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Can a kit-built RV-12 still be a S-LSA

JimMac

Active Member
I am having trouble finding a clear answer to this question. I am building an RV-12 aircraft EXACTLY according to instructions - with no deviations in engine, avionics etc. When I am finished, can it be certificated as a S-LSA just as if I had purchased it as a completely finished aircraft in the first place? I would appreciate any clarification.
 
No. LSA aircraft built by the manufacturer are S-LSA, at least one of which has to be built to allow kits to be produced and sold that can be registered E-LSA provided they are identical copies of the S-LSA original.
 
To my knowledge, no. I can't give you the regulation but that is my understanding.

An RV-12 built exactly per the plans, with no unapproved modifications, may be certificated as an ELSA under 21.191(i)(2). (Experimental Category)

An RV-12 built exactly per the plans, or with modifications, may be certificated as an EAB under 21.191(g). (Experimental Category)

An RV-12 built by a factory under contract from Vans will be certificated as an SLSA under 21.190. (Light Sport Category)
 
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Technicality, but if you build it ELSA, Vans is the builder! That was personally offensive to me, after all that work on my baby, I wanted MY NAME to be on the data plate as builder, not Vans.

If Vans builds it, it is S-LSA.
If anyone else builds it, it is E-LSA or E-AB.
 
Technicality, but if you build it ELSA, Vans is the builder! That was personally offensive to me, after all that work on my baby, I wanted MY NAME to be on the data plate as builder, not Vans.

You'll have to move to Australia Don. CASA doesn't buy that argument. Over here, if you built it, you are the builder whether you certify it ELSA or AB(E). They won't accept `Vans Aircraft Inc.' on the data plate. Only problem with certifying ELSA here is that while you can do maintenance on your pride and joy, you can't sign off the annuals (unless you happen to be a licensed aircraft maintenance engineer (LAME) or similarly qualified). Consequently, hardly anyone here bothers with ELSA. It's more of a restriction than a benefit.
 
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Yeah, it is cute how there are MANY reasons to go either way. As an A&P myself of course that was never even a consideration. From some point of view, I don't agree with who the builder is on an ELSA. Almost fraudulent actually to make it appear Vans built it, instead of the lonely houswife with a pair of pliers and a screwdriver.:D.
You'll have to move to Australia Don. CASA doesn't buy that argument. Over here, if you built it, you are the builder whether you certify it ELSA or AB(E). They won't accept `Vans Aircraft Inc.' on the data plate. Only problem with certifying ELSA here is that while you can do maintenance on your pride and joy, you can't sign off the annuals (unless you happen to be a licensed aircraft maintenance engineer (LAME) or similarly qualified). Consequently, hardly anyone here bothers with ELSA. It's more of a restriction than a benefit.
 
Yeah, it is cute how there are MANY reasons to go either way. As an A&P myself of course that was never even a consideration. From some point of view, I don't agree with who the builder is on an ELSA. Almost fraudulent actually to make it appear Vans built it, instead of the lonely houswife with a pair of pliers and a screwdriver.:D.

Just in case it is not clear, Van's Aircraft Inc is listed on an E-LSA RV-12 as manufacturer because that is what the FAA Order 813o.2G requires (not because they wanted to be).
In simple terms (though it is not quite that simple) the FAA considers an E-LSA RV-12 to be a production line RV-12 that was built remotely in some home builders shop. Because its construction was not done under the quality control process's in place to build an S-LSA airplane, it must be certificated as an E-LSA, but Van's as the manufacturer signifying it is a copy of the previously certificated S-LSA.
 
Because its construction was not done under the quality control process's in place to build an S-LSA airplane, it must be certificated as an E-LSA, but Van's as the manufacturer signifying it is a copy of the previously certificated S-LSA.

Subtle difference then if I understand it correctly. So Vans name on the data plate simply confirms that the remote manufactured E-LSA is a true copy of the factory original, but does not make Van's`the builder' in the normal sense (ie. unlike an S-LSA)? Of course that assurance has to be taken on trust, backed by the actual builder's declaration that what he put together does conform strictly to the plans.
 
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Subtle difference then if I understand it correctly. So Vans name on the data plate simply confirms that the remote manufactured E-LSA is a true copy of the factory original, but does not make Van's`the builder' in the normal sense (ie. unlike an S-LSA)? Of course that assurance has to be taken on trust, backed by the actual builder's declaration that what he put together does conform strictly to the plans.

That's my understanding of it, Robert. That, and the DAR being familiar enough with the design to also verify conformity.
 
That's my understanding of it, Robert. That, and the DAR being familiar enough with the design to also verify conformity.

Still, it's an odd situation isn't it. Once the DAR has signed off, away you go and make whatever alterations you like (presumably documented somewhere), yet somehow it still remains the E-LSA that Vans said it once was. And indeed it can be sold on as such with all the attendant E-LSA privileges for the new owner, even though it may have evolved well away from its S-SLA ancestor. I can't imagine that Vans is altogether comfortable with this arrangement. It would make more sense if the E-LSA builder wasn't allowed to make any subsequent unauthorised changes. At least then there would be a logical separation between E-LSA and EAB instead of the fuzzy boundaries that exist now. You guys in the US have some funny rules. :confused:
 
Nobody ever said that FAA regulations have to make sense!

This crazy rule is why some manufacturers don't offer an ELSA kit.
 
Rob
Having said that, we in Australia seem to have the world champion bureaucracy at making silly rules (I have been dealing with our aviation bureaucracy recently and am getting a headache from banging my head on a wall).
I guess from here in Australia I wish the FAA were in Australia.
John
 
John, maybe we could arrange a swap. I'm sure the aviation community downunder would support moving CASA offshore. If the FAA didn't want to come, we could always ask New Zealand to take them. :)
 
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