RV-3, RV-4, RV-9 as LSA?

[Tony Spicer]

Two years ago when I was starting my RV-3, I wondered if it would be possible for it to be LSA compliant. So I asked EAA. Their response from November 2005 follows:

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"Since you are the builder of the aircraft you determine the gross weight, etc. and if operating as a sport pilot, you are responsible for flying only aircraft which qualify as an LSA.

The FAA preamble states:

"The FAA notes that compliance with light-sport aircraft parameters can be more readily verified for type-certificated aircraft than for amateur-built aircraft certificated under existing ?21.191 (g). Amateur-built aircraft do not have a TC, a flight manual, or a type certificate data sheet. Because of this, it may be difficult to determine if aircraft with other than a standard airworthiness certificate meet the limits listed for a light-sport aircraft and can be operated by a sport pilot. The FAA anticipates that the aircraft design consensus standard will include methodologies that will readily enable a determination that an aircraft design meets the light-sport aircraft definition."

The ASTM standards have addressed the FAA's preamble language. The ASTM standards clearly define what V sub H is in 3.2.32. The Committee felt and the FAA agreed that there was nothing more to say, fly the aircraft with maximum continues power in level flight record the speed and correct for standard day the answer is the answer nothing more needs to be defined.

The ASTM standard also includes 4.3.1 which states:
Maximum RPM shall not be exceeded with full throttle during takeoff, climb, or flight at 0.9 V H, and 110 % maximum continuous RPM shall not be exceeded during a glide at V NE with throttle closed.

So the above is one way to prove that your aircraft is an LSA which is acceptable to the FAA. Can you establish Vh some other way? I would say yes for an amateur built but I would definitely document it as part of my flight testing program.

Practical considerations are that the burden of proof will be on you to establish that an RV-3 meets the definition. A knowledgeable FAA Inspector who "knows" that an RV-3 doesn't fit LSA will violate you first and then let you prove that it is in compliance. If the FAA has nothing else to go on, they will no doubt revert to the engine manufacturer's documentation, which will have a specific maximum continuous power rating (which definitely won't be 55% power!). For example, Lycoming calls out a maximum continuous rated power and RPM for the O-320-A2B of 150 hp and 2700 rpm. It would be pretty tough to convince an FAA inspector that the Lycoming engine in your homebuilt (even if it's modified in some way) has a substantially different maximum continuous power rating than what's on the TC. Van's probably will give you no support since they do not view it as LSA eligible.

Also, I would guess that you could also run into some insurance problems as they will use readily available reference material to determine what they will insure for sport pilot operations."

Tony Spicer (just the messenger)

[Pirkka]

Few issues back in the RVator there was some notes from Van's aircraft for making RV-9(a) LSA. You better read it. And if I recall this has been discussed as well here in the forum some time ago -- not recently.

What comes to maximum continuous power -- I haven't seen that it would be restricted. Only maximum cruise speed has limit with full power. It ain't too hard to put limiter which limits your throttle like 75 % of maximum to meet this rules... or have a suitable propeller with proper pitch.

[pierre smith]

Tony,
A guy in Florida has a -9 licensed as an LSA. Check this thread from earlier this year.

http://www.vansairforce.com/communit...hlight=rv9+lsa

Regards,

[Geico266]

Originally Posted by pierre smith

Tony,
A guy in Florida has a -9 licensed as an LSA. Check this thread from earlier this year.

http://www.vansairforce.com/communit...hlight=rv9+lsa

Regards,

That is simply amazing, and the best chioce for LSA I can think of. I have heard there are now 3 RV9's flying as LSA.

[rvbuilder2002]

Originally Posted by Geico266

That is simply amazing, and the best chioce for LSA I can think of. I have heard there are now 3 RV9's flying as LSA.

Actually... the amazing part, is that the rule to allow an aircraft to be licensed as E(xperimental)-LSA, requires that an S-LSA example has already been previously certified. Van's Aircraft (or anyone else) has never certificated an RV-9 as an S-LSA so these three RV-9's should never have received E-LSA certificates.

[Mel]

Under 21.191(i)(1) until 1/31/2008, an aircraft may be be certified as E-LSA as an existing aircraft without such documentation. This rule covers the overweight, over seated, too fast ultralights. However, the applicant must show that the aircraft meets LSA parameters. And no one as yet has satisfactorily proven these parameters to me concerning any RV.

[rvbuilder2002]

Originally Posted by Mel

Under 21.191(i)(1) until 1/31/2008, an aircraft may be be certified as E-LSA as an existing aircraft without such documentation. This rule covers the overweight, over seated, too fast ultralights. However, the applicant must show that the aircraft meets LSA parameters. And no one as yet has satisfactorily proven these parameters to me concerning any RV.

Of course your right Mel. I forgot that they can have been certified under the consenses standard with 21.191(i)(1) until Jan 31, 2008.

I do agree with your position...regardless of how the were certified, they probably should not have been.

[13brv3]

Greetings,

I've been trying to decide what to build next, and have been looking at sport pilot type designs. Unfortunately, I just don't find them all that interesting, mostly because they all seem about the same to me.

The more I think about it, the more I think the RV-3 could be made into a Sport Pilot compliant aircraft fairly easily. The speed is really the only problem, and that's easily limited. I just wondered if I was the only one who was thinking about this?

Cheers,
Rusty

[13brv3]

Originally Posted by Tony Spicer

Rusty,
Nope, you're not the only one that thought of doing that. But you must have missed this post:

http://www.vansairforce.com/communit...37&postcount=1

Tony

Hi Tony,

I haven't been hanging around the RV forum too much, so you're right, I didn't see that post. Sounds like the only potential problem is with engine manufacturers continuous power specs. Fortunately, I'll be the engine manufacturer, so I don't anticipate any problems

I also haven't read any of your build threads. When do you think you'll be flying?

Rusty

[Tony Spicer]

Originally Posted by 13brv3

Hi Tony,

I haven't been hanging around the RV forum too much, so you're right, I didn't see that post. Sounds like the only potential problem is with engine manufacturers continuous power specs. Fortunately, I'll be the engine manufacturer, so I don't anticipate any problems

I also haven't read any of your build threads. When do you think you'll be flying?

Rusty

Rusty,

In the short rows. Should be ready for the first engine start tomorrow, then a few more days on the spinner, then a call to the FAA.

http://picasaweb.google.com/tonyboyt...17785795216914

Tony