie Kerr, selling 9A and waiting on 12A.
|
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mjurotich(at)hst.nasa.gov Guest
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Posted: Tue May 15, 2007 5:06 am Post subject: RV-9 Certified As E-LSA |
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Build your airplane as an experimental and set the gross weight at
1320 or less and put on a prop that maxs top speed at 120 knots.
Then a certificated pilot with a medical can fly it as experimental
amateur built and LSA pilot can fly it as an LSA. Just like a 1946
Aeronca Champ!
Matthew M. Jurotich
e-mail mail to: <mjurotich(at)hst.nasa.gov>
phone : 301-286-5919
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mrobert569(at)hotmail.com Guest
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Posted: Tue May 15, 2007 5:50 am Post subject: RV-9 Certified As E-LSA |
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Sorry, Someone distracted me right when I was typing this. You are correct. It is 45 knots.
Mike
> From: khorton01(at)rogers.com
Quote: | Subject: Re: RV-9 Certified As E-LSA
Date: Mon, 14 May 2007 20:20:30 -0400
To: rv-list(at)matronics.com
--> RV-List message posted by: Kevin Horton <khorton01(at)rogers.com>
Where did the 39 kt stall requirement come from? The light sport
aircraft definition in FAR 1.1 says 45 kt stall, without the use of
lift-enhancing devices.
Kevin Horton
On 14 May 2007, at 16:30, Mike Robertson wrote:
> Hawk,
>
> it is not supposed to be a discrepancy. Category 1 that you talk
> about is for existing light-sport aircraft. That has created
> somewhat of a loophole. It was designed for existing ultra-lights,
> but also was meant to include those folks already building an
> otherwise amateur-built aircraft at the time this new rule took
> effect that have not had the chance to get a letter of compliance
> from the manf. but otherwise met the rule/definition of a light-
> sport aircraft. If the builder of an RV-9 was able to convince an
> inspector that his aircraft could not/would not go faster than 120
> kts in cruise and could stall at 39 knots or less then he was
> eligible for an experimental light-sport certificate. The up side
> is he can operate it with only a driver's license instead of a
> medical and will get away with a few less flight test hours. The
> down side is he will have to go to a 16 hour school somewhere in
> order to qualify for the repairman cert.
>
> Mike Robertson
> Das Fed
> From: hawk(at)compuplus.net
> To: rv-list(at)matronics.com
> Subject: RV-9 Certified As E-LSA
> Date: Fri, 11 May 2007 22:49:50 -0600
>
> A current thread in Doug Reeve's VAF Forums (and a First-Flight
> report on Van's site) concerns the certification of an RV-9 in the
> ELSA Category. I can't find any reference to the mechanism of
> such a certification in the Final Rule on SP/LSA published by the
> FAA. Indeed, all the references I have run across support Ron
> Wanttaja's summary in his May 2005 'Kitplanes' article:
>
> "There are three basic ways an aircraft can receive an ELSA
> airworthiness certificate: (1) conversion of a former two-seat
> ultralight trainer (through early 2008), (2) construction of the
> aircraft from an ELSA kit or plans, and (3) conversion of an
> existing SLSA.
>
> It takes no FAA approval to put together an Ex/AB kit to sell to
> other builders. A potential ELSA manufacturer, however, must build
> a prototype aircraft, ensure it meets the LSA concensus standards,
> pass the FAA inspection and receive the SLSA certificate. At that
> point, the manufacturer can either begin producing ready-to-fly
> SLSAs or ELSA kits."
>
> Can anyone comment on this apparent discrepancy, particularly from
> the Fed side?
======================
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mrobert569(at)hotmail.com Guest
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Posted: Tue May 15, 2007 6:01 am Post subject: RV-9 Certified As E-LSA |
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Charlie,
After January 31, 2008 you last paragraph is exactly what will happen. In order for a kit manufacturer to issue a letter of compliance he must have submitted the design to the Standardization board to proof compliance and have received concurrence from them. Even under the current rules, any aircraft that meets the requirements of a light-sport aircraft under FAR 1 may be operated as a light-sport aircraft. With that in mind then a person with a private license and a current medical could be operating IFR one day, then the next day when his medical expires he could operating the exact same aircraft as a light-sport providing it meets the definition.
Mike Robertson
> Date: Mon, 14 May 2007 19:24:19 -0500
Quote: | From: ceengland(at)bellsouth.net
To: rv-list(at)matronics.com
Subject: Re: RV-9 Certified As E-LSA
--> RV-List message posted by: Charlie England <ceengland(at)bellsouth.net>
Hi Mike,
The info below seems to imply one of two things. Either there's an easy
out, since the builder is the manufacturer, or we are sliding down that
slippery slope where parts sellers become manufacturers, with all the
legal/liability ramifications.
If I build the a/c, shouldn't I, as the manufacturer, be the one to
supply the letter of compliance?
If I scratch build a Cub or Taylorcraft-like plane from plans, who will
be able to supply the letter of compliance?
Or are you saying that the plane would simply be an experimental
(instead of E-LSA) with gross weight & top speed set to comply with the
LSA limits, then we can operate that plane under LSA rules?
Thanks,
Charlie
Mike Robertson wrote:
>
>
>
> Bernie,
>
> You were not mislead under the current rules. BUT, after January 31,
> 2008 there is going to be some changes. On that date the category 1
> existing aircraft certification possibilities will go away. After that
> date you will have to prove that the aircraft is LSA compliant, be it a
> kit or pre-built, via a letter of compliance from the aircraft
> manufacturer. So if you have an aircraft you want to get into LSA, you
> better get on the stick.
>
> Now, with that being said, that will not change anything about operating
> an aircraft under the LSA rules, just the certification rules.
>
> Mike Robertson
>
> ------------------------------------------------------------------------
> From: jbker(at)juno.com
> Date: Mon, 14 May 2007 21:57:08 +0000
> To: rv-list(at)matronics.com
> Subject: RE: RV-9 Certified As E-LSA
>
> Mike,
> I was given the opinion at SnF by both the FAA and EAA that there
> was no distinction on FAA records whether an amateur built exp was
> an airplane or a LSA. Also that there was nothing that a kit builder
> did to say which is was and it was up to the builder to decide if it
> qualified as an LSA to be flown by a driver's license medical pilot.
> Was I mislead??
> Ber=============
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jbker(at)juno.com Guest
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Posted: Tue May 15, 2007 9:09 am Post subject: RV-9 Certified As E-LSA |
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Mike,
I must be ready for LSA , I'm more confused now. Lets only talk about after Jan 31/08 since the 12 kit will not be out until about that date :>)
Will there be 3 categories of LSA? 1.Amateur built aircraft that meet LSA standards as certified by the builder 2. ELSA that will be certified by the FAA as LSA qualified and has to be built with no mods 3. LSA ready to fly aircraft
This is the way it was explained by Van at his 12 forum without mention of Jan 31/08.
Please help this senile ol' man out!
Bernie [quote][b]
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mrobert569(at)hotmail.com Guest
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Posted: Wed May 16, 2007 5:54 am Post subject: RV-9 Certified As E-LSA |
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Bernie,
Keep in mind that anything is subject to change. But, as the rule appears right now the first category for ELSA will go away entirely after January 31, 2008. After that only category 2 and category 3 will remain.
Please bear in mind that this is for CERTIFICATION in ELSA. It does not now, nor will it later, effect the flying. No matter what category an aircraft is certificated in (LSA, AMA-BLT, STD), as long as the aircraft meats the definition of an LSA aircraft in FAR 1, a person may fly that aircraft under the Light-Sport rules.
Mike Robertson
From: jbker(at)juno.com
Date: Tue, 15 May 2007 17:06:17 +0000
To: rv-list(at)matronics.com
Subject: RE: RV-9 Certified As E-LSA
Quote: | Mike,
I must be ready for LSA , I'm more confused now. Lets only talk about after Jan 31/08 since the 12 kit will not be out until about that date :>)
Will there be 3 categories of LSA? 1.Amateur built aircraft that meet LSA standards as certified by the builder 2. ELSA that will be certified by the FAA as LSA qualified and has to be built with no mods 3. LSA ready to fly aircraft
This is the way it was explained by Van at his 12 forum without mention of Jan 31/08.
Please help this senile ol' man out!
Bernie
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