Modifications to 19-XXXX aircraft

[ducksrus]

I have just spent the last couple of hours trawling through CAO 95.55 (2011), also the "overview of the legislative framework enabling sport and recreational aviation" tutorial on this site and sections 3.5.2 & 3.5.3 of the RA-Aus tech manual, which relate to "modifications to aircraft".

 

I have a 19-XXXX kit built Savannah VG XL of which I am the builder, so it is non LSA or Experimental and I am trying to conclusively establish if I am legally allowed to modify my aircraft, as I see fit, without any external authorisation, as is the case with some aircraft in other categories.

 

As I understand it, new CAO 95.55 para 1.2 (e) is applicable to my Savannah.

 

Trying to find the answer to a fairly simple question amdist the reams of documentation for all the different classifications of aircraft is quite daunting.

 

Any feedback appreciated.

 

Ducky

 

 

[AVOCET]

there are lots of modified 19 aircraft ,

 

I've seen a number of kit built aircraft that the builder has taken it upon him or her self to change the original design , you do so at your at your own risk ,

 

. that's what 19 xxxx is all about .

 

I might add that in some cases the mods are an improvement , but some are thinking ,the original designer isn't as smart as me ,.....

 

Yea'r, that's when it could get dangerous , or what.!

 

mike

 

 

[ducksrus]

Thanks Avocet, I am pretty sure I can modify my aircraft as I see fit, as a 19-XXXX aircraft under para 1.2 (e) of the the CAO. But it gets confusing, because there appears to be another classification of 19-XXXX under para 1.2 (h) which I think is for experimental LSA, which I assume cannot be modified without approval ?

 

So it may not be true that ALL 19-XXXX aircraft can be modified without approval ???

 

Ducky

 

 

[robinsm]

19 registered, legally you built it, you take responsibility for it, you do what you like., but remember, if it stuffs up, its your responsibility, no one elses.

 

 

[AVOCET]

Thanks Avocet, I am pretty sure I can modify my aircraft as I see fit, as a 19-XXXX aircraft under para 1.2 (e) of the the CAO. But it gets confusing, because there appears to be another classification of 19-XXXX under para 1.2 (h) which I think is for experimental LSA, which I assume cannot be modified without approval ?So it may not be true that ALL 19-XXXX aircraft can be modified without approval ???

Ducky

I think you will find that the rules differentiate the original builder and the second & subsequent owners .

I remember when 19 happened and it was discussed what to do with 19 aircraft after the owner builder wanted to sell , it was suggested that you would have to burn the aircraft to stop anybody else using it !!

 

 

[Robmus]

I think you will find that the rules differentiate the original builder and the second & subsequent owners .I remember when 19 happened and it was discussed what to do with 19 aircraft after the owner builder wanted to sell , it was suggested that you would have to burn the aircraft to stop anybody else using it !!

I have a 19 rego Boorabee that was fitted with a Rotax 582. I fitted a HKS 700 E and it was passed and approved by RAA with a W&B and photos. I have just lately fitted a Rotax 912 ULS to a 19 reg Jab 170C that has proved Quite successful. We'll see how we go with that when we change details with RAA?

 

Regards Robert.

 

 

[pylon500]

which I think is for experimental LSA

I could be wrong, but I think if you build an LSA kit (which you can't change), when finished, it is registered as an ELSA and given an E24-xxxx number?

The problem with 95:55 is that when LSA came along, instead of writing a new ANO, a modified version of 95:55 was written and confusion followed.

 

 

[AVOCET]

c

 

I could be wrong, but I think if you build an LSA kit (which you can't change), when finished, it is registered as an ELSA and given an E24-xxxx number?The problem with 95:55 is that when LSA came along, instead of writing a new ANO, a modified version of 95:55 was written and confusion followed.

confusion always follows !

 

 

[rgmwa]

As I understand it, S-LSA (24-xxxx or VH) allows no mods by the owner, only by the factory. E-LSA (19-xxxx or VH) can be maintained but can't have annuals signed off by the builder (not sure about RAA annuals but this applies under VH rules anyway, although US builders can sign off annuals), or be modified by the builder without the kit manufacturer's approval, who probably won't authorise your mods anyway. Therefore in Australia there is not much practical difference between owning an S-LSA and an E-LSA, so if you want to build an LSA kit you may as well go `experimental' (19-xxxx or VH) because then you can maintain/modify/sign annuals, etc as you like, at your risk. Furthermore, provided your mods don't take it outside CASA's defined LSA performance parameters, it remains an LSA aircraft. But if your mods take it outside those parameters, such as installing a constant speed prop, increasing the MTOW to 601kg, clipping the wings so that the full flap stall speed increases to 46kts or more, then you no longer have an LSA aircraft but a true experimental that can never be re-registered as an E-LSA, even if you remove all those non-conforming mods. Simple really.

 

rgmwa

 

 

[facthunter]

There may be occasions where a document appears clear and unambiguous. We are only human after all. Our normal high standards can be maintained only if alert users bring these matters to our notice promptly, and the matter will be rectified. sgd CASA.

 

 

[Camel]

Not sure about the LSA definitions above. An LSA is factory approved to ASTM standards if you put a inflight adjustable prop on it as has happened then it is E-LSA and unable to be used for hire or training and rego becomes E24-xxxx .

 

 

[jetjr]

I believe Owner of 19 can make changes and modifications, it is also written this way in aircraft manual.

 

It is a key difference between VH experimental and RA otherwise why bother with RAA?

 

Im not sure on LSA catagories, dont think 19 is LSA in any way.

 

As always just because you can doesnt mean you should, just like maintenence.

 

 

[rgmwa]

Not sure about the LSA definitions above. An LSA is factory approved to ASTM standards if you put a inflight adjustable prop on it as has happened then it is E-LSA and unable to be used for hire or training and rego becomes E24-xxxx .

An inflight adjustable prop is not allowed under our LSA rules (USA also) so if you put one on, you no longer have an LSA no matter whether it was originally registered as an S-LSA (24) or an E-LSA (19). You may find yourself in a CASA no-man's land (you now have an experimental aircraft (as in 19-xxxx) that is no longer compliant with its original registration). The prop has to be fixed pitch, although ground adjustable is OK.

 

rgmwa

 

 

[rgmwa]

I believe Owner of 19 can make changes and modifications, it is also written this way in aircraft manual.It is a key difference between VH experimental and RA otherwise why bother with RAA?

I believe that is correct. VH owners can now make changes to a purchased experimental aircraft, provided they have previously built a similar one. eg. If you built an RV-4 and subsequently bought an RV-8, you could exercise the same privileges you previously had (assuming you have done an MPC course).

 

rgmwa

 

 

[Head in the clouds]

Many of us still don't seem to know the regulations we operate by, or how to find the answers. I reckon this is something the RAA needs to address via the magazine because folks on this forum are better informed than those who don't read it so I wonder what the rest think about it all.

 

The so called 'LSA' class is actually no such thing at all. A whole bunch of former and new aircraft types have now been shoved together under a single CAO (Civil Aviation Order - formerly ANO (Air Navigation Order)), so that many of the planes that used to be 95.25 (450kg planes like Drifters/Thrusters) 101.55, 95.10, 101.28 etc AND the LSAs, ELSAs etc are now all in different subsections of CAO 95.55.

 

Here is a link to the complete CAO 95.55

 

Section 1.2 details which types of planes fit which particular categories i.e. single seat, two seat, homebuilt, factory built, planes from former ANOs/CAOs etc.

 

The one we're dealing with here is Sect 1.2 subsection (e). (In red below). Note this is the homebuilt section of this category, not the ELSA category, LSA is subsection (g), ELSA is subsection (h). The reason you can't mess around with changing your Drifter or Thruster is in subsection (d). The reason you CAN have a constant speed prop on your homebuilt 95.55 is in 1.1 subsection (b) i.e. one propellor, one engine, it doesn't say the prop has to be fixed pitch, it's just that if a factory fits a fixed pitch to a factory built LSA you can't change it to a constant speed prop.

 

So, if you build it yourself you'll not be flying an LSA, you'll be flying a homebuilt CAO 95.55 category aircraft - there's too much confusion around regarding what is and what isn't an LSA. To fit into CAO 95.55 a plane must comply with all of Section 1.1 and one subsection of Section 1.2

 

There is no restriction on fitting Constant Speed props, retractable landing gear or whatever you like, pretty much, if you build the plane yourself, and you can alter a kit as much as you want because it is YOU, at the end of the day, who is stating that it is sound, not the kit provider.

 

You cannot change a factory built LSA at all without the factory approving it, regardless of whether it is being used for training or not.

 

Below is a copy of part of CAO 95.25 (Sections 1 and 1.2) -

 

Schedule 1 Civil Aviation Order 95.55

 

 

 

Exemption from provisions of the Civil Aviation Regulations 1988 — certain ultralight aeroplanes

 

 

 

1 Application

 

 

 

1.1 This Order applies to a single-place or 2-place aeroplane that:

 

 

 

(a) is not a weight shift controlled aeroplane or a powered parachute; and

 

 

 

(b) has a single engine and a single propeller; and

 

 

 

© has a Vso stall speed of not greater than 45 knots, as determined by design standards or certification requirements; and

 

 

 

(d) is registered with the RAA; and

 

 

 

(e) is mentioned in paragraph 1.2.

 

 

 

 

 

1.2 For subparagraph 1.1 (e), an aeroplane must be 1 of the following:

 

 

 

(a) an aeroplane to which Order 101.28 applies that complies with the design standards specified in that Order, with a maximum take-off weight not exceeding:

 

 

 

(i) in the case of an aeroplane not equipped to land on water — 600 kg; or

 

 

 

(ii) in the case of an aeroplane equipped to land on water — 650 kg;

 

 

 

(b) an aeroplane described in paragraph 1.1 of Order 101.55;

 

 

 

© an aeroplane described in paragraph 1.2 of Order 101.55 that meets the design standards in that Order;

 

 

 

(d) an old section 95.25 aeroplane that has not been modified except with the approval of a person who is an authorised person for subregulation 35 (1) of CAR 1988;

 

 

(e) an aeroplane, the major portion of which has been fabricated and assembled by a person who undertook the construction project solely for the person’s own education or recreation, that has a maximum take-off weight not exceeding:

 

 

(i) in the case of an aeroplane not equipped to land on water — 600 kg; or

 

 

(ii) in the case of an aeroplane equipped to land on water — 650 kg;

 

(f)an aeroplane:

 

 

 

(i) of a type for which a type certificate, a certificate of type approval or an equivalent document has been issued by CASA, another national airworthiness authority (NAA) or a competent issuing authority; and

 

 

 

(ii) that has been manufactured for sale by the holder of a certificate, or an equivalent document, permitting the manufacture of aeroplanes of that type and issued by CASA or another NAA or a competent issuing authority; and

 

 

 

(iii) that has a maximum take-off weight not exceeding:

 

 

 

(A) in the case of an aeroplane not equipped to land on water — 600 kg; or

 

 

 

(B) in the case of an aeroplane equipped to land on water — 650 kg; and

 

 

 

(iv) that has a payload that is equal to, or exceeds, the minimum useful load for that aeroplane determined in accordance with paragraph 1.3;

 

 

 

(g) a light sport aircraft:

 

 

 

(i) manufactured by a qualified manufacturer as defined by regulation 21.172 of CASR 1998; and

 

 

 

(ii) for which there is a current special certificate of airworthiness;

 

 

 

(h) a light sport aircraft:

 

 

 

(i) to which paragraph 21.191 (j) or (k) of CASR 1998 applies; and

 

 

 

(ii) for which there is a current experimental certificate of airworthiness.

 

 

[jetjr]

Thats how I saw it, good referencing thx.

 

What about owner vs builder mods to 19 reg?

 

 

[Head in the clouds]

Thats how I saw it, good referencing thx.What about owner vs builder mods to 19 reg?

Good point, I realised after I'd posted that the OP asked about modifying rather than building.

 

At this stage, to pre-empt future confusion let's also introduce the other homebuilt ultralight category, planes built to comply with the CAO 95.10.

 

Here is a link to the complete CAO 95.10

 

CAO 95.10 planes are similar in some ways to some CAO 95.55 planes but can only have one seat. However, if you're aiming for a lightweight single seater CAO 95.10 allows you to build a far more interesting craft than 95.55 does.

 

Below is a part of 95.10 which describes what a 95.10 is. When reading these kinds of documents you should note that it is very specific, so if something isn't excluded directly or by external reference then you CAN have it, so note what the exclusions and limits are -

 

Schedule 1 Civil Aviation Order 95.10

 

 

 

Exemption from provisions of the Civil Aviation Regulations 1988 — low‑momentum ultralight aeroplanes

 

 

 

1 Application

 

 

 

This Order applies to a low-momentum ultralight aeroplane in relation to which the following requirements are satisfied:

 

 

 

(a) the aeroplane is registered with the RAA or, if the aeroplane is a weight‑shift controlled aeroplane, with the HGFA;

 

 

 

(b) the aeroplane is a single-place aeroplane that has a take-off weight of not more than:

 

 

 

(i) if it is equipped to land on water — 335 kilograms; or

 

 

 

(ii) if it is equipped with a recovery parachute system — 320 kilograms; or

 

 

 

(iii) if it is equipped to land on water and has a parachute recovery system — not more than 355 kilograms; or

 

 

 

(iv) in any other case — 300 kilograms;

 

 

 

© if the aeroplane first became registered with the RAA or the HGFA on, or after, 1 March 1990:

 

 

 

(i) the aeroplane was privately built; and

 

 

 

(ii) the aeroplane has a wing loading not greater than 30 kilograms per square metre at maximum all-up weight; and

 

 

 

(iii) if the aeroplane is owned by a person who is not the builder or 1 of the builders — a certificate is in force that has been issued by the RAA or the HGFA which certifies that the aeroplane meets the requirements set out in the RAA Technical Manual or the HGFA Operations Manual, as the case may be.

 

So - this means the basic 95.10 plane can be 300kg MTOW. Knock off 100kg for you and baggage and 40kg for 50lts of cruise fuel plus reserves and you have 160kg left to build ... what? Well the possibilities are endless. You can have a small jet or a push-pull twin, or a wing-mounted twin, a four engined Lancaster replica etc etc. With retractable gear ... Note there are no speed limits, no restriction on top speed and no minimum (or maximum) stall speed. OK so you have to have 10sqm of wing area to satisfy the other part of the limitations but nothing's stopping you having a variable geometry wing-set - a mini F1-11 perhaps? Or very large Fowler-type flaps that can be extended rearwards to satisfy the wing area limit but stowed at altitude for high-speed flight. Or - deltas need low wing-loading for best performance and are easy to build light because their wing is thick and of short span so what about a single seat Vulcan, with four RC model jet engines if you really want to impress - 200kts should be quite feasible ...

 

Regarding the modifications to a 95.55 or 95.10 homebuilt - if you built it you can maintain it certainly but I don't recall actually having seen anything in print about making modifications to it. Logically I think it would depend on how extensive the modifications are. Purely as an opinion I would say that if the modifications didn't significantly change the weight and balance or flight characteristics then you would be fine because there is only so much information submitted for the initial registration and if it doesn't change what was, or should have been, submitted then no-one is any the wiser. I'm not suggesting anything devious here, just that if you didn't have to list the type of wingtips or the instruments fitted, for example, then changing them doesn't affect the registration aspects, and at the end of the day it's only the registration aspects that we're dealing with.

 

If you do change the weight by adding or removing equipment then you should submit a new W&B and amend the POH, in this case you would simply be doing what a LAME or L2 might be doing to/with a GA or 95.55 aircraft. If, however, you change something within the primary structure or something that might significantly affect the handling then logically you should conduct the 25 or 40 hour proving period again - although, as mentioned, I've not seen anything in print to cover this situation. When the Tech Manager catches up with registration issues and has some time available it might be a good subject to submit to him for a determination.

 

As far as modifying, or even maintaining, a homebuilt 95.55 or 95.10 that you weren't the builder or one of the builders of, at present you can't, you have to treat it like an LSA or similar i.e. you have to have an L2 do any maintenance or repair work on it. Having said that I'm interested by rgmwa's comment above, about being able to work on a plane you own that is similar to one you have previously built - this presently being in the GA experimental category (SAAA regulated). That makes good sense and is probably worth RAA pursuing through the CASA to have a similar facility available for 95.55 and 95.10 categories.

 

 

[rgmwa]

Having said that I'm interested by rgmwa's comment above, about being able to work on a plane you own that is similar to one you have previously built - this presently being in the GA experimental category (SAAA regulated). That makes good sense and is probably worth RAA pursuing through the CASA to have a similar facility available for 95.55 and 95.10 categories.

http://www.casa.gov.au/wcmswr/_assets/main/download/caaps/airworth/42zc_2.pdf

 

Clause 6.1

 

rgmwa

 

 

[M61A1]

Also CAO 95.55

 

6 General conditions

 

6.1 The exemptions given by subsection 3, in relation to an aeroplane to which this Order applies, are subject to the following general conditions:

 

(a) the aeroplane must not be used for any purpose other than:

 

(i) private operations including glider towing but not aerial application operations; or

 

(ii) if the aeroplane has been wholly built and assembled by a commercial manufacturer — flying training to enable a person to obtain a pilot certificate;

 

(b) the aeroplane must not be operated by a person as pilot in command unless the person holds a valid pilot certificate and, subject to the other conditions set out in this Order, operates the aeroplane in accordance with the privileges and limitations of that certificate;

 

© subject to paragraph 6.2, if the aeroplane is being used for flying training, the person conducting the training must hold a valid flight instructor certificate;

 

(d) subject to the other conditions set out in this Order, the aeroplane must be operated in accordance with the requirements of the RAA Operations Manual;

 

(e) the aeroplane must be maintained in accordance with the maintenance standards set out in the RAA Technical Manual;

 

(f) in the case of an aeroplane to which this Order applies by virtue of subparagraph 1.2 (b), © or (f) — the aeroplane must not have been modified without the approval of CASA or of an authorised person for the purposes of regulation 35 of CAR 1988;

 

(g) in the case of an aeroplane to which this Order applies by virtue of subparagraph 1.2 (a), (e) or (g) — the aeroplane must:

 

(i) before its initial flight, have been inspected by a person authorised by CASA for that purpose; and

 

(ii) if any condition or limitation has been imposed under paragraph 6.3 — be operated subject to that condition or limitation.

 

Below paras 1.2 (b), © and (f) highlighted in blue

 

1.2 For subparagraph 1.1 (e), an aeroplane must be 1 of the following:

 

(a) an aeroplane to which Order 101.28 applies that complies with the design standards specified in that Order, with a maximum take-off weight not exceeding:

 

(i) in the case of an aeroplane not equipped to land on water — 600 kg; or

 

(ii) in the case of an aeroplane equipped to land on water — 650 kg;

 

(b) an aeroplane described in paragraph 1.1 of Order 101.55;

 

 

 

© an aeroplane described in paragraph 1.2 of Order 101.55 that meets the design standards in that Order;

 

(d) an old section 95.25 aeroplane that has not been modified except with the approval of a person who is an authorised person for subregulation 35 (1) of CAR 1988;

 

(e) an aeroplane, the major portion of which has been fabricated and assembled by a person who undertook the construction project solely for the person’s own education or recreation, that has a maximum take-off weight not exceeding:

 

(i) in the case of an aeroplane not equipped to land on water — 600 kg; or

 

(ii) in the case of an aeroplane equipped to land on water — 650 kg;

 

(f) an aeroplane:

 

 

 

(i) of a type for which a type certificate, a certificate of type approval or an equivalent document has been issued by CASA, another national airworthiness authority (NAA) or a competent issuing authority; and

 

 

 

(ii) that has been manufactured for sale by the holder of a certificate, or an equivalent document, permitting the manufacture of aeroplanes of that type and issued by CASA or another NAA or a competent issuing authority; and

 

 

 

(iii) that has a maximum take-off weight not exceeding:

 

 

 

(A) in the case of an aeroplane not equipped to land on water — 600 kg; or

 

 

 

(B) in the case of an aeroplane equipped to land on water — 650 kg; and

 

 

 

(iv) that has a payload that is equal to, or exceeds, the minimum useful load for that aeroplane determined in accordance with paragraph 1.3;

 

 

So, unless it's old 101.55, 95.25 or factory built with a certificate or equivalent, you can modify as long as the mods do not make the aircraft no longer compliant with the category.

 

 

[jetjr]

Sorry guys im still lost

 

Can a subsequent owner of a 19 regd make alterations (major or minor) to their aircraft?

 

Keep in mind before LSA, a lot of RAA are 19 regd, being factory assist build or similar.

 

Not talking VH experimental, having built similar etcetc. Not being the builder that doesnt mean much either.

 

Have trouble believing they revert to full L2 maint and your never going to get factory backing for an aircraft they didnt build. Id assume they would need to be reinstated to how the builder finished with them.

 

Keep in mind changing prop, any engine spec or tyres type isnt allowed under LSA. The whole point of 19 reg is so self maintained and operated as as a result CANNOT be used for training

 

 

[Head in the clouds]

jetjr, I can't find the specific reference for you, there have been so many changes to CARs, CAOs and the RAA documentation that I'm still catching up.

 

There now seems to be some confusion also, when reading the applicable part of the Tech Manual here, that refers to 19 reg as experimental LSA, but in fact, as I understand it, anything homebuilt is not an LSA at all, it is an Amateur Built 95.55 1.2(e) category aircraft, just as the 28-XXXX series are not LSAs they are 'former homebuilt VH category craft that happen to fit 95.55 class and similarly former 95.25 aircraft (like Drifters) etc etc. An ELSA is an LSA that has been altered without the factory approval (instead approved by an Approved person etc)

 

As far as answering the question is concerned - the following was the case previously but keep in mind there may have been some changes -

 

The actual builder(s) of a 19-XXXX (or 10-XXXX) should be able to make any modifications and do the maintenance on his/her craft as they see fit and, as I said in a previous post (and as detailed in the link above) if the W/B is affected a new W/B must be performed and entered in the POH and if there are major structural changes and or something that might affect the handling significantly then I think the proving flight time is supposed to be performed again.

 

You can NOT do maintenance on a plane that you didn't build, regardless of the category. Prior to there being a maintenance structure we did do our own maintenance to 95.10 machines (and most of them were factory built too) but since L2s came about they must do the servicing and maintenance on all RAA craft unless you are the actual builder of it. I did hear of an interesting situation some years ago. A fella sold his 19 reg plane to a friend who lived nearby and the new owner was getting the previous owner-builder to maintain it, because he built it. He was advised (though no document references were provided) that it was not legal, only the owner-builder could maintain it, or an L2. Since the builder was no longer the owner, he was not the owner-builder any longer. To avoid conflict they decided to just get another friend who was an L2 to do the maintenance, with the builder helping due to his greater knowledge of the machine, but it would be interesting to have the matter examined more closely.

 

Similarly with training - only the builder(s) can be trained in an amateur built 19-XXXX craft, not subsequent owners.

 

I hope it helps but anyone planning any of this and who is unsure of the position for their particular circumstance should word up a couple of paragraphs and send it to Darren the Tech Manager for clarification. I've spoken with Darren a few times and I can tell you he's a good bloke and the nicest and smartest Tech Manager you could wish for and will be sure to help with untangling the documentation vagaries.

 

Have trouble believing they revert to full L2 maint

Really there's no reason why they shouldn't. Someone buying a 19 reg is in no different a situation than if they bought any other reg, they still don't know about the technical aspects of the plane, so why would they know enough to maintain it?

 

The only reason the builder can maintain it is because he knows more about it than anyone else does.

 

 

[M61A1]

6.1 (e) Says they must be maintained iaw RAA tech manual, all that says is that if the factory made a manual you must use that, if not they have a section with a maintenance schedule for you. You must maintain it in accordance with (iaw) that schedule.

 

If it's a homebuilt, not factory built with some kind of certification (able to be used for hire or reward), So as long as you don't go making your stall speed higher than the category requires, or adding another engine, you can modify it.

 

 

[Head in the clouds]

6.1 (e) Says they must be maintained iaw RAA tech manual, all that says is that if the factory made a manual you must use that, if not they have a section with a maintenance schedule for you. You must maintain it in accordance with (iaw) that schedule.If it's a homebuilt, not factory built with some kind of certification (able to be used for hire or reward), So as long as you don't go making your stall speed higher than the category requires, or adding another engine, you can modify it.

Looking at the last page of the relevant sections of the Tech Manual it appears you're right about the maintenance aspect - the last page of the following link says if it's used for Private purposes only you can maintain any 95.55 aircraft with an L1 (any pilot is automatically an L1 unless it's been revoked).

 

I haven't found anything to confirm how you can modify an Amateur built though, regardless of whether you built it or not. Do you know of a reference for that?

 

The link above refers to modifications of privately operated 95.55 craft and says they must be done according to Section 3.5 of the Tech Manual. The only slightly relevant section there is Section 3.5.3 which contains a furphy because it refers to 95.55 para 1.8 and 1.9 which don't exist ... but it goes on to say that modifications must be conducted according to Advisory Circular AC 21.41 which is about modifying LSAs (factory built 95.55 1.2 (f) only, presumably) with or without factory approval - if without it then it turns them into Experimental LSAs, ( ELSAs - 95.55 1.2 (g) ) which then cannot be used for training, glider towing etc and must have an 'Experimental' sticker on the outside.

 

So I still don't think we have the definitive answer about 19-xxxx modifications unless I've missed something. Shall I word up a few lines for Darren's opinion on the subject perhaps?

 

Another interesting aspect is that the RAAus Tech Manual only refers to 19-xxxx craft as being Amateur built from factory produced kits, which is not right at all, 19 reg also includes all owner-designed scratch-builts and plans-builts.

 

 

[M61A1]

Have a look at sect 3.3.1 , in regards to amateur built. It doesn't mention mods, but I figure that it's pretty clear with CAO95.55, that only factory built (certificated in some way) need any type of approval/certification for modification. it's pretty much written to tell you what you can't do, so if it doesn't say you can't, it should be allowed. Assuming of course the aircraft still meets the criteria for 95.55, in regard to stall speeds, and number of engines etc. Those that took the slats off their homebuilts and put VG's on would be a good example, I can't remember whether it was Savannahs or CH701's.

 

Sect 3.5.2 mentions very specifically which categories require some sort of approval to modify.

 

 

[jetjr]

Without doubt any changes must be within RAA catagory limitations, stall, MTOW, PAX etc etc

 

Any weight changes will need W&B....... All simple logical stuff

 

Changes and minor changes like upgrading engine components, prop, brakes. More than likely upgrades to more current equipment should be no problem

 

How to draw the line at major repower, of wing alterations?, guess weight and stall keep some aspects controlled indirectly. Is it simply user/pax beware? Maybe a case where annual L2 inspections would benefit the registration catagory, at least stop someone doing anything dumb with mods.

 

Plenty of aftermarket people rely on owners of 19 being able to upgrade and many of factory improvements come from owner improvements.

 

Also best not to assume owners know less than builders, ive spent lots of time and money fixing or finishing builders work to how it should be BUT no way I have the time to build a new one.