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prop change is a major change

 
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tjs22t(at)verizon.net
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PostPosted: Tue Jan 22, 2008 5:34 am    Post subject: prop change is a major change Reply with quote

[quote]


I know it varies from DAR to DAR. our guy up here has been know to require an additional 20 hours for a prop change.

+++ Your DAR, like many that have been encountered by builders on this list, is marching to the beat of his own drum.
Examples:
Wayne B. was told by his DAR that the strobe/position lights on wingtips would have to be changed because they tilted forward too much.
Brent B. was given a 25 hour Phase I period with a Rotax 912 (not the certificated model).
Ron D. was told that his a/c was not inspectable with the flex-skin aileron hinges.
...probably many more.
According to FAR 21.93 the changing of a prop is a major change. Forget any "wood to metal" qualification that might seep into the discussion, the prop change will "...have an appreciable effect on the operational characteristics of the a/c," and as such you will have to look to the last page of your Operating Limitations granted when you received your airworthiness certificate.
Below is what most of us have if we were inspected up until 2004:
(at the bottom of this post is what you folks inspected after 2004 must do - note it says that DARs lack authority in this area)
8130.2D 2/15/00
CHG 1
Page 114 Par 134
(19)
After incorporating a major change as described in § 21.93, the aircraft owner is required to
re-establish compliance with § 91.319(b). All operations will be conducted VFR, day only, in a sparsely
populated area. The aircraft must remain in flight test for a minimum of 5 hours. Persons non-essential to the
flight shall not be carried. The aircraft owner shall make a detailed log book entry describing the change prior to
the test flight. Following satisfactory completion of the required number of flight hours in the flight test area, the
pilot shall certify in the records that the aircraft has been shown to comply with § 91.319(b). Compliance with
§ 91.319(b) shall be recorded in the aircraft records with the following or a similarly worded statement: "I
certify that the prescribed flight test hours have been completed and the aircraft is controllable
throughout its normal range of speeds and throughout all maneuvers to be executed, has no
hazardous operating characteristics or design features, and is safe for operation. The following
aircraft operating data has been demonstrated during the flight testing: speeds Vso______,
Vx______, and Vy______, and the weight______, and CG location______ at which they were
obtained."


< A prop change is not major and does not require additional hours to my understanding.
Quote:


<< By changing props, how much time is being added to the testing by the DAR?

+++ This example below from Government Relations clarification on the EAA website:
Quote:
Quote:

Historically, that limitation has evolved (with the help of EAA).
  1. Yours is an example of what was standard in 1985 - any major changes required an FAA inspection and re-certification of the aircraft. Which created a major FAA FSDO workload.
  2. In 1993 the limitation wording changed to "notify the FSDO prior to making any changes." Now it was no longer mandatory to get a new FSDO inspection if the FSDO approved your change data in writing. This reduced their workload by 50%, but you still had to get their approval in writing before starting with changing your aircraft.
  3. In 1999 the limitation was changed. No longer does the FSDO have to be notified of a major change. The aircraft owner now just has to make two entries in the logbook - one describing the major change, and after a minimum of a five hour test flight, one showing that the safety of the aircraft (FAR 91.319) and the critical airspeeds (Vx, Vy, Vso) have been reestablished. No FSDO workload.
  4. In 2004 the limitation changed again. In this change the owner has to obtain concurrence from the local FSDO as to the suitability of the proposed test flight area. FAR 91.305 provides the FAA guidance for this change. You can find the current limitation in FAA Order 8130.2F, paragraph 153b(19).

Updating your operating limitations is a paperwork procedure that does not require a reinspection of your aircraft.
Anyway, EAA recommends you ask your local FSDO or MIDO to update your existing operating limitations to the ones in FAA Order 8130.2F. You can locate your local FSDO or MIDO by calling EAA at 888-322-4636, extension 4821 or by using the FAA FSDO locatorFAA MIDO locator[/b][/u] web site. Call the FSDO or MIDO and tell them you'll be mailing (or by fax if they'll allow it) them a letter requesting to update your operating limitations, along with copies (DO NOT mail your originals – just in case they get lost in the mail) of your current airworthiness certificate, aircraft registration and operating limitations. Let them know you'll bring in the original documents for exchange when the new ones are ready - you can't fly your aircraft without the original documents in the aircraft so hang onto them as long as you can. This is a paperwork issue that should only take them 30 minutes to complete. Don't let them refer you to a DAR for the paperwork conversion because a DAR does not have the authority to do this - only a FAA FSDO or MIDO Safety Inspector can do the paperwork. Note: a DAR can do the paperwork under a "re-certification" action, which means they have to inspect your aircraft and charge you for their services - while the FSDO or MIDO Inspector does not have to do an inspection and the cost is more reasonable - Free.
+++ Bottom line - look in your operating limitations


Quote:


[b]


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alaskajim(at)cox.net
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PostPosted: Tue Jan 22, 2008 7:53 am    Post subject: prop change is a major change Reply with quote

Thank you for the correction concerning a "major change" for a prop installation.  In my case, I'm still in my original test area and still flying  off my hours.  I will make the change in my logbook and return it to service when the 40 hours are flown off.  No additional hours, in my case are warranted.  As you clarified, I'm not required to contact my original DAR  or even the FSDO office except to the suitability (does not apply here) of the test area.  I understand from my DAR this is because I could have flown off my hours and have moved back to Alaska in which case the local FSDO would approve/disapprove my new test area at that time.  This could be inaccurate, but this is the way I interpret this situation.  Thank you again for all the time to research this for our list.   Jim
  
On Jan 22, 2008, at 6:28 AM, THOMAS SMALL wrote:
Quote:
 
Quote:
 
I know it varies from DAR to DAR. our guy up here has been know to require an additional 20 hours for a prop change.

+++ Your DAR, like many that have been encountered by builders on this list, is marching to the beat of his own drum. 
Examples:
Wayne B. was told by his DAR that the strobe/position lights on wingtips would have to be changed because they tilted forward too much.
Brent B. was given a 25 hour Phase I period with a Rotax 912 (not the certificated model).
Ron D. was told that his a/c was not inspectable with the flex-skin aileron hinges.
...probably many more.
According to FAR 21.93 the changing of a prop is a major change.  Forget any "wood to metal" qualification that might seep into the discussion, the prop change will "...have an appreciable effect on the operational characteristics of the a/c," and as such you will have to look to the last page of your Operating Limitations granted when you received your airworthiness certificate.
Below is what most of us have if we were inspected up until 2004: 
(at the bottom of this post is what you folks inspected after 2004 must do - note it says that DARs lack authority in this area)
8130.2D 2/15/00
CHG 1
Page 114 Par 134
(19) After incorporating a major change as described in § 21.93, the aircraft owner is required to
re-establish compliance with § 91.319(b). All operations will be conducted VFR, day only, in a sparsely
populated area. The aircraft must remain in flight test for a minimum of 5 hours. Persons non-essential to the
flight shall not be carried. The aircraft owner shall make a detailed log book entry describing the change prior to
the test flight. Following satisfactory completion of the required number of flight hours in the flight test area, the
pilot shall certify in the records that the aircraft has been shown to comply with § 91.319(b). Compliance with
§ 91.319(b) shall be recorded in the aircraft records with the following or a similarly worded statement: "I
certify that the prescribed flight test hours have been completed and the aircraft is controllable
throughout its normal range of speeds and throughout all maneuvers to be executed, has no
hazardous operating characteristics or design features, and is safe for operation. The following
aircraft operating data has been demonstrated during the flight testing: speeds Vso______,
Vx______, and Vy______, and the weight______, and CG location______ at which they were
obtained."


< A prop change is not major and does not require additional hours to my understanding.  
Quote:


<< By changing props, how much time is being added to the testing by the DAR? 

+++ This example below from Government Relations clarification on the EAA website:
Quote:
Quote:

Historically, that limitation has evolved (with the help of EAA).
  1. Yours is an example of what was standard in 1985 - any major changes required an FAA inspection and re-certification of the aircraft. Which created a major FAA FSDO workload.
  2. In 1993 the limitation wording changed to "notify the FSDO prior to making any changes." Now it was no longer mandatory to get a new FSDO inspection if the FSDO approved your change data in writing. This reduced their workload by 50%, but you still had to get their approval in writing before starting with changing your aircraft.
  3. In 1999 the limitation was changed. No longer does the FSDO have to be notified of a major change. The aircraft owner now just has to make two entries in the logbook - one describing the major change, and after a minimum of a five hour test flight, one showing that the safety of the aircraft (FAR 91.319) and the critical airspeeds (Vx, Vy, Vso) have been reestablished. No FSDO workload.
  4. In 2004 the limitation changed again. In this change the owner has to obtain concurrence from the local FSDO as to the suitability of the proposed test flight area. FAR 91.305 provides the FAA guidance for this change. You can find the current limitation in FAA Order 8130.2F, paragraph 153b(19).

Updating your operating limitations is a paperwork procedure that does not require a reinspection of your aircraft.
Anyway, EAA recommends you ask your local FSDO or MIDO to update your existing operating limitations to the ones in FAA Order 8130.2F. You can locate your local FSDO or MIDO by calling EAA at 888-322-4636, extension 4821 or by using the FAA FSDO locatorFAA MIDO locator[/b][/u] web site. Call the FSDO or MIDO and tell them you'll be mailing (or by fax if they'll allow it) them a letter requesting to update your operating limitations, along with copies (DO NOT mail your originals – just in case they get lost in the mail) of your current airworthiness certificate, aircraft registration and operating limitations. Let them know you'll bring in the original documents for exchange when the new ones are ready - you can't fly your aircraft without the original documents in the aircraft so hang onto them as long as you can. This is a paperwork issue that should only take them 30 minutes to complete. Don't let them refer you to a DAR for the paperwork conversion because a DAR does not have the authority to do this - only a FAA FSDO or MIDO Safety Inspector can do the paperwork. Note: a DAR can do the paperwork under a "re-certification" action, which means they have to inspect your aircraft and charge you for their services - while the FSDO or MIDO Inspector does not have to do an inspection and the cost is more reasonable - Free.
+++ Bottom line - look in your operating limitations


Quote:



Quote:
Quote:
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tjs22t(at)verizon.net
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PostPosted: Tue Jan 22, 2008 8:50 am    Post subject: prop change is a major change Reply with quote

Alaska Jim,

Very confusing area. I sensed you were in still in Phase I and as such you can make any changes you want. Had you been in Phase II and moved and then made the prop change, I think you'd be required to at least contact the local FSDO/MIDO in case they wanted to be a bit heavy-handed and impose a new test area. Seems like the old reg adopted in 1999 was a bit more lenient - but at least that's what my a/c is under so fine by me.

This info came from Joe Norris at EAA when I called to check on a change made last month from the old Jabiru 60x48 prop to a Sensenich 64x51 for the opposite reason you did - to gain some cruise. Average speed increase in the 2600 to 2850 RPM range was 9 MPH. With the prop you described coming from Sensenich, you should have climb out the kazoo!

BTW, your bird is very sharp.

CAVU jeff HDS/3300 do not archive
[quote]


Thank you for the correction concerning a "major change" for a prop installation. In my case, I'm still in my original test area and still flying off my hours. I will make the change in my logbook and return it to service when the 40 hours are flown off. No additional hours, in my case are warranted. As you clarified, I'm not required to contact my original DAR or even the FSDO office except to the suitability (does not apply here) of the test area. I understand from my DAR this is because I could have flown off my hours and have moved back to Alaska in which case the local FSDO would approve/disapprove my new test area at that time. This could be inaccurate, but this is the way I interpret this situation. [b]


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dragonfuel(at)aol.com
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PostPosted: Tue Jan 22, 2008 10:25 am    Post subject: prop change is a major change Reply with quote

The ELSA planes follow a different path on such changes. The builder simply reverts the plane to Phase One test status, flys a minimum of one hour flight test (or more if he believes needed), re-certifies the plane back into normal status, and records the process in the log. Works for a change of prop, engine, landing gear, or whatever. Wanted to change my Sensenich to a McCauley (done it). Wanted to change the McCauley to a Warp Drive (done it). Switch from Zenith landing gear to Grove (done it). Want to change the Lycoming for a Jabiru? Might some day but not yet, but same procedure. Simple?

Some of you guys couldn't see the advantage of ELSA? This is one.

Cheers,

Bob Archibald
CH601XL/Lyc 125hp/Dynons/400 hrs
Dragonfly Aviation

Do not archive





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craig(at)craigandjean.com
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PostPosted: Tue Jan 22, 2008 10:36 am    Post subject: prop change is a major change Reply with quote

So is changing the pitch on a ground adjustable prop a major change? If you change it enough seems like it would have as much impact on flight characteristics as a new prop.

-- Craig

From: owner-zenith-list-server(at)matronics.com [mailto:owner-zenith-list-server(at)matronics.com] On Behalf Of THOMAS SMALL
Sent: Tuesday, January 22, 2008 9:45 AM
To: zenith-list(at)matronics.com
Subject: Re: prop change is a major change



Alaska Jim,



Very confusing area. I sensed you were in still in Phase I and as such you can make any changes you want. Had you been in Phase II and moved and then made the prop change, I think you'd be required to at least contact the local FSDO/MIDO in case they wanted to be a bit heavy-handed and impose a new test area. Seems like the old reg adopted in 1999 was a bit more lenient - but at least that's what my a/c is under so fine by me.



This info came from Joe Norris at EAA when I called to check on a change made last month from the old Jabiru 60x48 prop to a Sensenich 64x51 for the opposite reason you did - to gain some cruise. Average speed increase in the 2600 to 2850 RPM range was 9 MPH. With the prop you described coming from Sensenich, you should have climb out the kazoo!



BTW, your bird is very sharp.



CAVU jeff HDS/3300 do not archive
Quote:





Thank you for the correction concerning a "major change" for a prop installation. In my case, I'm still in my original test area and still flying off my hours. I will make the change in my logbook and return it to service when the 40 hours are flown off. No additional hours, in my case are warranted. As you clarified, I'm not required to contact my original DAR or even the FSDO office except to the suitability (does not apply here) of the test area. I understand from my DAR this is because I could have flown off my hours and have moved back to Alaska in which case the local FSDO would approve/disapprove my new test area at that time. This could be inaccurate, but this is the way I interpret this situation. http://www.matronics.com/Navigator?Zenith-List
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alaskajim(at)cox.net
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PostPosted: Tue Jan 22, 2008 10:38 am    Post subject: prop change is a major change Reply with quote

Yes, I'm in phase I with 33 hours to go.  I absolutely agree.  Thanks you     Jim
do not archive


On Jan 22, 2008, at 9:45 AM, THOMAS SMALL wrote:
Quote:
Alaska Jim,
 
Very confusing area.  I sensed you were in still in Phase I and as such you can make any changes you want.  Had you been in Phase II and moved and then made the prop change, I think you'd be required to at least contact the local FSDO/MIDO in case they wanted to be a bit heavy-handed and impose a new test area.  Seems like the old reg adopted in 1999 was a bit more lenient - but at least that's what my a/c is under so fine by me.
 
This info came from Joe Norris at EAA when I called to check on a change made last month from the old Jabiru 60x48 prop to a Sensenich 64x51 for the opposite reason you did - to gain some cruise.  Average speed increase in the 2600 to 2850 RPM range was 9 MPH.  With the prop you described coming from Sensenich, you should have climb out the kazoo!
 
BTW, your bird is very sharp.
 
CAVU  jeff   HDS/3300   do not archive
Quote:
 
Thank you for the correction concerning a "major change" for a prop installation.  In my case, I'm still in my original test area and still flying  off my hours.  I will make the change in my logbook and return it to service when the 40 hours are flown off.  No additional hours, in my case are warranted.  As you clarified, I'm not required to contact my original DAR  or even the FSDO office except to the suitability (does not apply here) of the test area.  I understand from my DAR this is because I could have flown off my hours and have moved back to Alaska in which case the local FSDO would approve/disapprove my new test area at that time.  This could be inaccurate, but this is the way I interpret this situation.          - The Zenith-List Email Forum class="Apple-converted-space"> --> http://www.matronics.com/Navigator?Zenith-List                 --> http://forums.matronics.com            - List Contribution Web Site -                             -Matt Dralle, List Admin. class="Apple-converted-space"> --> http://www.matronics.com/contribution


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George(at)gtelectricnc.co
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PostPosted: Tue Jan 22, 2008 12:39 pm    Post subject: prop change is a major change Reply with quote

I wonder if some of you guys that spend so much time and effort on these trivial discussions were to spend equal time on building your planes, I am sure some of you would probably finish your projects a lot sooner if you spend your time on your projects instead.


From: owner-zenith-list-server(at)matronics.com [mailto:owner-zenith-list-server(at)matronics.com] On Behalf Of dragonfuel(at)aol.com
Sent: Tuesday, January 22, 2008 1:31 PM
To: zenith-list(at)matronics.com
Subject: Re: prop change is a major change


The ELSA planes follow a different path on such changes. The builder simply reverts the plane to Phase One test status, flys a minimum of one hour flight test (or more if he believes needed), re-certifies the plane back into normal status, and records the process in the log. Works for a change of prop, engine, landing gear, or whatever. Wanted to change my Sensenich to a McCauley (done it). Wanted to change the McCauley to a Warp Drive (done it). Switch from Zenith landing gear to Grove (done it). Want to change the Lycoming for a Jabiru? Might some day but not yet, but same procedure. Simple?

Some of you guys couldn't see the advantage of ELSA? This is one.

Cheers,

Bob Archibald
CH601XL/Lyc 125hp/Dynons/400 hrs
Dragonfly Aviation

Do not archive





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Gig Giacona



Joined: 10 Jan 2006
Posts: 1416
Location: El Dorado Arkansas USA

PostPosted: Tue Jan 22, 2008 1:50 pm    Post subject: Re: prop change is a major change Reply with quote

Well George, if frogs had wings they wouldn't bump their butts when they hop. A lot of us don't have the option of working on the plane every day and use our not working on the plane time to wax philosophical on the process.

Don't feel like you must read all of our babbling.

If you don't like the stuff filling your mail box do what I do. Use the web based reader. It really is, in a lot of ways, better and it is easier to skip over stuff that isn't of interest.

For the record this thread on the regs has been of interest to me and I would assume it has been to those that have posted to it. Remember we don't just fly our planes in the sky. We fly them in a regulated sky.

George(at)gtelectricnc.co wrote:
I wonder if some of you guys that spend so much time and effort on these trivial discussions were to spend equal time on building your planes, I am sure some of you would probably finish your projects a lot sooner if you spend your time on your projects instead.



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