UAvionix install

[Tom Baker]

I think what he was trying to say, is you can't remove the Light Sport decal and install the Experimental decal until the DAR inspection is completed. 

[SportFlyer1]

If I take my E-LSA and add retractable gear and a spiffy new constant speed prop, is it now an EAB?

[FlyingMonkey]

19 hours ago, N456TS said:

No, you can't change them ever.  Those placards have to there at all times to be airworthy.  E-LSA has to have the passenger warning and "experimental" has to be visible.  For S-LSA, "Light Sport" on the side of the hull is a requirement.  All these requirements listed in the FARs.  These aren't ASTM specs. 

After the airworthiness is issued, you're free to change other placards.  Provided you equip the aircraft properly per 91.205(d), you could choose to remove the NO IMC placard. 

Maybe I was not clear.  You can't change from the factory, S-LSA placards and markings until the DAR inspection is complete and the new airworthiness certificate is issues.  Then you MUST change to the E-LSA required passenger warning and experimental markings.  Once E-LSA no other markings are required, except an N-number of course.  But even that could be changed to 3" lettering as an experimental. 

I meant remove the old S-LSA markings, not the new experimental ones.

[FlyingMonkey]

1 hour ago, SportFlyer1 said:

If I take my E-LSA and add retractable gear and a spiffy new constant speed prop, is it now an EAB?

No, now it's just illegal.

[coppercity]

4 hours ago, FlyingMonkey said:

No, now it's just illegal.

And then looks like this

 

[N456TS]

4 hours ago, FlyingMonkey said:

No, now it's just illegal.

I'm not trying to be picky, but that's not illegal.  You can have an E-LSA that is not a Light Sport.  So, go ahead and take an S-LSA and change it to E-LSA.  Then add retractable gear.  Still legal, but no longer a light sport and requires at least a PPL to operate it.  The aircraft is legal.  These regulations are really great and these edge examples are where they shine. 

[Ed Cesnalis]

37 minutes ago, N456TS said:

I'm not trying to be picky, but that's not illegal.  You can have an E-LSA that is not a Light Sport.  So, go ahead and take an S-LSA and change it to E-LSA.  Then add retractable gear.  Still legal, but no longer a light sport and requires at least a PPL to operate it.  The aircraft is legal.  These regulations are really great and these edge examples are where they shine. 

There is no path from SLSA or ELSA to EAB.   The mod would leave it an ELSA that is modified and no longer in compliance.

 

[Tom Baker]

I think what he was trying to say, is you can't remove the Light Sport decal and install the Experimental decal until the DAR inspection is completed. 

I didn't take the time to look it up, but there might be a different experimental category that you could put it under, but it wouldn't be EAB. If there is a route, it is likely going to have restrictive operating limitations. 

[N456TS]

On 8/10/2017 at 11:06 PM, Ed Cesnalis said:

The mod would leave it an ELSA that is modified and no longer in compliance.

No longer in compliance of what?  You can make an E-LSA not a light sport.  It legal.  Show me the regulation that says otherwise and I can edit the notes in my head.  I could be remembering this incorrectly, but we went though this in a class and clear it up.  The A/W would be an E-LSA, but it wouldn't be a light sport.  The regulation that proves this path could exist it that the FAA specifically states that if you add a constant speed prop, not only would it be no longer be defined as a "Light sport", but if that modification were to be removed, it still can't be considered a light sport.  The fact that they have that specific event outlined shows that this could be done.  This is all just theory, as I doubt anyone will ever do any of this. 

[Ed Cesnalis]

10 minutes ago, N456TS said:

No longer in compliance of what?  You can make an E-LSA not a light sport.  It legal.  Show me the regulation that says otherwise and I can edit the notes in my head.  I could be remembering this incorrectly, but we went though this in a class and clear it up.  The A/W would be an E-LSA, but it wouldn't be a light sport.  The regulation that proves this path could exist it that the FAA specifically states that if you add a constant speed prop, not only would it be no longer be defined as a "Light sport", but if that modification were to be removed, it still can't be considered a light sport.  The fact that they have that specific event outlined shows that this could be done.  This is all just theory, as I doubt anyone will ever do any of this. 

 

[SportFlyer1]

I believe you are correct. By doing something that allows your E-LSA to go faster, you create an E-LSA that doesn't conform to light sport limitations and can only be flown by a PPL or better. As I recall, an EAB must meet the 51% owner build rule, and of course the E-LSA doesn't. But we throw the 'experimental' umbrella over both of them. As a light sport pilot, I can only fly planes that conform to light sport limitations, no matter what the category.

I must confess to contributing to wandering off the original (and interesting) uAvionix install topic.... sorry about that.

[Ed Cesnalis]

2 minutes ago, SportFlyer1 said:

I believe you are correct. By doing something that allows your E-LSA to go faster, you create an E-LSA that doesn't conform to light sport limitations and can only be flown by a PPL or better. As I recall, an EAB must meet the 51% owner build rule, and of course the E-LSA doesn't. But we throw the 'experimental' umbrella over both of them. As a light sport pilot, I can only fly planes that conform to light sport limitations, no matter what the category.

I must confess to contributing to wandering off the original (and interesting) uAvionix install topic.... sorry about that.

A PPL cannot legally fly it either because it doesn't become an EAB when you make it faster.  

[N456TS]

4 minutes ago, SportFlyer1 said:

I must confess to contributing to wandering off the original (and interesting) uAvionix install topic.... sorry about that.

Fully my fault.

[N456TS]

1 minute ago, Ed Cesnalis said:

A PPL cannot legally fly it either because it doesn't become an EAB when you make it faster.  

EAB isn't a requirement??!?!?  I don't understand where you're coming from.  Show the FARs.

[Ed Cesnalis]

1 minute ago, N456TS said:

EAB isn't a requirement??!?!?  I don't understand where you're coming from.  Show the FARs.

There is no FAR to show you.  Why do you assume a modified light sport becomes an Experimental Armature Built?  This cannot be done but you assume it happens.

I don't know what you mean by 'EAB isn't a requirement??!?!?' 

[N456TS]

Just now, Ed Cesnalis said:

There is no FAR to show you.  Why do you assume a modified light sport becomes an Experimental Armature Built?  This cannot be done but you assume it happens.

I don't know what you mean by 'EAB isn't a requirement??!?!?' 

We're talking about an aircraft with an A/W given under E-LSA.  There is NO A/W change required to make modifications.  The "E" of E-LSA is experimental!  You're assuming that an E-LSA is bound by the limitations of the definition of "Light sport".  I'm telling you that you can modify the aircraft to the point which is no longer meets the definition of "light sport".  A person who has a light sport certificate would no longer be able to fly it.  The A/W would not change.  It's still an E-LSA.  There is no need to modify the A/W and I'm not sure there is a category which is even could be move to.  A/W of E-LSA doesn't always mean it's a "Light Sport"...unless there is a regulation which says otherwise.  If there is a regulation showing a limitation, I would happily accept it and edit the notes in my head.  This is all just theory as I don't expect anyone to ever do this.  But then again, the FAA thought LSAs would only be "fat ultralights" and 200 HP engines would never be fitted in LSAs...

[Ed Cesnalis]

51 minutes ago, N456TS said:

We're talking about an aircraft with an A/W given under E-LSA.  There is NO A/W change required to make modifications.  The "E" of E-LSA is experimental!  You're assuming that an E-LSA is bound by the limitations of the definition of "Light sport".  I'm telling you that you can modify the aircraft to the point which is no longer meets the definition of "light sport".  A person who has a light sport certificate would no longer be able to fly it.  The A/W would not change.  It's still an E-LSA.  There is no need to modify the A/W and I'm not sure there is a category which is even could be move to.  A/W of E-LSA doesn't always mean it's a "Light Sport"...unless there is a regulation which says otherwise.  If there is a regulation showing a limitation, I would happily accept it and edit the notes in my head.  This is all just theory as I don't expect anyone to ever do this.  But then again, the FAA thought LSAs would only be "fat ultralights" and 200 HP engines would never be fitted in LSAs...

Okay I see what you mean.  Guess I can put a turbo upgrade on my CTSW and go a lot faster

[Tom Baker]

21.191 covers experimental airworthiness certificate. The certificate for a ELSA is issued for the specific purpose of operating a light sport aircraft. The key here is "operating a light sport aircraft". A certificate that was issued specifically for the purpose of operating a light sport aircraft doesn't seem like it would be valid for operating a aircraft that is no longer meets the definition.

[FlyingMonkey]

2 hours ago, N456TS said:

We're talking about an aircraft with an A/W given under E-LSA.  There is NO A/W change required to make modifications.  The "E" of E-LSA is experimental!  You're assuming that an E-LSA is bound by the limitations of the definition of "Light sport".  I'm telling you that you can modify the aircraft to the point which is no longer meets the definition of "light sport".  A person who has a light sport certificate would no longer be able to fly it.  The A/W would not change.  It's still an E-LSA.  There is no need to modify the A/W and I'm not sure there is a category which is even could be move to.  A/W of E-LSA doesn't always mean it's a "Light Sport"...unless there is a regulation which says otherwise.  If there is a regulation showing a limitation, I would happily accept it and edit the notes in my head.  This is all just theory as I don't expect anyone to ever do this.  But then again, the FAA thought LSAs would only be "fat ultralights" and 200 HP engines would never be fitted in LSAs...

You *can* make changes that take it out of light Sport, but then it's no longer legal.  It's an E-LSA, and must continue to meet the definition of a Light Sport Aircraft.  If you read the regs for that definition, two of the points are:

*  Fixed pitch or ground adjustable prop

*  Fixed gear

As well as all the performance criteria (Vs1 of 45kt or less, Vh of 120kt CAS at sea level in a standard atmosphere, etc).

Just because it's experimental doesn't mean you can literally do anything and it stays legal.  Each type of experimental (E-AB, E-LSA, Exhibition) has its own limitations.  For an E-LSA, the aircraft must continuously meet the definition of a Light Sport Aircraft, including fixed prop and fixed gear.   You *might* be able to make an exhibition airplane out of it, but I don't know if there is a regulatory path to do that, or if a DAR would sign off that change.    

[Ed Cesnalis]

2 minutes ago, FlyingMonkey said:

You *can* make changes that take it out of light Sport, but then it's no longer legal.  It's an E-LSA, and must continue to meet the definition of a Light Sport Aircraft.  If you read the regs for that definition, two of the points are:

*  Fixed pitch or ground adjustable prop

*  Fixed gear

As well as all the performance criteria (Vs1 of 45kt or less, Vh of 120kt CAS at sea level in a standard atmosphere, etc).

Just because it's experimental doesn't mean you can literally do anything and it stays legal.  Each type of experimental (E-AB, E-LSA, Exhibition) has its own limitations.  For an E-LSA, the aircraft must continuously meet the definition of a Light Sport Aircraft, including fixed prop and fixed gear.   You *might* be able to make an exhibition airplane out of it, but I don't know if there is a regulatory path to do that, or if a DAR would sign off that change.    

Instead of reading the regs for the definintion of light sport we should read the same regs (light sport rule) to see the language that limits the modifications.

[FlyingMonkey]

33 minutes ago, Ed Cesnalis said:

Instead of reading the regs for the definintion of light sport we should read the same regs (light sport rule) to see the language that limits the modifications.

The rules are clear that an E-LSA must continue to meet the definition of an LSA.  There is no LSA, whether S-LSA, E-LSA, E-AB, or legacy certified airplane, that can have retractable gear and/or an in-flight adjustable prop.  Those items make it illegal for use as an LSA forever after, the same as having a gross weight over 1320lb (1430 amphib) would do so.  It's just part of the definition, and the rules state that if the airplane has *ever* not met the definition of an LSA, it never can again. 

Believe me, I wish it were not so!  

[Ed Cesnalis]

31 minutes ago, FlyingMonkey said:

The rules are clear that an E-LSA must continue to meet the definition of an LSA.  There is no LSA, whether S-LSA, E-LSA, E-AB, or legacy certified airplane, that can have retractable gear and/or an in-flight adjustable prop.  Those items make it illegal for use as an LSA forever after, the same as having a gross weight over 1320lb (1430 amphib) would do so.  It's just part of the definition, and the rules state that if the airplane has *ever* not met the definition of an LSA, it never can again. 

Believe me, I wish it were not so!  

I do believe you, but Tango Sierra isn't saying the modified plane would be 'legal LSA' for the purpose of flying with sport pilot privileges. He is saying that the  ELSA can be modified because its experimental and can be flown by a PPL because he is not limited and it already has an AW cert.

If there is no hurdle to cross there must be an FAR that is being violated to point at or Tango Sierra is right.  

If there is no language to prohibit the mod what stops me from upgrading to turbo?

[Tom Baker]

40 minutes ago, Ed Cesnalis said:

I do believe you, but Tango Sierra isn't saying the modified plane would be 'legal LSA' for the purpose of flying with sport pilot privileges. He is saying that the  ELSA can be modified because its experimental and can be flown by a PPL because he is not limited and it already has an AW cert.

If there is no hurdle to cross there must be an FAR that is being violated to point at or Tango Sierra is right.  

If there is no language to prohibit the mod what stops me from upgrading to turbo?

The regulation the airworthiness certificate is issued under specifically says it is for operating a light sport aircraft.

[Ed Cesnalis]

43 minutes ago, Tom Baker said:

The regulation the airworthiness certificate is issued under specifically says it is for operating a light sport aircraft.

5 hours ago, N456TS said:

EAB isn't a requirement??!?!?  I don't understand where you're coming from.  Show the FARs.

Tom, you are correct but that is ambiguous. Someone may rely on it when prosecuting enforcement but will they prevail?

Tango Sierra, I can't find a reg or an FAR but I think I found the rub. "The operating limitations issued to the aircraft as a part of its airworthiness certificate will include language that outlines the procedure for approval of a major change. The owner/operator needs to follow the procedure as outlined in the operating limitations if they want to incorporate a major change to the aircraft."  So maybe you could do what you want if you could get the operating limitations to be permissive enough?

It doesn't look like you could go for a retractable gear modification because you would not have been able to get the operating limitations that would permit included in your AW cert. 

 

 

PART 21—CERTIFICATION PROCEDURES FOR PRODUCTS AND ARTICLES

Subpart B—Type Certificates

§21.191   Experimental certificates. Experimental certificates are issued for the following purposes:

(i) Operating light-sport aircraft. Operating a light-sport aircraft that—

 

(1) Has not been issued a U.S. or foreign airworthiness certificate and does not meet the provisions of §103.1 of this chapter. An experimental certificate will not be issued under this paragraph for these aircraft after January 31, 2008;

(2) Has been assembled—

(i) From an aircraft kit for which the applicant can provide the information required by §21.193(e); and

(ii) In accordance with manufacturer's assembly instructions that meet an applicable consensus standard; or

(3) Has been previously issued a special airworthiness certificate in the light-sport category under §21.190.

 

[FlyingMonkey]

1 hour ago, Ed Cesnalis said:

I do believe you, but Tango Sierra isn't saying the modified plane would be 'legal LSA' for the purpose of flying with sport pilot privileges. He is saying that the  ELSA can be modified because its experimental and can be flown by a PPL because he is not limited and it already has an AW cert.

If there is no hurdle to cross there must be an FAR that is being violated to point at or Tango Sierra is right.  

If there is no language to prohibit the mod what stops me from upgrading to turbo?

I understand what he's saying.  But experimental or not, it's still a LIGHT SPORT AIRCRAFT.  You'd have to change the AW cert to something other than E-LSA.  The word "experimental" isn't magic, and doesn't mean you can do whatever you want.  In fact, the uniqueness of the E-LSA is that you can convert another AW type (S-LSA) to an E-LSA.  Other than Experimental Exhibition or Experimental R&D (I think there is such a cert), no other AW type allows that.  The part after "Experimental" matters -- in this case the airplane must be operated as a Light Sport Aircraft.  You can't just declare "I don't want to play the LSA game anymore" and make the "LSA" part go away.  You'd need to change the AW certificate type, and as I said there is no other place to go except possibly E-Exhibition.

This is not a gray area, really.  The regs are clear.