[gmcjetpilot]

New RV-12iS (experimental) aircraft , Builder/Owner/Pilot needs 5 hours of flight time transition training per insurance, as well as fly the Phase 1 for aircraft required by FAR's.

Can the additional crew member per AC 90-116 who is a CFI give transition training during Phase 1

 

[FlyingDiver]

I plan to get the 5 hours (or more) of transition training before first flight of my airplane. Probably at Lockwood in Sebring.

 

[Amadeus]

I plan to get the 5 hours (or more) of transition training before first flight of my airplane. Probably at Lockwood in Sebring.

Great plan!
How can you determine if something is off during Phase 1 if you haven't actually had the experience in type?
You don't want to be learning when you're also checking your systems.

 

[N8DAV8R]

New RV-12iS (experimental) aircraft , Builder/Owner/Pilot needs 5 hours of flight time transition training per insurance, as well as fly the Phase 1 for aircraft required by FAR's

Here are some questions and my (typical) answers . Correct me if wrong:

Phase (1) flight period, two pilots (both licensed, current in catagory/class) are allowed, for intent of safety during this period ? Yes.​

(Advisory Circular (AC 90-116) assume applies to LSA)​

​

Phase (1) flight period for a LSA-E built exactly to plans is 5 hrs? Yes.​

(Order 8130.2J)​

​

Phase (1) flight period Pilot/Builder/Owner can receive and log transition training (from CFI) during this period? Yes.​

(VAF Ref. https://vansairforce.net/threads/transition-training-during-phase-i.219263/)​

​

Phase (1) flight period typical geographical limitation for a LSA (RV-12) ? 55NM radius.​

(As designated by phase (1) limitations)​

Major differences between LSA-E and Experimental Amateur Built (EAB) aircraft not LSA, is the 5 hours Phase (1) IF LSA IS BUILT exactly per plans. Otherwise it will be the more typical 40 hours Phase (1). Also geographical region for EAB is 75nm radius, vs LSA-E and 55nm radius. These are typical of course, what is actually written in the Phase (1) limitations controls.

With the exception of the first, my answers would be the same as yours. It's also similar to how I kicked things off with my build last year, except that I only had to get 1 hour of dual instead of 5.

As far as the first goes, the formal requirements for two pilots during phase 1 are more complicated than current in category and class. There is a checklist and a scoring system to follow in order to be compliant with the additional pilot program. This is outlined in AC 90-116.

https://www.faa.gov/regulations_policies/advisory_circulars/index.cfm/go/document.information/documentid/1025667

 

[Auburntsts]

Normally transition training occurs before first flight for the reason already noted and also probably for your insurance to be in effect. Otherwise, you're self-insuring for those 5 hours. In addition, if you have a loan the lender probably requires insurance to be in effect before first flight so that might factor into a decision to get transition training before.

 

[Ironflight]

The thing about the 5 hours for E-LSA is that the flights are prescribed with flight test cards/plans. So you can;t just do transition training - you have to fly the prescribed flight plans. Good luck doing that and conducting meaningful transition training. One or the other is going to suffer.

Five hours in the life of the airplane is nothing - I did a neighbor’s RV-12 a few years ago - flew the test program in two consecutive mornings, then took the owner up for his first flight in his airplane (he had previously done transition training, but it had ben a long time before, so he didn’t feel current enough to do the first flight or flight testing). The airplane got tested, he got happy, no limits were pushed…..

 

[N8DAV8R]

The thing about the 5 hours for E-LSA is that the flights are prescribed with flight test cards/plans. So you can;t just do transition training - you have to fly the prescribed flight plans. Good luck doing that and conducting meaningful transition training. One or the other is going to suffer.

Can you clarify what you mean by "have to fly the prescribed flight plans"? This seems to suggest that the test cards are regulatory. I never found anything to suggest that. The log entry per op limitations make no reference to program specifics. Is there somewhere else we should look for this?

“I certify that the prescribed flight test hours have been completed and the aircraft is controllable throughout its normal range of speeds and throughout all maneuvers to be executed, has no hazardous operating characteristics or design features, and is safe for operation. The flight test was completed under the following conditions: maximum operating weight, style/set of wing or sail, maximum demonstrated airspeed, and minimum demonstrated stall speed.”

 

[rvbuilder2002]

The thing about the 5 hours for E-LSA is that the flights are prescribed with flight test cards/plans. So you can;t just do transition training - you have to fly the prescribed flight plans. Good luck doing that and conducting meaningful transition training. One or the other is going to suffer.

Five hours in the life of the airplane is nothing - I did a neighbor’s RV-12 a few years ago - flew the test program in two consecutive mornings, then took the owner up for his first flight in his airplane (he had previously done transition training, but it had ben a long time before, so he didn’t feel current enough to do the first flight or flight testing). The airplane got tested, he got happy, no limits were pushed…..

I’m in total agreement with Paul, And will add a five hours is a minimum, but the requirement for completing phase 1 flight testing, is completing all of the test cards.
It is fairly common that depending on pilot experience, doing the phase 1 testing can’t be completed entirely in just five hours if they are putting effort in to getting accurate results.

 

[N8DAV8R]

I’m in total agreement with Paul, And will add a five hours is a minimum, but the requirement for completing phase 1 flight testing, is completing all of the test cards.
It is fairly common that depending on pilot experience, doing the phase 1 testing can’t be completed entirely in just five hours if they are putting effort in to getting accurate results.

I would ask you the same question, what is the regulatory link for an E-LSA and completing the test cards? I don't mean to be argumentative, and I'm not saying that this is to be taken lightly but this being implied as a legal requirement is interesting to me.

 

[FlyingDiver]

I would ask you the same question, what is the regulatory link for an E-LSA and completing the test cards? I don't mean to be argumentative, and I'm not saying that this is to be taken lightly but this being implied as a legal requirement is interesting to me.

They're documented in the Production Acceptance Procedures (manual VAD-10007) for the RV-12. Which I believe is required to be completed as documented for the E-LSA registration.

 

[N8DAV8R]

They're documented in the Production Acceptance Procedures (manual VAD-10007) for the RV-12. Which I believe is required to be completed as documented for the E-LSA registration.

I understand where the test cards are. I have flown them in the RV-12 that I build. Where to find them is not the question.

The PAP is not required to be completed for "E-LSA registration". That would actually be impossible.

There are clear requirements for the E-LSA during the registration process and they are well understood and related to the supply of kit materials and attesting to completion of the airplane per the KAI. Those requirements must be met for registration, which has to be done before you can get an inspection for airworthiness. The AW cert comes after registration. A flight test logically has to come after registration, inspection, and AW certification. You can't "complete the PAP" before registration.

 

[FlyingDiver]

My bad, I used the wrong term. Do the Op Lims say that Phase 1 must be accomplished per the PAP? I think that's the requirement. Otherwise it would have the 40 hour Phase one requirement.

 

[N8DAV8R]

My bad, I used the wrong term. Do the Op Lims say that Phase 1 must be accomplished per the PAP? I think that's the requirement. Otherwise it would have the 40 hour Phase one requirement.

The operating limitations do not make any reference to a PAP or anything else published by Van's.

 

[jrtens]

I would ask you the same question, what is the regulatory link for an E-LSA and completing the test cards? I don't mean to be argumentative, and I'm not saying that this is to be taken lightly but this being implied as a legal requirement is interesting to me.

Perhaps this is what you are looking for.



From Faa Order 8130.2J chapter 17.

 

[N8DAV8R]

Perhaps this is what you are looking for.

View attachment 62088

From Faa Order 8130.2J chapter 17.

I'm familiar with the order. As with many other regulatory matters the order raises interesting questions but doesn't really seem to clarify anything. We all know that poorly written or referenced regs do happen.

Orders are written as guidance or obligations for FAA personnel, not builders/owners/pilots. While not true for every build, most of us are not FAA personnel. That document is guidance for the DAR/FAA when issuing an AW certificate.

 

[gmcjetpilot]

With the exception of the first, my answers would be the same as yours. It's also similar to how I kicked things off with my build last year, except that I only had to get 1 hour of dual instead of 5.

As far as the first goes, the formal requirements for two pilots during phase 1 are more complicated than current in category and class. There is a checklist and a scoring system to follow in order to be compliant with the additional pilot program. This is outlined in AC 90-116.

https://www.faa.gov/regulations_policies/advisory_circulars/index.cfm/go/document.information/documentid/1025667

AC 90-116 has additional pilot program matrix. Additional Pilot Program (APP) does not mean your buddy in hanger next door is qualified as additional pilot. Matrix to qualify AC 90-116 (see below). Word "additional" I assume applies to ONE additional pilot, not the one flying. assume owner/builder. The matrix has score for time, total time, time in model, hours flown last 12 months, recent t/o and ldgs... The AC says or implies either can be PIC, just decide which pilot is PIC, use CRM. All good. So only ONE has to meet matrix as I read it. If both pilots have to have time in make/model or "model series", the AC is restrictive and almost useless. It would encourage flying solo first flight with no experience vs. with additional crew who is experienced. I do think owner/pilot PIC should not only be qualified but current with recent experience, by all means, just no time in make/model. The additional pilot should have some experience in model or model series (kind of strange wording subject to interpterion). Is RV-6 time in the RV series for RV-10 or RV-12?

The thing about the 5 hours for E-LSA is that the flights are prescribed with flight test cards/plans. So you can;t just do transition training - you have to fly the prescribed flight plans. Good luck doing that and conducting meaningful transition training. One or the other is going to suffer.

Five hours in the life of the airplane is nothing - I did a neighbor’s RV-12 a few years ago - flew the test program in two consecutive mornings, then took the owner up for his first flight in his airplane (he had previously done transition training, but it had ben a long time before, so he didn’t feel current enough to do the first flight or flight testing). The airplane got tested, he got happy, no limits were pushed…..

Let's separate can you and should you, or is it practical or prudent. If an RV-12 builder / pilot has no time it type but is very current and qualified in SEL can fly their new planes Maiden flight. Doubtful they can get insurance. They can do first flight flight solo; they can do all Phase 1, then get dual or not. It is insurance requirement to get training. Would it be better to have an experienced CFI and RV pilot fly with them from first flight? Yes. Finding an experienced instructor, willing to do flight test and training locally.

Insurance drives this 5 or 10 hours of "transition training" not FAR's. You can get dual from a CFI without permission from FAA. RV-12 is a plane and flies like an airplane. Not much unlike the physics that governs a Piper Cherokee for example, that pilot flies and owns now. However there are differences to be sure.

As far as a rigorous flight test cards, those are for Van's RV-12iS production LSA's (not experimental). However they are published and very useful. "RV-12 PRODUCTION ACCEPTANCE PROCEDURES". They are online. No luck needed. Doing these cards IS TRAINING and experience. Very basic standard logical verification of performance and flight characteristics and system functions.

True flight test and training can go in parallel practically and logically logged or not, but it depends on pilot if they can do flight test effectively at all. Should you OR can you log any dual instruction during Phase 1? I do not think their is a definitive restriction in the scenario of Phase 1 with CFI, if you meet all the applicable regulations. EAB or E-LSA has airworthiness, with Phase 1, restricting geographical area of operation and no passengers. An additional pilot is not a passenger but "Min Crew" for Phase 1.

I get your point and someone at the FAA, random inspector may agree with you. But show me where it says this? It may not be right for all pilots. What an individual FAA inspector says at your FSDO overrides, but does not mean they are right. So much that is vague or not defined gets filled in with opinion and becomes the tribal knowledge. That is why I want something in writing. I saw a definitive NO from EAA that said no training during Phase 1 because you must fly SOLO... Ahaaaa. That does not include additional pilot and change in FAR that went from SOLO to min crew. Min crew for flight test can be two... Thee AC 90-116 is not a regulation.

Pilot builder flies Phase 1 with qualified additional pilot who happens to be CFI.... If during the flight testing, the instructor observes and coaches the pilot. That is training and PIC for both pilots. AC 90-116 addresses logging PIC. It does not seem to restrict taking credit for dual given or received or PIC.

Flt test cards, example: stalls, climbs, take off and landings is required for both Phase 1 and training (initial experience, practice). Also let's call TRAINING instead INITIAL OPERATING EXPERIENCE, and is driven or required by Insurance Company, not FAA. Also a E-LSA and EAB in phase 1 still has airworthiness, except geographically limited and limited from carriage of passengers. I do not see any restriction in training. A lot has been written about flight training in E-LSA, EAB and LODA's. Not sure the answer is there?

There is no category/class RV-12 endorsement or type rating. It is a single engine land airplane. There is no official mandatory part 61 or 91 transition training syllabus or endorsement from one SEL airplane to another, certified or experimental, except high performance, complex and Tailwheel.

Show me a FAR that says a builder/owner/pilot can't log any instruction during Phase 1 from qualified CFI. I would love something definitive.

NOTE Your phase 1 FAA-issued operating limitations must note AC 90-116 is allowed during Phase I. Keep in mind AC's are not regulatory unless they are related to a controlling FAR. It is far to say (I think) if the Phase 1 LIMITATIONS states AC 90-116, additional pilot program is allowed during Phase 1, than the AC is regulatory.

 

[N8DAV8R]

My interpretation is close enough to your regarding APP. Both do not need to meet the score in the matrix for 'additional pilot', one does.

To get back to the original question, every situation is a little different but I'll offer mine as one example. I tried very hard to get transition training in an already flying RV-12is with a CFI. This time last year, that was nearly impossible to do. Seager had already told me he was too busy and I needed to go somewhere else and referenced the Van's site. Van's site was outdated info. There are/were very few RV-12s available to train in, and of the ones that were many were down for one maintenance issue or another. Mostly landing gear repair related if I recall correctly. I went all the way from California to Wisconsin in June with plans to fly there but got skunked by the wildfire smoke. Per my insurance, I need 1 single hour of dual but of course I was willing to do more to feel good about it.

My insurance eventually agreed to cover a local high-time part-time CFI with extensive experience with flight testing including other model RVs. He was named insured and covered on the first flight. They stipulated that he needed to get 1 hour in the airplane before giving me the 1 hour that I needed.

He flew the first flight. It was a little over an hour verifying the basic control characteristics including stalls, flap configurations, observing temps, etc. Of course with it being a -12 built by the book there wasn't really any surprises. His requirement to instruct me per insurance was met. We then flew the next hour together doing almost the exact same flight. It was enough to establish that the airplane flew as expected and for me to be comfortable and safe doing takeoffs and landings. From there I completed the test card flights and phase 1 as prudent and required. This worked well, and for this particular airplane it's hard for me to think we did anything unsafe or foolish.

 

[rvbuilder2002]

I would ask you the same question, what is the regulatory link for an E-LSA and completing the test cards? I don't mean to be argumentative, and I'm not saying that this is to be taken lightly but this being implied as a legal requirement is interesting to me.

First off let me say that I admit there are some disconnects when we talk about regulatory details regarding LSA.
The ASTM committee has been working to close those gaps, but for some of it, it has been taking a while.

But technically the biggest issue in this regard is with Experimental amateur built.

E-AB and E-LSA receive the exact same operating limitation "I certify that the prescribed flight test has been completed......

For E-AB, what is the prescribed flight test? It is not testing within the stipulated flight test area for 40 hours. That is the required minimum flight test duration.

But since there was no prescribed flight test, the 40 hrs has been the lowest common denominator reference that has been used.
That has now been at least partially correct with the FAA introducing the task based flight testing program (though they left in place the option of using the old reference of 40 hrs) .

With LSA, the disconnect is that a lot of the regulatory basis is within the Consensus Standard (ASTM's). There are actually only a small number of FAR's that directly regulate LSA. The rest is handled within the ASTM's, which the FAA does require compliance with, by use of the FAR's.

I can't point you the specifics in the ASTM's regarding this discussion, because the are a subscription based document that I no longer have access to since I am no longer employed at Vans.

So where the big disconnect comes from is that Van's is required to meet all ASTM requirements. Producing the PAP document and providing it to E-LSA builders was just one of hundreds.
Van's is required to follow and use a very similar document for every SLSA they produce, and stipulate that an ELSA builder do the same (Though the PAP is a bit different in order to make it easier for a novice airplane inspector and test pilot to follow).
The way this can happen is that the ASTM's mandate (and empower) the manufacturer to regulated certain aspects of the building, operating, inspecting, and maintaining of aircraft it has produced.

Having said all that, the disconnect is that there is nothing in the FAR's (that I can think of at the moment) to regulate an E-LSA builder to follow the PAP other than that the aircraft to be approved as an E-LSA, it must meet all pertinent parts of the consensus standard (which ELSA builders don't have access to).
In simplest terms, if an E-LSA builder wants to do that, they must follow all of the directives of the ELSA kit manufacturer.
Example - To be certified as an E-LSA the aircraft must be built exactly as directed by the manufacturer. This isn't in the FAR's but it is in the ASTM's and Order 8130.2.

 

[Amadeus]

Having said all that, the disconnect is that there is nothing in the FAR's (that I can think of at the moment) to regulate an E-LSA builder

Regardless of whether any regulation encourages or prohibits accomplishing the 5 hour insurance flight training concurrently with doing the 5 hour E-LSA fly-off it is just a bad idea. Is someone really getting the transition training they need when they are busy setting up AOA parameters and autopilot settings, feeling for a heavy wing, etc.? These wonderful examples of an airplane burn 4 gallons an hour of mogas so flying an "extra" 5 hours is what......less than $100 of fuel wherever you may be located. A phrase I hear often is "we fly experimental, we can do whatever we want." So it may be less than optimal to cover both requirements in the same flight but "we fly experimental, do whater you want."

 

[gmcjetpilot]

Regardless of whether any regulation encourages or prohibits accomplishing the 5 hour insurance flight training concurrently with doing the 5 hour E-LSA fly-off it is just a bad idea. Is someone really getting the transition training they need when they are busy setting up AOA parameters and autopilot settings, feeling for a heavy wing, etc.? These wonderful examples of an airplane burn 4 gallons an hour of mogas so flying an "extra" 5 hours is what......less than $100 of fuel wherever you may be located......

I appreciate all you said. Let me assure you. The experienced and current pilot is getting inital operating experience and doing Phase 1. The pilot is flying well after 1.4 hr, 2 flights, 2 landings, slow flight, stall and recovery. Flight check items are being checked off just by flying.

As far as AOA cal, with the APP (additional pilot program), it will be safer than doing it solo. He will finish 5 hrs with me and fly solo 5 hrs before flying a PAX. During that 5 hr solo he is free to gain experience and do more testing and calibrations. This 5 and 5 was a limitation that was imposed, but not by me.

As EAA Tech Conselor before I flew with pilot we spent two hours. I picked up a handful of minor issues that were addressed. Gave 1 hr of logged ground instruction going over the plane, preflight, limitations and paperwork before first flight.

1st flight was by plan short, 0.6hrs. If there was any issue we would have landed immediately. I was able to record data, verification engine and aircraft performance, checked off a lot of items (after flight). Yes I was busy monitoring and recording. Plane performance was exactly the values Vans Aircraft. Flight resulted in 3 minor write ups. I was able to share workload with pilot, CRM, to allow pilot to focus on flying, while I did radio and looked for traffic. Like we do in airlines. This is all good. I gave pilot some tips, called out altitude, heading, airspeed and suggest pitch and power (i.e., instruction). Very organized, routine.

The 1st flight pick-ups were corrected (cowl to exhaust clearance, flaperon to SOB clearance very nicely. Slight, minor left heavy wing (very slight) is not being corrected until flown more, per Van's instructions. Other than that the airplane is well sorted out in prep for flight 2, and the pilot is getting use to plane nicely. NOTE you mention heavy wing as a reason not be get instruction during Phase 1 makes no sense to me. Again they are a full fledged pilot. They are not learning to fly. This "instruction" is not for a rating. If the wing is too heavy we knock it off and land. That was not thee case.

2nd flight 0.8 hours shortened a bit due to weather (isolated CB's) approaching. Autopilot use, stall and stall recovery, 2 landings. Pilot did radio and I gave less tips. It was windy with 8kt cross wind. Taxi with free castering nose wheel is new to him. He is getting the hang of it nicely, but we are focused on this in all phases, taxi, t/o and landing, especially in cross winds. Cross winds is my pet topic and pet peeve. Many pilots are not proficient, and may have never learned proper cross wind takeoff and landing. I am a stickier on this topic.

Continuing with longer flights. I anticipate pilot and plane completing goals, pilot proficient / comfortable, checks and as required adjustments done. However you are never really done adjusting and testing. If we need more time we will take it. No rush. It's going well. This RV-12iS LSA is a good well proven design, built to uniform standards, has been surprise free.

RV-12 has an excellent accident history, and phase 1 and early flights mostly go safely. However there are many that happen in first 8 to 10 hours of aircraft operations, even 1st flight. Even though total fatal accident stats are above average for RV-12, early accidents represents a significant percentage of RV-12 accidents. Always be focused. We are not complacent. Getting training and APP with an experienced safety minded pilot adds safety margins, makes Phase 1 more efficient. This will reduce all accidents especially early accidents. Doing Phase 1 in itself is good training, but getting another set of experienced eyes to observe, guide, critique and instruct is better than trial and error. Thank you everyone for your replies.

PS Also use EAA Tech Counselor Program. An experienced builder, will inspect your work and may have pearls of wisdom and suggestions.

 

[N8DAV8R]

First off let me say that I admit there are some disconnects when we talk about regulatory details regarding LSA.


So where the big disconnect comes from is that Van's is required to meet all ASTM requirements. Producing the PAP document and providing it to E-LSA builders was just one of hundreds.
Van's is required to follow and use a very similar document for every SLSA they produce, and stipulate that an ELSA builder do the same (Though the PAP is a bit different in order to make it easier for a novice airplane inspector and test pilot to follow).
The way this can happen is that the ASTM's mandate (and empower) the manufacturer to regulated certain aspects of the building, operating, inspecting, and maintaining of aircraft it has produced.

Having said all that, the disconnect is that there is nothing in the FAR's (that I can think of at the moment) to regulate an E-LSA builder to follow the PAP other than that the aircraft to be approved as an E-LSA, it must meet all pertinent parts of the consensus standard (which ELSA builders don't have access to).
In simplest terms, if an E-LSA builder wants to do that, they must follow all of the directives of the ELSA kit manufacturer.
Example - To be certified as an E-LSA the aircraft must be built exactly as directed by the manufacturer. This isn't in the FAR's but it is in the ASTM's and Order 8130.2.

Here's the problem I see with this explanation in the context of the PAP and questions raised in this thread. It's not true that Van's even stipulates that an ELSA builder follows the PAP. For whatever reason, they excepted that out of the documents in the one place where there could have been a connection made. I can't help but think that was intentional, and not an accident.

To register my RV-12is I had to submit an 8130-15 along with the other paperwork, and had to attest with signature that I followed those guidelines. The 8130-15 is a document that is completed and provided by Van's and has Rian's wet signature. That document lists the ASTM standards and mfr documentation that is in support of all of the requirements for the E-LSA compliance.

The box on the form provided to me show's "N/A" where the PAP would have been mentioned. The PAP is not among the directives stipulated by the manufacturer in the case of the RV-12is.

 

[rvbuilder2002]

Here's the problem I see with this explanation in the context of the PAP and questions raised in this thread. It's not true that Van's even stipulates that an ELSA builder follows the PAP. For whatever reason, they excepted that out of the documents in the one place where there could have been a connection made. I can't help but think that was intentional, and not an accident.

To register my RV-12is I had to submit an 8130-15 along with the other paperwork, and had to attest with signature that I followed those guidelines. The 8130-15 is a document that is completed and provided by Van's and has Rian's wet signature. That document lists the ASTM standards and mfr documentation that is in support of all of the requirements for the E-LSA compliance.

The box on the form provided to me show's "N/A" where the PAP would have been mentioned. The PAP is not among the directives stipulated by the manufacturer in the case of the RV-12is.

This Form 8130-15 was not filled out correctly.
I have just communicated with Rian and he is going to look into it and make sure it doesn’t happen in the future.