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Thread: Understanding Light Sport Pilot Rules for EA-B Aircraft

  1. #11

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    Quote Originally Posted by rwanttaja View Post
    Back when the Mode C veil was instituted here in Seattle, a friend of mine (EAA Tech Counselor, in fact) pulled the alternator from his T-18 so he didn't have to install a transponder. His argument was the wording of 14 CFR 91.215 which excepted the following aircraft from the requirement: "...any aircraft which was not originally certificated with an engine-driven electrical system or which has not subsequently been certified with such a system installed...
    Seems it would depend on the definition of certificated as used within the context of 91.215.

    If the FAA meant "type certificated" then a homebuilt is free and clear. If the FAA meant certificated as in received an airworthiness certificate....that would really cloud things over as issuance of an a/w certificate is an administrative process only that does not include technical details such as whether or not an engine driven electrical system is installed.

    If the latter is true, your friend can reinstall his electrical system and say his T-18 was originally certificated without an engine drive electrical system. The engine driven electrical system was added later but never certified. (.215(b)(3) says subsequently been "certified" with such a system installed). If we use the logic that issuance of an a/w certificate is the point where the airplane becomes certified that would not take place until a new airworthiness certificate is issued.

  2. #12

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    The FAA might retain a copy of the original weight and balance. So a change to LSA gross weight might be an issue.
    I don't know if the gross weight is required or just empty weight on certification?

  3. #13
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    Quote Originally Posted by Bill Berson View Post
    The FAA might retain a copy of the original weight and balance. So a change to LSA gross weight might be an issue.
    I don't know if the gross weight is required or just empty weight on certification?
    Can't speak to modern practices, but I got the FAA records dump for my airplane about twenty years ago. There's no mention of aircraft weight in any of the registration or airworthiness documents. Dunno what happens nowadays. Does the W&B paperwork get copied, or does the DAR just check it over?

    The FAA registration database includes a "weight class" for each aircraft, but there are only four classes and the first run runs from 1 to 12,499 pounds.

    Quote Originally Posted by martymayes View Post
    Seems it would depend on the definition of certificated as used within the context of 91.215.

    If the FAA meant "type certificated" then a homebuilt is free and clear. If the FAA meant certificated as in received an airworthiness certificate....that would really cloud things over as issuance of an a/w certificate is an administrative process only that does not include technical details such as whether or not an engine driven electrical system is installed.

    If the latter is true, your friend can reinstall his electrical system and say his T-18 was originally certificated without an engine drive electrical system. The engine driven electrical system was added later but never certified. (.215(b)(3) says subsequently been "certified" with such a system installed). If we use the logic that issuance of an a/w certificate is the point where the airplane becomes certified that would not take place until a new airworthiness certificate is issued.
    I'd say that the FAA's failure to use the term "Type" when referring to "certification" in Part 91 means that it'd be hard to argue that stuff like 91.215 DIDN'T affect aircraft with Special Airworthiness. But, as you say, the lack of any technical details on record would complicate things.

    I think my friend would have been just fine if he'd re-installed the alternator, making a clear log entry when he did. As you point out, the airplane would never have been "subsequently certified" with an electrical system. As I've mentioned in the past, I've considered building a new Fly Baby without an electrical system to avoid the ADS-B requirement. I'd probably duplicate my current airplane's electrical system, and just not include the generator when originally licensing the aircraft.

    In any case, I think the level of risk faced by my two friends with "sporty" interpretations of the rules is pretty low. The planes were based at uncontrolled fields, and aren't likely to have FAA folks snooping around.

    Ron Wanttaja

  4. #14

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    The current FAA Advisory Circular 20-27G may require an extra weight and balance copy submitted to FAA at inspection.

    Program letter: "I have weighed the aircraft to determine that the most forward and aftcenter of gravity positions are within established limits. The weight andbalance report is available at the aircraft, and a copy is submitted withthis application. "
    Last edited by Bill Berson; 09-07-2018 at 11:35 AM.

  5. #15

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    I contacted the FAA to get all the paper work they had on an airplane I owned at the time. What I got back from them was nothing more then the registration they had on file. They said this was all the info they had on this airplane I contacted them about.

  6. #16
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    Quote Originally Posted by 1600vw View Post
    I contacted the FAA to get all the paper work they had on an airplane I owned at the time. What I got back from them was nothing more then the registration they had on file. They said this was all the info they had on this airplane I contacted them about.
    As just an interested observer here, do you think this is an anomaly or is the FAA or other regulatory bodies and the individuals connected to them apathetic, unconcerned or laissez-faire about E-AB things within the broader scope of all aircraft categories?
    Last edited by Floatsflyer; 09-07-2018 at 03:48 PM.

  7. #17
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    Note that the definition of a "light-sport aircraft" found in 14 CFR 1.1 makes no mention of what category the aircraft is actually certificated in. The basic definition applies equally to any aircraft, regardless of whether it's type-certificated, amateur-built, exhibition, or any of the light-sport certification categories. So even for amateur-built aircraft, if the aircraft has EVER been operated in a configuration that is outside the LSA definition, then it is forever ineligible for operation by sport pilots (including pilots who hold higher-level certificates who are operating at the sport pilot level). If it's ever been operated with a controllable pitch prop, or at a maximum weight of over 1320 lbs (for land planes), at a maximum level flight speed of over 125 kts, or outside any other LSA criteria, it is not and can never be a light-sport aircraft.

    How do you know if that's ever happened or not? You look at the aircraft's records. And as others in this thread have mentioned, there isn't a lot that's recorded in the aircraft's permanent file at the FAA that would verify one way or another. So it's down to the records that are kept with the aircraft. If there are records of equipment installed that would disqualify it, or records of too-high stall speeds or too-high maximum level flight speeds, then the aircraft is forever disqualified from operation by sport pilots.
    Cheers!

    Joe

  8. #18
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    Quote Originally Posted by martymayes View Post
    Seems it would depend on the definition of certificated as used within the context of 91.215.

    If the FAA meant "type certificated" then a homebuilt is free and clear. If the FAA meant certificated as in received an airworthiness certificate....that would really cloud things over as issuance of an a/w certificate is an administrative process only that does not include technical details such as whether or not an engine driven electrical system is installed.

    If the latter is true, your friend can reinstall his electrical system and say his T-18 was originally certificated without an engine drive electrical system. The engine driven electrical system was added later but never certified. (.215(b)(3) says subsequently been "certified" with such a system installed). If we use the logic that issuance of an a/w certificate is the point where the airplane becomes certified that would not take place until a new airworthiness certificate is issued.
    91.215 says "originally certificated"... or "subsequently certified. Two different words, "certified" could mean when the condition inspection is recorded, I.e. "I certify this aircraft has been inspected..."

  9. #19

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    Quote Originally Posted by Dana View Post
    91.215 says "originally certificated"... or "subsequently certified. Two different words, "certified" could mean when the condition inspection is recorded, I.e. "I certify this aircraft has been inspected..."
    I don't interpret my CI signoffs that way. What I'm "certifying" when I sign off a CI is that I "inspected the aircraft and found it in a condition for safe operation" - in other words, I'm certifying the INSPECTION, not the AIRCRAFT.

    So I'd argue that the "Originally Certificated" or "Subsequently certified" apply to issuance of any and all original or subsequent Airworthiness Certificates, NOT Annual or Condition Inspections.

  10. #20

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    I agree with what Marc says, a person performing a condition inspection is only certifying that an activity was performed. Part 65 does not authorize a mechanic or repairman to certify an aircraft or any of it's components.

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