Operating Limitations Change

[tonycondon]

Im considering requesting a change to my Operating Limitations that says something like

"If equipped in accordance with 91.205(d)(2-6) and 91.205(d)(8-9), aircraft is approved for flight under IFR"

Right now mine say "This aircraft must be operated day VFR only, and be equipped in accordance with 91.205"

I want to leave out (1) because i dont want or need all the position lights, which are a huge battery drain. leave out (7) because dont have a generator or alternator and cant have one.

I understand this is essentially just a paperwork change? get a new airworthiness cert. with it. Anyone think Ill be able to get the change made to the operating limitations before the glider is equipped with IFR instruments?

 

[Steve]

The FAA likes to give a backhanded approval to IFR in experimentals by requiring the following wording (or similar) in the Operating Limitations:

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

Again, your FSDO will be responsible for issuing you any changes to the existing limitations. My personal feeling is they will be reluctant to allow exceptions to the full list of requirements, if only to avoid setting a precedent.

 

[tonycondon]

ok and here is question 2. I am required to instrument my aircraft in accordance with 91.205, which is for "Powered civil aircraft with standard category U.S. airworthiness certificates:" would having no instruments at all still be technically in accordance with the reg?

 

[Steve]

That's why they have different classifications....as an "experimental" the rules can be whatever they want them to be.

ok and here is question 2. I am required to instrument my aircraft in accordance with 91.205, which is for "Powered civil aircraft with standard category U.S. airworthiness certificates:" would having no instruments at all still be technically in accordance with the reg?

 

[tonycondon]

yea but they sure arent very clear!

 

[Stache]

I have certificated gliders and have given others what you are asking for. It is a simple request on a FAA Form 8130-6 to ammend your operation limitations by a FSDO of MIDO only.

If you wanted to have a DAR perform this task you would have to deregister your aircaft and start all over again from scratch. I have seen this done also.

If you would like to discuss this off line send me a private e-mail.

Stache

 

[gismo]

ok and here is question 2. I am required to instrument my aircraft in accordance with 91.205, which is for "Powered civil aircraft with standard category U.S. airworthiness certificates:" would having no instruments at all still be technically in accordance with the reg?

Tony, since 91.205 clearly applies to powered aircraft, I think the instrumentation requirements are up to you on a glider. Isn't there someone at the SSA with a better idea of the true requirements? I'm pretty sure that I've seeen "IFR equipped" gliders with nothing more than what you already have plus a turn gyro.

 

[tonycondon]

yeabut my op. limitations specifically limit me to day VFR now, and mention that I must be equipped in accordance with 91.205. sounds like a leftover from a cookie cutter operating limitations designed for powered aircraft?

 

[gismo]

sounds like a leftover from a cookie cutter operating limitations designed for powered aircraft?

Sounds likely. But like I said, someone at SSA (or maybe EAA) should already know the answers for today's rules.