21.191(d) Exhibition. {for purpose of} Exhibiting the aircraft’s flight capabilities, performance, or unusual characteristics at air shows, motion picture, television, and similar productions, and the maintenance of exhibition flight proficiency, including (for persons exhibiting aircraft) flying to and from such air shows and productions.

Exhibition is also commonly used for imported foreign manufactured aircraft without FAA type certificates and war birds. To convert a previously FAA standard certified aircraft to EE, the aircraft’s owner must have a valid reason to meet the regulation’s purpose, simply stating, “I want to reduce my operating cost by using non-certified avionics and Lycoming experimental line of engine parts” won’t meet the requirement, as this would not be considered a unique or an unusual characteristic. However, installing a non-certified automotive engine would be unique, and a statement similar to, “Aircraft will primarily be operated for the purpose of exhibiting the flight capabilities, environmental benefits, performance, and unique characteristics of using automotive technologies in aircraft”, would be a valid purpose.

The initial process includes submitting your initial program letter (an experimental operation is referred to as a program) to the local FSDO or MIDO (Manufacturers Inspection District Office) wherein you state the reason for converting to experimental. You may need to include some additional technical documents as well, depending on extent of modification(s) from the certified configuration to demonstrate a basic safety analysis, such a basic engineering analysis, and what certification basis (the regulations or standards used for the basis, such as FAR part 23, or other such as EASA or even automotive SAE standard) was used. This will likely require a FAA designated engineering representative (DER) or other engineer qualified in the specialty required for a written analysis, such as a structural and/or electrical engineer. The FAA has discretion in determining what is needed to demonstrate basic safety requirements.

Other documents likely required include a pilot’s operating handbook (POH) supplement that explains any changes original limitations, operating procedures, checklists, weight and balance procedures (and current weight & balance data in experimental configuration), as well as instructions for continued airworthiness (a detailed maintenance manual specific to your modification). The maintenance manual must include any changes to inspection and service schedules from original certified configuration, and the basis or testing methods you referenced when calculating it (you cannot arbitrarily make-up your own schedules or limitations, you must have some acceptable basis). Information for creating these documents are in FAA advisory circulars (AC) and 14 CFR part 21 and 23 regulations. This process can be quite complex and out of most pilot’s skill set, so most hire FAA DER’s and/or DAR’s to create this documentation and lead you through the process, but this can be very expensive.  Corsair conversions include all required technical documentation and experimental process checklist.   

Although many have tried, past & current FAA policy does not allow for converting a previously certified aircraft to the experimental amateur-build category, regardless how much you modify, disassemble/assemble the aircraft. However, some countries allow for simple conversion to similar amateur-built type category, such as Canada’s Owner Maintenance Category, intended to keep older aircraft flying by allowing non-certified mods such as engine conversions.

Once the FAA accepts your program letter and requested data, they will perform an inspection of the aircraft (typically, the inspection will be performed by a DAR at your cost). This inspection is mostly a review of documentation and overall safety assessment of the aircraft. If passed, the special experimental airworthiness certificate and operating limitations are issued. All experimental aircraft have additional operating limitations that are part of the special-experimental airworthiness certificate. These limitations are now standard nationwide and listed in FAA order 8130.2, but can be modified by the local FSDO if they have unique concerns, such as if your home base airport is in a densely populated area requiring a specific departure/arrival path to avoid most of the populated areas. Most of the standard EE operating limitations for single piston engine aircraft are the same for amateur built aircraft. Unlike other experimental programs, the duration of an airworthiness certificate for exhibition is unlimited and does not need to be renewed (same as standard airworthiness certificate).

Below are most current FAA operating limitations for exhibition SE piston aircraft:

Annual Condition Report- This is similar to an annual inspection for certified aircraft, but can be signed off by an A&P rather than an AI. Unlike an amateur built aircraft, if the aircraft was previously type certified, such as a C182, the operating limitations will include requirement to follow the C182’s maintenance schedule for life limited parts and procedures. So, normally the C182’s annual inspection procedure is used when performing the annual condition inspection for original components, and your derived maintenance manual for the experimental components.

Annual Program Letter: Exhibition aircraft have the additional requirement of faxing, mailing, or emailing an annual program letter to local FSDO (program is how you operate your experimental aircraft). This simple letter lists the events you intend to exhibit the aircraft for that year by event name, location and date. Events can include organized airshows, organized air races, organized fly-in activities, organized exhibitions, youth education events, shopping mall/school/similar static displays, organized aerobatic competition, fly-ins or competitive races or meets, and movie or television productions. These events are loosely defined, and can be almost any organized event, including flying club pancake breakfasts.  There is no requirement to attend any of the events listed, and events can be added anytime by sending revision to local FSDO.  Remember, the primary purpose is for exhibiting your aircraft, and there is likely several opportunities close to home to attend occasionally. Local EAA chapters have fly ins on a weekly basis, and are a great experience.

Adding “experimental” to call sign when talking to a control tower, and entering “experimental” in flight plan remarks.

Renting, leaseback, charter or other commercial use is prohibited, including all towing (glider, banner, ect..).

Operations to/from a class B airport is prohibited (flight in class B airspace is allowed). There are exceptions to this rule.

Flight outside US requires the pilot receive prior authorization from that country.

Avoiding flight over densely populated areas and congested airways except for takeoff and landings:

“Flight over a densely populated area or in a congested airway is authorized per § 91.319(c) only for the purpose of takeoff and landing. The area on the surface described by the term “only for the purpose of takeoff and landing” is the traffic pattern. For the purpose of this limitation, the term “only for the purpose of takeoff and landing” does not allow multiple traffic patterns for operations such as training or maintenance checks. This does not restrict a go around/rejected landing for safety reasons. When avoiding populated areas, aircraft speed and weight must be considered” (limitation #59, Order 8130.2J for exhibition aircraft).

This limitation is a bit different than the standard for amateur-built aircraft, which includes statement, “or unless sufficient altitude is maintained to make a safe emergency landing in the event of a power unit failure, without hazard to persons or property on the ground”. Most EE pilots believe the term, “When avoiding populated areas, aircraft speed and weight must be considered”, to mean the same (staying high & fast until landing assured to extend glide range), but there is no official FAA guidance. Essentially, this limitation eliminates closed traffic pattern operations that overfly congested areas, but does not limit such operations with traffic patterns over non-populated areas. 

The PIC must hold appropriate airman certificate and rating for aircraft and operation.

IFR is normally allowed if the aircraft is IFR equipped per FAR 91.205(d).

Only required crew members (no passengers allowed) for phase 1 flight testing.

Experimental aircraft have a phase1 (initial test flights) and phase 2 (after aircraft test flight program is complete and aircraft is signed off by owner to be safe within its operating envelope) operations. All new experimental aircraft require a defined phase 1 flight test area for initial flight testing that is not over a populated area. Normally, the aircraft owner will define the area by latitude/longitude, radius around a known fix, or other specific definition around the home base airport. The FSDO can modify or change this area, as well as define departure arrival corridors to/from any airport within populated areas. Phase 1 testing normally requires 25 or 40 hours and can be performed by any appropriate rated pilot (using an experienced pilot with test experience is highly recommended), using your flight test plan.

The test plan takes the aircraft through all normal pilot operating handbook (POH) operating envelope maneuvers, at different weights & CG locations, as well as allows you to modify any original limitations or checklist procedures. For the C172 with a new experimental engine, for example, the aircraft would need to conduct all maneuvering allowed by the original C172 POH, including stalls, steep turns, flight at minimum speed (Vs) and max speed (Vne), takeoff & landings, steep turns, trim stability, ect.. for a minimum of 40 hours.  Corsair can supply the phase 1 flight test plan if requested.

Once the test plan is complete, the owner makes a logbook entry basically stating the aircraft has been flown and is controllable throughout its operating envelope and safe for operation. Once this is complete, the aircraft is released to phase 2 operations. However, if a modification to the aircraft is later made which may affect its safe characteristics, such as installing a new prop, the aircraft must be returned to phase 1 limitations until the aircraft is flight tested (this time duration is dependent on how long it takes to assure the modification is safe) and again signed off by owner as safe.

Phase 2 operations for single engine EE eliminates the phase 1 geographic limitation, as well as allows passengers during proficiency, currency flights and traveling to/from events. However, passengers are normally prohibited when conducting exhibition performances, air racing, or unusual characteristics. Passengers are always prohibited during phase 1 operations.

Unless specifically otherwise stated in the operating limitations (again, local FSDO may change the standard limitations), there is no geographic limitation(s) for maintenance, proficiency, flying to exhibition events, or currency flying except to avoid flying over populated areas or on congested airways.

Flight training is allowed if there is no charge for the aircraft (CFI can charge for services), as FAA Order 8900.1  sec 3-292(A) indicates below:

3-292    FLIGHT TRAINING IN EXPERIMENTAL AIRCRAFT.

• Use of Experimental Aircraft for Flight Training. Persons may receive, and provide compensation for, flight training in an aircraft holding an experimental certificate issued for any of the purposes specified in § 21.191. Other than the person receiving flight training, the operation must not involve the carriage of persons or property for compensation or hire or be prohibited by the aircraft’s operating limitations

Can experimental aircraft be used to form a flying club? If the club is non-profit equity type club, wherein every member owns a share of each aircraft and reasonable operating expenses are charged, then yes. If the club merely rents out the aircraft to non-equity members, then no.

Can I build time in an experimental exhibition aircraft? Yes. Remember, the primary purpose must be to exhibit the aircraft, so include some distant events to fly to between proficiency, currency and maintenance flights.

Can owner of EE aircraft obtain a repairman’s certificate as experimental amateur-built kit builders get, allowing them to sign off my own aircraft’s annual condition report? No, not for previously certified aircraft.

1. Use of less expensive/non-certified, high tech experimental components, such as avionics, batteries, lights, autopilots, .

2. Annual condition report requires only A&P (not AI) to sign off.

3. Overall lower operating cost.

4. Overall lower cost and wider range of more environmentally-friendly fuel types.

Converting to experimental is not for everyone. But for many, it makes sense and may be the only way to afford the passion of flying. The average age of piston aircraft worldwide now exceeds 40 years old, and new piston replacements are basically the same as their ancestors. When considering you can purchase a complete brand new hybrid vehicle for less than the cost of re-manufacturing a 40 year old O-360, leaded fuel burning engine (requiring only parts such as rings, pistons, seals, ect..), converting to experimental is worth considering.

Each Corsair firewall forward kit will include the required documents to convert to experimental and assistance if requested. Much of the paperwork can be handled by a local DAR, which are listed on the FAA website, or we can recommend a DAR familiar with our product.