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#1
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Which aircraft certification is required for R&D?
I have not seen a definitive description as to what can be done in the way
of modifications to either "Special -LSA" or "Experimental -LSA" vs. "Experimental - Amateur Built". It seems that S-LSA cannot be modified by the owner/operator without the manufacturer's approval - Is this the equivalent of obtaining an "STC" (but issued by the manufacturer instead of the FAA)? What about "Experimental - LSA"? Can the owner/operator make significant modifications without the approval of the manufacturer - as is the case with the "Experimental - Amateur Built" and still be "legal" according to the type certificate issued? Here's why I'm asking - I would like to develop and test several avionics/autopilot/flight-control products and I will need a test-bed aircraft in order to do this. The amateur-built category doesn't seem to apply because this isn't just for personal education, etc. - there's a clear commercial intent and application. What should I be looking for? A certificated aircraft with some waivers/permits, etc. or an experimental? Thanks in advance for any input. |
#2
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On Sun, 21 Nov 2004 17:59:52 -0500, "Netgeek" wrote:
I have not seen a definitive description as to what can be done in the way of modifications to either "Special -LSA" or "Experimental -LSA" vs. "Experimental - Amateur Built". It seems that S-LSA cannot be modified by the owner/operator without the manufacturer's approval - Is this the equivalent of obtaining an "STC" (but issued by the manufacturer instead of the FAA)? What about "Experimental - LSA"? Can the owner/operator make significant modifications without the approval of the manufacturer - as is the case with the "Experimental - Amateur Built" and still be "legal" according to the type certificate issued? SLSAs (Special LSA, the production aircraft) must be maintained in strict accordance to the manufacturer's instructions, including performing only those modifications that the manufacturer approves and making all changes the manufacturer later specifies. However, if an owner does not WISH to maintain his aircraft to the manufacturer's requirements, the owner can change the aircraft to Experimental LSA. I haven't got a good read, yet, on what limitations for changes (if any) are placed on ELSA-category aircraft. You obviously don't have to conform to the consensus standard, but I'm not sure if "anything goes" or not. Other than former "fat" ultralights converted to ELSA, you are not likely to see too many ELSA aircraft for a while. The designs must first be certificated as Special Light Sport before they can be sold as ELSA kits. Here's why I'm asking - I would like to develop and test several avionics/autopilot/flight-control products and I will need a test-bed aircraft in order to do this. The amateur-built category doesn't seem to apply because this isn't just for personal education, etc. - there's a clear commercial intent and application. The Experimental/Amateur-Built category requires that the *construction* be undertaken for recreation or education. It does not require that the plane be operated solely for recreation or education...other than the limitation against commercial operation. So you can't hire someone to build an Experimental/Amateur-Built RV-7A for your company to use as a test bed. But you can put down the money and buy a used one, and use *it* for your test bed. In that case, you'd just need an A&P mechanic to perform the annual condition inspection...which would include whether your experimental hardware are safe for flight. What should I be looking for? A certificated aircraft with some waivers/permits, etc. or an experimental? You can buy a Cessna 172 and put it into the Experimental/Research and Development category. It's more paperwork-intensive (the airworthiness certificate will have to be renewed every year, and only required crews are allowed onboard) but if you're going for the certificated-aircraft market (as opposed to marketing strictly to homebuilts) you'll have to take this step at some point, anyway. Ron Wanttaja |
#3
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Thanks for the input, Ron. It seems that there are still quite a few
unresolved issues surrounding both SLSA and ELSA (at least in my feeble mind 8-)...... For some examples: Suppose that the owner of an SLSA wanted to install a simple autopilot. It seems that this would require the explicit approval of the manufacturer (sort of a "virtual STC"), and would also need to be installed and signed off by an A&P. Yet it appears that no additional equipment certification is required. So the questions then become: What types of equipment can or cannot be installed in an SLSA without the manufacturer's approval? Only items which are TSO'd? Is there going to be an additional STC approval process? Same rules as for Part 23? Suppose an owner of an ELSA wanted to do the same thing. Do the same rules apply as those for Experimental - Amateur Built or will there be a more restrictive set of rules applicable only to ELSAs? "Ron Wanttaja" wrote in message ... SLSAs (Special LSA, the production aircraft) must be maintained in strict accordance to the manufacturer's instructions, including performing only those modifications that the manufacturer approves and making all changes the manufacturer later specifies. Exactly. But within what limits? (e.g. non-TSO panel mount GPS is okay but Acme-brand wing leveler is not?). However, if an owner does not WISH to maintain his aircraft to the manufacturer's requirements, the owner can change the aircraft to Experimental LSA. I haven't got a good read, yet, on what limitations for changes (if any) are placed on ELSA-category aircraft. You obviously don't have to conform to the consensus standard, but I'm not sure if "anything goes" or not. Do you suspect (as I do) that this is going to be a real can of worms? Is it reasonable to allow an owner to do virtually anything he wants after purchasing a "99% kit"? Probably not... I can imagine that until this is clarified there are going to be some really disappointed folks who see the "Experimental" tag and then assume that they're getting the same privileges associated with "Amateur Built" without having to do any real building. The Experimental/Amateur-Built category requires that the *construction* be undertaken for recreation or education. It does not require that the plane be operated solely for recreation or education...other than the limitation against commercial operation. But if registered to a *company* - and I then hire a commercial pilot to operate it while I'm twiddling knobs, flipping switches and juggling test equipment - certainly that would be considered "commercial operation" would it not? So you can't hire someone to build an Experimental/Amateur-Built RV-7A for your company to use as a test bed. But you can put down the money and buy a used one, and use *it* for your test bed. In that case, you'd just need an A&P mechanic to perform the annual condition inspection...which would include whether your experimental hardware are safe for flight. Same problem as above? And an additional problem in that the original owner would be required to make any major modifications? You can buy a Cessna 172 and put it into the Experimental/Research and Development category. It's more paperwork-intensive (the airworthiness certificate will have to be renewed every year, and only required crews are allowed onboard) but if you're going for the certificated-aircraft market (as opposed to marketing strictly to homebuilts) you'll have to take this step at some point, anyway. It's starting to look like this may be my *only* legal option. Unless, of course, I build something as an individual, do all testing, etc. as an individual, and then transfer or license the end result somehow to the company entity. Hmmmmm..... May be time to try out some of the EAA troubleshooters in their legal department...8-)...... Ron Wanttaja Sounds like you'll have no shortage of material for some future articles, Ron! 8-) Thanks again, Bill |
#4
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On Mon, 22 Nov 2004 10:28:49 -0500, "Netgeek" wrote:
Thanks for the input, Ron. It seems that there are still quite a few unresolved issues surrounding both SLSA and ELSA (at least in my feeble mind 8-)...... Ohhh, yeah. It's still, really, a work in progress. If you need up-to-the-minute answers, contact Earl Lawrence at the EAA. Suppose that the owner of an SLSA wanted to install a simple autopilot. It seems that this would require the explicit approval of the manufacturer (sort of a "virtual STC"), and would also need to be installed and signed off by an A&P. You are correct that it needs the explicit approval of the manufacturer. However, it does not need an A&P signature, as a person with an LSA Maintenance (LSA-M) Repairman rating can do it as well. The LSA-M rating needs only a 120-hour training course, though who knows when (and if!) these will be offered. But for the LSA-M Repairman to sign it off, he or she must follow the specific instructions *supplied by the aircraft manufacturer*. I believe this will also apply to A&Ps performing the same function, as SLSAs must continue to conform to the manufacturer's standard. Yet it appears that no additional equipment certification is required. Absolutely correct. So the questions then become: What types of equipment can or cannot be installed in an SLSA without the manufacturer's approval? Only items which are TSO'd? No additional certification is required, so items installed do not need to be TSO'd or anything else. This is what will allow the SLSA manufacturers to use non-certified engines in their planes. But *everything* that gets installed in an SLSA must be approved by the aircraft manufacturer, and their approval means that the modification still meets the consensus standard. My suspicion is that they'll be reluctant to do this for third-party providers (why should they take the liability?). Is there going to be an additional STC approval process? Same rules as for Part 23? If the aircraft manufacturer requires Part 23 certification prior to their approval, then you have to perform the Part 23 process. If the manufacturer says, "Just paint the front face blue", that's all the approval process you'll need. Basically, the SLSA concept is to get the FAA out of the loop. There are no ADs on SLSA aircraft or parts (unless the part itself is certified). But manufacturer service directives are mandatory, with all the authority of ADs. Suppose an owner of an ELSA wanted to do the same thing. Do the same rules apply as those for Experimental - Amateur Built or will there be a more restrictive set of rules applicable only to ELSAs? According to the FAA write-up at the announcement of the FAA rules, if an owner of an SLSA does not want to continue to keep his or her aircraft in accordance to the manufacturer's configuration, they can change the certification to ELSA. *My* interpretation is that the owner can then do whatever he or she wants, just like Experimental/Amateur-Built. The owner of the ELSA can sign it off, just like the owner of an Ex/Am-Built. If the owner gets a LSA Inspector (LSA-I) Repairman Rating (which the EAA will have courses on) they can sign off the installation at every annual. The big difference between ELSA and Exp/Am-Built is that *anyone* can receive the LSA-I rating to do the annual inspections on their owned aircraft. .. SLSAs (Special LSA, the production aircraft) must be maintained in strict accordance to the manufacturer's instructions, including performing only those modifications that the manufacturer approves and making all changes the manufacturer later specifies. Exactly. But within what limits? (e.g. non-TSO panel mount GPS is okay but Acme-brand wing leveler is not?). Within the limits the SLSA manufacturer sets. If he will only approve Acme wing-levelers and won't even consider other models, that's it. However, if an owner does not WISH to maintain his aircraft to the manufacturer's requirements, the owner can change the aircraft to Experimental LSA. I haven't got a good read, yet, on what limitations for changes (if any) are placed on ELSA-category aircraft. You obviously don't have to conform to the consensus standard, but I'm not sure if "anything goes" or not. Do you suspect (as I do) that this is going to be a real can of worms? Is it reasonable to allow an owner to do virtually anything he wants after purchasing a "99% kit"? Probably not... I can imagine that until this is clarified there are going to be some really disappointed folks who see the "Experimental" tag and then assume that they're getting the same privileges associated with "Amateur Built" without having to do any real building. Actually, if they take that 16-hour LSA-I course, they *do* get the same privileges as an Exp/Am-Built owner. They can maintain and inspect their aircraft. The can of worms is whether there are going to be any restrictions on modifications. But let's not forget our brothers to the north. The Canadians have an "Owner Maintenance" option where an aircraft owner can change the certification of the plane and not only maintain it himself, but do stuff like install an auto engine. They seem pretty happy with it... The Experimental/Amateur-Built category requires that the *construction* be undertaken for recreation or education. It does not require that the plane be operated solely for recreation or education...other than the limitation against commercial operation. But if registered to a *company* - and I then hire a commercial pilot to operate it while I'm twiddling knobs, flipping switches and juggling test equipment - certainly that would be considered "commercial operation" would it not? You'd probably have to get an FSDO ruling on that, but on first glance, you're probably right. But I think you could probably handle it with creative job titles ("Vice President for Test Operations"... oh, by the way, can you ride with me and fly the airplane while I fiddle the knobs?). So you can't hire someone to build an Experimental/Amateur-Built RV-7A for your company to use as a test bed. But you can put down the money and buy a used one, and use *it* for your test bed. In that case, you'd just need an A&P mechanic to perform the annual condition inspection...which would include whether your experimental hardware are safe for flight. Same problem as above? And an additional problem in that the original owner would be required to make any major modifications? No, the owner of an Exp/Am-Built aircraft can modify his aircraft. An A&P (or the original builder with a Repairman Certificate) must approve the mods at the next annual inspection. Sounds like you'll have no shortage of material for some future articles, Ron! 8-) Thanks again, You're welcome! And my writing time is already allocated to something else for the next five months.... Ron Wanttaja |
#5
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You know, I'm really starting to have some doubts about the utility/value of
the Special-LSA ruling in general. Without some legislative changes regarding liability on the part of the manufacturers and potential aftermarket suppliers I wonder if this isn't going to be "The Death of General Aviation - Part II". No doubt there are going to be any number of lawyers just waiting to pounce on S-LSA manufacturers as soon as there's an accident or two - and those manufacturers will get to walk the plank just as their larger predecessors (e.g. Cessna, Piper, Beech, et. al.) have been forced to in the past. I don't think it's a stretch of the imagination to envision a whole new batch of ambulance chasers (ala James Sokolov) trolling the airwaves with ads looking for "victims" - "If you or a loved one have been involved in a Light Sport Aircraft incident please contact the law offices of Weel, Screwem and Howe..." (Note that I said "incident" because, as we all know, there's no longer any such thing as an "accident" - or individual stupidity - there's always *someone* who must be blamed 8-)... I applaud the few intrepid manufacturers that will brave this. I suspect that there will be few. As for the potential manufacturers of aftermarket equipment - they will have little incentive to develop and market products because they will need the individual approval of *each and every* SLA manufacturer in order to sell their products. And, as Ron has pointed out, why would they grant such approval at all since it only serves to increase their exposure to liability?!!! If the "old" rules appeared ponderous (i.e. TSO, Part 23, etc.) the "new" rules are worse *unless* additional methods for a blanket approval of some type can be developed. In other words, create some rules for industry "consensus standards" to be applied to add-on products (such as autopilots) which would allow them to be used in S-LSA aircraft *without* requiring individual manufacturer approvals. This gets the LSA manufacturer off the hook in terms of liability - and gives the aftermarket manufacturer an incentive to proceed. Garmin doesn't need Cessna's approval or endorsement for installation. However, Acme Audio Panels will need such approval for *every* installation - and it's not likely to be forthcoming under the current rules 8-)... IF (and this still seems to be a big IF) the Experimental-LSA category will allow more or less unrestrained modification, customization, and installation of newer avionics and systems by the owner - while reducing the burden of the 51% rule - the market might just take off in a big way! (No pun intended). Remains to be seen and it should be quite interesting over the next few years to see how this pans out. As for me, I think that the safe bet for my needs and desires at the moment lead directly back to the current Experimental/Amateur-Built category. And maybe that's the great news for the EAA and all of you builders out there - looks like this category is going to be around for quite some time - LSA or not 8-)....! Rant Off Bill |
#6
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On Mon, 22 Nov 2004 21:31:23 -0500, "Netgeek" wrote:
You know, I'm really starting to have some doubts about the utility/value of the Special-LSA ruling in general. Without some legislative changes regarding liability on the part of the manufacturers and potential aftermarket suppliers I wonder if this isn't going to be "The Death of General Aviation - Part II". No doubt there are going to be any number of lawyers just waiting to pounce on S-LSA manufacturers as soon as there's an accident or two - and those manufacturers will get to walk the plank just as their larger predecessors (e.g. Cessna, Piper, Beech, et. al.) have been forced to in the past. But they probably won't have two coins to rub together to start with ANYWAY, and if they're smart, they won't carry liability insurance. Without a deep pocket to go after, the liability lawyers won't be interested. Makers of current homebuilt kits are vulnerable, too. As for the potential manufacturers of aftermarket equipment - they will have little incentive to develop and market products because they will need the individual approval of *each and every* SLA manufacturer in order to sell their products. And, as Ron has pointed out, why would they grant such approval at all since it only serves to increase their exposure to liability?!!! If the "old" rules appeared ponderous (i.e. TSO, Part 23, etc.) the "new" rules are worse *unless* additional methods for a blanket approval of some type can be developed. Well...remember that the LSA rules were created for a specific purpose: To make new, low-cost simple aircraft available again. The main push was to remove the government from the process and let aircraft builders innovate. Making things easier for aftermarket component vendors was not a factor. IF (and this still seems to be a big IF) the Experimental-LSA category will allow more or less unrestrained modification, customization, and installation of newer avionics and systems by the owner - while reducing the burden of the 51% rule - the market might just take off in a big way! The difficulty comes in the process required to license a new airplane as an ELSA. To get approved as an ELSA kit, the design must first be certified as an SLSA. Joe Smith can't just build a prototype, fly off 40 hours, and start selling ELSA kits of the design. He must perform all the analyses and flight testing the consensus standard requires, and earn a SLSA certificate for his prototype. Only then can he sell ELSA kits. As for me, I think that the safe bet for my needs and desires at the moment lead directly back to the current Experimental/Amateur-Built category. Bill, it really depends on what type of aircraft you anticipate selling your product to. If you're going to sell it to Cessna and Piper owners, you'd best pick up a Cessna/Piper to use for flight testing. If your market is going to be RV/Glasair/Lancair homebuilders, pick up one of those types of planes for testing. And if you anticipate your product will be primarily of interest to LSA owners, work on making it capable of non-permanent mounting. That probably will still be legit, even under the LSA restrictions. Ron Wanttaja |
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