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Re: FAA Letter

Posted: Tue Dec 04, 2018 11:48 am
by 3Dreaming
MrMorden wrote:
The only aircraft that have a special airworthiness certificate are SLSA.
Any aircraft other than type certified aircraft have special airworthiness certificates.

This is from CFR 21.175, (b) Special airworthiness certificates are primary, restricted, limited, light-sport, and provisional airworthiness certificates, special flight permits, and experimental certificates

Re: FAA Letter

Posted: Tue Dec 04, 2018 12:08 pm
by MrMorden
drseti wrote:
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.
I may be wrong on the AW cert details, I'd have to check and verify. But I'm sure of the markings queation, I've gone through the conversion process twice now (once on my airplane and assisting another owner) and the DAR was specific and adamant about it both times. Light Sport / Experimental markings should be either/or, but never both.

Re: FAA Letter

Posted: Tue Dec 04, 2018 12:41 pm
by drseti
MrMorden wrote: DAR was specific and adamant about it both times. Light Sport / Experimental markings should be either/or, but never both.
I certainly concur about that part.

Re: FAA Letter

Posted: Tue Dec 04, 2018 6:09 pm
by ShawnM
Again, this will vary from DAR to DAR as I've been a part of 3 S-LSA to E-LSA conversions and two DAR's didn't ask for the word light sport to be removed and one did. One of the DAR's that DIDN'T ask for the light sport to be removed works directly for a VERY POPULAR airplane manufacturer in the pacific northwest. :mrgreen:

Another Florida member here just did the conversion so we'll wait for him to chime in and see what his DAR said. I was not part of that conversion nor do I know who the DAR was. Although there are only 3 or so of them in Florida.

My E-LSA aircraft has a "SPECIAL AIRWORTHINESS CERTIFICATE" that is salmon colored and states "experimental" under category/designation. Under "purpose" it reads "operating light sport aircraft-airplane". So my experimental light sport aircraft has a special airworthiness certificate.

As far as placards go, my DAR told me to install all the necessary placards on the plane for "experimental" and put masking tape over them before I flew it to him for inspection. Once he was finished with his inspection I removed the masking tape to reveal the words "experimental" and the placard on the dash for passengers and he was satisfied. Very easy to do if away from your home airport and your hangar.

As for climbing in my plane, the word EXPERIMENTAL is in large 2" letters on a placard that is easily recognizable just as the LIGHT SPORT is on the outside and is easily seen. Then there is a "occupant warning" placard right in front of the passenger that also states that this aircraft is "ametur built" (which it's technically not) and does not comply with federal safety regulations.....etc....etc. No need to hunt down the airworthiness certificate.

We can go back and forth forever on this topic and never get the same answer from various DAR's on the subject. I'm willing to bet money that if you were ramp checked by the FAA tomorrow they wouldn't know the answer to the question either. :mrgreen:

Re: FAA Letter

Posted: Tue Dec 04, 2018 6:34 pm
by FastEddieB
ShawnM wrote:
Then there is a "occupant warning" placard right in front of the passenger that also states that this aircraft is "ametur built" (which it's technically not) and does not comply with federal safety regulations.....etc....etc...
There’s a Passenger Warning placard that might be more appropriate for E-LSA’S, in that it doesn’t incorrectly reference “amateur built”. The one on my Sky Arrow:

Image

Re: FAA Letter

Posted: Tue Dec 04, 2018 6:36 pm
by 3Dreaming
Just because there are airplanes flying around like that, and a few DAR's have chosen to not follow the rules doesn't make continuing to operate that way right.

Re: FAA Letter

Posted: Tue Dec 04, 2018 6:40 pm
by TimTaylor
Do this...There is NOTHING debatable about it. It's totally clear what the requirement is. The operative word is "or." It doesn't say "and."

§ 45.23 Display of marks; general.
(a) Each operator of an aircraft must display on that aircraft marks consisting of the Roman capital letter “N” (denoting United States registration) followed by the registration number of the aircraft. Each suffix letter used in the marks displayed must also be a Roman capital letter.

(b) When marks include only the Roman capital letter “N” and the registration number is displayed on limited, restricted or light-sport category aircraft or experimental or provisionally certificated aircraft, the operator must also display on that aircraft near each entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches nor more than 6 inches high, the words “limited,” “restricted,” “light-sport,” “experimental,” or “provisional,” as applicable.

[Doc. No. 8093, Amdt. 45-5, 33 FR 450, Jan. 12, 1968, as amended by Amdt. 45-9, 42 FR 41102, Aug. 15, 1977; Amdt. 45-24, 69 FR 44863, July 27, 2004]

Re: FAA Letter

Posted: Tue Dec 04, 2018 6:46 pm
by drseti
Eddie, you need to add another line at the bottom of your Passenger Warning placard (with Dymo tape):

"It exceeds them."

Re: FAA Letter

Posted: Tue Dec 04, 2018 7:27 pm
by Scooper
FastEddieB wrote:
ShawnM wrote:
Then there is a "occupant warning" placard right in front of the passenger that also states that this aircraft is "ametur built" (which it's technically not) and does not comply with federal safety regulations.....etc....etc...
There’s a Passenger Warning placard that might be more appropriate for E-LSA’S, in that it doesn’t incorrectly reference “amateur built”. The one on my Sky Arrow:

Image
Eddie, my DAR insisted on exactly the same wording with the change to experimental, and I got the placard from Aircraft Spruce.

Image

Re: FAA Letter

Posted: Tue Dec 04, 2018 7:35 pm
by ShawnM
FastEddieB wrote:
ShawnM wrote:
Then there is a "occupant warning" placard right in front of the passenger that also states that this aircraft is "ametur built" (which it's technically not) and does not comply with federal safety regulations.....etc....etc...
There’s a Passenger Warning placard that might be more appropriate for E-LSA’S, in that it doesn’t incorrectly reference “amateur built”. The one on my Sky Arrow:
Thanks Eddie and Stan, I'll certainly change mine to read as your does. I remade all my interior placards myself so everything "matches" on the panel. I'll reprint my passenger warning to read the same. My DAR just referenced the "experimental" verbage sent me a sample of the "amaetur built" one and it was good enough for him. I like yours better for sure.

As for the light sport placard on the outside of my experimental aircraft, it's staying and I'll let you guys sort out your own placards. My DAR didn't ask for it to be removed, that's my story and I'm sticking to it. :mrgreen:

Re: FAA Letter

Posted: Tue Dec 04, 2018 7:50 pm
by drseti
ShawnM wrote:My DAR didn't ask for it to be removed, that's my story and I'm sticking to it. :mrgreen:
Shawn, may I remind you of FAR 91.3(a)? Compliance with all rules is solely the responsibility of the PIC.
Blaming the DAR (or the CFI, DPE, A&P, or anyone else) just won't cut it.

Re: FAA Letter

Posted: Tue Dec 04, 2018 7:52 pm
by TimTaylor
Why not simply remove the "light sport" and be in compliance with the FAR's?

Re: FAA Letter

Posted: Tue Dec 04, 2018 8:22 pm
by Warmi
TimTaylor wrote:Why not simply remove the "light sport" and be in compliance with the FAR's?
Yes, why not Shawn ... who knows , after you do comply your plane may actual start flying faster and further and perhaps even stall at significantly lower speeds ... :-)

Re: FAA Letter

Posted: Tue Dec 04, 2018 8:24 pm
by TimTaylor
Warmi wrote:
TimTaylor wrote:Why not simply remove the "light sport" and be in compliance with the FAR's?
Yes, why not Shawn ... who knows , after you do comply your plane may actual start flying faster and further and perhaps even stall at significantly lower speeds ... :-)
What a ridiculous response. Are you implying it's OK to ignore FAR's unless you decide there is something in it for you? This attitude gets people killed.

Re: FAA Letter

Posted: Tue Dec 04, 2018 8:36 pm
by Warmi
TimTaylor wrote:
Warmi wrote:
TimTaylor wrote:Why not simply remove the "light sport" and be in compliance with the FAR's?
Yes, why not Shawn ... who knows , after you do comply your plane may actual start flying faster and further and perhaps even stall at significantly lower speeds ... :-)
What a ridiculous response. Are you implying it's OK to ignore FAR's unless you decide there is something in it for you? This attitude gets people killed.
Not thinking , being stupid and careless gets people killed ... one can always claim that not having a correct placard is a gateway drug to much more dangerous and consequential behavior but then again, that’s only if you are not thinking , being stupid and careless ... and in that case, having every applicable placard in the universe will not make any difference anyway ...