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RV-12 is a Special LSA

JerryG150

JerryG150

Well Known Member
I guess all of our homebuilt RV-12's will be E-LSA as per the Rvator posted today on Van's site. http://doc.vansaircraft.com/RVator/2008/1-2008-RVator.pdf I for one, would like to see a Quickbuild Kit for the RV-12 that doesn't have to worry about the 51% Rule. The sooner I get into the air the better. I had no intentions of deviating from Van's plans at all.

I hope we have an option to buy a panel that is "prefabricated" to the Special LSA prototype. An exact replica is fine with me.

I just want to get started!
 
Any wiggle room for customization?

So, is there any wiggle room at all for customization of a special LSA?

For example will the builder still have his choice of panel instruments?

If Vans certifies without wheel pants can the builder add them?

Its good to see the 12 "almost ready to go". Kudos to Vans for posting the RVator online. With Sun-N-Fun just a month away I would not expect anymore information until then, but I'm assuming a lot of information with be available at Sun-N-Fun (including a look at both prototypes!)

Frank
 
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FrankS said:
So, is there any wiggle room at all for customization of a special LSA?

For example will the builder still have his choice of panel instruments?

If Vans certifies without wheel pants can the builder add them?
Click to expand...
IIRC, it all depends on what Van's explicitly allows - if they allow option A or B, you can use A or B, but not C. For example, if they allow steam gauges, Dynon or AFS, you can use those but not a WizzBang SuperEFIS. That's the down side to S-LSA and E-LSA.

TODR
 
Wow...if I understand this correctly, Vans just let me down. what happened to the -12 being simply another RV kit that happens to fall into the parameters of LSA? I for one was hoping to be able to add slight modifications such as exterior lights, wheel pants, and a NAV radio to the -12. Not to mention get my repairman's certificate for the kit I built.. :(

Am I missing something or will we all have to take an LSA class to give condition inspections to our own airplanes??? If so, I suddenly see the RANS S-19 getting much more popular...


EDIT: After re-reading the newsletter, I read this article:

Builders who wish to modify our S-LSA kit in any
way will have to submit their finished aircraft to the FAA
for certification under the E-AB rules – including the
51% rule. In the past this "proof" of kit completion level
was demonstrated by Van's Aircraft but for at least the
duration of the moratorium it will become solely the responsibility
of the builder.


Do the Vans employees see this as being a problem? (proving you built 51% of the airplane?) I can understand this being an issue if they do come out with a QB kit, but for the basic kit I can't imagine the FAA or DARS saying the builder did not build the majority...anyone care to chime in on if this would be a problem?
 
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Mike_ExpressCT said:
Do the Vans employees see this as being a problem? (proving you built 51% of the airplane?) I can understand this being an issue if they do come out with a QB kit, but for the basic kit I can't imagine the FAA or DARS saying the builder did not build the majority...anyone care to chime in on if this would be a problem?
Click to expand...

The point Van is making is that at this juncture, with the moratorium on adding kits to the 51% list........we just don't know how the RV-12 will be classified by the FAA. It may be harder to get the RV-12 standard kit approved as 51% since the new standard kit is so prefabricated, but we won't know for certain until the FAA releases its new standards, and Vans works through the new 51% evaluation.

We just have to wait.......
 
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From everything I've heard from Van's, it was their intention to release the kit meeting the 51% rule for E-AB, as well as to certify it as an SLSA. Unfortunately, I think the FAA's moratorium put a temporary crimp in their plans. It just means that for now, they are recommending that you plan to build it as an ELSA as opposed to an E-AB. From the RVator:

But how about the still-to-be-released RV-12 kit? Van's Aircraft, Inc.'s best option at this time is to license the new RV-12 as a Special LSA. This will allow our customers to build an Experimental LSA from our kit with no doubts about gaining an airworthiness certificate.​
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They are going to go through the hoops to license this plane as an S-LSA to guarantee a finished kit will get an Airworthiness Certificate.

However, it is my opinion that probably before any of us get close to completing it, the updated rules will be out and by then they should have evaluated it for compliance with the 51% rule. Those that want to do modifications and complete it as an E-AB can do so - as I have no doubt that the standard kit that they are releasing initially will fall well within the 51% guidelines.

Van's intends to release a "quickbuild" later. Whether that falls under the 51% for E-AB will have to be seen. He may offer a 51% quickbuild for E-AB, and then a 75 or 80% quickbuild as is legal under E-LSA.
So, in a nutshell... this shouldn't be any kind of deal killer for anybody. It isn't for me.

DJ
 
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Mike_ExpressCT said:
Do the Vans employees see this as being a problem? (proving you built 51% of the airplane?) I can understand this being an issue if they do come out with a QB kit, but for the basic kit I can't imagine the FAA or DARS saying the builder did not build the majority...anyone care to chime in on if this would be a problem?
Click to expand...

I can't imagine that the initial "standard" kit will be a problem. But that is JMHO.

I can live with it as an E-LSA... but actually hope to be able to certify it as an E-AB - as I want to do a few things as you mentioned like wig-wag lights and wheel pants. But then again... maybe the S-LSA plane will be certified with those things on it. ;)

DJ
 
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STC Equivalent

Phyrcooler said:
......
I can live with it as an S-LSA... but actually hope to be able to certify it as an E-AB - as I want to do a few things as you mentioned like wig-wag lights and wheel pants. But then again... maybe the S-LSA kit will be certified with those things on it. ;)

DJ
Click to expand...

Dumb question... but do the S-LSA standards have a STC equivalent for third parties to sell "certified" (for want of a better word...) goodies for an existing LSA plane?

I don't recall having seen this aspect addressed...

gil A
 
az_gila said:
Dumb question... but do the S-LSA standards have a STC equivalent for third parties to sell "certified" (for want of a better word...) goodies for an existing LSA plane?

I don't recall having seen this aspect addressed...

gil A
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Short answer...NO! Any mods must be approved in writing from the manufacturer.
 
E-LSA is built from kit. S-LSA is factory built.

E-LSAs are built from a kit. See 21.191(i)(2). It MUST be built exactly like the S-LSA that it was derived from. i.e. same engine, same prop, same instruments, same size tires, etc.
 
Can the builder petition for E-AB?

The way I read the notice is that even though the FAA is suspending adding kits to the 51% list, if the builder can document and convince the DAR that the work done meets the criteria, it can be certified as E-AB - is that correct?
 
Mel said:
That is correct!
Click to expand...


Not that I want to continue beating a dead horse, but as a DAR Mel, what criteria would you look for in a case such as the -12? Total build hours, work done, etc.? Do you foresee a problem with the -12 being seen as a E-AB (And yes, I know that we haven't seen the kit, so that's a tough question...I was just wondering what your initial feelings are).
 
Clarification...

I went back and corrected my posts (shouldn't write so late!). TODR and Mel are obviously correct... Van's will build and get this production RV-12 approved as an S-LSA, and then the kits, if built identical to that plane, qualify as an E-LSA.

Again... I am probably going out on a limb here... but I think that the kit will get approved under E-AB/51% rules when it finally does get reviewed... hopefully in a few months. We MAY find that a quick-build RV-12 may look less complete than the current quick-builds if it qualifies under E-AB. However, as noted... they also can sell a kit that is much MORE complete... up to 99%... but again, you'd have to build it identical to the qualifying S-LSA that Van's builds.

Hopefully I have that all straight now! :)

DJ
 
We have not received any change notice at this time.

Until we get a change notice from FAA we will continue to use form 8000.38.
My annual recurrent meeting with FAA is next Tuesday and Wednesday.
 
Question for Mel...

Worst case scenario... and Van's doesn't qualify the kit as a 51% E-AB before I, or someone else reaches completion...

If we build it to conform to E-SLA (not making any changes)... and then apply for an Airworthiness Cert as an E-AB... there is no risk. If it gets signed off as an E-AB - great, because we have the latitude to make changes (improvements! ;)). If the DAR doesn't approve it, (unlikely I think) we just change lanes and request it to be certed as an E-SLA. Does this make sense and is it workable?

DJ
 
Phyrcooler said:
Worst case scenario... and Van's doesn't qualify the kit as a 51% E-AB before I, or someone else reaches completion...

If we build it to conform to E-SLA (not making any changes)... and then apply for an Airworthiness Cert as an E-AB... there is no risk. If it gets signed off as an E-AB - great, because we have the latitude to make changes (improvements! ;)). If the DAR doesn't approve it, (unlikely I think) we just change lanes and request it to be certed as an E-SLA. Does this make sense and is it workable?

DJ
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This gets into a sticky area. If you apply for an E-AB airworthiness certificate and it is found to "not comply", then the application is supposed to be "denied" for reason and a "letter of denial" sent to the applicant and FAA. Since this scenario hasn't come up, I'm not sure how it would be handled. Bottom line; you are probably right, but I can't say for certain.
I will add this to my list of questions for next week.
 
Phyrcooler said:
I went back and corrected my posts (shouldn't write so late!). TODR and Mel are obviously correct... Van's will build and get this production RV-12 approved as an S-LSA, and then the kits, if built identical to that plane, qualify as an E-LSA.
Click to expand...
Yes, and remember that E-LSA can be 1% or 99% finished by the factory - the "51% rule" does not apply for E-LSA.

TODR
 
Mel said:
Short answer...NO! Any mods must be approved in writing from the manufacturer.
Click to expand...


Mel, since many of the current LSA manufacturers are likely to be out of business in a few years, where does that leave the owners who need to make modifications or repairs? My understanding is there is no "337" type process available in this situation.
 
LSA

The failure of the manufacturer, is addressed in the ASTM standards. Standard F2295 ... Continued Operational ... of LSA,,, paragraph 8 says something to the effect of (Sorry it's a pdf file,, and I can't cut-n-paste,, so paraphasing),, "Should a manufacturer no longer support the LSA product ,,,, the manufacturer should transfer data needed for continued airworthiness support to another manufacturer, type club, user group or other interested party. "
 
E-AB shouldn't be difficult to demonstrate

Mike_ExpressCT said:
Not that I want to continue beating a dead horse, but as a DAR Mel, what criteria would you look for in a case such as the -12? Total build hours, work done, etc.? Do you foresee a problem with the -12 being seen as a E-AB (And yes, I know that we haven't seen the kit, so that's a tough question...I was just wondering what your initial feelings are).
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Remember, the 51% rule is based on the list of activities that need to be done by the builder, not hours, work, etc. If the current QB kits meet that standard, I can't imagine you'd have much difficulty with the RV12 kit.
 
DGlaeser said:
Remember, the 51% rule is based on the list of activities that need to be done by the builder, not hours, work, etc. If the current QB kits meet that standard, I can't imagine you'd have much difficulty with the RV12 kit.
Click to expand...

The potential problem (as Vans sees it) is that the FAA is starting to look at the fabricated parts. Vans example was that if the wing has 32 ribs then the amateur builder would have to form 17 of those ribs. I'm sure that is not how Vans intends on selling the kits. So until we write the FAA and convince them that prefabricating the parts at the kit manufacturer is acceptable I wouldn't count on licensing the 12 as an E-AB.

I don't mind that people start with raw materials and cut and form every part of their plane. But I also think it is just as educational to assemble parts that were fabricated at the factory with expensive production tooling (something the amateur builder cannot afford). Learning how an airplane assembles with all the plumbing, wiring, rigging, etc should be sufficient education to qualify as E-AB. If a pilot gets a basic undestanding of the internal structure, systems and controls in a plane that should be the type of education that will make him a better pilot.

So get out the pen and paper and write the FAA and lets get this resolved so the 12 can be added to the E-AB approved list this year.

Frank
 
According to AVweb:

The FAA may resume ?courtesy inspections? of new homebuilt designs after the Congressman representing the district that is home to Lancair and Epic Aircraft complained that the freeze on inspections could harm the companies. The FAA halted the inspections as part of a review of homebuilt rules ...
Click to expand...

Note that Bend (home of Lancair and Epic) is in Oregon congressional district 2, and I believe Aurora (home of you-know-who) is in district 5. I live in district 1, so not a direct constituent...

--Bill
 
Per an article in AVWEB, congress is putting pressure on the FAA to resume courtesy inspections of kits to see if they comply with the 51% rule. If they do, I'm sure that Van's will try to get the 12 certified to qualify. I plan to build mine as an experimental amateur built even if the kit is not inspected. I strongly believe that the builder will complete the major portion of the plane and qualify for that status. I wrote my letter to the FAA like Van's asked. Did you?
 
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