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S-LSA converted to E-LSA

Posted: Sun May 27, 2018 5:32 pm
by c162pilot
Seeking advice from those of you who have taken your S-LSA to E-LSA. If you purchase a S-LSA aircraft and then transition it into the E-LSA category can you then make changes to the aircraft that takes it beyond S-LSA regulations? Example would be changing to a prop that causes the aircraft to exceed 120 KTIS. The reason I ask is that some S-LSA’s sold in the USA are certified to higher speeds in their country of manufacture but are modified to reduce there speed in the USA to qualify as a S-LSA.

Re: S-LSA converted to E-LSA

Posted: Sun May 27, 2018 5:40 pm
by FastEddieB
c162pilot wrote:Seeking advice from those of you who have taken your S-LSA to E-LSA. If you purchase a S-LSA aircraft and then transition it into the E-LSA category can you then make changes to the aircraft that takes it beyond S-LSA regulations?
No.
c162pilot wrote:If you purchase a S-LSA aircraft and Example would be changing to a prop that causes the aircraft to exceed 120 KTIS.
You could do that, but would have to placard it in such a way to stay below that speed in normal cruise. RPM limitation would be the most obvious way.

Re: S-LSA converted to E-LSA

Posted: Tue Jun 05, 2018 3:03 pm
by zodiac flyer
Thats a pretty interesting question. I have a Zodiac AMD built, converted to ELSA from SLSA. The registration and airworthiness certificate say Experimental, operating as a light sport. Once you take the aircraft out of it's operating limitations, I don't think you are able to go back. So if it's not an experimental operating as a light sport, what is it? Does it become a Experimental? How can it be, if the paperwork says operating as a light sport?
This is above my pay grade, hopefully Mel or some other DAR can respond to this.
Dave
N601XP

Re: S-LSA converted to E-LSA

Posted: Tue Jun 05, 2018 3:11 pm
by TimTaylor
I'm guessing it's experimental operating as light sport until it no longer meets the definition of light sport. At that time, it would become experimental. A Sport Pilot can only fly LSA, so I assume you would need a Private or better to fly it.

Re: S-LSA converted to E-LSA

Posted: Tue Jun 05, 2018 3:58 pm
by 3Dreaming
Experimental airworthiness certificates are issued under I think 9 different sub areas. You have to fall under one of them. Take a look at CFR 21.191 for the options. If you leave experimental operating as a light sport you don't have many options, Experimental R&D or Experimental exhibition would be your choices. Neither of which will have desirable operating limitations.

Re: S-LSA converted to E-LSA

Posted: Tue Jun 05, 2018 4:41 pm
by comperini
TimTaylor wrote:I'm guessing it's experimental operating as light sport until it no longer meets the definition of light sport. At that time, it would become experimental. A Sport Pilot can only fly LSA, so I assume you would need a Private or better to fly it.
It doesn't change experimental categories. You simply have invalidated your airworthiness certificate. period

Re: S-LSA converted to E-LSA

Posted: Tue Jun 05, 2018 9:11 pm
by ShawnM
A simple way to look at it is it's still a light sport aircraft and it DOES meet all the definitions of a light sport airplane. I converted my SportCruiser and only have a sport pilot rating. Nothing changes except I'm now allowed to make any and all changes I want, myself. I no longer need a LOA/MRA or permission from the manufacturer or a LSRMA to work on it other than for my annual since I didn't take the class to do it myself. I cannot however make any changes that take the aircraft outside the definition of a light sport, that would violate the FAR's. (ie, a constant speed prop, etc.) I dont know what would happen if you did and why.

On the FAA website my registration now reads:

Classification: Experimental
Category: Operating Light-Sport Prev. issued cert under 21.190

There's more to the conversion but that's basically it in a nutshell.

Re: S-LSA converted to E-LSA

Posted: Tue Jun 05, 2018 9:26 pm
by TimTaylor
There are two question raised here. Converting from S-LSA to E-LSA, not a problem. Making a modification that takes it out of the LSA definition, is a problem. For example, if you did something that raised the stall speed above LSA limits or put on a constant speed prop.

Re: S-LSA converted to E-LSA

Posted: Wed Jun 06, 2018 9:23 am
by ShawnM
TimTaylor wrote:There are two question raised here. Converting from S-LSA to E-LSA, not a problem. Making a modification that takes it out of the LSA definition, is a problem. For example, if you did something that raised the stall speed above LSA limits or put on a constant speed prop.
Correct Tim, in my opinion most make the switch to E-LSA to be able to make minor changes and do a lot of the work on their own plane. I also switched because my manufacturer, Czech Sport Aircraft, does not issue LOA/MRA’s for any reason. I simply wanted to upgrade my outdated 2007 avionics and the manufacturer would not allow it. In a nutshell, they suck.

I have no intention of making changes that would take my plane out of the definition of a light sport. Since I currently only hold a SP rating and I don’t even know what would happen if I did and what the new category would be. I also don’t think others are making these changes either, it’s really all about the freedom from the manufacturer and their rules. :mrgreen:

Re: S-LSA converted to E-LSA

Posted: Tue Sep 01, 2020 1:10 pm
by JimParker256
Just in case this thread gets revived (again) and / or the issue comes up (again)...

Remember that to be flown as an LSA by a Sport Pilot (or to maintain an S-LSA airworthiness certificate), the aircraft must have ALWAYS (since it was first certified) meet the LSA standards. My local DAR told me that once you "burn" the LSA status, it's gone forever... If you do ANYTHING to the aircraft that makes it no longer meet the LSA "definition" (such as changing to a constant-speed prop, or changing the max gross weight to something above 1320 lbs), the airworthiness certificate is voided (revoked) and the aircraft not only IS no longer qualified to be an LSA, but even if you reverse the change that disqualified it (going back to a fixed-pitch prop or reducing the max gross weight to 1320) that aircraft no longer meets the "ALWAYS" clause, and thus can NEVER be flown as an LSA again.

The other question that arose was about making a change to an E-LSA that took it outside the LSA standards (such as – again – a constant-speed prop). In that situation, the minute it no longer meets the LSA rules, the airworthiness certificate is invalidated. Once again, reversing the change to restore compliance with the LSA rules does NOT allow you to meet the "Operating as LSA" rules, because those require it to have been "continuously" met.

The only recourse in either of the above situations is to obtain an "Experimental" airworthiness certificate, but since it was once certified as an LSA (either S-LSA or E-LSA), by "rule" it does NOT meet the requirements to be issued an "Experimental - Amateur Built" airworthiness cert. Even though the airplane has an "Experimental" airworthiness certificate, and may originally have met the "Amateur Built" requirements, it cannot be registered as EAB, and could only be re-registered into one of the other (more restrictive) Experimental categories. (The FAA won't allow a previously registered EAB to be "remanufactured" and granted a new airworthiness certificate.) It might be eligible for one of the other Experimental categories, but those categories are far more restrictive, often requiring "program letters" to be approved by your local FSDO, and often require every flight outside a very limited area to be "approved in advance" by the FSDO.

So, the bottom line is this: Don't make any changes to your LSA (whether S-LSA or E-LSA) that are disallowed under the LSA certification rules, because once you do so, there is no going back, and your airplane A) can no longer be flown by a Sport Pilot, and B) probably lost most of its value due to the limitations imposed by the "other" Experimental certification categories.

Re: S-LSA converted to E-LSA

Posted: Tue Sep 01, 2020 6:20 pm
by drseti
ShawnM wrote:I'm now allowed to make any and all changes I want, myself.
Well, only if none of the changes you want would take it outside of the FAR 1.1 definition of LSA.

Re: S-LSA converted to E-LSA

Posted: Tue Sep 01, 2020 7:04 pm
by ShawnM
drseti wrote:
ShawnM wrote:I'm now allowed to make any and all changes I want, myself.
Well, only if none of the changes you want would take it outside of the FAR 1.1 definition of LSA.
ShawnM wrote: I cannot however make any changes that take the aircraft outside the definition of a light sport, that would violate the FAR's. (ie, a constant speed prop, etc.)
ShawnM wrote:I have no intention of making changes that would take my plane out of the definition of a light sport. Since I currently only hold a SP rating and I don’t even know what would happen if I did and what the new category would be.
Of course Paul, I'm experienced enough to know that and have said it many times in my recent posts. :mrgreen:

Re: S-LSA converted to E-LSA

Posted: Tue Sep 01, 2020 7:45 pm
by drseti
I was saying that for the sake of some of our newcomers, Shawn, not you. :D