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ELSA saga continues

 
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budyerly(at)msn.com
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PostPosted: Thu Jul 22, 2010 12:54 pm    Post subject: ELSA saga continues Reply with quote

<?xml:namespace prefix="v" /><?xml:namespace prefix="o" /><![endif]--> Fred,
Background,
12AY started as Marvin Alverez's aircraft 139AB, fixed pitch Classic Trigear. I bought it to use as a test bed, but I had to rebuild so much of it, replace wings, gut the fuselage to fix the gear, wing incidence problems required a full redo of the cockpit sides, pulled the top and replaced, pull out the pitch system, fuel tank and tail tube, rebuilt the stabs, rebuilt the foam fin, replaced the doors and converted the engine mount and cowl for the XS, so it is now a new kit 054A and my FSDO allowed it as a new build. 800 hours in that sucker less paint and finish. The only thing original is the rudder hinges. Even the original rudder delaminated. Hell of a deal, but I am too picky I guess, anyone else would have just flown it as it did so, provided you didn't stall it.

So, just prior to registration of my aircraft in Dec 2009 I did the following. I ran the conversion problems of the Europa Classic Kit by my FSDO, (many different answers from FSDOs and the FAA home office) and as the owner/builder, and since I am doing a modification by adding VGs within the phase one modifications ruling during the 40 hour fly off, I am establishing my aircraft as an Experimental Amateur Built LSA (EABLSA) through flight test (that controllable at 45 kts rule is tough with a short wing and my max continuous speed is 122). My new modifications made in the 40 hour fly off, satisfies that my intent was to make it an amateur built experimental LSA from the start and the plane needed tweaking. Logged it all in the book for sure. I have not lost my medical, I'm doing this to give you guys who haven't finished your aircraft an opportunity to work within the rules and continue to finish your aircraft as an Experimental Amateur Built LSA if you have lost your medical.

Fred, your ELSA assumption is correct! The rules suck. I have test flown and established that my aircraft meets EABLSA rules. Should I now make changes which removes the plane out of EABLSA, it can never be an LSA again according to the FAA maintenance guys! Here is the rub, my 12AY will also be used to test the new AP420 constant speed and that will not make it eligible for LSA unless I lie about it and never log the conversions. I'm not keen on that. The prop change is considered by the maintenance guys as a major modification and requires another log book entry and a mother may I from the FSDO. My FSDO disagrees, but it is looking that will be overruled by the maintenance guys at FAA under the LSA . The Registration of my aircraft, and my airworthiness certificate does not note the plane has a constant speed prop or not on an airworthiness certificate on a Tri-gear Experimental Amateur Built aircraft that just happens to meet LSA criteria. It is confusing. Technically, because of the rules that the LSA qualified plane "continuously" has met the LSA criteria , although I can pull the fixed pitch prop and VGs off, put on another prop, take it off again, put the VGs and fixed prop back on and tweak my flap (my wing area is a bit less than the XS at only 96 square feet so I have to do that on my plane) I have removed it from LSA criteria by changing the prop and or pull my VGs.

To all,
I talked with Larry Buchannan and Edsel Ford at the FAA (LSA division) and Brad Outlaw of the DAR area (he is the guy who helped me with the proper way to convert to the MG) and they agree that this flight test method I am using is allowable within the LSA and Experimental rules. As for modifying a flying a Classic, the problem is you get different answers. Suffice to say, if a plane was a mono wheel (a retractable gear aircraft) on its airworthiness certificate, never intended as an LSA or to meet it's criteria, it has not met the "continuous" use in the LSA criteria. FSDOs didn't mind the prop change (or gear during phase 1), but the maintenance division was adamant that it is a major modification, and the plane did not continuously meet the LSA criteria even if modified during the 40 hour phase 1. Granted the maintainers work in the certified world, the point is, the flying mono to trigear is a major modification (not just a minor mod which I prefer) and the plane was a complex aircraft and never intended nor did it meet the continuous LSA criteria (that's true). As I write this, the experimenters and maintainers are discussing that an experimental amateur built aircraft is not built with a manufacturers equipment list, so changing the prop, or other equipment even with another fixed prop is a bit of a rub.

I tried to weasel my way into also allowing the flying classic mono-wheel to be converted and that is, according to the FAA regulations, illegal. I argued that the experimental plane is a continuous experiment and actually rarely does the owner call it truly completed. The experimenters know what I mean, we are always tweaking equipment, engine, props, fuel system, drag devices etc. Once Phase 1 is completed, the plane, according to the maintainers is technically set in stone, FSDOs know better and don't want to be bothered by all the little stuff we do, and prefer to only know about major changes such as gear and wings. LSA criteria though is set in stone ( but it is not necessarily solid). The only win I had was with the vortex generators. They are not lift augmenting devices and as such do not fall under the major modification changes and can be added.

Please don't fudge your log books (for those of you who have them and or failed to make the Phase 1 complete write up) to try to do this. It is not worth it.


This LSA conversion I am doing to the Europa kit is allowable, provided the owner never registered the plane at a gross weight that exceeds 1320 lbs and you make it meet the LSA criteria. Hell, there are guys flying RV9s as LSAs. That's not right, as if he ever fills the tanks full with two people (170 lbs each), it is no longer an LSA (to the purist), but it meets the criteria.

Final advice to Europa Owners,
Conversion of a flying mono or trigear classic to Experimental Amateur Built Light Sport Aircraft is not possible. Even the Tri-gear didn't continuously meet the criteria and is prohibited.

This also brings up what is the proper way to do a MG conversion (and it provides an example for the FAA to work with to give the FSDOs ).
Example I used with the FAA: Europa Classic trigear registered at 1320lbs.
Builder contacts his DAR and says I am attempting to fly my aircraft as an LSA come and give me an airworthiness inspection. Initial stall speed in tests of 49 KTS observed.

Owner/manufacturer modifies to meet LSA and adds vortex generators etc and meets the basic LSA criteria.
Completes his fly off and the aircraft must stay an LSA always.

Now, let's say I want to add MG wings, I cannot add MG wings and fly then go back to LSA because the aircraft was not continuously flown in the LSA criteria.

For you MG guys, How do you convert properly your XS or Classic to a MG.
Owner contacts his FSDO and says I am adding MG wings to my Europa XS/Classic.
He requests: I will need my original test fly area (or new one if you moved) to be approved for an additional Phase 1 fly off of the new wings.
I will test fly the aircraft for 10 hours minimum, or as required, to confirm the wings are safe and meet the kit plane manufacturers criteria.
Owner/manufacturer builds his wings. FSDO may simply allow you to do this on your own, and go fly, or he may, if you made him mad, require a DAR to look at the wings before flight and check your weight and balance...
Owner records his changes and performs a weight and balance.
Flight test the wings under the Phase 1 approval above.
Your FSDO, if he is a purist, adds notes that the aircraft airworthiness certificate with long wings is an experimental glider, and with the short wings is an experimental airplane.

Personal note: I prefer the motor glider to an LSA. I have a better cruising speed and a safer plane in my estimation, and do not need a medical at all. Paperwork is minimal and is a known quantity. Working with the FAA is a breeze.

Also, the VGs are quite a good safety device and do lower the stall speed a couple of knots and improve low speed handling without causing a significant reduction in airspeed. Watch out though because it flies so well, it is easy to get slow.

Now to decide on the prop... It seems that if I never complete phase 1 I can change props as I may become a glider, and if it is not recorded, (after all my intentions are good, I only strayed a short time) I may be able to get away with this. I need a lawyer, and a sympathetic jury.

Much info and miss info out there, even from me and your FSDO and now you know where I am coming from, why I am test flying an pushing.

I missed two hours of work, got'ta get back.

Bud

References:
Title 14
FAA Part 1
1.1 abbreviations

Light-sport aircraft means an aircraft, other than a helicopter or powered-lift that, since its original certification, has continued to meet the following:
(1) A maximum takeoff weight of not more than—
(i) 1,320 pounds (600 kilograms) for aircraft not intended for operation on water; or
(ii) 1,430 pounds (650 kilograms) for an aircraft intended for operation on water.
(2) A maximum airspeed in level flight with maximum continuous power (VH) of not more than 120 knots CAS under standard atmospheric conditions at sea level.
(3) A maximum never-exceed speed (VNE) of not more than 120 knots CAS for a glider.
(4) A maximum stalling speed or minimum steady flight speed without the use of lift-enhancing devices (VS1) of not more than 45 knots CAS at the aircraft's maximum certificated takeoff weight and most critical center of gravity.
(5) A maximum seating capacity of no more than two persons, including the pilot.
(6) A single, reciprocating engine, if powered.
(7) A fixed or ground-adjustable propeller if a powered aircraft other than a powered glider.
(Cool A fixed or autofeathering propeller system if a powered glider.
(9) A fixed-pitch, semi-rigid, teetering, two-blade rotor system, if a gyroplane.
(10) A nonpressurized cabin, if equipped with a cabin.
(11) Fixed landing gear, except for an aircraft intended for operation on water or a glider.
(12) Fixed or retractable landing gear, or a hull, for an aircraft intended for operation on water.
(13) Fixed or retractable landing gear for a glider.


[quote] ---


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fklein(at)orcasonline.com
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PostPosted: Thu Jul 22, 2010 3:09 pm    Post subject: ELSA saga continues Reply with quote

On Jul 22, 2010, at 1:53 PM, Bud Yerly wrote:
Quote:
I argued that the experimental plane is a continuous experiment


Bud...couldn't agree w/ you more...
As for the rest of your post, let me take a moment and acknowledge you for what you bring to the Europa community...what you do is way beyond the scope and responsibility of a company rep...and I want you to know how much I appreciate what you do and your willingness to share it with everyone. The process you describe regarding how our birds may be able to be shoe-horned into the LSA is valuable information...it goes in my special "Bud's Wisdom" file. I can only guess at the time you've devoted to this subject...but I do know how long it takes me to put together a concise but comprehensive letter on a given subject, so I thank you again for your efforts on my behalf.
See ya at RR,
Fred

[quote][b]


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rampil



Joined: 04 May 2007
Posts: 870

PostPosted: Sun Jul 25, 2010 11:18 am    Post subject: Re: ELSA saga continues Reply with quote

Hey Bud,

I am sure I am missing something here!

Why in heaven's name would anyone ever want to convert an MG
to LSA? By performance and by privilege that would be a serious
downgrade.

Ira


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budyerly(at)msn.com
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PostPosted: Sun Jul 25, 2010 1:01 pm    Post subject: ELSA saga continues Reply with quote

<?xml:namespace prefix="v" /><?xml:namespace prefix="o" /><![endif]--> Ira,
It seems that some folks just do not get it. They have no medical, so they see they can fly under the LSA guidelines. So they call the FAA and EAA, and they are told correctly, if you want to fly under the LSA pilot rules, the MG must meet LSA guidelines, which is correct, however, they can't get it through their head that the glider rating frees them from the LSA bonds.

Go figure.
Bud
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rampil



Joined: 04 May 2007
Posts: 870

PostPosted: Mon Jul 26, 2010 5:14 am    Post subject: Re: ELSA saga continues Reply with quote

Just to be clear to those folks Bud is speaking of:

A pilot with a GLIDER rating with a SELF-LAUNCH endorsement

can fly the Europa Motor Glider as a powered aircraft as follows:

No LSA Speed Limit (135kts vs 120)

No LSA Weight Limit (1450#)

No Stall speed Limit

Full Night privileges (with lights)

Full IFR privileges (if so rated and equipped)

NO MEDICAL CERTIFICATION of ANY KIND

NO issue with prior FAILED Medical Certification
Why would any US Pilot care to convert a Europa MG to the restrictions of
LSA?

Ira (former FAA Designated Aviation Medical Examiner)


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PostPosted: Mon Jul 26, 2010 7:33 am    Post subject: ELSA saga continues Reply with quote

<?xml:namespace prefix="v" /><?xml:namespace prefix="o" /><![endif]--> Ira,
Someone without a 47 foot wide hanger I guess. The short tips on Homers 419PL are about 41 feet, and his hangar is 40. He goes in sideways on a trolley.


Bud
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terrys(at)cisco.com
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PostPosted: Mon Jul 26, 2010 8:41 am    Post subject: ELSA saga continues Reply with quote

Hi Bud, Ira,

We have a 39 foot hanger and a 47 foot MG (some of the time). My partner on the plane, Dave DeFord, built a pair of wheeled dollies that allow us to remove the starboard wing and wheel it into the hanger, next to the plane. It takes 7 minutes to rig or derig, and can be done by only one person.

Regards,
Terry Seaver
A135 Mono XS, long and short wings.


From: owner-europa-list-server(at)matronics.com [mailto:owner-europa-list-server(at)matronics.com] On Behalf Of Bud Yerly
Sent: Monday, July 26, 2010 8:28 AM
To: europa-list(at)matronics.com
Subject: Re: Re: ELSA saga continues



Ira,

Someone without a 47 foot wide hanger I guess. The short tips on Homers 419PL are about 41 feet, and his hangar is 40. He goes in sideways on a trolley.





Bud
[quote]
---


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rparigoris



Joined: 24 Nov 2009
Posts: 791

PostPosted: Mon Jul 26, 2010 9:08 am    Post subject: Re: ELSA saga continues Reply with quote

Hi Terry

"We have a 39 foot hanger and a 47 foot MG (some of the time). My partner on the plane, Dave DeFord, built a pair of wheeled dollies that allow us to remove the starboard wing and wheel it into the hanger, next to the plane. It takes 7 minutes to rig or derig, and can be done by only one person."

You by chance have any pics of dollies and plane nested in hangar?

thx.
Ron Parigoris


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PostPosted: Mon Jul 26, 2010 9:21 am    Post subject: ELSA saga continues Reply with quote

Hi Ron,

I don't have anything I could send you right now, but it there is
interest in this we could look at getting some pics and a description a
little later.

Regards,
Terry
--


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PostPosted: Mon Jul 26, 2010 9:41 am    Post subject: ELSA saga continues Reply with quote

On Jul 26, 2010, at 10:16 AM, Terry Seaver (terrys) wrote:

Quote:

>

I don't have anything I could send you right now, but it there is
interest in this we could look at getting some pics and a
description a
little later.

They would be much appreciated Terry, particularly if your set up
facilitates a switch between motorglider and regular...BTW, now that
you have wings long and short, and shared ownership to boot, how do
you find the process of "wing switching" to have evolved?...i.e.,

- Logged hours...%'age as MG, and %'age w/ shorties (?)

- Are "switches" between longs and shorts made seasonally, or
whimsically?

Fred


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rparigoris



Joined: 24 Nov 2009
Posts: 791

PostPosted: Mon Jul 26, 2010 10:34 am    Post subject: Re: ELSA saga continues Reply with quote

Hi Terry

"If there is interest in this we could look at getting some pics and a description a little later"

That would be appreciated!

Ron Parigoris


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PostPosted: Mon Jul 26, 2010 2:06 pm    Post subject: ELSA saga continues Reply with quote

<?xml:namespace prefix="v" /><?xml:namespace prefix="o" /><![endif]--> Terry,
For rigging and de-rigging I have a set of Wing Walkers I can't live without. I have 30 stitches and a torn shoulder from man-handling glider wings. Now I let the equipment do the work in less than 20 minutes and save my body for other things.

Bud Yerly
[quote] ---


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varoum55



Joined: 10 Jul 2010
Posts: 3

PostPosted: Tue Jul 27, 2010 12:34 pm    Post subject: Re: ELSA saga continues Reply with quote

These MG wings are heavy. The max GW is 1370lbs not 1450lbs. No long range tank etc... For more check this link: http://www.europa-aircraft.co.uk/motorglider/specification.php

Marc
Montréal


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