FAA Letter

Talk about airplanes! At last count, there are 39 (and growing) FAA certificated S-LSA (special light sport aircraft). These are factory-built ready to fly airplanes. If you can't afford a factory-built LSA, consider buying an E-LSA kit (experimental LSA - up to 99% complete).

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RickSigler
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FAA Letter

Postby RickSigler » Mon Dec 03, 2018 4:07 pm

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I just received this letter Saturday from the FAA stating that there is an error in my registration. I contacted the dealer concerning the error and he said that this is a new required document that has not been required before. I submitted my registration in May 2018 and thought everything was fine, but I forgot how the FAA won't miss an opportunity to make your life miserable.

The FAA doesn't cite any law or regulation that mandates this ridiculous requirement and I have been unable to find any support for their demand. I suspect this is something they just dreamt up. There is obviously one major glaring error in their demand. I did not buy the plane from the manufacturer, but rather I bought it from the U.S. dealer. So, there is nothing wrong with my registration and the error supposedly occurred when the dealer registered the plane to his corp which the FAA had no problem with at the time. What makes this really silly is that my plane was built for me and was brand new when I took possession. It seems that even the intellects at the FAA could figure out that the plane was transferred from the manufacturer to the dealer and there is no possible way another owner could have been involved.

I don't know how far back the FAA is going to go for previous registrations, but I doubt any planes imported have had this document provided by the Country's registration authority. I can't imagine getting this letter for a CT or any imported plane that was purchased years ago and passed through different owners and now having to contact a foreign country to get the document. If that happened to me I would not accept FAA's demand without proof that they have the legal authority to make this demand.

I don't think I'm going to have a problem with this demand because the dealer said he has contacted the manufacturer and will soon provide the letter, but I thought I'd let the members know that there is a possibility that more letters may be going out. The dealer told me I am the second owner that has contacted him about the problem.

I would like to know if any other members have ever had to meet this new requirement or am I and the other owner the only lucky ones.

Thanks.

Rick

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Scooper
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Re: FAA Letter

Postby Scooper » Mon Dec 03, 2018 4:41 pm

Rick, the registration shows that the airplane was originally certificated as Light Sport under §21.190 (SLSA) and subsequently recertificated as Experimental operating Light Sport under §21.191 (i) (3) (ELSA). Could the issue be related to the change in certification? Who was the DAR (or which FSDO) submitting the change documentation to FAA Aircraft Registration?

§21.191 Experimental certificates.

Experimental certificates are issued for the following purposes:

(i) Operating light-sport aircraft. Operating a light-sport aircraft that-

(3) Has been previously issued a special airworthiness certificate in the light-sport category under §21.190.

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Stan Cooper (K4DRD)
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TimTaylor
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Re: FAA Letter

Postby TimTaylor » Mon Dec 03, 2018 6:14 pm

You probably should have registered it as S-LSA first. Then, after is was properly registered in your name, gone through the proper steps to convert from S-LSA to E-LSA.
Commercial Pilot Airplane Single & Multiengine Land; Instrument Airplane; Sport Endorsement Airplane Single Engine Sea; Flight Instructor Airplane Single And Multiengine; Ground Instructor Advanced Instrument

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Re: FAA Letter

Postby Scooper » Mon Dec 03, 2018 6:32 pm

TimTaylor wrote:You probably should have registered it as S-LSA first. Then, after is was properly registered in your name, gone through the proper steps to convert from S-LSA to E-LSA.

That's what I'm thinking too.

§21.190 Issue of a special airworthiness certificate for a light-sport category aircraft.
Excerpt:

(b) Eligibility. To be eligible for a special airworthiness certificate in the light-sport category:
(1) An applicant must provide the FAA with—
(i) The aircraft's operating instructions;
(ii) The aircraft's maintenance and inspection procedures;
(iii) The manufacturer's statement of compliance as described in paragraph (c) of this section; and
(iv) The aircraft's flight training supplement.
(2) The aircraft must not have been previously issued a standard, primary, restricted, limited, or provisional airworthiness certificate, or an equivalent airworthiness certificate issued by a foreign civil aviation authority.
(3) The aircraft must be inspected by the FAA and found to be in a condition for safe operation.


(d) Light-sport aircraft manufactured outside the United States. For aircraft manufactured outside of the United States to be eligible for a special airworthiness certificate in the light-sport category, an applicant must meet the requirements of paragraph (b) of this section and provide to the FAA evidence that—

(1) The aircraft was manufactured in a country with which the United States has a Bilateral Airworthiness Agreement concerning airplanes or Bilateral Aviation Safety Agreement with associated Implementation Procedures for Airworthiness concerning airplanes, or an equivalent airworthiness agreement; and

(2) The aircraft is eligible for an airworthiness certificate, flight authorization, or other similar certification in its country of manufacture.

[Amdt. 21-85, 69 FR 44862, July 27, 2004]
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Re: FAA Letter

Postby Warmi » Mon Dec 03, 2018 6:48 pm

Or simply sell the darn thing and enjoy your life some other way that doesn’t involve dealing with FAA - life is too darn short as it is , do you really want to waste your time dealing with this nonsense ?
Flying Sting S4 ( N184WA ) out of Illinois

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Re: FAA Letter

Postby 3Dreaming » Mon Dec 03, 2018 6:51 pm

In addition to what Scooper posted from 21.190 it also contains this statement,

"(2) The aircraft must not have been previously issued a standard, primary, restricted, limited, or provisional airworthiness certificate, or an equivalent airworthiness certificate issued by a foreign civil aviation authority.".

It sounds like the FAA is wanting a letter stating that it meets this requirement.

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Re: FAA Letter

Postby TimTaylor » Mon Dec 03, 2018 7:10 pm

Warmi wrote:Or simply sell the darn thing and enjoy your life some other way that doesn’t involve dealing with FAA - life is too darn short as it is , do you really want to waste your time dealing with this nonsense ?


Yes, following the law and doing what is required is difficult for some people.
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Scooper
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Re: FAA Letter

Postby Scooper » Mon Dec 03, 2018 7:25 pm

3Dreaming wrote:In addition to what Scooper posted from 21.190 it also contains this statement,

"(2) The aircraft must not have been previously issued a standard, primary, restricted, limited, or provisional airworthiness certificate, or an equivalent airworthiness certificate issued by a foreign civil aviation authority.".

It sounds like the FAA is wanting a letter stating that it meets this requirement.

I agree it sounds like there's a screwup getting the FAA Registry the right forms/paperwork to complete the change from 21.190 to 21.191. If that is the case, since it's a brand new airplane Rick bought from Bristell's U.S. dealer, the dealer should be responsible for providing Rick with the information the FAA is requesting.
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Re: FAA Letter

Postby TimTaylor » Mon Dec 03, 2018 7:39 pm

Again, I think if the OP had registered the airplane as S-LSA first, he may have avoided the problem. Several people on this forum have gone through the process of re-registering an S-LSA as an E-LSA. It does appear to require quite a bit of information be provided to the FAA to make this happen, but it's all clearly spelled out in the FAR's.
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Re: FAA Letter

Postby Scooper » Mon Dec 03, 2018 7:53 pm

Looking at the registration history for N585NM, it was imported by Sport Flying USA in Ronkonkoma NY and registered to them (a corporation) on April 25, 2018. The builder certification was Light Sport (21.190). The airworthiness certificate date for Experimental (21.191) was May 7, 2018, and It was then registered to Rick on July 6, 2018.

Rick, I'd get after Sport Flying USA to straighten things out with the FAA. I do have a couple of quick questions, though. Does N585NM have "EXPERIMENTAL" in 2" high letters on it and "Light Sport" removed from the fuselage?

Stan
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Re: FAA Letter

Postby Warmi » Mon Dec 03, 2018 7:53 pm

TimTaylor wrote:
Warmi wrote:Or simply sell the darn thing and enjoy your life some other way that doesn’t involve dealing with FAA - life is too darn short as it is , do you really want to waste your time dealing with this nonsense ?


Yes, following the law and doing what is required is difficult for some people.


Well, it is not like the OP is trying to scam the system or try to do anything even remotely improper....

The problem is not with doing what’s required but trying to figure out what is required in the first place ...
Flying Sting S4 ( N184WA ) out of Illinois

TimTaylor
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Re: FAA Letter

Postby TimTaylor » Mon Dec 03, 2018 7:55 pm

Warmi wrote:
TimTaylor wrote:
Warmi wrote:Or simply sell the darn thing and enjoy your life some other way that doesn’t involve dealing with FAA - life is too darn short as it is , do you really want to waste your time dealing with this nonsense ?


Yes, following the law and doing what is required is difficult for some people.


Well, it is not like the OP is trying to scam the system or try to do anything even remotely improper....

The problem is not with doing what’s required but trying to figure out what is required in the first place ...


FAR 21.190

https://www.law.cornell.edu/cfr/text/14/21.190
Commercial Pilot Airplane Single & Multiengine Land; Instrument Airplane; Sport Endorsement Airplane Single Engine Sea; Flight Instructor Airplane Single And Multiengine; Ground Instructor Advanced Instrument

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Re: FAA Letter

Postby Scooper » Mon Dec 03, 2018 7:58 pm

TimTaylor wrote:Again, I think if the OP had registered the airplane as S-LSA first, he may have avoided the problem. Several people on this forum have gone through the process of re-registering an S-LSA as an E-LSA. It does appear to require quite a bit of information be provided to the FAA to make this happen, but it's all clearly spelled out in the FAR's.

Tim, I'm one of those who went through the process with my AMD Zodiac SLSA. Brian and Carol Carpenter of Rainbow Aviation Services shepherded me though all the paperwork (Brian is a DAR and A&P IA).

My airplane was made in Eastman, Georgia, so I didn't have the added complication of a foreign manufacturer. It was complicated enough as it was. :(
Last edited by Scooper on Mon Dec 03, 2018 8:05 pm, edited 1 time in total.
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Re: FAA Letter

Postby TimTaylor » Mon Dec 03, 2018 8:04 pm

Scooper wrote:
TimTaylor wrote:Again, I think if the OP had registered the airplane as S-LSA first, he may have avoided the problem. Several people on this forum have gone through the process of re-registering an S-LSA as an E-LSA. It does appear to require quite a bit of information be provided to the FAA to make this happen, but it's all clearly spelled out in the FAR's.

Tim, I'm one of those who went through the process with my AMD Zodiac SLSA. Brian and Carol Carpenter of Rainbow Aviation Services shepherded me though all the paperwork (Brian is a DAR and A&P IA).


Yes Stan. You and Andy and Eddie to name a few I know of.
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Re: FAA Letter

Postby FastEddieB » Mon Dec 03, 2018 9:07 pm

Scooper wrote: Does N585NM have "EXPERIMENTAL" in 2" high letters on it and "Light Sport" removed from the fuselage?



I’m not sure of the significance of the last (italicized) part.
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