Updating operating limitations?

[1600vw]

I've been through the process twice now with two different experimental aircraft. Once because I changed the N-number and the second time because I needed to change the flight test area from the builder's east coast area to my midwest location due to a major alteration. The best way to do it is in-person. Call your nearest FSDO and tell them what you want to do and ask to speak to the inspector who will be handling it. During that phone call, (a) tell the inspector what you want to do (obtain a new Operating Limitation), (b) why you need to do it, (c) suggest your preferred test area, (d) exchange e-mail addresses and phone numbers, (e) make a future appointment to get it done, and finally (f) tell him what documents you will send him in advance and how, and encourage the inspector to call or e-mail you if he has any questions prior to the appointment. If he/she will, it's even a good idea to ask for a draft copy be faxed or e-mailed to you prior to the appointment.
Next, fax or e-mail the inspector a copy of your existing aircraft registration, airworthiness certificate, and operating limitations so he'll have something to start working with.
FSDO inspectors have a thick book of step-by-step guidelines that are very specific in how to do almost everything they do. Do your homework and know the airspace where you are requesting your test area. If the area you request is acceptable, that's what you'll get. If it isn't, work with them to get an area that works well for you. It can be a give-and-take discussion.
Take all your paperwork to your appointment. Most inspectors rarely do operating limitations. Expect some mistakes. Read the operating limits very carefully to ensure accuracy before you walk out of there.
1. Who picks the test area? You do, but they have to approve it.
2. Form? None. Don't bother to draft your own version. What will and will not be included is in their specific guidance. They'll prepare the draft.
3. Does it cost? No. Just your time.
4. What goes in the OL changes from time to time. If you've completed phase 1 & 2, you should still define a test area nearby in the event you need it in the future.
My FSDO issued new OL's and required me to sign them. The inspector said a new OL should be issued every time the aircraft ownership changes so the owner's signature is on the OL. I asked what reg requires that, where can I find it, and how should I know that. The answer was that it was only in their guidance documents. Unless you have a need to revise your OL, I see no need to revise them until you do (e.g., tail number change, major alteration, etc.)

I would like to thank you for posting this and taking the time to do it. Just the info I was looking for.

Thanks again.

Tony

[planecrazzzy]

If your in the MIDDLE of the 50 mile Diameter... It's only 25 miles to the edges...

If yer lucky... You can get three airports in your circle...Not including your starting point...

Kind of gives you something to do....More than testing...
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Gotta Fly...
Jam
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[Frank Giger]

If your in the MIDDLE of the 50 mile Diameter... It's only 25 miles to the edges...

If yer lucky... You can get three airports in your circle...Not including your starting point...

Kind of gives you something to do....More than testing...
.
Gotta Fly...
Jam
.
.

This is exactly the reason I'm going to have my home base as an airport an hour away - flat terrain with loads of emergency landing strips (plus it's pretty and very rural) and three airports within 25 miles...and if I can get him to spot me another three or four NM a fourth.

The airport nearest my house has lots of ridges, trees, houses, and a noise abatement area. Um, let's keep things simple.

Oh, and low traffic and no towers.

[dusterpilot]

...flat terrain with loads of emergency landing strips (plus it's pretty and very rural) and three airports within 25 miles...and if I can get him to spot me another three or four NM a fourth.....Oh, and low traffic and no towers.

That's exactly the kind of test area FSDO wants to see.

[rv7charlie]

That 50 mi circle is something that originated in the early days of homebuilt certification, when homebuilts were much more Cub-like in performance. It isn't a requirement, and doesn't have to be a circle. Many FSDOs will give a *much* larger area if you request it, give a valid reason (higher performance, faster plane, available emergency landing areas, even boredom avoidance), and the area of the country (population density) permits it. My local FSDO will give almost half the state, as long as I agree to avoid busy towered airport airspace. That isn't a real limitation, because in an emergency, the pilot is the boss and picks the safest option to get on the ground.

Charlie

[Byron J. Covey]

That 50 mi circle is something that originated in the early days of homebuilt certification, when homebuilts were much more Cub-like in performance. It isn't a requirement, and doesn't have to be a circle. Many FSDOs will give a *much* larger area if you request it, give a valid reason (higher performance, faster plane, available emergency landing areas, even boredom avoidance), and the area of the country (population density) permits it. My local FSDO will give almost half the state, as long as I agree to avoid busy towered airport airspace. That isn't a real limitation, because in an emergency, the pilot is the boss and picks the safest option to get on the ground.

Charlie

My area was a 100 mile radius around Arlington, WA, excluding Canada, which is about 50 miles north of Arlington.


BJC

[1600vw]

That 50 mi circle is something that originated in the early days of homebuilt certification, when homebuilts were much more Cub-like in performance. It isn't a requirement, and doesn't have to be a circle. Many FSDOs will give a *much* larger area if you request it, give a valid reason (higher performance, faster plane, available emergency landing areas, even boredom avoidance), and the area of the country (population density) permits it. My local FSDO will give almost half the state, as long as I agree to avoid busy towered airport airspace. That isn't a real limitation, because in an emergency, the pilot is the boss and picks the safest option to get on the ground.

Charlie

The question becomes. Do you mind landing somewhere that is not your home base or field and do repairs at this location. Or are you comfortable having a stranger help work on your airplane?

I ask this question to all you who claim to fly tens of miles away from your home field during the Phase fly off of your homebuilt. Just what are you flying when doing this? Meaning airframe and engine design. Myself and this is just me, but getting in a brand new aircraft that uses an engine that is not certified or anything else that is not certified on said airframe, just me but I am spending more then a couple dozen hrs flying close to home base. If I need to come down for any reason I am landing at my own field not some strange airfield, then relying on strangers for help.

I myself have had enough engine outs in these types of aircraft to know until one gets around 40 or so hrs on them, you have problems that do creep up. Even my buddy who is a A&P has had many failures in his new airplane that has grounded it in the 40 hrs he has flown it off. More then 1 more then 2. So many you can not count them on one hand. To many to be flying off tens of miles away or 20 - 40 mins away.

I will stick with what I do. I do it for not only safety but for my aircraft. No stranger is touching my airplane. I have done this and had more problems from others telling me they know what they are doing. Example. I had an A&P adjust the valves on my VW. He never worked on VW engines and put my valve covers back on without gaskets. He puts forum-a-gasket in place of the Gaskets. My covers have the Bail-wire style of covers. I am taxing and loose both valve covers. The come completely off and onto the runway. I was just getting ready for take off when they fell off. My airplane got covered in oil.

Never again. I work on my airplane thank you. Also every time my airplane comes out of the shop and I have worked on her. I do a few hrs right above my runway. I have stories about this to. Maintenance induced failures. I have had them. No I do not know it all. But learning. I know more then most and not as much as others.

Tony

[1600vw]

The question becomes. Do you mind landing somewhere that is not your home base or field and do repairs at this location. Or are you comfortable having a stranger help work on your airplane?

I ask this question to all you who claim to fly tens of miles away from your home field during the Phase fly off of your homebuilt. Just what are you flying when doing this? Meaning airframe and engine design. Myself and this is just me, but getting in a brand new aircraft that uses an engine that is not certified or anything else that is not certified on said airframe, just me but I am spending more then a couple dozen hrs flying close to home base. If I need to come down for any reason I am landing at my own field not some strange airfield, then relying on strangers for help.

I myself have had enough engine outs in these types of aircraft to know until one gets around 40 or so hrs on them, you have problems that do creep up. Even my buddy who is a A&P has had many failures in his new airplane that has grounded it in the 40 hrs he has flown it off. More then 1 more then 2. So many you can not count them on one hand. To many to be flying off tens of miles away or 20 - 40 mins away.

I will stick with what I do. I do it for not only safety but for my aircraft. No stranger is touching my airplane. I have done this and had more problems from others telling me they know what they are doing. Example. I had an A&P adjust the valves on my VW. He never worked on VW engines and put my valve covers back on without gaskets. He puts forum-a-gasket in place of the Gaskets. My covers have the Bail-wire style of covers. I am taxing and loose both valve covers. The come completely off and onto the runway. I was just getting ready for take off when they fell off. My airplane got covered in oil.

Never again. I work on my airplane thank you. Also every time my airplane comes out of the shop and I have worked on her. I do a few hrs right above my runway. I have stories about this to. Maintenance induced failures. I have had them. No I do not know it all. But learning. I know more then most and not as much as others.

Tony

I had a brand new airplane and brand new engine. Everything on the airplane was brand new and the airplane was just built or finished, she had 4 hrs on her when this happened. I take off one day and fly about 10 miles to a buddies place. On the trip back the engine comes apart and I end up in a field. Its around 7 pm. By the time I got my airplane back in its hangar it was 3 am. I was just 7 miles from my home airfield. It took until 3am before I was in my hangar again. I told myself that night never again.

Tony

[cub builder]

A buddy of mine just did his 40 hr. Fly off. He told me that the FAA wanted him to do this fly off about 10 miles from our home field. I have problems with this. We all know these airplanes are not certified in any way. Problems come up and happen where one needs to get on the ground now more so then in a certified aircraft or airplane.

So this Brand New never flown airplane takes off and flies off out of sight. On the very first flight within mins of taking flight. I am pacing back and forth like a new father in the waiting room waiting on his first kid. I was asked why in the yeck did I care anyway. I said first there is a life in that airplane and second this hobby sport don't need the bad wrap that comes when things go wrong. About 25 mins goes by and here comes the airplane. He lands and the rear seat is full of fuel from a fuel leak. Everyone was very lucky.

The FAA did not want him doing his fly-off above our field because we border on the edge of class C airspace. But Ultralights and me even fly right above this field on most nice days. We do not fly off. We stay by the private airfield.

My point what the FAA wanted from this new aircraft and pilot, just was not safe. I would not have done it. I careless what someone setting behind some desk has to say about it. The FAA put a lot at stake doing this, but none of them would have had to pay the price if things went wrong, as they did. We as a group dodged a bullet that day as did the pilot. This never should have happened.

Tony

Keep in mind, the test area isn't for the safety of the pilot. It's for the safety of those on the ground. The pilot's safety is in his own hands. The first plane I completed had a reputation for being fast and squirrelly. I chose to do my initial testing at an airport that is not my home airport due to the open area around the airport and the multiple long runways at that airport. I would have much rather have kept it in my own hangar during the initial tests than rent a hangar 35 miles away, but that simply wasn't going to happen until I felt the aircraft and pilot (me) were capable of handling the more challenging conditions of my home airport. I asked for a test area to include both airports so I could move the plane to my own hangar for maintenance and/or modifications during the test phase when I felt it was safe to do so.

Duster pilot pretty much nailed the process for replacing the Operating Limitations, or for that matter, most any other interaction with FSDO. Just call FSDO, talk to an inspector and tell them what you need. If you need to go see them in person, arrange an appointment. I recall when the FSDOs weren't locked. They locked the doors after incidents like the Oklahoma bombing. Lots of people don't like the FAA and many express their aggravation with them in public forums (myself included), so they don't want to leave the doors open as they have a fear of someone walking in a shooting up the place. It's become too common place in our society and with the FAAs reputation, their fears may have some foundation. I have found that typically if I happen to be in town and want to talk to them, they will let me in. Sometimes I have to call on me cell standing outside the office and tell them I stopped in to chat with them 'cause I was in town and it's a 200 mile trip to come back to visit them another day. Then they will open the door and are usually pretty helpful even though I am interrupting their work. Make no mistake, these guys really are busy. When I did a ferry permit with them a couple of months ago, the inspector I was working with was there at 8:00 in the morning. He told me he would email me the ferry permit before he left at the end of the day. He emailed it out at 7:00 that evening. I don't work that kind of hours.

As for flight test areas, the recommendation is a 25 mile radius. But it's always negotiable. In the old Operating Limitations, they wanted your area drawn out on a sectional, then photocopied to add to the OL. Then the FAA discovered that sectionals expire and didn't want your test area on an expired map, so revised the OL so you had to have a written description of your test area and can not include a map. I have seen 25 mile radius test areas, and I have seen a 100 mile radius test area for faster aircraft, with corridors added to the test area to allow some cross country testing to other airports in phase 1. The phase 1 test area depends a great deal on the performance of your aircraft, the inspector you get that issues it, and what you request. As long as you are reasonable and have some sort of logic behind your request (like my requesting a nearby airport with more runways for part of phase 1 testing), you are likely to get the requested test area.

-Cub Builder

[1600vw]

Keep in mind, the test area isn't for the safety of the pilot. It's for the safety of those on the ground. The pilot's safety is in his own hands. The first plane I completed had a reputation for being fast and squirrelly. I chose to do my initial testing at an airport that is not my home airport due to the open area around the airport and the multiple long runways at that airport. I would have much rather have kept it in my own hangar during the initial tests than rent a hangar 35 miles away, but that simply wasn't going to happen until I felt the aircraft and pilot (me) were capable of handling the more challenging conditions of my home airport. I asked for a test area to include both airports so I could move the plane to my own hangar for maintenance and/or modifications during the test phase when I felt it was safe to do so.

Duster pilot pretty much nailed the process for replacing the Operating Limitations, or for that matter, most any other interaction with FSDO. Just call FSDO, talk to an inspector and tell them what you need. If you need to go see them in person, arrange an appointment. I recall when the FSDOs weren't locked. They locked the doors after incidents like the Oklahoma bombing. Lots of people don't like the FAA and many express their aggravation with them in public forums (myself included), so they don't want to leave the doors open as they have a fear of someone walking in a shooting up the place. It's become too common place in our society and with the FAAs reputation, their fears may have some foundation. I have found that typically if I happen to be in town and want to talk to them, they will let me in. Sometimes I have to call on me cell standing outside the office and tell them I stopped in to chat with them 'cause I was in town and it's a 200 mile trip to come back to visit them another day. Then they will open the door and are usually pretty helpful even though I am interrupting their work. Make no mistake, these guys really are busy. When I did a ferry permit with them a couple of months ago, the inspector I was working with was there at 8:00 in the morning. He told me he would email me the ferry permit before he left at the end of the day. He emailed it out at 7:00 that evening. I don't work that kind of hours.

As for flight test areas, the recommendation is a 25 mile radius. But it's always negotiable. In the old Operating Limitations, they wanted your area drawn out on a sectional, then photocopied to add to the OL. Then the FAA discovered that sectionals expire and didn't want your test area on an expired map, so revised the OL so you had to have a written description of your test area and can not include a map. I have seen 25 mile radius test areas, and I have seen a 100 mile radius test area for faster aircraft, with corridors added to the test area to allow some cross country testing to other airports in phase 1. The phase 1 test area depends a great deal on the performance of your aircraft, the inspector you get that issues it, and what you request. As long as you are reasonable and have some sort of logic behind your request (like my requesting a nearby airport with more runways for part of phase 1 testing), you are likely to get the requested test area.

-Cub Builder

In that very first paragraph you agree with what I do. Keep the airplane above an airfield. Very good. I said my own field for that is all I need. But other fields or strips would work to. I would not fly off 25 miles, or 10 miles. Not in the first so many hrs. Yeck today I do not fly off. I just do not trust these non-certified aircraft. I trust one as far as I can throw it. But that is me. I have had way to many engine outs in these little things we call airplanes.

Tony