DEWATSON

Well Known Member
Have any of you been told by the FAA to provide a "program letter" describing the territory where you intend to fly your RV once it is airworthy?

Thanks for any and every response on this one.

David Watson
49FD
 
A program letter is usually part of the package that a builder submits to the FAA when requesting an Airworthiness inspection, along with the 8130-6. In the program letter there is space provided to define the requested test area. Some parts of the country already have defined areas from certain airports, and it can not be changed. Others are more flexible, and we can usually work with the builder on a test area that is convenient for them and at the same time mindful of the need to stay away from congested areas and cerain classes of airspace during phase I testing.

Vic
 
I had to fill out the program letter as part of the airworthiness application. It does ask for area under which Phase 1 testing will take place. I had to draw it on a sectional map also
 
letter

after you do phase one and now are in phase 2 are you required to submitt a letter to the faa asking permission to fly in differnt parts of the country i heard of a faa insp saying it was required to be on file for phase 2 and if your ramped checked its required to be on board that you have permission to fly to that location is that true
 
This is interesting to me. I did the program letter for my inspection and the inspector was very lenient with me and allowed the phase I test area that I asked for. BUT, he said that I have to have an approved program letter on board the airplane along with the airworthiness certficate and registration for phase II. He said that the FAA will usually comply to the program letter request for phase II, but it should be on board the airplane and filed with the FAA in case I am ramp checked in, let's say, Idaho. He said that the normal area for phase II flying is about a 300 mile radius from my home airport in north Florida.

I certainly don't want to stir anything up because the inspector was a very considerate and polite man. My wife and I made a friend forever...he was just such a genuine and friendly fellow. I'm sure I understood him to tell me what I've quoted here. It was news to me and I just want to see if anybody else has ever been told this.
 
No such letter is needed.

The requirement for a letter in Phase II is not required. Once you complete Phase I you can operate like any other airplane, both nationally and internationally, as long as you comply with the pertinent rules, i.e., night, IFR/IMC, international requirments for the specific country, etc. You do need to carry your Phase II limitations with you at all times. I don't know where this is coming from unless someone is mixing it up with Experimental EXHIBITION. These usually require a letter with a stated area, which is usually a defined readiius from the home airport for proficiency flights.

Vic
 
. . .You do need to carry your Phase II limitations with you at all times. . . Vic
Vic,
You just confused me with this statement. Is this a typo? Did you mean to say "You do NOT need to carry. . ."? If you did mean it the way you stated it originally that would seem to conflict with the concept of being able to fly our airplanes like any other certificated airplane.

Just trying to clear this up in my mind.
 
Vic,

Please clarify Steve's question. It confused me too.

The FAA inspector told me that the program letter approved by the FAA for phase II flying should be kept in the airplane and that it was required. I think I need to get back in touch with him and get his take on this again. Both I and my wife had him explain his comments to us twice and I'm sure of what he told me. Our conversation about this letter went on for about five minutes. I told him that I had intentions of flying the airplane to Osh Kosh when I was in phase II. He said that if I was ramp checked at Osh Kosh and did not have the letter on board, I would be out of compliance. I told him to expect a letter from me for phase II requesting approval that will cover the entire USA. He said that it was no problem, just get the letter approved and have it on board at all times.
 
Vic,
You just confused me with this statement. Is this a typo? Did you mean to say "You do NOT need to carry. . ."?
The Operating Limitations are part of the airworthiness certificate. If they are not on board during phase 2 operations , the airworthiness certificate is meaningless e.g. same effrect as not having the .airworthiness certificate on board.
 
You MUST carry your limitations at all times!

Dave got it right, and it is exactly what I did say: YOU MUST CARRY YOUR OPERATING LIMITATIONS IN YOUR AIRPLANE AT ALL TIMES. It explicitly states that the limitations are a part of the airworthiness certificate right on your airworthiness certificate. No limitations on board, and the aircraft is not airworthy.
It's pretty simple.
Please don't hesitate to call if I can be of any help.

Vic
 
Dave got it right, and it is exactly what I did say: YOU MUST CARRY YOUR OPERATING LIMITATIONS IN YOUR AIRPLANE AT ALL TIMES. It explicitly states that the limitations are a part of the airworthiness certificate right on your airworthiness certificate. No limitations on board, and the aircraft is not airworthy.
It's pretty simple.
Please don't hesitate to call if I can be of any help.

Vic
Ok, thanks for clearing that up. Another question though. What limitations exist in Phase II that would be on this document? I guess I have thought that just having a document stating that the aircraft had completed Phase I testing was the document that allowed the aircraft to be operated in Phase II flight.

Reading this thread makes me wonder. I have the airworthiness certificate in the plane and I have a document stating it has met the Phase I requirements but perhaps I do not have everything I need.

Can you direct me to information on what the actual Phase II "Limitations" need to say? It looks like I have missed something in my study of documentations needed.
 
Vic,

Please clarify Steve's question. It confused me too.

The FAA inspector told me that the program letter approved by the FAA for phase II flying should be kept in the airplane and that it was required. I think I need to get back in touch with him and get his take on this again. Both I and my wife had him explain his comments to us twice and I'm sure of what he told me. Our conversation about this letter went on for about five minutes. I told him that I had intentions of flying the airplane to Osh Kosh when I was in phase II. He said that if I was ramp checked at Osh Kosh and did not have the letter on board, I would be out of compliance. I told him to expect a letter from me for phase II requesting approval that will cover the entire USA. He said that it was no problem, just get the letter approved and have it on board at all times.

Heck, just ask for the whole world. Maybe use one of those blow-up globes, and then deflate it and stuff it into a pocket in the plane.

I've never seen any such "limitation" in a certificated plane...
 
OK.....I didn't mean to cause a stir.

I think the inspector should have used the words "phase II limitations" rather than "FAA approved program letter". I'm convinced now that the phase II limitations is what he was referring to.

Happy and safe flying.
 
I've never seen any such "limitation" in a certificated plane...
Those limitations are not applicable to certified aircraft just are phase 1 and phase 2 testing are not. Certified operating limitations are usually contained in the POH (which as I understand it, but may be wrong, are required to be on board experimental aircraft also...).
 
So as a part of an EAB Operating Limitations, does one normally have to describe the area of intended operations (geographically) for Phase II?

DARs...what is the rule here?

Builders...did you have to provide this info and include it in YOUR Op Limits?
 
POH required??

Those limitations are not applicable to certified aircraft just are phase 1 and phase 2 testing are not. Certified operating limitations are usually contained in the POH (which as I understand it, but may be wrong, are required to be on board experimental aircraft also...).

I'm not sure if you meant that the operating limitations, or the POH, was required. If the POH, please see the rest of the message.

A month ago there was a discussion on one of the Sonex boards about whether Weight and Balance information was required to be carried on an experimental.

The document from the EAA in this link:

http://tinyurl.com/39zt4lh

discusses what is required. From what we could determine, since an experimental's POH is not an FAA approved document, it is not required to be carried on the aircraft.

It appears that the air worthiness certificate, the registration, and the operating limitations are specifically required, and the weight and balance is strongly recommended.

Chris Smith
 
. . .It appears that the air worthiness certificate, the registration, and the operating limitations are specifically required, and the weight and balance is strongly recommended.

Chris Smith
And I would still like to hear from someone who knows, or who can direct me to the proper readings, about what specifically the "operating limitations" need to say. Can someone address this question?
 
And I would still like to hear from someone who knows, or who can direct me to the proper readings, about what specifically the "operating limitations" need to say. Can someone address this question?

Steve,

The "operating limitations" are determined by the FSDO. However, if you email me at "bill (at) repucci (dot) com", I'll reply with a copy of my "Program Letter".
 
You guys are confusing yourselves.

Program Letter is presented to inspector requesting Phase I flight test area.

Operating limitations are issued to you by the inspector listing phase I flight test area.

Operating limitations will normally allow you to sign off phase I and continue flight under phase II. There are few limitations under phase II and they are listed within the operating limitations.

Operating Limitations must be in the aircraft at all times. This is covered in 2 places:
(1) Your airworthiness certificate states in block E that; "Operating Limitations Dated xx/xx/xxxx are a part of this certificate"
(2) Operating limitations paragraph 1 state: "These operating limitations are a part of Form 8130-7, and are to be carried in the aircraft at all times and be available to the pilot in command of the aircraft."

Experimental amateur-built aircraft are not required to have a POH. The operating limitations serves as a POH.
 
I think this confusion about POH's vs. Op Limits vs. Program Letters has obscured the original question. To wit:

"Have any of you been told by the FAA to provide a "program letter" describing the territory where you intend to fly your RV once it is airworthy?"

(by which I assume he means post-Phase I)

followed by

"after you do phase one and now are in phase 2 are you required to submitt a letter to the faa asking permission to fly in differnt parts of the country i heard of a faa insp saying it was required to be on file for phase 2 and if your ramped checked its required to be on board that you have permission to fly to that location is that true"

and

"he said that I have to have an approved program letter on board the airplane along with the airworthiness certficate and registration for phase II. He said that the FAA will usually comply to the program letter request for phase II, but it should be on board the airplane and filed with the FAA in case I am ramp checked in, let's say, Idaho. He said that the normal area for phase II flying is about a 300 mile radius from my home airport in north Florida."

All of these lead me to believe that there is either a requirement to define the area of operation for the life of the aircraft somewhere, and have that approved by the FAA, OR said statements by FAA reps or DARs are incorrect and no such constraint exists.

Does it, or not? If it does, where is it documented and approved? If it doesn't, then...
 
See below:

I think this confusion about POH's vs. Op Limits vs. Program Letters has obscured the original question. To wit:

"Have any of you been told by the FAA to provide a "program letter" describing the territory where you intend to fly your RV once it is airworthy?" (An RV can never be "airworthy". The definition of "airworthy" is "meets its type certificate." An RV is "in a condition for safe operation.")

Everyone has to submit a program letter.

(by which I assume he means post-Phase I)

followed by

"after you do phase one and now are in phase 2 are you required to submitt a letter to the faa asking permission to fly in differnt parts of the country i heard of a faa insp saying it was required to be on file for phase 2 and if your ramped checked its required to be on board that you have permission to fly to that location is that true"

Phase II you must have your operating limitations on board. No further letters need be submitted.

and

"he said that I have to have an approved program letter on board the airplane along with the airworthiness certficate and registration for phase II. He said that the FAA will usually comply to the program letter request for phase II, but it should be on board the airplane and filed with the FAA in case I am ramp checked in, let's say, Idaho. He said that the normal area for phase II flying is about a 300 mile radius from my home airport in north Florida."

This has to do with experimental exhibition. Does not apply to experimental amateur-built.

All of these lead me to believe that there is either a requirement to define the area of operation for the life of the aircraft somewhere, and have that approved by the FAA, OR said statements by FAA reps or DARs are incorrect and no such constraint exists.

Does it, or not? If it does, where is it documented and approved? If it doesn't, then...

FAA Order 8130.2

It sounds as if this inspector is talking about experimental exhibition as previously stated.
 
Quotes 1 and 3 are from the same person, quote 2 from someone else (albeit secondhand).

If 2 is true, then at least 2 inspectors are perhaps promulgating incorrect limitations and information, no?

ETA: Thanks for answering the questions, Mel...sometimes these threads wander all over, and the original question never quite *does* get a direct, straight answer :)
 
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Quotes 1 and 3 are from the same person, quote 2 from someone else (albeit secondhand).

If 2 is true, then at least 2 inspectors are perhaps promulgating incorrect limitations and information, no?

ETA: Thanks for answering the questions, Mel...sometimes these threads wander all over, and the original question never quite *does* get a direct, straight answer :)

Everything Mel wrote is 100% correct. Read FAA Order 8130.2F change 5 for all the current info.

I will not speculate on what someone else may or may not have said. The info in 2 that you talk about is incorrect. See Mel's post and FAA Order 8130.2F change 5 for info that is valid today.
 
How big an area to request in Phase 1?

How big of an area can one reasonable getting away with asking for in the program letter? What have DARS found reasonable and what are the reasonable criteria on which to base this request?

Obviously, I'd like to have as big an area as possible--not so that I can do cross countries in Phase 1 but so that I can get away from local university flight school training and also so that maybe I can get to some (much) cheaper gas in my later phase 1 hours at nearby airports (about 40-50 miles away). I suspect cheap gas is not high on the list of acceptable reasons for the FAA, so I need to find other good excuses to make that cheaper gas accessible. There are very few heavily populated areas in central Washington, so that reason probably won't help me much. Any other good criteria to justify a large area?
 
How big of an area can one reasonable getting away with asking for in the program letter? What have DARS found reasonable and what are the reasonable criteria on which to base this request?

Obviously, I'd like to have as big an area as possible--not so that I can do cross countries in Phase 1 but so that I can get away from local university flight school training and also so that maybe I can get to some (much) cheaper gas in my later phase 1 hours at nearby airports (about 40-50 miles away). I suspect cheap gas is not high on the list of acceptable reasons for the FAA, so I need to find other good excuses to make that cheaper gas accessible. There are very few heavily populated areas in central Washington, so that reason probably won't help me much. Any other good criteria to justify a large area?

I was able to fly approx. 100 miles to the west, and 50 miles to the south. These areas (two airports) were less populated desert & mountain areas. My home airport is under Class B.

L.Adamson
 
An acceptable area depends on the speed of the aircraft, the area of the U.S. you will be flying over, the local FSDO, and other considerations.

As an example, I typically give RVs a 75 nm radius from the home airport plus a couple of airports outside this area within about 125 nm. We DARs are usually given a certain amount of leeway as long as we keep it reasonable.

Reasons for requesting additional airports may be to get to a paint shop or have your pitot/static/transponder check done.

In other words, there are a lot of factors in determining this area. Each situation is different.

The final area must be agreed to between the applicant and the inspector.
 
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VFR vs. IFR on program letter

My sample program letter (I think I got it from EAA) has a line:

"After Phase I flight test completion, I plan to operate the aircraft under VFR _____ IFR _____conditions."

I'm only set up for VFR, but if I check VFR will that in anyway limit the ease with which I can legally fly IFR later on (assuming I upgrade my aircraft appropriately)?