Standard category to Experimental?

[N659HB]

Is there such a process? I'm thinking it would be necessary to install a non-OEM engine (i.e. Rotax or Aerovee) in something like a Luscombe. As a follow-up, would the Experimental designation allow use of non-TSO'd electronics (i.e. a glass panel, radios, etc.)

 

[ClimbnSink]

Yes and no. You can do it but only for testing. No idea if you could abuse the intent, install a Rotax on a Luscombe under the pretense of developing a STC then fly it for years while you *cough*work out the details... Probably a time limit in the issuance, perhaps they can be renewed indefinitely...

 

[N659HB]

That's what I thought.

I see Luscombes converted to higher HP engines, i.e. C-85. Is that done by STC?

 

[flyingron]

Note, that all EXPERIMENTAL is not the same. Other than EXPERIMENTAL--AMATEUR BUILT which lets you fly your plane as you like (with minor technical restrictions) and great freedom for mods and maintenance, the other EXPERIMENTAL have more stringent rules on how you can fly your plane and how the maintenance occurs.

If you want to stick a funky engine on your Luscombe, it can be put in the R&D category but watch what you get for operating limitations in the process. It can go back to standard when you either get the installation approved or you undo your experimental changes.

 

[l8evator]

I see Luscombes converted to higher HP engines, i.e. C-85. Is that done by STC?

The Luscombe type certificate includes Continental A65, A75, C85 and C90 engines and provides the authority to install those engines. I believe, but don't know for certain, one needs an STC to install the O200.

 

[FastEddieB]

...the other EXPERIMENTAL have more stringent rules on how you can fly your plane and how the maintenance occurs.

Not relevant to the OP, but I converted my Sky Arrow S-LSA to E-LSA.

It did not really change how I can fly my plane, and it opened me up to doing my own maintenance and parts substitution, and with a 16-hour course have also done my last several annual condition inspections.

Main downside is no flight instruction or rental, but I had not planned on doing that anyway.

As far as standard category to Experimental, as stated already in this thread I think that's a very tough road.

 

[Henning]

Is there such a process? I'm thinking it would be necessary to install a non-OEM engine (i.e. Rotax or Aerovee) in something like a Luscombe. As a follow-up, would the Experimental designation allow use of non-TSO'd electronics (i.e. a glass panel, radios, etc.)

Soon, when the Pt 23 revision comes out it will introduce a "Non Commercial" category where you will be able to do all these mods and maintain your own plane on the same rules as experimental AB.

 

[kgruber]

Soon, when the Pt 23 revision comes out it will introduce a "Non Commercial" category where you will be able to do all these mods and maintain your own plane on the same rules as experimental AB.

That would be nice, in my lifetime. It should include CAR3, as well.

 

[Henning]

That would be nice, in my lifetime. It should include CAR3, as well.

The final draft is already in the pipe.

 

[N659HB]

That would be nice, in my lifetime. It should include CAR3, as well.

It would be nice.

 

[N659HB]

The Luscombe type certificate includes Continental A65, A75, C85 and C90 engines and provides the authority to install those engines. I believe, but don't know for certain, one needs an STC to install the O200.

Good tonknow. Thanks. BTW, I don't yet own a Luscombe.

 

[Tom-D]

Soon, when the Pt 23 revision comes out it will introduce a "Non Commercial" category where you will be able to do all these mods and maintain your own plane on the same rules as experimental AB.

That's a long ways from a reality.

after it is added to the FARs, the ink is dry, and the fsdo's get it hashed around it may take longer than you realize.

 

[stratobee]

It is virtually impossible to take a certified aircraft to the experimental category, unless you're willing to take it apart and re-manufacture a lot of parts. Here are the options in the experimental category:

The following is a list of the different types of Experimental certificates (quoted from 14-CFR-21.191) which are available and how they apply to the installation of a non-certified powerplant onto a certified airframe.

(a) Research and Development: Testing new aircraft design concepts, new aircraft equipment, new aircraft equipment, new aircraft installations.

NOTE: An R&D certificate must be renewed annually. Your FSDO contact will usually issue the first one fairly easily. You will have to prove some substantial reasons to justify the issuance for a second year. In my region, there has never been one issued for the third year.
ALSO, after the expiration of your R&D certificates, you will find it extremely difficult to convert the aircraft back into its original form (ie, restore it to being a standard Cessna-185 or whatever) because now the burden is on you, the modifier, to prove that the aircraft complies with the original type certificate .

(b) Showing Compliance with Regulations: Conducting flight tests and other operations to show compliance with the airworthiness regulations including flights to show compliance for issuance of type certificates and supplemental type certificates, flights to substantiate major design changes, and flights to show compliance with the function and reliability requirements of the regulations.

This classification is what you would use for the flight test verification to obtain an STC for the installation of a different certified powerplant onto a certified airframe. The number of times this certificate can be renewed is also limited.

(c) Crew Training: Training of the applicant's flight crews.

This requires substantiation, periodic inspections, and ongoing renewals. The allowable operations under this classification are limited.

(d) Exhibition: Exhibiting the aircraft's flight capabilities, performance, or unusual characteristics at air shows, motion picture, television and similar productions, and the maintenance of exhibition flight proficiency, including (for persons exhibiting aircraft) flying to and from such air shows and productions.

The allowable aircraft operations under this classification are very limited.

(e) Air Racing: Participating in air races, including (for such participants) practicing for such air races and flying to and from such events.

The allowable aircraft operations under this classification are very limited.

(f) Market Surveys: Use of aircraft for purposes of conducting market surveys, sales demonstrations, and customer crew training only as provided in paragraph 21.195.

FAR 21.195 is very specific about the restrictions that apply here.

(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.

(h) Operating Kit-built Aircraft: Operating a primary category aircraft that meets the criteria of paragraph 21.24(a)(1) that was assembled by a person from a kit manufactured by the holder of a production certificate for that kit, without the supervision and quality control of the production certificate holder, under paragraph 21.184(a).

 

[FastEddieB]

Just curious...

...why is Experimental Light Sport excluded from that list?

 

[Henning]

Just curious...

...why is Experimental Light Sport excluded from that list?

Is LSA part of Pt 21?

 

[ChitDisturber]

Is there such a process? I'm thinking it would be necessary to install a non-OEM engine (i.e. Rotax or Aerovee) in something like a Luscombe. As a follow-up, would the Experimental designation allow use of non-TSO'd electronics (i.e. a glass panel, radios, etc.)

This sounds like a metric ton of work, paperwork and money.

I'd wager that plane is goin to be in pieces and for sale on barnstormers for a fraction of what you will have "into" it.

I wouldn't recommend doing this if I were you.

 

[Tom-D]

This sounds like a metric ton of work, paperwork and money.

I'd wager that plane is goin to be in pieces and for sale on barnstormers for a fraction of what you will have "into" it.

I wouldn't recommend doing this if I were you.

Lots of people have done this in the past, every alternate engine STC started by a simple field approval, worked thru to a STC

AC 43-210 covers this subject.

 

[N659HB]

AC 43-210 covers this subject.

Thanks for the reference, Tom. I'll be sure to check it out.

There's a company converting Bonanzas to turboprop (for about a half mil!) that got me thinking about some possibilities. I'm pretty sure there are Cub variants (SuperCub?) that have been around for awhile, so this can't be too uncommon.

I'm not saying it would be worth the trouble, just wondering if it was possible, and what the limitations were. My aviation 'fortune' is already small enough, thank you!

And again, I do not (yet) own an aircraft. This is all hypothetical, and I am still learning.

Thanks for the replies.

 

[N659HB]

This sounds like a metric ton of work, paperwork and money.

I'd wager that plane is goin to be in pieces and for sale on barnstormers for a fraction of what you will have "into" it.

I wouldn't recommend doing this if I were you.

It does sound like a good way to end up with a small fortune.

 

[Geico266]

It is sad to me that an innovation like the OP suggested is killed by paperwork.

What the hell is wrong with taking an old airframe and trying to put a new technology engine on it?

Op, before you throw the idea away call the EAA. There has got to be a way, and they can find it.

I think it is a cool idea.

 

[FastEddieB]

Is LSA part of Pt 21?

Have no idea.

Back to the OP, and expanding on my previous post, if one is looking for something to tinker with*, finding an S-LSA and converting it to Experimental or finding one already so classified, is one way to go if Light Sport would meet one's mission profile.

That's what I did with my Sky Arrow about three years ago, and absolutely no regrets to date. It's easy to do, via hiring a DAR to come and do an inspection and revise the paperwork.

Required placards (2 on the plane and one on Karen, my wife):

*that "tinkering" could even include a different engine and/or prop, as long as the resulting installation met Light Sport limitations (no constant-speed prop, for example). Major changes, such as a different engine or prop, would necessitate a flight testing protocol, as outlined in my new Limitations - smaller changes do not.

 

[poadeleted20]

The S-LSA to E-LSA conversion is specifically addressed in the regulations. It has no applicability outside of S-LSA's. In the OP's case, the long-term use of a non-certified engine in his Standard airworthiness Luscombe would require a field approval or STC. He could apply for an Experimental-Showing Compliance with Regulations certificate for six months to complete flight testing for field approval/STC with that other engine, but if he doesn't get one of those by the end of that period (or the one allowable 6-month extension), he will have to return it to its original configuration.

 

[Geico266]

The S-LSA to E-LSA conversion is specifically addressed in the regulations. It has no applicability outside of S-LSA's. In the OP's case, the long-term use of a non-certified engine in his Standard airworthiness Luscombe would require a field approval or STC. He could apply for an Experimental-Showing Compliance with Regulations certificate for six months to complete flight testing for field approval/STC with that other engine, but if he doesn't get one of those by the end of that period (or the one allowable 6-month extension), he will have to return it to its original configuration.

There are FAA certified versions of the same Rotax 912 engine. Hmmmmm.

Any reason why a certified Rotax 912iSC could not be installed for testing on a Luscomb and then apply for an STC?

Op you need to call EAA and proceed!

 

[FastEddieB]

The S-LSA to E-LSA conversion is specifically addressed in the regulations. It has no applicability outside of S-LSA's.

I know.

I simply said it was "one way to go" and was not addressing his particular Luscombe query.

 

[poadeleted20]

As a follow-up, would the Experimental designation allow use of non-TSO'd electronics (i.e. a glass panel, radios, etc.)

Generally speaking, there is no requirement for TSO'd avionics in light planes, even production planes, although they must be approved aircraft parts. For example, the King KX-175 is the TSO'd version of the non-TSO'd KX-170, and you can put either in your Luscombe with neither STC nor field approval. Only for those avionics for which the regulations require TSO (like GPS's and transponders) must the avionics be TSO'd.

In the case of flight instruments for Standard airworthiness aircraft, it must be an approved aircraft part, TSO'd or PMA'd. This is discussed in the catalogs of suppliers such as Aircraft Spruce and Chief Aircraft.

 

[poadeleted20]

Any reason why a certified Rotax 912iSC could not be installed for testing on a Luscomb and then apply for an STC?

None whatsoever, but you can't fly it that way until you get that Experimental-Showing Compliance with Regulations airworthiness certificate, and there's no guarantee an STC will be issued after you finish the required inspections and testing. If the FAA declines, or the approved test period expires, then the plane is grounded until it's returned to its original configuration.

Op you need to call EAA...

EAA can probably give the OP a good idea of what's involved in the process and what his chances for FAA approval are.

...and proceed!

I would strongly recommend doing that "due diligence" before proceeding with a project that may have little or no hope for eventual approval.

 

[ClimbnSink]

I would strongly recommend doing that "due diligence" before proceeding with a project that may have little or no hope for eventual approval.

Thanky no one told the Wright bros that. Our GA fleet is good enough stop tinkering or we will ground the crap out of you. Then bury you in paperwork.

 

[Geico266]

Thanky no one told the Wright bros that. Our GA fleet is good enough stop tinkering or we will ground the crap out of you. Then bury you in paperwork.

Seriously, in today's world the Wright Bros would be arrested for contributing world hunger, global warming, endangering children, etc.

Innovation is dead in general aviation in the US while the rest of the world zooms past us. Pathetic that Americans now take this paperwork crap as normal, and as Ron so cheerfully, and gleefully cites as a wall against innovation and modernization of our fleet. Pathetic really. This use to be the country every looked to for innovation, now we are the prime example of what not to do.

The approach needs to be the engine will burn less fuel, less carbon emmisions, less pollution and they will get a grant for $10 mil to do it.

I say build it and let the feds have a heart attack. **** them.

There is a reason aviation is dying in this country, and we just found another reason why.

 

[Tom-D]

although they must be approved aircraft parts.

Show me that requirement.

In light of what the rules say


23.1301 Function and installation.
Each item of installed equipment must—

(a) Be of a kind and design appropriate to its intended function.

(b) Be labeled as to its identification, function, or operating limitations, or any applicable combination of these factors; and

(c) Be installed according to limitations specified for that equipment.

 

[poadeleted20]

...and as Ron so cheerfully, and gleefully cites...

Please do not assume that I am either cheerful or gleeful about the regulations, other than being gratified when people who want to know what the rules are learn the rules and how to comply with them.

 

[Tom-D]

In the case of flight instruments for Standard airworthiness aircraft, it must be an approved aircraft part, TSO'd or PMA'd. This is discussed in the catalogs of suppliers such as Aircraft Spruce and Chief Aircraft.

IOWs it can't be in its properly altered condition.

 

[poadeleted20]

Show me that requirement.

In light of what the rules say


23.1301 Function and installation.
Each item of installed equipment must—

(a) Be of a kind and design appropriate to its intended function.

(b) Be labeled as to its identification, function, or operating limitations, or any applicable combination of these factors; and

(c) Be installed according to limitations specified for that equipment.

Who do you think gets the final say on whether or not the item is "of a kind and design appropriate to its intended function"? And how is that information conveyed by the manufacturer to the buyer? Not to mention how you comply with the aircraft's type certificate when you install a required item like an airspeed indicator that isn't approved in the type certificate or other FAA authorization?

 

[Tom-D]

Who do you think gets the final say on whether or not the item is "of a kind and design appropriate to its intended function"? And how is that information conveyed by the manufacturer to the buyer? Not to mention how you comply with the aircraft's type certificate when you install a required item like an airspeed indicator that isn't approved in the type certificate or other FAA authorization?

Who has final say?? the person returning to service .

EASY,, field approval. or install as a minor alteration.

 

[poadeleted20]

Who has final say?? the person returning to service .

Wrong.

EASY,, field approval. or install as a minor alteration.

Wrong again. Field approval of unapproved parts for required flight instruments is hardly "easy," and installation of such unapproved parts for such a purpose is the fast track to an FAA enforcement action.

 

[RotorAndWing]

None whatsoever, but you can't fly it that way until you get that Experimental-Showing Compliance with Regulations airworthiness certificate, and there's no guarantee an STC will be issued after you finish the required inspections and testing. If the FAA declines, or the approved test period expires, then the plane is grounded until it's returned to its original configuration.

Actually you can put the aircraft into Experimental-Exhibition and do the same thing. I had a friend that put an Allison turbine in a TH-55 helicopter and put it under Experimental-Exibition. Also there was a fellow that put a turbine on a Luscombe and used the Experimental-Exhibition category.

There are restrictions in that category but it really depends upon the DAR or Inspector doing the airworthiness as to the level of restrictions.

 

[Kiddo's Driver]

Not relevant to the OP, but I converted my Sky Arrow S-LSA to E-LSA.

...

Main downside is no flight instruction or rental, but I had not planned on doing that anyway.

...

And that once done, you cannot go back to S-LSA.

You could have taken the three week LSRM-A course that Blue Ridge Community College offers every summer in Weyers Cave, VA. I did it this summer. It will allow you to do maintenance and condition inspections on S-LSA and E-LSA aircraft. It also allows you to be compensated for doing the work.
http://community.brcc.edu/aviation/index.php/light-sport/

You still would not have been able to make changes to your S-LSA like you can with your E-LSA.

Jim

 

[FastEddieB]

And that once done, you cannot go back to S-LSA.

I think there is a theoretical way it could be done, but for all practical purposes, you're right. In any case, it does not concern me.

You could have taken the three week LSRM-A course that Blue Ridge Community College offers every summer in Weyers Cave, VA. I did it this summer. It will allow you to do maintenance and condition inspections on S-LSA and E-LSA aircraft. It also allows you to be compensated for doing the work.

Jim

Thanks, Jim.

I have considered the 3-week course. Maybe next summer and VA is closer to home the some of the other options.

I took the 16 hour course to do my own annual condition inspections, but that's heavily focused on inspection, not maintenance.

Thanks again.

 

[N659HB]

Generally speaking, there is no requirement for TSO'd avionics in light planes, even production planes, although they must be approved aircraft parts. For example, the King KX-175 is the TSO'd version of the non-TSO'd KX-170, and you can put either in your Luscombe with neither STC nor field approval. Only for those avionics for which the regulations require TSO (like GPS's and transponders) must the avionics be TSO'd.

In the case of flight instruments for Standard airworthiness aircraft, it must be an approved aircraft part, TSO'd or PMA'd. This is discussed in the catalogs of suppliers such as Aircraft Spruce and Chief Aircraft.

Thanks, Ron. Good to know.

 

[Geico266]

Please do not assume that I am either cheerful or gleeful about the regulations, other than being gratified when people who want to know what the rules are learn the rules and how to comply with them.

The tone of your post was very negative, thats all I'm saying.

Regurgitation rules and regs is gratifying to you? You must be in hog heaven then.

 

[Geico266]

Actually you can put the aircraft into Experimental-Exhibition and do the same thing. I had a friend that put an Allison turbine in a TH-55 helicopter and put it under Experimental-Exibition. Also there was a fellow that put a turbine on a Luscombe and used the Experimental-Exhibition category.

There are restrictions in that category but it really depends upon the DAR or Inspector doing the airworthiness as to the level of restrictions.

I have moved foreign aircraft into this category. The only major restriction is the local FSDO needs to know where the plane is going past a 300 mile radius. If you are going out side that area an email or fax is all you need send. No reply is needed. It really was not an issue at all. Just send an email any time traveling outside that area.

This would be an easy category to use for the OP's project. I assume you could apply for STC's under the experimental category.