School me dgapilot. I’m probably coming from a point of ignorance, but I thought EXP Exhibition allowed you to do whatever you needed to do to perform the exhibition, which in reality left the door wide open. Back in the day, we’d bought old duster Stearmans in Restricted Category. We’d leave them in Restricted if we were going to banner tow, otherwise we’d put them in Exh Exhibition. A buddy of mine still has his in Exhibition to this day. These are Stearmans with highlight wings (Vern’s 4412’s), metal sides, BT wheels and so on. When it comes to the Cub, I thought in the name of exhibition, say STOL contests, I could modify it in ways I believed would enhance it’s competitiveness, in this case, a structural mod to the door area. Again, I’m coming from a point of ignorance, you know more about it than me, but am I mistaken on my interpretation of EXP Exhibition?
Dave.. Actually a number of people operated banner tows without a proper Certificate of Airworthiness. As a Van Nuys FSDO Inspector said to me... each FSDO is an independently operated concession with its own rules. The correct procedure was to apply for a Special C of A in Restricted Category for the "purpose of Aerial Advertising." Some had multiple airworthiness certs. I had an Inspector on Long Island give me a Restricted Cert for a Standard category PA-18 just because we were towing banners - that was without even making an application. How could he just issue a Cert without having received an application for a Certificate of Airworthiness? He was way off base, but fixed in is ways, so we just went about our business. When a California Central Valley operator had a pi--ing match with an inspector about licensing his AgCat for banner towing it set off a national ban on using AgCats for Aerial Advertising, with the FAA in Washington DC stating the FSDO Inspectors did not have the authority, and could not issue Certs of airworthiness. Everyone lost out. What I read here and elsewhere is that taking a Standard airplane into Experimental is not a good idea at all - and that EX-Exhibition will likely drastically reduce the resale value of your airplane.
“It depends”, I operated banner tow airplanes for about 10 years. So long as there is a legal way to install a hitch and stay standard there is no reason to put an airplane in “Restricted”. If there is a reason you can’t stay standard, a boom hitch, extended fuel system or no cowling are examples, then you go Restricted.
43.1 (b) in part says “This part does not apply to -
(1) Any aircraft for which the FAA has issued an experimental certificate, unless the FAA has previously issued a different kind of airworthiness certificate for that aircraft;”
Given the plain language of the regulation, 43 still applies. One of the reasons for requiring an annual program letter is to inform the FSDO what you are doing with the airplane. It is also the reason why there is an operating limitation that says any change that meets the definition of 21.93 must be coordinated with the FSDO. I’ve issued a number of Field Approvals and 8110-3s that explicitly state they can only be installed while the aircraft is operated in Experimental Exhibition (or Restricted). A big reason is to document changes while Experimental in case the owner chooses to return the aircraft to Standard. Makes the conformity for returning it much easier.
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