"Downgrade" SLSA to ELSA?

Are you building/buying/flying an Experimental Amateur-Built (E-AB) or Experimental Light Sport (E-LSA) aircraft? Converting an S-LSA to E-LSA? Changing or adding equipment, or otherwise modifying an S-LSA? Need help with Letters of Authorization? Or maybe designing your own aircraft? This forum is the place to discuss All Things Experimental.

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FastEddieB
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"Downgrade" SLSA to ELSA?

Postby FastEddieB » Mon Nov 30, 2009 3:31 pm

I own and fly a Sky Arrow 600 LSA.

The way the Maintenance Manual is written, it makes it problematical to do even the most simple tasks. It requires a LSA Maintenance License or better to do nearly anything, including many things that one could legally do as Preventive Maintenance under Part 91.

My annual is due in December. This would be an opportunity to have that inspection count as the inspection required by a DAR to convert from an SLSA to an ELSA.

I am seriously considering it, so I can do more of my own maintenance. I do not rent or instruct in the plane, nor do I intend to do so. I also am not overly concerned with resale value, since I plan on keeping the plane a long time.

In addition, the manufacturer (3i) is technically in some sort of Italian bankruptcy. They are currently supporting the Sky Arrow, but going forward its not at all certain they'll be able to continue doing so.

Has anyone done this - gone from SLSA to ELSA? Are there any other downsides I haven't considered?

Thanks in advance...

Fast Eddie B. (Ed Benson - Mineral Bluff, GA)
Sky Arrow 600 LSA • N467SA

seastar
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S to E

Postby seastar » Tue Dec 01, 2009 2:33 pm

I can't answer your question but it is my understanding that the main difference is that no charge can be made for the airplane.
I am considering buying a Cubcrafters Super Sport Cub and having the certificate changed to ELSA at the factory.
There are many reasons to do this.
I hope some one can answer your question since I would also like to know all of the ramifications.

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FastEddieB
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Postby FastEddieB » Tue Dec 01, 2009 7:42 pm

So far, insurance has been the only bugaboo.

My agent (Falcon via EAA) told me that they would only insure the hull for 50% of the current insured value ($70k). That, because of the lowered assumed value of an ELSA.

They initially said they'd need a copy of my A&P - which I don't have. And that I could not work on the plane unless I built at least 51% of it.

That's wrong, legally, but shows how confusing all this can be, and an underwriter could have higher standards.

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CharlieTango
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Postby CharlieTango » Tue Dec 01, 2009 9:05 pm

i have posted before that unless you are the builder or have a light sport repairman's certificate or an a&p that you cannot do the maintenance.

eddie, why do you say that is wrong?

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FastEddieB
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Postby FastEddieB » Wed Dec 02, 2009 8:31 am

I've been flying and doing Preventive Maintenance on my planes for over 30 years. But I find the new regs and certifications VERY confusing.

And the AMM for my S-LSA Sky Arrow precludes me from doing some VERY simple maintenance, much of which would have been allowed under Part 43 for normally certificated planes.

I got some of my info from this site:

http://www.askbob.aero/node/116

The relevant part (emphasis mine):

As a sport pilot flying an ELSA for pleasure, you only need the 16 hour inspection course. Classes are normally schedule on the weekend. Successful completion of the course will allow you to perform annual condition inspections on any ELSA in the assigned “class” of the selected course (airplane, weight shift, powered parachute, glider, gyroplane, or lighter-than-air) which you own or purchases in the future that are certificated in the E-LSA category in any of the three ways listed above.
However, if you fly two different classes of aircraft, say, airplane and weight shift, then you will have to take one 16 hour inspection course for weight shift and another 16 hour inspection course for airplane.
The good news: There are no renewal requirements for your certificate, once you earn it, and there are no limits on how many aircraft in the select class you may own. Additionally, all maintenance is already allowed. There is no requirement for a repairman certificate to perform maintenance on your E-LSA. This is important because after you convert your aircraft, you will have one year until you need to have completed the required repairman inspection course.


Is this wrong?

I'm not arguing - just trying to get it straight in my mind before converting.

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CharlieTango
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Postby CharlieTango » Wed Dec 02, 2009 8:39 am

that sounds wrong eddie,

the underwriter had it close, he said a&p not a&p or light sport repairman's certificate.

i think what you posted above would only be true if you built 51%.

of course someone else told me i'm wrong on this, it would be good to cite the relevant rule.

rsteele
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Postby rsteele » Wed Dec 02, 2009 9:44 am

The 51% rule isn't relevant to E-LSA, it only applies to EAB (Experimental Amateur Build).
To be able to work on you own E-LSA you need (at a minimum) a 3 day E-LSA repairmen course. These are taught regularly by EAA chapters. The cost is usually around $300.

There is also a E-LSA inspector's certificate, but I'm less clear on it's purpose. I know its "lower" certification than repairmam (just the opposite of an A&P vs A&P-IA)

If not already a member, join EAA, they have a lot of resources on this stuff.

Ron

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FastEddieB
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Postby FastEddieB » Wed Dec 02, 2009 11:46 am

Thanks, guys.

I think the different answers show how confusing it can be.

I do plan on taking the 16-hour E-LSA Inspection course. It appears as though I'll then be able to work on my downgraded E-LSA Sky Arrow, and I'm pretty sure the 51% does not apply to a previously certified S-LSA.

I am an EAA member already - I may go to their site and see if they have anything to add.

Thanks again,

Fast Eddie B. (Ed Benson - Mineral Bluff, GA)
Sky Arrow 600 LSA • N467SA

rsteele
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Postby rsteele » Wed Dec 02, 2009 2:23 pm

I'm pretty sure you need the repairmen course, not inspector.
I'm no expert though. I attended an hour long seminar on this issue by some who presents the courses, and this is what I remember. This guy is an A&P and he says the LSA stuff is about the most confusing thing he's ever seen.

Good luck!

Ron

comperini
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Postby comperini » Wed Dec 02, 2009 10:53 pm

rsteele wrote:There is also a E-LSA inspector's certificate, but I'm less clear on it's purpose. I know its "lower" certification than repairmam (just the opposite of an A&P vs A&P-IA)


What you are talking about is a repairman certificate. It gives people who own aircraft certificated in the E-LSA category one privilege: They can perform their own annual condition inspections.

Even owner's of experimental amateur built planes, who have built more than 51% of that plane, can not perform an annual condition inspection unless they also hold the repairman certificate for their plane. Proving to the FAA that you built at least 51% makes you eligible to obtain the repairman certificate for that plane, but you still need one.

The repairman certificate you'll get on an amateur built plane, is given simply by filling out the application, and proving you built the plane. With E-LSA there is no "51% rule", so the FAA had to come up with some other way of making people eligible to obtain the repairman certificate, and that's the 16 hour course. There are two versions of this repairman certificate. The 16 hour course, give you the "inspection" rating, which allows you to perform annual condition inspections on any E-LSA you own. The 120 hour "maintenance" rating, allows you to perform 100 hour and annual condition inspections on E-LSA and S-LSA aircraft owned by anyone.

No rating of any kind is required to perform maintance on experimentals. Why? Part 43 doesn't apply.... [14 CFR 43.1(b)]

... except for one unfortunate case: SLSAs that were converted to ELSA under 21.191(i)(3). In this case, Part 43 still applies. This goof, is one of the "22 things" being changed with the new release of regs due out soon.

So, once that little goof is fixed, if you convert your SLSA TO ELSA, yes, you'll be able to perform your own maintenance without needing a rating of any kind. You'll also be able to modify the plane to your heart's content.

rsteele
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Postby rsteele » Thu Dec 03, 2009 9:33 am

[/quote]

... except for one unfortunate case: SLSAs that were converted to ELSA under 21.191(i)(3). In this case, Part 43 still applies. This goof, is one of the "22 things" being changed with the new release of regs due out soon.
.[/quote]

This is interesting. I hadn't heard it. Is this the same set of rules that are anticipated that will change the Sport Pilot regs?

If this happens it's a real game changer because E-SLA kits would become more attractive than EAB kits since the 51% rule is pretty limiting for a lot of potential builders. Even EAB "quick build" kits have some work to do that's not all that straight forward for Joe Builder.

Ron

comperini
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Postby comperini » Thu Dec 03, 2009 11:03 am

rsteele wrote:This is interesting. I hadn't heard it. Is this the same set of rules that are anticipated that will change the Sport Pilot regs?


Yes, this quirk is one of the things that will be changed with the upcoming rule changes (expected out any time now)

rsteele wrote: If this happens it's a real game changer because E-SLA kits would become more attractive than EAB kits since the 51% rule is pretty limiting for a lot of potential builders. Even EAB "quick build" kits have some work to do that's not all that straight forward for Joe Builder.


Note: This has nothing to do with E-LSA kits, certificated under 21.191(i)(2). This maintenance quirk has to do with E-LSA's that were "converted SLSAs" per 21.191(i)(3).

You can already perform maintenance on E-LSA kits under 21.191(i)(2), and any other experimental, for that matter.

roger lee
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New Rules

Postby roger lee » Wed Dec 09, 2009 8:13 pm

The new rules are due out Dec. 13th. You will like some of the new rules.
Roger Lee
Tucson, Az.
LSRM-A, Rotax Instructor & Rotax IRC
(520) 574-1080 (Home) Try Home First.
(520) 349-7056 (Cell)

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CharlieTango
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Re: New Rules

Postby CharlieTango » Wed Dec 09, 2009 8:42 pm

roger lee wrote:The new rules are due out Dec. 13th. You will like some of the new rules.


roger lee,

tell us more

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FastEddieB
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The deed is done...

Postby FastEddieB » Sat Dec 12, 2009 9:47 am

As of Thursday, my Sky Arrow is an E-LSA.

The inspection was completed in one day, but that was after I spent about 3 days disassembling things, lubing wheel bearings, draining the oil and cutting the filter, etc.

A DAR came up from Lawrenceville, GA do do the inspection/conversion.

My battery was definitely weak, and a new one is on the way. Turns out my transponder certification is overdue, and the ELT does not seem to be activating with a normal "impact".

Other than that, no real squawks. The EXPERIMENTAL decal is ready to go on, as is the passenger warning.

Photos to follow.
Last edited by FastEddieB on Fri Dec 18, 2009 6:39 pm, edited 1 time in total.


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