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Thread: CG Limits

  1. #11
    SWeidemann's Avatar
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    Default Re: CG Limits

    Guys,

    For a local opinion from an experienced builder friend of mine, who is also a long time EAA Chapter Technical Counselor for two chapters, I called him today.

    I'm going with his advice that new inspections by the Feds followed by designated flight testing would only be prudent for major changes that will affect the flight characteristics. Small changes that change or add (small) weight distribution should be recorded as far as what they weigh, where the changes are in the airframe, and be included in a re-done weight and balance, or better yet, an actual re-weighing to figure the flight range. A new engine, same model as the one removed has no significance.

    So far the only change (for weight & balance) I have made is the cabin heater kit. I will probably add the thermostats as well. My friend has a set of scales, so I may be re-weighing as well.

    Since this EAB plane was built by another, I will be getting my Condition Inspection (not an Annual) by my regular mechanic. He is aware of what I am doing. If I had a ELSA I would be taking the Rainbow repairman's certificate class. If I built a kit or something with the 51% rule I would certainly apply for my repairman's certificate for that aircraft.

    Skot
    Kitfox Vixen 912 ULS
    N24V at C29

  2. #12
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    Default Re: CG Limits

    An interesting article on changing from an SLSA to ESLA.
    Definitely some advantages to going ESLA. I have considered doing this with my plane.

    http://www.newplane.com/amd_download...0to%20ELSA.pdf
    Paul Zimmermann
    LSRM-A
    Garland, Texas

  3. #13
    SWeidemann's Avatar
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    Default Re: CG Limits

    Paul,

    As the current rules stand, you could convert your Kitfox SLSA to the ELSA category, take a two day maintenance course, and then be qualified to legally maintain your plane (and sign off the annual condition inspections). Sounds wonderful to me, however I would want to follow up what (if anything) is happening with the Craig Holmes FAA draft proposing restrictions. I have found old information about these ideas to change the regulations (from around March, 2014), but nothing since.

    Skot
    Kitfox Vixen 912 ULS
    N24V at C29

  4. #14
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    Default Re: CG Limits

    Skot,

    As the current rules stand, you could convert your Kitfox SLSA to the ELSA category, take a two day maintenance course, and then be qualified to legally maintain your plane (and sign off the annual condition inspections).
    Sorry, but that's not quite right. The 16 hours is for an inspection training course and only gets you the "Inspection Rating" of an LSA Repairmans Certificate. This only allows the holder to sign off on the annual condition inspection of his own ELSA.

    To get the "Maintenance Rating" of an LSA Repairmans Certificate you need 120 hours of FAA approved instruction for that rating.

    Full rule here: http://fsims.faa.gov/wdocs/8900.1/v0...05_006rev1.htm

    Greg

  5. #15
    SWeidemann's Avatar
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    Default Re: CG Limits

    Greg,

    So I can work on my own E-LSA and sign off the annual Condition Inspection with the 16 hour course. Right? That's the advantage I can see, and that is a big one since as I know arranging to get my plane to the mechanic's shop when he can do the Inspection is often an exercise in juggling schedules and going when the weather is good (if you fly it to his shop).

    On my Certified aircraft (not Experimental) as an owner pilot (with no special ratings other than being the owner and pilot) I can already do all the important things. I can take off cowls, grease wheels, adjust brakes, change oil and so on without any "illegal" behavior. IF I get into a gray area (of maintenance) that may not be included in my pilot/owner privileges I can still do it with supervision and approval by my favorite A&P, and of course he has the Inspection Authorization to sign off my owner assisted annuals.

    Skot
    Kitfox Vixen 912 ULS
    N24V at C29

  6. #16
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    Default Re: CG Limits

    Skot,

    The same applies as to certified aircraft. With an "Inspection Rating" you can only do "preventative maintenance" - just like certified.

    For any other "maintenance" you would need an A&P to sign off or hold the "Maintenance Rating".

    FAA definition of "maintenance":

    Maintenance. Inspection, overhaul, repair, preservation, and the replacement of parts, but excludes preventive maintenance.

    Greg

  7. #17
    Senior Member HighWing's Avatar
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    Default Re: CG Limits

    From reading this it appears there are lots of apparent approaches to the "legalities"

    I would like to post a little documented "facts" as I would call them. This is from my:

    Experimantal Operating Limitations
    Operating Amateur Build Aircraft
    Phase 2 document
    Operations Outside the Assigned Test Area
    The paragraph below is exactly the same wording as in the Phase 1 Document.
    Operations in the Assigned Flight Test Area

    Paragraph:

    (19) After incorporating a major change as described in 14 CFR & 21.93. the aircraft owner is required to reestablish compliance with 14CFR & 91.319(b) and notify the geographically responsible FSDO of the location of the proposed test area. The aircraft owner must obtain concurrence from the FSDO as to the suitability of the test area. If the major change includes installing a different type of engine(reciprocating or turbine) or a change of a fixed-pitch from or to a controllable propeller, the aircraft owner must fill out a revised FAA form 8130-6 to update the aircraft file in the FAA Aircraft Registration Branch. All operations must be conducted under day VFR conditions in a sparsely populated area. The aircraft must remain in flight test for a minimum of 5 hours. The FSDO may require additional time (more than 5 hours) depending on the extent of the modification. Persons nonessential to the flight must not be carried. The aircraft owner must make a detailed logbook and maintenance records entry describing the changes before the test flight. Following satisfactory completion of the required number of flight hours in the flight test area, the pilot must certify in the records that the aircraft has been shown to comply with 14CFR &91.319(b), must be recorded in the aircraft records with the following, or similarly worded statement: "I certify that the prescribed flight test hours have been completed and the aircraft is controllable throughout its normal range of speeds and throughout all maneuvers to be executed, has no hazardous characteristics or design features and is safe for operation. The following aircraft operating data has been demonstrated during the flight testing: Vso_________, Vx_______,
    and Vy________, and the weight_______, and CG location _______ at which they were obtained."

    Notice all reference to the person performing the modification or submitting data to the FAA is referred to as the "Owner" or the "Pilot". There is no reference to any need for a certificated person to be involved either in the major modification or in the log book entry or in the notification of the FSDO. Also notice that in the occasion of an engine or prop type change the notification is made to the Registration Branch to "update the file".

    I am not one to ignore the regs or prudent behavior especially since I had to submit all my records after our "hard landing" destroyed our first Kitfox, but this seems all pretty simple and straightforward. Also keep in mind that this document was presented to me and signed by Richard T Dilbeck, Aviation Safety Inspector, Sacramento FSDO.

    With regard to the hard landing. The ultimate enforcer, in my opinion, is your insurance company. My understanding is that if you are in violation of the FARs, your insurance company is likely to say, "Hey, thanks for the premiums all these years, see you later."
    Lowell Fitt
    Goodyear, AZ


    My You Tube Channel

  8. #18
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    Default Re: CG Limits

    Quote Originally Posted by SWeidemann View Post
    Paul,

    As the current rules stand, you could convert your Kitfox SLSA to the ELSA category, take a two day maintenance course, and then be qualified to legally maintain your plane (and sign off the annual condition inspections). Sounds wonderful to me, however I would want to follow up what (if anything) is happening with the Craig Holmes FAA draft proposing restrictions. I have found old information about these ideas to change the regulations (from around March, 2014), but nothing since.

    Skot
    I am taking the 120 hour Rainbow Aviation class in January, Paul Leadabrand recommended taking the class, he took it so he maintains his own fleet. He does an excellent job. With the Light Sport Repairman Certification, I will be able to do my own work. So that will resolve one issue. However, I am still considering converting the Kitfox SLSA to the ELSA, making changes is a real painful process, requiring a long round trip flight.
    Paul Zimmermann
    LSRM-A
    Garland, Texas

  9. #19
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    Default Re: CG Limits

    Lowell,

    If you are referring to the 1st part of this thread - I disagree.

    Nowhere in what you posted does it say the owner or pilot can make the modification, alteration or repair. It essentially says - the owner is responsible for the proper documentation of it.

    Your post further states in 3 places, it all has to comply with CFR 14. CFR 14 part 43.7 only allows a a private pilot to return an aircraft to service after preventative maintenance - for everything else you either need to be an A&P or hold the Repairmans Certificate. As pertains to EAB in this scenario.

    So with EAB, he could do the work under the supervision of an A&P, but an A&P would have to sign off to return the aircraft to service. As he stated he bought the aircraft used, he does not hold the Repairmans Certificate.

    The "facts" of 43.7 are here: http://www.ecfr.gov/cgi-bin/text-idx...43_17&rgn=div8

    If you are referring to the last part of the thread - it doesn't apply at all as we were discussing SLSA converted to ELSA not EAB.

  10. #20
    Super Moderator Av8r3400's Avatar
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    Default Re: CG Limits

    Owning an E-LSA registered aircraft and having taken the 16 hour class, here is what I was told to this specific question.

    My light sport repairman's license, specified to my aircraft only, allows me to do any and all maintenance and modifications within the instruction of the operating limitations (eg notifying the FAA of a major change) as I see fit. It allows me to do the annual condition inspection and sign off the aircraft as airworthy. In simpler terms this license has given me the "repairman's certificate" for this particular aircraft.

    If I wanted to work on a different aircraft that I do not own, the 120 hour class is required.
    Av8r3400
    Kitfox Model IV
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