Fred,
Background,
12AY started as Marvin Alverez's aircraft 139AB, fixed pitch Classic
Trigear. I bought it to use as a test bed, but I had to rebuild so much
of it, replace wings, gut the fuselage to fix the gear, wing incidence
problems required a full redo of the cockpit sides, pulled the top and
replaced, pull out the pitch system, fuel tank and tail tube, rebuilt
the stabs, rebuilt the foam fin, replaced the doors and converted the
engine mount and cowl for the XS, so it is now a new kit 054A and my
FSDO allowed it as a new build. 800 hours in that sucker less paint and
finish. The only thing original is the rudder hinges. Even the
original rudder delaminated. Hell of a deal, but I am too picky I
guess, anyone else would have just flown it as it did so, provided you
didn't stall it.
So, just prior to registration of my aircraft in Dec 2009 I did the
following. I ran the conversion problems of the Europa Classic Kit by
my FSDO, (many different answers from FSDOs and the FAA home office) and
as the owner/builder, and since I am doing a modification by adding VGs
within the phase one modifications ruling during the 40 hour fly off, I
am establishing my aircraft as an Experimental Amateur Built LSA
(EABLSA) through flight test (that controllable at 45 kts rule is tough
with a short wing and my max continuous speed is 122). My new
modifications made in the 40 hour fly off, satisfies that my intent was
to make it an amateur built experimental LSA from the start and the
plane needed tweaking. Logged it all in the book for sure. I have not
lost my medical, I'm doing this to give you guys who haven't finished
your aircraft an opportunity to work within the rules and continue to
finish your aircraft as an Experimental Amateur Built LSA if you have
lost your medical.
Fred, your ELSA assumption is correct! The rules suck. I have test
flown and established that my aircraft meets EABLSA rules. Should I now
make changes which removes the plane out of EABLSA, it can never be an
LSA again according to the FAA maintenance guys! Here is the rub, my
12AY will also be used to test the new AP420 constant speed and that
will not make it eligible for LSA unless I lie about it and never log
the conversions. I'm not keen on that. The prop change is considered
by the maintenance guys as a major modification and requires another log
book entry and a mother may I from the FSDO. My FSDO disagrees, but it
is looking that will be overruled by the maintenance guys at FAA under
the LSA . The Registration of my aircraft, and my airworthiness
certificate does not note the plane has a constant speed prop or not on
an airworthiness certificate on a Tri-gear Experimental Amateur Built
aircraft that just happens to meet LSA criteria. It is confusing.
Technically, because of the rules that the LSA qualified plane
"continuously" has met the LSA criteria , although I can pull the fixed
pitch prop and VGs off, put on another prop, take it off again, put the
VGs and fixed prop back on and tweak my flap (my wing area is a bit less
than the XS at only 96 square feet so I have to do that on my plane) I
have removed it from LSA criteria by changing the prop and or pull my
VGs.
To all,
I talked with Larry Buchannan and Edsel Ford at the FAA (LSA division)
and Brad Outlaw of the DAR area (he is the guy who helped me with the
proper way to convert to the MG) and they agree that this flight test
method I am using is allowable within the LSA and Experimental rules.
As for modifying a flying a Classic, the problem is you get different
answers. Suffice to say, if a plane was a mono wheel (a retractable
gear aircraft) on its airworthiness certificate, never intended as an
LSA or to meet it's criteria, it has not met the "continuous" use in the
LSA criteria. FSDOs didn't mind the prop change (or gear during phase
1), but the maintenance division was adamant that it is a major
modification, and the plane did not continuously meet the LSA criteria
even if modified during the 40 hour phase 1. Granted the maintainers
work in the certified world, the point is, the flying mono to trigear is
a major modification (not just a minor mod which I prefer) and the plane
was a complex aircraft and never intended nor did it meet the continuous
LSA criteria (that's true). As I write this, the experimenters and
maintainers are discussing that an experimental amateur built aircraft
is not built with a manufacturers equipment list, so changing the prop,
or other equipment even with another fixed prop is a bit of a rub.
I tried to weasel my way into also allowing the flying classic
mono-wheel to be converted and that is, according to the FAA
regulations, illegal. I argued that the experimental plane is a
continuous experiment and actually rarely does the owner call it truly
completed. The experimenters know what I mean, we are always tweaking
equipment, engine, props, fuel system, drag devices etc. Once Phase 1
is completed, the plane, according to the maintainers is technically set
in stone, FSDOs know better and don't want to be bothered by all the
little stuff we do, and prefer to only know about major changes such as
gear and wings. LSA criteria though is set in stone ( but it is not
necessarily solid). The only win I had was with the vortex generators.
They are not lift augmenting devices and as such do not fall under the
major modification changes and can be added.
Please don't fudge your log books (for those of you who have them and or
failed to make the Phase 1 complete write up) to try to do this. It is
not worth it.
This LSA conversion I am doing to the Europa kit is allowable, provided
the owner never registered the plane at a gross weight that exceeds 1320
lbs and you make it meet the LSA criteria. Hell, there are guys flying
RV9s as LSAs. That's not right, as if he ever fills the tanks full with
two people (170 lbs each), it is no longer an LSA (to the purist), but
it meets the criteria.
Final advice to Europa Owners,
Conversion of a flying mono or trigear classic to Experimental Amateur
Built Light Sport Aircraft is not possible. Even the Tri-gear didn't
continuously meet the criteria and is prohibited.
This also brings up what is the proper way to do a MG conversion (and it
provides an example for the FAA to work with to give the FSDOs ).
Example I used with the FAA: Europa Classic trigear registered at
1320lbs.
Builder contacts his DAR and says I am attempting to fly my aircraft as
an LSA come and give me an airworthiness inspection.
Initial stall speed in tests of 49 KTS observed.
Owner/manufacturer modifies to meet LSA and adds vortex generators etc
and meets the basic LSA criteria.
Completes his fly off and the aircraft must stay an LSA always.
Now, let's say I want to add MG wings, I cannot add MG wings and fly
then go back to LSA because the aircraft was not continuously flown in
the LSA criteria.
For you MG guys, How do you convert properly your XS or Classic to a
MG.
Owner contacts his FSDO and says I am adding MG wings to my Europa
XS/Classic.
He requests: I will need my original test fly area (or new one if you
moved) to be approved for an additional Phase 1 fly off of the new
wings.
I will test fly the aircraft for 10 hours minimum, or as required, to
confirm the wings are safe and meet the kit plane manufacturers
criteria.
Owner/manufacturer builds his wings. FSDO may simply allow you to do
this on your own, and go fly, or he may, if you made him mad, require a
DAR to look at the wings before flight and check your weight and
balance...
Owner records his changes and performs a weight and balance.
Flight test the wings under the Phase 1 approval above.
Your FSDO, if he is a purist, adds notes that the aircraft airworthiness
certificate with long wings is an experimental glider, and with the
short wings is an experimental airplane.
Personal note: I prefer the motor glider to an LSA. I have a better
cruising speed and a safer plane in my estimation, and do not need a
medical at all. Paperwork is minimal and is a known quantity. Working
with the FAA is a breeze.
Also, the VGs are quite a good safety device and do lower the stall
speed a couple of knots and improve low speed handling without causing a
significant reduction in airspeed. Watch out though because it flies so
well, it is easy to get slow.
Now to decide on the prop... It seems that if I never complete phase 1
I can change props as I may become a glider, and if it is not recorded,
(after all my intentions are good, I only strayed a short time) I may be
able to get away with this. I need a lawyer, and a sympathetic jury.
Much info and miss info out there, even from me and your FSDO and now
you know where I am coming from, why I am test flying an pushing.
I missed two hours of work, got'ta get back.
Bud
References:
Title 14
FAA Part 1
1.1 abbreviations
Light-sport aircraft means an aircraft, other than a helicopter or
powered-lift that, since its original certification, has continued to
meet the following:
(1) A maximum takeoff weight of not more than-
(i) 1,320 pounds (600 kilograms) for aircraft not intended for operation
on water; or
(ii) 1,430 pounds (650 kilograms) for an aircraft intended for operation
on water.
(2) A maximum airspeed in level flight with maximum continuous power
(VH) of not more than 120 knots CAS under standard atmospheric
conditions at sea level.
(3) A maximum never-exceed speed (VNE) of not more than 120 knots CAS
for a glider.
(4) A maximum stalling speed or minimum steady flight speed without the
use of lift-enhancing devices (VS1) of not more than 45 knots CAS at the
aircraft's maximum certificated takeoff weight and most critical center
of gravity.
(5) A maximum seating capacity of no more than two persons, including
the pilot.
(6) A single, reciprocating engine, if powered.
(7) A fixed or ground-adjustable propeller if a powered aircraft other
than a powered glider.
(8) A fixed or autofeathering propeller system if a powered glider.
(9) A fixed-pitch, semi-rigid, teetering, two-blade rotor system, if a
gyroplane.
(10) A nonpressurized cabin, if equipped with a cabin.
(11) Fixed landing gear, except for an aircraft intended for operation
on water or a glider.
(12) Fixed or retractable landing gear, or a hull, for an aircraft
intended for operation on water.
(13) Fixed or retractable landing gear for a glider.
----- Original Message -----
From: Fred Klein<mailto:fklein@orcasonline.com>
To: europa-list@matronics.com<mailto:europa-list@matronics.com>
Sent: Tuesday, July 20, 2010 6:31 PM
Subject: Re: Europa-List: ELSA
On Jul 20, 2010, at 10:49 AM, Bud Yerly wrote:
If you are a weight zealot, the XS should be eligible provided you
have not already registered it's gross weight as over 1320. Darn those
rules.
Bud,
Thanks for the comprehensive background on making an XS into an
ELSA...I take it that N12AY is Clive's airplane.
So here's a question:
...suppose one registers his XS mono w/ a FP prop and with a gross
weight of 1320 as an experimental...then, later...takes it back to the
shop, converts it to a fixed tri or conventional gear (w/ dirty, grimy
wheel pants), adds the VGs to further slow it down, and does the
requisite flight tests to show the plane's within the LSA envelope...
Can it them become an ELSA? Can you recommend an FAA contact to run
this by, if you'd rather not speculate?
Thanks,
Fred
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