Why are some RV12's EAB and some ELSA?

[rcarsey]

Originally Posted by hamblin10

Starting to build an RV-12iS and I think I may certify as E-AB just incase I want to install the IFR package and fly on an actual IMC path. Not sure what advantage certifying as E-LSA provides.

Nothing prohibits you from flying an E-LSA in IMC. You are not bound by the language in the POH/AFM.. only the language in your Airworthiness Certificate. (S-LSA is a different story). However, you "should" have more than just the IFR package installed (heated pitot, alternate air, a second ADAHARS unit, etc).

[Mel]

Originally Posted by DaleB

Yep. Theoretically possible, probably not ever actually done.

I do know of one case where an E-LSA was returned to S-LSA. It was not a kit-built. It was originally an S-LSA and it was NOT a Van's.

I will not reveal the name of the manufacturer "to protect the innocent".

I will agree that it is EXTREMELY rare. And the case I'm referring to was an exception.

[SARLDO]

Originally Posted by rcarsey

Nothing prohibits you from flying an E-LSA in IMC. You are not bound by the language in the POH/AFM.. only the language in your Airworthiness Certificate. (S-LSA is a different story). However, you "should" have more than just the IFR package installed (heated pitot, alternate air, a second ADAHARS unit, etc).

Did the ASTM on LSA finally get revised? Last I checked, it does not differentiate between E or S LSA for prohibiting flight in IMC.

https://www.aopa.org/news-and-media/...-be-prohibited

Straight off the Vans avionics ordering page:
Quote

Note that the current Light Sport Aircraft standards (ELSA and SLSA) preclude operation in Instrument Meteorological Conditions (IMC). While aircraft licensed under the LSA standard may be operated "in the system" under Instrument Flight Rules, such as in a training environment, certification as LSA currently prohibits IMC operations. Also, note that EAB-licensed aircraft are not restricted in this fashion.

End quote

[12vaitor]

Originally Posted by rcarsey

Nothing prohibits you from flying an E-LSA in IMC. You are not bound by the language in the POH/AFM.. only the language in your Airworthiness Certificate. (S-LSA is a different story). However, you "should" have more than just the IFR package installed (heated pitot, alternate air, a second ADAHARS unit, etc).

I am curious as to what limitations a DAR has on writing operating limits in the Airworthiness Certificate for an E-LSA. Supposedly he is inspecting something that was built as an ASTM conforming item (the S-LSA), and the ASTM specifically prohibits IMC operation. Can a DAR make whatever non-conforming modifications to the S-LSA limitations they want in writing the AW certificate? Is there any reason they could not also increase the gross weight or airspeed limitations as an example? The presumption here is the POH, which is part of the conforming item presented for inspection, does not apply to the limitations written in the AW certificate.

John Salak
RV-12 N896HS (EAB)

[rgaynor]

I don’t have specific details but I have a friend who has a Tecnam LSA. He had the plane recertified as an ELSA and when he did this he also had the operating limitations changed to allow IFR if so equipped. Again not an expert but he is and said you can change the operating limitations of an ELSA to allow IFR.

Originally Posted by hamblin10

Starting to build an RV-12iS and I think I may certify as E-AB just incase I want to install the IFR package and fly on an actual IMC path. Not sure what advantage certifying as E-LSA provides.

[MMiller]

Originally Posted by 12vaitor

I am curious as to what limitations a DAR has on writing operating limits in the Airworthiness Certificate for an E-LSA.

Opening limits aren’t issued randomly, there issued under the guidance of FAA order 8130.2J. If you want to see the differences between S-LSA, E-LSA and E-AB download a copy https://www.faa.gov/documentlibrary/...er_8130.2j.pdf
have a look at appendix D and build yourself a set of each.

Supposedly he is inspecting something that was built as an ASTM conforming item (the S-LSA), and the ASTM specifically prohibits IMC operation. Can a DAR make whatever non-conforming modifications to the S-LSA limitations they want in writing the AW certificate? Is there any reason they could not also increase the gross weight or airspeed limitations as an example?

It’s not the DAR, it’s the FAA that allows IFR/IMC operations though the opening limits. The airspace we fly is the FAAs domain, ASTM has no jurisdiction

The presumption here is the POH, which is part of the conforming item presented for inspection, does not apply to the limitations written in the AW certificate.

Look at the op-limits, compliance to operations dictated in the Manufacture supplied POH only applies to an S-LSA. If your an E-LSA add the required equipment and modify the page after certification, after all you are experimental

An E-LSA only needs to match its S-LSA duplicate at the time of certification. Once certified you can modify it all you want as long as you keep it within the definition of an LSA (FAR section 1.1) and follow your op-limits

[12vaitor]

Originally Posted by MMiller

Opening limits aren’t issued randomly, there issued under the guidance of FAA order 8130.2J. If you want to see the differences between S-LSA, E-LSA and E-AB download a copy https://www.faa.gov/documentlibrary/...er_8130.2j.pdf
have a look at appendix D and build yourself a set of each.



It’s not the DAR, it’s the FAA that allows IFR/IMC operations though the opening limits. The airspace we fly is the FAAs domain, ASTM has no jurisdiction



Look at the op-limits, compliance to operations dictated in the Manufacture supplied POH only applies to an S-LSA. If your an E-LSA add the required equipment and modify the page after certification, after all you are experimental

An E-LSA only needs to match its S-LSA duplicate at the time of certification. Once certified you can modify it all you want as long as you keep it within the definition of an LSA (FAR section 1.1) and follow your op-limits

Thanks for the reference. For LSA, FAR 1.1 appears to be the only limitation on what you cannot modify after certification or change by AW limitations, an in-flight adjustable prop for example.

My OLs state "Instrument Flight operations are authorized if ... 91.205(d)...". It was built that way from the start and is one reason I went EAB. Looking back on the build, as an EAB I was able to incorporate a lot of changes that originated from builders on VAF before Van's eventually incorporated many of them in the KAI. To Eric H's question, going EAB makes it a lot easier to add some items like a heated pitot to the wing while you are building vs doing it post-ELSA certification with the wings closed up. Same for adding a COMM2, NAV/GS/LOC and of course more antennas and wiring. You may also want to consider a second battery / emergency buss electrical change to keep the fuel pumps, ECU running, and essential panel running.

John Salak
RV-12 N896HS

[jliltd]

Originally Posted by bshawco

Correct me if I'm wrong, but I'm under the impression that a pilot with a Light Sport license and a "Driver's License medical" is legal to fly an E-LSA certificated airplane but not an E-AB, since an E-AB requires at least a Private Pilot license and 3rd Class Medical.

I'd think that this could be a reason to choose E-LSA over EAB registration.

Almost right. Change the last 3 words of the last line of your first paragraph from “3rd Class Medical” to “BasicMed medical”

[SARLDO]

Originally Posted by MMiller

Opening limits aren’t issued randomly, there issued under the guidance of FAA order 8130.2J. If you want to see the differences between S-LSA, E-LSA and E-AB download a copy https://www.faa.gov/documentlibrary/...er_8130.2j.pdf

Once certified you can modify it all you want as long as you keep it within the definition of an LSA (FAR section 1.1) and follow your op-limits

And herein lies the confusion.

Can you modify your ELSA after certification? Yes
Can you modify your ELSA to the point it no longer meets the definition of being an LSA? No (it would be nice, wouldn’t it?)
What defines the certification requirements for an ELSA? ASTM 2245-20
What does ASTM 2245-20 say about VFR/IFR? Limited to VFR flight only.

When you build your ELSA, you’ll placard it to say flight in IMC prohibited. Can you peel that off after certification and go fly in IMC? Sure you can. Will anyone question you or care? Probably not… unless you are involved in a mishap. Then I’m sure your insurance company will turn away from you in a heartbeat and the FAA will question why you flew an aircraft in IMC that wasn’t certificated to do so. That the aircraft is “experimental” is moot. It’s not an EAB, it’s an LSA.

But hey folks, it’s your license. What’s it worth to you?

[MMiller]

Originally Posted by SARLDO

And herein lies the confusion.

Can you modify your ELSA after certification? Yes
Can you modify your ELSA to the point it no longer meets the definition of being an LSA? No (it would be nice, wouldn’t it?)
What defines the certification requirements for an ELSA? ASTM 2245-20
What does ASTM 2245-20 say about VFR/IFR? Limited to VFR flight only.

Actually the current FAA accepted standard is F2245-16c for “Design and Performance” and “Required Equipment.” Here is the complete list of the FAA LSA Accepted Standards;
https://www.faa.gov/aircraft/gen_av/...dardsChart.pdf

It doesn’t matter what the ASTM standard says about IFR operation, The FAA writes rules and they permit IFR operation via the op-limits.

When you build your ELSA, you’ll placard it to say flight in IMC prohibited. Can you peel that off after certification and go fly in IMC? Sure you can. Will anyone question you or care? Probably not… unless you are involved in a mishap. Then I’m sure your insurance company will turn away from you in a heartbeat and the FAA will question why you flew an aircraft in IMC that wasn’t certificated to do so.

you omitted this line of my post, maybe I wasn’t clear. Here it is [with a bit more detail];
“If your an E-LSA, add the required equipment [for IFR flight] and modify the [POH] page after certification…’

I personally don’t care if you build E-AB or E-LSA. My point is that you will get the exact same operating limits for IFR/IMC operation either way it’s licensed.

That the aircraft is “experimental” is moot. It’s not an EAB, it’s an LSA.

But hey folks, it’s your license. What’s it worth to you?

Look a FAR 21.191. There are nine sub groups for “Experimental” certification, including both E-AB and E-LSA. LSA is one path into certification. Both E-AB and E-LSA get specific benefits/penalties for being “experimental” But for IFR operation they are treated equally.