Sport Pilot Talk

jnmeade · Joined: 30 Nov 2010 Posts: 144 Location: Iowa

I have an EAB glider which I bought from the builder. Can it be re-registered as light sport? It meets weight and speed requirements.

drseti · Joined: 28 Nov 2009 Posts: 1387 Location: Lock Haven PA

My understanding is that, in order to get a Special (pink) Airworthiness Certificate in the Experimental Light Sport category, the kit needs to be based 100% upon a Special Light Sport design, and the manufacturer needs to so certify. An exception is fat ultralights, but the window of opportunity for transitioning those to E-LSA has closed. However, you can register any homebuilt as Experimental Amateur Built (also a pink airworthiness certif) and, if it meets all the LSA limitations, operate it as a Sport Pilot Eligible aircraft.

jnmeade · Joined: 30 Nov 2010 Posts: 144 Location: Iowa

Well, this is interesting. Back in the late 1960's, Laister Gliders built the LP-49 in the factory and offered it as a kit, both. The FAA permitted amateurs to build their kit in the Laister factory and have it declared a standard certified plane. My glider was built that way. However, the builder let it sit for nearly 40 years and never flew it and didn't finalize the paperwork. When I bought it from him, I had to get with the FAA and have the status changed to experimental amateur built, because they no longer recognized the old program. So, mine is built to the manufacturer's specs in the factory and was inspected and signed off by the manufacturers own mechanics and inspectors.

The original plane as built by Laister was before the days of Light Sport, even though it meets LS criteria, so I don't know if the ability to recertify it exists. Probably not, or many would want to recertify their J3 Cub so they could do their own maintenance.

The deal on this to me is that if I get an LSMR certificate, I can do my own sign-offs. If not, I can do the work but not perform the condition inspection. You see where I'm at least mildly interested in having my glider redesignated as some kind of LSA. Since I already have the LSMI ticket, I could do my own sign-offs now if could call it an E-LSA.

Oh, well, an interesting topic, to me at least.

drseti · Joined: 28 Nov 2009 Posts: 1387 Location: Lock Haven PA

Even if the original builder had completed the paperwork 40 years ago, and registered the plane as an FAR Part 23 certificated aircraft, it would not be eligible to become an LSA of any kind (any more than an otherwise eligible Cub, Champ, Luscombe, or Ercoupe could be). It would be Sport Pilot eligible from the pilot's point of view, but not an LSA for maintenance or inspection purposes. (One of my students bought an Ercoupe -- he can fly it as a Sport Pilot, but I can't maintain or inspect it with my LSRM-A.)

There are several Experimental categories into which certified aircraft can be re-registered (and folks on this forum far more knowledgeable that I about that subject). As an Experimental (amateur built, exhibition, whatever), anyone can do the maintenance; no AMT license or repairman's certificate required. (That's the good news.) However, only an A&P/IA can sign off the annual condition inspection. (That's the bad news...)

rsteele · Joined: 12 Feb 2007 Posts: 261

Every owner of an EAB that I know, and that's several including EAA tech counselors, will tell you that an A&P/IA isn't needed to sign off the condition inspection on an EAB. A "plain old" A&P can do it. Now, I've heard A&P/IAs say this isn't the case, but the FAA seems to feel all that's needed is an A&P.

In either case you are stuck getting someone else to do it unless you hold the original repairman's certificate. But an A&P is probably easier to find and may cost a bit less.

I'd recommend finding an A&P and establishing a good relationship. You should be able to do most of the condition inspection yourself, saving a lot of money.

I"m shocked that you were able to convert you glider to EAB. I've never heard of it happening before. E-LSA is of course out of the question as there is no S-LSA design for it to comply with.

Ron

jnmeade · Joined: 30 Nov 2010 Posts: 144 Location: Iowa

Why are you shocked that my glider was registered as EAB? After the rather unusual arrangement to issue a standard certificate to an amateur built airplane was discontinued, what other alternative did the FAA have? Well, that's by the by. It's done.

As far as there bing no SLSA, that is technically correct as there was no SLSA category in those days. However, the factory built a couple of dozen of these gliders so there were SLSA equivalents, and this plane was built in the factory to factory specs under the supervision of the factory mechanics and passing the inspection of the factory inspectors, so one could make a case that it meets the intent of the ELSA program.

Well, I thought you all would enjoy a rather unusual history.

As far as finding an A&P to sign the condition inspection, I can but I simply prefer to be able to legally sign it off myself. I hope no one things that is out of line. I don't know why the reference to the A&P/IA, I never suggested I needed one.

drseti · Joined: 28 Nov 2009 Posts: 1387 Location: Lock Haven PA

jnmeade wrote: the factory built a couple of dozen of these gliders so there were SLSA equivalents,

Well, not precisely. It may seem nit-picking, but there is indeed a very real difference between a Sport Pilot Eligible aircraft and an ASTM-compliant LSA. The former meets the performance limitations of an LSA (as set by the FAA). The latter must meet the process limitations of the ASTM standards, which can be very different from the design and manufacturing requirements for a Part 23 certified aircraft (and, in some areas, even more rigorous). Since the factory-built version of your plane predates those ASTM standards, there is little likelihood that it complies with them (and no easy way to find out if it happens to).

Now, if the manufacturer still exists, and wishes to submit two samples of their Part 23 certified product for an ASTM audit, it is just possible that they could get them registered as S-LSAs, and then petition the FAA to declare the homebuilt ones E-LSAs. Even if the manufacturer is still around, this is an expensive process, plus you're then asking them to take back a whole lot of liability -- doubtful anyone would want to do that.

So, performance-wise, what you have is rather like an LSA. Certifying it under ASTM standards is another matter altogether.

Quote: Well, I thought you all would enjoy a rather unusual history.

You bet!

Quote: As far as finding an A&P to sign the condition inspection, I can but I simply prefer to be able to legally sign it off myself.

That's one of the great appeals of the E-LSA, and not at all unreasonable.

Quote: I don't know why the reference to the A&P/IA, I never suggested I needed one.

I'm afraid I threw that distractor into the mix. Sorry; didn't mean to hijack the thread. This is one of the areas where the FARs are not internally consistent (so, what's new?) In one place it says only an A&P with Inspection Authorization can sign off condition inspections. In another place, it lists exceptions. S-LSA and E-LSA are specifically excluded from that other reg, but E-AB is not. There may be another exemption for E-AB somewhere else in the FARs, but I haven't found it yet. From a practical standpoint, I don't think the FAA has any problem with an A&P doing the annual on an E-AB, and signing it off -- but the regs are confusing. (That's why we have lawyers! :wink: )

comperini · Joined: 24 Feb 2008 Posts: 152 Location: California

drseti wrote:

In one place it says only an A&P with Inspection Authorization can sign off condition inspections. In another place, it lists exceptions. S-LSA and E-LSA are specifically excluded from that other reg, but E-AB is not.

Experimentals are experimentals. no IA required for the annual condition inspection. An A&P, Repairman (if one exists for the particular aircraft) or a repair station can perform them. Remember, Part 43 does not apply to experimentals, except as noted in the operating limits. So all the "IA" talk in Part 43 does not apply to experimentals. Operating limits spell out who can perform the inspections. Those operating limits do not call for an IA.

drseti · Joined: 28 Nov 2009 Posts: 1387 Location: Lock Haven PA

comperini wrote: Remember, Part 43 does not apply to experimentals, except as noted in the operating limits.

Thanks for the clarification, Bob. Now, to make sure I understand this: doesn't the DAR (or is it DER?) write the operating limits for an exp, and does not the local FSDO have to sign off on them? If so, and if a DAR happens to write in "IA", and the FSDO accepts that, I would guess that an IA would indeed be required to do the annuals. Might this scenario explain some of the confusion among IAs?

comperini · Joined: 24 Feb 2008 Posts: 152 Location: California

drseti wrote: comperini wrote: Remember, Part 43 does not apply to experimentals, except as noted in the operating limits.

Thanks for the clarification, Bob. Now, to make sure I understand this: doesn't the DAR (or is it DER?) write the operating limits for an exp, and does not the local FSDO have to sign off on them? If so, and if a DAR happens to write in "IA", and the FSDO accepts that, I would guess that an IA would indeed be required to do the annuals. Might this scenario explain some of the confusion among IAs?

The DAR (designated airworthiness representative) doesn't "write" the op limits... he assigns (pre-written) op limits, as defined and directed in FAA Order 8130.2F.

If a DAR is taking liberty to "re-write" op limits with words that don't appear in that Order, he better be reported to the FAA.

3Dreaming · Joined: 10 Jan 2010 Posts: 301 Location: noble, IL USA

comperini wrote: drseti wrote:

In one place it says only an A&P with Inspection Authorization can sign off condition inspections. In another place, it lists exceptions. S-LSA and E-LSA are specifically excluded from that other reg, but E-AB is not.

Experimentals are experimentals. no IA required for the annual condition inspection. An A&P, Repairman (if one exists for the particular aircraft) or a repair station can perform them. Remember, Part 43 does not apply to experimentals, except as noted in the operating limits. So all the "IA" talk in Part 43 does not apply to experimentals. Operating limits spell out who can perform the inspections. Those operating limits do not call for an IA.

Part 43 does apply to some experimentals. If the aircraft carried a different type of airwortiness certificate at some point then part 43 does apply. An example wold be a SLSA converted to ELSA or standard category converted to experimental exhibition. For these the requirements of part 43 still have to be met. Tom

comperini · Joined: 24 Feb 2008 Posts: 152 Location: California

3Dreaming wrote: Part 43 does apply to some experimentals. If the aircraft carried a different type of airwortiness certificate at some point then part 43 does apply. An example wold be a SLSA converted to ELSA or standard category converted to experimental exhibition. For these the requirements of part 43 still have to be met. Tom

Part 43 does not apply to SLSAs converted to ELSAs. This was a change recently made in Part 43. 43.1(b)(2) was created to specifically deal with that oversight. Prior to this last change, technically Part 43 DID apply to SLSAs that were converted to ELSA.

rsteele · Joined: 12 Feb 2007 Posts: 261

There are may kinds of experimentals. I think we've been talking Experimental Amateur Built (EAB). This would seem to be the only one that applies to this case. The key part is "Amateur Built". I believe it's the only experimental that allows general private use. Other are restricted test articles, exhibition planes etc.

As to why I was shocked that a part 23 plane was switched to EAB: People ask about doing this all the time. It would seem to make sense to be able to keep older, no longer factory supported light planes flying. But I'd never heard of a single instance of it being allowed in the 6 years or so that I've been seriously following EABs, nor ever heard of it happening previously. I think this is a really unusual case. Very interesting and I'm glad it worked out for you.

Ron