Understanding Light Sport Pilot Rules for EA-B Aircraft

[thisadviceisworthles]

I'm trying to understand the Light Sport Pilot rules as they apply to EA-B, specifically lifetime changes.

As I understand, the gross weight must be under 1320lbs and have remained under 1320 for the aircraft's entire life (this disqualifies some Ercoupes). I'm wondering if the lifetime requirements apply to every factor. Namely, if the aircraft has an in-flight adjustable prop installed, does that permanently disqualify it from Light Sport Flying, or can you just swap the prop for a fixed pitch and fly it Light Sport?

[thisadviceisworthles]

Also, does anyone know of a good explainer for how the Light Sport Rules apply to EA-B planes?

[Bill Berson]

The "Light Sport Aircraft" is defined in FAR 1.1. Should answer your question.

[rwanttaja]

As I understand, the gross weight must be under 1320lbs and have remained under 1320 for the aircraft's entire life (this disqualifies some Ercoupes). I'm wondering if the lifetime requirements apply to every factor. Namely, if the aircraft has an in-flight adjustable prop installed, does that permanently disqualify it from Light Sport Flying, or can you just swap the prop for a fixed pitch and fly it Light Sport?

14CFR Part 1, which includes the definition of light sport:

Light-sport aircraft means an aircraft, other than a helicopter or powered-lift that, since its original certification, has continued to meet the following:

Emphasis added. So if the airplane had had an adjustable prop at the time it was original certification, it does not qualify as light sport. Note that this also includes "...has continued to meet". So if the airplane received an STC for a constant speed prop, it no longer has continued to meet the light sport definition and thus cannot operate under the Light Sport rules.

Also, does anyone know of a good explainer for how the Light Sport Rules apply to EA-B planes?

It applies wholly. Where it gets sporty is the paperwork.

First off is establishing whether the airplane meets the Light Sport rules to start with. Easy enough for a production airplane, but rather loosey-goosey for a homebuilt. The same model of homebuilt may or may not meet, for instance, the stall speed requirement, depending on how the builder constructed the airplane.

I know someone with an RV-6-class* airplane that's operating it as "Light Sport". He claims that the aircraft has certain features (no spinner, no wheel pants, etc.) that limit its speed and keep it in the Light Sport definition.

* NOT saying it's an RV-6....

As it is, by definition, a one-of-a-kind aircraft (like every homebuilt), the only way the FAA can prove otherwise is to seize the airplane and perform its own tests. Not likely to happen, and, frankly, I doubt anyone at the FAA cares. Should an accident occur, I'm certain there'd be a lot of tsk-tsking, but probably not beyond that. Mind you, I have a picture of the same airplane sporting spinner, wheel pants, fairings, etc, so the "continuously meeting" aspect of the rule might be at issue, if I were thirsty and me and the owner were sitting at the same bar.

The second issue is how a homebuilt might be modified out of the Light Sport category WITHOUT being reflected in the paperwork. FAA part 43 doesn't apply to homebuilts, and aircraft configuration is governed by its Operating Limitations. Perform a major modification, and the airplane drops back into the Phase 1 test period...but my Operating Limitations, at least, don't say anything about required logbook entries. So things could happen...and happen BACK...without being reflected in the official aircraft record.

Ron Wanttaja

[robert l]

I liked the way you phrased that Ron ! Good info for the ones that are building or flying a fine line of weight, speed, etc.
Bob

[thisadviceisworthles]

Thanks Ron. That both answers my question, and possibly justifies my confusion.

[Marc Zeitlin]

FAA part 43 doesn't apply to homebuilts, and aircraft configuration is governed by its Operating Limitations. Perform a major modification, and the airplane drops back into the Phase 1 test period...but my Operating Limitations, at least, don't say anything about required logbook entries. So things could happen...and happen BACK...without being reflected in the official aircraft record.

I've been having this "discussion" with various folks over on the HBA forum. While Part 43 doesn't apply to EAB aircraft and the OL's don't say anything about logging maintenance, Part 91 most certainly does apply to EAB aircraft and 14 CFR Part 91.417 requires maintenance entries for ALL work performed on an airplane. Now, it only requires retention until the work is superseded or one year, whichever is longer, so changes to the plane COULD occur and then be lost to posterity due to logbook entries older than one year magically (or not magically - just torn out pages) disappearing.

But maintenance entries in the aircraft log ARE required (by my reading of the FAR's and be verbal indication from the FAA's legal branch, although for the life of me I can't pry a written interpretation of the rules out of them).

[rwanttaja]

I've been having this "discussion" with various folks over on the HBA forum. While Part 43 doesn't apply to EAB aircraft and the OL's don't say anything about logging maintenance, Part 91 most certainly does apply to EAB aircraft and 14 CFR Part 91.417 requires maintenance entries for ALL work performed on an airplane. Now, it only requires retention until the work is superseded or one year, whichever is longer, so changes to the plane COULD occur and then be lost to posterity due to logbook entries older than one year magically (or not magically - just torn out pages) disappearing.

But maintenance entries in the aircraft log ARE required (by my reading of the FAR's and be verbal indication from the FAA's legal branch, although for the life of me I can't pry a written interpretation of the rules out of them).

Yes, I agree with your logic here.

Re-familiarizing myself with 91.417 triggers my loophole-finding senses. The word "log" is never used; one could keep the required records in a loose-leaf notebook. I kind of do that, now, making notes in a rough log (three-ring binder) and updating the formal logs occasionally. It would make it easy for records to be made as required and dumped without trace after the required year.

Also, the reg says..."The records specified... shall be retained until the work is repeated or superseded by other work or for 1 year after the work is performed." If one wanted to try out a modification that causes the plane to no longer meet the Light Sport definition, it appears to be legal to destroy any record of the modification once the plane is restored to its pre-test configuration ("...superseded by other work"). Would just have to word the restoration entry carefully.

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..."

His claim was that there was NOTHING in the certification paperwork reflecting the presence of an electrical system, hence there was no proof the airplane had been originally certified with an engine-driven electrical system.

With the upcoming ADS-B requirement, I'm noticing more and more that MY airplane's certification doesn't reflect the presence of an electrical system.....

Ron "I'm a little too high-profile to get away with it" Wanttaja

[robert l]

Ron "I'm a little too high-profile to get away with it" Wanttaja

Well, you know what they say, "Ignorance is 9/10's of the law" ! Well, maybe they don't say that, sometimes I get infused, I mean confused. Anyway, I'm just happy to be here.
Bob

[FlyingRon]

Most operating lims require not only the test period but a letter to the FSDO telling them what you did. I don't know what the FSDO does with that notification.