Op Lim Question (not necessarily RV)

[Auburntsts]

So I'm engaged in a debate over op lims over on AOPA. The catalyst argument was flight into known icing (FIKI) for E-AB certified aircraft. For type certified aircraft this is governed by 14 CFR Part 23.1419. My argument is that an E-AB would have to have in its op lims that FIKI was authorized if properly equipped based upon the following:

Part 91.319 Aircraft having experimental certificates: Operating limitations
(d) Each person operating an aircraft that has an experimental certificate shall?
(2) Operate under VFR, day only, unless otherwise specifically authorized by the Administrator

and
FAA Order 8130.2F Para. 153. (a) Operating limitations must be designed to fit the specific situation encountered. The ASI may impose any additional limitations deemed necessary in the interest of safety. The ASI and/or designee must review each imposed operating limitation with the applicant to ensure that the operating limitations are understood by the applicant.

My logic is based upon what the standard op lims state regarding night and IFR flight unless properly equipped. Is my argument valid or am I in for a huge helping of crow?

[rvbuilder2002]

with your interpretation, but I think this is definitely one of those issues were you would get a different answer with every FAA person you ask.
One thing that is common with any question you ask, that has much room for interpretation, is that the answer will generally be provided leaning towards teh very conservative side (understandably so). My point being, some would say you could not get the approval at all. In the long run this may be the best answer. Certificated aircraft go through quite an extensive flight testing and certification program that is most likely way beyond the capability of any home builder. This is the very reason that many general aviation aircraft are equipped with deicing equipment but few have ever been certified for FIKI. It is just an available option to give you more "options".

[Mel]

It's going to be very difficult to find an inspector that will sign off on FIKI on an experimental aircraft without a "LOT" of engineering data.

[Auburntsts]

Thanks fellas! You get some odd interpretations of things over there sometimes and this one just didn't feel right so I felt obiliged to try and argue the point.

[Ron Lee]

Are you trying to get approval to fly an RV into known icing conditions?

[Auburntsts]

Heck no, I have no desire for FIKI nor for an inadvertant icing system. The question was asked over at AOPA by another poster and the discussion migrated to op lims. My position based upon my interpretation of the CFRs was you couldn't operate into FIKI without some type of approval even as an E-AB and just wanted feedback here and what folks thought. In the end I gave up as I wasn't going to change anyone's mind.