Matronics Email Lists :: View topic - 300 nm range restriction

Matronics Email Lists
Web Forum Interface to the Matronics Email Lists

Get Email Distribution Too! FAQ Search Memberlist Usergroups Register

Profile Log in to check your private messages Log in

300 nm range restriction

Matronics Email Lists Forum Index -> Yak-List

View previous topic :: View next topic

Author Message

barryhancock

Joined: 09 Oct 2008
Posts: 285

Posted: Mon Jan 12, 2009 8:37 am Post subject: 300 nm range restriction

Hey Skip,



I believe this was covered a few months back on the list, but essentially if you go to the EAAWB web site they will give you a step by step.  With the memorandum in hand you can apply for an addendum to your existing Operating Limitations, or have new one's issued.   We've been successful in doing both with the local FSDO.   As always, the more educated you are the smoother the process will go.  

Here's an excerpt from the EAAWB release in '07

 How to obtain the letter of deviation:  Former military aircraft receiving initial experimental exhibition (FAR 21.191(d)) certification from today forward, need to present the September 11, 2007 FAA Memorandum to their FSDO in order to be exempt from the 300/600-mile proficiency flight area limitation. The next change to FAA Order 8130.2(F) will contain the elimination of this requirement, but in the meantime, this FAA Memorandum is the authority to remove the proficiency flight area limitation on their operating limitations. 
All former military experimental exhibition aircraft in Groups I, II, and III currently operating and with the flight proficiency 300/600 mile limitations on their operating limitations must continue to operate under the issued limitations until such time they get their operating limitations updated from their local FSDO. 
All former military experimental exhibition aircraft owners can immediately apply to their local FSDO to amend their operating limitations to eliminate the 300/600-mile flight proficiency area limitation. Once amended, they will no longer have a proficiency flight area limitation. When submitting the request to the FSDO to drop the proficiency area limitation, owners should:  Submit a cover letter to their local FSDO—“Request the operating limitations issued to TYPE OF AIRCRAFT, N-NUMBER, be updated to eliminate the proficiency flight area limitation per FAA Memorandum, subject: Deviation to Order 8130.2, dated September 11, 2007, from Frank Paskiewicz, Manager AIR-200. FAA headquarters, AFS-800, and AIR-200 have approved that this operating limitation change request will be processed per FAA Order 8130.2F, paragraph 27b(6), and no aircraft certification inspection is required for this paperwork change.”

 

 The owners need to attach the following to their letter:

 (1) A completed FAA Form 8130-6 http://forms.faa.gov/forms/faa8130-6d.pdf; and

 (2) A copy of their current operating limitations (not the original); and

 (3) A copy of their aircraft registration (not the original); and

 (4) A copy of the FAA Memorandum from AIR-200. 
As a note, once the local FSDO office is ready to update the operating limitations, the owners can expect to go to that office and exchange their old operating limitations for a new set (face to face). 
The mailing addresses for local FSDOs is at: http://www.faa.gov/about/office_org/field_offices/fsdo/   



Good luck!

Barry



 [quote][b]

_________________
Barry Hancock
Worldwide Warbirds, Inc.
www.worldwidewarbirds.com

GreasySideUp

Joined: 24 Oct 2007
Posts: 44

Posted: Wed Feb 04, 2009 11:25 am Post subject: Program letter

I am having the local FSDO redo the operating limits to get rid of the proficiency area.  They are saying I'll still need a program letter.  I thought the whole point was to avoid writing program letters each year.  Is this still the case with the new op limits or is he mistaken?  Will I still need to write a letter for every Airshow I wish to attend?



Thanks

viperdoc(at)mindspring.co
Guest

Posted: Wed Feb 04, 2009 11:49 am Post subject: 300 nm range restriction

Yep.

VD



--

dsavarese0812(at)bellsout
Guest

Posted: Wed Feb 04, 2009 2:32 pm Post subject: 300 nm range restriction

Unfortunately, the program letter or sometimes called a  Schedule of Events, has not been eliminated.  Ridiculous as it may be, we  still have to submit an annual Program letter.  So your FSDO inspector is  correct.  Hopefully when FAA Order 8130.2F is rewritten, the need for a  program letter will be eliminated.

 Dennis

  

 [quote]   ---

barryhancock

Joined: 09 Oct 2008
Posts: 285

Posted: Wed Feb 04, 2009 2:59 pm Post subject: Re: 300 nm range restriction

We need to remember that we are flying "exhibition" airplanes.  The intent of owning and operating these aircraft, as far as the FAA is concerned, is primarily for exhibition.  Therefore, a Program Letter announcing the events you intend to attend each year is just part and parcel of ownership of a warbird.  



Whilst inconvenient, it is certainly not onerous to type a letter with event dates and send it off via fax to the FAA.  Further, if you are flying to an event, make sure you have a copy of your program letter WITH THAT EVENT on there, as that could open you up to FAA scrutiny.  



The Program Letter serves as an opportunity to plan your flying for the year, so it ain't all bad.... 



Barry

_________________
Barry Hancock
Worldwide Warbirds, Inc.
www.worldwidewarbirds.com

dsavarese0812(at)bellsout
Guest

Posted: Wed Feb 04, 2009 3:34 pm Post subject: 300 nm range restriction

I'm not trying to sound arrogant here, but a  legitimate question is - If there are no restrictions on where you can  fly for proficiency except for landing at Class B primary airports, they why  does one need a program letter?  If there are no restrictions on  proficiency flights, which is what they are called, then flying to an airfield  that on that day just happened to have a local fly-in could certainly be a  flight for proficiency and not specifically for exhibiting the  aircraft.   If you're not going to exhibit the airplane, then it's  just a pleasure flight or a so-called proficiency flight.  But  because there is an airshow  or fly-in there that you flew to see (not  exhibit), the FAA says you need a program letter.  Why?

  

 Legitimate question?

 Dennis

   

 [quote]   ---

barryhancock

Joined: 09 Oct 2008
Posts: 285

Posted: Wed Feb 04, 2009 3:58 pm Post subject: Re: 300 nm range restriction

Dennis, 



You're asking a logical question about FAA regulations on experimental aircraft?  Shame on you...you know better!

_________________
Barry Hancock
Worldwide Warbirds, Inc.
www.worldwidewarbirds.com

dsavarese0812(at)bellsout
Guest

Posted: Wed Feb 04, 2009 4:11 pm Post subject: 300 nm range restriction

You're right Barry.  I do know better.

 Dennis

  

 [quote]   ---

yak52driver

Joined: 05 Jul 2008
Posts: 5

Posted: Wed Feb 04, 2009 5:56 pm Post subject: 300 nm range restriction

My local FSDO rep, who I fly with every six months for checkrides, told me to just put the airports I want to fly to during 2009 in the program letter, no dates/events necessary.  Not sure if that's true for every FSDO, but that's what mine wanted.

   From: barryhancock <bhancock(at)worldwidewarbirds.com>

To: yak-list(at)matronics.com

Sent: Wednesday, February 4, 2009 4:59:07 PM

Subject: Re: 300 nm range restriction

--> Yak-List message posted by: "barryhancock" <bhancock(at)worldwidewarbirds.com (bhancock(at)worldwidewarbirds.com)>

We need to remember that we are flying "exhibition" airplanes.  The intent of owning and operating these aircraft, as far as the FAA is concerned, is primarily for exhibition.  Therefore, a Program Letter announcing the events you intend to attend each year is just part and parcel of ownership of a warbird.  

Whilst inconvenient, it is certainly not onerous to         [quote][b]

dsavarese0812(at)bellsout
Guest

Posted: Wed Feb 04, 2009 6:21 pm Post subject: 300 nm range restriction

That's rather odd!  The purpose of the program letter is  to notify the FAA/FSDO of the EVENTS you plan to attend/exhibit the aircraft or  training events you plan on attending.  Certainly not what airports you  intend to fly to as you can fly anywhere your heart desires without  restriction.

  

(37) The owner/operator of  this aircraft must submit an annual program letter update to the local FSDO that  lists airshows, fly-ins, etc., that will be attended during the next  year, commencing at the time this aircraft is released into phase II  operation. This list of events may be amended, as applicable, by letter or fax  to the FSDO prior to the intended operation amendments. A copy of the  highlighted aeronautical chart, when applicable, must be carried aboard this  aircraft and be available to the pilot.  (Applicability:  All)

 [quote]   ---

barryhancock

Joined: 09 Oct 2008
Posts: 285

Posted: Thu Feb 05, 2009 9:10 am Post subject: Re: 300 nm range restriction

Agreed, it's odd, but beyond that do not ever take what someone tells you, regardless of their "expertise" or position within the FAA, as license to deviate from your Operating Limitations.  If they want to cause you trouble they won't care what Joe FSDO said, only what is in the Program Letter and whether or not you complied with it.



We deal with the FAA on a rather regular basis and are in the process of joining up with a Part 145 operation.  My eyes have been opened as I've now seen the "inner workings" of the way "interpretations", etc., can go down.  It can get ugly quick if you don't fully comply with your paperwork and fully cooperate with the powers that be.



Again, what "someone" says, regardless of their position or authority, will matter not when someone decides they want to violate you.  The ONLY thing that is going to save your bacon is working within the constraints of your program letter and getting any even potential deviation approved in writing first.

_________________
Barry Hancock
Worldwide Warbirds, Inc.
www.worldwidewarbirds.com

dsavarese0812(at)bellsout
Guest

Posted: Thu Feb 05, 2009 10:04 am Post subject: 300 nm range restriction

Well stated Barry.

 Dennis

  

 [quote]   ---

GreasySideUp

Joined: 24 Oct 2007
Posts: 44

Posted: Thu Feb 05, 2009 1:19 pm Post subject: Re: 300 nm range restriction

So what is the purpose of the program letter?  How is it used and what do they need it for?  How is it maintained, does anyone look at it and enter it into a database or is it filed away never to be seen again?  Is it something we can all get together on and petition it's  relevance?



It seems as though there are many rules that at one time had a great intent, but over time the reason they were implemented is no longer valid.

dsavarese0812(at)bellsout
Guest

Posted: Thu Feb 05, 2009 1:45 pm Post subject: 300 nm range restriction

Many logical questions, which are all good.  However,  regardless of the answers and whether or not they are meaningful or meaningless,  the Operating Limitations for your aircraft and mine require that we still  submit them.  Whether the local FSDO looks at them, reviews them, studies  them, files them or just simply disregards them doesn't matter because if you  don't have it along with updates with you in the airplane for any event you are  attending that is not on your annual program letter, if you get ramp checked you  could be violated.

  

 The whole mess goes back to 1993 when the first FAA Order 8127  was issued covering Experimental Exhibition aircraft.  The FAA wanted to  "control" where these aircraft flew because at the same time in 1993 there were  quite a few Mig 15's being imported.  When the applications came in for  Airworthiness Certificates for these former military fighters, all of the sudden  the FAA said "Whoa!".  We don't know how to handle this.  So a  moratorium was issued for all Experimental Exhibition aircraft while the  FAA tried to figure out what to do with these airplanes.  Yak's and CJ's  that were issued Airworthiness Certificates and OL's prior to June of 1993 did  not have any proficiency area limitations.

  

 I guess they figured by knowing where these airplanes were  going to fly by the requirement of a program letter which is really a schedule  of events where the aircraft was to be exhibited, was the way to control  them.

  

 Through the many reiterations of the FAA Order to what it is  today, 8130.2F Change 3, the requirement for the Program Letter has  remained.  Including with the issuance of the letter of Sept. 2007 removing  the 300 and 600 mile proficiency areas.  Unfortunately, not a lot of  intelligence went into the issuance of that letter.  Instead of stating  something like "When carried in the aircraft, the 300/600 mile proficiency area  stated in the aircraft's Operating Limitations is eliminated." or something to  that effect.  AIR 200 didn't think about the additional paperwork  required to reissue OL's to remove the 300/600 mile proficiency  area.   Nor did they ask themselves, "well....why does the  Experimental Exhibition aircraft need a Program Letter or Schedule of  Events if they are not restricted on where they can fly for  proficiency?" 

  

 I have discussed this entire issue with the EAA Gov't Affairs  contact person, Randy Hanson and he understands how foolish it is and is pushing  to have the program letter requirement removed when the FAA Order is  rewritten.  Until such time as that occurs, we're stuck with what we have  and all the petitioning in the world is probably not going to make things change  until the Order is rewritten.

 Dennis

  

 [quote]   ---

viperdoc(at)mindspring.co
Guest

Posted: Thu Feb 05, 2009 2:03 pm Post subject: 300 nm range restriction

Somewhere there is a shoe clerk getting his jollies off on these program

letters. This is a do so because I said so kind of deal.

Viperdoc



--

dsavarese0812(at)bellsout
Guest

Posted: Thu Feb 05, 2009 2:12 pm Post subject: 300 nm range restriction

You got that right!

 Dennis

 [quote]   ---

Display posts from previous:

	Matronics Email Lists Forum Index -> Yak-List	All times are GMT - 8 Hours
Page 1 of 1

Jump to:

You cannot post new topics in this forum
You cannot reply to topics in this forum
You cannot edit your posts in this forum
You cannot delete your posts in this forum
You cannot vote in polls in this forum
You cannot attach files in this forum
You can download files in this forum