Backcountry Pilot • Recertification to experimental

Recertification to experimental

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Re: Recertification to experimental

mtv wrote:And, by the way, DARs "consult" for a fee. If you don't know what you want to do, a DAR will help you lighten up alright....your wallet. They don't work for free.

But, as noted, if you really want to go down this road, bring cash.

MTV


Gosh... you're making it sound like the DAR will cost so much to just negate the project!
The last DAR I worked with on my Eagle build was very reasonable... I think he is no longer doing any work, but I'll look him up anyway.
Building something is also a prime consideration, but with CC kits (and the like) costing their weight in gold... I must find other alternatives. Heading to Wittman Regional in a couple weeks to do some scoping.
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Re: Recertification to experimental

dirtstrip wrote:Completely different animal. The EAB and E-LSA operate under completely different rules. They do not meet the same requirement as Experimental Amateur Built. It is right to say the Light Sport Aircraft built by the manufacturer is certified but not experimental. No changes are allowed. The same plane can be built by an individual with a identical kit purchased from the factory but is still more restrictive than EAB. It is experimental but there are additional rules and limitations within the class.

I don't have first hand experience in this discussion of E-LSA and LSA

So I will add this to the confusion.

http://www.kitplanes.com/sportplanes/0505-3740.pdf


The Carbon Cub is available as either an E-LSA or E-AB in kit form. The EAB kit has been vetted by the FAA as meeting the 51% rule.

As to DAR fees, I'm simply pointing out that they don't work free. Also,they can lose THEIR designation if they sign off anything that doesn't meet the regulatory requirements. They aren't authorized to sign off as airworthy a craft that doesn't comply with the regs. They are simply a "representative" of the FAA.

Good luck.

MTV
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Re: Recertification to experimental

I am out of my comfort zone here but by the article I referenced, http://www.kitplanes.com/sportplanes/0505-3740.pdf and using the Carbon Cub as an example of the rules being two different animals on the same plane, the rules for E-LSA from a certified kit would require that an individual could only build that Carbon Cub to be an exact copy of the factory certified one. No changes would be allowed during construction that are not approved by the manufacturer. Not one change in the radio selection or engines or even in the type epoxy is allowed. Bummer. But..no 51% requirement and after the Carbon Cub passes the final inspection by the FAA then you can make any of those changes and its allowed to stay in the Experimental Light Sport class as long as the other weight, hp etc. rules for the class are not violated so you still get to fly it with just a drivers license instead of 3rd Class medical. This is a weird and expensive allowance of the rules if you go that way but it allows a way to jump that Carbon Cub to most of the same freedoms enjoyed in the Experimental Amateur Built class.
The practical use of the rule would be that it means more freedom for a second owner of the aircraft to do changes he wants.

Now build that same Carbon Cub kit under the EAB rules and providing you observe the 51% rule you are allowed any darn changes you want from the git-go. So EAB is much less restrictive yet both planes are experimental Carbon Cubs and providing you observed the weight, hp etc required of light sport aircraft both Carbon Cubs could be flown without the medical certificate under E-LSA rules.

As a third option, if you started by buying a factory built certified Carbon Cub, even though it is a certified aircraft it can be de-certified and modified as either of the two planes above. It is allowed to jump from certified down to experimental light sport AB, unlike a standard certified aircraft that is not a light sport aircraft and the 51% rule that disqualifies other certified aircraft from EAB class does not apply. That makes Experimental Light Sport rules a different animal from regular EAB.
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Re: Recertification to experimental

My experience with a DAR has been great, not very expensive for what I got and did not have to deal with the time schedule of the FSDO.
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Re: Recertification to experimental

dirtstrip wrote:....the rules for E-LSA from a certified kit would require that an individual could only build that Carbon Cub to be an exact copy of the factory certified one. No changes would be allowed during construction that are not approved by the manufacturer. Not one change in the radio selection or engines or even in the type epoxy is allowed. Bummer. But..no 51% requirement and after the Carbon Cub passes the final inspection by the FAA then you can make any of those changes and its allowed to stay in the Experimental Light Sport class as long as the other weight, hp etc. rules for the class are not violated.........
As a third option, if you started by buying a factory built certified Carbon Cub, even though it is a certified aircraft it can be de-certified and modified as either of the two planes above. .........


It is my understanding that if you build one certified as an E-LSA, you must get approval from the mfr for any changes. Ditto for an S-LSA. Never heard of this "decertifying" from S-LSA or E-LSA status.
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Re: Recertification to experimental

dirtstrip wrote: Hot rod 150, I see your point also but where then would be the line between classes? ......


The line would be the airworthiness certificate that says either experimental or standard. If an aircraft is "experimental", what's the difference if the parts came from Aircraft Spruce, Cub Crafters, Piper, or Ace Hardware?
I know, I know, the rules say..... Well, the rules (or the inter[pretation of them) are bogus. But like someone pointed out, it's easier to change the tides than change the rules.
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Re: Recertification to experimental

hotrod150 wrote:
dirtstrip wrote:....the rules for E-LSA from a certified kit would require that an individual could only build that Carbon Cub to be an exact copy of the factory certified one. No changes would be allowed during construction that are not approved by the manufacturer. Not one change in the radio selection or engines or even in the type epoxy is allowed. Bummer. But..no 51% requirement and after the Carbon Cub passes the final inspection by the FAA then you can make any of those changes and its allowed to stay in the Experimental Light Sport class as long as the other weight, hp etc. rules for the class are not violated.........
As a third option, if you started by buying a factory built certified Carbon Cub, even though it is a certified aircraft it can be de-certified and modified as either of the two planes above. .........


It is my understanding that if you build one certified as an E-LSA, you must get approval from the mfr for any changes. Ditto for an S-LSA. Never heard of this "decertifying" from S-LSA or E-LSA status.


I got all of that info from the same source. http://www.kitplanes.com/sportplanes/0505-3740.pdf
Last article in the series. I did take liberty with the word "decertify" to make the point of comparing this to modifying a "regular certified" aircraft as it accomplishes the same thing of making a "transition" from regular certified aircraft to EAB status. In these sport pilot categories it is allowed according to the article. The "transition" process requires only an the FAA sign off followed by flying off a test period following the mods as would be required with any other Amateur Built. One other "feature" unmentioned in the article is the wallet hit of lost resale from taking the factory built certified aircraft out of SLSA and giving up the certification (transitioning) to go ELSA.. yet again freedom comes at a price.

"The SLSA to ELSA Transition:

There is an interesting feature in the
ELSA rules. As noted above, the owner
of an existing SLSA can transition his
or her plane to ELSA. This means you
can buy a ready-to-fl y aircraft, apply
for an ELSA certifi cate, and, once it is
received, you can do nearly anything
you want.
Want an auto-engine airplane but
don’t want to spend years building an
Ex/AB machine? Buy an SLSA, switch
to an ELSA certifi cate, pull the installed
engine, and put in your favorite Subaru
or Honda. You’ll need the FAA signoff
and have to fl y off a test period, and,
of course, the plane must still meet the
basic LSA defi nition.
That’s probably the most interest-
ing thing about ELSA: If you take the LS-I
course, you’ll have the same freedoms
as an Ex/AB builder without having to
actually build an aircraft! Buy a ready-
to-fl y plane, convert it to ELSA (if it isn’t
already), then do all your own mainte-
nance and inspections and modify it to
match your needs..."
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Re: Recertification to experimental

One quite often hears the words "just re-register it as an experimental and put whatever you want in it" or some version of that phrase. As if it was just a mere paper one needed to fill in and sent off to the FAA. However, there is no clear legal way of taking a certified aircraft to experimental, unless you remanufacture or dis-assemble the airplane and construct parts of it yourself, and even then you're at the mercy of the inspector. This is from the people at EPI, Inc when they tried to certify an Aero Commander with an uncertified V8 engine. But don't think it just applies to engines - it applies to everything that's on the Type Certificate for that type. Any and all changes to those are basically not allowed. I quote:

The following is a list of the different types of Experimental certificates (quoted from 14-CFR-21.191) which are available and how they apply to the installation of a non-certified powerplant onto a certified airframe.

(a)Research and Development: Testing new aircraft design concepts, new aircraft equipment, new aircraft equipment, new aircraft installations.

NOTE: An R&D certificate must be renewed annually. Your FSDO contact will usually issue the first one fairly easily. You will have to prove some substantial reasons to justify the issuance for a second year. In my region, there has never been one issued for the third year.
ALSO, after the expiration of your R&D certificates, you will find it extremely difficult to convert the aircraft back into its original form (ie, restore it to being a standard Cessna-185 or whatever) because now the burden is on you, the modifier, to prove that the aircraft complies with the original type certificate .

(b) Showing Compliance with Regulations: Conducting flight tests and other operations to show compliance with the airworthiness regulations including flights to show compliance for issuance of type certificates and supplemental type certificates, flights to substantiate major design changes, and flights to show compliance with the function and reliability requirements of the regulations.

This classification is what you would use for the flight test verification to obtain an STC for the installation of a different certified powerplant onto a certified airframe. The number of times this certificate can be renewed is also limited.

(c) Crew Training: Training of the applicant's flight crews.

This requires substantiation, periodic inspections, and ongoing renewals. The allowable operations under this classification are limited.

(d) Exhibition: Exhibiting the aircraft's flight capabilities, performance, or unusual characteristics at air shows, motion picture, television and similar productions, and the maintenance of exhibition flight proficiency, including (for persons exhibiting aircraft) flying to and from such air shows and productions.

The allowable aircraft operations under this classification are very limited.

(e) Air Racing: Participating in air races, including (for such participants) practicing for such air races and flying to and from such events.

The allowable aircraft operations under this classification are very limited.

(f) Market Surveys: Use of aircraft for purposes of conducting market surveys, sales demonstrations, and customer crew training only as provided in paragraph 21.195.

FAR 21.195 is very specific about the restrictions that apply here.

(g) Operating Amateur-built Aircraft: Operating an aircraft, the major portion of which has been fabricated and assembled by persons who undertook the construction project solely for their own education or recreation.

This certificate is clearly not applicable. (See NOTE below.)

(h) Operating Kit-built Aircraft: Operating a primary category aircraft that meets the criteria of paragraph 21.24(a)(1) that was assembled by a person from a kit manufactured by the holder of a production certificate for that kit, without the supervision and quality control of the production certificate holder, under paragraph 21.184(a).

This certificate is clearly not applicable.

The Restricted category offers at least the remote possibility, but we have not fully explored that avenue. BUT notice the name: RESTRICTED.
Another approach we frequently hear suggested is an approval by means of a One-Time STC. Again, STC's apply to certified engines in certified airframes. Yet another often-suggested approach is an authorization by means of a Form-337. Realistically, I think it would be quite a challenge to find an A&P-IA who would be willing to risk losing his tickets by signing and submitting to the FAA a field approval which flies in the face of existing spirit, intent and practice. More important, since 337's must be approved by FSDO, it is unlikely that the field approval would be granted.

Bottom line: unless you are ready to obtain BOTH a type certificate and a production certificate for the powerplant, AND an STC for the installation into an existing certified airframe, you might as well forget it.

NOTE: We do know of a path which a few energetic builders have taken, with varying degrees of success. The steps are:
disassemble the certified aircraft down to bare pieces (de-riveting the skins in the case of monocoque airframes),
make a few new duplicates of existing parts along with the new pieces required for the desired modifications,
reassemble the aircraft, using the duplicated original parts and incorporating the desired modifications,
Generate copious photos and documentation of the rebuild process,
Apply for Experimental-Homebuilt { FAR 21.191(g) } certification of your new "from scratch" aircraft as the "Hermann Umschlagplatz Firebreather Which Looks A Lot Like A Bonanza With A V8 Engine".

The success of that strategy involves a fair bit of luck in convincing the FAA Inspector or Designee that your project really is a "homebuilt" under the 14-CFR-21.191(g) definitions, and it entails certain risks with respect to deception of Government Officials, but it has been done.
The best plan for this strategy includes (1) energetic invocation of the "...for the education and recreation of the builder..." clause, (2) having pounds of documentation, including detailed engineering drawings of most parts, which you are alleging to have "handmade", and (3) excellent salesmanship skills.


So as you can see, it's no easy task to achieve unless one is willing to get some serious and costly ground work done. It will be much, much cheaper to buy whatever STC there might be than to try to do it through the above ways.
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Re: Recertification to experimental

hotrod150 wrote: The line would be the airworthiness certificate that says either experimental or standard. If an aircraft is "experimental", what's the difference if the parts came from Aircraft Spruce, Cub Crafters, Piper, or Ace Hardware?
I know, I know, the rules say..... Well, the rules (or the inter[pretation of them) are bogus. But like someone pointed out, it's easier to change the tides than change the rules.


OK, gov't rules and common sense just don't get along. So here's my question... who cares about all these rules and why do we put up with it? Why not just do what YOU want to YOUR plane? I'd rather it be right than legal. The majority on this forum adhere to the notion that forgiveness comes easier than permission, yet we get all wound up in what's leagl to bolt to our airframes. Why?

Maybe I view this differently since I don't have bankers buy my stuff for me, and I self insure. I live & fly in remote areas where no ramp check has ever happened and is unlikely since I don't encounter others often. What's more, the FAA, DAR, and FSDO people I have dealt with are either very cool or very incompetent. Unless they have a hard on for you, not much will happen. In remote Alaska, I understand experimental mods on certified planes is common. Is that true? If so, what's really the worse that could happen? I'm not talking about unsafe parts causing an accident. I'm talking about the REGULATORS.

There are plenty of rules that are helpful and make things better, but I just don't get why devout rule followers choose to be obedient when common sense suggests another path. Somebody help me here.
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Re: Recertification to experimental

Spinner wrote:OK, gov't rules and common sense just don't get along. So here's my question... who cares about all these rules and why do we put up with it? Why not just do what YOU want to YOUR plane? I'd rather it be right than legal. The majority on this forum adhere to the notion that forgiveness comes easier than permission, yet we get all wound up in what's leagl to bolt to our airframes. Why?

Maybe I view this differently since I don't have bankers buy my stuff for me, and I self insure. I live & fly in remote areas where no ramp check has ever happened and is unlikely since I don't encounter others often. What's more, the FAA, DAR, and FSDO people I have dealt with are either very cool or very incompetent. Unless they have a hard on for you, not much will happen. In remote Alaska, I understand experimental mods on certified planes is common. Is that true? If so, what's really the worse that could happen? I'm not talking about unsafe parts causing an accident. I'm talking about the REGULATORS.

There are plenty of rules that are helpful and make things better, but I just don't get why devout rule followers choose to be obedient when common sense suggests another path. Somebody help me here.


Go ahead and try it. To me, I hear you say the tree is falling in the forrest and no one will hear. If its a common sense part I am sure it will fly just fine until the next annual or you want to sell and then it does not pass inspection and you can pay for the real part at that time if you want. If not it should fly just fine out of annual and besides you may never sell it anyway. It definitely is one of your choices. You might have to stay away from controlled airports and airshows and you'll be just fine illegally, but then there is that problem with flying it illegally, dodging the law and calling it common sense. :lol:
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Re: Recertification to experimental

Gosh Spinner, I suppose you don't follow any of the flight rules, either--or are they there just for those who are "devout rule followers"? Do you just go anywhere you want, without regard to the rules for Class B, C, D, E, or G? Do you fly in the clouds without a clearance? Are you instrument qualified and current, or is getting an IR just for the "devout rule followers"? What happens if you prang on landing and severely injure or kill your passenger? What happens if it's because your hardware store part broke and caused the failure? Do not bother with insurance, either?

No doubt some of the rules are a little hard to understand, but it's not our job to pick and choose which to follow. It's hard enough for us "devout rule followers" to follow all of them when we try to, but that's no reason to be scofflaws and ignore them.

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Re: Recertification to experimental

Spinner, I think there are plenty of us that agree with your thoughts on that subject, it is how one maneuvers around the rules that count. Who has not bent or broken aviation regs a time or two? I assume the followers of all the rules, have never speeded and would also give up all their guns if ever asked.

GIve Spinner a break, he just verbalized what many of us have daydreamed on occasion.

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Re: Recertification to experimental

I hate to break this to you, Spinner, but most every rule in the book has come about because SOMEONE has done something stupid or got hurt.

You argue that common sense should dictate what you put in your airplane.....Uh, have you looked around lately for examples of common sense being used in our country?? The rules aren't judpst for you or me, they are for all those folks out ther who have a "better" (read hair brained" idea they want to try out.

Oh yeah, and those folks are going to take their aviation ignorant neighbors for a ride....

Unfortunately for the gifted in this society, rules have to be put in place to protect the somewhat less gifted, like me, for exampl :D .

And, compared to most other countries, we still have the most liberal aviation regulations in the world.

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Re: Recertification to experimental

I live in two worlds like spinner. I live in the one that is not only isolated by distance from busy airspace regs and far from those looking over my shoulder on a regular basis. I normally have the luxury of looking the other way on a lot of regs that would be considered only a nuisance in my world, not only because of distance but because I built, maintain and fly experimental. So there is a glaring contradiction when I cross into that other world of city life airports and park alongside rows of certified aircraft whose pilots maintain to certified standards. Then I appreciate the choice I made of which to live in.

Looking back on raising children and now having grand kids, I realize I also crossed from a world of greater responsibility to one of just being able to enjoy those kids with out that burden. Even now with a full generation between those days of responsibility and today, I know I did them a service teaching them to live in a world with rules and expectations, they will be able to live along side others in the city life they chose and won't become the cannon that needs lots of elbow room and space that I did to operate. That space gets smaller as the cities get larger. If this sounds like rambling it might be, but there is an importance of learning to live in the world that is, rather than the one we wish it were. There is a separate world for parents and grandparents and they are worlds apart but its best to realize early which one we are in.
Go experimental.
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Re: Recertification to experimental

I'm going to change the direction of this thread just slightly. I've been looking for sometime for that perfect project. I my search I've occasionally come across perfectly good airframes that do not have data tags. My question to all of you is can a person build an experimental from an airframe with no data tag?

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Re: Recertification to experimental

180jocky wrote:I'm going to change the direction of this thread just slightly. I've been looking for sometime for that perfect project. I my search I've occasionally come across perfectly good airframes that do not have data tags. My question to all of you is can a person build an experimental from an airframe with no data tag?

180jocky


A type certificated plane without a data tag is still a TC plane. MTV in the second post in this thread answered the question well as the others have, too. In short, NO you can't convert TC to experimental (unless under very restrictive categories). There have been a few planes converted in the past but that loop hole is closed now.
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Re: Recertification to experimental

Spinner wrote:........OK, gov't rules and common sense just don't get along. So here's my question... who cares about all these rules and why do we put up with it? Why not just do what YOU want to YOUR plane? I'd rather it be right than legal. The majority on this forum adhere to the notion that forgiveness comes easier than permission, yet we get all wound up in what's leagl to bolt to our airframes. Why?.......There are plenty of rules that are helpful and make things better, but I just don't get why devout rule followers choose to be obedient when common sense suggests another path. Somebody help me here.


I've been known to bend (not break!) a few rules my own self, but generally speaking I try to follow them (the important ones anyway). I know a pretty wealthy guy who owned and flew a $100K+ airplane for several years but never annualled it. Probably no liability insurance either, but since no annuals were ever done the insurance would have been void anyway. He (sort of) did his own maintenance & repairs and everything worked out fine, except of course when he sold it the price reflected all the deferred maintenace & AD's that had to be addressed. The problem would have been if he had been involved in an accident or incident where someone was hurt or god forbid even killed. Even to me, failing to do even better-late-than-never annual inspections implies negligence on his part, and I think a sharp lawyer could have knocked a helluva big settlement out of him or maybe even some criminal charges. Even a few spendy annuals wold have cheap compared to either one of those.
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Re: Recertification to experimental

Here you go this one has been on the market for a long time lotta mods but you can't do anything legal with but "exhibit" it.
http://flightplanet.com/airplane-for-sa ... __1158.php
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Re: Recertification to experimental

dirtstrip wrote:One other "feature" unmentioned in the article is the wallet hit of lost resale from taking the factory built certified aircraft out of SLSA and giving up the certification (transitioning) to go ELSA.. yet again freedom comes at a price.


Not always true, in many cases a SLSA transioned to ELSA is actually worth a bit more than the SLSA orignal. Many folks go this route to avoid some of the SLSA restrictions and want the peperwork already completed in the resale market. For one example, Cub Crafters SLSA products aren't legal to fly night VFR, while the very same aircraft transitioned to ELSA is legal to fly at night. Apples to apples, the ELSA transitioned version of the factory-built SLSA orignal is more desirable in the market.
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Re: Recertification to experimental

I think what we need in this country is an "owner maintenance" category like Canada has. I'm not sure of all the why's and wherefores, but I believe it allows the owner to do his own maintenance & inspections, as well as at least some mods without benefit of STC etc. Can any Canadians on the board give us more details?
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