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RV-12 as Slsa?

M

mitchw62

Member
RV12 SLSA?

We had a retired FAA-type speak at our local EAA meeting today. He said something that I think might be correct but probably impossible.

He said I could purchase an RV-12, assemble and test it with a QA plan IAW the consensus standard, then apply for a Special LSA certificate IAW FAR 21.190. Assume that I am the manufacturer and fulfill the requirements for an SLSA certificate. If its just a matter of paperwork and an airworthiness inspection, this may allow a customer built SLSA and primary flight training in an RV-12. Vans may not sell you his plane with these intentions....

FAR 21.190...
Provide FAA with:
(i) The aircraft's operating instructions;
(ii) The aircraft's maintenance and inspection procedures;
(iii) The manufacturer's statement of compliance
(iv) The aircraft's flight training supplement...

Have the aircraft inspected by the FAA ... for safe operation.

(1) Identify the aircraft by make and model, serial number, class, date of manufacture, and consensus standard used;
(2) State that the aircraft meets the provisions of the identified consensus standard;
(3) State that the aircraft conforms to the manufacturer's design data, using the manufacturer's quality assurance system that meets the identified consensus standard;
(4) State that the manufacturer will make available to any interested person the following documents that meet the identified consensus standard:
(i) The aircraft's operating instructions.
(ii) The aircraft's maintenance and inspection procedures.
(iii) The aircraft's flight training supplement.
(5) State that the manufacturer will monitor and correct safety-of-flight issues through the issuance of safety directives and a continued airworthiness system that meets the identified consensus standard;
(6) State that at the request of the FAA, the manufacturer will provide unrestricted access to its facilities; and
(7) State that the manufacturer, in accordance with a production acceptance test procedure that meets an applicable consensus standard has?
(i) Ground and flight tested the aircraft;
(ii) Found the aircraft performance acceptable; and
(iii) Determined that the aircraft is in a condition for safe operation.
 
First, I doubt that you would be able to find an inspector anywhere who would sign off on such an airplane.
Second, You would probably be sued by Van's (the original designer and manufacturer of the design).
Third, It would not be experimental so "just anyone" could neither maintain or inspect the airplane.
Fourth, No modifications of any kind could be made to the airplane even after certification.
Fifth, Would you be willing to accept the liability involved?
Should I continue?
 
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Continuing....

The biggest hurdle may be Vans not allowing this use of their product.

Inspection would be coordinated with the local FAA MIDO.
Maintenance, Inspection, and alterations would be the same as any SLSA.
I accept a huge liability already....a&p/IA/CFI....

I think the procedure is supported by 14-CFR-21

Mitch - "not dead yet"
 
With in the letter of the law (so to speak) it might be possible but it would be a huge undertaking (totally discounting the possibility of a law suit.

You would have to comply with every section of the consensus standard that applies to fixed wing LSA (see below list).

You would need to develop documented assembly procedures

A quality assurance program

A continued airworthiness program

A production acceptance flight test program

A maintenance manual

A pilots operating handbook

A flight training supplement (An add on to the POH for flight instructors)

Do all of the flight testing (and produce teh supporting documentation) to prove that the airplanes performance and handling quality's conform to the consensus standard.

(and probably a few others I have forgotten).

Note: A person is not required to submit all of the above items with an application for S-LSA certification (only the POH, Maint. Manual, and Flight training supplement are required), but you better have all of it because the FAA is entitled to come for a visit and inspect any of them at any time (with a reasonable advanced notice).

I am assuming that a person could not get away with submitting the documents already produced and submitted by Van's Aircraft, even if you could, a lot ( the majority) of the required documentation is not supplied to a kit purchaser.
 
I think these are interesting questions that have been lurking. I am a Sport Pilot wanting to responsibly test my 12, and meet insurance requirements and FAA Regs. It would be nice to have some (5 hours) experience in the 12 when I start flying. To my knowledge, no one has a letter of deviation permitting training in the 12.

Why do all trainers (over VH 87k) have to be expensive and built in the Czech Republic or China? Is manufacturing a SLSA in the US totally unfeasable because of liability? How do you Know what VANs plans regarding SLSA's are?
Sue, Sue, Sue....

I think the 12's documentation is that of a superb certified aircraft, and whats wrong with someone building an unmodified 12 and using it for training? If Vans doesn't want us doing that, they should put in their license agreement.

Mel, I know there is a RV-12 flying somewhere in Texas. Boy, that narrows it down for me a lot. I guess the only people flying 12s should be 5000 hour pilots with expired medicals.

Maybe Vans could let someone licence as an SLSA so people could fly it and pay for instruction. It could help make the RV-12 fleet much bigger.

John M
 
okiejohn said:
Maybe Vans could let someone license as an SLSA so people could fly it and pay for instruction. It could help make the RV-12 fleet much bigger.
Click to expand...

The most practical way to accomplish this would be for the FAA FSDOs to get on board and issue letters of deviation for training in the ELSA RV-12s. This is the way it is intended. Unfortunately, the the best of my knowledge, none of the FSDOs has done this to date.

Another possible solution would be for Van's to build and sell a limited number of SLSA RV-12s.
 
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I know what you are saying is correct Mel, but it drives me crazy that paperwork is the only thing standing in the way of using the RV-12 for training. A piece of paper makes it okay? I have a hard time getting use to that concept.

Using the -12 (or any E-LSA) for transition training would help the pilots be SAFER pilots. I know the rules are there, and I adher to them, but it makes no sense to me when it comes to making the light sport world a safer place.

Rant off, I'm on vacation! :D
 
Transition training is available in Vans Aircraft's RV-12 N412RV to anyone that contacts Mike Seager and schedules it with him.
 
okiejohn said:
I think the 12's documentation is that of a superb certified aircraft, and whats wrong with someone building an unmodified 12 and using it for training? If Vans doesn't want us doing that, they should put in their license agreement.
Click to expand...

Van's is not preventing anyone from using an RV-12 for training, the FAA is.
Actually any RV-12 can be used for training, you just can't charge for its use (unless it is S-LSA and has had a condition inspection within the previous 100 hours).

Added- there is (was) a provision in the E-LSA operating limitations for operating for compensation or hire

(13) No person may operate this aircraft for compensation or hire, except this aircraft may
be used for compensation or hire to conduct flight training in accordance with § 91.319(e), until
January 31, 2010, at which time this airworthiness certificate and operating limitation expires.

I heard that this provision has been extended beyond Jan 31, 2010 (maybe Mel can comment). Even if it has, I am not sure what teh issues are related to getting another C of A issued if/when it ever does expire. One possibility though. I do agree with others, their should be a way for instructors to get authorization to use an E-LSA for transition training.

I think what some flight instructor should do, is issue a request for deviation authority as specified in FAR 91.319(e), and see what happens.

Paragraph A of FAR91.319 (operating limitation requirements for E-LSA) says...
(a) No person may operate an aircraft that has an experimental certificate--
(1) For other than the purpose for which the certificate was issued; or
(2) Carrying persons or property for compensation or hire.

Paragraph H says...
(h) The FAA may issue deviation authority providing relief from the provisions of paragraph (a) of this section for the purpose of conducting flight training. The FAA will issue this deviation authority as a letter of deviation authority.
 
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rvbuilder2002 said:
I heard that this provision has been extended beyond Jan 31, 2010 (maybe Mel can comment). Even if it has, I am not sure what the issues are related to getting another C of A issued if/when it ever does expire. One possibility though. I do agree with others, their should be a way for instructors to get authorization to use an E-LSA for transition training.

I think what some flight instructor should do, is issue a request for deviation authority as specified in FAR 91.319(e), and see what happens.

Paragraph A of FAR91.319 (operating limitation requirements for E-LSA) says...
(a) No person may operate an aircraft that has an experimental certificate--
(1) For other than the purpose for which the certificate was issued; or
(2) Carrying persons or property for compensation or hire.

Paragraph H says...
(h) The FAA may issue deviation authority providing relief from the provisions of paragraph (a) of this section for the purpose of conducting flight training. The FAA will issue this deviation authority as a letter of deviation authority.
Click to expand...

I just completed my annual DAR seminar and it was stated that the 1/31/2010 deadline has NOT been extended.

I know several instructors have applied for Letters of Deviation for training in ELSAs, but I have not heard of any being issued.
 
Back the original question.

Scott said "(unless it is S-LSA and has had a condition inspection within the previous 100 hours)."

Back the original question. Will FAA allow my company to construct an RV-12 and certify it as an S-LSA so that we can rent it for primary flight instruction? I think yes.

Will Vans allow a company to construct RV-12 (Kits purchased from Vans) and certify as Slsa. Probably not.

Would it be worthwhile? I think it would be a better performer than the PiperSport or the Skycatcher, or technam or other slsa, and likely lower cost and better durability.

mitch
 
mitchw62 said:
Will FAA allow my company to construct an RV-12 and certify it as an S-LSA so that we can rent it for primary flight instruction? I think yes.
Click to expand...

Maybe they would , but you would have to complete all of the work that I posted previously...

You would have to comply with every section of the consensus standard that applies to fixed wing LSA (see below list).
You would need to develop documented assembly procedures
A quality assurance program
A continued airworthiness program
A production acceptance flight test program
A maintenance manual
A pilots operating handbook
A flight training supplement (An add on to the POH for flight instructors)
Do all of the flight testing (and produce teh supporting documentation) to prove that the airplanes performance and handling quality's conform to the consensus standard.
(and probably a few others I have forgotten).

to be able to support your claim that the RV-12 that you are manufacturing meets the consensus standard and that you have all of the other quality control and continued airworthiness (system for owners and mechanics to report service difficulty problems and for you to issue service notices) programs in place.

Just because Van's already did it would not be good enough. The particular company doing the manufacturing would have to have all of it for the RV-12 that they were producing.

So I say that unless a company was willing to do all of this, it is not possible.
If you want a final word, Call Van Stumpner at the LSA regulatory branch of the FAA in Oklahoma City. He will be able to give you the official FAA position. PM me if you want his phone #.
 
Need a Clarification-MY BiAnnual in MY RV-12

Just reading the words as posted by Scott, it would seem I CANNOT receive my next biannual flight exam using my RV-12. Am I interpreting paragraph (a)(2) correctly. I would be paying the CFI for his time at his usual hourly rate.

"Carrying persons for compensation" is where I am getting hung up. Or does some other regulation clarify this.

Can someone comment??

"Paragraph A of FAR91.319 (operating limitation requirements for E-LSA) says...
(a) No person may operate an aircraft that has an experimental certificate--
(1) For other than the purpose for which the certificate was issued; or
(2) Carrying persons or property for compensation or hire."
 
MartySantic said:
Just reading the words as posted by Scott, it would seem I CANNOT receive my next biannual flight exam using my RV-12. Am I interpreting paragraph (a)(2) correctly. I would be paying the CFI for his time at his usual hourly rate.

"Carrying persons for compensation" is where I am getting hung up. Or does some other regulation clarify this.

Can someone comment??

"Paragraph A of FAR91.319 (operating limitation requirements for E-LSA) says...
(a) No person may operate an aircraft that has an experimental certificate--
(1) For other than the purpose for which the certificate was issued; or
(2) Carrying persons or property for compensation or hire."
Click to expand...

Marty,
You would not be carrying him for hire. You would be paying him for giving you instruction. This is totally legal.
The very same operating limitation is issued to E-AB aircraft and people pay instructors all the time.

The thing you can't do with your airplane is rent it to your neighbor by the hour to use for flight training while he also pays a flight instructor to teach him. This then is payment related to the airplane, not the flight instructor.

If you let him use the airplane entirely for free, then he could take flight training in it while still paying an instructor.

Make sense?
 
rvbuilder2002 said:
Marty,
You would not be carrying him for hire. You would be paying him for giving you instruction. This is totally legal.
The very same operating limitation is issued to E-AB aircraft and people pay instructors all the time.

The thing you can't do with your airplane is rent it to your neighbor by the hour to use for flight training while he also pays a flight instructor to teach him. This then is payment related to the airplane, not the flight instructor.

If you let him use the airplane entirely for free, then he could take flight training in it while still paying an instructor.

Make sense?
Click to expand...

THANKS. Makes perfect sense. :)
 
Another small clarification;

mitchw62 said:
Scott said "(unless it is S-LSA and has had a condition inspection within the previous 100 hours)."
Click to expand...

The "100 hr." condition inspection required for commercial operations must be accomplished by a repairman with a "maintenance" rating. The condition inspection performed by a repairman with an "inspection" rating will qualify for an "annual condition inspection" but not for the "100 hr. inspection".

I realize this is backwards from what we are used to in the certified world, but that's the way it is.
 
SLSA is expensive....

RANS S-19LS - Features and Pricing
Base Price: Analog $127,000 / Digital $ 135,000

Cost more than a Skycatcher....
 
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