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BirdDog

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Our Evektor Sportstar (and Birddogs presumably) is facory built LSA (specifically SLSA).  Which, as I understand it, is an international standard. 

Edited by SGM
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To answer the original question;

if it were me and I had the money to burn, I'd pick 4a or 4b.

Keep the Sportstar and run on condtion, the deciding factor between 4a or 4b is whether RAA allow you to run on condition for factory built LSA and the cost of the Evektor Glass panel approval.

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21 minutes ago, RossK said:

To answer the original question;

if it were me and I had the money to burn, I'd pick 4a or 4b.

Keep the Sportstar and run on condtion, the deciding factor between 4a or 4b is whether RAA allow you to run on condition for factory built LSA and the cost of the Evektor Glass panel approval.

 

Yep!  That's about where I am sitting at the moment.  I think if I can't get Evektor to come to the party, I won't install unauthorised and just leave as is.  Will sit and decide whether to sell now or not etc.  So will wait and see.  

I have no problem going to E24 for "On Condition:" if I have to, as an quick engine swap, should enable the 24 rego again.  So really just a paperwork exercise for nothing!  LOL!

 

 

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Has RAAus defined in any official document or manual what the term "On Condition" means? If there is such a definition, then that's the end of the discussion. If not, the discussion continues.

 

My reading of that letter from Continental suggests to me that if a part is still within the limits described in its specifications, than it is OK to keep using it until 

(a) it has, or is likely to, exceed specification limits before the next scheduled inspection, or

(b) a calendar time, or number of operation cycles, prescribed by the manufacturer is reached.

 

A good example of a part that is more likely to exceed calendar time than hours are fuel and oil hoses.

 

This is what CASA Airworthiness Bulletin 85-004 says This AWB provides guidelines for procedures to be followed to ensure continued airworthiness of the engines that have exceeded the calendar time overhaul limits specified by the manufacturer. These guidelines are in addition to the recommendations by the manufacturers relating to inspections for corrosion.

https://www.casa.gov.au/sites/default/files/_assets/main/airworth/awb/85/004.pdf?acsf_files_redirect

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RAA has an LSA Synopsis here

https://members.raa.asn.au/storage/lsa-synopsis.pdf

extract from that; 

 

"The Special Certificate of Airworthiness for LSA is for production ready-to-fly aircraft. These aircraft may be used for hire, flying training and towing gliders. The Special Certificate of Airworthiness remains valid provided the aircraft is maintained in accordance with the requirements of the manufacturer and the aircraft has not been modified unless approved by the manufacturer. However, if the aircraft is not maintained in accordance with the manufacturer, or the manufacturer can no longer provide the continuing airworthiness, or the aircraft is modified without the manufacturer’s approval, the Special Certificate of Airworthiness will no longer be in force and the owner will need to apply for an Experimental Certificate to operate the aircraft"

 

Evektor Manual says motor to be maintained in accordance with the Rotax Maintenance manual.

Rotax maintenance manual lists TBO as 2000hrs or 15 years. Doesn't say anything about running on condition, so doesn't allow or specifically disallow, depends on your interpretation.

 

EDIT:

from the Rotax Maintenance Manual;

"GENERAL OVERHAUL (TBO)
Definition The time between overhauls (TBO) for all objects (such as the engine, component assemblies,
add-on components) is the approved length of operation under normal operating
conditions before it becomes mandatory to send in these objects for an overhaul.
Normal operating conditions are the conditions which comply with the manufacturer's and
the aviation authority’s recommendations for the certification of airworthiness."

 

They've used that word, mandatory, so to comply with the Special Certificate of Airworthiness for LSA, it is mandatory to overhaul the motor at TBO.

Edited by RossK
Rotax information added
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RossK - "They've used that word, mandatory, so to comply with the Special Certificate of Airworthiness for LSA, it is mandatory to overhaul the motor at TBO."

 

Only if you wish to maintained the privilege of being able to use your aircraft for hire  or reward (SCA). If you are willing to alowe the aircraft to move to E status you can continue to operate on condition. 

 

Rotax, in common with all  engine manufacturers, is not interested in having their engines go beyond factory TBO neither do they prevent such action.

 

 

 

 

 

 

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19 hours ago, SGM said:

Our Evektor Sportstar (and Birddogs presumably) is facory built LSA (specifically SLSA).  Which, as I understand it, is an international standard. 

 

SGM - was this your reply to my question?

 

SGM ; Soooo "Van’s RV–12 SLSA powered by a Rotax 912ULS, you are required by regulation to overhaul it at the 2,000-hour mark—because that’s what Rotax says to do" is a factory built aircraft in Australia ?????????

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39 minutes ago, skippydiesel said:

 

SGM - was this your reply to my question?

 

SGM ; Soooo "Van’s RV–12 SLSA powered by a Rotax 912ULS, you are required by regulation to overhaul it at the 2,000-hour mark—because that’s what Rotax says to do" is a factory built aircraft in Australia ?????????

SLSAs are a different category, SLSA homebuilts don't have to be 51% owner built according to my reading of the SLSA regulations.

So a homebuilt RV-12 built to the factory build plans would get its Certificate of Airworthiness under the SLSA provisions, and therefore need to be maintained as per Vans RV manual.

If you deviate from the plans it would be Experimental SLSA.

That's how I understand it, but I could be wrong, it has happened before 😁

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21 minutes ago, RFguy said:

if you want a bit of glass, try an Uavionix AV-30  (or a pair of them) - they fit in a round hole.  but that's off topic.

Ours has had an Aspen EFD1000 fitted, which gives both AH and DG, plus a few other functions.

Fits in the Round hole where the Steam AH was.

16040950745337231340700705964817_2836214350956662.jpg.af2006c63fe9e5b42bf49cb95d1e5644.jpg

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35 minutes ago, RossK said:

SLSAs are a different category, SLSA homebuilts don't have to be 51% owner built according to my reading of the SLSA regulations.

So a homebuilt RV-12 built to the factory build plans would get its Certificate of Airworthiness under the SLSA provisions, and therefore need to be maintained as per Vans RV manual.

If you deviate from the plans it would be Experimental SLSA.

That's how I understand it, but I could be wrong, it has happened before 😁

Curious ! - kit built but somehow comes under factory built - anyone out there able to explain?

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8 hours ago, skippydiesel said:

Curious ! - kit built but somehow comes under factory built - anyone out there able to explain?

"SLSAs are a different category, SLSA homebuilts don't have to be 51% owner built according to my reading of the SLSA regulations.

So a homebuilt RV-12 built to the factory build plans would get its Certificate of Airworthiness under the SLSA provisions, and therefore need to be maintained as per Vans RV manual.

If you deviate from the plans it would be Experimental SLSA.

That's how I understand it, but I could be wrong, it has happened before 😁"

 

 

This makes no sense to me but stranger things have happened -Under RAA regulations, is it possible to have a kit built aircraft recognised as a factory build ???

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UPDATE - I have preliminary approval from Evektor to install glass if I wish.  I am just waiting on the LOA.

 

They have provided info on 3 models they approve.  D700 D1000 and a Garmin unit.

 

Will keep you updated.

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28 minutes ago, BirdDog said:

UPDATE - I have preliminary approval from Evektor to install glass if I wish.  I am just waiting on the LOA.

 

They have provided info on 3 models they approve.  D700 D1000 and a Garmin unit.

 

Will keep you updated.

I would speculate that if you ae moving to RAA E the need to get factory approval is moot

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1 hour ago, skippydiesel said:

I would speculate that if you ae moving to RAA E the need to get factory approval is moot

 

Not quite!  Because when I sell it, if the new owner wants to rent it, train in it etc, all they would need to do is replace the donk.  Without Evektor approval, it will NEVER be able to go back to 24.

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1 hour ago, BirdDog said:

 

Not quite!  Because when I sell it, if the new owner wants to rent it, train in it etc, all they would need to do is replace the donk.  Without Evektor approval, it will NEVER be able to go back to 24.

Fair enough.

 

I  have my doubts about the return to "factory built rego' after becoming an E (does that stand for Experimental ?) which implies (at least to me) that the aircraft no longer meets the criteria to be "factory".

 

Replacing the engine befor or on TBO run out, certainly would meet the criteria - continuing "on condition" would seem to me that you have "left the fold" so to speak.

 

I guess if Evektor are happy to approve your changes, then all well & good BUT what if down he track you want to d something they wont approve? (eg fit an menstruate not on their list) AND what if even further along, you or prospective purchaser want to return it to "factory" and they say computer says Nooooooo! ?????

 

Might be pertinent to get something in writing from Evektor and/or RAA

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Skippy, 

 

I spoke to RAA today, and the E24 rego can be reverted back to 24, if the engine was replaced.  So a scenario like this....

 

At TBO, I apply and get issued an E24 rego.  That allows me to continue running on condition.  Then, 3, 4, or 5 years later (or whenever) me or a new owner can simply put a new motor in, and revert it back to 24 Rego - PROVIDED that any other mods done are approved by Evektor (Glass etc).  If do those mods unapproved, there will likely be no way back to 24. Hence why I need their approval, or no glass gets installed.

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1 hour ago, BirdDog said:

Skippy, 

 

I spoke to RAA today, and the E24 rego can be reverted back to 24, if the engine was replaced.  So a scenario like this....

 

At TBO, I apply and get issued an E24 rego.  That allows me to continue running on condition.  Then, 3, 4, or 5 years later (or whenever) me or a new owner can simply put a new motor in, and revert it back to 24 Rego - PROVIDED that any other mods done are approved by Evektor (Glass etc).  If do those mods unapproved, there will likely be no way back to 24. Hence why I need their approval, or no glass gets installed.

Sorry to be nosey, but how old are you?  If you are as ancient as me.......what I own now,  I will be happy to fly my aircraft to my grave with steam guages , 345 Hrs and flying on condition with 19 rego.  Will pimp it and play with it and  the fact that it flys is good enough for me, don’t care about resale as that will be my estate executors problem after I croak it 🙂

 

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2 hours ago, BirdDog said:

Skippy, 

 

I spoke to RAA today, and the E24 rego can be reverted back to 24, if the engine was replaced.  So a scenario like this....

 

At TBO, I apply and get issued an E24 rego.  That allows me to continue running on condition.  Then, 3, 4, or 5 years later (or whenever) me or a new owner can simply put a new motor in, and revert it back to 24 Rego - PROVIDED that any other mods done are approved by Evektor (Glass etc).  If do those mods unapproved, there will likely be no way back to 24. Hence why I need their approval, or no glass gets installed.

So much depends on the continuing good will of the factory (Evektor in this case) What if the factory is bought out/under new ownership/goes bankrupt and fades from the scene? - what then for your 24 classification?

 

 Seems to me that a Government authority may have a good chance of continuity (politics aside) a commercial entity is an ephemeral thing, here today, gone or changed tomorrow.

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44 minutes ago, skippydiesel said:

So much depends on the continuing good will of the factory (Evektor in this case) What if the factory is bought out/under new ownership/goes bankrupt and fades from the scene? - what then for your 24 classification?

 

 Seems to me that a Government authority may have a good chance of continuity (politics aside) a commercial entity is an ephemeral thing, here today, gone or changed tomorrow.

Probably like the Gazelles and tail dragged Skyfox, factory closed and approvals remain.

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8 hours ago, Blueadventures said:

Probably like the Gazelles and tail dragged Skyfox, factory closed and approvals remain.

How can that be - approvals depend on the factory.  The concept of factory approval, is one where the regulator (RAA) shifts the burden of certification/assurance from itself to the manufacturer/factory (for aircraft with approval to be used for hire/reward). RAA's response to, a non factory approved, change/modification, has been to deem the aircraft an E. A clear signal to owner/operator that this aircraft can no longer be used for financial gain. The inference here is that the owner/operator is now largely responsible for the aircrafts continued airworthiness, not the factory and not RAA . In general, the law views any financial transaction, as having actual or implied responsibilities, on the service/good provider, to provide a safe product/service, to the customer . The law also sees that a regulatory body (RAA) has a responsibility to oversee such transactions. It is in this area that RAA has sought to shift its responsibility, to the manufacturer.

 

With the exception of owners who deliberately set out to purchase an aircraft for financial gain, I think the 24 type standard is a bit of a furphy, having little more than a marketing (illusory) benefit to the owner. However 24 (while in play), is of  great benefit to RAA.

 

Okay so example (not to be taken too literally):

 

1. A Passive Change - TBO has run out due to operational hours or passage of time. Aircraft no longer meets origination factory complacence. Solution, replace engine with one identical to original.  The original configuration has been maintained exactly. One would reasonably expect, that even without factory approval, this scenario would meet the regulators (RAA ) approval. Aircraft retains its 24 status. All good.

 

2. An Active Change - Fancy glass avionics "kaput". Replacement no longer available. Replaced with another brand/model. No approval from factory. This small change means the aircraft, is no longer is as delivered by the factory. Under existing RAA requirements, with no factory approval, this aircraft can not be used for hire or reward.  I guess RAA may make some sort of a case by case judgement call but what happens if an incident occurs where the change/modification is deemed to have been  a contributing factor - RAA  is now he certifier and the court awards a massive financial penalty??  All still good ?????

 

(You could substitute 2. with something a little more structural eg a new nose wheel assembly, a wholly different CS propeller , cockpit canopy, etc)

 

This is why I do not think it likely that a 24 (or similar) registration can continue indefinitely, simply because in the absence of factory approval (for whatever reason) the essence of RAA's ruling (to achieve minimal/nil responsibility for certification) is undermined and RAA becomes legally  exposed.

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