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

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