Converting a USA C of A from Standard to Experimental

On Dec 4, 3:36*pm, Pat Russell wrote:
The "Operating Limitations" will require an annual "Program Letter" to
be sent to the local FSDO/FAA and placed in your aircraft folder.

I have seen this. *I have also seen Operating Limitations that do not
specify that Program Letters be submitted.

I have looked for a FAR or AC that requires Program Letters (in
general) to be submitted for Experimental Aircraft. *So far I haven't
found any such regulation.

-Pat

Say what? Ever heard of Google?

14CFR §21.193 Experimental certificates: general.

An applicant for an experimental certificate must submit the following
information:

(a) A statement, in a form and manner prescribed by the Administrator
setting forth the purpose for which the aircraft is to be used.

....

Darryl

Actually Darryl, Pat is partially correct. I know JJ can attest to
this.
The operating limitations are assembled and printed during the final
inspection by a FSDO representative. Although there is a boilerplate
example of the operating limitations document in the computer they use
in the field, the actual construction of the document you will be
branded with is subject to modification by that very same FSDO
representative. In every case we had a bit of a negotiation on what
paragraphs would be included in my aircraft's document.

At this moment I own two gliders with Experimental Certificates. Both
were originally registered within a year of each other. Both
documents are significantly different in specifying the conditions
underwhich I may fly outside of the 300nm circle and both are
different in specifying when a FAX needs to be sent when intending to
fly outside of that 300nm circle. My first glider got its
experimental certificate before 1998 and it had no requirement to
notify the receiving FSDO. So every aircraft experimental certificate
operating limitations can be slightly different than others even if
they were certificated at about the same time from the same FSDO
office.

Still, the ability to make modifications without all the paperwork and
hassel involved with the Standard Certificate makes sending FAXes a
breeze.

Bye the way, I had the new manditory ramp inspections done on both my
planes on the same day by the same inspector just a couple months
ago. The operating limitations for both planes are different and the
inspector had a difficult time explaining to me the exact limitations
I had to flying outside of the 300nm circle for each plane. He read
the documents over and over and came to a slightly different
conclusion each time he read through them. THere are just so many
ways to interpret the meaning of those boilerplate sentences and
phrases that are in those documents that even the very experienced
FSDO rep kept contradicting himself.

On Dec 4, 6:34*pm, Darryl Ramm wrote:
Say what? Ever heard of Google?

14CFR §21.193 * Experimental certificates: general.

An applicant for an experimental certificate must submit the following
information:

(a) A statement, in a form and manner prescribed by the Administrator
setting forth the purpose for which the aircraft is to be used.

...

Darryl

Nice try, Darryl. But that is for the APPLICATION for the
airworthiness certificate. Basically, you are to use their form and
write them a letter telling them what you plan to do with the plane.
It says nothing as to what you are to do each year. If you want to
see what you will be dealing with as far as limitations and yearly
requirements, please look at 8130.2F, available from the FAA. It was
revised again 8-31-2010, so if you haven't downloaded your copy in a
couple of months, you might want to do it again. It is only about 300
pages. :-) There are about 30 pages of interest to the subject of
Experimental Exhibition and Racing Airworthiness Certificates. This
document will be supersceded in April of 2011 by 8130.2G.

This message is really no different than any other on RAS, in that you
just got exactly what you paid for! :-) But, at least now you know
where in the FAA documents to look for what you will be stuck with
doing.

Steve Leonard

On Dec 4, 6:13*pm, Steve Leonard wrote:
On Dec 4, 6:34*pm, Darryl Ramm wrote:

Say what? Ever heard of Google?

14CFR §21.193 * Experimental certificates: general.

An applicant for an experimental certificate must submit the following
information:

(a) A statement, in a form and manner prescribed by the Administrator
setting forth the purpose for which the aircraft is to be used.

...

Darryl

Nice try, Darryl. *But that is for the APPLICATION for the
airworthiness certificate. *Basically, you are to use their form and
write them a letter telling them what you plan to do with the plane.
It says nothing as to what you are to do each year. *If you want to
see what you will be dealing with as far as limitations and yearly
requirements, please look at 8130.2F, available from the FAA. *It was
revised again 8-31-2010, so if you haven't downloaded your copy in a
couple of months, you might want to do it again. *It is only about 300
pages. *:-) *There are about 30 pages of interest to the subject of
Experimental Exhibition and Racing Airworthiness Certificates. *This
document will be supersceded in April of 2011 by 8130.2G.

This message is really no different than any other on RAS, in that you
just got exactly what you paid for! *:-) *But, at least now you know
where in the FAA documents to look for what you will be stuck with
doing.

Steve Leonard

The new doc that Steve is referring to that is effective April 16 2011
is at http://rgl.faa.gov/Regulatory_and_Guidance_Library/rgOrders.nsf/0/1774fe9a01420b56862577ce005128dc/$FILE/Order%208130.2G.pdf

--

BTW I quick skimmed that doc and I could not see a clear statement of
where the authority to require an annual program letter comes from.

14CFR §21.193 requires a statement saying how the aircraft can be used
to be granted an experimental certificate and allows the Administrator
to define the form and manner of that documentation. That alone might
give the Administrator the authority to require an annual program
letter.

Even if 14CFR §21.193 did not grant the authority to require an annual
program letter, then it probably could come from 14CFR §91.319...

91.319 - Aircraft having experimental certificates: Operating
limitations.
....
(i) The Administrator may prescribe additional limitations that the
Administrator considers necessary, including limitations on the
persons that may be carried in the aircraft.

On Dec 4, 3:36*pm, Pat Russell wrote:
The "Operating Limitations" will require an annual "Program Letter" to
be sent to the local FSDO/FAA and placed in your aircraft folder.

I have seen this. *I have also seen Operating Limitations that do not
specify that Program Letters be submitted.

I have looked for a FAR or AC that requires Program Letters (in
general) to be submitted for Experimental Aircraft. *So far I haven't
found any such regulation.

-Pat

It depends on when the program letter was written.
Old.. Pre..(I forget the year).. did not ahve that requirement.
New.. current issue Program Letters do have the requirement.

Remember.. these are "Experimental for Exihibition and Racing".. built
by a factory and imported without a Standard Airworthy Certificate.
These are not "Experimental".. built by you and issued an airworthy
certificate based on you building it.

And there is mroe to Part 21 then mentioned above.

T

On Dec 2, 10:57*pm, RAS56 wrote:

4. Who do I talk to at the FAA to accomplish this and what's needed in
the way of paperwork?

5. Anything else to make me smarter on this topic?
Well, there's the new rule, effective on April 16, 2011, at
http://www.faa.gov/regulations_polic...umentID/324850
and the old rule, at
http://www.faa.gov/regulations_polic...cumentID/14171

On Dec 6, 5:04*am, danlj wrote:
On Dec 2, 10:57*pm, RAS56 wrote:

4. Who do I talk to at the FAA to accomplish this and what's needed in
the way of paperwork?

5. Anything else to make me smarter on this topic?

Well, there's the new rule, effective on April 16, 2011, athttp://www.faa..gov/regulations_policies/orders_notices/index.cfm/go/d...
and the old rule, athttp://www.faa.gov/regulations_policies/orders_notices/index.cfm/go/d...


One more question regarding a conversion like this. What might it do
to the resale value of the glider? Any input would be appreciated.

Paul G

On 12/6/2010 9:40 AM, gliderman wrote:
On Dec 6, 5:04 am, wrote:
On Dec 2, 10:57 pm, wrote:

4. Who do I talk to at the FAA to accomplish this and what's needed in
the way of paperwork?

5. Anything else to make me smarter on this topic?

Well, there's the new rule, effective on April 16, 2011, athttp://www.faa.gov/regulations_policies/orders_notices/index.cfm/go/d...
and the old rule, athttp://www.faa.gov/regulations_policies/orders_notices/index.cfm/go/d...


One more question regarding a conversion like this. What might it do
to the resale value of the glider? Any input would be appreciated.

Paul G

Replies to this question should be interesting! Here's one...

Assuming that whatever a person does to the ship's hardware once it's
converted to the Experimental category is 'essentially trivial' (as in,
doesn't tinker with primary structure), a reasonable answer is 'very little.'
For examples you can go as far back as Wil Schuemann's Diamant and
'Schuemannized Libelle' from the early 1970's. More recent examples would be
(eventually) ATC-ed German ships imported prior to obtaining reciprocal U.S.
licensing.

That noted, conversion likely *will* reduce the potential pool of buyers,
since there seems (to me, anyway) to be a proportion of U.S. pilots who simply
*never* will consider purchasing an experimentally licensed glider.

Regards,
Bob - never owned a non-experimental, post-1-26 sailplane - W.

another consideration is how restrictive the experimental operating
limitations are.

many experimental - racing/exhibition operating limitaitons from "back
in the day" are quite unrestrictive and literally worth their weight
in unobtanium.

however if you take your Ka6 or otherwise semi-common type certified
glider and put it into the experimental - racing/exhibition category
in the modern era it will have restrictions that involve faxing FSDO's
annual letters and getting special permission to operate more than X
miles from home. These in and of itself aren't too tough to deal with
but as a buyer why would I want the hassle when there are plenty of
other non-restricted gliders out there available to buy?

I own 3 experimental - amatuer builts which I thoroughly enjoy.
However the restrictions on them are no where near as restrictive as
experimental - racing/exhibition.

On Dec 6, 9:45*am, Tony wrote:
another consideration is how restrictive the experimental operating
limitations are.

many experimental - racing/exhibition operating limitaitons from "back
in the day" are quite unrestrictive and literally worth their weight
in unobtanium.

however if you take your Ka6 or otherwise semi-common type certified
glider and put it into the experimental - racing/exhibition category
in the modern era it will have restrictions that involve faxing FSDO's
annual letters and getting special permission to operate more than X
miles from home. *These in and of itself aren't too tough to deal with
but as a buyer why would I want the hassle when there are plenty of
other non-restricted gliders out there available to buy?

I own 3 experimental - amatuer builts which I thoroughly enjoy.
However the restrictions on them are no where near as restrictive as
experimental - racing/exhibition.

And to the question of limiting the pool of potential buyers..
Any buyer.. if he does his research and wants your experimental glider
will buy it.

However, if he does his research, he will find that he may have to
reaccomplish the CofA with updated Operating Limitations when he moves
the glider to a new location. Unless he is already on your airport.

We had some club members that bought a glider in KY and moved it west.
Then they found the Operating Limitations were written for the glider
being based in Penn. The entire time the glider was in KY, that owner
had not updated the Cof A or the Ops Limits, nor had he faxed in an
annual Program Letter as required. The entire time the glider was in
KY. It was flying illegally without a valid CofA.. and the A&P signing
off the "condition inspections" did not catch it.

They moved it west, had to reaccomplish the Cof A inspections and
Operating Limitations at an additional cost of about $500 to the DAR
and was issued a new CofA. Yes, the FSDO can process the Operations
Limitations and CofA, if they are used to dealing with gliders and
understand what they are doing. If not.. you can hand walk them
through it, with a little pain and frustration.

If the purchaser does his research and knows.. then it is not an
issue. He knows what he is up against.

Personally, an older experimental glider with the less restrictive
Operating Limitations are worth they weight in Gold. So are gliders
with Standard Certificates that do not have "Operating Limitations",
such as some of the newer 304CZ models.

Yes, an A&P can sign off the experimental "annual condition
inspection". An IA is required for a standard CofA.

T