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rickofudall
Joined: 19 Sep 2009
Posts: 1392
Location: Udall, KS, USA
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 Posted: Thu Sep 16, 2010 4:51 am Post subject: That pesky ELSA re-registration problem |
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After much thought about how to make it legal to re-register an ELSA that the owner has allowed the registration to expire under the terms of the new rule I sent the following to the applicable FAA personnel this morning.
"Dear Sirs, There is a problem with the new rule for triennial re-registration of aircraft when it is applied to experimental light sport aircraft (ELSA) that were registered under the provisions of FAR 21.191 i(1). If an owner of an ELSA fails to re-register during the applicable period and the registration expires there is no legal means to register the aircraft again.
FAR 21.191 i(1) expired on January 3, 2008. Form 8050-88A (Affidavit of Ownership) that is required to be filed along with 8050-1 to register an ELSA has been revised so that the only two options for registering an ELSA are through FAR 21.191 i(2) (aircraft built from a kit of a qualifying special light sport aircraft (SLSA)) and FAR 21.190 (essentially for manufacturers who need to register a prototype to do compliance testing of an SLSA).
I believe there is a simple way to fix this problem. Revise form 8050-88A to include an option to the effect, "this aircraft was previously registered as N_______ under the provisions of FAR 21.191 i(1) and the paperwork is on file with the FAA". I believe wording like this or similar would allow an errant owner to re-register the aircraft following expiration with a minimum of problems and prevent those who might try to use the provision to register an aircraft that had not previously been registered.
Thank you for your time."
I did this after spending a good portion of yesterday morning talking and writing to various officials in the FAA about the problem. It occurred to me late last night that the easiest way to get something fixed when there is a problem is to present a solution to those who can remedy it. What the heck, it's worth a try.
Rick Girard
--
Zulu Delta
Kolb Mk IIIC
582 Gray head
4.00 C gearbox
3 blade WD
Thanks, Homer GBYM
It is not bigotry to be certain we are right; but it is bigotry to be unable to imagine how we might possibly have gone wrong.
- G.K. Chesterton
[quote][b]
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bob(at)fly-ul.com
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| Posted: Thu Sep 16, 2010 5:25 am Post subject: That pesky ELSA re-registration problem |
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Did you really tell them it expired on January 3, or did you tell them it expired on January 31?
--Bob Comperini
On Sep 16, 2010, at 5:42 AM, Richard Girard <aslsa.rng(at)gmail.com (aslsa.rng(at)gmail.com)> wrote:
[quote]After much thought about how to make it legal to re-register an ELSA that the owner has allowed the registration to expire under the terms of the new rule I sent the following to the applicable FAA personnel this morning.
"Dear Sirs, There is a problem with the new rule for triennial re-registration of aircraft when it is applied to experimental light sport aircraft (ELSA) that were registered under the provisions of FAR 21.191 i(1). If an owner of an ELSA fails to re-register during the applicable period and the registration expires there is no legal means to register the aircraft again.
FAR 21.191 i(1) expired on January 3, 2008. Form 8050-88A (Affidavit of Ownership) that is required to be filed along with 8050-1 to register an ELSA has been revised so that the only two options for registering an ELSA are through FAR 21.191 i(2) (aircraft built from a kit of a qualifying special light sport aircraft (SLSA)) and FAR 21.190 (essentially for manufacturers who need to register a prototype to do compliance testing of an SLSA).
I believe there is a simple way to fix this problem. Revise form 8050-88A to include an option to the effect, "this aircraft was previously registered as N_______ under the provisions of FAR 21.191 i(1) and the paperwork is on file with the FAA". I believe wording like this or similar would allow an errant owner to re-register the aircraft following expiration with a minimum of problems and prevent those who might try to use the provision to register an aircraft that had not previously been registered.
Thank you for your time."
I did this after spending a good portion of yesterday morning talking and writing to various officials in the FAA about the problem. It occurred to me late last night that the easiest way to get something fixed when there is a problem is to present a solution to those who can remedy it. What the heck, it's worth a try.
Rick Girard
--
Zulu Delta
Kolb Mk IIIC
582 Gray head
4.00 C gearbox
3 blade WD
Thanks, Homer GBYM
It is not bigotry to be certain we are right; but it is bigotry to be unable to imagine how we might possibly have gone wrong.
- G.K. Chesterton
[b]
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rickofudall
Joined: 19 Sep 2009
Posts: 1392
Location: Udall, KS, USA
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| Posted: Thu Sep 16, 2010 7:40 am Post subject: That pesky ELSA re-registration problem |
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No, it appears that I inadvertantly backspaced over the 1 and didn't catch it on the proof read. I'm sure they'll catch it, the brain fills in what it expects to see.
Rick
On Thu, Sep 16, 2010 at 8:18 AM, Bob Comperini <bob(at)fly-ul.com (bob(at)fly-ul.com)> wrote:
| Quote: | Did you really tell them it expired on January 3, or did you tell them it expired on January 31?
--Bob Comperini
On Sep 16, 2010, at 5:42 AM, Richard Girard <aslsa.rng(at)gmail.com (aslsa.rng(at)gmail.com)> wrote:
| Quote: | After much thought about how to make it legal to re-register an ELSA that the owner has allowed the registration to expire under the terms of the new rule I sent the following to the applicable FAA personnel this morning.
"Dear Sirs, There is a problem with the new rule for triennial re-registration of aircraft when it is applied to experimental light sport aircraft (ELSA) that were registered under the provisions of FAR 21.191 i(1). If an owner of an ELSA fails to re-register during the applicable period and the registration expires there is no legal means to register the aircraft again.
FAR 21.191 i(1) expired on January 3, 2008. Form 8050-88A (Affidavit of Ownership) that is required to be filed along with 8050-1 to register an ELSA has been revised so that the only two options for registering an ELSA are through FAR 21.191 i(2) (aircraft built from a kit of a qualifying special light sport aircraft (SLSA)) and FAR 21.190 (essentially for manufacturers who need to register a prototype to do compliance testing of an SLSA).
I believe there is a simple way to fix this problem. Revise form 8050-88A to include an option to the effect, "this aircraft was previously registered as N_______ under the provisions of FAR 21.191 i(1) and the paperwork is on file with the FAA". I believe wording like this or similar would allow an errant owner to re-register the aircraft following expiration with a minimum of problems and prevent those who might try to use the provision to register an aircraft that had not previously been registered.
Thank you for your time."
I did this after spending a good portion of yesterday morning talking and writing to various officials in the FAA about the problem. It occurred to me late last night that the easiest way to get something fixed when there is a problem is to present a solution to those who can remedy it. What the heck, it's worth a try.
Rick Girard
--
Zulu Delta
Kolb Mk IIIC
582 Gray head
4.00 C gearbox
3 blade WD
Thanks, Homer GBYM
It is not bigotry to be certain we are right; but it is bigotry to be unable to imagine how we might possibly have gone wrong.
- G.K. Chesterton
3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D
| Quote: |
3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D
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3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D
3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D
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--
Zulu Delta
Kolb Mk IIIC
582 Gray head
4.00 C gearbox
3 blade WD
Thanks, Homer GBYM
It is not bigotry to be certain we are right; but it is bigotry to be unable to imagine how we might possibly have gone wrong.
- G.K. Chesterton
[quote][b]
| | - The Matronics RotaxEngines-List Email Forum - | | | Use the List Feature Navigator to browse the many List utilities available such as the Email Subscriptions page, Archive Search & Download, 7-Day Browse, Chat, FAQ, Photoshare, and much more:
http://www.matronics.com/Navigator?RotaxEngines-List |
|
_________________
The smallest miracle right in front of you is enough to make you happy.... |
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