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Phase 1 time - ELSA vs. E-AB

bsbarnes10

Active Member
To All,
I have a question for any DARs out there or anyone else who may have come across this issue. I’m building an RV-12iS with my father and we’re opting for the Garmin IFR package and planning to register the plane as E-AB so that it can be operating legally in (light) IFR as my understanding is that ELSAs cannot be operated IFR. However, we are making no deviations from the plans and thus we could just as easily register it ELSA. As I see it, the ONLY difference between registering it ELSA and E-AB will be the pieces of paper I hand to the DAR/FAA representative, there will be no material difference in the aircraft. With this in mind I want to politely ask the DAR/FAA representative to assign the shorter (~5 hour) ELSA Phase 1 time, rather than the typical 40 hour E-AB phase 1 time since our aircraft meets all the requirements for ELSA, we’re just registering it E-AB.

I should note that we both take flying very seriously and do not intend to simply “fly-off” the Phase 1 time, but I do genuinely believe that because we’re not making any changes a shorter Phase 1 is reasonable and that gets us flying it TOGETHER sooner :)

Has anyone attempted this before? Is there anything I’m missing in my logic? (although I realize logic and bureaucratic rules are sometimes mutually exclusive!)

Perhaps some of the DARs could weigh in?


Thanks,
Bruce
 
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If you build the aircraft "EXACTLY" per plans, with NO changes, you may license the aircraft as E-LSA with a Phase I flight test of 5 hrs. minimum. If you deviate from the plans in any way and/or license the aircraft as EAB, the Phase I flight test will have a 40 hr. minimum. The rules are very clear and there are no exceptions. Several similar requests have been made in the past and I've never heard of any exceptions.

E-LSA aircraft MAY be flown IFR. The following paragraph is included in the operating limitations for E-LSA:

20. Instrument flight operations are authorized if the instruments specified in §91.205(d) are installed, operational, compliant with the performance requirements of, and maintained per the applicable regulations. All maintenance or inspection of this equipment must be recorded in the aircraft maintenance records and include the following items: Date, work performed, and name and certificate number of the person returning the aircraft to service. (49)
 
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...but

I know of a guy that just completed an RV-10 and the DAR gave him 25 hours, as he had a "certified engine propeller" combination...

Actually, now that I think about it, it was the FAA that did his A/W inspection...
 
Only vaguely related to your question, mostly just curious, but how far along are you on your build?

As Mel pointed out, you may not have correct understanding of the IFR/IMC limitations for an ELSA 12. To further complicate things, there is potential for the IMC limitation to be removed at some point in the future.

Anyway, another way to possibly accomplish your goal of flying together sooner you may want to look into the APP program.

https://www.faa.gov/documentLibrary/media/Advisory_Circular/AC_90-116.pdf


To All,
I have a question for any DARs out there or anyone else who may have come across this issue. I’m building an RV-12iS with my father and we’re opting for the Garmin IFR package and planning to register the plane as E-AB so that it can be operating legally in (light) IFR as my understanding is that ELSAs cannot be operated IFR. However, we are making no deviations from the plans and thus we could just as easily register it ELSA. As I see it, the ONLY difference between registering it ELSA and E-AB will be the pieces of paper I hand to the DAR/FAA representative, there will be no material difference in the aircraft. With this in mind I want to politely ask the DAR/FAA representative to assign the shorter (~5 hour) ELSA Phase 1 time, rather than the typical 40 hour E-AB phase 1 time since our aircraft meets all the requirements for ELSA, we’re just registering it E-AB.

I should note that we both take flying very seriously and do not intend to simply “fly-off” the Phase 1 time, but I do genuinely believe that because we’re not making any changes a shorter Phase 1 is reasonable and that gets us flying it TOGETHER sooner :)

Has anyone attempted this before? Is there anything I’m missing in my logic? (although I realize logic and bureaucratic rules are sometimes mutually exclusive!)

Perhaps some of the DARs could weigh in?


Thanks,
Bruce
 
I know of a guy that just completed an RV-10 and the DAR gave him 25 hours, as he had a "certified engine propeller" combination...
Actually, now that I think about it, it was the FAA that did his A/W inspection...

This is totally within the regs. I do them quite often. It must be a certified engine/propeller combination.
 
As Mel pointed out, you may not have correct understanding of the IFR/IMC limitations for an ELSA 12. To further complicate things, there is potential for the IMC limitation to be removed at some point in the future.

Anyway, another way to possibly accomplish your goal of flying together sooner you may want to look into the APP program.

https://www.faa.gov/documentLibrary/media/Advisory_Circular/AC_90-116.pdf

I would agree my understanding of the IFR/IMC limitations for ELSA aircraft is limited, primarily because I have not found anything official that clarifies the situation.

What ARE the limitations for IFR/IMC for ELSA aircraft (not for pilots as I am a Private Pilot certificate holder)?

Where are these limitations/conditions documented?

Essentially I want to be sure that as a PPL, I will be able to operate my RV-12iS under IFR rules and in IMC. The only real reason I am even exploring registering it ELSA (aside from the Phase 1 length) is that is may have a positive impact on resale value, as compared to EAB. Ultimately, this will all be discussed with the DAR long before my airworthiness issuance, but I want to have as much solid (not hearsay) information as I can before I start those discussions.

Thank you for the link regarding the APP, I will definitely look into that.

-Bruce
 
See post #2. This paragraph is included in the operating limitations issued to ELSA.
 
All RV-12's E-LSA and S-LSA, including the RV-12iST equipped for IFR, are placarded "FLIGHT INTO IMC PROHIBITED".

The IMC prohibition is a manufacturer limitation and probably due to the ASTM standards governing the aircraft design. So, while IFR flight is permitted under the Operating Limits, flying into IMC is prohibited by a manufacturer limitation.

I guess you could ignore the placard, but it might not be ignored by an insurance investigator.

Do I have this right?
 
Additional background, per Van's (from http://www.flyrv12.com/slsa-ifr-operation-and-training/):

"Operating IFR vs. Operating in IMC - The RV-12iST SLSA is a great platform for meeting both the long cross country requirements and shorter, skills-based instructional flying. Filing IFR and operating/training in the IFR “system” is perfectly fine and is allowed if the airplane is properly equipped and the crew meets the training/certification requirements. By operating under IFR, you are simply participating in the ATC system under the established instrument flight rules. Doing so does not necessarily imply that you are flying the airplane in the clouds.

The current regulations preclude entering actual Instrument Meteorological Conditions (IMC) in any SLSA airplane. While the FAA does not directly/specifically object to it, the ASTM committee’s LSA standard states that the aircraft must be placarded including a statement that flight into IMC is not allowed (but notably makes no exclusions on IFR operations – or operating “in the system” with air traffic control). Because the FAA accepts and adopts the ASTM SLSA rules as written, this becomes a regulatory issue. Conversations between Van’s staff and the FAA this year have confirmed that these restrictions “live” completely in the LSA standard, and that no such restrictions are found directly within the FAA regs. In other words, it is up to the ASTM committee that governs the SLSA standard (called “ASTM F37”) to determine and dictate what is allowed and what is not."
 
E-LSA in IMC

I just went thru this with my DAR; once the E-LSA is certified, it is now an experimental aircraft and the owner can change the POH ( a POH is not legally required) and remove the limitation of no flight in IMC and remove the no flight in IMC placard. Now the operating limitations issued for the aircraft are the rules to fly by and the aircraft can be operated in IMC and in the IFR system. A S-LSA would still have the no flight in IMC limitation unless removed by the manufacture.
 
Additional background, per Van's (from http://www.flyrv12.com/slsa-ifr-operation-and-training/):

"Operating IFR vs. Operating in IMC - The RV-12iST SLSA is a great platform for meeting both the long cross country requirements and shorter, skills-based instructional flying. Filing IFR and operating/training in the IFR “system” is perfectly fine and is allowed if the airplane is properly equipped and the crew meets the training/certification requirements. By operating under IFR, you are simply participating in the ATC system under the established instrument flight rules. Doing so does not necessarily imply that you are flying the airplane in the clouds.

The current regulations preclude entering actual Instrument Meteorological Conditions (IMC) in any SLSA airplane. While the FAA does not directly/specifically object to it, the ASTM committee’s LSA standard states that the aircraft must be placarded including a statement that flight into IMC is not allowed (but notably makes no exclusions on IFR operations – or operating “in the system” with air traffic control). Because the FAA accepts and adopts the ASTM SLSA rules as written, this becomes a regulatory issue. Conversations between Van’s staff and the FAA this year have confirmed that these restrictions “live” completely in the LSA standard, and that no such restrictions are found directly within the FAA regs. In other words, it is up to the ASTM committee that governs the SLSA standard (called “ASTM F37”) to determine and dictate what is allowed and what is not."

That placard and limitation only applies to SLSA aircraft. The placard and limitation is not required for E-LSA aircraft.
 
I notice the wording is different than my 2011 EAB op limits, specifically, the use of the words ‘....compliant with the performance requirements....’
Is this an opening for the use of non-TSO’d gps units under ifr?
 
Mel, I have a question for you about the process for issuing airworthiness certificates and operating limits. You mentioned:

E-LSA aircraft MAY be flown IFR. The following paragraph is included in the operating limitations for E-LSA:

20. Instrument flight operations are authorized if the instruments specified in §91.205(d) are installed, operational, compliant with the performance requirements of, and maintained per the applicable regulations. All maintenance or inspection of this equipment must be recorded in the aircraft maintenance records and include the following items: Date, work performed, and name and certificate number of the person returning the aircraft to service. (49)

Where does that language come from? I'm inferring from your post that there are some generic operating limits for E-LSA (and I'd assume E-AB, E-Exhibition, etc.) which makes sense, I assume DARs like yourself don't just make up the operating limitations for each aircraft on the spot, there must be some bank of "standard" op limits that you pull from? Do you get guidance from the FAA based on the type of airworthiness certificate? Where can lay-folk like myself see them so I know what my DAR / FAA rep is working from?

Thanks to Mel for your response and to everyone else as well. This is my first time through the process (it won't be the last :) so it's been helpful to hear how others dealt with it and what to expect...

-Bruce
 
Operating limitations come from FAA Order 8130.2J Appendix D.

This Order is our Bible for issuing Airworthiness Certificates.
 
ELSA not EAB

If you CAN register ELSA, then do so for this reason.
You, or any subsequent buyer can sign off on the annual inspection by taking a weekend course. EAB, that must forever be signed off by an A&P.
 
Not quite.....

If you CAN register ELSA, then do so for this reason.
You, or any subsequent buyer can sign off on the annual inspection by taking a weekend course. EAB, that must forever be signed off by an A&P.

EAB condition inspection may be signed off by the person holding the repairman certificate for that aircraft regardless of who owns it.
 
Essentially I want to be sure that as a PPL, I will be able to operate my RV-12iS under IFR rules and in IMC.

-Bruce

If you are going to fly IMC, I hope you will have dual screens, a secondary ADAHRS and a heated pitot.
 
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