What's new
Van's Air Force

Don't miss anything! Register now for full access to the definitive RV support community.

Operating Limits Seem Conflicting

RFSchaller

Well Known Member
My aircraft was licensed in 2012. I have been considering installing a VOR receiver so I can legally file IFR since even in VMC it greatly simplifies travel in the LA basin and near San Diego. I checked my operating limits and found these two items that seem to conflict with each other, because my phase 2 limits say both apply. The first seems to preclude IFR, while the second leaves the door open after equipment installation:

10. This aircraft is to be operated under VFR day only.
11. After completion of phase 1 flight testing, unless appropriately equipped for night and/or instrument flight in accordance with 14 CFR 91.205, this aircraft is to be operated under VFR day only.

Does everyone else have both these limitations in phase 2? Does #11 trump #10? Are my limits in error to carry #10 into phase 2?
 
When built as an ELSA, the POH is part of the as-equipped ELSA. IFR capability is not an ELSA option. You can modify the POH to reflect new equipment as you modify the plane once past Phase 1.
 
Haven't checked the POH, but the POH is not my legal operating limits. I wonder if the DAR screwed up and kept #10 in phase 2 when #11 was the correct limit for phase 2. Can some of you guys weigh in on what your OLs say?

Thanks,

Rich
 
Cut and pasted directly from FAA Order 8130.2G

(7) During Phase 1 flight testing, this aircraft is to be operated under VFR, day only.
(8) After completion of phase I flight testing, unless appropriately equipped for night
and/or instrument flight in accordance with 14 CFR ? 91.205, this aircraft is to be operated under
VFR, day only.

This is the wording that should be in your op limitations.
The absolute limitation of no IFR is Phase 1 only.
After that it is allowed if properly equipped.
 
Mine was the first ELSA this DAR did. I think he got it wrong. I sent him a note, and I am awaiting a reply.
 
Update: my DAR agrees the OLs need to be changed to make the absolute day VFR restriction phase 1 only. Phase 2 will lift the restriction if properly equipped.
 
Interesting.....has anyone been flying their 12 IFR?

I can see the advantage not wanting to get stuck on those sorta vfr/ifr days.

Is subbing in a navcom and antenna enough?

Would you need a second screen, Ahrs and gps and alternate static source to be legal? Heated pitot?

Then that brings the whole amperage issue back into play.

****...thx for adding another future project....back to my pp kit.
 
Last edited:
You guys are assuming IFR means IMC. My intent is to legally be "in the system" when flying into SOCAL airspace VMC. It is much easier to move through the LA basin under ATC control, but they don't seem to want to provide VFR flight following. The concerns many of you seem to have are the reliability of the RV-12 avionics. Not really a concern in VMC. Besides there are plenty of EAB aircraft flying in IMC with non-TSO'd avionics so the RV-12 is not unique in that respect. As usual what is legal and what is prudent are not always the same. I seek legality so I can exercise my prudence.
 
John,

My read on 91.205 is that the minimum addition to fly the RV-12 under IFR would be an approved Nav system. Our portable Garmin units (old D180 planes) and Skyview don't seem to meet the FAA requirements to use GPS as our IFR navigation. I think the cheapest legal minimum would be an ADF or VOR. Aircraft Spruce has a VOR/GS unit with integral indicator for about $1800.

Rich
 
John,

My read on 91.205 is that the minimum addition to fly the RV-12 under IFR would be an approved Nav system. Our portable Garmin units (old D180 planes) and Skyview don't seem to meet the FAA requirements to use GPS as our IFR navigation. I think the cheapest legal minimum would be an ADF or VOR. Aircraft Spruce has a VOR/GS unit with integral indicator for about $1800.

Rich

No portable is approved for IFR use. A VOR would be the least expensive way.
 
Kyle,

I'm not sure about the legality of a handheld VOR receiver for IFR. I have an SP-400 and have flown both VOR and ILS approaches in VFR to evaluate it. The ILS was dead on but the VOR was not reliable beyond about 15 miles from the station. My conclusion is that it's a great backup if you can get to the IAF, but not reliable enough to depend on for enroute. Others may have had a different experience with it.

Rich
 
Based off this thread

Kyle,

I'm not sure about the legality of a handheld VOR receiver for IFR. I have an SP-400 and have flown both VOR and ILS approaches in VFR to evaluate it. The ILS was dead on but the VOR was not reliable beyond about 15 miles from the station. My conclusion is that it's a great backup if you can get to the IAF, but not reliable enough to depend on for enroute. Others may have had a different experience with it.

Rich

http://www.vansairforce.com/community/showthread.php?t=69172

Worked for him
 
Kyle,

Like I said, others may have a different experience with the SP-400. If you buy one I recommend doing some airway tracking and approaches to determine your specific characteristics in your airplane.

Rich
 
I finally got the answer on my operating limits from my DAR after his discussion with the MIDO. Everybody agrees the day VFR restriction does not apply in Phase 2 if equipped for night or IFR, but the MIDO says there is no revision required although they will make changes in future OLs to make the wording clear. I intend to carry a copy of the correspondence with my OLs if I equip for night and/or IFR.
 
Keep in mind you must have a medical to operate with less than 3 miles visibility, or out of ground contact.
 
Earlier versions of 8130.2 had miss-wording for paragraph 10. It has been corrected to read; "(10) During phase I flight testing this aircraft is to be operated under VFR day only."
 
Keep in mind you must have a medical to operate with less than 3 miles visibility, or out of ground contact.

Or, at night, or above 10,000' altitude. Or any other condition not covered under Sport Pilot operations.
 
I checked my operating limits and found these two items that seem to conflict with each other, because my phase 2 limits say both apply. The first seems to preclude IFR, while the second leaves the door open after equipment installation:

10. This aircraft is to be operated under VFR day only.
11. After completion of phase 1 flight testing, unless appropriately equipped for night and/or instrument flight in accordance with 14 CFR 91.205, this aircraft is to be operated under VFR day only.

Does everyone else have both these limitations in phase 2? Does #11 trump #10? Are my limits in error to carry #10 into phase 2?

This is an older thread but its content just became current for me, so I thought I'd update the community on the latest development.
I was just in the same position as Rich, as I was getting ready to take Private lessons in my ELSA RV-12, checking my Operating Limitations if Night VFR was ok to do in my night equipped RV-12.
I had the very same limitations as Rich had quoted which had the exclusive Day VFR clause applied to Phase II.
I contacted my DAR who had issued my Airworthiness Certificate and the OpLims some 3 years ago and he contacted his supervisor at the FSDO who authorized him to re-issue amended Operating Limitations (along with a new Airworthiness Certificate) which correct this mistake.
The whole procedure was done in less than a week and my bird is now legal to fly at night if equipped according to FAR 91.205.
The OpLims look completely different now, it's a complete rewrite and more of a narrative than just numbers to express limitations. Less of a chance for errors that way, I suppose.
 
Would you need a second screen, Ahrs and gps and alternate static source to be legal? Heated pitot?

No, no, and no. The FARs and the "usual" operating limits only require the bare minimums, no backups. Now, whether or not that is wise, is another story...
 
Torsten and I exchanged copies of our operating limits. I found it interesting that his new limits address the life limited components and the requirements of the aircraft operating handbook.

There seems to be some regulatory creep in this moving things closer to the SLSA requirements.
 
I just got my SECOND set of Op Lims. The DAR was telling me that it is a program that you pick and choose the stuff that applies, and it is easy to get limits that are not supposed to be there for your application. I don't think mine have anything like you mentioned in them.
 
I just got my SECOND set of Op Lims. The DAR was telling me that it is a program that you pick and choose the stuff that applies, and it is easy to get limits that are not supposed to be there for your application. I don't think mine have anything like you mentioned in them.

If he is "picking and choosing", he is in violation of the FARs. The required paragraphs for each category are clearly spelled out in the order.
 
Rich, while I owned my first 12, I pulled the sl40 and installed a sl30 which requires the same panel space. The 30 is a bit longer but will fit. The D180 has an internal GS indicator that worked perfectly. I mounted the whiskers on the tail cone fairing under the stabilator . You barely even notice the antenna. There is a slight pin change required, but it worked very well. You could also use the VAL Nav 2000. The only glitch with this would be identifying the station if you don't have an audio panel and you would have to figure out where to mount it. The SL30 does work very well for what you are wanting to do.
 
My original ones had a 25 hr phase 1, and I should have a 40 hour. Apparently this is confusing since it seems often the builder gets the wrong Op Lims (like Torsten did).

If he is "picking and choosing", he is in violation of the FARs. The required paragraphs for each category are clearly spelled out in the order.
 
Kyle,

I'm not sure about the legality of a handheld VOR receiver for IFR. I have an SP-400 and have flown both VOR and ILS approaches in VFR to evaluate it. The ILS was dead on but the VOR was not reliable beyond about 15 miles from the station. My conclusion is that it's a great backup if you can get to the IAF, but not reliable enough to depend on for enroute. Others may have had a different experience with it.

Rich

Using a handheld VOR receiver for IFR is legal, believe it or not. It is "Certified" when you certify it in you log your VOR check.

Now, if you want to fly IFR with it is another thing altogether.
 
Torsten and I exchanged copies of our operating limits. I found it interesting that his new limits address the life limited components and the requirements of the aircraft operating handbook.

There seems to be some regulatory creep in this moving things closer to the SLSA requirements.

I've noticed that. Fortunately, we Experimentals can write, change and amend our own POH, so I'm not worried yet.
 
If he is "picking and choosing", he is in violation of the FARs. The required paragraphs for each category are clearly spelled out in the order.
Mel,
Where can I find the order. My RV12 ELSA inspection was done by the FAA. My operation limitations restrict me to VFR and does not allow a path to upgrade the plane to IFR in phase 2. I would like to get mine corrected but would like to be able to reference something official for discussion.
 
Mel,
Where can I find the order. My RV12 ELSA inspection was done by the FAA. My operation limitations restrict me to VFR and does not allow a path to upgrade the plane to IFR in phase 2. I would like to get mine corrected but would like to be able to reference something official for discussion.

Operating limitations are in FAA Order 8130.2H, Appendix C.
It takes quite a bit of patience to get through them if you are not familiar.
The paragraph you are looking for is #41. It applies to 21.191(b), (f), (g), (h), & (i). and states:

"Instrument flight operations are authorized if the instruments specified in
§ 91.205(d) are installed, operational, and maintained in accordance with
the applicable requirements of part 91. All maintenance or inspection of
this equipment must be recorded in the aircraft maintenance records and
include the following items: date, work performed, and name and
certificate number of person returning aircraft to service. (41)"
 
Last edited:
Using a handheld VOR receiver for IFR is legal, believe it or not. It is "Certified" when you certify it in you log your VOR check.

Now, if you want to fly IFR with it is another thing altogether.

Looking at Mel's quote of the op limits (above), I believe a handheld is not legal for meeting the requirements, unless it is "installed".
 
Mel

My ELSA operation limitations doesn't allow the installation of and use of TOS IFR equipment for IFR use. I thought if the RV-12 was built ELSA and was certified as such that the operation limitations would contain standard language allowing for IFR if so equipped per 91.205 (d). during phase 2.

If this is correct, where can I find the authoritative source for the language that must be used in the operating limitations?
 
Mel

My ELSA operation limitations doesn't allow the installation of and use of TOS IFR equipment for IFR use. I thought if the RV-12 was built ELSA and was certified as such that the operation limitations would contain standard language allowing for IFR if so equipped per 91.205 (d). during phase 2.

If this is correct, where can I find the authoritative source for the language that must be used in the operating limitations?

I might be stepping into doo doo, but my understanding is....once air worthiness certificate is give for E-LSA build; you can make alterations "as long as you don't..1. Exceed 1320 gross, 2. Exceed E-LSA speed. Appropriate changes in POH would be needed for equipment added. Along with maintaining fixed or ground adjustable prop.
 
I might be stepping into doo doo, but my understanding is....once air worthiness certificate is give for E-LSA build; you can make alterations "as long as you don't..1. Exceed 1320 gross, 2. Exceed E-LSA speed. Appropriate changes in POH would be needed for equipment added. Along with maintaining fixed or ground adjustable prop.

You cannot make any changes that conflict with the operating limitations.
 
Mel
My ELSA operation limitations doesn't allow the installation of and use of TOS IFR equipment for IFR use. I thought if the RV-12 was built ELSA and was certified as such that the operation limitations would contain standard language allowing for IFR if so equipped per 91.205 (d). during phase 2.
If this is correct, where can I find the authoritative source for the language that must be used in the operating limitations?

See post 34 above.
 
FYI and potential action on engine start. Compared revision 6 dated 01/03/17 with older POH and noted page 4-7 has the avionics switch coming on after engine start just like GA aircraft.

Don't know why or when Vans made this change on Engine Start procedure, but it should be noted by operators of RV-12's with older POH's.

Suggest also compare both your's and the new POH Shut down procedure.
 
Since the EIS is part of the main display I always turn on avionics before starting to avoid a "blind" engine start. I like to know immediately if my oil pressure isn't responding, and the voltage drop during cranking can give you some warning that the battery is about to die.
 
Plus, Dynon states that it perfectly acceptable to have their avionics "On" prior to and during engine start.
 
Moot Point

This might all be a moot point because after careful reading of the engine limitations Rotax prohibits IFR flight for the 912 engine. Not sure about EAB RV-12 with a Viking engine, have not come across any engine limitations for them.
 
Dave,

For EAB and ELSA the operating limits are issued by the FAA with your AWC. While it is certainly prudent to observe manufacturer recommendations and prohibitions they are not legally binding unless incorporated in the operating limits. So it isn't a moot point for ELSA and EAB.

Rich
 
Dave,
For EAB and ELSA the operating limits are issued by the FAA with your AWC. While it is certainly prudent to observe manufacturer recommendations and prohibitions they are not legally binding unless incorporated in the operating limits. So it isn't a moot point for ELSA and EAB.
Rich

Rich is correct!
 
Thanks, Mel! It makes up for that ONE time in my life when I was wrong!😜

P.S. It was when I was right but thought I was wrong!😁
 
Thanks, Mel! It makes up for that ONE time in my life when I was wrong!😜
P.S. It was when I was right but thought I was wrong!😁

I understand completely. The only time I was wrong was when I thought I had made a mistake.

Hey, That's kinda like what you just said. Great minds think alike!
 
Since the EIS is part of the main display I always turn on avionics before starting to avoid a "blind" engine start. I like to know immediately if my oil pressure isn't responding, and the voltage drop during cranking can give you some warning that the battery is about to die.

Check! Voltage drop during start, gonna write that in, never thought of it!
Thanks Rich!
 
Voltage drop?

Since the EIS is part of the main display I always turn on avionics before starting to avoid a "blind" engine start. I like to know immediately if my oil pressure isn't responding, and the voltage drop during cranking can give you some warning that the battery is about to die.

What does that drop look like?
 
Plus, Dynon states that it perfectly acceptable to have their avionics "On" prior to and during engine start.

If Dynon is strictly referring for Dynon equipment then is the POH inferring, turn a Non-dynon radio on and off separate from the avionics master to protect it?
 
Back
Top