Today's Message Index:
----------------------
1. 08:16 AM - Re: RV-12 as a True E-LSA (Richard Girard)
2. 04:56 PM - Re: Re: RV-12 as a True E-LSA (bert murillo)
3. 08:07 PM - Re: Re: RV-12 as a True E-LSA (Richard Girard)
4. 08:47 PM - Re: RV-12 as a True E-LSA ()
Message 1
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| Subject: | Re: 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
=97
(2) Has been assembled=97
(i) From an aircraft kit for which the applicant can provide the informatio
n
required by =A721.193(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 =A721.191(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 =A721.190(c), except that instead of meeti
ng
=A721.190(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 th
e
builder.
Rick
On Tue, Nov 25, 2008 at 6:50 AM, <bakerocb@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 t
he
> RV-12 list as addressees when you respond? Thanks.
>
> --------------------------------------------------------------------
>
> ----- Original Message ----- From: <rkoehler4@verizon.net>
> To: <bakerocb@cox.net>
> Cc: "Koehler, Richard E." <rkoehler4@verizon.net>; "G & C DEHNEL" <
> gcdehnel@verizon.net>; "SHUMAKER, BOB" <rhshumaker@cox.net>
> Sent: Sunday, November 23, 2008 8:28 PM
> Subject: RE: A True E-LSA?
>
> Guys:
> I taught the E-LS Repairman's course at OSH last weekend, so I am a
> bit up on this stuff. Your analysis is correct, but as far as I know,
> no E-LSA kits are available. None of the manufacturers have chosen to
> go this route! (Their E-LSA must be a knock-off of their S-LSA.) I
> asked this question of Charlie Becker, Joe Norris, and Ron Wagner. None
> knew of an E-LSA kit, yet.
> One other avenue is possible. One can convert an S-LSA to an E-LSA
> if you can prove that the original manufacturer is no longer supporting
> their S-LSAs. For example, if the company went out of business. I
> don't know if there are any in this category, yet.
> The other approach is to just buy someone's E-LSA.
> The deadline for starting the paperwork to convert a "fat"
> ultralight to LSA has passed, so that approach is no longer viable.
> I had 13 in the class, and all passed.
> Dick
>
> --------------------------------------------------------------------
>
> On Sun, Nov 23, 2008 at 1:54 PM, bakerocb@cox.net wrote:
>
> 11/23/2008
>>
>
> Hello Gary, Thanks for your quick response. Perhaps you can help me with
> a related aspect.
>
> I have considered building a LSA, but I wanted one that I could build,
> register, certify, and fly as a true E-LSA rather than as an LSA that
> was built, registered, certified and flown as an amateur built
> experimental that met the LSA criteria.
>
> My motivation for this was looking forward to the time of selling this
> aircraft and the future owner, or some other non A&P, or person without
> an amateur built repairman's certificate for that specific airplane,
> being able to perform the annual inspections.
>
> My understanding is that the LSA related CFR 14 regulations permit a
> person to become trained in a manner that would allow that person to
> become qualified to perform the annual inspections on an E-LSA. That
> training, while not trivial, is far more easily accomplished than
> becoming an A&P.
>
> (From the EAA website: "For an Inspection rating-complete a 16 hour
> course on the inspection requirements of the particular class of
> light-sport aircraft")
>
> So the question becomes: "How does one build, register, certify and fly
> a true E-LSA?" I believe some possible CFR 14 regulatory answers are:
>
> 1) Manufacturers of S-LSA's are permitted to sell an essentially
> completed LSA that, along with written completion instructions, only
> require a very minimal final step to completion / conversion (say
> installing the "hub caps"), and then the finished airplane could be
> registered, certified, and flown as an E-LSA with all the privileges
> inherent thereto.
>
> 2) Kit providers could provide a kit, along with complete instructions
> for building the kit, that the kit builder needed to follow exactly (no
> modifications permitted) in order to produce an airplane that the FAA
> would permit to be built, registered, certified and flown as an E-LSA
> with all the privileges inherent thereto.
>
> So my questions to you (and to Dick Koehler) are:
>
> A) Do you believe that it is possible to create a true E-LSA using
> either method 1 or 2 above?
>
> B) If one wants to go the kit build route described in 2 above is there
> an existing kit (such as one provided by Zenith or Vans RV-12) that
> would permit one to create a true E-LSA?
>
> I would be very interested in your thoughts on the above. Many thanks.
>
> 'OC' Says: "The best investment we can make is the effort to gather and
> understand knowledge."
>
> -----------------------------------------------------
>
>
> Richard Girard" <aslsa.rng(at)gmail.com>Subject: Re: Fuel in wings
>
> Jim, You're right on this one, and you're wrong, too. There are two ways
> to
> put tanks in your wings.
> One, get a letter of authorization from Van's allowing the change. The
> letter must mention your aircraft's N number and it is good for that
> airplane only.
> Two, present the airplane to the FAA exactly as Van's designed it, get
> your
> E-LSA airworthiness certificate, and then install them. Once you have th
e
> ELSA AC you can do anything you want, all it takes is a log book
> endorsement
> and put the plane back into phase one testing for five hours.
>
> Rick
> ---------------------------------------------------------------------
>
Message 2
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| Subject: | Re: 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@gmail.com> wrote:
> From: Richard Girard <aslsa.rng@gmail.com>
> Subject: RV12-List: Re: RV-12 as a True E-LSA
> To: bakerocb@COX.NET, rv12-list@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 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@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.
> >
> >
> --------------------------------------------------------------------
> >
> > ----- Original Message ----- From:
> <rkoehler4@verizon.net>
> > To: <bakerocb@cox.net>
> > Cc: "Koehler, Richard E."
> <rkoehler4@verizon.net>; "G & C DEHNEL"
> <
> > gcdehnel@verizon.net>; "SHUMAKER, BOB"
> <rhshumaker@cox.net>
> > Sent: Sunday, November 23, 2008 8:28 PM
> > Subject: RE: A True E-LSA?
> >
> > Guys:
> > I taught the E-LS Repairman's course at OSH last
> weekend, so I am a
> > bit up on this stuff. Your analysis is correct, but
> as far as I know,
> > no E-LSA kits are available. None of the
> manufacturers have chosen to
> > go this route! (Their E-LSA must be a knock-off of
> their S-LSA.) I
> > asked this question of Charlie Becker, Joe Norris, and
> Ron Wagner. None
> > knew of an E-LSA kit, yet.
> > One other avenue is possible. One can convert an
> S-LSA to an E-LSA
> > if you can prove that the original manufacturer is no
> longer supporting
> > their S-LSAs. For example, if the company went out of
> business. I
> > don't know if there are any in this category, yet.
> > The other approach is to just buy someone's
> E-LSA.
> > The deadline for starting the paperwork to convert a
> "fat"
> > ultralight to LSA has passed, so that approach is no
> longer viable.
> > I had 13 in the class, and all passed.
> > Dick
> >
> >
> --------------------------------------------------------------------
> >
> > On Sun, Nov 23, 2008 at 1:54 PM, bakerocb@cox.net
> wrote:
> >
> > 11/23/2008
> >>
> >
> > Hello Gary, Thanks for your quick response. Perhaps
> you can help me with
> > a related aspect.
> >
> > I have considered building a LSA, but I wanted one
> that I could build,
> > register, certify, and fly as a true E-LSA rather than
> as an LSA that
> > was built, registered, certified and flown as an
> amateur built
> > experimental that met the LSA criteria.
> >
> > My motivation for this was looking forward to the time
> of selling this
> > aircraft and the future owner, or some other non
> A&P, or person without
> > an amateur built repairman's certificate for that
> specific airplane,
> > being able to perform the annual inspections.
> >
> > My understanding is that the LSA related CFR 14
> regulations permit a
> > person to become trained in a manner that would allow
> that person to
> > become qualified to perform the annual inspections on
> an E-LSA. That
> > training, while not trivial, is far more easily
> accomplished than
> > becoming an A&P.
> >
> > (From the EAA website: "For an Inspection
> rating-complete a 16 hour
> > course on the inspection requirements of the
> particular class of
> > light-sport aircraft")
> >
> > So the question becomes: "How does one build,
> register, certify and fly
> > a true E-LSA?" I believe some possible CFR 14
> regulatory answers are:
> >
> > 1) Manufacturers of S-LSA's are permitted to sell
> an essentially
> > completed LSA that, along with written completion
> instructions, only
> > require a very minimal final step to completion /
> conversion (say
> > installing the "hub caps"), and then the
> finished airplane could be
> > registered, certified, and flown as an E-LSA with all
> the privileges
> > inherent thereto.
> >
> > 2) Kit providers could provide a kit, along with
> complete instructions
> > for building the kit, that the kit builder needed to
> follow exactly (no
> > modifications permitted) in order to produce an
> airplane that the FAA
> > would permit to be built, registered, certified and
> flown as an E-LSA
> > with all the privileges inherent thereto.
> >
> > So my questions to you (and to Dick Koehler) are:
> >
> > A) Do you believe that it is possible to create a true
> E-LSA using
> > either method 1 or 2 above?
> >
> > B) If one wants to go the kit build route described in
> 2 above is there
> > an existing kit (such as one provided by Zenith or
> Vans RV-12) that
> > would permit one to create a true E-LSA?
> >
> > I would be very interested in your thoughts on the
> above. Many thanks.
> >
> > 'OC' Says: "The best investment we can
> make is the effort to gather and
> > understand knowledge."
> >
> > -----------------------------------------------------
> >
> >
> > Richard Girard"
> <aslsa.rng(at)gmail.com>Subject: Re: Fuel in wings
> >
> > Jim, You're right on this one, and you're
> wrong, too. There are two ways
> > to
> > put tanks in your wings.
> > One, get a letter of authorization from Van's
> allowing the change. The
> > letter must mention your aircraft's N number and
> it is good for that
> > airplane only.
> > Two, present the airplane to the FAA exactly as
> Van's designed it, get
> > your
> > E-LSA airworthiness certificate, and then install
> them. Once you have the
> > ELSA AC you can do anything you want, all it takes is
> a log book
> > endorsement
> > and put the plane back into phase one testing for
> five hours.
> >
> > Rick
> >
> ---------------------------------------------------------------------
> >
Message 3
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|
| Subject: | Re: 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@yahoo.com> wrote
:
>
> 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@gmail.com> wrote:
>
> > From: Richard Girard <aslsa.rng@gmail.com>
> > Subject: RV12-List: Re: RV-12 as a True E-LSA
> > To: bakerocb@COX.NET, rv12-list@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 that=97
> >
> > (2) Has been assembled=97
> >
> > (i) From an aircraft kit for which the applicant can
> > provide the information
> > required by =A721.193(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 =A721.191(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 =A721.190(c), except that
> > instead of meeting
> > =A721.190(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@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.
> > >
> > >
> > --------------------------------------------------------------------
> > >
> > > ----- Original Message ----- From:
> > <rkoehler4@verizon.net>
> > > To: <bakerocb@cox.net>
> > > Cc: "Koehler, Richard E."
> > <rkoehler4@verizon.net>; "G & C DEHNEL"
> > <
> > > gcdehnel@verizon.net>; "SHUMAKER, BOB"
> > <rhshumaker@cox.net>
> > > Sent: Sunday, November 23, 2008 8:28 PM
> > > Subject: RE: A True E-LSA?
> > >
> > > Guys:
> > > I taught the E-LS Repairman's course at OSH last
> > weekend, so I am a
> > > bit up on this stuff. Your analysis is correct, but
> > as far as I know,
> > > no E-LSA kits are available. None of the
> > manufacturers have chosen to
> > > go this route! (Their E-LSA must be a knock-off of
> > their S-LSA.) I
> > > asked this question of Charlie Becker, Joe Norris, and
> > Ron Wagner. None
> > > knew of an E-LSA kit, yet.
> > > One other avenue is possible. One can convert an
> > S-LSA to an E-LSA
> > > if you can prove that the original manufacturer is no
> > longer supporting
> > > their S-LSAs. For example, if the company went out of
> > business. I
> > > don't know if there are any in this category, yet.
> > > The other approach is to just buy someone's
> > E-LSA.
> > > The deadline for starting the paperwork to convert a
> > "fat"
> > > ultralight to LSA has passed, so that approach is no
> > longer viable.
> > > I had 13 in the class, and all passed.
> > > Dick
> > >
> > >
> > --------------------------------------------------------------------
> > >
> > > On Sun, Nov 23, 2008 at 1:54 PM, bakerocb@cox.net
> > wrote:
> > >
> > > 11/23/2008
> > >>
> > >
> > > Hello Gary, Thanks for your quick response. Perhaps
> > you can help me with
> > > a related aspect.
> > >
> > > I have considered building a LSA, but I wanted one
> > that I could build,
> > > register, certify, and fly as a true E-LSA rather than
> > as an LSA that
> > > was built, registered, certified and flown as an
> > amateur built
> > > experimental that met the LSA criteria.
> > >
> > > My motivation for this was looking forward to the time
> > of selling this
> > > aircraft and the future owner, or some other non
> > A&P, or person without
> > > an amateur built repairman's certificate for that
> > specific airplane,
> > > being able to perform the annual inspections.
> > >
> > > My understanding is that the LSA related CFR 14
> > regulations permit a
> > > person to become trained in a manner that would allow
> > that person to
> > > become qualified to perform the annual inspections on
> > an E-LSA. That
> > > training, while not trivial, is far more easily
> > accomplished than
> > > becoming an A&P.
> > >
> > > (From the EAA website: "For an Inspection
> > rating-complete a 16 hour
> > > course on the inspection requirements of the
> > particular class of
> > > light-sport aircraft")
> > >
> > > So the question becomes: "How does one build,
> > register, certify and fly
> > > a true E-LSA?" I believe some possible CFR 14
> > regulatory answers are:
> > >
> > > 1) Manufacturers of S-LSA's are permitted to sell
> > an essentially
> > > completed LSA that, along with written completion
> > instructions, only
> > > require a very minimal final step to completion /
> > conversion (say
> > > installing the "hub caps"), and then the
> > finished airplane could be
> > > registered, certified, and flown as an E-LSA with all
> > the privileges
> > > inherent thereto.
> > >
> > > 2) Kit providers could provide a kit, along with
> > complete instructions
> > > for building the kit, that the kit builder needed to
> > follow exactly (no
> > > modifications permitted) in order to produce an
> > airplane that the FAA
> > > would permit to be built, registered, certified and
> > flown as an E-LSA
> > > with all the privileges inherent thereto.
> > >
> > > So my questions to you (and to Dick Koehler) are:
> > >
> > > A) Do you believe that it is possible to create a true
> > E-LSA using
> > > either method 1 or 2 above?
> > >
> > > B) If one wants to go the kit build route described in
> > 2 above is there
> > > an existing kit (such as one provided by Zenith or
> > Vans RV-12) that
> > > would permit one to create a true E-LSA?
> > >
> > > I would be very interested in your thoughts on the
> > above. Many thanks.
> > >
> > > 'OC' Says: "The best investment we can
> > make is the effort to gather and
> > > understand knowledge."
> > >
> > > -----------------------------------------------------
> > >
> > >
> > > Richard Girard"
> > <aslsa.rng(at)gmail.com>Subject: Re: Fuel in wings
> > >
> > > Jim, You're right on this one, and you're
> > wrong, too. There are two ways
> > > to
> > > put tanks in your wings.
> > > One, get a letter of authorization from Van's
> > allowing the change. The
> > > letter must mention your aircraft's N number and
> > it is good for that
> > > airplane only.
> > > Two, present the airplane to the FAA exactly as
> > Van's designed it, get
> > > your
> > > E-LSA airworthiness certificate, and then install
> > them. Once you have the
> > > ELSA AC you can do anything you want, all it takes is
> > a log book
> > > endorsement
> > > and put the plane back into phase one testing for
> > five hours.
> > >
> > > Rick
> > >
> > ---------------------------------------------------------------------
> > >
>
>
===========
===========
===========
===========
>
>
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| Subject: | Re: 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."
-------------------------------------------------------------------------
----- Original Message -----
From: "Richard Girard" <aslsa.rng@gmail.com>
Sent: Tuesday, November 25, 2008 11:16 AM
Subject: Re: 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@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.
>
> --------------------------------------------------------------------
>
> ----- Original Message ----- From: <rkoehler4@verizon.net>
> To: <bakerocb@cox.net>
> Cc: "Koehler, Richard E." <rkoehler4@verizon.net>; "G & C DEHNEL" <
> gcdehnel@verizon.net>; "SHUMAKER, BOB" <rhshumaker@cox.net>
> Sent: Sunday, November 23, 2008 8:28 PM
> Subject: RE: A True E-LSA?
>
> Guys:
> I taught the E-LS Repairman's course at OSH last weekend, so I am a
> bit up on this stuff. Your analysis is correct, but as far as I know,
> no E-LSA kits are available. None of the manufacturers have chosen to
> go this route! (Their E-LSA must be a knock-off of their S-LSA.) I
> asked this question of Charlie Becker, Joe Norris, and Ron Wagner. None
> knew of an E-LSA kit, yet.
> One other avenue is possible. One can convert an S-LSA to an E-LSA
> if you can prove that the original manufacturer is no longer supporting
> their S-LSAs. For example, if the company went out of business. I
> don't know if there are any in this category, yet.
> The other approach is to just buy someone's E-LSA.
> The deadline for starting the paperwork to convert a "fat"
> ultralight to LSA has passed, so that approach is no longer viable.
> I had 13 in the class, and all passed.
> Dick
>
> --------------------------------------------------------------------
>
> On Sun, Nov 23, 2008 at 1:54 PM, bakerocb@cox.net wrote:
>
> 11/23/2008
>>
>
> Hello Gary, Thanks for your quick response. Perhaps you can help me with
> a related aspect.
>
> I have considered building a LSA, but I wanted one that I could build,
> register, certify, and fly as a true E-LSA rather than as an LSA that
> was built, registered, certified and flown as an amateur built
> experimental that met the LSA criteria.
>
> My motivation for this was looking forward to the time of selling this
> aircraft and the future owner, or some other non A&P, or person without
> an amateur built repairman's certificate for that specific airplane,
> being able to perform the annual inspections.
>
> My understanding is that the LSA related CFR 14 regulations permit a
> person to become trained in a manner that would allow that person to
> become qualified to perform the annual inspections on an E-LSA. That
> training, while not trivial, is far more easily accomplished than
> becoming an A&P.
>
> (From the EAA website: "For an Inspection rating-complete a 16 hour
> course on the inspection requirements of the particular class of
> light-sport aircraft")
>
> So the question becomes: "How does one build, register, certify and fly
> a true E-LSA?" I believe some possible CFR 14 regulatory answers are:
>
> 1) Manufacturers of S-LSA's are permitted to sell an essentially
> completed LSA that, along with written completion instructions, only
> require a very minimal final step to completion / conversion (say
> installing the "hub caps"), and then the finished airplane could be
> registered, certified, and flown as an E-LSA with all the privileges
> inherent thereto.
>
> 2) Kit providers could provide a kit, along with complete instructions
> for building the kit, that the kit builder needed to follow exactly (no
> modifications permitted) in order to produce an airplane that the FAA
> would permit to be built, registered, certified and flown as an E-LSA
> with all the privileges inherent thereto.
>
> So my questions to you (and to Dick Koehler) are:
>
> A) Do you believe that it is possible to create a true E-LSA using
> either method 1 or 2 above?
>
> B) If one wants to go the kit build route described in 2 above is there
> an existing kit (such as one provided by Zenith or Vans RV-12) that
> would permit one to create a true E-LSA?
>
> I would be very interested in your thoughts on the above. Many thanks.
>
> 'OC' Says: "The best investment we can make is the effort to gather and
> understand knowledge."
>
> -----------------------------------------------------
>
>
> Richard Girard" <aslsa.rng(at)gmail.com>Subject: Re: Fuel in wings
>
> Jim, You're right on this one, and you're wrong, too. There are two ways
> to
> put tanks in your wings.
> One, get a letter of authorization from Van's allowing the change. The
> letter must mention your aircraft's N number and it is good for that
> airplane only.
> Two, present the airplane to the FAA exactly as Van's designed it, get
> your
> E-LSA airworthiness certificate, and then install them. Once you have the
> ELSA AC you can do anything you want, all it takes is a log book
> endorsement
> and put the plane back into phase one testing for five hours.
>
> Rick
> ---------------------------------------------------------------------
>
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