I believe that your FAA briefer was attempting to state that the aircraft cannot have a combination of lift enhancing devices, retractable gear, and inflight adjustable prop, which would constitute a complex aircraft. Flaps alone would not be prohibited because they make approaches safer, they just might be prohibited for establishing the stall speed as previously stated.
You are really opening up a can of worms if you attempt to build a KR1 or 2 and get it certified under the ELSA rules due to the fact that more than 1000 examples have already been built which do not comform to the rules. After extensive exposure to the FAA, both attempting to get inspected, and nearly 4 years as an Aviation Safety Counselor, I firmly believe that you will not be able to simply request your example be certified under the new rule without extensive proving ground type testing prior to certification. There is no manufacturer of the KR so there is no parent company to provide a factory example modified to conform to the new rules. With so many not conforming, I can see the DAR unwilling to approve ELSA until you prove to him that your plane does in fact conform. I know for sure that no actual FAA employee will sign off on it. I can tell you that solo, with belly board deployed, my KR2 sets down between 50 and 55 mph IN GROUND EFFECT. Clean air stall will be higher. If I were intending on trying to make the KR conform, I would use one of the commercially available design software programs, and input the known data from the examples of KRs flying and then see what modification that the software predicts must be done to achieve the performance numbers, save that data to show the DAR, and then decide whether those modifications warrant going ahead with this design or another design. Remember that snowball rolling downhill.... (ie: changes grow ) FLY SAFE! Colin & Bev Rainey KR2(td) N96TA Sanford, FL crain...@cfl.rr.com http://kr-builder.org/Colin/index.html