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  #11  
Old 08-03-2017, 12:11 PM
lon@carolon.net lon@carolon.net is offline
 
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Originally Posted by N456TS View Post
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!
Please don't go "read only" quite yet . . .

What you wrote is exactly what I have thought the law is, but I haven't been able to find, in print, the provision of the law that says this. Do you know where to find it, in print, from the FAA or ASTM Committee?
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  #12  
Old 08-03-2017, 01:55 PM
rvbuilder2002 rvbuilder2002 is offline
 
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Originally Posted by N456TS View Post
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!
The current operating limitations issued to E-LSA RV-12's states the aircraft is approved for day VFR only, unless properly equipped for night operations. They never mention anything about being approved for IFR if properly equipped.

I agree that once certified, an E-LSA is a full fledged experimental (which can even be extensively modified as long as the modifications don't change its performance to be outside the LSA performance requirements), but all experimentals must abide by the operating limitations that are attached to the airworthiness certificate, regardless of whether you think the ASTM requirement is still relevant.

If anyone owns an E-LSA RV-12 that has operating limitations that specifically state that IFR is allowed if properly equipped, I would like to hear from you (private message is fine).
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  #13  
Old 08-03-2017, 02:24 PM
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rmartingt rmartingt is offline
 
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I looked up Order 8130.2, which is where the operating limitations assigned to our aircraft are defined.

https://www.faa.gov/regulations_poli...mentID/1031547

Appendix D lists the various operating limitations and which type of aircraft are supposed to get them. For determining applicability, E-AB aircraft are 191(h) and E-LSA are 191(i); S-LSA is 190.

Item 49 is the IFR limitation, in the "Phase II" section:
Quote:
Instrument flight operations are authorized if the instruments specified in § 91.205(d) are installed, operational, compliant with the performance requirements of, and maintained per the applicable regulations. 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.
This applies to 191(h) and 191(i). So at least by my read of this Order (disclaimer: I'm not a DAR), E-LSA aircraft should be issued operating limitations that permit IFR operation if properly equipped, once they are in Phase II.

S-LSA aircraft get operating limit 6:
Quote:
This aircraft may only be operated per the manufacturer’s aircraft operating instructions (AOI), including any requirement for necessary operating equipment specified in the aircraft’s equipment list. Night flight and instrument flight rules (IFR) operations are authorized if allowed by the AOI and if the instruments specified in § 91.205 are installed, operational, and maintained per the applicable requirements of part 91.
What the ASTM standard permits or doesn't isn't necessarily binding on the FAA--IIRC ASTM permits controllable-pitch propellers and retractable gear, but the FAA does not.
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  #14  
Old 08-03-2017, 04:04 PM
rvbuilder2002 rvbuilder2002 is offline
 
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Hmmmm.....
I haven't looked at 8130.2 for a while so I will look into this in more detail.
I think Rev. J is just becoming effective this month so maybe there have been some changes?
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  #15  
Old 08-03-2017, 04:36 PM
Cth6 Cth6 is offline
 
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Default Stupid Question

I thought that ELSAs (RV-12) only had to meet a 5 hour Phase 1 sign off. When would a phase 2 start / end? Or is Phase 2 only for EABs?
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  #16  
Old 08-03-2017, 04:48 PM
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Originally Posted by Cth6 View Post
I thought that ELSAs (RV-12) only had to meet a 5 hour Phase 1 sign off. When would a phase 2 start / end? Or is Phase 2 only for EABs?
Phase II begins when phase I is signed off and continues unless the aircraft is placed back into Phase I for some reason.

The paragraph from the previous post authorizing IFR IS indeed contained in the Operating Limitations for ELSA.
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  #17  
Old 08-03-2017, 06:04 PM
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rv7boy rv7boy is offline
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Default Known IMC in an S-LSA

Here's an example of an ATP who had just transitioned from a C182 to an S-LSA (not an RV-12) and was flying in IMC. I'm not sure if the outcome would have been any different flying into an area of reported tornadoes, but it does raise one's eyebrows to the fact that a pilot can get into the IFR system in an S-LSA. It will be interesting to see if the NTSB addresses whether or not the Operating Limitations allow flight into known IMC. I think we know the answer. If this is too much of a tangent, let me know, and I'll delete this post.

UPDATE and CORRECTION: As Prof. Sobel (lon@carolon.net) points out in the below post, N155CL was indeed certificated as "EXPERIMENTAL, EXHIBITION." I had looked on the manufacturer's web page and assumed N155CL was an S-SLA. It is intriguing that it's TYPE was shown as a GLIDER, so I guess someone considered it a motorglider. Sure was a fast one, and not what we usually consider as a motorglider. Even though I did not pick up on it being EXPERIMENTAL, EXHIBITION, it would seem even less likely to be approved for IMC flight than an LSA. I always thought aircraft in those categories stayed pretty close to home, or were flown on a limited basis in test programs, or at airshows. Thanks for the correction, Prof. Sobel.
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Last edited by rv7boy : 08-04-2017 at 03:26 PM. Reason: Added the "UPDATE and CORRECTION."
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  #18  
Old 08-03-2017, 06:56 PM
lon@carolon.net lon@carolon.net is offline
 
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Quote:
Originally Posted by rv7boy View Post
Here's an example of a ATP who had just transitioned from a C182 to an S-LSA (not an RV-12) and was flying in IMC. I'm not sure if the outcome would have been any different flying into an area of reported tornadoes, but it does raise one's eyebrows to the fact that a pilot can get into the IFR system in an S-LSA. It will be interesting to see if the NTSB addresses whether or not the Operating Limitations allow flight into known IMC. I think we know the answer. If this is too much of a tangent, let me know, and I'll delete this post.
It's not too much of a tangent, and it would be interesting to know whether the plane's Operating Limitations allowed it to be flown in IMC. But the plane was registered as an Experimental, Exhibition, not as an SLSA or even an E-LSA, so if the NTSB does say something about whether the plane was legally flown in IMC, it won't tell us whether an E-LSA legally can be.
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  #19  
Old 08-03-2017, 07:05 PM
lon@carolon.net lon@carolon.net is offline
 
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Quote:
Originally Posted by rmartingt View Post
I looked up Order 8130.2, which is where the operating limitations assigned to our aircraft are defined.

https://www.faa.gov/regulations_poli...mentID/1031547

Appendix D lists the various operating limitations and which type of aircraft are supposed to get them. For determining applicability, E-AB aircraft are 191(h) and E-LSA are 191(i); S-LSA is 190.

Item 49 is the IFR limitation, in the "Phase II" section:


This applies to 191(h) and 191(i). So at least by my read of this Order (disclaimer: I'm not a DAR), E-LSA aircraft should be issued operating limitations that permit IFR operation if properly equipped, once they are in Phase II.

S-LSA aircraft get operating limit 6:

What the ASTM standard permits or doesn't isn't necessarily binding on the FAA--IIRC ASTM permits controllable-pitch propellers and retractable gear, but the FAA does not.
Bob, Thanks for this, very much. Your post is the first I've seen that actually cites chapter and verse. I'm amazed that you were able to find and understand the information. You said you're not a DAR; but you must be some sort of aviation professional. I say that because I've taught tax law to law students. I even wrote a tax book for lawyers. And though tax law has a reputation for being complicated and difficult to understand, what you found and explained is much more difficult. It's like a treasure hunt with obscure clues. So, again, thanks.
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  #20  
Old 08-04-2017, 01:22 AM
Rrhsch Rrhsch is offline
 
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Default 8130.2J dated 7/21/2017

Phase 2 operating limitations for 191i ELSA in order 8130.2J released 7/21/2017
Appendix D-1 item 50. This is located at the end of the document if you want to look it up.

Instrument flight operations are authorized if the instruments specified in § 91.205(d) are installed, operational, compliant with the performance requirements of, and maintained per the applicable regulations. The pilot in command must have a method to comply with the § 91.319(c) prohibition from operating over densely populated areas or in congested airways. 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. (50)

The limitation for IFR in VFR conditions only applies if the following:

D-4 f. Aircraft with very high risk factors or safety of flight issues must have those factors properly mitigated. Restrict operations to a specified geographical area, and prohibit the carriage of passengers, flight over densely populated areas, and night or instrument flight rules (unless restricted to visual meteorological conditions (VMC)) operations for any of the
following conditions:
(1) Aircraft for which the applicant has surrendered a special LSA airworthiness certificate (§ 21.190) and is applying for an experimental airworthiness certificate (§ 21.191) for the first time, and is not in compliance with § 91.327(b)(3) or (4);
(2) Aircraft for which the manufacturer’s or country of origin’s emergency checklist requires bailout or ejection in the event of an engine or other system failure;
(3) Any aircraft in which a single system failure will render the aircraft uncontrollable, such as an airplane with a hydraulic flight control system with only one hydraulic pump;
(4) Aircraft unable to comply with § 91.117(a) in normal cruise configuration; and
(5) Rocket-powered aircraft.

IFR flight in IMC is aloud in a properly equipped and maintained ELSA provided the pilot is rated and current. The POH must be changed to include:
"Instrument flight operations are authorized if the instruments specified in § 91.205(d) are installed, operational, compliant with the performance requirements of, and maintained per the applicable regulations."

All references to "VFR only" must be removed.

Please tell me if I have missed something.
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