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New N number

texdog

Well Known Member
The FAA issued new operation limitations for my RV6A that has been flying for 10 years. I requested and received permission for the new N number, they limited me to day VFR, before it was day, night VFR and IFR. also 40 hours of flying, like it was a new certification, limited to my local area. They informed me that any airplane that moves to a different FSDO area from initial certification must have new operation limitations. This has been going on since January and isn?t fixed yet. Any ideas would be appreciated. The FAA says every experimental that moves from initial flight test area has to have new operation limitations issued. Thank you.
 
I would be checking Regs.

The N number has nothing to do with op limits.

This does not sound right.

Someone with first hand knowledge will jump in
This thread and help you out.
 
I would be checking Regs.

The N number has nothing to do with op limits.

This does not sound right.

Someone with first hand knowledge will jump in
This thread and help you out.
Unfortunately with experimental aircraft if you change the N number you also have to update the Airworthiness Certificate, which includes the the Op limits, to reflect the new N number. I went through this back in 2007 when I changed the N number of my airplane and had to "update" both the AW and Op Lim.

Note I said "update" not "new". If you request a "new" Op Lim, then everything gets reset as if it never had an AW and the FSDO can issue whatever they see fit. I got lucky because the FSDO inspector I dealt with explained this to me before I changed the N Number. I made sure I requested an "update" to the AW and not a "new" one. It was still a big PITA. The AW and Op Lim request had to be made after the N number change had been completed so my airplane was grounded for several weeks just waiting paperwork.

:cool:
 
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"N" number change requires new Airworthiness Certificate an Operating Limitations. If the location of the aircraft has moved, it is highly recommended that you change the Phase I flight test location at the same time.
New Phase I testing is not required unless there has been a major change to the aircraft.
I've done many of these.
 
Different FSDO

Mel,

Are you able to do update the Op Spec's for an aircraft that has a new AW certificate because of new N number and updated Phase 1 area that is located in a different FSDO area than yours?
 
Could you please verify it doesn't say something along the lines of "This aircraft is to be operated under VFR, day only, unless appropriately equipped for night and/or instrument flight".

If so, you're still legal for night/IFR as long as you're appropriately equipped. Even though the first line says VFR, day only.
 
They informed me that any airplane that moves to a different FSDO area from initial certification must have new operation limitations.
Can someone confirm if this is accurate? Or only in the case of application for new N-number at the same time? My plane that I purchased in December has had a couple of moves from its original FSDO area and no new op limits issued.
 
I got updated ops limits a few months ago to include ifr and it was extremely painless. Sent in my old ones and received new ones a week later from the Birmingham FSDO
 
Can someone confirm if this is accurate? Or only in the case of application for new N-number at the same time? My plane that I purchased in December has had a couple of moves from its original FSDO area and no new op limits issued.

That's nonsense. Unless you live in that guy's FSDO area, I guess...

I've bought and sold several homebuilts across FSDO lines, and never had to deal with any of that. You *do* have to get approval for a new test area if you do a major mod, but on the most recent version of oplims I have (issued shortly after 911), new approval of test area is required for every new major mod even if the paperwork was issued locally. Oplims I got prior to 911 allowed simple logbook entries to go into and out of phase 1.
 
It sure seems to me that Ops Limits should apply to a specific AIRFRAME according to serial number, not registration number. I?ve always viewed a reigistration number like a license plate on a car.

Funny that all this is coming up now because the buyer of my Midget Mustang is dealing with it now and I may end up helping facilitate a solution. I changed the N number on the MM over a decade ago. A local DAR issued a new airworthiness Certificate with the new N number, but not new Ops Limits. I didn?t need a new test area because the old one still worked...

Now, 2 months after I sold the plane, the buyer is running into bureaucratic trouble and contacted me for help. I called the DAR from 10 years ago and he says the Ops Limita are still good because they belong to a serial number not a registration number.

Does a Gulfstream have to go back to the factory for a conformity check when a new owner gets a vanity N Number?

If this is an issue, it sure seems like something the EAA should be involved in.
 
It sure seems to me that Ops Limits should apply to a specific AIRFRAME according to serial number, not registration number. I?ve always viewed a reigistration number like a license plate on a car.
Funny that all this is coming up now because the buyer of my Midget Mustang is dealing with it now and I may end up helping facilitate a solution. I changed the N number on the MM over a decade ago. A local DAR issued a new airworthiness Certificate with the new N number, but not new Ops Limits. I didn?t need a new test area because the old one still worked...
Now, 2 months after I sold the plane, the buyer is running into bureaucratic trouble and contacted me for help. I called the DAR from 10 years ago and he says the Ops Limita are still good because they belong to a serial number not a registration number.
Does a Gulfstream have to go back to the factory for a conformity check when a new owner gets a vanity N Number?
If this is an issue, it sure seems like something the EAA should be involved in.

The operating limitations list the "N" number in the heading along with the serial number. Therefore new op lims are required with a change of "N" number.
 
Typical government nonsense

All of this just sounds typical government bureaucratic nonsense that serves no purpose....other than trying to justify someone?s job.😏
 
The operating limitations list the "N" number in the heading along with the serial number. Therefore new op lims are required with a change of "N" number.

Is there regulatory guidance to support this statement? If the DAR also lists that my plane is RED, do I need new Ops Limits for a change of color?

If I report my plane as stolen, is it considered recovered if they seize a Cessna 210 in Del Rio with my N number painted on the fuselage? Does that 210 need new Ops Limits because it now lives in a new FSDO region and has the N number of a homebuilt painted on the fuselage?
 
The FAA issued new operation limitations for my RV6A that has been flying for 10 years. I requested and received permission for the new N number, they limited me to day VFR, before it was day, night VFR and IFR. also 40 hours of flying, like it was a new certification, limited to my local area.

Somebody didn't know what the heck they were doing! As Mel has mentioned, an N number change does require issuance of a new airworthiness certificate. And since the operating limitations are a part of the airworthiness certificate, they need to be reissued to reflect the new N number as well. And yes, the new operating limitations will contain a description of a flight test area. But since this particular aircraft has already been tested and that test (hopefully) has been properly recorded in the aircraft records, there is no need to redo the flight testing.


They informed me that any airplane that moves to a different FSDO area from initial certification must have new operation limitations.

Poppycock! There is no regulation or policy that requires this. The inspector(s) you talked to may be confusing the requirement for experimental EXHIBITION aircraft to file a new program letter with the FSDO if it changes its home base. And even in that case, there is no requirement to issue new operating limitations.

This has been going on since January and isn?t fixed yet. Any ideas would be appreciated. The FAA says every experimental that moves from initial flight test area has to have new operation limitations issued.

I strongly suggest that you call us here at EAA so we can help educate the inspector(s) you are working with. They are way off base with this. The main person you would talk to here at EAA would be Tom Charpentier. His direct phone number is 920-426-6124. Or you can call me and I can conference Tom in. My direct number is 920-426-6145. Or email me at [email protected] and I can get the ball rolling for you.
 
Is there regulatory guidance to support this statement? FAA Order 8130.2j Chapter 15 If the DAR also lists that my plane is RED, do I need new Ops Limits for a change of color? Color is not listed in the op lims

If I report my plane as stolen, is it considered recovered if they seize a Cessna 210 in Del Rio with my N number painted on the fuselage? Does that 210 need new Ops Limits because it now lives in a new FSDO region and has the N number of a homebuilt painted on the fuselage? Certified aircraft do not have operating limitations like amateur-built aircraft

EAB operating limitations do not have to be changed when moved to a new location. It is just a recommendation that you change the Phase I location if you are updating you op lims anyway, such as a new "N" number.
 
I just read Chapter 15 of 8130.2j in its entirety.

It says nothing supporting your assertion that new operating limitations must be issued based on a change of N number. Can you point to a specific paragraph or section that I?m missing?

I hate to be argumentative here, but aviation is full of rules that are promulgated by tribal knowledge and accepted because trustworthy and well respected (deservedly so) people just keep repeating them.

I?m a rule follower like most people on this site, but I?m not anxious to follow extra rules that don?t really exist.
 
I just read Chapter 15 of 8130.2j in its entirety.
It says nothing supporting your assertion that new operating limitations must be issued based on a change of N number. Can you point to a specific paragraph or section that I?m missing?
I hate to be argumentative here, but aviation is full of rules that are promulgated by tribal knowledge and accepted because trustworthy and well respected (deservedly so) people just keep repeating them.
I?m a rule follower like most people on this site, but I?m not anxious to follow extra rules that don?t really exist.

Aircraft inspectors have a "job aid" from the FAA that lays out the format for operating limitations. That format includes the "N" number, Make, Model, and Serial Number of the aircraft along with the Date of Issuance. If you have changed the "N" number and not the op lims the op lims will not match the Airworthiness Certificate. The inspector issuing new A/W Certificate should automatically issue op lims that match the new "N" number.
 
Clarification

The old 8130-7 pink slips are still ok to use but the govt isn?t buying anymore.instead, a single document that includes the new printed 8130-7 and operating limitations are current way you get your documents. Each lists the make,model, and serial number as well as the N number.

Vern
 
It says nothing supporting your assertion that new operating limitations must be issued based on a change of N number. Can you point to a specific paragraph or section that I’m missing?

You are correct that there is nothing in the guidance that specifically states that the operating limitations need to be reissued due to an N number change. However, the operating limitations themselves contain the following statement:

These operating limitations are a part of FAA Form 8130-7 and are to be carried in the aircraft at all times and to be available to the pilot in command of the aircraft.

FAA Form 8130-7 is the special airworthiness certificate. The operating limitations are considered by the FAA to be a a part of the airworthiness certificate, not a separate document. As such, ALL identifying data (N number, builder name, aircraft model, and aircraft serial number) MUST match exactly on all documents. If you change the N number, the airworthiness certificate must be changed to reflect the new N number. And since the operating limitations are A PART of the airworthiness certificate, they must be updated to reflect the new N number just like the 8130-7 itself. If you have one N number on the 8130-7 and a different one on the operating limitations, you are not legal.

New new "all in one" document that is being issued by most FAA inspectors and DARs these days solve this problem because there isn't a separate airworthiness certificate and operating limitations. It's all one physical document, so changing the N number automatically changes the whole works.

I hope this clears up the situation for you.
 
Joe and Mel are correct. I emailed the inspector and he confirmed that I?m legal for day, night, VFR and IFR. He apologized for the confusion. They are all new airworthiness and limitations emailed.

Thanks everyone for your help.
 
Last year I bought an aircraft that was built in Houston, TX area. It was then sold to a pilot in Georgia and I bought it from him.

I got a new A/W with new Operating Limitations when I changed my N number here at the North Dallas FSDO. They gave me new Op Limits but that paperwork says that if I do any major change I have to fly 5 hours as per the local FSDO so even though it still mentions Phase 1 having to be flown in Houston, if I ever need to fly due to a major modification I have to get a new test area where I live.

So even if they give you new Ops Limits, once you have flown Phase 1 you're done, no need to fly them again.

Having said that like in all professions there are good employees and there are bad employees. On the 29th I have an appointment with the same FSDO to go get my new A/W and new Op Limits for my RV-8 so we'll see how that turns out.
 
Joe and Mel are correct. I emailed the inspector and he confirmed that I?m legal for day, night, VFR and IFR. He apologized for the confusion. They are all new airworthiness and limitations emailed.

Cool beans! Glad you got things ironed out. Fly safely!!
 
Interesting. Just went through this last month. Had to make an appointment at the FSDO to trade my old Special Airworthiness Certificate for a new one reflecting the new N number. I asked about new operating limitations, but was told to attach the new certificate to my old operating limitations.

The new certificate states (in part):
OPERATING LIMITATIONS REMAIN THE SAME AS PREVIOUSLY ISSUED LIMITATIONS DATED JULY 1, 2008 WITH THE ONLY CHANGE BEING THE REGISTRATION NUMBER (PREVIOUS NUMBER N328SL). THIS CERTIFICATE MUST BE ATTACHED TO ORIGINALLY ISSUED OPERATING LIMITATIONS.

Cheers, David
RV-6A KBTF
 
Interesting. Just went through this last month. Had to make an appointment at the FSDO to trade my old Special Airworthiness Certificate for a new one reflecting the new N number. I asked about new operating limitations, but was told to attach the new certificate to my old operating limitations.

The new certificate states (in part):
OPERATING LIMITATIONS REMAIN THE SAME AS PREVIOUSLY ISSUED LIMITATIONS DATED JULY 1, 2008 WITH THE ONLY CHANGE BEING THE REGISTRATION NUMBER (PREVIOUS NUMBER N328SL). THIS CERTIFICATE MUST BE ATTACHED TO ORIGINALLY ISSUED OPERATING LIMITATIONS.

Cheers, David
RV-6A KBTF

Did they give you a pink AW Certificate or a regular printer paper one?
 
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