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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Scooper
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Re: FAA Letter

Postby Scooper » Mon Dec 03, 2018 9:34 pm

FastEddieB wrote:
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.

Eddie, a requirement by the Carpenters when I made the change was to apply the "EXPERIMENTAL" placard and remove the "Light-Sport" decals from the fuselage.

This quote is from the FAA document "Light-Sport Aircraft Airworthiness Certification" dated July 8, 2013:

An SLSA must display the words “LIGHT-SPORT” near each entrance to the cabin, cockpit, or pilot station. This marking must be displayed at a 2-inch minimum to no more than 6-inch maximum height. (Ref. 14 CFR § 45.23(b))

NOTE: When an SLSA certification changes to an ELSA certification, the word “EXPERIMENTAL” must be displayed on the aircraft in lieu of “LIGHT-SPORT.” (Ref. 14 CFR § 45.23(b))


Also, FAA Order 8130.2J (7/21/2017) specifies the inspection required of the airplane by the DAR or FSDO when making the change from SLSA to ELSA:

d. Inspect Aircraft. A general airworthiness inspection is accomplished only after the aircraft is complete in every respect and before the issuance of the experimental airworthiness certificate. Do not perform any fabrication, construction, assembly, testing, manufacturer’s quality inspections, or closing work on the aircraft. During this inspection, the FAA may only request disassembly when a safety hazard is identified that would endanger the general public.
(1) In preparation for the inspection, ensure that plates, access doors, fairings, and cowlings are open or removed to allow inspection.
(2) Verify the aircraft meets § 1.1 as applicable.
(3) Verify the aircraft N-number marks are per part 45. If an aircraft previously held a special airworthiness certificate in the light-sport category, the “LIGHT-SPORT” mark required by § 45.23(b), must be changed to “EXPERIMENTAL.”
(4) Verify the ID plate meets the requirements of § 45.11, as applicable.
(5) Verify the information on the ID plate is correct, matches the information on FAA Form 8130-6, and is per § 45.13, as applicable. Identification data required by § 45.13(a)(1), (2), and (3) are mandatory. Any other optional data that the manufacturer/builder includes on the ID plate must be in such a manner as not to confuse the mandatory data contents.
(6) For kit-built LSA, verify that the LSA is properly assembled per the manufacturer’s assembly instructions for that aircraft and the applicable FAA-accepted consensus standard.
(7) Verify the following placard is displayed in the aircraft in full view of all occupants: “PASSENGER WARNING—THIS AIRCRAFT DOES NOT COMPLY WITH FEDERAL SAFETY REGULATIONS FOR STANDARD AIRCRAFT.” This applies to all classes of LSA certificated in experimental purpose for operating LSA.
(8) Verify that installed equipment matches the AOI.
(9) Verify the flight control systems and associated instruments as equipped operate properly and are appropriate for each of the six classes of LSA.
(10) Verify the cockpit instruments are appropriately marked, as specified in the FAA-accepted consensus standard of ASTM, International, (ASTM) for the aircraft class and as found in the aircraft’s AOI, and that placards are installed and placed for easy reference.
(11) Verify that the airspeed indicator marks match the AOI limitations.
(12) Verify the system controls (for example, fuel selector(s) and electrical switches/breakers) are appropriately placed, clearly marked, provide easy access and operation, and function per the manufacturer’s instructions and specification documentation.
(13) Verify airframe emergency parachutes that are ballistic, assisted, or deployable are properly marked and identified. The aircraft must have provisions that provide for clear marking and identification of all explosive devices used in conjunction with ballistic parachutes. Marks indicating the aircraft is equipped with explosive devices must be applied externally and able to be read while standing on the ground. An airworthiness certificate will not be issued before meeting this requirement.
Stan Cooper (K4DRD)
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FastEddieB
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Re: FAA Letter

Postby FastEddieB » Mon Dec 03, 2018 10:02 pm

Thanks for the detailed response.

My conversion was circa 2009, so predated that 2013 document.

I wonder if I should now remove my LIGHT SPORT decals to stay in accordance with the later guidance.

It all seems illogical - an EXPERIMENTAL Light Sport does not lose its Light Sport designation. It just changes from Special to Experimental. It’s still a Light Sport, so why not flaunt it?
Fast Eddie B.
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Re: FAA Letter

Postby Scooper » Mon Dec 03, 2018 11:14 pm

Eddie, I'd just leave the Light-Sport decals on the airplane until/unless the FAA gets picky and tells you to remove them.

You're absolutely right; even though it's experimental it still meets the Light-Sport category requirements so what's the big deal about calling it what it is?
Stan Cooper (K4DRD)
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Re: FAA Letter

Postby 3Dreaming » Mon Dec 03, 2018 11:15 pm

FastEddieB wrote:Thanks for the detailed response.

My conversion was circa 2009, so predated that 2013 document.

I wonder if I should now remove my LIGHT SPORT decals to stay in accordance with the later guidance.

It all seems illogical - an EXPERIMENTAL Light Sport does not lose its Light Sport designation. It just changes from Special to Experimental. It’s still a Light Sport, so why not flaunt it?


It does change the basis for the issuance of the airworthiness certificate. It also takes in to consideration that the aircraft may have been changed causing it to no longer be in compliance with ASTM standards. Also it might be worth a look at CFR part 45. It has been a while since I looked at it, but I seem to remember the regulations also follow the AC.

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Re: FAA Letter

Postby RickSigler » Tue Dec 04, 2018 8:30 am

The plane was imported as a S-LSA and registered to the dealer as a S-LSA. A DAR did the conversion to ELSA while it was still owned by the dealer and all placards were properly installed (cost me $2K). The FAA knows that the plane was transferred to the dealer from the manufacturer as a brand new plane since they had the docs when the dealer registered the plane, so it doesn't make any sense that it could have been registered to someone else. The dealer has assured me that they will get letters for all of the Bristells sold by them, so all I have to do it wait.

Have any other members run into this? Thanks.

Rick

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Re: FAA Letter

Postby drseti » Tue Dec 04, 2018 9:37 am

I think it's a good idea to remove the "Light Sport" markings when converting to an ELSA, and replace them with "Experimental." Yes, under FAR 1.1 they are both LSAs. So are some Champs, Cubs, T-Craft. Luscombe, Ercoupes, Intersates, etc. This effects who can fly them. But a "Light Sport" marking on those would only confuse things from a maintenance and inspection standpoint.
The opinions posted are those of one CFI, and do not necessarily represent the FAA or its lawyers.
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Re: FAA Letter

Postby 3Dreaming » Tue Dec 04, 2018 9:48 am

I had a customer with a different brand airplane that ran into some issue where they needed extra documentation from the manufacturer. I don't remember the specifics, but it took quite a while to get it straightened out.

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Re: FAA Letter

Postby ShawnM » Tue Dec 04, 2018 10:25 am

I also converted my S-LSA SportCruiser to E-LSA in 2016 here in Florida and the DAR did not ask me to remove the "light sport" decal from the side of the fuselage. I of course was required to ADD a placard to the airplane in 2" letters that read "experimental". I added this inside in the luggage area that is clearly visible to anyone entering the airplane. It is placarded as an "experimental" in two place inside the cockpit per the regulations. It's never been an issue and I currently have no plans to remove the word "light sport" from the fuselage. It is after all still a "light sport".

I've seen it go both ways with various DAR's since I converted mine. I know of 3 other people that have converted since I have and some were asked to remove the "light sport" while others were not. Just goes to show you that the FAA rules can be interpreted differently by different people. :?

Surprisingly my conversion was very easy and took only a few hours and cost $400. All paperwork was filled out by either me or the DAR before I flew to him. $2000 for the conversion is highway robbery. :shock: But if you can afford a new Bristell then you probably could find $2000 in your couch cushions. :mrgreen:

Back to the OP, there clearly is a paperwork mixup somewhere along the line. Given that it was imported in April, registered and then converted in May the paperwork was sitting in a huge pile on someones desk in Oklahoma with the ink still wet on it. Doing the conversion is one pile of paperwork and then ownership transfer is another pile so somewhere along the line things went awry with the FAA, I know they are perfect in every way so that's just not possible and it's all Rick's fault and the burden of proof is on him unfortunately. :mrgreen:

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Re: FAA Letter

Postby 3Dreaming » Tue Dec 04, 2018 10:40 am

Back when Airtime Aviation was doing the testing to get floats approved for the Flight Design CTLS the FAA made them remove the "Light Sport" decal and replace it with an "Experimental" decal. The airplane was returned to SLSA status after the testing was completed and the floats were determined to be in ASTM compliance by Flight Design. The Experimental decal was removed and the Light Sport decal reinstalled.

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Re: FAA Letter

Postby MrMorden » Tue Dec 04, 2018 11:06 am

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.


To be fair, the FAA doesn't always make it easy or understandable. I just helped a friend through the SLSA to ELSA conversion process, and the DAR was just as frustrated as any owner over the nonsensical nature of some of the requirements.
Andy Walker
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Re: FAA Letter

Postby MrMorden » Tue Dec 04, 2018 11:11 am

drseti wrote:I think it's a good idea to remove the "Light Sport" markings when converting to an ELSA, and replace them with "Experimental."


It's not just a good idea, it's a legal requirement. SLSA *must* be marked "Light Sport" visible from each entrance (but no particular font or letter height is specified) , and ELSA *must* be marked "Experimental" in two-inch letters visible from each entrance. If you don't have the correct markings for the airworthiness type and fly the airplane, you are not operating legally.

This gets funky when converting, because you can't remove the Light Sport markings until the inspection is complete, and then the DAR is suposed to see the correct Experimental marking on the airplane before leaving after the inspection. It makes for something of a timing and logistical hassle sometimes.
Andy Walker
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2007 Flight Design CTSW E-LSA

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Re: FAA Letter

Postby drseti » Tue Dec 04, 2018 11:18 am

MrMorden wrote:It's not just a good idea, it's a legal requirement.


And conversely, Andy:

"It's not just the law, it's a good idea."
;)
The opinions posted are those of one CFI, and do not necessarily represent the FAA or its lawyers.
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Re: FAA Letter

Postby MrMorden » Tue Dec 04, 2018 11:19 am

ShawnM wrote:I also converted my S-LSA SportCruiser to E-LSA in 2016 here in Florida and the DAR did not ask me to remove the "light sport" decal from the side of the fuselage. I of course was required to ADD a placard to the airplane in 2" letters that read "experimental". I added this inside in the luggage area that is clearly visible to anyone entering the airplane. It is placarded as an "experimental" in two place inside the cockpit per the regulations. It's never been an issue and I currently have no plans to remove the word "light sport" from the fuselage. It is after all still a "light sport".


"Light Sport" is a marking specifically referring to an airplane with a "special" airworthiness certificate, and the "Experimental" lettering is specific to an airworthiness certificate in the experimental category, whether ELSA, EAB, or what have you. Both should not exist on the same aircraft, as they have mutually exclusive meanings.

The only aircraft that have a special airworthiness certificate are SLSA. Legacy airplanes like Cubs and Ercoupes do not, even though they meet the definition of an LSA by the FAA. These airplanes can't display "Light Sport" markings legally, even though they meet the LSA definition. Likewise experimentals may meed the LSA definition, but do not have Special Airworthiness certificates and should not display the Light Sport markings. Those markings are supposed to indicate that an airplane has a special airworthiness certificate, neither certified nor experimental. It's how you can tell Part 43 aircraft from SLSA from Experimental, even though all can be LSA.
Andy Walker
Athens, GA
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2007 Flight Design CTSW E-LSA

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Re: FAA Letter

Postby TimTaylor » Tue Dec 04, 2018 11:26 am

Technically, someone climbing into an airplane might want to know what kind of airplane it is. Short of reading the airworthiness certificate, the lettering near the entrance would tell them. They might be eager to get into an LSA, but not an experimental, etc.

And, of course, the problem is the FAA. It always is. After all, the FAA is a federal government agency.
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Re: FAA Letter

Postby drseti » Tue Dec 04, 2018 11:31 am

MrMorden wrote:"Light Sport" is a marking specifically referring to an airplane with a "special" airworthiness certificate, and the "Experimental" lettering is specific to an airworthiness certificate in the experimental category, whether ELSA, EAB, or what have you.


I don't think that's entirely correct, Andy.

As I understand it, airworthiness certificates come in two flavors and colors: standard (white) and special (red). Standard Category ones are normally issued to certified aircraft (unless converted to Special for some specific purpose). Special will indicate "operating as" which may be Experimental Light Sport, Experimental Exhibition, Experimental Amateur Built. Special Flight Permit, Special Light Sport, etc. You gotta read the fine print on the Special Airworthiness Certificate to get the whole picture.
The opinions posted are those of one CFI, and do not necessarily represent the FAA or its lawyers.
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