changing operating limitations

This whole thing seems to be, once again, an issue of terminology...

We are dealing with four separate types of aircraft:

1. Certified - Built under a type certificate, with the type certificate
being approved by the FAA. Some of these aircraft may also meet the Light
Sport Aircraft requirements, and may be flown by holders of a Sport Pilot
Certificate; others require at minimum a PPL (or Rec Pilot) license.

2. Experimental - Given an airworthiness certificate on a case-by-case
basis. Requires at minimum a PPL (or Rec Pilot) license.

3. Special Light Sport Aircraft - Built to consensus standards adopted by
the FAA. May be flown by a Sport Pilot or above.

4. Experimental Light Sport Aircraft - Given an airworthiness certificate on
a case-by-case basis. May be flown by a Sport Pilot or above.

That portion of the FAA regs requiring that the aircraft must have met the
Light Sport Requirements since it was built has to do with Certified
aircraft that, under their original type certificate, met the LSA
requirements, and have never been modified to an extent that would take them
outside of the LSA requirements.

In other words, if a Certified aircraft met the LSA requirements under it's
original type certificate but was later modified in such a manner that it no
longer met the LSA requirements, it cannot be "rolled back" by removing the
modifications and still be an LSA, even though it would then be at it's
original type certified state.

Again, this applies to Certified Aircraft.

As far as converting an Experimental aircraft into an Experimental Light
Sport Aircraft, allow me to SPECULATE...

I would GUESS, that you would first need to de-register the aircraft and
"turn in" the airworthiness certificate. At that point, you could then
modify the aircraft to meet the eLSA specs and then go through the eLSA
certification process.

Again, that part is just a guess...









"T o d d P a t t i s t" wrote in message
...
"Russell Duffy" wrote:

"Light-sport aircraft means an aircraft...

This certainly uncovers some of the confusion. We need to make sure and
distinquish between "light sport aircraft", "experimental light sport
aircraft", and aircraft that can be flown by sport pilots.

I'm not sure what confusion you think this clears up. I
agree there are differences between the aircraft definitions
above, but if you want to fly an airplane with a Subpart J
"Sport Pilot" certificate, the airplane must meet the
definition of an LSA I quoted. The whole purpose of
"modifying" the RV, I presumed, was to get it inside the LSA
definition.

The original
question asked about a homebuilt, and specifically an RV-3, so I assumed
it
would have an experimental certification.

I presume that too, but he wanted it to meet the definition
of a "Light-sport aircraft" so he could fly with a DL, and
no medical. If it did not meet the requirements I quoted,
he'd have to have a medical.

My understanding is that it would be possible to take an experimental
aircraft, and modify it so that it would meet the limitations of the
sport
pilot.

Not if it had an "original certification" outside the
limits. I suppose there's an opening for taking it apart,
and building something new from some/all of the parts, but
that's more than just modifying it.

I don't agree with this. I've certified 3 experimental aircraft, and not
one single time has the "maximum airspeed in level flight with maximum
continuous power(VH)" ever been listed anywhere.

What don't you agree with? I didn't say it did have such a
speed listed - did I? Nonetheless, according to the FAA
there *is* such a speed. I've got no idea how it's
determined for an experimental. I presume that the builder
has some control over it, since he's got control over the
entire aircraft.

The Vne is listed, but
many aircraft have Vne's that can't be achieved in level flight, so it
doesn't mean the plane will do it.

Agreed. Anyway, Vne is only important for gliders as LSAs.

The operating limitations received from the FAA with the airworthiness
certificate don't list ANY speeds, as these must be determined during the
phase one test period, and noted in the aircraft log. The log can be
modified over time to reflect changes in the aircraft as well, so if
modification is made that would reduce the weight, airspeed, etc, it
appears
to be perfectly legal to change the log to reflect that mod.

If it's your opinion that an experimental aircraft capable
of exceeding Vh of 120 knots when originally certified can
later be modified to comply with the LSA definition, then we
completely disagree. If you are saying the builder can
build an LSA compliant aircraft within the specs and *then*
get it certified, we agree. If you are expressing some
opinion as to *how* to determine the Vh of an aircraft like
an RV-3, I'm neutral at this point, as I don't know what the
FAA would find to be acceptable. It's possible that no one
knows for sure right now.

Getting the paperwork right may be enough, as long as it's
done before certification. It's possible a minor mod, such
as restricting throttle might be enough. I'm interested in
the answer, not trying to give one.

That does not look like the "exact question" asked above.

Let's see... The question I asked AOPA was- "I currently have an RV-3
with a
two rotor Mazda engine. If I put a single rotor engine, with far less
power, and use a prop that will reduce the top speed to 138 mph, could it
be
flown by a sport pilot?" Seems pretty close to the exact question to me
:-)

Perhaps I misunderstood. First you said:

"My understanding is that it would be possible to take an
experimental aircraft, and modify it so that it would meet
the limitations of the sport pilot. "

I took that to be a question about modifying an aircraft
that was already certified.

Then you said:

"I even asked AOPA this exact question about this a week or
so ago, and their opinion was that the plane would have to
be truly incapable of exceeding the speed limit, rather than
just an RPM limitation. "

That looked like an answer to the question of how to
determine Vh on an RV-3. I assumed the AOPA would know you
can't bring an aircraft that was outside LSA limits into LSA
limits. If they gave you the second answer to the first
question, they didn't give you enough information.

I know someone who has an aircraft with two different
certified max gross weights (one below LSA max, one above)
depending on the type of gear installed.

It was upgraded to the higher max gross at one point in its
life. He has the old gear. He's been told, and finally
concluded himself, that under the regs he cannot go
backwards to meet the LSA requirements by reinstalling the
old gear.

T o d d P a t t i s t
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