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Thread: Will a DAR let me tear down and rebuild an unregistered ELSA

  1. #11
    CarlOrton's Avatar
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    Marty, this may sound argumentative, but I'm not trying to be. We're all busy this time of the year, so I'm being lazy, and I'll admit it.

    I understand the "fabrication" part, but in today's environment, I think that's loosened up a LOT. As an example, I'm currently building a Zenith Cruzer. Without thinking too hard, the only items I've had to "fabricate" were some corner reinforcements I cut from lengths of thin L-angle and pilot drilled. A FAR cry from my Sonex where I really did have to fabricate tail ribs etc from only bent stock. I don't know his/her kit, but *IF* it were something on a simple level of fabrication, I don't see an issue with re-fabricating things.

    I spoke with several FAA reps over my years of E-AB involvement, and they consistently emphasized that it's not 51% of the total effort, it's 51% of the total number of *tasks*. You don't need to fabricate 51% of the ribs, f'rinstance, but you have to show you know *how* to fabricate a rib. As I said, I'm amazed at the ridiculously low level of fabrication I've had to do thus far. And other popular kits are the same way.

    Again, I don't know the brand/model of the kit in question, so based on the unknowns, I see no problem with "re-fabricating" things. ;-) If difficult, though, I concur with your exp-exhibition approach.

    Carl Orton
    Sonex #1170 / Zenith 750 Cruzer
    http://mykitlog.com/corton

  2. #12
    Joda's Avatar
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    Quote Originally Posted by martymayes View Post
    I would register it as exp-exhibition and go fly.
    Be aware that an exhibition certificate is not guaranteed. Most FAA offices these days are looking for a valid reason to "exhibit" the aircraft. In other words, the applicant must show some sort of reason for "exhibiting the aircraft’s flight capabilities, performance, or unusual characteristics at air shows, fly-ins, and similar events;" (Quoted from FAA Order 8130.2J) Not sure that a former ultralight would have any valid exhibition purpose in many FAA office's eyes. Applicants had better be prepared to make an argument that the aircraft does have some sort of feature that they are "exhibiting".
    Cheers!

    Joe

  3. #13

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    So I guess you are saying the procedure from AC103-7 dated 1984 might not apply in 2019?

  4. #14
    Joda's Avatar
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    Quote Originally Posted by Bill Berson View Post
    So I guess you are saying the procedure from AC103-7 dated 1984 might not apply in 2019?
    Yes, that's basically correct. There are a number of things in the AC that are not up to date. For example, it refers to "General Aviation District Offices" (GADOs), which do not exist anymore in the FAA structure. It also refers to "Flight Service Stations" which also no longer exist in the field. The AC also references AC 20-27C, which is long obsolete. The current version is 20-27G. So yes, this AC could use a bit of freshening up. However, the basic info on ultralights is still valid, as is the general procedures called out in the AC. Just be aware that, in the current FAA guidance, and how it is applied, an experimental exhibition certificate is not guaranteed.
    Cheers!

    Joe

  5. #15

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    I suppose if one works hard enough, they could convince the FAA to deny issuance of an EE certificate.

    Of course where I live, they FAA would....

    "If, after notifying the applicant of all unsatisfactory findings, the applicant does
    not correct those findings to your satisfaction in a timely manner, write a letter to the applicant
    denying issuance of the certificate and stating the reason(s) for the denial. If feasible, identify
    which steps may be accomplished to meet the certification requirements"


    ....all because they are swell guys (and because it's in the 8130.2J guidance) they would give the applicant an opportunity to correct any issues before issuing a denial. If one is really inept, they could hire someone to bring the discrepancies into compliance for them.

    One of my friends list 2 exhibition events per yr for his aircraft and one of them is an annual cookout at his hangar. The other, I'm not sure if he has ever attended cause of wx or maint cancellations. So in the end, I just don't see EE being that big of an issue but maybe that's just me.

  6. #16
    Joda's Avatar
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    Quote Originally Posted by martymayes View Post
    One of my friends list 2 exhibition events per yr for his aircraft and one of them is an annual cookout at his hangar. The other, I'm not sure if he has ever attended cause of wx or maint cancellations. So in the end, I just don't see EE being that big of an issue but maybe that's just me.
    It's not about the events, or whether they attend or not. It's about whether there is a valid reason to "exhibit" the aircraft. What unusual or unique characteristics does it have that are being exhibited? That's what the FAA guys I work with are looking at.

    I'm not saying that someone, somewhere, in another FAA district may or may not have an easier time getting an exhibition certificate. I'm just saying that it's not a given and some FAA offices are getting pretty strict on determining whether there is a valid reason to "exhibit" the aircraft. I've worked on a few exhibition applications, so I'm just reporting what I've learned. As always, your mileage may vary. Don't shoot the messenger!
    Cheers!

    Joe

  7. #17
    DaleB's Avatar
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    You could actually ask a DAR... Are you a Kitplanes subscriber? I recommend it (along with your EAA membership, of course).

    Please send your questions for DAR Asberry to editorial@kitplanes.com with “Ask the DAR” in the subject line.
    Measure twice, cut once...
    scratch head, shrug, shim to fit.

    Flying an RV-12. I am building a Fisher Celebrity, slowly.

  8. #18

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    The reason for exhibiting it could be to display an example of how the instruction exemption provided a flurry of growth and available local instructors in the 1980’s. Back then almost 30,000 Ultralights were built, some 400 displayed at Oshkosh, 160 were hangared at Arlington. All gone since the Light Sport rules of 2004.

  9. #19

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    Quote Originally Posted by Joda View Post
    It's not about the events, or whether they attend or not. It's about whether there is a valid reason to "exhibit" the aircraft. What unusual or unique characteristics does it have that are being exhibited? That's what the FAA guys I work with are looking at.
    Joe, not holding or pointing a loaded gun, I'm interested in learning.

    For my own edification, what is characteristically unusual or unique about a SubSonex that justifies a reason to exhibit the aircraft? Sonex is advertising/marketing a quick build version of the SubSonex that can only be certified to fly as an exp. exhibition airplane simply because it doesn't meet the major portion rule. Based on the ads and sales contract I would say there is an implied guarantee that it can be done. Otherwise, I'd be suing to get my money back. I'm betting Sonex will provide a boiler plate program letter to ensure exp-exhibition certification is obtained.

    That begs the question: If a Subsonex can do it, why can't an ultralight that doesn't meet the major portion rule do it? Are they any less exhibit worthy?

    The FAA guys where I live have somewhat confirmed exp-exhibition is an option for any plane for which there is no other legitimate path to obtain an airworthiness certificate. This comes up at almost every IA recurrent event now because of the growing number of aircraft operating as exp-exhibition.

  10. #20
    Joda's Avatar
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    Marty,

    As long as the program letter contains an explanation of what the aircraft is exhibiting that is acceptable to the cognizant FAA office, you're good to go. All I'm trying to point out is, it is not a guaranteed certification path.

    Regarding the specific case of the SubSonex, the only two certifications I was involved in were the two factory prototypes. It was pretty obvious that they were exhibition aircraft in the eyes of the inspectors at FAA MSP MIDO, and they certainly have been used to exhibit the operational characteristics and performance of a "micro jet". I have no idea what other SubSonex builders have used as their exhibition program, but I'm assuming they are using something similar to what Sonex used for the two prototypes.

    I'm not trying to say it can't be done. I'm just trying to keep everyone's expectations realistic. I've been involved in some exhibition certifications where it was touch and go as to whether the FAA was going to proceed with the certification or not. It can be a bit of a "negotiation", if not a fight, to get the certificate approved. It all comes down to what the cognizant FAA office is willing to accept, and sometimes how good a salesman the applicant can be.

    Forwarded is forearmed. That's all I'm saying. Don't waltz into the FAA office thinking that it's a done deal. Be ready to justify your application.
    Cheers!

    Joe

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