ELSA (E- L-SA) Registration

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Piper
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Joined: Fri May 21, 2021 2:08 pm

ELSA (E- L-SA) Registration

Post by Piper »

Has anyone here registered an Air Camper under 14 FAR 21.191(g), the Experimental- Light-Sport Aircraft, regulations.

I have a copy of AC 20-27 G, and it's not hard to understand-- being at least as clear as anything else that lawyers have written.

Other than "Engine Manufacturer:" "A" designed the case and crank, but there probably aren't any parts made by "A" in it. "B" "C" "D" "E" and "F" made the internal parts and I made the external parts, some of the accessories and assembled the whole thing. I guess I could just engrave my name on the case. On the worksheet the engine is an exempt "fabrication" item, maybe with it I could legitimately claim 101%.

Has anyone encountered any difficulties or "oddball" interpretations, anything "special" to do?

Thanks
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Clay Hammond
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Re: ELSA (E- L-SA) Registration

Post by Clay Hammond »

Any E-AB built aircraft can be operated by an LSA pilot if it meets the criteria for an LSA aircraft in terms of gross weight, number of occupants, speeds and horsepower. This is just like any LSA pilot can operate a standard category aircraft as well if it meets those same criteria...i.e. J3 Cub or Champ or T-Craft. E-LSA to my knowledge has always been a provision by which an S-LSA certified factory built aircraft can be moved into an experimental realm whereby an owner can make changes to the aircraft without factory approval. That's different than building a flivver from scratch that in turn meets the requirements for LSA. An E-AB built aircraft is already experimental by its nature. If it is light enough and low powered enough it will also meet LSA standards, which the Pietenpols due depending on the builder's choices. If you raise the gross weight, or the V-speeds, or the horsepower, or the occupancy...then it simply won't qualify and moving it out of E-AB won't help that.
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Piper
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Re: ELSA (E- L-SA) Registration

Post by Piper »

Sorry,

I'm confused... (all bolds are mine)

How do people register Air Campers so you can carry a single passenger?

I wanted to know if anyone registered a Pietenpol, especially an Air Camper under the provisions of...

"Title 14, FAR § 21.191 Experimental certificates.
Experimental certificates are issued for the following purposes:


(a) Research and development...
(b) Showing compliance with regulations...
(c) Crew training. Training of the applicant's flight crews...
(d) Exhibition...
(e) Air racing...
(f) Market surveys...
(g) Operating amateur-built aircraft. Operating an aircraft the major portion of which has been fabricated and assembled by persons who undertook the construction project solely for their own education or recreation.

AC 20-27 reads:

"Subject: Certification and Operation of Amateur-Built Aircraft
Date: 9/30/2009
Initiated by: AIR-200
AC No: 20-27G
1. Purpose.
a. This advisory circular (AC) provides information about Title 14, Code of
Federal Regulations (14 CFR) part 21, Certification Procedures for Products and Parts,
§ 21.191(g) for the purpose of operating amateur-built aircraft.


The appendix of AC 20-27 contains a number of documents that must be submitted in order to certify the aircraft in one of several
categories... Most have the same 9/30/2009 date as the AC, but some have a 9/7/2012 date such as the 8130-6...

"9/7/2012 AC 20-27G
Appendix 6
6-2
APPENDIX 6. SAMPLE FAA FORM 8130-6, APPLICATION FOR
AIRWORTHINESS CERTIFICATE (LIGHT SPORT)"


27G says "6. Where You Can Obtain FAA Form 8130-6. You can obtain FAA Form 8130-6 by downloading it from the FAA website at http://www.faa.gov, or by contacting your local FAA office. You should use the latest form version. The FAA will not accept superseded form versions.

But the instructions in 21-12C say
"Subject: Application for U.S. Airworthiness Date: 9/7/2012 AC No: 21–12C
Certificate, FAA Form 8130–6 Initiated by: AIR–200
1. Purpose. This advisory circular (AC) provides guidance and information needed to prepare and submit Federal Aviation Administration (FAA) Form 8130-6, Application for U.S. Airworthiness Certificate. This application is required to obtain an airworthiness certificate
or to amend a current certificate. In some cases, an application may be required for the issuance of a replacement airworthiness certificate. This AC is not mandatory and does not constitute a regulation. It describes an acceptable means, but not the only means, to comply with requirements. However, if you use the means described in the AC, you must follow it in all respects.
2. Audience. This AC applies to any person applying for an FAA airworthiness certificate.
3. Effective Date. This AC is effective September 7, 2012.
4. Explanation of Changes. This revision—
a. Updates the instructions on how to complete the current FAA Form 8130-6."

It seems to me the FAA is conflating a number of different things.
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Piper
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Re: ELSA (E- L-SA) Registration

Post by Piper »

Clay Hammond wrote: Fri Jun 11, 2021 1:01 pm Any E-AB built aircraft can be operated by an LSA pilot if it meets the criteria for an LSA aircraft in terms of gross weight,
1320 pounds on wheels check or 1430 on floats (hmmm, an AC on floats, IIRC 1660s are 233 pounds or so) CHECK
Clay Hammond wrote: Fri Jun 11, 2021 1:01 pm number of occupants,
two, CHECK
Clay Hammond wrote: Fri Jun 11, 2021 1:01 pmspeeds
52 and 140 mph CHECK
Clay Hammond wrote: Fri Jun 11, 2021 1:01 pm Any LSA pilot can operate a standard category aircraft as well if it meets those same criteria...i.e. J3 Cub or Champ or T-Craft. E-LSA to my knowledge has always been a provision by which an S-LSA certified factory built aircraft can be moved into an experimental realm whereby an owner can make changes to the aircraft without factory approval. That's different than building a flivver from scratch that in turn meets the requirements for LSA. An E-AB built aircraft is already experimental by its nature. If it is light enough and low powered enough it will also meet LSA standards, which the Pietenpols do depending on the builder's choices. If you raise the gross weight, or the V-speeds, or the horsepower, or the occupancy...then it simply won't qualify and moving it out of E-AB won't help that.
One can get a waiver for 4 occupants (I have no idea how difficult that would be), but just my $0.02 I think it would be quite a trick to build an AC outside of the LSA limits.
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Piper
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Re: ELSA (E- L-SA) Registration

Post by Piper »

A letter confirming reservation of my N-number arrived today (previously held by a Bamboo Bomber dad flew) along with more contradictory boilerplate.

(The poorly named) Expiramental is a CATEGORY, like RESTRICTED, or STANDARD, then Amateur Built or Light-Sport are subcategories right.

I mean they make the rules, can't they even read what they write? Pietenpols were never issued a type certificate, correct? (I searched OKC on every Piet N-number I have and each returns: "none.")

Amateur, "plans built" 97% (and 3% is generous).
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Terry Hand
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Re: ELSA (E- L-SA) Registration

Post by Terry Hand »

Piper,

Maybe it's my advancing age, but you have lost me in what you asking. I think that your original question was, "can the Pietenpol Air Camper be built and registered as E-LSA?" I thought that Clay had done a good job of explaining how aircraft move from S-LSA to E-LSA. Yet you want people on the forum to read FAR91. Why?

The Pietenpol Air Camper is typically registered as an experimental amateur built aircraft. It is that simple. What are you attempting to accomplish by registering another way? Help us to understand.
Semper Fi,

Terry Hand
Athens GA
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Piper
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Re: ELSA (E- L-SA) Registration

Post by Piper »

I understood and appreciated Clay's response. As I look back at my text I can understand why he interpreted the question as he did. But, it was a good answer for something that I wasn’t trying to ask-- moving an already registered aircraft into a new subcategory.

In a sub-leased space connected to my hanger, spars, wing ribs, drag braces and compression struts sit glued together on some sturdy sawhorses. Lines are being drawn, copied from the plans I bought from Andy, onto the butcher's paper covering the long workbench where the sticks that will soon be part of a fuselage sit with a tin of glue and bags of AN hardware.

On a smaller desk I have four envelopes from Franz Kafka and Company, Oklahoma City. The small one I understand, it confirms that I've reserved a registration number. Three large envelopes are contradictory-- both with one another and with the FARs they purport to have extractions from. If anybody's interested in how their taxes are wasted I’ll elaborate on what sort of feces is in them. But stating it up front will probably only confuse the facts.

Has anybody registered a previously unregistered Air Camper E-AB since 9/7/2012?
Did you use the forms included as an appendix in AC 20-27G?
Did you encounter any problems in registering it that pertained to use of those forms?
Has anybody registered a previously unregistered Air Camper E-LSA since 9/7/2012?
(And if so why-- is there any advantage to doing it that way that you know of?)

Many thanks,

Piper
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Terry Hand
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Re: ELSA (E- L-SA) Registration

Post by Terry Hand »

Piper,

Maybe your question should be, "Has anyone ever registered a Pietenpol Air Camper as anything but an experimental amateur built?" You keep coming back around to the idea of registering a Pietenpol as an E-LSA? I am just curious as to why you are interested in doing so. What do you perceive to be the advantages of doing so? If you can help those of us in the forum understand why you are interested, that might be helpful in getting your question answered.

It is my understanding that the E-LSA is merely an S-LSA that has had it airworthiness certificate changed to E-LSA. I do not believe it is possible to have a DAR come inspect your plane and have it designated an E-LSA, because there is no such thing as an S-LSA Pietenpol. If I am wrong maybe Clay or someone can chime in.
Semper Fi,

Terry Hand
Athens GA
tom kreiner
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Re: ELSA (E- L-SA) Registration

Post by tom kreiner »

Terry,

One of my chapter members purchased an S-LSA RV-12, and changed it from S to E... The reason was to permit him to perform both repairs and maintenance. This was some form of a factory built RV, which permitted the S designation. Rules permit the change from S to E, but NOT from E to S, as S implies factory built (for all intents & purposes).

To the best of my knowledge - limited, I know - assuming the builder is NOT a factory, simply an individual, the RV-12 would be an E-LSA when signed off.

That said, we need an FAA kinda guy to chime in, as the rules are pretty different for LSA's. Rather than strict compliance with FAA, the comply with ANSI, or ASME, can't remember which.

Something to note... If a PP purchases an E-LSA, or ANY OTHER experimental, HE, and ONLY HE, may take flight training in that aircraft. Rules permit, however, for anyone to train in an S-LSA, including for the CFI-S.
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Piper
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Re: ELSA (E- L-SA) Registration

Post by Piper »

Hi Terry,
Terry Hand wrote: Sun Jun 13, 2021 10:40 am Piper,

Maybe your question should be, "Has anyone ever registered a Pietenpol Air Camper as anything but an experimental amateur built?" You keep coming back around to the idea of registering a Pietenpol as an E-LSA? I am just curious as to why you are interested in doing so. What do you perceive to be the advantages of doing so? If you can help those of us in the forum understand why you are interested, that might be helpful in getting your question answered.
I have a letter from my DAR stating that I "must" register my aircraft as an E-LSA, not an E-AB. But that letter contains statements that I don't believe to be correct, and can find no evidence to support. IE: that the Air Camper has an FAA issued type certificate. (My request for the number of this supposed TCDS remains to-date unanswered.) Every AC that I trace by registration number through OKC is registered E-AB. And state: "TCDS: none."

***Edit, an anonymous contributor gave me N-numbers of two E-AB registrations that disprove the DAR's statement. Thank you kindly.***
Terry Hand wrote: Sun Jun 13, 2021 10:40 am
It is my understanding that the E-LSA is merely an S-LSA that has had it airworthiness certificate changed to E-LSA. I do not believe it is possible to have a DAR come inspect your plane and have it designated an E-LSA, because there is no such thing as an S-LSA Pietenpol. If I am wrong maybe Clay or someone can chime in.
That is how I read it. S-LSA has to be manufactured by a certificated manufacturer to an FAA approved type certificate, but an S-LSA can be "temporarily" moved to E-LSA for "evaluation" of modifications. Being an open-ended time frame, the sun can super-nova before you get around to moving it back.

I have multiple letters from my DAR and from the puzzle palace regarding AC 20-27. My-- sadly, not legally significant*-- reading is that the "new" (9/7/2012) rules do not supersede, but add a new option-- one I wouldn't choose to exercise-- to the 2009 rules. But the DAR disagrees. The puzzle palace says he is wrong about that. But they support an unsupportable requirement he made-up regarding kits. That I cannot build as "plan-built" if a kit option exists, and must submit a completed 8050-2.

The puzzle palace also says that while the "recommendations" in AC 20-27 are "not-mandatory" the DAR can deny approval if the DAR feels the build doesn't meet standards because AC 20-27's "recommendations" were not followed. Making the "recommendations"-- such as building from a kit if one is available-- mandatory in my book. I mean, the DAR can approve 14 blank pieces of paper if he wants to-- not according to the regs. But he doesn't read those, remember.

I'm just getting my ducks in a row because I don't see this as being an easy process. (Full disclosure: I hold a CPL and an A&P and have a stormy history with this DAR who has a habit of making written statements that are not remotely supported by either facts or regulatory language (often both). IE: that as an A&P I cannot work on an "E-AB" registered aircraft.)

Piper

* I was disqualified from applying to law school because my parents were legally married to one another when I was conceived.
Last edited by Piper on Sun Jun 13, 2021 10:18 pm, edited 1 time in total.
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Terry Hand
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Re: ELSA (E- L-SA) Registration

Post by Terry Hand »

Piper,

The Pietenpol has been around since 1929, and Bernard Pietenpol should really be considered the patron saint of homebuilders. So, I am a bit in shock the your DAR is unaware of its history and the fact that it is a plans built airplane. Currently there is not kit or factory for this airplane. Therefore, by its very nature, it must be certified under an experimental amateur built designation. Your DAR is simply wrong.

There are more DARs than just this one. Maybe you should look elsewhere. You may also talk with the EAA and see what help they might be able to provide.

Best wishes in dealing with an unreasonable person.
Semper Fi,

Terry Hand
Athens GA
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Terry Hand
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Re: ELSA (E- L-SA) Registration

Post by Terry Hand »

Piper,

One other thing to ask your DAR - if I am the second owner of an experimental amateur built aircraft, who can do my Condition Inspection? The answer is - either the builder who has received the repairman’s certificate or an A&P. NOT an A&P/IA like a certified aircraft. Your DAR needs to have his license revoked as he does not even know the regs. An A&P can absolutely work on an EAB certified aircraft. He/she is an idiot.
Semper Fi,

Terry Hand
Athens GA
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Piper
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Re: ELSA (E- L-SA) Registration

Post by Piper »

Hi Terry,

I'm not sure I'd call it a "kit," but Aircraft Spruce sells six pre-cut wood "kits" (with the dimensions taken directly from Andy's bill of materials for the "Improved Air Camper" (is that the 1933 version, I have four (slightly) different complete AC plan sets and a 1962 fuselage plan for air cooled engines). Just pre-cut wood, the dimensions of which Andy sends you when you buy his plans, nothing else.

(Those who cut their own wood instead of buying the kit will probably make one wing six foot long with a nine foot chord and the other 32 foot long with a 32 inch cord and mount them both upside down and backwards using paperclips :D )

Piper
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Piper
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Re: ELSA (E- L-SA) Registration

Post by Piper »

Terry Hand wrote: Sun Jun 13, 2021 10:25 pm Piper,

One other thing to ask your DAR - if I am the second owner of an experimental amateur built aircraft, who can do my Condition Inspection? The answer is - either the builder who has received the repairman’s certificate or an A&P. NOT an A&P/IA like a certified aircraft. Your DAR needs to have his license revoked as he does not even know the regs. An A&P can absolutely work on an EAB certified aircraft. He/she is an idiot.
As an A&P I often work on E-AB certified aircraft (Part 103 "vehicles" too for friends). The DAR has a monopoly here, it's cost prohibitive to ship an aircraft elsewhere to flight test it. I could take the test but I couldn't then do my own aircraft, which is funny because a couple guys back the price of anything you wanted signed was a bottle of good scotch. This one just enjoys being an impediment.
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