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RV-12 as a True E-LSA

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aslsa.rng(at)gmail.com
Guest

Posted: Tue Nov 25, 2008 8:16 am Post subject: RV-12 as a True E-LSA

21.191   Experimental certificates.

Experimental certificates are issued for the following purposes:

(i) Operating light-sport aircraft. Operating a light-sport aircraft that—

  



(2) Has been assembled—

(i) From an aircraft kit for which the applicant can provide the information required by §21.193(e); and

(ii) In accordance with manufacturer's assembly instructions that meet an applicable consensus standard;   

21.193   Experimental certificates: general.

An applicant for an experimental certificate must submit the following information:



(e) In the case of a light-sport aircraft assembled from a kit to be certificated in accordance with §21.191(i)(2), an applicant must provide the following:  

(1) Evidence that an aircraft of the same make and model was manufactured and assembled by the aircraft kit manufacturer and issued a special airworthiness certificate in the light-sport category.

(2) The aircraft's operating instructions.  

(3) The aircraft's maintenance and inspection procedures.

(4) The manufacturer's statement of compliance for the aircraft kit used in the aircraft assembly that meets §21.190(c), except that instead of meeting §21.190(c)(7), the statement must identify assembly instructions for the aircraft that meet an applicable consensus standard.  

(5) The aircraft's flight training supplement.

(6) In addition to paragraphs (e)(1) through (e)(5) of this section, for an aircraft kit manufactured outside of the United States, evidence that the aircraft kit was manufactured in a country with which the United States has a Bilateral Airworthiness Agreement concerning airplanes or a Bilateral Aviation Safety Agreement with associated Implementation Procedures for Airworthiness concerning airplanes, or an equivalent airworthiness agreement.  

Notice that there is no provision for the amount of work done by the builder. As far as the FAA is considered, the manufacturer can leave off a single knob that the "builder" then installs.

That being said, the burden of proving that the aircraft qualifies for an experimental certificate as an amateur built under 21.191(g) would be on the builder.  

Rick



On Tue, Nov 25, 2008 at 6:50 AM,  <bakerocb(at)cox.net (bakerocb(at)cox.net)> wrote:

 [quote] 11/25/2008

 

 Hello Rick, You wrote: "...present the airplane to the FAA exactly as Van's designed it, get your

 E-LSA airworthiness certificate....."

 

 I am interested in knowing on what basis you feel that a kit built RV-12 can be built, registered, and certified as a true E-LSA instead of as an amateur built experimental that meets LSA criteria.

 

 Please see the exchange of emails copied below. Thank you.

 

 'OC' Says: "The best investment we can make is the effort to gather and understand knowledge."

 

 PS: I am not yet receiving the RV-12 list digest for some reason even though I have recently subscribed. Would you please include both me and the RV-12 list as addressees when you respond? Thanks.

 

 --------------------------------------------------------------------

 

 ---

robertrv607(at)yahoo.com
Guest

Posted: Tue Nov 25, 2008 4:56 pm Post subject: RV-12 as a True E-LSA

HI: Have a question, one is L_SA, which I pressume is a Light, s.a..

is there any other, kind? (Single Engine etc.. no?

is only the Light Sport Aircraft, which the Rv12 is...



thanks

robert

--- On Tue, 11/25/08, Richard Girard <aslsa.rng(at)gmail.com> wrote:



[quote] From: Richard Girard <aslsa.rng(at)gmail.com>

 Subject: Re: RV-12 as a True E-LSA

 To: bakerocb(at)COX.NET, rv12-list(at)matronics.com

 Date: Tuesday, November 25, 2008, 11:16 AM

 21.191   Experimental certificates.

 

 Experimental certificates are issued for the following

 purposes:

 

 (i) *Operating light-sport aircraft. *Operating a

 light-sport aircraft thatâ€”

 

 (2) Has been assembledâ€”

 

 (i) From an aircraft kit for which the applicant can

 provide the information

 required by Â§21.193(e); and

 

 (ii) In accordance with manufacturer's assembly

 instructions that meet an

 applicable consensus standard;

 

 21.193   Experimental certificates: general.

 

 An applicant for an experimental certificate must submit

 the following

 information:

 

 (e) In the case of a light-sport aircraft assembled from a

 kit to be

 certificated in accordance with Â§21.191(i)(2), an

 applicant must provide the

 following:

 

 (1) Evidence that an aircraft of the same make and model

 was manufactured

 and assembled by the aircraft kit manufacturer and issued a

 special

 airworthiness certificate in the light-sport category.

 

 (2) The aircraft's operating instructions.

 

 (3) The aircraft's maintenance and inspection

 procedures.

 

 (4) The manufacturer's statement of compliance for the

 aircraft kit used in

 the aircraft assembly that meets Â§21.190(c), except that

 instead of meeting

 Â§21.190(c)(7), the statement must identify assembly

 instructions for the

 aircraft that meet an applicable consensus standard.

 

 (5) The aircraft's flight training supplement.

 

 (6) In addition to paragraphs (e)(1) through (e)(5) of this

 section, for an

 aircraft kit manufactured outside of the United States,

 evidence that the

 aircraft kit was manufactured in a country with which the

 United States has

 a Bilateral Airworthiness Agreement concerning airplanes or

 a Bilateral

 Aviation Safety Agreement with associated Implementation

 Procedures for

 Airworthiness concerning airplanes, or an equivalent

 airworthiness

 agreement.

 

 Notice that there is no provision for the amount of work

 done by the

 builder. As far as the FAA is considered, the manufacturer

 can leave off a

 single knob that the "builder" then installs.

 

 That being said, the burden of proving that the aircraft

 qualifies for an

 experimental certificate as an amateur built under

 21.191(g) would be on the

 builder.

 

 Rick

 

 

 

 On Tue, Nov 25, 2008 at 6:50 AM, <bakerocb(at)cox.net>

 wrote:

 

 > 11/25/2008

 >

 > Hello Rick, You wrote: "...present the airplane

 to the FAA exactly as Van's

 > designed it, get your

 > E-LSA airworthiness certificate....."

 >

 > I am interested in knowing on what basis you feel that

 a kit built RV-12

 > can be built, registered, and certified as a true

 E-LSA instead of as an

 > amateur built experimental that meets LSA criteria.

 >

 > Please see the exchange of emails copied below. Thank

 you.

 >

 > 'OC' Says: "The best investment we can

 make is the effort to gather and

 > understand knowledge."

 >

 > PS: I am not yet receiving the RV-12 list digest for

 some reason even

 > though I have recently subscribed. Would you please

 include both me and the

 > RV-12 list as addressees when you respond? Thanks.

 >

 >

 --------------------------------------------------------------------

 >

 > ---

aslsa.rng(at)gmail.com
Guest

Posted: Tue Nov 25, 2008 8:07 pm Post subject: RV-12 as a True E-LSA

Bert, Light Sport Aircraft are defined in FAR 1.1



Rick



On Tue, Nov 25, 2008 at 6:56 PM, bert murillo <robertrv607(at)yahoo.com (robertrv607(at)yahoo.com)> wrote:

 [quote]--> RV12-List message posted by: bert murillo <robertrv607(at)yahoo.com (robertrv607(at)yahoo.com)>

  

 HI: Have a question, one is L_SA, which I pressume is a Light, s.a..

 is there any other, kind? (Single Engine etc.. no?

 is only the Light Sport Aircraft, which the Rv12 is...

 

 thanks

 robert

 

 

 --- On Tue, 11/25/08, Richard Girard <aslsa.rng(at)gmail.com (aslsa.rng(at)gmail.com)> wrote:

 

 > From: Richard Girard <aslsa.rng(at)gmail.com (aslsa.rng(at)gmail.com)>

 > Subject: Re: RV-12 as a True E-LSA

 > To: bakerocb(at)COX.NET (bakerocb(at)COX.NET), rv12-list(at)matronics.com (rv12-list(at)matronics.com)

 > Date: Tuesday, November 25, 2008, 11:16 AM

 

 	  Quote: 	
		   21.191   Experimental certificates.

 >
	


 > Experimental certificates are issued for the following

 > purposes:

 >

 > (i) *Operating light-sport aircraft. *Operating a

 > light-sport aircraft that—

 >

 > (2) Has been assembled—

 >

 > (i) From an aircraft kit for which the applicant can

 > provide the information

 > required by §21.193(e); and

 >

 > (ii) In accordance with manufacturer's assembly

 > instructions that meet an

 > applicable consensus standard;

 >

 > 21.193   Experimental certificates: general.

 >

 > An applicant for an experimental certificate must submit

 > the following

 > information:

 >

 > (e) In the case of a light-sport aircraft assembled from a

 > kit to be

 > certificated in accordance with §21.191(i)(2), an

 > applicant must provide the

 > following:

 >

 > (1) Evidence that an aircraft of the same make and model

 > was manufactured

 > and assembled by the aircraft kit manufacturer and issued a

 > special

 > airworthiness certificate in the light-sport category.

 >

 > (2) The aircraft's operating instructions.

 >

 > (3) The aircraft's maintenance and inspection

 > procedures.

 >

 > (4) The manufacturer's statement of compliance for the

 > aircraft kit used in

 > the aircraft assembly that meets §21.190(c), except that

 > instead of meeting

 > §21.190(c)(7), the statement must identify assembly

 > instructions for the

 > aircraft that meet an applicable consensus standard.

 >

 > (5) The aircraft's flight training supplement.

 >

 > (6) In addition to paragraphs (e)(1) through (e)(5) of this

 > section, for an

 > aircraft kit manufactured outside of the United States,

 > evidence that the

 > aircraft kit was manufactured in a country with which the

 > United States has

 > a Bilateral Airworthiness Agreement concerning airplanes or

 > a Bilateral

 > Aviation Safety Agreement with associated Implementation

 > Procedures for

 > Airworthiness concerning airplanes, or an equivalent

 > airworthiness

 > agreement.

 >

 > Notice that there is no provision for the amount of work

 > done by the

 > builder. As far as the FAA is considered, the manufacturer

 > can leave off a

 > single knob that the "builder" then installs.

 >

 > That being said, the burden of proving that the aircraft

 > qualifies for an

 > experimental certificate as an amateur built under

 > 21.191(g) would be on the

 > builder.

 >

 > Rick

 >

 >

 >

 > On Tue, Nov 25, 2008 at 6:50 AM, <bakerocb(at)cox.net (bakerocb(at)cox.net)>

 > wrote:

 >

 > > 11/25/2008

 > >

 > > Hello Rick, You wrote: "...present the airplane

 > to the FAA exactly as Van's

 > > designed it, get your

 > > E-LSA airworthiness certificate....."

 > >

 > > I am interested in knowing on what basis you feel that

 > a kit built RV-12

 > > can be built, registered, and certified as a true

 > E-LSA instead of as an

 > > amateur built experimental that meets LSA criteria.

 > >

 > > Please see the exchange of emails copied below. Thank

 > you.

 > >

 > > 'OC' Says: "The best investment we can

 > make is the effort to gather and

 > > understand knowledge."

 > >

 > > PS: I am not yet receiving the RV-12 list digest for

 > some reason even

 > > though I have recently subscribed. Would you please

 > include both me and the

 > > RV-12 list as addressees when you respond? Thanks.

 > >

 > >

 > --------------------------------------------------------------------

 > >

 > > ---

bakerocb

Joined: 15 Jan 2006
Posts: 727
Location: FAIRFAX VA

Posted: Tue Nov 25, 2008 8:47 pm Post subject: RV-12 as a True E-LSA

11/25/2008



Hello Rick, Thank you for your quick, detailed, and authoritative response. 

However as Dick Koehler pointed out in his email it still is not possible, 

at this time, to build a true E-LSA from a kit -- even an RV-12 kit.



Here is why in my opinion.



1) From 14 CFR 21.191 I quote from your email below:



"(ii) In accordance with manufacturer's assembly instructions that meet an

applicable consensus standard;"



2) From 14 CFR 21.193 I quote from your email below:



"(e) In the case of a light-sport aircraft assembled from a kit to be 

certificated in accordance with §21.191(i)(2), an applicant must provide the 

following:

(4) The manufacturer's statement of compliance for the aircraft kit used in 

the aircraft assembly that meets §21.190(c), except that instead of meeting 

§21.190(c)(7), the statement must identify assembly instructions for the 

aircraft that meet an applicable consensus standard."



Both of these 14 CFR extracts require that the kit provider must provide 

".......assembly instructions for the aircraft that meet an applicable 

consensus standard." for the kit builder to follow during constuction of the 

kit.



To my knowledge no such "applicable consensus standard" exists. If no such 

standard exists then Vans cannot possibly be providing assembly instructions 

for the RV-12 kit that meets that standard.



It may be possible that some day such a standard will exist. It may even be 

possible that the Vans assembly instructions for the RV-12 kit may 

retroactively (or is it future-istically?) meet that yet to exist standard. 

It may be possible that Van's instructions for assembly of the RV-12 kit may 

be the forerunner / standard creator for that forthcoming standard.



But as it stands right now today, I still maintain that it is not possible 

to build a true E-LSA from a kit, even a Vans RV-12 kit.



Your response is?



Then you wrote: "That being said, the burden of proving that the aircraft 

qualifies for an

experimental certificate as an amateur built under 21.191(g) would be on the 

builder."



I don't understand your point here. The whole object of this discussion is 

to NOT build, register, and certify an amateur built experimental airplane 

that would be subject to the burden of having either the repairman for that 

specific airplane or an A&P required to perform the annual condition 

inspection. Instead the object is to build a true E-LSA that could be sold 

to subsequent owners who could annually inspect the airplane after going 

through a 16 hour training course. Perhaps you did not understand?

'OC' Says: "The best investment we can make is the effort to gather and 

understand knowledge."



-------------------------------------------------------------------------

---

bakerocb

Joined: 15 Jan 2006
Posts: 727
Location: FAIRFAX VA

Posted: Wed Nov 26, 2008 7:24 am Post subject: RV-12 as a True E-LSA

11/26/2008



Hello Rick, Thanks for your quick response. You wrote:



1) "So the answer to your question is, no, at this time there is no way to 

build an E-LSA without having a registration issued before 1-31-2008, and 

that only last until the expiration of the extension on 1-31-2010."



We both agree on the above.



2) "Per the above, the FAA accepted ASTM standard is F2536-06."



http://www.astm.org/Standards/F2563.htm



I stand corrected -- the instruction standard does exist. And I feel that if 

Vans instructions for assembling the RV-12 kit meet that standard then, 

eventually when the other LSA boxes are appropriately filled by Vans, then a 

kit built RV-12 should be able to be built, registered, and certified as a 

true E-LSA. I thank you for educating me.



'OC' Says: "The best investment we can make is the effort to gather and 

understand knowledge."



-------------------------------------------------------------------------

---

AV8ORJWC

Joined: 13 Jul 2006
Posts: 1149
Location: Aurora, Oregon "Home of VANS"

Posted: Wed Nov 26, 2008 9:41 am Post subject: RV-12 as a True E-LSA

To add to this important discussion, it is my understanding that the

RV-12 kit "in its entirety" has not yet been FAA blessed.  Further,

under the ARC 51% perspective by the FAA participants, there is a small

but real risk that it might not be without some healthy attitude change

by the FAA on what constitutes - 51%.  Your comments (forwarded to the

FAA) prior to the final/final deadline of December 15th could have a

compelling impact.  Can anyone advise?



John Cox



--

Apik

Joined: 05 Feb 2009
Posts: 4

Posted: Fri Feb 06, 2009 3:58 am Post subject: Re: RV-12 as a True E-LSA

Yeah, the  RV-12 meets the certification standards of the Light Sport Aircraft category. Extensive and thorough testing has demonstrated compliance with LSA  performance and structural requirements. It is what we say it is and does what we say it does, and we have the test data to prove it! Extensive testing means the RV-12 is not the first LSA kit on the market, but it might be the best understood.

_________________
used rv sale

Apik

Joined: 05 Feb 2009
Posts: 4

Posted: Sun Feb 15, 2009 10:27 pm Post subject: Re: RV-12 as a True E-LSA

HI, I have got the following response to my post by email, I have replied, if you have any other suggestions ,or just another point of view you can post in this thread :Thanks for your input. But there is still no registered and certified 

copy 

of an RV-12 as an S-LSA is there?



I do not understand what your relationship is to the RV-12 kit 

production 

and testing or the point that you are making below. Can you please 

educate 

me? I am not a member of the RV-12 forum so please respond direct if 

possible. You may include a copy of anything that I transmit to the 

forum if 

you wish.



Below your email is an exchange of emails that pertain. It appears that 

as 

of today there are still two stumbling blocks to actually registering 

and 

certifying a kit built RV-12 as a true E-LSA: 1) The builder convincing 

the 

FAA that the kit meets the major portion rule; and 2) The fact that no 

registered and certified S-LSA version of the RV-12 exists.



Do you agree or do you have anything else to offer on this subject?

_________________
used rv sale

deej(at)deej.net
Guest

Posted: Mon Feb 16, 2009 9:05 am Post subject: RV-12 as a True E-LSA

Apik wrote:

 	  Quote: 	
		   of today there are still two stumbling blocks to actually registering 

 and 

 certifying a kit built RV-12 as a true E-LSA: 1) The builder convincing 

 the 

 FAA that the kit meets the major portion rule; and 2) The fact that no 

 registered and certified S-LSA version of the RV-12 exists.



   


	


    Re: #1 above, the 51% rule only applies if you want to register it

as an amateur built experimental.  51% does not apply to the E-LSA category.



    Re: #2, you will not be able to register it as an E-LSA until there

is a registered and certified S-LSA version available, which I believe

has to be done by Van's.  Until they do so, you'd have to register the

RV-12 as an amateur built experimental, in which case you'd then need to

prove that the kit meets the 51% rule...  



    IMHO you should give Van's a call and ask how to proceed.



-Dj



-- 

Dj Merrill - N1JOV

Glastar Sportsman 2+2 Builder #7118 N421DJ    KR-2 Builder N770DJ

http://deej.net/sportsman/                    http://deej.net/kr-2/



"Many things that are unexplainable happen during the construction of an 

airplane."  --Dave Prizio, 30 Aug 2005

aslsa.rng(at)gmail.com
Guest

Posted: Mon Feb 16, 2009 9:12 am Post subject: RV-12 as a True E-LSA

This is really pretty simple. If Vans didn't give you a letter of compliance, maintenance and inspection manual, flight training supplement, evidence that Vans was issued an S-LSA certificate for the RV-12 and operation instructions, the FAA will not register your RV-12 as an E-LSA (FAR 21.191i(2) and 21.193e(1-5)). 



Rick



On Mon, Feb 16, 2009 at 12:27 AM, Apik <lily_f(at)auswww.com (lily_f(at)auswww.com)> wrote:

[quote] --> RV12-List message posted by: "Apik" <lily_f(at)auswww.com (lily_f(at)auswww.com)>

 

 HI, I have got the following response to my post by email, I have replied, if you have any other suggestions ,or just another point of view you can post in this thread :Thanks for your input. But there is still no registered and certified

  copy

 of an RV-12 as an S-LSA is there?

 

 I do not understand what your relationship is to the RV-12 kit

 production

 and testing or the point that you are making below. Can you please

 educate

 me? I am not a member of the RV-12 forum so please respond direct if

 possible. You may include a copy of anything that I transmit to the

 forum if

 you wish.

 

 Below your email is an exchange of emails that pertain. It appears that

 as

 of today there are still two stumbling blocks to actually registering

 and

 certifying a kit built RV-12 as a true E-LSA: 1) The builder convincing

 the

 FAA that the kit meets the major portion rule; and 2) The fact that no

 registered and certified S-LSA version of the RV-12 exists.

 

 Do you agree or do you have anything else to offer on this subject?

 

 

 

 

 Read this topic online here:

 

 http://forums.matronics.com/viewtopic.php?p=230457#230457

 

 

 

 

 

 

 

 ===========

 " target="_blank">http://www.matronics.com/Navigator?RV12-List

 ===========

 MS -

 k">http://forums.matronics.com

 ===========

 e -

           -Matt Dralle, List Admin.

 t="_blank">http://www.matronics.com/contribution

 ===========

 

 

 

 [b]

robertrv607(at)yahoo.com
Guest

Posted: Mon Feb 16, 2009 8:38 pm Post subject: RV-12 as a True E-LSA

I would ask Van's, period.  He would know the answer no?



--- On Mon, 2/16/09, Richard Girard <aslsa.rng(at)gmail.com> wrote:

  	  Quote: 	
		  

From: Richard Girard <aslsa.rng(at)gmail.com>

Subject: Re: Re: RV-12 as a True E-LSA

To: rv12-list(at)matronics.com

Date: Monday, February 16, 2009, 12:09 PM



 This is really pretty simple. If Vans didn't give you a letter of compliance, maintenance and inspection manual, flight training supplement, evidence that Vans was issued an S-LSA certificate for the RV-12 and operation instructions, the FAA will not register your RV-12 as an E-LSA (FAR 21.191i(2) and 21.193e(1-5)). 



 Rick



 On Mon, Feb 16, 2009 at 12:27 AM, Apik <lily_f(at)auswww.com (lily_f(at)auswww.com)> wrote:

  	  Quote: 	
		  --> RV12-List message posted by: "Apik" <lily_f(at)auswww.com (lily_f(at)auswww.com)>



HI, I have got the following response to my post by email, I have replied, if you have any other suggestions ,or just another point of view you can post in this thread :Thanks for your input. But there is still no registered and certified

copy

of an RV-12 as an S-LSA is there?



I do not understand what your relationship is to the RV-12 kit

production

and testing or the point that you are making below. Can you please

educate

me? I am not a member of the RV-12 forum so please respond direct if

possible. You may include a copy of anything that I transmit to the

forum if

you wish.



Below your email  is an exchange of emails that pertain. It appears that

as

of today there are still two stumbling blocks to actually registering

and

certifying a kit built RV-12 as a true E-LSA: 1) The builder convincing

the

FAA that the kit meets the major portion rule; and 2) The fact that no

registered and certified S-LSA version of the RV-12 exists.



Do you agree or do you have anything else to offer on this subject?





Read this topic online here:



[url=http://forums.matronics.com/viewtopic.php?p 30457#230457]http://forums.matronics.com/viewtopic.php?p 30457#230457[/url]



===========

" target="_blank">http://www.matronics.com/Navigator?RV12-List

===========

MS -

k">http://forums.matronics.com

===========

e -

         -Matt Dralle, List  Admin.

t="_blank">http://www.matronics.com/contribution

===========





	


	


         [quote][b]

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