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  #1  
Old 08-02-2017, 10:56 AM
rvbuilder2002 rvbuilder2002 is offline
 
Join Date: Jul 2005
Location: Hubbard Oregon
Posts: 7,062
Default RV-12 and actual IFR......

I need to correct some mis-information I provided a few people at OSH.

The RV-12 is old enough now that I haven't been in the ASTM's for quite a while, and had forgotten some of the details. Rian Johnson has, because he is on the ASTM committee, so I got some clarification during a conversation we just had while talking about our plan to introduce a flight training version of the RV-12 that flight schools could use to provide inexpensive advanced training (IFR).

The short answer is that even though there is nothing in the FAR's or LSA operating limitations that prohibit it, an E-LSA or S-LSA RV-12 can't be used for flight in actual IFR conditions because of limitations written into the ASTM they are certified under.

The current applicable ASTM states the following.....


9. Operating Limitations and Information
9.1 Markings and Placards:
9.1.1 General:
9.1.1.1 The airplane must contain the markings and placards
specified within this section and any additional information,
instrument markings, and placards required for safe operation
if it has unusual design, operating, or handling characteristics.
9.1.1.2 Each marking and placard prescribed in this section
must be displayed in a conspicuous place and may not be easily
erased, disfigured, or obscured.
9.1.1.3 The units of measurement used on placards must be
the same as those used on the corresponding equipment.
9.1.1.4 The placards and marking information in this section
must be furnished in the Pilot’s Operating Handbook.
9.1.1.5 Language and Localization—The language used in
markings and placards may be adjusted to accommodate
language and localization concerns. For example, the word
“aeroplane” may be substituted for the word “airplane”.
9.1.2 Instrument Markings:
9.1.2.1 When markings are on an instrument cover, there
must be means to maintain the correct alignment of the cover
with the face of the instrument.
9.1.2.2 Markings must be large enough to be clearly visible
to the pilot.
9.1.2.3 Airspeed Indicator—Each airspeed indicator must
be marked at the corresponding indicated airspeed as follows:
(1) Flap Operating Range—A continuous white marker
with the lower limit at VS0 established under 4.4.1 and the
upper limit at VFE. For airplanes without flaps, this marker is
not required.
(2) Normal Operating Range—A continuous green marker
with the lower limit at VS established under 4.4.1 and the upper
limit at VC established under 5.2.4.3.
(3) Caution Range—A continuous yellow marker extending from upper limit of the green marker specified in Item 2
(above) to the VNE line specified in Item 4 (below).
(4) Never Exceed Speed, VNE—A red line perpendicular to
the movement direction of the indicator.
9.1.3 Pilot Warning—A placard that specifies the kinds of
operation to which the airplane is limited or from which it is
prohibited and that the airplane is to be operated according to
the limitations in the Pilot’s Operating Handbook. The kinds of
operation specified on the placard must be within the limits
given in 9.2.
9.1.4 Passenger Warning—“This aircraft was manufactured
in accordance with Light Sport Aircraft airworthiness standards
and does not conform to standard category airworthiness
requirements.”
9.1.5 Spinning—“NO INTENTIONAL SPINS” if applicable (see 4.5.9).
9.1.6 Occupant Safety Restraint System—The occupant restraint system must have a permanent and legible marking
stating compliance with ASTM F2245, the working load rating
(see 6.10.2), and the date of manufacture. The use of approved
safety belts listed in 6.10.2.1, 6.10.2.2, 6.10.2.3, 6.10.2.4,
6.10.2.5, or 6.10.2.6 shall be deemed acceptable.
9.2 Kinds of Operation:
9.2.1 Flight operations are limited to VMC (visual meteorological conditions).
9.2.2 Flight operations in IMC (instrument meteorological
conditions) are prohibited.


This doesn't prohibit training in simulated IFR, but the only legal way (as we currently understand it) to use an RV-12 for actual IFR is if it is built and certified as an E-AB (experimental amateur built), and properly equipped as required by FAR 91.205.
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Any opinions expressed in this message are my own and not necessarily those of my employer.

Scott McDaniels
Hubbard, Oregon
RV-6A (aka "Junkyard Special ")
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  #2  
Old 08-02-2017, 04:37 PM
rongawer's Avatar
rongawer rongawer is offline
 
Join Date: Dec 2007
Location: Brentwood, CA
Posts: 239
Default Building E-AB

Hence the reason I am building E-AB with a nicely equipped panel. Having said that, I don't see the purpose for installing a Garmin GTN navigator (option listed for the new 12iS), which is TSO'd for precision approaches, in a -12 if you're only doing VFR. The G3X or Skyview systems will both do great GPS navigation in VFR.
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- RV12, N975G, SN 120840, Build in progress...finishing up.
- BE58, N1975G, stimulating the economy one flight at a time.
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  #3  
Old 08-02-2017, 06:42 PM
Driftdown Driftdown is offline
 
Join Date: Jan 2011
Location: Clearwater, Florida
Posts: 295
Default

Quote:
Originally Posted by rvbuilder2002 View Post
9.2 Kinds of Operation:
9.2.1 Flight operations are limited to VMC (visual meteorological conditions).
9.2.2 Flight operations in IMC (instrument meteorological
conditions) are prohibited.
[/b][/i]

This doesn't prohibit training in simulated IFR, but the only legal way (as we currently understand it) to use an RV-12 for actual IFR is if it is built and certified as an E-AB (experimental amateur built), and properly equipped as required by FAR 91.205.
The operative term is "conditions."

Nobody is questioning the prohibition of operating under "IFR conditions."

The real question is, "under VFR conditions, can an LSA be operated on an IFR flight plan, if suitably equipped, to adhere to IFR clearances?

If the whole state of Oregon is VFR and forecasted to be that way all day, what regulation prevents an RV-12 operator from filing IFR, obtaining an IFR clearance and flying the said flight, under continuous VFR conditions, for the planned and filed route?
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  #4  
Old 08-02-2017, 06:46 PM
BobTurner BobTurner is online now
 
Join Date: Dec 2011
Location: Livermore, CA
Posts: 4,736
Default

Quote:
Originally Posted by Driftdown View Post
The operative term is "conditions."

Nobody is questioning the prohibition of operating under "IFR conditions."

The real question is, "under VFR conditions, can an LSA be operated on an IFR flight plan, if suitably equipped, to adhere to IFR clearances?

If the whole state of Oregon is VFR and forecasted to be that way all day, what regulation prevents an RV-12 operator from filing IFR, obtaining an IFR clearance and flying the said flight, under continuous VFR conditions, for the planned and filed route?
I think you are correct. But can you imagine the following conversation:
Pilot: "It looks like actual IMC ahead so we need to cancel IFR"
ATC: "????"
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  #5  
Old 08-02-2017, 07:33 PM
Driftdown Driftdown is offline
 
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Location: Clearwater, Florida
Posts: 295
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Quote:
Originally Posted by BobTurner View Post
I think you are correct. But can you imagine the following conversation:
Pilot: "It looks like actual IMC ahead so we need to cancel IFR"
ATC: "????"
How about this instead, "we are canceling IFR and proceding visually."
Reason for canceling IFR is optionally up to the pilot.

ATC will probably ask, "okay, radar service terminated, squawk VFR, what are your intentions?"

Actually, ATC could care less, as long as you avoid his/her other IFR traffic.
As soon as you cancel, he/she is finished providing IFR seperation services (less required work for him/her).
IOW, you are then, on your own. Just maintain appropriate VFR altitude.

Last edited by Driftdown : 08-02-2017 at 08:45 PM.
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  #6  
Old 08-02-2017, 08:34 PM
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Tony_T Tony_T is offline
 
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Location: Seattle, WA
Posts: 1,173
Default

Quote:
Originally Posted by BobTurner View Post
I think you are correct. But can you imagine the following conversation:
Pilot: "It looks like actual IMC ahead so we need to cancel IFR"
ATC: "????"
Exactly; if you accept an IFR clearance aren't you saying that you can comply with what generally IFR entails, that would seem to me to include IMC.

Otherwise, it's like signing up in the Marine Corp because you like the uniform - unfortunately you could end up in combat one day . Just my opinion...
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RV-12 #202 -- Flying
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  #7  
Old 08-02-2017, 08:54 PM
Driftdown Driftdown is offline
 
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Location: Clearwater, Florida
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Quote:
Originally Posted by Tony_T View Post
Exactly; if you accept an IFR clearance aren't you saying that you can comply with what generally IFR entails, that would seem to me to include IMC.
Where does it regulatorily mandate that?

If conditions are absolutey VFR, there is no reason all those clearances will not be complied with.
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  #8  
Old 08-02-2017, 10:17 PM
RFSchaller RFSchaller is offline
 
Join Date: Oct 2010
Location: Phoenix, AZ
Posts: 2,132
Default

If the operating limits issued for an ELSA don't address the ASTM standard is it (the ASTM standard) applicable to that airframe?

When I asked my DAR about night flying and IFR the response I got was that if properly equipped those operations are authorized. My Question:

Have you had a chance to see if my Op Limits can be changed to drop the day VFR limitation in phase 2 operations if equipped for night or IFR?


His response:

I had my discussion with MIDO and the reading is that after you sign off Phase I and are now operating in Phase II, Op Limit #10 becomes a mute point and #11 is in effect. You don't need to change your current limitations.
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  #9  
Old 08-02-2017, 10:45 PM
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Tony_T Tony_T is offline
 
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Location: Seattle, WA
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Quote:
Originally Posted by Driftdown View Post
Where does it regulatorily mandate that?

If conditions are absolutey VFR, there is no reason all those clearances will not be complied with.
Not quoting mandates, just asking a question and giving my opinion .

In Washington and a lot of other places I think it would be hard to schedule a day of IFR instruction without a good chance of being vectored by ATC into the proximity of clouds. If waiting for absolute VFR days here it might take years to get an IFR rating.
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RV-12 #202 -- Flying
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  #10  
Old 08-03-2017, 11:55 AM
N456TS N456TS is offline
 
Join Date: Aug 2017
Location: NC
Posts: 11
Default

So, after years of only reading, this thread finally made me create an account to post a message....Surprisingly, quite a few hoops just to make an account!

rvbuilder2002, you're fully correct on S-LSA. S-LSAs are bound throughout their life to the ASTM standard as it was at the time the statement of compliance was issued by the manufacture. Any LOAs issued in the future have to comply with the ASTM standard at the date of issue of the LOA. The ASTM standard prevents all the IMC fun. (As it should, based on the intent of the aircraft).

Here's where you're only half correct, but technically correct for a split moment in time. A E-LSA must be built to those exact same ASTM standards. Just like an S-LSA is must meet the current ASTM standards at the time the airworthiness is issued. That means no IMC place card. Exactly as an S-LSA. At that time, the only difference between the E-LSA and an S-LSA is "light spot" written on the outside of the aircraft, "Experimental" visual from the entrances, and the passenger warning. Unlike an S-LSA, the E-LSA no longer must comply with the current ASTM standard for modifications. This includes changing the POH to allow flight in IMC and installing the equipment to legally fly IFR. At this point, the rules you must follow are 100% from the FAA. Refer to the FARs and the operating limitations issued to that specific E-LSA. ASTM has zero say at this point.

In conclusion, you folks don't need to worry about changing to amateur-built. I hope this clarifies. I'm not here to argue about this. These are the facts of the issue. Please excuse any typos. I will now resume read-only mode!
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