On Aug 14, 6:37 pm, bildan wrote:

Every E&R Experimental operations limitations letter I've seen
requires operation in compliance with the AFM.

I can find no such requirement in mine. Does anyone else operating
experimental (racing/exhibition) have this requirement in their
operating limitations? If so, would you please email me a copy.

FAR Part 91.9(a) requires operation in compliance with an AFM if one is part of the
original airworthiness certification. (i.e JAR-22)

My operating limitations do not require compliance with all of part
91. They reference very specific sections. In reference to 91.9 they
state in para 21 - This aircraft shall contain the placards.,
markings, etc. required by 91.9.

91.9 (a) states

a) Except as provided in paragraph (d) of this section, no person may
operate a civil aircraft without complying with the operating
limitations specified in the approved Airplane or Rotorcraft Flight
Manual, markings, and placards, or as otherwise prescribed by the
certificating authority of the country of registry.

It is my interpretation that "or as otherwise prescribed by the
certificating authority of the country of registry" means that the
details of the operating limitations specified by FAA (the
certificating authority in the country of registry) take precedence.
Those operating limitations make specific reference to the requirement
for placards and markings but make no reference to the AFM.

Why would the operating limitations pick out specific sections of part
91, and specific data from the AFM, for inclusion unless only those
included references/restrictions were applicable? It would be far
simpler to state that the aircraft is required to operate in
accordance with Part 91.

I'm very sure (based on FAA interpretations) if an E&R airworthiness
certificate is issued for a glider which had a standard airworthiness
certificate with AFM in it's country of origin, the mere issuance of a
US E&R airworthiness certificate does not excuse the owner of the
glider from compliance with the AFM.

Can you please give me references to, or email copies of, any
interpretation that requires compliance with the AFM when the
operating limitations do not. Do those interpretations also relate to
compliance with an approved maintenance manual?

thanks

Andy