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I was recently referred to an EAA News article dated back in 2005 (10/13/05) that stated that uncertified UL engines were not to be flown at night or in IFR conditions.  ("Many S-LSA are equipped with Rotax engines. Rotax's operating instructions prohibit the use of a Rotax engine at night or in IFR conditions unless it is the FAA type-certificated engine; that is, certificated to FAR Part 33. Rotax's non-certificated engines are indicated by the letters "UL" after the engine series number; for example, 912UL, 912ULS, and 914UL.")  I personally don't have an issue with this, however, there are some PPL pilots in our flying club who would like to fly our otherwise night equipped Tecnam P92 with a 912ULS at night.  Can someone point me to the specific text in Rotax documents that says talk about this restriction?  


Jeffrey Fritts, USAF (ret.)

www.flywwlsa.com

"In aircraft maintenance, good enough is not good enough."

  • Re: Rotax 912ULS and night flying...

    by » one month ago


    The only reference to night flying in the current Operators Manual is in Section 1.4 (Safety Information) which says, in part:

    "Due to the varying designs, equipment and types of aircraft, BRP-Rotax grants no warranty on the suitability of its engines use on any particular aircraft. Further, BRP-Rotax grants no warranty on this engines suitability with any other part, components or system which may be selected by the aircraft manufacturer, assembler or user for aircraft application."

    "WARNING Non-compliance can result in serious injuries or death! For each use of DAY VFR, NIGHT VFR or IFR in an aircraft the applicable legal requirements and other existing must be adhered to."

    That doesn't sound like a prohibition to me.


    Thank you said by: Jeffrey Fritts

  • Re: Rotax 912ULS and night flying...

    by » one month ago


    Rotax can not prohibit night flying, especially Experimental, but the LSA manufacturer might.

    One point to consider...

    Being an LSA and intended for day VFR,  the NAV lighting is strictly optional.
    Many OEMs cheat on the NAV lights.
    They look good cosmetically but do not meet the Night Flight requirement.

    There are Brightness and Coverage requirements to be met.
    The NAV lights must only show from straight ahead to 110° on either side.
    The White Tail Light from straight back to 110° on either side.
    360° Beacon/Strobe lights are another requirement.  Not Optional.

    The lights do Not need to be TSO'd but they must meet the TSO Lighting standard.

    I installed Night Qualified Lighting and they were twice the price of the "Optional" VFR-Day NAV Lights.
    One thing for sure, from 10 feet away, They are Painfully bright even in daylight.
    At night, they light up half the ramp!  Impressive!

    Something to confirm.


    Bill Hertzel
    Rotax 912is
    North Ridgeville, OH, USA
    Bill.Hertzel@Yahoo.com
    Clicking the "Thank You" is Always Appreciated.


    Thank you said by: Jeffrey Fritts

  • Re: Rotax 912ULS and night flying...

    by » one month ago


    The night lighting regs were pointed out to me by the DAR in our EAA chapter...  He  pointed out to me that the operating limitations for my E-LSA RANS S-6ES (pretty standard for any experimental) reads "After completion of flight testing, unless appropriately equipped for night and/or instrument flight in accordance § 91.205, this aircraft is to be operatted under VFR day only."  He went on to state that experimental of not, § 91.205 (c) states (and note the bolded portion):

    (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.

    He then asked me "How would you convice an FAA or NTSB hearing board that your non-TSO position and anticollision lights were 'Approved position lights'?"  His answer was that if you use TSO'ed lights, you definitely meet the regs.  If you use non-TSO'ed lights, the burden of proof is on you.  That said – and completely 'off the record' (as in "not in my capacity as a DAR") – he suggested that IF the manufacturer were willing to provide you a letter stating that their lighting system complies with the requirements of the TSO, that would "probably" be sufficient proof of due diligence on your part.  Otherwise, you would need to do the testing yourself, and be able to document all of the brightness, angularity, color fidelity, etc. through the use of certified test equipment.  (Way too much trouble...)

    So, until I get clarification from the vendor of my combination position light / strobe system, I'm restricting myself to day VFR.  (I hold Commercial ASEL ratings, so legal at night IF properly equipped.)


    Thank you said by: Jeffrey Fritts

  • Re: Rotax 912ULS and night flying...

    by » 5 weeks ago


    Gentlemen,

    Thank you for your guidance.  You are all correct.  The question was, in the end, settled for this particular aircraft by the manufacture, Tecnam.   This S-LSA factory-built P92 Echo Super is not certified by Tecnam for night VFR operations.  Since it is not an experimental aircraft and therefore must comply with the ASTM standard it falls under Tecnam's operating limitations.  And yes the aircraft does meet 91.205 (c) but 91.205 is, "Powered civil aircraft with standard category  U.S. airworthiness certificates: Instrument and equipment requirements."   This aircraft falls under 21.190 and flies with a Special Airworthiness Certificate.  

    The world of light-sport aircraft and the FARs can often be a grey area because of the way the regs are written.  Often what is not said ends up being as important as what is said.  

    Thanks again.

     


    Jeffrey Fritts, USAF (ret.)

    www.flywwlsa.com

    "In aircraft maintenance, good enough is not good enough."


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