Re-registering SLSA to ELSA...

[dholly 718]

I had a WTB ad on Barnstormers for an Aeropro CV Aerotrek engine mount and cowl. I had figured it was likely one of the best options to fit on my Avid+ project. Well, I got a call from someone who actually had the parts, and the rest of a damaged low-time plane as well. Long story short, the damage looked quite repairable and price so right I agreed to buy the whole darn 'pile of parts' (no airworthiness certificate and de-registered for liability reasons). I'm convinced that repair will be cost effective and after my A&P returns from Sun 'n Fun next week we will see what he says. If I decide to go the repair route, I will obviously need to register the aircraft and I believe my only real option is ELSA. Typically, new aircraft must undergo the 40-hr flight test, however, since this was a previously registered, manufacturer-built SLSA with prior airworthiness certificate, I wonder how much, if any, of the 40-hr requirement can be eliminated (which I understand is at the discretion of the DAR).

For example, an SLSA receives the initial production flight-test airworthiness permit and then is flight tested by the manufacturer. Following successful completion, the aircraft is then eligible for a permanent SLSA airworthiness certificate, usually issued in the name of the importing dealer. The buyer then registers the new aircraft in his/her name at purchase. Of course, as an SLSA, the owner can not perform maintenance, inspections or repair without the proper certifications and/or manufacturer's written letter of authorization. If an owner of an S-LSA aircraft wants to change it to an E-LSA (in accordance with 14 CFR 21.191(i)(3)), primarily to do their own maintenance and make modifications without the need for a manufacturer LOA, the following steps must be completed:

- Complete a new 8130-6 (Application for Airworthiness Certificate.

- Create a Program letter.

- Provide current air airworthiness certificate for the airplane and current flight restrictions (these get turned in and you receive a complete new set for ELSA).

- Provide aircraft/Engine log books showing the aircraft is current and all AD's complied with.

- I have read where some who went ELSA ended up with a 5 hour Phase I flight restriction of 100 miles, while others had no Phase I or restrictions.

Again, assuming the aircraft is repaired to manufacturer specs and nothing else changed prior to registration, because the aircraft has been fully tested and held a prior airworthiness certificate, it seems like a whole bunch of bureaucratic overkill to require and repeat the same 40-hr test as a one-off experimental. Anyone have experience, thoughts, recommendations, etc. to help make this case when I speak to the DAR?

Secondly, let's assume I want to fly my ELSA as a sport pilot and I register it as a land airplane with gross weight of 1320 lbs. Then, after the restrictions have been flown off, I want to put it on floats. I understand installing the floats will be considered a major change, however, that will not be a problem if I ensure my operating limitations allow a major change. I suspect the first time I install the floats I will need to put the aircraft back into a flight-test period of a minimum of 5 hrs. min., during which the aircraft handling with the floats installed is tested (at it's new gross weight up to 1430 lbs. if elected). After successful completion of flight testing with floats, I should then have the option of operating the aircraft on floats at the 1430 lb. gross weight and on wheels at the 1320 lb. gross weight. It appears you simply make a logbook entry each time you switch from wheels to floats or vice versa. Can anyone confirm that requirement?

Exciting, but my poor Avid+ project keeps getting pushed farther and farther back into the corner.

[Av8r3400 1179]

Good luck, Doug.

I think you may have a pandoras box type nightmare trying to reregister a deregistered, certificated airplane now as an experimental. I'll be interested to see how this plays out.

Seriously, good luck. I hope you can get it done.

[marshawk 82]

Nice looking plane there Doug, I have no idea on the paper work but hope it works out for you, still plugging away on my Avid ,once I get the cowl finished I'll post a picture

[dholly 718]

Good luck, Doug.

I think you may have a pandoras box type nightmare trying to reregister a deregistered, certificated airplane now as an experimental. I'll be interested to see how this plays out.

Seriously, good luck. I hope you can get it done.

Larry, have a little faith will ya! I understand your concern with the gov't bureaucracy but just because an aircraft has been deregistered, doesn't mean it can't ever be registered again. Heck, that happens all the time. And remember, this is about an experimental, not standard certified, aircraft. Standard airworthiness certificates are airworthiness certificates issued for aircraft type certificated in the normal, utility, acrobatic, commuter, or transport category, and for manned free balloons, and for aircraft designated by the FAA as special classes of aircraft. Special airworthiness certificates are primary, restricted, limited, light-sport, and provisional airworthiness certificates, special flight permits, and experimental certificates. At issue is whether you can change a special airworthiness certificate classification after an aircraft has already been issued one (whether or not that original special airworthiness certificate has expired or been surrendered) and I believe you can... subject to certain restrictions, of course (ie., one no-no is you can not change from E-AB to ESLA).

As I understand...

Aircraft previously issued an LSA category airworthiness certificate under FAR §21.190 (Special Airworthiness Certificate, or SLSA) are eligible for an experimental LSA airworthiness certificate. In fact, FAR §21.191(i)(3) specifically allow and address aircraft that "Has been previously issued a special airworthiness certificate in the light-sport category under §21.190.". The applicant must provide documented evidence that the aircraft has been manufactured and constructed to the applicable consensus standard (Aeropro CV has received this approval of course, it is a requirement for a SLSA manufacturer/importer) except when the aircraft is eligible in accordance with FAR §21.191(i)(1) (not applicable to me - this was the one-time conversion to ESLA 'window' offered to 'Fat Ultralights' and has expired).

Without a current airworthiness certificate, one needs to go through the entire process of getting a new registration, ie. inspections, new N-number, Phase I and II etc., just like is necessary when first registering and seeking an airworthiness certificate for your newly built Experimental-Amateur built LSA. Moving an existing SLSA to ELSA also requires changes to the aircraft’s placards, the size of the N number, an aircraft inspection, and the issuance of a new airworthiness certificate and operating limitations.

Upon satisfactory completion of the records inspection, documentation review, and aircraft inspection by the appropriate DAR, the FAA will complete experimental LSA certification by issuing an airworthiness certificate for the purpose of operating an experimental LSA with appropriate operating limitations to be attached to Form 8130-7. Under FAR 91.319(e), the FAA may prescribe any additional limitations in phase I or phase II deemed necessary in the interest of safety. When the experimental LSA certification is to be issued for an unlimited duration, the operating limitations may be prescribed in two phases in the same document as follows:

- For the phase I limitations, the FAA will prescribe all operating limitations appropriate for the applicant to demonstrate compliance with FAR 91.319(b) in the assigned flight test area. This includes a limitation requiring the owner/operator to endorse the aircraft logbook with a statement certifying that the prescribed flight hours have been completed, and the aircraft has been shown to comply with FAR 91.319(b) and the requirements of the applicable consensus standard. The owner/operator may then operate in accordance with phase II.

- For the phase II limitations, the FAA may prescribe operating limitations for experimental LSA for an unlimited duration, as appropriate (ie., Day VFR only) .

If the aircraft meets the requirements of the experimental LSA certification, upon completion of Phase I, the FAA will issue the special airworthiness certificate (Form 8130-7) with operating limitations.

So I do think I can get this thing registered as an ELSA, however, my question again...

I have complete aircraft, engine and prop logs as well as the Pilot Operating Handbook w/ Flight Training Supplement and Maintenance Manual to satisfy the records requirement. I have the original Operating Limitations of the SLSA manufacturer that were attached to the original airworthiness certificate. Unlike the Operating Limitations typically attached to a E-AB airworthiness certificate, there is NO mention of Phase I testing or restrictions. All the requirements to satisfy Phase I flight testing have obviously already been accomplished and satisfactorily recorded by the SLSA manufacturer. This is why, assuming all repairs return the aircraft to it's original state without significant modification, I am wondering if the DAR might be willing to forego the standard 40 hr Phase I testing in favor of a 5 hr Phase I, or something more akin to the testing requirement when making a 'major change'.

Was just asking if anyone had any experience in this or heard of such a thing. In any event, we'll see what my DAR has to say about this soon enough...

Edited 26 Mar 2012 by dholly

[Russ. 7]

Larry, have a little faith will ya! I understand your concern with the gov't bureaucracy but just because an aircraft has been deregistered, doesn't mean it can't ever be registered again. Heck, that happens all the time. And remember, this is about an experimental, not standard certified, aircraft. Standard airworthiness certificates are airworthiness certificates issued for aircraft type certificated in the normal, utility, acrobatic, commuter, or transport category, and for manned free balloons, and for aircraft designated by the FAA as special classes of aircraft. Special airworthiness certificates are primary, restricted, limited, light-sport, and provisional airworthiness certificates, special flight permits, and experimental certificates. At issue is whether you can change a special airworthiness certificate classification after an aircraft has already been issued one (whether or not that original special airworthiness certificate has expired or been surrendered) and I believe you can... subject to certain restrictions, of course (ie., one no-no is you can not change from E-AB to ESLA).

As I understand...

Aircraft previously issued an LSA category airworthiness certificate under FAR §21.190 (Special Airworthiness Certificate, or SLSA) are eligible for an experimental LSA airworthiness certificate. In fact, FAR §21.191(i)(3) specifically allow and address aircraft that "Has been previously issued a special airworthiness certificate in the light-sport category under §21.190.". The applicant must provide documented evidence that the aircraft has been manufactured and constructed to the applicable consensus standard (Aeropro CV has received this approval of course, it is a requirement for a SLSA manufacturer/importer) except when the aircraft is eligible in accordance with FAR §21.191(i)(1) (not applicable to me - this was the one-time conversion to ESLA 'window' offered to 'Fat Ultralights' and has expired).

Without a current airworthiness certificate, one needs to go through the entire process of getting a new registration, ie. inspections, new N-number, Phase I and II etc., just like is necessary when first registering and seeking an airworthiness certificate for your newly built Experimental-Amateur built LSA. Moving an existing SLSA to ELSA also requires changes to the aircraft’s placards, the size of the N number, an aircraft inspection, and the issuance of a new airworthiness certificate and operating limitations.

Upon satisfactory completion of the records inspection, documentation review, and aircraft inspection by the appropriate DAR, the FAA will complete experimental LSA certification by issuing an airworthiness certificate for the purpose of operating an experimental LSA with appropriate operating limitations to be attached to Form 8130-7. Under FAR 91.319(e), the FAA may prescribe any additional limitations in phase I or phase II deemed necessary in the interest of safety. When the experimental LSA certification is to be issued for an unlimited duration, the operating limitations may be prescribed in two phases in the same document as follows:

- For the phase I limitations, the FAA will prescribe all operating limitations appropriate for the applicant to demonstrate compliance with FAR 91.319(b) in the assigned flight test area. This includes a limitation requiring the owner/operator to endorse the aircraft logbook with a statement certifying that the prescribed flight hours have been completed, and the aircraft has been shown to comply with FAR 91.319(b) and the requirements of the applicable consensus standard. The owner/operator may then operate in accordance with phase II.

- For the phase II limitations, the FAA may prescribe operating limitations for experimental LSA for an unlimited duration, as appropriate (ie., Day VFR only) .

If the aircraft meets the requirements of the experimental LSA certification, upon completion of Phase I, the FAA will issue the special airworthiness certificate (Form 8130-7) with operating limitations.

So I do think I can get this thing registered as an ELSA, however, my question again...

I have complete aircraft, engine and prop logs as well as the Pilot Operating Handbook w/ Flight Training Supplement and Maintenance Manual to satisfy the records requirement. I have the original Operating Limitations of the SLSA manufacturer that were attached to the original airworthiness certificate. Unlike the Operating Limitations typically attached to a E-AB airworthiness certificate, there is NO mention of Phase I testing or restrictions. All the requirements to satisfy Phase I flight testing have obviously already been accomplished and satisfactorily recorded by the SLSA manufacturer. This is why, assuming all repairs return the aircraft to it's original state without significant modification, I am wondering if the DAR might be willing to forego the standard 40 hr Phase I testing in favor of a 5 hr Phase I, or something more akin to the testing requirement when making a 'major change'.

Was just asking if anyone had any experience in this or heard of such a thing. In any event, we'll see what my DAR has to say about this soon enough...

Doug,

Looking forward to getting back home in about 2 weeks. I see we will have alot to talk about, with my repair work, and your new project.

I beleive you are correct in your thinking. I have heard of 5--20hrs. times. Russ.

Edited 27 Mar 2012 by Russ.

[akflyer 1427]

I have a poor outlook on things such as this.. if they give you a hard time and wont issue a certificate, the only way they could keep me from flying it is to lock me up. I had to tell them that when they were giving me grief over issuing a new certificate for mine because the original burned up in a house fire. As soon as I told them I was going to fly with or without that lil piece of paper, they were VERY prompt in getting it to me.

[dholly 718]

Well I talked to the DAR today. Very helpful, he has done this before. Besides paperwork, he will require a condition inspection by an A&P or IA, not an LSA Repairman, and only 5 hr. Phase I flight tests.

[SuberAvid 617]

Wow Doug, good job sorting that out. I thought what you were proposing was near impossible. Good information.

[dholly 718]

Maybe not that difficult to go SLSA --> ELSA with the right papers, but impossible to go back to SLSA with out approval from the manufacturer... which ain't ever gonna happen.

[Av8r3400 1179]

Are you going to have their support for parts at all?

[dholly 718]

Dunno. I haven't called the dealer yet, been too busy with work related priorities at quarter end. I do know the question of purchasing new wings was brought up by the prior owner and the dealer seemed less than enthusiastic about it as he would rather have the container filled with a complete, new high profit-margin SLSA. Apparently they are selling all they can import and are weeks into the waiting list. What recession, huh? In any event, a handful of parts such as ribs and drag tubes take up a whole lot less space so I am hopeful on that. If the dealer says no, I still have the option of going direct to the manufacturer and buying parts from their kit vs. SLSA division, or making my own.