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 4, 8:39*pm, Darryl Ramm wrote:
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 athttp://rgl.faa.gov/Regulatory_and_Guidance_Library/rgOrders.nsf/0/177...

--

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.- Hide quoted text -

- Show quoted text -

Ahhhhh................. reg-mongers arise..................it must be
wintertime in the US!
Merry Christmas,
JJ

I am compelled to make a distinction between properly complying with
the regulations and being in a noncompliance state. I just purchased
a very nice single place ship for our club (November of this year).
When I asked the owner for a copy of his program letter (so I could
use it as a template) he had no idea what I was referring to. After
arriving for the prepurchase inspection I noticed that the last time a
program letter was filed was in 2003 when the glider was imported from
Canada. The operating limitations clearly specified the need for an
annual program letter. Obviously some owners of "experimental racing/
exhibition" ships have no clue as to what their ops limitations
specify. It seems some people confuse "experimental" for "do as I
please". Please protect yourself by reading your operating
limitations and understanding each line item. The operating
limitations and any supporting documents called for such as "weight
and balance", "program letter" etc. must be on board the glider during
flight.

Lane Bush
XF

On Dec 5, 7:34*am, JJ Sinclair wrote:

Ahhhhh................. reg-mongers arise..................it must be
wintertime in the US!
Merry Christmas,
JJ

Not a reg-monger, JJ. Just one who has to live with them day in and
day out. And just like I said, "You get exactly what you paid for
with anything you read on RAS." I discovered just after hitting "Send"
that I was in fact looking at 8130.2G. 8130.2F is still in effect
until April of 2011.

But, it is wintertime here in the US, that is for sure!

Steve Leonard

On Dec 5, 11:00*am, lanebush wrote:
I am compelled to make a distinction between properly complying with
the regulations and being in a noncompliance state. *

Well I read all your post several times but I don't see where you make
that distinction. Seems to me the two are equivalent in that failing
to do one will always result in the other.

I just spent over an hour going through the sections of Order 8130.2G
that apply to group 1, and then reviewing my Operating Limitations.
It is clear to me that my operating limitations do not comply with the
group 1 requirements of 4113. They have several paragraphs that are
not currently called out by the order and others do not match the
wording of the boilerplate.

I'm also puzzled by the fact that 4110 assigns a requirement for a
geographic area only to groups 6 and 7. I don't see a requirement
for a defined geographic area for group 1 (except for phase 1 flight
test). Did I miss it or is this something that has changed since my
operating limitations were issued in 2002. Did the 300nm radius
requirement go away?

No, I don't plan to call my local FSDO, but I will have a copy of
Order 8130.2G on hand if/when I become the target of a FSDO
inspection.

Andy

On Dec 5, 1:26*pm, Andy wrote:
On Dec 5, 11:00*am, lanebush wrote:

I am compelled to make a distinction between properly complying with
the regulations and being in a noncompliance state. *

Well I read all your post several times but I don't see where you make
that distinction. *Seems to me the two are equivalent in that failing
to do one will always result in the other.

I just spent over an hour going through the sections of Order 8130.2G
that apply to group 1, and then reviewing my Operating Limitations.
It is clear to me that my operating limitations do not comply with the
group 1 requirements of 4113. They have several paragraphs that are
not currently called out by the order and others do not match the
wording of the boilerplate.

I'm also puzzled by the fact that 4110 assigns a requirement for a
geographic area only to groups 6 and 7. * I don't see a requirement
for a defined geographic area for group 1 (except for phase 1 flight
test). *Did I miss it or is this something that has changed since my
operating limitations were issued in 2002. *Did the 300nm radius
requirement go away?

No, I don't plan to call my local FSDO, but I will have a copy of
Order 8130.2G on hand if/when I become the target of a FSDO
inspection.

Andy

The following web site has some good info on aircraft certification.
Two weeks ago I met with an Atlanta FSDO inspector and we rewrote my
operating limitations to clean up some outdated language. The 300
mile radius was in effect at that time. Try this website for more
info http://www.faa-aircraft-certificatio...ir-racing.html

Lane
XF