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Thread: Exhibition Category Program Letter and Limitations - seeking advice

  1. #1

    Exhibition Category Program Letter and Limitations - seeking advice

    I'm new to Experimental and to the Exhibition category in particular. I'm thinking of purchasing a Scottish Aviation Bulldog but I'm concerned about Program Letter restrictions. My mission objective is to attend a few Fly In's, do some recreational low key aerobatics (loops, cubans, etc), carry friends for sightseeing and aerobatics. I've read FAA Order 8130.2 but need wisdom. Should the Program Letter specify the requirements for carrying passengers e.g. to exhibit aircraft performance including aerobatics ... or ... since it does not appear to be prohibited (except in association with flight tests) is it best left unmentioned because it is NOT prohibited? What do y'all do out there regarding pax and aerobatics and the Program Letter? Can I complete a Program Letter with my FSDO prior to purchase to ensure they won't lay down draconian requirements before I have parted with money buying the aircraft? Any help welcome.

  2. #2
    EAA Staff Joda's Avatar
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    Quote Originally Posted by Charlestonpilot View Post
    I'm new to Experimental and to the Exhibition category in particular. I'm thinking of purchasing a Scottish Aviation Bulldog but I'm concerned about Program Letter restrictions. My mission objective is to attend a few Fly In's, do some recreational low key aerobatics (loops, cubans, etc), carry friends for sightseeing and aerobatics. I've read FAA Order 8130.2 but need wisdom. Should the Program Letter specify the requirements for carrying passengers e.g. to exhibit aircraft performance including aerobatics ... or ... since it does not appear to be prohibited (except in association with flight tests) is it best left unmentioned because it is NOT prohibited? What do y'all do out there regarding pax and aerobatics and the Program Letter? Can I complete a Program Letter with my FSDO prior to purchase to ensure they won't lay down draconian requirements before I have parted with money buying the aircraft? Any help welcome.
    Best to only include the minimum required info in the Program Letter. Program Letter content is covered in Order 8130.2J, in paragraph 4-6 starting on page 4-2 of the order, and in Appendix C. For Exhibition aircraft, appendix C lists the following items are required in the program letter:

    b. Exhibition. The program letter should—
    (1) Provide event names and dates for the events at which the aircraft will be exhibited.
    (2) Propose route(s) of flight to and from the events.
    (3) For proficiency and/or maintenance flights, include the estimated number of flight hours and the intended area and airports in which the aircraft will be operated.

    This is in addition to the basic requirements found in paragraph 4-6.

    Nowhere in the order does it mention a requirement for the program letter to include any info on passengers. However, the operating limitations may or may not contain restrictions on when passengers may be carried, so a thorough review of the existing operating limitations would be wise.

    If the aircraft has held its airworthiness certificate for some time (prior to when Order 8130.2J was effective) it may be beneficial to have updated operating limitations issued that reflect the current state of exhibition operations, as earlier operating limitations are much more restrictive than what is typically issued currently.
    Cheers!

    Joe

  3. #3

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    Plus the program letter is a living document. You can change it at any time, as many times as needed during the yr. If my friend wanted to fly somewhere not listed in his program letter, he would write a revised letter, wait till Sat. to fax it to the FSDO, fly to the event on Sun. and the FSDO would get the amendment when they came in on Mon. morn after it was all said and done.

    If it's an aerobatic plane, the FAA knows you'll be doing aerobatics. Just follow the operating rules for when, where, min altitudes and parachutes.

  4. #4

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    Here's a hint. Do one where you list all of the big aviation events that you might go to, and for local proficiency list all of the local airports that you might go to. Every year send the same letter with updated dates.

    There is no penalty for not flying to everywhere in your program letter and there is no penalty for flying fewer hours that your letter states.

    The above satisfies the letter of the requirement and is easy to do once and be done forever. No need to over think it. The FSDO staff are going to file it without reading it anyway.

    Best of luck,

    Wes

  5. #5

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    I’ve written a few exhibition category letters. I’m not sure what a Bull dog is but expect it’s a class 1 aircraft so limitations should be predictable as outlined in order 8130.2j. If the aircraft was originally certified by some recognized CAA and has manuals, should be easy. If not, such as it’s a war bird, then you may need to put together surplus manuals, especially for time limited parts and other docs to show a safe instructions for continued airworthiness. It there’s a Bull dog club, they can likely help.

    if the aircraft was originally certified, than part 43 may apply, such as requiring an A&P perform work just like any certified plane, even though it has an exp AC. The exhibition isn’t meant to be a foregone conclusion for such aircraft to fly, you will have to articulate how it meets the requirements of the regulation, such as “to exhibit unique flight and design characteristics of vintage aircraft”. Again, 8130.2j list the standard limitations you can expect, but FSDO can add more as it feels needed, but I expect you will be dealing with a DAR.

    good luck.

  6. #6
    rwanttaja's Avatar
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    Looks like about 56 on the US registry, almost all listed as Experimental-Exhibition.

    Looked at the FAA's Type Certificate Data Sheets; didn't find it, so don't think it was ever certified here. As it was a military trainer, it may not have undergone UK civilian certification either, which would have made it easier to get it certified on this side of the pond.

    For those not familiar with the type:


    Ron Wanttaja

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    Not all that relevant to the discussion, but I had my first flight in a Scottish Bulldog way back when I was a RAF cadet 25 years ago. Great little aircraft!

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