kgassert wrote:
> Bill,
>
> So if a 337 was filed showing the changes were made to convert from a C to a 
> D but the airworthiness certificate still shows it is a C your letter says 
> that it would sill be a C in the eyes of the FAA?
>
> Kevin1

The subject of model designation for Cs or CDs converted to D has been 
and continues to be discussed extensively. Title 14, Chapter 1, section 
1.1 of the FAA regulations says:

" Light-sport aircraft means an aircraft, other than a helicopter or 
powered-lift that, since its original certification, has continued to 
meet the following:

(1) A maximum takeoff weight of not more than—

(i) 1,320 pounds (600 kilograms) for aircraft not intended for operation 
on water..."


I'm no airplane mechanic, but as I understand it, the change that ERCO 
made to allow 1400 lbs. MTOW was to change the elevator upward travel 
from 13 degrees to 9 degrees. The only change from the model D to the 
later model CD was to return the upward travel to 13 degrees.

People have argued over what "continued to meet the following" means. 
What I haven't read, yet, is a story of a sport pilot getting into hot 
water with the FAA for flying a C or CD that had been converted. Or vice 
versa. Either one would give us something concrete to go on, wouldn't it?


Jim Hart




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