VansAirForceForums  
Home > VansAirForceForums

-POSTING RULES
-Advertise in here!
- Today's Posts | Insert Pics

Keep VAF Going
Donate methods

Point your
camera app here
to donate fast.


Go Back   VAF Forums > Model Specific > RV-12/RV-12iS
Register FAQ Members List Calendar Search Today's Posts Mark Forums Read

Reply
 
Thread Tools Search this Thread Display Modes
  #1  
Old 02-01-2021, 08:53 AM
bsbarnes10 bsbarnes10 is offline
 
Join Date: Sep 2019
Location: Texas
Posts: 30
Default Phase 1 time - ELSA vs. E-AB

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
__________________
Dues Paid! Thanks for all the help...

Last edited by bsbarnes10 : 02-01-2021 at 08:55 AM. Reason: changed "try to convince" to "politely ask"
Reply With Quote
  #2  
Old 02-01-2021, 09:01 AM
Mel's Avatar
Mel Mel is offline
 
Join Date: Mar 2005
Location: Dallas area
Posts: 10,919
Default

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)
__________________
Mel Asberry, DAR since the last century. Over 1,000 certifications accomplished.
EAA Flight Advisor/Tech Counselor, Friend of the RV-1
Recipient of Tony Bingelis Award and Wright Brothers Master Pilot Award
USAF Vet, High School E-LSA Project Mentor.
RV-6 Flying since 1993 (sold)
<rvmel(at)icloud.com>

Last edited by Mel : 02-01-2021 at 09:08 AM.
Reply With Quote
  #3  
Old 02-01-2021, 10:29 AM
rocketman1988 rocketman1988 is offline
 
Join Date: Jun 2010
Location: Sunman, IN
Posts: 2,344
Default ...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...
__________________
Bob
Aerospace Engineer '88

RV-10
Phase I as of 12-02-2020

Dues+ Paid 2020,...Thanks DR+
Reply With Quote
  #4  
Old 02-01-2021, 11:06 AM
N8DAV8R N8DAV8R is offline
 
Join Date: Apr 2007
Location: Salida, Ca
Posts: 31
Default

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/.../AC_90-116.pdf


Quote:
Originally Posted by bsbarnes10 View Post
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
Reply With Quote
  #5  
Old 02-01-2021, 11:16 AM
Mel's Avatar
Mel Mel is offline
 
Join Date: Mar 2005
Location: Dallas area
Posts: 10,919
Default

Quote:
Originally Posted by rocketman1988 View Post
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.
__________________
Mel Asberry, DAR since the last century. Over 1,000 certifications accomplished.
EAA Flight Advisor/Tech Counselor, Friend of the RV-1
Recipient of Tony Bingelis Award and Wright Brothers Master Pilot Award
USAF Vet, High School E-LSA Project Mentor.
RV-6 Flying since 1993 (sold)
<rvmel(at)icloud.com>
Reply With Quote
  #6  
Old 02-01-2021, 12:25 PM
bsbarnes10 bsbarnes10 is offline
 
Join Date: Sep 2019
Location: Texas
Posts: 30
Default

Quote:
Originally Posted by N8DAV8R View Post
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/.../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
__________________
Dues Paid! Thanks for all the help...
Reply With Quote
  #7  
Old 02-01-2021, 12:37 PM
Mel's Avatar
Mel Mel is offline
 
Join Date: Mar 2005
Location: Dallas area
Posts: 10,919
Default

See post #2. This paragraph is included in the operating limitations issued to ELSA.
__________________
Mel Asberry, DAR since the last century. Over 1,000 certifications accomplished.
EAA Flight Advisor/Tech Counselor, Friend of the RV-1
Recipient of Tony Bingelis Award and Wright Brothers Master Pilot Award
USAF Vet, High School E-LSA Project Mentor.
RV-6 Flying since 1993 (sold)
<rvmel(at)icloud.com>
Reply With Quote
  #8  
Old 02-01-2021, 01:35 PM
Tony_T's Avatar
Tony_T Tony_T is offline
 
Join Date: Dec 2008
Location: Lacey, WA
Posts: 1,381
Default

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?
__________________
Tony
E-LSA RV-12 ULS
SkyView Touch
Reply With Quote
  #9  
Old 02-01-2021, 02:15 PM
Kuhtenia Kuhtenia is offline
 
Join Date: Jan 2018
Location: Galena, Ohio
Posts: 36
Default

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."
__________________
2021 dues paid
RV-6A Driver
Reply With Quote
  #10  
Old 02-01-2021, 02:31 PM
barryrv10 barryrv10 is offline
 
Join Date: Dec 2007
Location: Fl
Posts: 169
Default 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.
Reply With Quote
Reply


Thread Tools Search this Thread
Search this Thread:

Advanced Search
Display Modes

Posting Rules
You may not post new threads
You may not post replies
You may not post attachments
You may not edit your posts

vB code is On
Smilies are On
[IMG] code is On
HTML code is Off
Forum Jump


All times are GMT -6. The time now is 11:16 PM.


The VAFForums come to you courtesy Delta Romeo, LLC. By viewing and participating in them you agree to build your plane using standardized methods and practices and to fly it safely and in accordance with the laws governing the country you are located in.