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EAB to ELSA

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wrice(at)omnicityusa.com
Guest

Posted: Sun Apr 06, 2008 8:20 am Post subject: EAB to ELSA

Bob:  Is there any process to convert  a EAB to the ELSA in order for the owner/pilot can take the 16 hour course and  be able to inspect is own  plane??                          Thanks  fpr your input.  Bill Rice 

 [quote]   To: Kolb-list(at)matronics.com (Kolb-list(at)matronics.com) 

   Sent: Saturday, April 05, 2008 3:59    PM

   Subject: FAA advice

   



I cobbed this off FLY-UL :    

      

This message was posted to    another group (Sport_aircraft)

--------



Re: ex-planes?



OK,    folks, I'm new to the group and have been "lurking" in the

background    reading this (sometimes painful) thread on certificating

existing or new    light-sport aircraft. Now I think it's time to jump in

and clarify some of    the confusion.



I am an FAA DAR who certificates light-sport and    amateur-built

aircraft. I also provide FAA-accepted 16-hour ELSA repairman    courses--

more that 40 courses all over the eastern half of the U.S. I've    also

been building experimental airplanes for 40 years.



So, I deal    with these questions every day. Here are the facts.



There are only five    conceivable ways to certificate a light-sport

aircraft: 1) standard    category, 2) special light-sport aircraft

(SLSA), 3) experimental    light-sport aircraft (ELSA), 4) experimental

amateur-built (EAB) aircraft,    and 5) experimental exhibition aircraft.

Although these are all conceivable    ways, some of them are not

practical. Let's talk about each    one.



STANDARD CATEGORY

These are the type certificated Cessnas,    Pipers, Beech's, etc. Nobody

is going to certify a light-sport aircraft in    standard category because

it is a multi-million-dollar process to do so and    would result in an

aircraft that nobody could afford. 'Nuff    said.



SPECIAL LIGHT SPORT AIRCRAFT (SLSA)

These are the 70-odd    ready-to-fly new aircraft designs that have come

on the scene in the last 3    years. Although not the multi-million-

dollar process that would be    required for type certification, SLSA

manufacturers must create aircraft    designs and implement inhouse

procedures to meet ASTM light-sport aircraft    standards. With each such

aircraft manufactured, they must certify that    they have met all

applicable standards.



EXPERIMENTAL LIGHT SPORT    (ELSA)

In the words of FAR 21.191(i), there are three kinds of    ELSAs:



1. Existing "ultralight-like vehicles" certificated prior to    January

31, 2008 per 21.191(i)(1). Note that the EAA and ASC have    gotten

exemptions to allow the certification deadline to be extended    for

aircraft that were REGISTERED before the deadline. That means that    if

your existing ultralight was not FAA-registered before the deadline,    it

can NEVER be certificated according to this paragraph. It also    means

that manufacturers of ultralights are essentially out of    business

unless they want to get their design certificated as    SLSA.



2. ELSAs built from a SLSA kit per 21.191(i)(2). The    manufacturer

must have gotten SLSA certification on the aircraft prior to    offering

it in kit form. The kit does not have to meet the 51% rule, but    the

manufacturer must certify that the kit meets the ASTM standards and    the

builder must certify that he has completed the kit EXACTLY as    the

manufacturer specifies. There is no registration or    certification

deadline on this type of ELSA.



3. ELSAs that were    converted from SLSA per 21.191(i)(3). Let's say

a guy buys an SLSA, but    wants to do his own annual condition inspection

after attending a 16-hour    ELSA repairman course (such as the ones I

offer). He can ask the FAA to    change his certification from SLSA to

ELSA. There is no deadline on making    such a conversion.



EXPERIMENTAL AMATEUR-BUILT (EAB)

In the words of    FAR 21.191(g), to qualify for certification as an EAB,

the major portion    must have been "fabricated and assembled by persons

who undertook the    construction project solely for their own education

or recreation" (note    the word "fabricated" in addition to the

word "assembled).



In the    olden days when I was a pup, before there were EAB kits, we

simply bought    plans and materials, built the entire aircraft, and

documented the    construction process in a builder's log. Also, in those

days, an FAA    inspector (there were no DARs) had to perform an interim

inspection of any    portion of the aircraft that would be "closed out"

and would not be visible    at the final inspection. Because of that,

there was generally no question    that the "major portion" requirement

was met, even in the case where one    individual began the construction

and then sold the project to another    individual.



However, over the ensuing 20-30 years, kits began to be    available.

First, they were simply raw material kits, but they gradually    advanced

into having more and more of the aircraft fabrication completed by    the

kit manufacturer. So, to assure that the "major portion"    requirement

was being met, the FAA began evaluating kits and approving them    as

meeting the so-called "51% rule." Therefore, if I bought an    approved

51% kit, finished it myself and maintained a construction log,    FAA

inspectors (and DARs, which had come on the scene by then) would    accept

it as meeting the "major portion" requirement. This held true even    if

I bought such a kit from someone else who had done some of    the

fabrication and assembly work, as long as that person was able    to

provide me with the original bill of sale for the kit and    a

construction log for his efforts.



Of course, then people started    abusing the system, by getting other

people to finish the kits for them.    That situation has gotten so bad

that the FAA is now revamping their entire    system for evaluating kits

and evaluating EABs submitted for certification.    Some of the current

quick-build kits may be disqualified.



So, how    does that affect the ability to certificate an existing

ultralight as an    EAB? I hear guys who have missed the ELSA

registration deadline say, "I'll    just take my ultralight apart and

reassemble it, take a few pictures,    create a construction log, and get

it certificated as EAB." Unfortunately,    that is not legal. First,

most ultralights do not meet the "major portion"    requirement--either

they were purchased ready to fly or as a kit that was    not evaluated by

the FAA. Second, FAR 191(g) requires that the major    portion be

FABRICATED and assembled by the applicant-- just reassembling it    would

not qualify.



I'm not saying that no ultralight is ever going    to be certificated as

an EAB, because DARs and FAA inspectors vary in    strictness by which

they interpret the requirements. I know if I tried to    vary from the

requirements, I would be in trouble with my FAA    supervisor!



EXPERIMENTAL EXHIBITION AIRCRAFT

This certification    category is for aircraft that are intended to be

used only for "exhibition"    purposes, such as performing in air shows,

performing in aerobatic    competitions, competing in air races, display a

certain kinds of aviation    events, etc.



When certificating an aircraft as experimental exhibition,    the FAA

issues "operating limitations" that severely limit where and when    the

aircraft can be flown. Generally that means the aircraft may be    flown

only 1) while performing or competing at an aviation event, 2)    to

travel to and from such an event, and 3) to practice for such an    event.



Experimental exhibition is "the bottom of the barrel"--the    least

desirable way to certificate an aircraft because of the restrictions    it

imposes. Do people sometimes ignore those restrictions?--sure, but    if

they are caught, they are in trouble.



CONCLUSIONS

1. If you    have missed the January 31, 2008 ELSA registration deadline,



a. You    MIGHT be able to get it certificated as an EAB, but it is

not    likely.



b. You can probably get it certificated as experimental    exhibition,

but that would be very restrictive as to where and when you    could fly.



c. Otherwise, you have an expensive lawn ornament on your    hands.

Thus, if you are tempted to buy an existing ultralight off eBay    or

somewhere else, it is critical to determine that it has already    been

certificated as an ELSA (unless of course it meets FAA 103, which    very

few ultralights do).



2. Any ELSA manufactured, registered, and    certificated after January

31, 2008 must be based on an SLSA kit, as    explained above.



If you have other questions about this, feel free to    post them and I'll

do my best to answer them. Also, I invite you to visit    my website

listed below--it has lots of good information on this topic and    much

more.



Hope this clarifies some of the    confusion!



Mike



      regards,

   Bob N.    FireFly 070 Old Kolb

   http://www.angelfire.com/rpg/ronoy/

   

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cristalclear13

Joined: 19 Sep 2007
Posts: 363
Location: Southeast Georgia

Posted: Sun Apr 06, 2008 7:13 pm Post subject: Re: EAB to ELSA

Bill,

I'm not Bob, but I took Mike Huffman's LS-I repairman course last week.  It's a great course and he's a great teacher.  He talked about this (what you asked) in his class.  Probably NOT what you want to hear, but there is no way to certificate a plane as E-LSA when it has already been certificated as E-AB.

Mike's web site - http://www.sportaviationspecialties.com/Articles.htm

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_________________
Cristal Waters
Kolb Mark II Twinstar Rotax 503 DCSI Sept 2007 - sold Sept 2012
Private Pilot Aug 2008
ELSA Repairman for N193Y April 2008
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