S-LSA to E-LSA

[chanik]

I've been reading up on this in many places, including that other CT site, and it occurs to me that there are many significant ramifications to such a move. I started worrying about this before getting into my CTSW since the market is so tenuous with aircraft companies dying like gulf-coast seabirds. Basically, it seems such a transition would be necessary if the company went belly-up. You convert your plane to Experimental, put the stickers on the side, and then service it as best you can. It's an option anyway if you want to make un-approved modifications to your bird but I was surprised by some of the nuances associated with such as move:

 

On the negative side:

1. 
    
   
2. You bascially void any manufacturers' warranties of course.
   
3. You'd have to change your insurance over to ELSA or it would be void as well.
   
4. Likely drop your resale value
   
5. Cannot rent it out anymore
   

On the plus side:

1. 
    
   
2. SB's would be at owner discretion
   
3. 100hr inspection is no longer required but annual still is
   
4. IFR becomes an option
   

This last one sort of surprised me but after reading an article by Dan Johnson and finding the FAA requirements:

http://www.faa-aircraft-certification.com/experimental-lsa-operating.html

and reading up on this equipment FAQ:

http://www.bluemountainavionics.com/pdf/IFR%20equipment.pdf

I'm pretty sure this is correct. You'd need a VOR receiver but in the looser world of non-TSO'd Experimental avionics something like the new SPORTY 400 would be enough

http://sportys.com/pilotshop/product/14807

I used to fly a LONG-EZE that was IFR capable which had much less of a panel than my CTSW so this makes a certain sense to me. It didn't have lightning protection or heated pitot tube either.

 

Anyway, I don't plan to drop out of S-LSA category anytime soon but I would be interrested to get some feedback on this since I've never seen it spelled out elsewhere that there is a way to fly IFR in these birds.

[Roger Lee]

Hi Kurt,

 

You are right on all accounts. The insurance will almost double going to ELSA for the amount we have our planes insured. I gave it some thought just before I recieved my CT, but thought better of it after I did the research. High insurance and low resale turned me away from the idea. It think it might be an option if a company went belly up.

[chanik]

Hi Kurt,

 

You are right on all accounts. The insurance will almost double going to ELSA for the amount we have our planes insured. I gave it some thought just before I recieved my CT, but thought better of it after I did the research. High insurance and low resale turned me away from the idea. It think it might be an option if a company went belly up.

 

I wondered about the insurance. Seems hull would go up since you're operating much less constrained but for just liability, I don't think it would matter much. My basic insurance for the Rutan was very low; about the same as when I owned a Traumahawk. In a forum below a Skyarrow owner also said his insurance rate didn't really change, probably he doesn't have hull. With the 16hr course though, an E-LSA owner can do his own annuals, oil changes, etc with impunity. The IFR angle is most intriguing to me. I think the huge downside is the likely loss of resale value. Maybe $20K or so but I've never seen a E-LSA CT sold so I have nothing to go on there.

[Roger Lee]

Hi Kurt,

 

When I looked into it Avemco, they said that when you add the "E" on the front the insurance almost doubles from that of SLSA if you keep the same coverages. Mine would have gone from $2100 to $4200 if I kept the identical amounts. Their reasoning is that ELSA doesn't have to have a certified mechanic to work on it, doesn't have to keep up with SB's and only has an annual which could be done by the owner. They look at it as having a less trained individual work on it and maybe not kept up to standards. I'm sure they equate this to more problems and a bigger chance for a claim later. Most people that have ELSA's don't have them insured for the same amounts we do as SLSA owners. Not many ELSA owners are insured for $110k-$150k and for hull, liability and medical. many ELSA owners only have liability and some a reduced amount of hull.

[chanik]

All right, I am officially an ELSA. Insurance didn't change. No immediate experiments planned.

[Jim Meade]

I'm planning to change my SW to ELSA very soon because I'm installing a SkyView 10" and FD will not issue an LOA, according to my phone conversation with Arian of FD USA. I chatted about this issue a little today with Tom, the FD USA owner and he saw no relief. In a discussion with the Rainbow Aviation people, the issue of SLSA, ELSA and E-AB was discussed. There was discussion that insurance and resale rates might change but perhaps more especially in the E-AB option.

 

In my own case, the SkyView may hold value better than the current panel, there is probably zero likelihood that anyone will buy an older CTSW for use as a rental or trainer, and the personal satisfaction I'll gain from having the plane the way I want it is adequate to me. When it comes down to it, each owner makes his own choice and no one else's opinion matters a whit.

 

 

[Runtoeat]

Hi Kurt and Jim. I would appreciate it if you might provide occasional updates regarding your "pros and cons" of E-LSA ownership. This is a subject that seems to make more and more sense to me the more time goes by owning my CTSW. This probably will be my first and last airplane I'll own and I'm not concerned about the value of it when it comes time to sell. The first question I had was insurance costs and based on your post, this appears to not be a problem.

[kentuckynet]

Im ELSA as well....never looked back!

 

I dont have insurance and never plan to sell................

[chanik]

Surprisingly the insurance didn't change. No idea about resale as I can't find a single instance of an ELSA CT or Remos or Tecnam ever sold. The minus side is obvious, but on the plus side, I can now fly actual IFR in it (light overcast for me only. Experimenting with ice and lightning seems a bad idea). I can fix the Ducati regulator problem, swap out Aveoflash units for the crappy LED lights that are failing on my wingtips and tail. I can use 8-ply tires at 35psi, update my panel and use the right size Sensenich prop. I can skip the parachute repack, or fly without while it is serviced. All without LOAs that mostly I wouldn't be able to get anyway. I plan on mostly sticking to the FD recommendations and keeping good records, like Roger always emphasizes, but largely the resale issue is also moot for me as I have no plans to sell either. I would guess that the IFR option might more than compensate for the questionable nature of EXPERIMENTAL though. My flight instructor friend thought so. Now he wants to buy into one, but before he wasn't interrested.

[FastEddieB]

Elsewhere on this site I documented my changing my Sky Arrow to E-LSA.

 

In my case, the insurance actually went down a little bit, but this reflected the fact they'd only insure it for $50k hull value, as opposed to the $70k I had before. All this through the EAA's "Falcon" Insurance.

 

I cannot overstate the freedom of E-LSA, if you're mechanically handy. It enabled me to add the "Soft Start" module without asking anyone's permission, and to install an Odyssey Battery without getting 3i's approval - and approvals by them were not forthcoming in general, even for simple part substitutions. I did take the 16-hour Inspection course and did my last "annual". To correct a prior post, this course has nothing to do with changing the oil or otherwise maintaining an E-LSA - anyone can do that with no certification required.

[Jim Meade]

For those of you who have already gone ELSA.

 

1. Did you get new operating conditions issued?

 

2. Were you restricted from flying over congested or densely populated areas or airways?

 

 

 

 

 

[chanik]

For those of you who have already gone ELSA.

 

1. Did you get new operating conditions issued?

 

2. Were you restricted from flying over congested or densely populated areas or airways?

 

1) No new limitations.

 

2) Sure, just like every other experimental out there which is effectively the same limitation certified aircraft have.

[207WF]

Are you SURE about being able to go IFR even when the engine is not approved for it by Rotax AND the airframe is not approved for it by the manufacturer? If we could do IFR, I would be sorely tempted! WF

[chanik]

I covered alot of this ground in the similar thread, CT to ELSA http://ctflier.com/index.php?/topic/81-ct-to-elsa/page__st__20

but basically, the FAA NEVER certifies anything as IMC capable. They say

(11) After completion of phase I flight testing, unless appropriately equipped for night

and/or instrument flight in accordance with 14 CFR § 91.205, this aircraft is to be operated under VFR day only.

Then it is up to the owner to make sure they meet the MEL. The block that goes away with an ELSA is FD with their prohibition in the POH. As for ROTAX, they are understandably just covering their butts. But specifically to your point, the FAA does not require experimentals to have explicit consent or endorsement from equipment manufacturers to operate in IFR or IMC. I did have a long talk about all this stuff with the FAA examiner. What might happen soon though is a blanket prohibition from the FAA against any IMC operation for new LSA plane registrations and they would require a placard saying as much. This is because they can't seem to come to terms with an IFR-lite sort of definition that would be appropriate for our lightning and ice-vulnerable birds. Old ones already equipped for IFR would be grandfathered in.

[Flying Bozo]

Hmmm. I don't get it, the Experimental LSA Operating Limitations link that was in the first posting says VFR Day only on item #10. That pretty much excludes any IFR.

Larry

Flying Bozo

Cottonwood, AZ

[chanik]

This is the same for every experimental out there.

unless appropriately equipped... means when equipped, IFR and night are OK. 91.205 speels out the requirements. Basically, you need a mounted VOR receiver to minimally qualify for IFR.

[Flying Bozo]

This is the same for every experimental out there.

unless appropriately equipped... means when equipped, IFR and night are OK. 91.205 speels out the requirements. Basically, you need a mounted VOR receiver to minimally qualify for IFR.

I don't think so if you believe the number 10 on the light sport operating rules that have a link in the first post on this topic. Number 10 clearly states that the limitation is day VFR only so that seems to preclude any IFR doesn't it?

[chanik]

10. This aircraft is to be operated under VFR day only.

 

 

11. After completion of phase I flight testing, unless appropriately equipped for night and/or instrument flight in accordance with FAR 91.205, this aircraft is to be operated under VFR day only.

 

 

So then 11 contradicts 10

 

Basically, the FAA writes confusing regs. It's worth noting that most S-LSA OEMs support night flying, many IFR, and some even IMC. They couldn't claim any of it if this were really prohibited by the FARs

[Roger Lee]

LSA can not fly IFR

[Tomasz]

LSA can not fly IFR

Why? Last time I've checked FAR did not prohibit IFR flights in LSA. Can you point me to such info?

[Jim]

No IFR for S-LSA because nobody makes an instrument-rated S-LSA and the manufacturers won't approve the mods to make one instrument-rated. It may also be disallowed in the ASTM standards. As for E-LSA, it's all up to you to make the aircraft IFR legal.

[Runtoeat]

Jim is correct. If there were a manufacturer that sold a LSA which had TSO'd instruments (the Garmin 327 transponder installed in CT's is a TSO'd instrument) AND a certified engine (the Rotax 912ULS is not a certified engine), I belive that the LSA which incorporated these things would be able to fly IFR.

[Tom Baker]

Jim is correct. If there were a manufacturer that sold a LSA which had TSO'd instruments (the Garmin 327 transponder installed in CT's is a TSO'd instrument) AND a certified engine (the Rotax 912ULS is not a certified engine), I belive that the LSA which incorporated these things would be able to fly IFR.

 

ASTM standards now say flight in IMC prohibited. Prior to the change in the standards if the airplane had IFR equipment, and it was not restricted by the manufacture it could be flown in IMC. Until the IFR standards are established no flight in IMC for any new LSA's. You can however file and fly on an IFR flight plan and work within the system if your airplane the required equipment, just no IMC.

[chanik]

No IFR for S-LSA because nobody makes an instrument-rated S-LSA and the manufacturers won't approve the mods to make one instrument-rated. It may also be disallowed in the ASTM standards. As for E-LSA, it's all up to you to make the aircraft IFR legal.

That is basically it. FD could have made an IMC rated S-LSA before 2010 but now they cannot. It is only in the E category that you could fly in true IMC, not that it would be a good idea to dive into hard IMC with these lttle birds. The reason it is easy in E-LSA is that the FAA does not require the equipment in the MEL to be TSO'd or IFR certified by any OEMs. It's really up to the 'experimenter'. There is surprisingly little in the MEL, in fact. Even the requirement for navigation equipment receiving signals from ground stations (VORs) is dropped as of 2009 FARs. from 91.205:

 

 

(d) Instrument flight rules. For IFR flight, the following instruments and equipment are required:

 

(1) Instruments and equipment specified in paragraph ( of this section, and, for night flight, instruments and equipment specified in paragraph © of this section.

(2) Two-way radio communication and navigation equipment suitable for the route to be flown.

 

(3) Gyroscopic rate-of-turn indicator, except on the following aircraft:

<snip>

 

(4) Slip-skid indicator.

(5) Sensitive altimeter adjustable for barometric pressure.

 

(6) A clock displaying hours, minutes, and seconds with a sweep-second pointer or digital presentation.

 

(7) Generator or alternator of adequate capacity.

 

(8) Gyroscopic pitch and bank indicator (artificial horizon).

 

(9) Gyroscopic direction indicator (directional gyro or equivalent).

 

Really that's all the FAA has to say about it.

[Jim Meade]

319CT is now E-LSA. Had it done while by Bryan Carpenter while attending the LSMR-A class at Oshkosh. I had to change out the Light Sport for Experimental placards and had to add a placard advising passengers that the airplane was Experimental, etc.

I had talked with the FSDO about it and they would have done it free in about 30 days after they assigned an inspector to it. I paid Carpenter for the service, but it was done pretty painlessly.

My insurance agent said there would be no change in premium if there was no change in insured value. He asked for the reason why - not to second guess me but to verify there was not a big valuation change. I told him I was going to put in 2 10" SkyView panels and he asked if I'd increase hull value. I said not now...I'd think about it and could modify if if I decided it was worth it.