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Cowling attachment

D

dsm8

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RV-12ers

I have hung the Rotax 912-ULS engine. Although I have followed the KAI to this point. What modifications can be made prior to FAA/DAR inspection. I am confused about:

1. LSA vs. ELSA
2. Is there a difference between armature built and experimental with respect to the RV-12
3. If so, what are the differences.
4. Are any modifications before the build is compete authorized?
5. I am considering using a different fastener system for the cowling piano hinge vs. Skybolt/quarter turn fasteners.

Have a a great weekend.
 
LSA can be broken up into two parts.. S-LSA and E-LSA. S-LSA are factory-built aircraft (that conforms to the current LSA rules). E-LSA are the same airplanes, but built by "amateurs" (not in the factory). E-LSA aircraft must be built exactly like their S-LSA counterparts "bolt for bolt" in order to be eligible for this category. However, once the E-LSA airworthiness certificate is issued by the DAR, you can change anything you want -- as long as the changes don't put it outside of the LSA requirements (2 seats, 1320lbs gross, stall speed below... etc..).

Since you're not a factory, you have the choice of getting one of two AW certs.. E-LSA.. or E-AB (regular amateur built).

With E-AB, you can do ANY changes right now (even changes that put the airplane outside of LSA rules), before the DAR comes out. Sounds like a good deal right? There are some drawbacks though. You must prove to the FAA that _you_ built it, if you want the Repairman certificate which allows you to do your own "annuals".. you, or an A&P.

If you go E-LSA, then any owner (you, or future owner) can do the "annual" by taking a 2-day course (or any A&P). You (or future owner) only need a Sport Pilot license to fly it.. and in most cases, you don't need a medical or BasicMed to fly.. This may enhance resale value.

My general advice, is unless you want to make drastic changes.. such as using flush rivets instead of pulled rivets everywhere.. or something else that can't be undone in a week.. you may be better off building per plans and going for E-LSA.. then after you get the certificate, undo some things.. and redo them however you want.

In your specific case of the Skybolt fasteners for the cowl.. maybe you can put piano hinges on, get the E-LSA, then simply dont use the hinge. and proceed in installing the skybolt fastener system. .. or something along those lines. I feel you may hurt resale value if you go straight to E-AB.
 
LSA airworthiness has two types: Special LSA (factory built) and ELSA (built by anybody but the factory). ELSA must be built exactly to the kit plans unless the designer (Vans) approves deviation from the plans, and the nameplate will show Vans as the manufacturer for ELSA and SLSA. Experimental Amateur Built (EAB) will have the builder name on the nameplate, and any modification may be made even if it takes it outside LSA definition. After the airworthiness certificate is issued you may make any modifications you want to an ELSA as long as you don’t take it outside the definition of an LSA. You may not modify a SLSA unless directed to by the designer (Vans).


SLSA must be inspected annually by a LSA Repairman who graduated from the 120 hour FAA approved course, any A&P or any IA. ELSA can be maintained and inspected by the owner if they attend a 16 hour Light Sport Repairman course and obtain a LSA Repairman certificate from FAA. EAB can be maintained, altered and inspected by the original builder if issued a Repairman certificate for that airframe, any A&P or any IA.
 
I would add one thing. Don’t confuse Sport Pilot Certificate limitations with LSA definition. A Light Sport Pilot can fly any aircraft that meets the definition of the Light Sport Aircraft regardless of what type airworthiness certificate it has (EAB, ELSA, LSA or Normal). I believe some Ercoupes and the Taylorcraft meet LSA limits. A couple of limits on Sport Pilots are day VFR with visual contact of the ground and max altitude, while LSA aircraft definition limits are performance limits (Vso and Max Gross weight are examples). LSA aircraft may be flown at night or in IMC by a properly rated pilots if properly equipped and the operating limits permit. A Sport Pilot would not be allowed to conduct night or IMC , and any Pilot Private or above exercising Sport Pilot privileges would not be able to legally fly at night or in IMC in the aircraft. That becomes an issue when the pilot has a Private or higher certificate but no medical or basic med.
 
The way I view it, "LSA" basically refers to two different things:

  • An aircraft that a Sport Pilot can fly. This is any aircraft that meets the criteria in FAR 1.1, no matter what type of airworthiness certificate it has.
  • One of two new airworthiness certificate types, available only to aircraft that meet the above and based on ASTM manufacturing standards: S-LSA and E-LSA. S-LSAs are factory built; E-LSAs are built to factory specifications, or also, an S-LSA can be converted to E-LSA.

Unless you make a really huge change like putting a bigger engine or constant-speed prop on, your RV-12 will be an LSA by definition (a) and a Sport Pilot will be allowed to fly it. But it won't be eligible for the E-LSA certification unless you build it exactly how Van's says (the other option would be E-AB, experimental amateur built). And there are some big advantages to being an E-LSA rather than E-AB, as mentioned above.
 
Unless ASTM has changed while I was not looking LSA aircraft are prohibited from operating in IMC. They can operate in the IFR system but must remain in VFR conditions.

From the VAN's website:

"Operating IFR vs. Operating in IMC
The RV-12iST SLSA is a great platform for meeting both the long cross country requirements and shorter, skills-based instructional flying. Filing IFR and operating/training in the IFR “system” is perfectly fine and is allowed if the airplane is properly equipped and the crew meets the training/certification requirements. By operating under IFR, you are simply participating in the ATC system under the established instrument flight rules. Doing so does not necessarily imply that you are flying the airplane in the clouds.

The current regulations preclude entering actual Instrument Meteorological Conditions (IMC) in any SLSA airplane. While the FAA does not directly/specifically object to it, the ASTM committee’s LSA standard states that the aircraft must be placarded including a statement that flight into IMC is not allowed (but notably makes no exclusions on IFR operations – or operating “in the system” with air traffic control). Because the FAA accepts and adopts the ASTM SLSA rules as written, this becomes a regulatory issue. Conversations between Van’s staff and the FAA this year have confirmed that these restrictions “live” completely in the LSA standard, and that no such restrictions are found directly within the FAA regs. In other words, it is up to the ASTM committee that governs the SLSA standard (called “ASTM F37”) to determine and dictate what is allowed and what is not."
 
Also from Van's E-LSA avionics kit order page:

"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.

This package is available only for RV-12iS aircraft equipped with the Rotax 912iS Sport engine. The 912 ULS engine does not deliver the electrical capacity required to support this package."

It appears that if you build the RV-12is with appropriate equipment installed you could register it as an EAB and fly it in IMC.

I'm not an expert on equipment requirements but I believe the required equipment includes a heated pitot tube which would have to be mounted out on a wing unless there is a way to heat the tube that exits out through the spinner.
 
Both of those postings on Van's website are misleading. S-SLA cannot be flown IMC. E-LSA can, per their op-lims, if suitably equipped.

This is an "ask the DAR" question, as it's totally dependent on the op-lims for a specific aircraft. For E-LSA, the op-lims have the final say.

Actually, the first post quoted is fine. It ONLY refers to S-LSA.

The second is wrong.
 
I agree with you on the Operating Limits. Good luck in getting them stating operation in IMC is ok. I know of One RV-12 ULS! that has it and I believe it was a screw up on the part of the FSDO inspector. All of LSA falls under the ASTM rules if I am not mistaken.

From the first post above:

"Conversations between Van’s staff and the FAA this year have confirmed that these restrictions “live” completely in the LSA standard, and that no such restrictions are found directly within the FAA regs."

If FAA grants it in the Op Lims you are good to go.
 
Perhaps I'm wrong it happened once before!
I'll talk with my FSDO again and see if their opinion has changed.
 
Build is complete.
Expecting a DAR visit this Friday.
Only a couple small things left to do on the Production acceptance testing until after the AWC Inspection.
Aint it purdy!
 

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Very nice. I should be finishing up the Fuselage kit this week, and starting on Finish. Also Avionics should arrive within 2 weeks, so I can do both of those as needed. Need to check on the powerplant. I think I'll have that in June or July.
 
I ordered all of the Sheet metal kits and finish kit at OSH 2021, then I ordered the Powerplant kit a month later, and the Avionics kit a month after that. It took it took until early July 2022 for the first kit to arrive... avionics! Then the engine was available, two days after that the wing kit was available. then a month or so later the Fuse and another month later the empennage kit was ready. All of the kits were available in the exact reverse order most people would want/need them! None of the kits were complete except for the avionics kit. If it were not for the backorders the airplane could have been done in six months or less but It's done now in about 8 months (860ish hours) and I'm happy to be almost flying it. It will be mid May before I can begin Phase 1 because I'm out of town from the day after the AW inspection until mid May. When I return I hope to be a Light Sport Repairman with Mechanic rating!

Too much fun!

Good luck with your build and may all your kits arrive complete!:D
 
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