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Three-Inch Tail Numbers--Possible?


DocRon

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I have always disliked large tail numbers on my CTLS.  When I checked on the legality of smaller numbers after I purchased the aircraft, this appeared to be illegal. I just re-checked the Advisory Circular (AC45-2D) and that appears to have changed.  I'd appreciate your opinions before I run out and spend money to further beautify my CT.

 

In Table 2, page 9 of that document,  it notes: under Fixed-wing aircraft:  Minimum Height 12 inches (with exceptions as shown in Table 3.)

 

In Table 3, page 12, it notes: Displaying a minimum-height N-number on exhibition, amateur-built, or light-sport aircraft with a maximum cruising speed of 180 knots or less:

(1) If you display N-numbers on each side of the vertical tail surface, the minimum height for a newly painted mark is 3 inches, except for antique aircraft, or aircraft with the same external configuration as an aircraft built at least 30 years ago.  Details are found in 45.22(B)(1)

 

(Personal Note: this refers to 14CFR 45.22(B)(1) which notes these older aircraft can use 2-inch letters.)

 

So, Gentlemen, am I reading into this what I want to read?  Or, can we switch to 3-inch tail numbers displayed on the vertical stabilizer that will further enhance the beauty of our aircraft?  I'd certainly appreciate your opinions.

AC 45-2D.pdf

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In Table 2 it says (under Aircraft Type)

 

 

Experimental aircraft—exhibition, amateur-built, and light-sport aircraft with a maximum cruising speed of 180 knots or less

 

In Table 3, it says (under Circumstances)

 

Displaying a minimum-height N-number on exhibition, amateur-built, or light-sport aircraft with a maximum cruising speed of 180 knots or less

(Note: Table 3 are exceptions to Table 2). 

 

Note they dropped the "Experimental aircraft--", but as Table 3 are exceptions to Table 2  I believe the 3 inch allowance was intended to apply to Experimental aircraft only, whether they are exhibition, amateur built or light sport.  Thus I do not think S-LSA would get the benefit of the the allowance.  Just my reading--not even close to being an expert on this (or any flying) topic.

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In Table 2 it says (under Aircraft Type)

 

 

Experimental aircraft—exhibition, amateur-built, and light-sport aircraft with a maximum cruising speed of 180 knots or less

 

In Table 3, it says (under Circumstances)

 

Displaying a minimum-height N-number on exhibition, amateur-built, or light-sport aircraft with a maximum cruising speed of 180 knots or less

(Note: Table 3 are exceptions to Table 2). 

 

Note they dropped the "Experimental aircraft--", but as Table 3 are exceptions to Table 2  I believe the 3 inch allowance was intended to apply to Experimental aircraft only, whether they are exhibition, amateur built or light sport.  Thus I do not think S-LSA would get the benefit of the the allowance.  Just my reading--not even close to being an expert on this (or any flying) topic.

 

I agree.  In general it seems they want to keep these smaller numbers on experimentals (of any type) only.  If you have an E-LSA you are golden.

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OK, consider that this AC appears to address E-LSA and S-LSA separately.  The E--LSA reference is on the bottom of page 8, and the SLSA reference is on the top of page 9, with the applicable exceptions on page 12.

 

There are also differences in these two references on where the N-number can be placed.  The E-LSA location is stated as both sides of the fuselage OR both sides of the vertical tail surface.  The S-LSA location is stated as on both sides of the vertical tail surface only.

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Sorry Ron I don't see where it implies S-LSA goes on Vertical tail surface only.  (Top of page 9 clearly states "or").

 

Also in looking at section CFR§ 45.29, the reference to 21.191(i) (in (iii) below) appears to knock out E-LSA if they are conerted S-LSA's.

 

Size of marks.

(a) Except as provided in paragraph (f) of this section, each operator of an aircraft must display marks on the aircraft meeting the size requirements of this section.
("b") Height. Except as provided in paragraph (h) of this part, the nationality and registration marks must be of equal height and on—
(1) Fixed-wing aircraft, must be at least 12 inches high, except that:
(i) An aircraft displaying marks at least 2 inches high before November 1, 1981 and an aircraft manufactured after November 2, 1981, but before January 1, 1983, may display those marks until the aircraft is repainted or the marks are repainted, restored, or changed;
(ii) Marks at least 3 inches high may be displayed on a glider;
(iii) Marks at least 3 inches high may be displayed on an aircraft for which the FAA has issued an experimental certificate under § 21.191 (d), § 21.191 (g), or § 21.191 (i) of this chapter to operate as an exhibition aircraft, an amateur-built aircraft, or a light-sport aircraft when the maximum cruising speed of the aircraft does not exceed 180 knots CAS; and
(iv) Marks may be displayed on an exhibition, antique, or other aircraft in accordance with § 45.22.
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This gets more and more complicated.  You would think one Advisory Circular would definitively state the standard.  I'll go deeper and wade into 45.22 and 45.29.  I'd better look at the 21XX series too.

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Ron,

Be careful. An AC is not regulatory (unless included by reference in a reg). It may describe a way to comply with regulations but what I'm saying is if in doubt it may be better to go to the regulation and try to understand it, using the AC as a guide, rather than go to the AC and trying to see if the Reg supports it. Twisted logic, maybe, but the way the FAA would approach it. Said another way, there may be other acceptable ways to comply with the Reg than the AC.

With any regulatory question, it helps to go to the earliest or most basic citation and work forward, paying careful attention to applicability.

I'm not trying to teach you individually to suck eggs, only making a general observation for the readers to keep in mine.

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I must conclude that you are correct, all of you.  14 CFR 45.29 (B) (1) covers experimental aircraft but not any S-LSA ones regarding three-inch N-numbers.  For smaller surfaces between the trailing edge of the wing and the tail there is an exception that covers us folks with less surface area, e.g. "as large as practicable".

 

However, Advisory Circular 45-2D does say (my interpretation) that S-LSA can use three-inch N-numbers on the vertical tail surface.

 

I (sadly) agree that I'm "spitting into the wind" on this.  "Illogical" on different rules for E-LSA and S-LSA with the same aircraft type is no defense.  (Sigh...)

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