Sorting out Experimental Airworthiness Certification and LSA designation

[son_of_flubber]

I have a glider manufactured in 1998 in Poland and imported to the USA in 1999 and issued an Experimental Airworthiness Certificate. It is type certified in Europe. (SZD 51-1)

The glider appears to meet all of the operational specifications for LSA wrt weight, VNE, stall speed etc.. Is that sufficient to make it an LSA for FAR purposes? Is it necessary/possible to amend the Air Worthiness Certificate to designate the glider as an LSA? Is there any particular advantage/disadvantage to doing this?

Why would I stir the pot?

I bought the glider used. I moved it to a new base of operations. The original operating limitations required flying within 300 NM of the previous location. Last year, the local FAA office was happy with a program letter specifying my 'temporary' base of operation. This year they want me to amend my airworthiness certification and change my base of operations. They tell me that an inspection is not needed to amend the certificate.

Why do I care about LSA? I would like to get rid of the 300 NM geographic radius limitation and also eliminate the need for a program letter whenever I want to fly outside that radius. I'm wondering if I can ask for this amendment to be made at this time and whether the LSA designation would help me.

[Two Shoes (Judson Knowles)]

Here is what I found with my Google-Fu.... from RAS 2010: https://groups.google.com/forum/#!topic/rec.aviation.soaring/L8SfJBQjM0I

[Andy K]

On Wednesday, April 16, 2014 6:16:55 PM UTC-4, son_of_flubber wrote:
> I have a glider manufactured in 1998 in Poland and imported to the USA in 1999 and issued an Experimental Airworthiness Certificate. It is type certified in Europe. (SZD 51-1)
>
>
>
> The glider appears to meet all of the operational specifications for LSA wrt weight, VNE, stall speed etc.. Is that sufficient to make it an LSA for FAR purposes? Is it necessary/possible to amend the Air Worthiness Certificate to designate the glider as an LSA? Is there any particular advantage/disadvantage to doing this?
>
>
>
> Why would I stir the pot?
>
>
>
> I bought the glider used. I moved it to a new base of operations. The original operating limitations required flying within 300 NM of the previous location. Last year, the local FAA office was happy with a program letter specifying my 'temporary' base of operation. This year they want me to amend my airworthiness certification and change my base of operations. They tell me that an inspection is not needed to amend the certificate.
>
>
>
> Why do I care about LSA? I would like to get rid of the 300 NM geographic radius limitation and also eliminate the need for a program letter whenever I want to fly outside that radius. I'm wondering if I can ask for this amendment to be made at this time and whether the LSA designation would help me.

Where do you currently send you program letter?

[[email protected]]

I have no knowledge about LSAs.
But I have an experimental.
My FSDO has been quite helpful and easy to work with.
My yearly program letter calls out about 15 locations where I am planning to practice for proficiency or participate in racing.
Historically my planning never works out.
In the past I never made it anywhere close to all those 15 different locations in 1 year. I am not aware of any limit in the number of locations you can state in the program letter.
Anyway, my 15 locations cover all of the routes we usually fly.
Nearly all of California, Nevada, Utah.
And if I want to go to a location that I did not plan for at the moment of issuance of the program letter, I only need to send an email to my FSDO, stating the new location(s) as amendment.

[Bill T]

I would not care about changing an experimental to LSA. AFAIK it would gain you nothing. If the glider qualifies within the speed limitations of an LSA, a glider rated LSA pilot can fly it. An aircraft does not have to be registered as LSA for an LSA rated pilot to fly it.

Changing the program letter for a new location and region of flying is a standard practice for the "newer" program letters. It may require a reissue of the airworthy cert, I would keep it experimental for exhibition and racing.

I'm not sure if what is listed on the TCDS may restrict how it is certified, ruling out LSA.
BT

[son_of_flubber]

On Wednesday, April 16, 2014 10:09:55 PM UTC-4, Bill T wrote:
> I would not care about changing an experimental to LSA. AFAIK it would gain you nothing. If the glider qualifies within the speed limitations of an LSA, a glider rated LSA pilot can fly it. An aircraft does not have to be registered as LSA for an LSA rated pilot to fly it.

That helps.

Have any glider manufacturers brought their products into the USA as LSA?
The LSA lobby seems to be large, strong and effective at moderating regulations.

And though it is traditional and many have gotten used to it, Experimental Racing/Exhibition owners seem to be a small and marginalized group, that is at the mercy of local FSDO interpretations.

It seems that LSA regulations are friendly, and getting friendlier, whereas Experimental regulations seem somewhat arbitrary and tending to get less friendly over time.

I realize that the Experimental regs encompass all sorts of marginal truly experimental aircraft and thus the FAA oversight functions are justified. But putting my 'type-certified-in-Europe-conservative-glider' in the experimental bucket seems an expedient hack.

Now that LSA is emerging, I wonder if I'd should try to get into that bucket instead. The holder of the type certificate is still a viable business.

[Tom (2NO)]

"I would like to get rid of the 300 NM geographic radius limitation and also eliminate the need for a program letter whenever I want to fly outside that radius."

If you simply add OLC to your list of events you never have to worry about the geographic limitation. I fax my program letter in the first week of Jan each year. No receipt or confirmation is required, just make sure you have a copy of it with your other required documents.

[son_of_flubber]

On Thursday, April 17, 2014 8:33:29 AM UTC-4, Tom (2NO) wrote:
> "I would like to get rid of the 300 NM geographic radius limitation and also eliminate the need for a program letter whenever I want to fly outside that radius."
>
>
>
> If you simply add OLC to your list of events you never have to worry about the geographic limitation.

I suppose that would work until someone at my FSDO decides that OLC is not a 'race' in the same sense as what is called a 'race' in my operating limitations written in 1998.

[Dan Marotta]

I've owned one Standard airworthiness category glider and 5 Experimental. I
would not want other than Experimental simply for the lower maintenance
requirements. I don't mean shoddy maintenance - I simply mean that I can do
more and an A&P can complete the annual condition inspection. The program
letter is a bothersome requirement but trivial to execute. I keep a copy on
my computer and simply update it annually and email it to the FSDO. The
first time I had to do this, I called and spoke to a real person. He gave
me his email address and said to send the letter directly to him. He never
responds unless I ping him for confirmation, but I copy myself as proof that
it was sent. The wording says, in addition to planned events, that I can
fly anywhere while practicing for those events or for the OLC.


"Bill T" > wrote in message
...
I would not care about changing an experimental to LSA. AFAIK it would gain
you nothing. If the glider qualifies within the speed limitations of an LSA,
a glider rated LSA pilot can fly it. An aircraft does not have to be
registered as LSA for an LSA rated pilot to fly it.

Changing the program letter for a new location and region of flying is a
standard practice for the "newer" program letters. It may require a reissue
of the airworthy cert, I would keep it experimental for exhibition and
racing.

I'm not sure if what is listed on the TCDS may restrict how it is certified,
ruling out LSA.
BT

[Frank Whiteley]

On Thursday, April 17, 2014 7:11:33 AM UTC-6, son_of_flubber wrote:
> On Thursday, April 17, 2014 8:33:29 AM UTC-4, Tom (2NO) wrote:
>
> > "I would like to get rid of the 300 NM geographic radius limitation and also eliminate the need for a program letter whenever I want to fly outside that radius."
>
> >
>
> >
>
> >
>
> > If you simply add OLC to your list of events you never have to worry about the geographic limitation.
>
>
>
> I suppose that would work until someone at my FSDO decides that OLC is not a 'race' in the same sense as what is called a 'race' in my operating limitations written in 1998.

Your operating limitations should say something about FAI and SSA records and awards. SSA recognizes OLC.

Frank Whiteley

[Frank Whiteley]

On Thursday, April 17, 2014 1:02:54 PM UTC-6, Frank Whiteley wrote:
> On Thursday, April 17, 2014 7:11:33 AM UTC-6, son_of_flubber wrote:
>
> > On Thursday, April 17, 2014 8:33:29 AM UTC-4, Tom (2NO) wrote:
>
> >
>
> > > "I would like to get rid of the 300 NM geographic radius limitation and also eliminate the need for a program letter whenever I want to fly outside that radius."
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> > >
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> >
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> > >
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> >
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> >
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> > > If you simply add OLC to your list of events you never have to worry about the geographic limitation.
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> >
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> >
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> > I suppose that would work until someone at my FSDO decides that OLC is not a 'race' in the same sense as what is called a 'race' in my operating limitations written in 1998.
>
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> Your operating limitations should say something about FAI and SSA records and awards. SSA recognizes OLC.
>
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> Frank Whiteley

That is, given the date of your operating limitations. FAA Order 8130.2 has omitted those from the lexicon for the past few revisions.

The new draft order is available here. Comment period closed Feb 7.
http://www.faa.gov/aircraft/draft_docs/media/draft_order_8130.2.pdf

Frank Whiteley

[Bill T]

Aircraft (gliders) imported to the US under a TCDS. For a foreign manufacturer to import with a "standard" certificate would have to go through a lot more proce$$es and expen$e. The FAA orders related to airworthy certs recognize the factory built glider under the "experimental for exhibition and racing".

Not many current manufacture gliders meet LSA. Their VNE is to high.
BT

[son_of_flubber]

On Friday, April 18, 2014 12:16:16 AM UTC-4, Bill T wrote:

> Not many current manufacture gliders meet LSA. Their VNE is to high.

It would likely be a trainer or something like the PW-5.

[son_of_flubber]

Though it is not the absolute final word, a DAR told me today that it currently impossible to convert an Experimental Glider Racing/Exhibition air-worthiness to E-LSA (Experimental LSA).

I was interested in doing this because an owner can obtain a 'repairman' rating (after taking a 16 hour course) for an E-LSA (even if it was not home-built). Repairman seems to be a good match to what I would like to be able to do legally with my glider without supervision.

[Frank Whiteley]

On Wednesday, April 23, 2014 9:02:04 AM UTC-6, son_of_flubber wrote:
> Though it is not the absolute final word, a DAR told me today that it currently impossible to convert an Experimental Glider Racing/Exhibition air-worthiness to E-LSA (Experimental LSA).
>
>
>
> I was interested in doing this because an owner can obtain a 'repairman' rating (after taking a 16 hour course) for an E-LSA (even if it was not home-built). Repairman seems to be a good match to what I would like to be able to do legally with my glider without supervision.

If you think of the next potential owner and resale value, you might think again.

[son_of_flubber]

On Thursday, April 24, 2014 1:15:53 PM UTC-4, Frank Whiteley wrote:

> If you think of the next potential owner and resale value, you might think again.

That had occurred to me. The cheap way to get into an E-LSA is to buy a used low hours weight shift soarable trike. They do not hold their value and they are a way to on a calm day with marginal lift.