Updating operating limitations?

[Dana]

Some time ago I recall seeing something about getting operating limitations replaced with the new wording, but I can't find it. My plane was originally built in 1992, with the operating limitations from that era, including a complete prohibition on flight over densely populated areas or congested airways (what is a "congested airway", anyway?) except for takeoff and landing, any major change invalidates the airworthiness certificate instead of just going back to phase 1, and a test area 3000 miles from where I live. What is involved in getting the FAA to issue me new limitations?

[cub builder]

The biggest issue with the old Operating Limitations like you have, and like I have on my first plane (1996) is that the operating limitations spell out the test area for phase 1 testing in the operating limitations rather than referencing a document or approval by the local FSDO. Under such, if you were to move to another part of the country, then make a modification to your aircraft that requires phase 1 testing for some specified period of time, legally, you would have to transport your aircraft back to where you originally performed the phase 1 testing as spelled out in your Operating Limitations. Under the newer OL, it allows the local FSDO to assign a new phase 1 test area without issuing you new OL paperwork. When I discussed this with the local FSDO in the past, they wanted me to send them my OL and said they would have a new OL sent out to me within 2 weeks. I would have been on board if I could walk in and exchange papers, but I wasn't willing to ground my plane for 2 weeks to make the change, so retained my old OL. Some day in the future, I plan to relocate, so will need to make the change.

-Cub Builder

[1600vw]

The biggest issue with the old Operating Limitations like you have, and like I have on my first plane (1996) is that the operating limitations spell out the test area for phase 1 testing in the operating limitations rather than referencing a document or approval by the local FSDO. Under such, if you were to move to another part of the country, then make a modification to your aircraft that requires phase 1 testing for some specified period of time, legally, you would have to transport your aircraft back to where you originally performed the phase 1 testing as spelled out in your Operating Limitations. Under the newer OL, it allows the local FSDO to assign a new phase 1 test area without issuing you new OL paperwork. When I discussed this with the local FSDO in the past, they wanted me to send them my OL and said they would have a new OL sent out to me within 2 weeks. I would have been on board if I could walk in and exchange papers, but I wasn't willing to ground my plane for 2 weeks to make the change, so retained my old OL. Some day in the future, I plan to relocate, so will need to make the change.

-Cub Builder


Why not make a copy of your OL and send that to them . Retain the original in your airplane. I keep my original OL in my house and have a copy in my airplane. All it would take is for someone to climb aboard my airplane when I am not around and take the OL or any of the documents that must be in my airplane and ruin my day, week, month. This is why I keep copies in my airplane. If someone said I want to see the originals, fine I will show them. But really the copies look just like the original. The only thing I do not do this with is the registration. But I do have a copy of said registration.

Tony

[cub builder]

Why not make a copy of your OL and send that to them . Retain the original in your airplane.
Tony

The FAA wants the originals back and I'm not currently in the mood to play FAA games, nor has the mood struck in the last 9 years since the FAA told me they would like to replace my OLs. Since I haven't moved in the last 30 years, it hasn't been a problem. As you may have noticed from the other thread about Operating Limitations, the FAA keeps changing them. I don't see the need to try to hit a moving target until it's necessary. Since mine are legal, there's no need to change yet. I'll deal with it next time I plan to have the plane grounded for an extended period of time for upgrades, which would really be the only time I would go back to phase 1 anyway. My current OL is 2 pages long. The OL for the last plane I built was 15 pages of lawyer speak. I'd rather have the 2 page OL. :D

-Cub Builder

[Dana]

The issue with mine is that I can't even put it back into phase 1; anything that would require that (i.e. major change) would "invalidate the airworthiness certificate." And I'd like to remove the limitation on flight over densely populated areas.

I don't even have the original copy of the op limitations; they (and the airworthiness certificate) were missing when I bought the plane. The local FSDO issued me a replacement AC and gave me a copy of the original op limitations from their records.

I guess I'll have to contact them and ask how to proceed. If it requires sending stuff back, I'll just wait until winter when it's too cold to fly an open cockpit anyway.

[1600vw]

Dana keep us posted. This is a very interesting subject that effects a lot of us. My OL was written or given in 2004 and its just as you say. I want this changed as well. Over all these years I am sure we are not the only two who have to deal or dealing with this. Second hand airplane moved across the country.

No one in their right mind will take an airplane some thousand miles to fly off another phase 1. Its just not happening.

Tony

[1600vw]

The FAA wants the originals back and I'm not currently in the mood to play FAA games, nor has the mood struck in the last 9 years since the FAA told me they would like to replace my OLs. Since I haven't moved in the last 30 years, it hasn't been a problem. As you may have noticed from the other thread about Operating Limitations, the FAA keeps changing them. I don't see the need to try to hit a moving target until it's necessary. Since mine are legal, there's no need to change yet. I'll deal with it next time I plan to have the plane grounded for an extended period of time for upgrades, which would really be the only time I would go back to phase 1 anyway. My current OL is 2 pages long. The OL for the last plane I built was 15 pages of lawyer speak. I'd rather have the 2 page OL. :D

-Cub Builder

If they want the originals, make copies and send them the originals. Having this paper work redone will not make your airworthy certificate void. Your registration will not be void, your OL are changing, when you get them you get new instructions on how you operate your airplane. Until then operate according to your current OL instructions.

How I would do it.

Tony

[rv7charlie]

I've had them reissued on 3 different planes over the last 25 years, & the local FSDO always let me fax my request, created new lims based on current policy, and had me bring the existing ones in person for a swap. Every FSDO seems to be different in their policies but it might be worth a try to fax them a copy of your lims & request for new lims, and offer to bring the originals in person for a swap.

Charlie

[Dana]

I emailed the local FSDO, I'll see what they say. I had to go there in person to get the new AC, they wanted to look at the logbooks. Hopefully they won't hassle me about not having the original OLs (they gave me the copy, after all), and hopefully I won't have to go there in person... it means wasting a vacation day from work that I'd rather save for fun things.

[1600vw]

Dana why would they give you a hard time for not have originals? After all you could loose all documents and contact the FAA to send you copies of everything they have issued for your airplane. I purchased an airplane without all its paper work. I sent a letter to OK city asking for all documents for my new to me airplane. They sent me all documents on file.

Tony

[Dana]

Dana why would they give you a hard time for not have originals? After all you could loose all documents and contact the FAA to send you copies...

Well, somebody mentioned the FAA wanting the originals back before issuing new ones. I agree it shouldn't really be an issue, though.

[cub builder]

Well, somebody mentioned the FAA wanting the originals back before issuing new ones. I agree it shouldn't really be an issue, though.

Maybe I should correct my previous statement. The FSDO will want you to turn in your Current Operation Limitations (in my case, the originals), then will issue you new ones. They shouldn't give you any problems over it. You could just as well tell them you lost your current Operating Limitations paperwork and ask them to issue you the latest version rather than sending you copies. If they are in the mood, there is no reason why it can't be accomplished in a day as all they have to do is fill in the blanks on a few pages of lawyer speak, then photocopy it for their records. My FSDO said it would take them a couple of weeks and could be handled via US Mail. Your local FSDO may work faster. My recent experience with FSDO is that they are spread pretty thin and really good at losing paperwork. A Ferry Permit I did with them recently convinced me that I don't want to hand those guys any important piece of paper as it's likely to get buried for months.

1600VW: I don't need a solution as I don't have a problem to resolve. Just not interested in playing FAA paperwork games right now. :D

-Cub Builder

[1600vw]

Maybe I should correct my previous statement. The FSDO will want you to turn in your Current Operation Limitations (in my case, the originals), then will issue you new ones. They shouldn't give you any problems over it. You could just as well tell them you lost your current Operating Limitations paperwork and ask them to issue you the latest version rather than sending you copies. If they are in the mood, there is no reason why it can't be accomplished in a day as all they have to do is fill in the blanks on a few pages of lawyer speak, then photocopy it for their records. My FSDO said it would take them a couple of weeks and could be handled via US Mail. Your local FSDO may work faster. My recent experience with FSDO is that they are spread pretty thin and really good at losing paperwork. A Ferry Permit I did with them recently convinced me that I don't want to hand those guys any important piece of paper as it's likely to get buried for months.

1600VW: I don't need a solution as I don't have a problem to resolve. Just not interested in playing FAA paperwork games right now. :D

-Cub Builder

I feel the exact same way. But I do want to get this done. I am not sure how to go about doing it.

1. Who picks the fly-off area?
2. Is there a forum one sends out to have this done? Example forum 8050-1 we all know we need that for a registration. What forum must be used for changing ones OL.
3. Does this cost?
4. What about all the specs ones OL should have but most don't. What happens here? I have seen a few OL and all these area's are blank. And yes the fly-ff of both Phase 1 and 2 is complete and signed off.

Questions I am sure many have. If I missed something or someone has different questions ask them here. Maybe Tom or someone in the know can give us all direction in this area.

Great thread. I need a Like Button. Because I like this thread.

Tony

[1600vw]

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

[1600vw]

The man who owns this airplane I speak of in the above post, is an A&P. He did do ground test and even crow hopped the airplane. He put a few hrs on it before its first flight. The fuel leak happened in flight. The test pilot could not see it but he smelt it. He was shocked when he saw how much fuel was on that seat.

So I would say the FAA or FSDO office gives out the fly-off area. One does not request an area?
Tony

[Dana]

The FAA chooses the test area. I'm sure you can suggest it, and if it's reasonable they will probably approve it. It's the kind of thing where you can simply fill out a form and send it in, but a preliminary phone conversation would go a long way in preventing any surprises.

I'm still waiting for a response from the FSDO (they're pretty slow).

[1600vw]

Keep us posted Dana and maybe someone else will chime in with more info.

I went to our local FSDO one day. I just drove up got out of the car and walked up to find a locked door. I stood there for about 10 mins scratching my head wondering why any government office would be lock to the American citizens its there to support when some dude walked up. He asked what was I doing. I told him I was going after my SP certificate and needed a Student Pilot forum. He informed me that these FSDO offices are always locked and I need to call in advance. No one can just walk up. I said just imagine if the DMV operated this way, no one would get anything done. I know how to influence people and make friends...lol

He looked around for a few mins behind this desk then looks up to me and says, I have no idea what you want, thank you and goodbye. I went to OshKosh and received my Student Certificate. My point, to my minds eye and after dealing with our local FSDO, don't expect much help from them when dealing with an EAB and SP. They are lost or was back then. This happened in 2010.

I bet that door is still locked today. I really feel welcome there.:mad: Don't tell me this is because of 911. Every other government office I have been to is unlocked during normal hrs. But because this is the FSDO for aviation it must be locked, really.

I mentioned this before and was told its because of 911 that these doors are locked. I got a good laugh from that.

Tony

[planecrazzzy]

I picked my Flight area... and the FAA approved it ... It was a 50 mile Diameter
.
Gotta Fly...
.
.

[1600vw]

I picked my Flight area... and the FAA approved it ... It was a 50 mile Diameter
.
Gotta Fly...
.
.

In the airplane I fly and the one like Dana flies, a 50 mile radius will take me quite a while to travel. Maybe something with speeds up in the triple digits maybe. But with a ground speed of 60 - 65 like most of us have flying a single seat EAB 50 miles is a long distance. I call it a x-country trip in my Fisher airplane.

[dusterpilot]

I feel the exact same way. But I do want to get this done. I am not sure how to go about doing it.
1. Who picks the fly-off area?
2. Is there a forum one sends out to have this done? Example forum 8050-1 we all know we need that for a registration. What forum must be used for changing ones OL.
3. Does this cost?
4. What about all the specs ones OL should have but most don't. What happens here? I have seen a few OL and all these area's are blank. And yes the fly-ff of both Phase 1 and 2 is complete and signed off.
Questions I am sure many have.
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.)

[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...
.
Gotta Fly...
Jam
.
.

[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

[Dana]

Got a response from the FAA today, saying, "Please contact us to arrange for an office visit with me. Please bring all required documentation with you. Our office main telephone number is..."

I guess I need to call him. Silly me, thinking email would be easier.

[dusterpilot]

....Please bring all required documentation with you.....

A phone call to ask what "all required documentation" includes would be helpful.

What the "inspector" requires may be more than what you think is required by the regs. Take your aircraft logs and any other documentation you have BUT LEAVE IT IN THE CAR if you don't think you need it. Only take the documents inside they've specifically requested or you think you will need. (Definitely take AWC, Registration, and OL.) Both times I've had my OLs revised, the inspector asked about my aircraft logs. They clearly are NOT needed to revise an OL, but if you take them in with you they probably will look at them and I've rarely seen an experimental aircraft log that is perfect. If there's something incorrectly entered or worded, they may find it and may make an issue of it. If you have them with you, you can go back out and get them if their absence becomes a show stopper. But, if they don't demand them, don't let them know you've got them with you. Give them what they need, but nothing more.