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Why are some RV12's EAB and some ELSA?
- Thread starter dabney
- Start date
The main difference for you is that if the plane is registered as E-AB, you must hire an A&P to do the annual inspection (unless the builder does it). If it is registered as E-LSA, then you can do the annual inspection yourself after taking a 16 hour class and getting a repairman's certificate.
There must be operating limitations.
It it is wise to have a pre-buy inspection by someone like Vic Syracuse.
There must be operating limitations.
It it is wise to have a pre-buy inspection by someone like Vic Syracuse.
Builder's choice. To qualify as ELSA the aircraft must be built exactly per plans and all parts must be purchased from the kit manufacturer.
Some people prefer to make minor or major modifications during the build. Or in some cases they may already have an engine or avionics and prefer to install these as opposed to ordering new from Vans. The builder my opt for EAB so that he/she doesn't have to go to class to obtain the repairman certificate. EAB can be modified to take it out of the Light-Sport parameters. ELSA cannot. There can be a multitude of reasons.
EAB is not necessarily better or worse than ELSA. Just different.
Some people prefer to make minor or major modifications during the build. Or in some cases they may already have an engine or avionics and prefer to install these as opposed to ordering new from Vans. The builder my opt for EAB so that he/she doesn't have to go to class to obtain the repairman certificate. EAB can be modified to take it out of the Light-Sport parameters. ELSA cannot. There can be a multitude of reasons.
EAB is not necessarily better or worse than ELSA. Just different.
If it is EAB, it's forever. If it's ELSA, it's forever. If it's SLSA it may be changed to ELSA.
randylervold
moderator
That?s actually not true. If you can get the manufacturer (Van?s) to do a full conformity inspection, and the aircraft hasn?t been changed in any way so that it does actually conform, then a new SLSA airworthiness certificate can be issued. Just not very practical.
DaleB
Well Known Member
Yep. Theoretically possible, probably not ever actually done.
There's no path from E-LSA to E-AB because E-LSA does not have a 51% amateur built requirement.
No one has answered this part of your question.
No it is not possible. Even SLAS's have operating limitations.
Perhaps he lost them.
Sorry, I missed that part of the question. Like Scott says, Operating Limitations are issued as part of the Airworthiness Certificate and must be in the airplane during any and all operations.
DonFromTX
Well Known Member
Another point for a buyer, if you feel that the ELSA is "better" because it was built strictly according to a standard, think again. The day AFTER the ELSA certificate, most any changes you might dream up are perfectly legal and do not have to be in accordance with the ELSA requirements. If you like your lawnmower engine, you can now fly behind your lawnmower engine. After all, it is EXPERIMENTAL!
DaleB
Well Known Member
The only reason I would prefer E-LSA as a buyer is the ability to get the repairman certificate and sign off on the condition inspection. Of course an E-AB RV-12 was most likely not built strictly to plans (why else would you make it E-AB?), but one would hope that any deviations would be discovered and discussed during the prebuy inspection. No matter what the airworthiness certificate says, just like any other airplane you really need to know exactly what you're buying -- or be willing to deal with the inevitable surprises.
The possibility here is that the builder may already have an engine, prop, avionics, etc., and prefer to use those instead of buying new from the kit manufacturer.
jnorris
Well Known Member
Yep, that's the main reason people go amateur-built instead of ELSA on an RV-12. But there is another, obscure reason to go AB. That is to allow the ability to lease the aircraft to another entity. By regulation, ELSA cannot be leased (Ref. 91.319(f)). This is why EAA built the "One Week Wonder" RV-12 as amateur-built, even though it is built strictly in accordance with Van's instructions. The plan is to lease the aircraft to the EAA employee flying club after it finishes it's promotional touring duties.
So, as mentioned before, when one is looking to purchase a flying RV-12, make sure to understand what airworthiness certificate it has, and why. As with any experimental aircraft, each one is unique.
randylervold
moderator
My thoughts and opinion on the issue...
http://www.romeolima.com/rv12-home/info-elsaveab/
http://www.romeolima.com/rv12-home/info-elsaveab/
bshawco
Active Member
Light Sport Pilot Certificate doesn't qualify to fly EAB airplane
Correct me if I'm wrong, but I'm under the impression that a pilot with a Light Sport license and a "Driver's License medical" is legal to fly an E-LSA certificated airplane but not an E-AB, since an E-AB requires at least a Private Pilot license and 3rd Class Medical.
I'd think that this could be a reason to choose E-LSA over EAB registration.
Correct me if I'm wrong, but I'm under the impression that a pilot with a Light Sport license and a "Driver's License medical" is legal to fly an E-LSA certificated airplane but not an E-AB, since an E-AB requires at least a Private Pilot license and 3rd Class Medical.
I'd think that this could be a reason to choose E-LSA over EAB registration.
greghughespdx
Well Known Member
Not quite.
An aircraft flown by a sport pilot doesn't have to be certified as light sport, but it must meet the performance definition of a light-sport aircraft as defined in 14 CFR 1.1.
AOPA has some useful information on this subject.
rcarsey
Well Known Member
Nothing prohibits you from flying an E-LSA in IMC. You are not bound by the language in the POH/AFM.. only the language in your Airworthiness Certificate. (S-LSA is a different story). However, you "should" have more than just the IFR package installed (heated pitot, alternate air, a second ADAHARS unit, etc).
I do know of one case where an E-LSA was returned to S-LSA. It was not a kit-built. It was originally an S-LSA and it was NOT a Van's.
I will not reveal the name of the manufacturer "to protect the innocent".
I will agree that it is EXTREMELY rare. And the case I'm referring to was an exception.
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Did the ASTM on LSA finally get revised? Last I checked, it does not differentiate between E or S LSA for prohibiting flight in IMC.
https://www.aopa.org/news-and-media/all-news/2010/september/03/lsa-flight-into-imc-to-be-prohibited
Straight off the Vans avionics ordering page:
Quote
Note that the current Light Sport Aircraft standards (ELSA and SLSA) preclude operation in Instrument Meteorological Conditions (IMC). While aircraft licensed under the LSA standard may be operated "in the system" under Instrument Flight Rules, such as in a training environment, certification as LSA currently prohibits IMC operations. Also, note that EAB-licensed aircraft are not restricted in this fashion.
End quote
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I am curious as to what limitations a DAR has on writing operating limits in the Airworthiness Certificate for an E-LSA. Supposedly he is inspecting something that was built as an ASTM conforming item (the S-LSA), and the ASTM specifically prohibits IMC operation. Can a DAR make whatever non-conforming modifications to the S-LSA limitations they want in writing the AW certificate? Is there any reason they could not also increase the gross weight or airspeed limitations as an example? The presumption here is the POH, which is part of the conforming item presented for inspection, does not apply to the limitations written in the AW certificate.
John Salak
RV-12 N896HS (EAB)
I don’t have specific details but I have a friend who has a Tecnam LSA. He had the plane recertified as an ELSA and when he did this he also had the operating limitations changed to allow IFR if so equipped. Again not an expert but he is and said you can change the operating limitations of an ELSA to allow IFR.
Opening limits aren’t issued randomly, there issued under the guidance of FAA order 8130.2J. If you want to see the differences between S-LSA, E-LSA and E-AB download a copy https://www.faa.gov/documentlibrary/media/order/faa_order_8130.2j.pdf
have a look at appendix D and build yourself a set of each.
It’s not the DAR, it’s the FAA that allows IFR/IMC operations though the opening limits. The airspace we fly is the FAAs domain, ASTM has no jurisdiction
Look at the op-limits, compliance to operations dictated in the Manufacture supplied POH only applies to an S-LSA. If your an E-LSA add the required equipment and modify the page after certification, after all you are experimental
An E-LSA only needs to match its S-LSA duplicate at the time of certification. Once certified you can modify it all you want as long as you keep it within the definition of an LSA (FAR section 1.1) and follow your op-limits
Thanks for the reference. For LSA, FAR 1.1 appears to be the only limitation on what you cannot modify after certification or change by AW limitations, an in-flight adjustable prop for example.
My OLs state "Instrument Flight operations are authorized if ... 91.205(d)...". It was built that way from the start and is one reason I went EAB. Looking back on the build, as an EAB I was able to incorporate a lot of changes that originated from builders on VAF before Van's eventually incorporated many of them in the KAI. To Eric H's question, going EAB makes it a lot easier to add some items like a heated pitot to the wing while you are building vs doing it post-ELSA certification with the wings closed up. Same for adding a COMM2, NAV/GS/LOC and of course more antennas and wiring. You may also want to consider a second battery / emergency buss electrical change to keep the fuel pumps, ECU running, and essential panel running.
John Salak
RV-12 N896HS
Almost right. Change the last 3 words of the last line of your first paragraph from “3rd Class Medical” to “BasicMed medical”
And herein lies the confusion.
Can you modify your ELSA after certification? Yes
Can you modify your ELSA to the point it no longer meets the definition of being an LSA? No (it would be nice, wouldn’t it?)
What defines the certification requirements for an ELSA? ASTM 2245-20
What does ASTM 2245-20 say about VFR/IFR? Limited to VFR flight only.
When you build your ELSA, you’ll placard it to say flight in IMC prohibited. Can you peel that off after certification and go fly in IMC? Sure you can. Will anyone question you or care? Probably not… unless you are involved in a mishap. Then I’m sure your insurance company will turn away from you in a heartbeat and the FAA will question why you flew an aircraft in IMC that wasn’t certificated to do so. That the aircraft is “experimental” is moot. It’s not an EAB, it’s an LSA.
But hey folks, it’s your license. What’s it worth to you?
Actually the current FAA accepted standard is F2245-16c for “Design and Performance” and “Required Equipment.” Here is the complete list of the FAA LSA Accepted Standards;
https://www.faa.gov/aircraft/gen_av/light_sport/media/StandardsChart.pdf
It doesn’t matter what the ASTM standard says about IFR operation, The FAA writes rules and they permit IFR operation via the op-limits.
you omitted this line of my post, maybe I wasn’t clear. Here it is [with a bit more detail];
“If your an E-LSA, add the required equipment [for IFR flight] and modify the [POH] page after certification…’
I personally don’t care if you build E-AB or E-LSA. My point is that you will get the exact same operating limits for IFR/IMC operation either way it’s licensed.
Look a FAR 21.191. There are nine sub groups for “Experimental” certification, including both E-AB and E-LSA. LSA is one path into certification. Both E-AB and E-LSA get specific benefits/penalties for being “experimental” But for IFR operation they are treated equally.
True statement!
bkc3921
Well Known Member
Ugh..!
I tried to re-read this thread to make sure I had all the rules down pat......but then decided to do something less confusing.... like drinking a fifth of Jack Daniels and unscrambling a Rubik's Cube while strapped to an inversion table.....
This is most certainly the quintessence of FAA rulemaking .....
I tried to re-read this thread to make sure I had all the rules down pat......but then decided to do something less confusing.... like drinking a fifth of Jack Daniels and unscrambling a Rubik's Cube while strapped to an inversion table.....
This is most certainly the quintessence of FAA rulemaking .....
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LOL!!! We need a "like" button on this forum.
There seems to be some confusion with the terms LSA and E-LSA.
LSA describes the characteristics of an aircraft as defined by our government. LSA has nothing to do with aircraft registration.
There is no aircraft registration category called LSA, just as there are no aircraft registration categories called high-wing or tail-dragger.
Many type certificated aircraft are LSA.
Homebuilt aircraft can be registered as E-AB or E-LSA and other ways.
Both E-AB and E-LSA are Experimental. If someone says that they are going to register their aircraft as experimental,
they need to be more specific. Do they mean E-AB or E-LSA or E-Exhibition or what?
LSA describes the characteristics of an aircraft as defined by our government. LSA has nothing to do with aircraft registration.
There is no aircraft registration category called LSA, just as there are no aircraft registration categories called high-wing or tail-dragger.
Many type certificated aircraft are LSA.
Homebuilt aircraft can be registered as E-AB or E-LSA and other ways.
Both E-AB and E-LSA are Experimental. If someone says that they are going to register their aircraft as experimental,
they need to be more specific. Do they mean E-AB or E-LSA or E-Exhibition or what?
Sorry to say that I work for a not to be named agency of a not to be named government and it’s what we do. And we’re really good at it.
Pass the bottle…. I’m farther than 50 feet from an aircraft.
Well, Kinda........
There IS a category called Light-Sport. It is for S-LSA, certificated under §21.190
There IS a category called Light-Sport. It is for S-LSA, certificated under §21.190
Not Quite...
Paragraphs 22 & 23 that you quote are used in Op Lims for E-AB and E-LSA.
If these 2 paragraphs are found in Op Lims for S-LSA, they were issued in error.
Go to FAA Order 8130.2J Appendix D and you will find that these 2 paragraphs are issued to aircraft certificated under 21.191 and 21.191(b), (f), (g). (h), & (i) respectively.
S-LSA are certificated under 21.190.
Paragraphs 22 & 23 that you quote are used in Op Lims for E-AB and E-LSA.
If these 2 paragraphs are found in Op Lims for S-LSA, they were issued in error.
Go to FAA Order 8130.2J Appendix D and you will find that these 2 paragraphs are issued to aircraft certificated under 21.191 and 21.191(b), (f), (g). (h), & (i) respectively.
S-LSA are certificated under 21.190.
DaleB
Well Known Member
Nope. As has been more or less mentioned, the airplane just has to fall within the limits of the “light sport” definition. The airplane can be S-LSA, E-LSA, E-AB, or type certificated like an Ercoupe, Cub, Champ, etc. it’s not what’s on the airworthiness certificate, it’s whether or not the plane meets the criteria for max gross weight, speed, stall speed, gear, prop, and so on.
Yes, Sport Pilots (i.e., driver's license only) can fly (some) E-AB!
The term "LSA" is, in part, a definition for purposes of identifying Sport Pilot privileges. The FAA states that exercising Sport Pilot privileges permits you to operate "Any light-sport aircraft for which you hold the endorsements required for its category and class." The FAA notes that when you get a sport pilot certificate, it "will not have any category and class ratings." The Sport Pilot limitations and privileges dictate what you can fly. One of the privs is to act as PIC of a "light-sport" aircraft.
Yes, there is a "LSA Category" (e.g., S-LSA) but Sport Pilots are not limited to flying LSA Category aircraft - as noted above, the SP certificate does not specify any category limitations (not even an "LSA category" limitation).
One simple fact helps to clarify:
- Certified/standard category planes can (and some do) meet the LSA definitions (e.g., ER Coupe). Is the ER Coupe a certified plane? Yes, but they are also at the same time an "LSA." Why . . . its AW certificate does not state it is an LSA - in fact it was built before the definition existed and they sure the heck did not comply with any LSA ASTM standard when built. Correct, but what is on the ER Coupe's AW certificate does not dictate whether it is an LSA - whether a plane is an LSA for purposes of Sport Pilot privileges is dictated by the FAA (not ASTM) definition.
This conveniently cross-applies to E-AB (yes regs sometimes are logical - shocking, right!).
- Similarly, some E-AB planes can and do meet the FAA's definition of LSA. Can a Sport Pilot act as PIC of an E-AB that meets the definition of an LSA - ya betcha if the Sport Pilot can fly it and be within what is allowed under the SP's privileges! What if you modify that E-AB so that it no longer meets the LSA definition? Then a Sport cannot act as PIC. Pretty simple.
Figuring out what planes you can fly as PIC with Sport Pilot privileges (i.e., driver's license/no 3rd class or basic med req) is a matter of applying the FAA's LSA definition (keeping in mind that the SP priv limitations include more than just the LSA definition that can impact what SP can fly). Whether a plane's AW certificate is standard/certified category or E-AB is 100% not relevant to determining whether a Sport Pilot can act as PIC. It really is that simple.
The term "LSA" is, in part, a definition for purposes of identifying Sport Pilot privileges. The FAA states that exercising Sport Pilot privileges permits you to operate "Any light-sport aircraft for which you hold the endorsements required for its category and class." The FAA notes that when you get a sport pilot certificate, it "will not have any category and class ratings." The Sport Pilot limitations and privileges dictate what you can fly. One of the privs is to act as PIC of a "light-sport" aircraft.
Yes, there is a "LSA Category" (e.g., S-LSA) but Sport Pilots are not limited to flying LSA Category aircraft - as noted above, the SP certificate does not specify any category limitations (not even an "LSA category" limitation).
One simple fact helps to clarify:
- Certified/standard category planes can (and some do) meet the LSA definitions (e.g., ER Coupe). Is the ER Coupe a certified plane? Yes, but they are also at the same time an "LSA." Why . . . its AW certificate does not state it is an LSA - in fact it was built before the definition existed and they sure the heck did not comply with any LSA ASTM standard when built. Correct, but what is on the ER Coupe's AW certificate does not dictate whether it is an LSA - whether a plane is an LSA for purposes of Sport Pilot privileges is dictated by the FAA (not ASTM) definition.
This conveniently cross-applies to E-AB (yes regs sometimes are logical - shocking, right!).
- Similarly, some E-AB planes can and do meet the FAA's definition of LSA. Can a Sport Pilot act as PIC of an E-AB that meets the definition of an LSA - ya betcha if the Sport Pilot can fly it and be within what is allowed under the SP's privileges! What if you modify that E-AB so that it no longer meets the LSA definition? Then a Sport cannot act as PIC. Pretty simple.
Figuring out what planes you can fly as PIC with Sport Pilot privileges (i.e., driver's license/no 3rd class or basic med req) is a matter of applying the FAA's LSA definition (keeping in mind that the SP priv limitations include more than just the LSA definition that can impact what SP can fly). Whether a plane's AW certificate is standard/certified category or E-AB is 100% not relevant to determining whether a Sport Pilot can act as PIC. It really is that simple.
DaleB
Well Known Member
Just remember also that the airplane in question, whether EAB or Standard or any other category, must have ALWAYS met 100% of the criteria, since day 1. If (for example) your Champ had an STC that bumped its max gross weight to, say, 1350#, and you remove that STC and return it to a lower, LSA compliant gross weight, well, tough. Still not legal for a Sport Pilot to fly. Ever.
Aren’t FAA regulations fun?
But this has not much to do with an RV12. Those can be flown by anyone with a Sport Pilot or higher certificate, assuming you haven’t had a medical revoked.
Aren’t FAA regulations fun?
But this has not much to do with an RV12. Those can be flown by anyone with a Sport Pilot or higher certificate, assuming you haven’t had a medical revoked.
My question would be.... If I already have a 100hp Rotax 912-ULS (exact engine spec-d for this kit) and not buy one thru Vans... would that require me to go the E-AB route? In other words... does it have to meet spec or does it have to be purchased thru kit manufacturer?
Thanks for any information you can offer.
David
The answer is yes to both questions.
Meeting the second requirement automatically assures it meets the first one.
Van's has to supply an ELSA builder with a form (Form 8130-15) certifying that the airplane kit was delivered able to be built as an exact copy of our SLSA aircraft. The able part is because it is then the builders responsibility to build it that way, and they have to sign the same form at certification certifying that they did so.
Van's is burdened with assuring that happens, and to help assure that, the FAA requires Van's to supply all components in order to sign the form certifying it as an ELSA kit.
As Scott says, Van's furnishes all components to build as an E-LSA. You must "show" the inspector that you built the aircraft exactly per the plans with no modifications. If there are any deviations from the plans, you must submit written documentation from the kit manufacturer approving such deviations.
