What's new
Van's Air Force

Don't miss anything! Register now for full access to the definitive RV support community.

Updating old operating limitations

00Dan

Well Known Member
Pardon in advance if my search engine skills are lacking here. Is there a documented way of having existing operating limitations updated to the most recent verbiage? My plane has the old version that explicitly defines the test area and requires re-inspection for major changes.

Tangentially, are there any catches I should be aware of before going down this route? Is there anything in the new verbiage that would be more restrictive than what I have now?
 
Any DAR with the proper function code (147 for DAR-T or 57 for DAR=F) can amend you operating limitations. It's strictly a paperwork function. The aircraft must have a current condition inspection.
 
Read the new ops limits before you change...
You'll still need an inspection after major changes.
Ed

Explain Please?.......

The paragraph concerning major changes hasn't changed in over 15 years.
 
Last edited:
Explain Please?.......

The paragraph concerning major changes hasn't changed in over 15 years.

Mel is correct. Unless you have a REALLY old set of operating limitations, there will be no reinspection of the aircraft required after incorporation of a major change. This has been the case since about 2000 or 2001. Might have even been before that.
 
My bad, I guess. The FAA guy did spend a lot of time looking over the entire engine installation in addition to data plate and paperwork...
 
Is a (generic/boilerplate/template) for the EAB op lims currently issued available somewhere?

Peter,

Yes, there is. While it is a bit cantankerous to figure out, the draft operating limitations can be found in appendix D of FAA Order 8130.2J. You can find the order via the FAA website at www.faa.gov.

To find the specific limitations that apply to amateur-built aircraft, look under the "Certification Basis" column for "191". Sometimes a particular limitation will apply to all aircraft certificated under 21.191, and sometimes you'll see a letter behind the 191. If there's a letter, you want to look at 191(g), which is the specific amateur-built paragraph in 21.191.

Yeah, clear as mud, right? But you asked!! This is the official guidance that inspectors (including DARs) use when issuing airworthiness certificates and operating limitations.
 
Peter,

Yes, there is. While it is a bit cantankerous to figure out, the draft operating limitations can be found in appendix D of FAA Order 8130.2J. You can find the order via the FAA website at www.faa.gov.

To find the specific limitations that apply to amateur-built aircraft, look under the "Certification Basis" column for "191". Sometimes a particular limitation will apply to all aircraft certificated under 21.191, and sometimes you'll see a letter behind the 191. If there's a letter, you want to look at 191(g), which is the specific amateur-built paragraph in 21.191.

Yeah, clear as mud, right? But you asked!! This is the official guidance that inspectors (including DARs) use when issuing airworthiness certificates and operating limitations.

Excellent, thank you!

I have older (circa 2009) op lims that prohibit aerobatics and am considering re-doing some testing to have certain maneuvers allowed, but I understand I’ll likely get the full re-write so want to understand what I’m getting into ...
Peter

Edit: Follows clear directions from Joe above, tries to decipher Appendix D of 8130.2J as suggested. Shakes head. So yeah, *that* was unnecessarily complex. But thanks again anyway ... I’ve gained new respect for how DARs and FSDO folks have to do their jobs ...
 
Last edited:
Excellent, thank you!

I have older (circa 2009) op lims that prohibit aerobatics and am considering re-doing some testing to have certain maneuvers allowed, but I understand I’ll likely get the full re-write so want to understand what I’m getting into ...
Peter

Edit: Follows clear directions from Joe above, tries to decipher Appendix D of 8130.2J as suggested. Shakes head. So yeah, *that* was unnecessarily complex. But thanks again anyway ... I’ve gained new respect for how DARs and FSDO folks have to do their jobs ...

You think that’s bad? In the REALLY old days, inspectors just seemed to make up whatever Ops Limits they wanted. I have a copy of the original Ops Lims for the RV-1 (they were re-issued every year because that’s what the rules were at the time - and every year, they were different....). The one I remember best was the last one, which read “Smoking in the cockpit is prohibited while aircraft is in flight”. It was like number 8 - that’s how few there were. But for some reason, it was important enough to the inspector to make it one of the very few limitations. And I don’t even know if Van smoked..... ;)
 
You think that’s bad? In the REALLY old days, inspectors just seemed to make up whatever Ops Limits they wanted. I have a copy of the original Ops Lims for the RV-1 (they were re-issued every year because that’s what the rules were at the time - and every year, they were different....). The one I remember best was the last one, which read “Smoking in the cockpit is prohibited while aircraft is in flight”. It was like number 8 - that’s how few there were. But for some reason, it was important enough to the inspector to make it one of the very few limitations. And I don’t even know if Van smoked..... ;)

But they have since been updated!!!! I know.
 
I have older (circa 2009) op lims that prohibit aerobatics and am considering re-doing some testing to have certain maneuvers allowed, but I understand I’ll likely get the full re-write so want to understand what I’m getting into ...

Peter,

There's not a huge difference between was we were issuing in 2009 and what we issue today. If your operating limitations do not include the paragraph that allows the aircraft to perform aerobatics, then you can have them amended to include the limitation. If your operating limitations DO include the paragraph, but you simply have not tested any maneuvers, you can simply follow the "major change" requirements found in your current limitations in order to add the maneuvers. Either way, it shouldn't be too big a deal for you.

Edit: Follows clear directions from Joe above, tries to decipher Appendix D of 8130.2J as suggested. Shakes head. So yeah, *that* was unnecessarily complex. But thanks again anyway ... I’ve gained new respect for how DARs and FSDO folks have to do their jobs ...

Now that we have the AWC system, the operating limitations are generated automatically, but we still have to go through them to make sure the system didn't miss something, or include something inappropriate. So not much of a benefit from our point of view. Imagine that! :)
 
Has anyone been successful in updating there operating limitations to the latest version? After 6 months of emails and lots of waiting my local FSDO has denied my request. :(
 
Last edited:
Unless you have a REALLY old set of operating limitations, there will be no reinspection of the aircraft required after incorporation of a major change. This has been the case since about 2000 or 2001. Might have even been before that.
Old? Mine are from Sept 1999 - that's not so old is it? Dang. :rolleyes:
Anyway they don't have anything about re-inspection, just that I have to go back into phase 1 for five hrs and log it.
My impression at the time was that they had been pretty well standardized by then.
 
When was the last time someone checked to see if you were operating within your operating limitations? I just found out that the prohibited airspace over Bush 43s ranch only goes to 5,000 msl! I’ll be going over at 12,500 on Sunday
 
Explain Please?.......

The paragraph concerning major changes hasn't changed in over 15 years.

But there has been some change to the nomenclature, right? I think they used to say that after a major mod, you were to notify the FSDO and go back into "Phase I" for a specified test period.
Now isn't the language different so that the testing is still required, but not called "returning to Phase I"?
 
Has anyone been successful in updating there operating limitations to the latest version? After 6 months of emails and lots of waiting my local FSDO has denied my request. :(

I had the Reno FSDO update my op lims last year. IIRC, it only took a few weeks start to finish. The inspector issued a new airworthiness certificate alongside the new op lims.

Here's something many of you may find interesting... my new op lims do not have a requirement to notify tower of the experimental nature of my aircraft.
 
I had the Reno FSDO update my op lims last year. IIRC, it only took a few weeks start to finish. The inspector issued a new airworthiness certificate alongside the new op lims.

Here's something many of you may find interesting... my new op lims do not have a requirement to notify tower of the experimental nature of my aircraft.

BUT......§91.319(d)(3) contains that requirement.
 
I think the FAA has assigned an Identifier for the RV series aircraft for ATC use. My understanding is this then negates the need for the word experimental to be used when communicating with ATC??
https://www.faa.gov/documentLibrary/media/Order/Order_7360.1D_Aircraft_Type_Designators_FINAL.pdf
Way towards the end see page C137

It does NOT! Unless it is removed from the FARs, it is still required.

Remember this requirement is only when taking off or landing at a controlled airport. Not necessary for "en route".
 
I think the FAA has assigned an Identifier for the RV series aircraft for ATC use. My understanding is this then negates the need for the word experimental to be used when communicating with ATC??
https://www.faa.gov/documentLibrary/media/Order/Order_7360.1D_Aircraft_Type_Designators_FINAL.pdf

Way towards the end see page C137

I wouldn't assume that. However it seems to have become pretty common practice to skip the "Experimental", which does seem kind of silly when RVs are more common than many brands of certified A/C.
 
I wouldn't assume that. However it seems to have become pretty common practice to skip the "Experimental", which does seem kind of silly when RVs are more common than many brands of certified A/C.

The regulation has nothing to do with commonality. It has to do with category, and RVs fall within the Experimental category.
 
The regulation has nothing to do with commonality. It has to do with category, and RVs fall within the Experimental category.
Of course - my point is that RVs are common enough that the "Experimental" is pretty much implied, or that's my feeling anyway.
If it even matters, it seems like an archaic reg to me but whatever.
 
The regulation has nothing to do with commonality. It has to do with category, and RVs fall within the Experimental category.

This is such a tempest in a teapot. Use it, don't use it, I don't think there's an ATC specialist in the US who gives a rat's behind about it. They all know what RVs are. And honestly, has any RV pilot been cited for not using the magic words in the last decade or so?

The only possible problem is that controllers might mistake you for "Army" something-or-other (had that happen a few times).
 
Im still working on my ticket so my opinion is not worth much but if I hear a pilot announce "Experimental.... I have no idea if it is an RV, Kitfox, Velocity, Lancair, or ? If they say, RV, Kitfox, or Lancair, I can guess their speed in the pattern or other flight characteristics.

I have no plans to ever fly into class B airport but do go into smaller tower airports. I think I will give the tower guys closes to me a call and see what they prefer. I know a regulation is a regulation but that doesnt make it the best option.

When I do my check ride shortly, I will for sure ask the check pilot what he wants!
 
My plane has the old version that explicitly defines the test area and requires re-inspection for major changes.

When I purchased my plane, the operating limitations were of the previous variety and still listed the original builder's Phase 1 test area. When I had them updated, the FSDO updated the document and changed the area to my local area. Do OL no longer specify the Phase 1 test area?
 
My plane has the old version that explicitly defines the test area and requires re-inspection for major changes. When I purchased my plane, the operating limitations were of the previous variety and still listed the original builder's Phase 1 test area. When I had them updated, the FSDO updated the document and changed the area to my local area. Do OL no longer specify the Phase 1 test area?

Current Operating Limitations still list Phase I flight test area.
 
This is such a tempest in a teapot. Use it, don't use it, I don't think there's an ATC specialist in the US who gives a rat's behind about it. They all know what RVs are. And honestly, has any RV pilot been cited for not using the magic words in the last decade or so?

My experience too. I used to describe myself as “Experimental” but have had both Approach and Tower controllers ask me what kind of “Experimental”. Now I just announce as “RV”. Everybody seems to be OK with that.
 
My experience too. I used to describe myself as “Experimental” but have had both Approach and Tower controllers ask me what kind of “Experimental”. Now I just announce as “RV”. Everybody seems to be OK with that.

The most efficient term would be "Experimental RV". This complies with regulations and tells the controller what kind of speeds to expect.

An exception would be the RV-12 where the term "Experimental Light-Sport" would be appropriate.
 
My impression from the FAR/AIM was that the pilot is only required to inform a tower controller of the experimental nature of the airplane, and not necessarily en route controllers. This language is in the 91.319:

(d) Each person operating an aircraft that has an experimental certificate shall -

(1) Advise each person carried of the experimental nature of the aircraft;

(2) Operate under VFR, day only, unless otherwise specifically authorized by the Administrator; and

(3) Notify the control tower of the experimental nature of the aircraft when operating the aircraft into or out of airports with operating control towers.

In the AIM, reference is made to "omit 'experimental' after initial contact," but it makes no reference to en route vs tower ATC. See here.

Is my understanding incorrect?
 
My impression from the FAR/AIM was that the pilot is only required to inform a tower controller of the experimental nature of the airplane, and not necessarily en route controllers. This language is in the 91.319:
In the AIM, reference is made to "omit 'experimental' after initial contact," but it makes no reference to en route vs tower ATC. See here.
Is my understanding incorrect?

See post #20.

As far as omitting after first contact, I usually follow lead of the tower. If he/she continues use of "Experimental", then I do also.
It is NOT required after initial call-up.
 
Last edited:
The most efficient term would be "Experimental RV". This complies with regulations and tells the controller what kind of speeds to expect.

An exception would be the RV-12 where the term "Experimental Light-Sport" would be appropriate.

Based on the example in the AIM, it appears they suggest the phrase "RV 1234 experimental" (§2/4.a.3 example 2), which conveys all of the information concisely. Not all RVs are experimental as there are a good number of RV-12 SLSAs being used by flight schools. Seems to me, though, as you say it'd be more helpful for ATC to know it's an RV-12 than an RV as the capabilities are significantly different than other RV models. I've always wondered what benefit the "Experimental" is to ATC?
 
Last edited:
Back
Top