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RV-12 and actual IFR......

rvbuilder2002

Legacy Member
Mentor
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.
 
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.
 
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?
 
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: "????"
 
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.
 
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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 :eek:. Just my opinion...
 
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.
 
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.
 
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.
 
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!
 
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?
 
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).
 
I looked up Order 8130.2, which is where the operating limitations assigned to our aircraft are defined.

https://www.faa.gov/regulations_pol...fm/go/document.information/documentID/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:
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:
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.
 
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?
 
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?
 
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.
 
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 ([email protected]) 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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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.
 
I looked up Order 8130.2, which is where the operating limitations assigned to our aircraft are defined.

https://www.faa.gov/regulations_pol...fm/go/document.information/documentID/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.
 
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.
 
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.

I'm an aircraft systems engineer. I deal mostly with Part 25 at work, but I was on the Part 23 ASTM committee for a while and have done some digging on other questions as well (e.g. the specifics of why certified airplanes "need" TSO'ed ADS-B equipment... the answer will surprise you). I'm not going to lie--part of it is the interest in finding loopholes or unexploited openings that we in the light GA community could use, and part of it is trying to find contradictory, outdated, or useless regs in the vain hope that the FAA will have to do something about them if I pester them them enough.
 
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.

Sorry, but I grabbed the wrong section. I should have grabbed Appendix D-1 item 49 not 50.

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. (49)
 
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).


Scott, FYI, directly from my op/limitations (issued 12/28/2013) - ELSA.

(10) This aircraft is to be operated under VFR day only.

(11) 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.


I already had the lights installed so I had assumed I was fully cleared to flight at night (fly under Private cert.) Had also assumed, that if I added appropriate equipment that I could legally fly in instrument flight conditions, not that I have any plans of doing that in an RV-12 but it appears that door was left open.
 
Scott, FYI, directly from my op/limitations (issued 12/28/2013) - ELSA.

(10) This aircraft is to be operated under VFR day only.

(11) 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.

There you go - third party confirmation. This paragraph should be the norm, not the exception. If someone has an E-LSA lacking this in the OL, I suggest you call up your DAR and have them correct it. :) Experimental is the core of aviation!
 
There you go - third party confirmation. This paragraph should be the norm, not the exception. If someone has an E-LSA lacking this in the OL, I suggest you call up your DAR and have them correct it. :) Experimental is the core of aviation!

The actual wording has changed since then but the effect is the same. Current wording is:

19. Day VFR flight operations are authorized.
Night flight operations are authorized if the instruments specified in § 91.205(c) are installed, operational, and maintained in accordance with the applicable requirements of part 91.
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 the person returning the aircraft to service. (41)
 
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This is the FAA's stance, at least for type certified aircraft that are not approved for IFR flight.

ORDER 8900.1, Volume 5.

5-439 USE OF AIRCRAFT NOT APPROVED FOR IFR OPERATIONS UNDER ITS TYPE CERTIFICATE FOR INSTRUMENT TRAINING AND/OR AIRMAN CERTIFICATION TESTING. The following paragraphs are intended to clarify the use of an aircraft not approved for IFR operations under its type certificate for instrument flight training and/or airman certification testing.

A. IFR Training in Visual Meteorological Conditions (VMC). Instrument flight training may be conducted during VMC in any aircraft that meets the equipment requirements of part 91 , sections (??) 91.109 , 91.205 , and, for an airplane operated in controlled airspace under the IFR system, ?? 91.411 and 91.413 . An aircraft may be operated on an IFR flight plan under IFR in VMC, provided the PIC is properly certificated to operate the aircraft under IFR. However, if the aircraft is not approved for IFR operations under its type certificate, or if the appropriate instruments and equipment are not installed or are not operative, operations in Instrument Meteorological Conditions (IMC) are prohibited. The PIC of such an aircraft must cancel the IFR flight plan in use and avoid flight into IMC.
 
I'm just asking because I am instrument rated. So there's no way me as an instrument rated pilot can fly an rv12 in IMC? or are we just talking about instrument training?
 
If your RV-12 is Amateur built, the operating limitations will state that only day VFR is approved UNLESS it is appropriately equipped IAW the FAR's for night and/or instrument flight. So, equip it properly and you can fly it IMC. Check your Operating Limitations. The new ones issued today and for quite a while have this verbiage mentioned above.

Vic
 
If your RV-12 is Amateur built, the operating limitations will state that only day VFR is approved UNLESS it is appropriately equipped IAW the FAR's for night and/or instrument flight. So, equip it properly and you can fly it IMC. Check your Operating Limitations. The new ones issued today and for quite a while have this verbiage mentioned above.

Vic

sorry, I got twisted, so assuming an RV12 is equipped for IFR
is the following table correct?

use IFR/VMC | IFR/IMC
type
S-LSA not allowed | not allowed
E-LSA allowed | allowed
EAB allowed | allowed

Thanks,
Brian.
 
Why is IFR not allowed for E-LSA?
Assume pilot has a current medical and is IFR rated and current and the plane is IFR equipped.
 
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I'm just wondering where I could fit a GTN625 now on my 12 and how much work to wire into my G3Xs....
 
Considering all the above, that the -12 meets all the FAA requirements for equipment (Instrument Flight) and is an E-AB, what about the engine? Does it need to have a certified version of the 912 to be legal?
 
I'm just wondering where I could fit a GTN625 now on my 12 and how much work to wire into my G3Xs....

Outfitting the RV-12 for a GTN625 or similar sized certified navigator is not a minor effort. The available panel depth is such the connectors are within an inch of the firewall, which limits mounting options. If you want a heated pitot, there is some work to be done for mounting on a wing not designed for a pitot tube installation. Not sure I would go with the GTN625 for IFR, the GTN650 would get you a second COMM and NAV/ILS/GS capability.

John Salak
RV-12 N896HS
 
I mounted a VOR/GS with 3LMB under my panel on the center line so I can shoot practice approaches. With a pitot static check on my XPDR I am legal for IFR.
 
Outfitting the RV-12 for a GTN625 or similar sized certified navigator is not a minor effort. The available panel depth is such the connectors are within an inch of the firewall, which limits mounting options. If you want a heated pitot, there is some work to be done for mounting on a wing not designed for a pitot tube installation. Not sure I would go with the GTN625 for IFR, the GTN650 would get you a second COMM and NAV/ILS/GS capability.

John Salak
RV-12 N896HS

I installed a GTN625 without too much trouble, as well as a Garmin GAP 260 heated pitot with AOA out in the left wing. It?s pretty straight forward process in my opinion.

I went without the NAV/COM, mainly because it was less than 1/2 the price of the GTN650 and also because the only times I?ve done VOR or ILS approaches anymore is for practice, and I have a GTR20 mounted behind the panel that works well.

If you?re building an airplane for hard IFR, yes, dual COM?s and a NAV radio might be your desires for redundancy, but if you think about what type of IFR flying you might actually do in the -12, one radio and GPS will likely be fine. It allows me to do ?gentleman IFR?, such as approaches down through a marine layer, or go flying on days when there?s multiple cloud layers at altitudes that I want to get through. Although it?s a fairly stable and well equipped airplane, I do not have plans to ?launch off into the clag? for hours of IMC that I would do no problem in my Baron.
 
Why is IFR not allowed for E-LSA?
Assume pilot has a current medical and is IFR rated and current and the plane is IFR equipped.
E-LSA not allowed | not allowed:(
Amateur built Equals EAB.

It's been confirmed many, many times now that E-LSAs can fly IFR if equipped per "91.205(d) are installed, operational, and maintained in accordance with the applicable requirements of part 91". There is no dispute. These are settled facts. You're limited by your operating limitations which do grant IFR operation if equipped per 91.205(d).
 
Bradley,

My 12 was licensed in 2012. Some of the guys are saying the OLs now include the POH by reference. The POH says no IFR flight (not IMC). They may have a problem if their OLs now reference the POH.

Rich
 
Bradley,

My 12 was licensed in 2012. Some of the guys are saying the OLs now include the POH by reference. The POH says no IFR flight (not IMC). They may have a problem if their OLs now reference the POH.

Rich

That's interesting, because guess what the POH requirements are for experimental aircraft? None. The only required documents are OL's, registration, AW and weight & balance (and possibly a radio operator license if applicable). OL's referencing a non-required document is in itself a problem.
 
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I agree, Ron, but some of the posts in other threads say their OLs referenced the POH. Looks like regulatory creep. I haven?t seen any of the latest OL language, so I can?t vouch for the accuracy of the claim. Maybe Mel, the DAR, can shed light on what the latest guidance is on OL language.
 
There is indeed some confusion here. Yes the latest operating limitations for ELSA DO reference the AOI:
14. The pilot may only conduct the flight maneuvers authorized in the AOI. (27)

and also later state: 22. 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 the person returning the aircraft to service. (49)

I have sent an email question in to Oklahoma City. Let's see what they say.

BTW, there are quite a few problems with the new 8130.2j Order. We will probably be seeing a revision if not a complete rewrite soon.
 
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They may have a problem if their OLs now reference the POH.

Just as you can modify and equip your aircraft with gear for IFR, you're also able to modify your POH as you wish. Does your panel state "Flights into IMC prohibited"? You're free to change that if you wish. This is experimental aviation. Not bound by Type Certificate. Not bound by ASTM. You're free to modify that E-LSA.
 
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