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Well here's an update for my LOA request, a big fat NOTHING after 2 1/2 months!

 

After emailing Patrick around my two month mark and he said he has not heard anything from CSA he gave me an email address to contact them directly. I've emailed 3 times with no response, not a word, nothing! I'll keep trying until they get sick of hearing from me, if they're not already!  

 

Squeaky wheel gets the oil, right?  :D

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31 October posting on CSA facebook page:

 

https://www.facebook.com/pages/Official-Czech-Sport-Aircraft-PS28-Cruiser/308000072545216

 

"ADS-B for SportCruiser/PiperSport aircraft existing fleet

Following the requirement applicable for the entire General Aviation fleet in the USA as of January 1, 2020 and calling for the ADS-B-out upgrade of all GA aircraft operated in the USA, Czech Sport Aircraft a.s. hereby informs all current users and owners of SportCruiser/ PiperSport aircraft operated in the USA that works on applicable and affordable solution of that requirement have been already started. We are analyzing the various systems available on the market with the objective to find the most suitable product for the SportCruiser/PiperSport aircraft

We will develop and present corresponding solution within such time frame that will provide and guarantee that all SportCruiser/PiperSport aircraft can be upgraded before January 1, 2020."

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This is good news.

 

At least CSA is acknowledging that there is a problem and they are key to solving the problem.

by CSA investigating and offering solutions with Letters of Authorizations in place

to allow installation in our CRUZ LSA aircraft.

 

I would recommend that SCFLIER members that are on Facebook

post comments on CSA 's Facebook notice above, providing details

on what CRUZ owners/Pilots would like and need in their ADS-B OUT/IN solutions

to meet the requirements of their various model year and avionics

configurations in the CRUZ fleet.

 

Social media may provide a conduit of information to CSA that they will listen to.

 

Time is of the essence. The clock is ticking to the December 31, 2019 deadline.

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In taking the SportCruiser to ELSA, would it be possible to have installed a certified GPS and make the plane IFR ready? Would a DAR and the FAA allow it?

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As long as all of the avionics, the engine, and of course the Pilot, as well
As the Maintenance checks and procedures follow and
have IFR ratings and capabilities, I believe an
Experimental LSA could be flown legally in IFR
conditions.

Certainly an Experimental RV-6, with an IFR RATED PILOT and
IFR CERTIFIED and Maintained avionics, can be flown IFR.
I know several IFR rated Private Pilots who fly their appropriately
Equipped EXPERIMENTAL aircraft IFR.

Also, a Night VFR current and proficient Private Pilot can legally fly
an appropriately equipped S-LSA at Night in VFR conditions.

Having said that, a significant portion of the
existing equipment on the CRUZ LSA
is

NOT

IFR CERTIFIED.

this might be an expensive modification path:

IFR CERTIFIED avionics,
Electrical systems,
IFR backups,
engine,
IFR maintenance checks,

the IFR list of modifications and steps required to fly IFR might be long.

But if approved by a DAR, it seems that it COULD be done starting with a CRUZ S-LSA converted to
E-LSA and then potentially executing a list of "IFR upgrades".

And assuming of course that an Instrument Rated Private Pilot Or higher was the PIC.

My opinion.

comments from those that are IFR RATED or have Experimental IFR Equipped aircraft ?

IMG_5733.PNG

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From AOPA, covering S-LSA

 

Special - Light-sport Aircraft

 

"Can I fly a special light-sport aircraft (S-LSA) in IFR conditions or at night?

 

Only day/VFR conditions are specifically addressed in the ASTM consensus standards that govern the design, safety, and production of S-LSA. Being that sport pilots and those exercising sport pilot privileges are limited to flying only in day/VFR conditions, this seems appropriate.

 

On the other hand, if an appropriately rated pilot (example: private pilot with an instrument rating) wants to fly S-LSA under IFR or at night, the aircraft's operating limitations must allow it, and the aircraft must be equipped per 91.205 for VFR flight at night and/or IFR flight. Additionally, 91.327(d) requires all S-LSA to be operated in accordance with the aircraft's operating instructions. Operating instructions differ from operating limitations in that the engine, airframe, and accessory manufacturers issue them; the FAA issues operating limitations."

 

E-LSA would follow the discussion in the above (prior) post, in my opinion.

 

But again some of the IFR E-LSA upgrades that

would need to be made to replace existing factory delivered S-LSA

equipment with IFR rated equipment, and to allow an IFR rated Private Pilot or higher

To fly an appropriately equipped, documented and maintained E-LSA IFR in actual IMC Conditions ....

 

.....might make for a long and expensive upgrade list.

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If the aircraft is properly equipped and the pilot is qualified, an E-LSA may be flown IFR.

Part 91.205 specifies equipment required.

Cheapest solution is probably Garmin SL-30. Your primary navigational/approach capability would be VOR/LOC/ILS using the SL-30 with Dynon/SV's non-IFR-approved GPS as "advisory". You could spend more and get an IFR-approved WAAS GPS such as the Garmin 430W and then be IFR GPS navigation and approach capable.

A certified engine and prop are NOT required for IFR on an uncertified E-LSA.

A backup AI is NOT required, but it would make sense if flying IFR in IMC to have a portable battery Dynon D1 or D2.

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I believe the SportCruiser that Musicman bought is IFR equipped. I flew it in South Carolina before he bought it and it has a Garmin 430 and I believe the SL-30. Not 100% the 430 is the WAAS version or not. The previous owner did his IFR training in this plane but wasn't allowed to take his check ride in it of course. Maybe Musicman can tell us more about his equipment. 

 

Are we getting a bit off topic or is it just me?  :D

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For those that want to read some of the legal details for

 

VFR (day) and VFR (night)

 

See

 

14 C.F.R. 91.205 b. and c. for the instruments and equipment required for both day and night VFR flight operations.

 

Also see Pilot proficiency requirements for night flight under 14 C.F.R. 61

 

Of course in addition to VFR weather conditions, both the Pilot AND the Aircraft need to meet the legal requirements ....

 

Both S-LSA and E-LSA IF equipped properly, can be flown VFR (day) and also VFR (night), assuming

The Pilot is at least a Private Pilot who is proficient and current with Night VFR flying requirements.

 

14 C.F.R 91.205

b. Visual-flight rules (day). For VFR flight during the day, the following instruments and equipment are required:

 

(1) Airspeed indicator.

 

(2) Altimeter.

 

(3) Magnetic direction indicator.

 

(4) Tachometer for each engine.

 

(5) Oil pressure gauge for each engine using pressure system.

 

(6) Temperature gauge for each liquid-cooled engine.

 

(7) Oil temperature gauge for each air-cooled engine.

 

(8) Manifold pressure gauge for each altitude engine.

 

(9) Fuel gauge indicating the quantity of fuel in each tank.

 

(10) Landing gear position indicator, if the aircraft has a retractable landing gear.

 

(11) For small civil airplanes certificated after March 11, 1996, in accordance with part 23 of this chapter, an approved aviation red or aviation white anticollision light system. In the event of failure of any light of the anticollision light system, operation of the aircraft may continue to a location where repairs or replacement can be made.

 

(12) If the aircraft is operated for hire over water and beyond power-off gliding distance from shore, approved flotation gear readily available to each occupant and, unless the aircraft is operating under part 121 of this subchapter, at least one pyrotechnic signaling device. As used in this section, “shore” means that area of the land adjacent to the water which is above the high water mark and excludes land areas which are intermittently under water.

 

(13) An approved safety belt with an approved metal-to-metal latching device for each occupant 2 years of age or older.

 

(14) For small civil airplanes manufactured after July 18, 1978, an approved shoulder harness for each front seat. The shoulder harness must be designed to protect the occupant from serious head injury when the occupant experiences the ultimate inertia forces specified in §23.561-b 2 of this chapter. Each shoulder harness installed at a flight crewmember station must permit the crewmember, when seated and with the safety belt and shoulder harness fastened, to perform all functions necessary for flight operations. For purposes of this paragraph—

 

(i) The date of manufacture of an airplane is the date the inspection acceptance records reflect that the airplane is complete and meets the FAA-approved type design data; and

 

(ii) A front seat is a seat located at a flight crewmember station or any seat located alongside such a seat.

 

(15) An emergency locator transmitter, if required by §91.207.

 

(16) For normal, utility, and acrobatic category airplanes with a seating configuration, excluding pilot seats, of 9 or less, manufactured after December 12, 1986, a shoulder harness for—

 

(i) Each front seat that meets the requirements of §23.785 (g) and (h) of this chapter in effect on December 12, 1985;

 

(ii) Each additional seat that meets the requirements of §23.785(g) of this chapter in effect on December 12, 1985.

 

 

c. Visual flight rules (night). For VFR flight at night, the following instruments and equipment are required:

 

(1) Instruments and equipment specified in paragraph b. of this section.

 

(2) Approved position lights.

 

(3) An approved aviation red or aviation white anticollision light system on all U.S.-registered civil aircraft. Anticollision light systems initially installed after August 11, 1971, on aircraft for which a type certificate was issued or applied for before August 11, 1971, must at least meet the anticollision light standards of part 23, 25, 27, or 29 of this chapter, as applicable, that were in effect on August 10, 1971, except that the color may be either aviation red or aviation white. In the event of failure of any light of the anticollision light system, operations with the aircraft may be continued to a stop where repairs or replacement can be made.

 

(4) If the aircraft is operated for hire, one electric landing light.

 

(5) An adequate source of electrical energy for all installed electrical and radio equipment.

 

(6) One spare set of fuses, or three spare fuses of each kind required, that are accessible to the pilot in flight.

 

 

 

§ 61.57 Recent flight experience: Pilot in command.

 

(a) General experience.

 

(1) Except as provided in paragraph (e) of this section, no person may act as a pilot in command of an aircraft carrying passengers or of an aircraft certificated for more than one pilot flight crewmember unless that person has made at least three takeoffs and three landings within the preceding 90 days, and—

 

(i) The person acted as the sole manipulator of the flight controls; and

 

(ii) The required takeoffs and landings were performed in an aircraft of the same category, class, and type (if a type rating is required), and, if the aircraft to be flown is an airplane with a tailwheel, the takeoffs and landings must have been made to a full stop in an airplane with a tailwheel.

 

(2) For the purpose of meeting the requirements of paragraph (a)(1) of this section, a person may act as a pilot in command of an aircraft under day VFR or day IFR, provided no persons or property are carried on board the aircraft, other than those necessary for the conduct of the flight.

 

(3) The takeoffs and landings required by paragraph (a)(1) of this section may be accomplished in a flight simulator or flight training device that is—

 

(i) Approved by the Administrator for landings; and

 

(ii) Used in accordance with an approved course conducted by a training center certificated under part 142 of this chapter.

 

 

b. Night takeoff and landing experience.

 

(1) Except as provided in paragraph e. of this section, no person may act as pilot in command of an aircraft carrying passengers during the period beginning 1 hour after sunset and ending 1 hour before sunrise, unless within the preceding 90 days that person has made at least three takeoffs and three landings to a full stop during the period beginning 1 hour after sunset and ending 1 hour before sunrise, and—

 

(i) That person acted as sole manipulator of the flight controls; and

 

(ii) The required takeoffs and landings were performed in an aircraft of the same category, class, and type (if a type rating is required).

 

(2) The takeoffs and landings required by paragraph b. 1 of this section may be accomplished in a flight simulator that is—

 

(i) Approved by the Administrator for takeoffs and landings, if the visual system is adjusted to represent the period described in paragraph b. 1. of this section; and

 

(ii) Used in accordance with an approved course conducted by a training center certificated under part 142 ....

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Letters of Authorization.

 

And CSA very reluctant to write them...

 

Great article posted above

 

....

 

"THE GREAT ESCAPE CLAUSE

 

As an aircraft owner for nearly 50 years and an active combatant in numerous struggles over ADs and maintenance requirements, if I have to be regulated, I’d much rather it be by the FAA than by the manufacturer of my aircraft or engine. We all love to complain about the FAA, but at least it is primarily motivated by a concern for safety, and is subject to numerous laws intended to protect us from overzealous regulation. In contrast, my experience with aircraft and engine manufacturers is that they primarily are motivated by concerns about being sued, and frequently act in ways that are harmful to those of us who own their products.

 

One evening over dinner in Sebring, I was talking to a staff member of the Experimental Aircraft Association about my concerns over the seemingly unfettered powers of coercion granted to LSA manufacturers. With a twinkle in his eye, he said, “Mike, that’s why we got the FAA to include the great escape clause.”

 

He explained that the owner of an SLSA who doesn’t care for how he’s being treated by the manufacturer of his aircraft has the ability to “opt out” by surrendering the aircraft’s SLSA airworthiness certificate and applying for an Experimental Light Sport airworthiness certificate to replace it. Then, he can basically ignore the manufacturer’s instructions and operate and maintain his factory-built LSA as he sees fit, almost as if it were an amateur-built Experimental.

 

By doing this, he probably gives up any remaining warranty and factory support to which he might have been entitled. He also gives up the ability to use his aircraft for compensation to give flight instruction or tow gliders. But what he gets in return is the ability to operate and maintain his LSA pretty much as he sees fit. Engine and propeller TBOs would become mere suggestions, the way they are for certificated aircraft. If the LSA is appropriately equipped, it probably can become legal to fly in IMC, assuming the designated airworthiness representative who approves its new operating limitations allows it."

 

Thanks EAA ! And also the FAA !

 

The great escape clause.

 

SLSA to ELSA

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Letters of Authorization.

And CSA very reluctant to write them...

Great article posted above

....

"THE GREAT ESCAPE CLAUSE

As an aircraft owner for nearly 50 years and an active combatant in numerous struggles over ADs and maintenance requirements, if I have to be regulated, I’d much rather it be by the FAA than by the manufacturer of my aircraft or engine. We all love to complain about the FAA, but at least it is primarily motivated by a concern for safety, and is subject to numerous laws intended to protect us from overzealous regulation. In contrast, my experience with aircraft and engine manufacturers is that they primarily are motivated by concerns about being sued, and frequently act in ways that are harmful to those of us who own their products.

One evening over dinner in Sebring, I was talking to a staff member of the Experimental Aircraft Association about my concerns over the seemingly unfettered powers of coercion granted to LSA manufacturers. With a twinkle in his eye, he said, “Mike, that’s why we got the FAA to include the great escape clause.”

He explained that the owner of an SLSA who doesn’t care for how he’s being treated by the manufacturer of his aircraft has the ability to “opt out” by surrendering the aircraft’s SLSA airworthiness certificate and applying for an Experimental Light Sport airworthiness certificate to replace it. Then, he can basically ignore the manufacturer’s instructions and operate and maintain his factory-built LSA as he sees fit, almost as if it were an amateur-built Experimental.

By doing this, he probably gives up any remaining warranty and factory support to which he might have been entitled. He also gives up the ability to use his aircraft for compensation to give flight instruction or tow gliders. But what he gets in return is the ability to operate and maintain his LSA pretty much as he sees fit. Engine and propeller TBOs would become mere suggestions, the way they are for certificated aircraft. If the LSA is appropriately equipped, it probably can become legal to fly in IMC, assuming the designated airworthiness representative who approves its new operating limitations allows it."

Thanks EAA ! And also the FAA !

The great escape clause.

SLSA to ELSA

There is a possible downside to taking the aircraft from S-LSA to E-LSA. It may decrease the resale value.

There are some prospective buyers (I have talked to several) who will not even consider a purchase of an Experimental or E-LSA.

It seems their reluctance has to do with how an aircraft has been maintained and by whom.

This speaks volumes about good record keeping and reputable mechanics, who give extra attention to detail.

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Excellent point.

 

In my investigations of the S-LSA to E-LSA conversion,  the potential drop in resale value is the only significant drawback,  in my opinion.

 

I totally agree on the need for Excellent Documentation of all Aircraft Maintenance and any Upgrades to the Equipment.  

 

Record keeping is key on ANY aircraft to maintaining a well documented history of the aircraft's Maintenance and operation,   and

excellent Maintenance records help with the resale value,  if/when the owner decides to sell the aircraft down the road.

 

I also believe that using an A&P for any maintenance,  even if "not required by Experimental aircraft Rules",  is an excellent idea.  

It is always good to have an unbiased, independent set of TRAINED Eyes on the aircraft during Maintenance.

 

Finally, note that the Owner can perform the annual (100 Hour) Condition Inspection on an E-LSA,  if the owner has completed the Light Sport Repairman - Inspection 16 hour course.  However,  even though that may have advantages,  I personally would prefer the 100 Hour Condition Inspection be performed by an A&P,   and/or a LSR-M,   who is extremely knowledgeable on Light Sport Aircraft,  and especially trained and knowledgeable  with the Rotax engine.

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In reference to Duane's (DnHill) question above on flying IFR in IMC with a CRUZ S-LSA that has been "converted" to an E-LSA Experimental Light Sport Aircraft

 

Posted 06 November 2016 - 01:57 PM

In taking the SportCruiser to ELSA, would it be possible to have installed a certified GPS and make the plane IFR ready? Would a DAR and the FAA allow it? 

Duane

2014 Sport Cruiser

 

I asked our local Designated Airworthiness Representative (DAR) the "IFR question" related to an aircraft changed from S-LSA to E-LSA 

 

and his reply was

 

"The following statement is standard in all Experimental Light-Sport operating limitations.

 

'...  Day VFR flight operations are authorized.      

Night flight operations are authorized if the instruments specified in § 91.205-c are installed, operational, and maintained in accordance with the applicable requirements of part 91.   

  

Instrument flight operations are authorized if the instruments specified in § 91.205-d are installed, operational, and maintained in accordance with the applicable requirements of part 91. All maintenance or inspection of this equipment must be recorded in the aircraft maintenance records and include the following items: date, work performed, and name and certificate number of the person returning the aircraft to service....'    "

 

So,  the discussion above by several folks are Spot-On Correct re IFR operations in a properly equipped and maintained and documented E-LSA.    

 

With an IFR rated and current/proficient Pilot,   IFR / IMC use is Perfectly acceptable and possible in an E-LSA if the aircraft owner wants to upgrade his Instruments per 91.205(d) and maintain/document them as required....

 

FYI

 

D

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More information on E-LSA Aircraft Operating Limitations from our local DAR, if an S-LSA owner decides to convert to Experimental E-LSA

there is a "Phase I" Flight test program that normally applies to Experimental - Amateur Built (example - Kit) Aircraft (E-AB).
This Phase I flight test program does NOT apply to factory built Special Light Sport Aircraft (S-LSA) being converted to E-LSA.

However, if a converted to E-LSA aircraft owner later modifies the aircraft to affect the aircraft handling or flight characteristics,
then a Phase I Flight Test program could apply. A normal safety procedure and flight test program for Experimental Aircraft.

In the Phase I flight test program, the aircraft is to be operated VFR without passengers, and in Day VMC conditions only, and in a (typically rural) flight test area as designated by the DAR. This would be a "non-congested area", for reasons of safety during the flight test program, and certainly no aircraft operation would be allowed in Bravo airspace during Phase I flight test (as it may occur or be required later with an E-LSA as a result of a modification).

After Phase I flight testing is complete, which is the case of course for a S-LSA that was production built and has ALREADY been flight tested by the original manufacturer, the E-LSA enters "Phase II" operating limitations, which are described in the post above re VFR/VMC Day and Night equipment requirements, and also IFR/IMC equipment/maintenance/documentation requirements, and additionally, some extra details below

1) The aircraft must be operated within the original flight test envelope, weight, airspeeds, and Cg limits as
already flight tested (by the Manufacturer in the case of an S-LSA later converted to E-LSA)

2) The normal aircraft limitation of "...fly with a sufficient altitude to make a safe emergency landing in the event of an engine failure....." -- applies to all aircraft, nothing really "new" here.

3) Externally carried equipment must be mounted in a manner which will prevent in-flight jettison. Normal precautions, and would not generally apply to most uses of the aircraft.


See the actual example Legal wording below, as would apply to an S-LSA to E-LSA Special Airworthiness Certificate.

The first picture is Phase II, in the case where an S-LSA has been previously flight tested by the Manufacturer.

The second Picture is Phase I Flight Test (only). Phase I Flight Test is N/A for Factory Built S-LSA's converted to E-LSA, assuming that the aircraft handling, flying characteristics, Cg envelope have not been later affected by an Owner's modification in the E-LSA Phase II time period. Returning to the Phase I Flight Test restrictions ONLY apply when an S-LSA converted to E-LSA REQUIRES additional Flight Testing, normally specified as a five hour Phase I (after modification) Flight Test period.

 

Note that § 91.305 specifies Flight test areas.

      ".....No person may flight test an aircraft except over open water, or sparsely populated areas, having light air traffic....."

 

After the E-LSA Phase I Flight Test program is successfully completed, the E-LSA would again return to a less restrictive Phase II Operating Limitations situation.

FYI.

 

Pictures:

 

The first picture is Phase II Operating Limitations, which applies in the case where an S-LSA has been previously flight tested by the Manufacturer.

The second Picture is Phase I Flight Test (only).   Phase I Flight Test is N/A for Factory Built S-LSA's converted to E-LSA (unless they are later modified to affect flight characteristics)

E_LSA_Operating_Limitations_Typical_from_FAA_DAR.jpg

E-LSA_PhaseI_Flight_Test_Only_this_is_N--A_for_S-LSA_Production_Aircraft.jpg

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The link below is to a letter that the EAA EXPERIMENTAL AIRCRAFT ASSOCIATION wrote to the FAA in an attempt to help S-LSA owners get ADS-B OUT equipment (and other modifications) legally made on their S-LSA aircraft.

 

The EAA cites concern over S-LSA manufacturers that have gone out of business, and also S-LSA manufacturers that are reluctant to provide a Letter of Authorization (LOA) for installation of ADS-B OUT equipment mandated by the FAA.

 

Interesting reading. I do not know what the FAA outcome of this letter has been. Designating a specific "...person acceptable to the FAA", to authorize changes.....as recommended in the letter by the EAA, a proposal to use certain LSA knowledgeable A&P Mechanics who are ATP pilots, FAA Experts in the Chicago ACO sounds like a great idea......

 

FYI

 

Excerpt from the EAA letter

 

"One area of recreational aviation that still has a pressing need for more accommodating policy is Special Light-Sport Aircraft (S-LSA). These aircraft cannot be modified without the approval of the manufacturer or “a person acceptable to the FAA” (14 CFR 91.327-b-5)). For some S-LSAs, the manufacturer may be out of business (creating an “orphaned” aircraft) or it may be unwilling to approve a specific change. A recent survey by the Small Airplane Directorate found little to no support among existing manufacturers for retrofitting ADS-B equipment on existing designs.

 

The only recourse an operator would have for the above would be to redesignate their aircraft as an Experimental Light-Sport Aircraft (E-LSA) – this is troublesome as it involves greater expense for insurance, operational restrictions on the aircraft and a great devaluation of the aircraft itself. Also, by placing an LSA into experimental status, fleet safety may suffer as requirement to strictly adhere to the approved Standard is longer present.

 

ADS-B compliance is such a critical issue to the general aviation community that every avenue should be pursued in enabling equipage in S-LSA. EAA therefore submits the following proposal to the record as a means to leverage the “person acceptable to the FAA” clause of 14 CFR 91.327-b- 5) to allow ADS-B equipage in S-LSA without manufacturer oversight."

 

The link to the letter itself

 

https://www.eaa.org/en/eaa/eaa-news-and-aviation-news/news/~/media/f0710b3cb6ce479cbc5e4cc39790df47.ashx

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For those in the USA that are Private Pilot and above with an Instrument rating, and may be considering going E-LSA and upgrading their NAV/COM/GPS equipment to IFR Certified, and fly IFR in IMC,

 

here is a handy excel file from GARMIN That shows which of their IFR certified products have which capabilities---drives which codes you may enter in the flight plan.....example.... /G as compared to /U....

 

https://static.garmincdn.com/apps/fly/files/support/icao-flight-plans/Garmin_ICAO_Flight_Plan_Information.xlsx

 

Looks to me that in order of steeply increasing cost, one might consider

 

GNS430W

 

GNS530W

 

GTN650

 

GTN750

 

some like the 430W could be found at a fairly "reasonable" ? Price in the used market

 

Might have to add an external alternator to supply enough Amps to run some of these devices

 

And weight and balance would of course need to be considered ... maybe an upgrade to the EarthX LiIon battery which saves over 6 pounds.....might be worth adding to your Christmas gift list...

 

"All" it takes is money and an IFR rating and an E-LSA....

IMG_0911.PNG

IMG_0916.PNG

IMG_0914.PNG

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Some good reading on "where did all this Letter of Authorizations stuff required for S-LSA modifications come from ?"

 

http://www.rainbowaviation.com/articles/Major%20Repairs.pdf

 

Describes how the Aircraft Manufacturer must write LOAs for modifications after S-LSA production aircraft

Certification, and who must sign the LOA from the manufacturer, and what type of information

And instructions are provided in a Letter of Authorization to modify a SPECIFIC serial number aircraft....

 

And more....

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Here's another news article from AOPA in March of 2015 where the FAA urged LSA manufacturers to move on ADS-B AND AOA. This has obviously fallen on deaf ears in the Czech Republic. The FAA sent this request to 65 LSA manufacturers.

 

https://www.aopa.org/news-and-media/all-news/2015/march/11/faa-urges-lsa-makers-to-move-on-ads-b-and-aoa.

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Great links to articles from AOPA and EAA supporting ACTION on ADS-B and AOA for S-LSA's that need Letters of Authorization from some reluctant S-LSA Aircraft manufacturer's.  

 

ADS-B OUT solutions and Angle of Attack solutions are high on our SCFLIER FORUM Ranked List of Items needing LOA Action from our manufacturer CSA in the Czech Republic.  

 

a comment on the LSA/Experimental aircraft ADS-B OUT solutions...from the AOPA link above....

"The letter also noted that the ADS-B equipment to be installed must meet the “performance” requirements of the technical standard order (TSO) for ADS-B Out, meaning TSO approval is not necessary."

That seems like a great idea for LSA's and Experimental Aircraft.   Make ADS-B OUT equipment that meets the GPS "PERFORMANCE" requirements,  and make the equipment cheaper by not requiring full TSO Approval.    Awesome.

But after FAA AD actions on Navworx "Experimental and LSA" ADSB OUT units,  only the CERTIFIED NAVWORX ADS600-B equipment,  the ones with part numbers ADS600-B part number 200-0112 and ADS600-B part number 200-0113,  which have a TSO CERTIFIED Internal GPS Position source,   are allowed to be used for ADS-B OUT transmissions in the USA FAA ATC controlled airspace.

 

The ones with "un-certified GPS Position sources",  part numbers ADS600-EXP, and 200-0012 and 200-0013,  have been the subject of an FAA AD and inspections requested at the Navworx factory.

The FAA has recently taken the special care to REQUIRE Certified GPS Position sources for ALL ADS-B OUT units.  I can certainly see the point of view of the FAA in making sure that the GPS position that is sent down to the FAA ground towers from aircraft using ADS-B OUT is VERY Accurate,  because ATC is going to use that ADS-B OUT GPS position data from airliners as well as General Aviation aircraft in Class B and Class C airspace to SAFELY SEPARATE TRAFFIC in the air.   Great !  Makes sense.

This Navworx box 200-0112 has a full TSO Certified GPS Position Source.   The Navworx ADS600-0112 Passes all the FAA In-Flight ADS-B OUT performancr checks.

ADS-B_OUT_and_S-LSA_Meet_Performance_Requirements_FAA_Directive-2015.jpg

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Just curious, is there any restriction on the ROTAX engine flying in IFR conditions? "The 912ULS and its certified sibling, the 912S, are built on the same Austrian factory floor, by the same technicians, to the same standards and specifications, out of the same parts bins. The main differences are the data plate (red vs. black), and of course the price."

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As far as I am aware,  using a Rotax 912 ULS in an S-LSA is not legal for IFR operation.  

There are no Letters of Authorization in place for our CRUZ S-LSA (that I know of.....) that allow IFR operation in IMC with our S-LSA.

If CSA would provide a list of all approved Letters of Authorization,  the answer to that question might be easier.

 

however,  with an E-LSA,   the Day VFR/Night VFR/IFR requirements and Operating Limitations that go with the aircraft are different.

 

"The following statement is standard, according to our North Texas FAA DAR,  in all Experimental Light-Sport operating limitations.

 

'...  Day VFR flight operations are authorized.      

Night flight operations are authorized if the instruments specified in § 91.205-c are installed, operational, and maintained in accordance with the applicable requirements of part 91.   

  

Instrument flight operations are authorized if the instruments specified in § 91.205-d are installed, operational, and maintained in accordance with the applicable requirements of part 91. All maintenance or inspection of this equipment must be recorded in the aircraft maintenance records and include the following items: date, work performed, and name and certificate number of the person returning the aircraft to service....'    "

 

Rotax has over the years,  changed some of their wording in their manuals and directions re Night VFR use,   relaxing it from years ago where it was "not allowed by Rotax",  to the most recent where it IS allowed under the S-LSA Operating limitations in place (updated) for a particular aircraft,   IF the required Night VFR equipment such as cockpit night lighting,  NAV lights, strobes,  and aircraft electrical equipment (battery backups and more) are in place, suitable for Night VFR operation.

 

I know your question was IFR with a uncertified Rotax 912ULS engine as opposed to a certified Rotax 912S which is the same engine but more expensive and of course "certified".

 

In the S-LSA world,  the question of VFR or IFR use is CONTROLLED BY THE S-LSA Manufacturer,  which in our CSA case (I presume) would defer to the guidance of Rotax,  and in effect,  we in the S-LSA world are restricted to "no IFR use" by the Letter of Authorization requirement for S-LSA production built aircraft.    I believe it is one way for the aircraft (and engine) manufacturer's to Limit their Liability in a very litigious society here in the USA. 

 

there is a LOT of bad information (my opinion) out there if you GOOGLE "ROTAX 912 and IFR" on the web.  

   Lots of folks Google and post and replicate bad information - on other forums......on the internet.....

 

my understanding is based on discussions with the North Texas USA FAA Designated Airworthiness Representative (DAR),  who offered the above guidance on VFR Day, VFR Night, and IFR (in IMC) operation of an Experimental E-LSA.      

 

 The formal legal Operating Limitations documented for a particular aircraft at the time of Special Airworthiness Certificate generation is key

 

I believe the key item needing "upgrade" in the CRUZ for operating  IFR in IMC would be replacing for example an uncertified portable GPS such as a Garmin 696 or a Garmin 796 with an IFR Certified (and maintained and documented....) GPS such as a Garmin GTN650 or GTN750.   Expensive and heavy and takes more current to run them.   But IFR Certified.  And allowed by E-LSA Operating limitations that I have seen.

 

It is a confusing world out there in the land of Google.     But my understanding from the USA FAA North Texas DAR is that you COULD fly a Rotax 912ULS with a Garmin GTN750 installed in a CRUZ E-LSA,  of course with an IFR Rated, proficient, and current Private Pilot or higher,  using IFR in IMC conditions.   This understanding on an Experimental aircraft powered by a Rotax 912 engine does NOT require a "Certified" Rotax 912S.

 

I don't know of any CRUZ E-LSAs that have taken all those IFR/IMC IFR certified Instrument GTN650/750 steps,  but it seems plausible.   It is also very interesting that in the CSA Manuals,  there are equipment drawings and descriptions of the Garmin GTN650/750 product line.....maybe someone has already done this and CSA is not advertising the fact.

 

my opinion only.   But I trust talking to an FAA DAR experienced in Rotax powered E-LSA aircraft more than Googling my way to an answer....

 

a great question.

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We've discussed all this previously. E-LSA flight conditions IFR in VMC or IMC does NOT require a certified engine or prop.

Nav equipment (VOR/LOC, ILS glideslope, GPS enroute, GPS non-precision approach, GPS WAAS approach) must be certified.

Garmin 496/696 units are not certified. But you can still have them switched on as "advisory" provided not the primary source of navigation.

.

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