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coppercity

UAvionix install

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13 minutes ago, Ed Cesnalis said:

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.

 

Not ambiguous.  The regs you quote state "operating a light sport aircraft".  LSA is very clearly defined elsewhere in the FARs, and the minute you deviate from that definition (including adding retract gear), you are no longer "operating a LSA" and your E-LSA AW certificate is no longer in effect.  You have violated its terms and are out of airworthiness.  It's no different from installing a Dynon D-100 in a Skyhawk as a primary flight instrument.  It's not allowed under part 23, you have violated the terms of the AW certificate and the Skyhawk is no longer airworthy under Part 23.

 

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3 minutes ago, FlyingMonkey said:

Not ambiguous.  The regs you quote state "operating a light sport aircraft".  LSA is very clearly defined elsewhere in the FARs, and the minute you deviate from that definition (including adding retract gear), you are no longer "operating a LSA" and your E-LSA AW certificate is no longer in effect.  You have violated its terms and are out of airworthiness.  It's no different from installing a Dynon D-100 in a Skyhawk as a primary flight instrument.  It's not allowed under part 23, you have violated the terms of the AW certificate and the Skyhawk is no longer airworthy under Part 23.

 

Your argument is correct but still argument, there is ambiguity.  The operating limitations is where the point becomes moot. You are poised to find out for yourself, do you think you can provide for mods at issue here?  Not really retract but adjustable prop, flap settings and more horse power are the obvious game changers. Your limitations have to be approved by a human being so anything can happen.

If I was the DAR I would want to limit modifications that increase performance or complexity for the reasons you state above. If enforcement comes into play I bet the operating limitations and the pilots privileges could/would be argued not the interpretation of operating as a light sport.

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Example of gray area:

LSA is defined by weight, performance and complexity.  Make it a retract and its complex and not LSA right?  

Here's a gray area example, a little complexity like in flight operable louvers to enhance cooling.  Not LSA but we all envision this level of enhancement in our ELSA.

 

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Hmm, my head is starting to hurt. Although I just recalled another random regulation tidbit. An E-LSA must be an exact duplicate of an existing S-LSA model. So a company cannot sell an E-LSA kit unless they certified an S-LSA first. The RV-12 is a classic case. The company builds mainly kits and wanted to sell an E-LSA plane, so they grudgingly had to go through the ASTM certification for the RV-12. I believe Dan Johnson does an extensive talk about this in his revue of the Arion Lightning, which is a plane you can buy as S-LSA, E-LSA or EAB ... some fun.

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16 hours ago, Ed Cesnalis said:

Example of gray area:

LSA is defined by weight, performance and complexity.  Make it a retract and its complex and not LSA right?  

Here's a gray area example, a little complexity like in flight operable louvers to enhance cooling.  Not LSA but we all envision this level of enhancement in our ELSA.

 

I honestly don't understand what you are saying.  Louvers do not increase performance, only cooling.  There is no way they would take the airplane out of LSA specs, so they are allowed.  The only gray area is that the FAA trusts that any changes you make are properly vetted to not take the airplane out of LSA spec.  For example, if you changed the reflex on your flaps to -12°, that is a performance change and you'd have to test the change to make sure performance stays within the LSA performance envelope.

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26 minutes ago, FlyingMonkey said:

I honestly don't understand what you are saying.  Louvers do not increase performance, only cooling.  There is no way they would take the airplane out of LSA specs, so they are allowed.  The only gray area is that the FAA trusts that any changes you make are properly vetted to not take the airplane out of LSA spec.  For example, if you changed the reflex on your flaps to -12°, that is a performance change and you'd have to test the change to make sure performance stays within the LSA performance envelope.

You miss my message because you see LSA limitations as being performance related only but they have 4 areas, performance, weight, and complexity.

  • Performance limitations 120kt and 39kts.
  • Weight limitations 1320lbs
  • Passengers - 2 seats
  • Complexity limitations - retractable, in-flight adjustable prop, in fight adjustable 

My gray area example attacked complexity not performance because its more gray.  

 

The example being discussed is retract which is complexity not performance.

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4 minutes ago, Ed Cesnalis said:

You miss my message because you see LSA limitations as being performance related only but they have 4 areas, performance, weight, and complexity.

  • Performance limitations 120kt and 39kts.
  • Weight limitations 1320lbs
  • Passengers - 2 seats
  • Complexity limitations - retractable, in-flight adjustable prop, in fight adjustable 

My gray area example attacked complexity not performance because its more gray.  

 

The example being discussed is retract which is complexity not performance.

The only "complexity" items specified are ground-adjustable or fixed pitch prop, and fixed gear.  No other "complexity" items are mentioned.  It is a general principle of law that something that is not prohibited by law is assumed to be allowed.  Therefore, ANY modification that:

1) is not specifically addressed (gear, prop, etc);

AND

2) Does not take the aircraft out of LSA performance specs; 

is allowed.  There is nothing in the LSA definition that mentions anything adjustable in flight other than the prop and gear.  Would you consider carb heat or flaps to be "gray areas"?  After all, they are adjustable in flight!   :)

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15 minutes ago, FlyingMonkey said:

The only "complexity" items specified are ground-adjustable or fixed pitch prop, and fixed gear.  No other "complexity" items are mentioned.  It is a general principle of law that something that is not prohibited by law is assumed to be allowed.  Therefore, ANY modification that:

1) is not specifically addressed (gear, prop, etc);

AND

2) Does not take the aircraft out of LSA performance specs; 

is allowed.  There is nothing in the LSA definition that mentions anything adjustable in flight other than the prop and gear.  Would you consider carb heat or flaps to be "gray areas"?  After all, they are adjustable in flight!   :)

You might have to go back to the discussions that resulted in the light sport rule to see that the intention behind limiting prop pitch adjustment, retract, and cooling louvers were to limit complexity.  Intent becomes less apparent when looking at the rule only.  

You have decided that only performance prop and gear are limited yet weight passengers and complexity are limited as well.

Another principal of law is that intent demonstrated during the drafting process can be used for clarification when litigated.   

I think we all know you won't get a jump seat installed yet it isn't specifically addressed or performance related.

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26 minutes ago, FlyingMonkey said:

...  Would you consider carb heat or flaps to be "gray areas"?  After all, they are adjustable in flight!   :)

Flaps, carb heat and selectable fuel valves all existed during rule development and here the intent is that the benefit out-weighs complexity unlike retract.

We agree on in-flight prop so we agree on the concept of complexity we just don't agree that the line is non-ambiguous.

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7 hours ago, FlyingMonkey said:

What the rule intended doesn't really matter.  What matters is how the rule was written.  Words matter.

There is case law in California with my name on it. The 3rd district created this bad law in order to force me to pay my ex-wife $4,000 / month in alimony even after she remarried.

The law is clear, alimony terminates upon remarriage and it takes 'magic language' to waive your right.

 

My wife alleged that intent overrid the language and that I could not rely on the law or the written agreement but had to look further into the drafting process and then argue intent.

I was screwed, I never intended such a thing, would any reasonable guy agree to that?

FAA enforcement might be litigated and its common for litigators to consider intent.  DARs have been around for a while and might be aware that the concern was unnecessary complexity.  

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On ‎7‎/‎31‎/‎2017 at 10:02 PM, coppercity said:

Slight delay as I decided to knock out the annual and 100 hr while things were apart.

Here are a few pics of the install so far.  I would estimate about 5-6hrs of install, some of that just deciding how to go about it.

I built up generic tray to mount the remote unit, and have room for other possible gadgets as they become available.   It also mounts like the old transponder tray and supports the comm radio.

Made a new center panel to cover the hole.

GDL 39 on the top of the mushroom.

The control head took place of the backup altimeter.20170727_154923.thumb.jpg.6068d0bb0ecfdbb1ca07f080e0179733.jpg

20170722_165204.thumb.jpg.db07f6654a58ad2e960b478f45b58226.jpg

20170727_154913.thumb.jpg.eb5197effe0cde28111917d7a3bedbe2.jpg

20170727_154928.thumb.jpg.d14c046e2114cadd149686eb3f7cb64c.jpg

20170723_092747.jpg

Update:

 

MRA approved!  I will be doing some testing on the new uAvionix Skybeacon (UAT) with the original Garmin 327 first but will go back and install this system once that is complete. 

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