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helili(at)chahtatushka.ne
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 Posted: Thu Jul 16, 2009 6:27 am Post subject: owner performed maintenance |
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Bob,
Your attention is invited to Title 14: Part 43 -MAINTENANCE, PREVENTIVE MAINTENANCE, REBUILDING, AND ALTERATION, Paragraph 43.1 (d).
URL: http://ecfr.gpoaccess.gov/cgi/t/text/text-idx?c=ecfr&sid=ac58ea778437f87fb6cef7d984262c50&rgn=div8&view=text&node=14:1.0.1.3.21.0.363.1&idno=14
,
It clearly states: ” (b) This part does not apply to any aircraft for which the FAA has issued an experimental certificate, unless the FAA has previously issued a different kind of airworthiness certificate for that aircraft.”
Amateur built Experimental aircraft are issued a “Special airworthiness certificate “ denoting Experimental.
Also, in Title 14: Part 43 -MAINTENANCE, PREVENTIVE MAINTENANCE, REBUILDING, AND ALTERATION, Paragraph 43.1 (d). (Same URL), expounds on Light Sport Category maintenance and alterations.
John Hart
KF IV, NSI Subaru
A&P
From: owner-kitfox-list-server(at)matronics.com [mailto:owner-kitfox-list-server(at)matronics.com] On Behalf Of Bob Brennan
Sent: Thursday, July 16, 2009 7:36 AM
To: kitfox-list(at)matronics.com
Subject: RE: owner performed maintenance
Dick,
If your aircraft has an Airworthiness Certification (not "licensed") as SLSA you have the same restrictions as to what you can do on it as any factory built STC (Standard Type Certificate) aircraft such as a Piper or Cessna. However an SLSA aircraft owner has the unique ability to do a 1-time change to ELSA certification (can never change it back to SLSA). The SLSA/now ELSA aircraft is still bound by STC approvals and restrictions regarding parts and modifications, but the owner now can do the work and inspections him/herself.
An ELSA aircraft has few restrictions as to parts and modifications although it is always wise to stick to the kit manufacturer's recommendations and airworthiness notifications, which for any Experimental aircraft are not mandatory like they are with STC aircraft.
I think the confusion comes in when people here offer opinion off the top of their heads. Sorry to be such a stickler for facts but here is the link to the FAA site regarding Airworthiness Certification and all the implications, which I hope I am summarising in a more readable form in this thread(?)
http://www.faa.gov/aircraft/air_cert/airworthiness_certification/
Bob Brennan - N717GB
ELSA Repairman, inspection rated
1991 UK Model 2 ELSA Kitfox taildragger
Rotax 582 with 3 blade GSC prop
Wrightsville Pa
From: owner-kitfox-list-server(at)matronics.com [mailto:owner-kitfox-list-server(at)matronics.com] On Behalf Of Catz631(at)aol.com
Sent: 16 July 2009 8:04 am
To: kitfox-list(at)matronics.com
Subject: Re: owner performed maintenance
Paul,
We are talking apples and oranges here. My Kitfox,as an example, is licensed as an amateur built experimental aircraft. As such I can do all the maintenance on the aircraft (with some exceptions). I am not hampered by a list of preventative maintenance items IF I was the original builder I could also do the annual condition inspection. However I am not the builder so I have to have an A&P do that. As stated previously this has been this way for a long time and is one of the benefits of owning an experimental aircraft.
Now IF my aircraft was licensed as an ELSA (or SLSA) that is a different story. I believe that is what you are referring to. This whole thing is a very confusing issue as illustrated in the many forums held at Lakeland and Sebring on that very subject.
Dick Maddux
Fox 4
Milton,Fl
Can love help you live longer? Find out now.
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[quote][b]
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Jim Feldmann
Joined: 01 Sep 2008
Posts: 54
Location: Burbank, CA
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| Posted: Thu Jul 16, 2009 7:30 am Post subject: Re: owner performed maintenance |
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Well, if the EAA is not authoritative enough for you, let's try the FAA's own documents. This is from the faa.gov website:
Detailed Explanation of Primary
Regulations (Parts 43 and 91)
14 CFR Part 43 â Maintenance, Preventive Maintenance, Rebuilding, and Alteration
§43.1 Applicability
Paragraph (a) states quite clearly that aircraft (whether
U.S.- or foreign-registered operating under part 121 or
135) and component parts thereof, must be maintained
in accordance with the rules set forth in this part.
However, although paragraph (b) states quite clearly
the type of aircraft for which this part does not apply,
it seems to have led to considerable confusion within
the aviation industry. If an aircraft is flying with a
Special Airworthiness â Experimental certificate (FAA
Form 8130-7, Special Airworthiness Certificate â pink
color certificate) and that is the only airworthiness
certificate this aircraft has ever had, then part 43 does
not apply.
If this is reversed, counteracted, excepted, modified or further defined somewhere else in the regs, perhaps you can direct me to that area.
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_________________
Jim Feldmann
Kitfox IV Speedster / 912 lost to prop failure
Building a Kitfox 5 Voyager |
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akflyer
Joined: 07 May 2007
Posts: 574
Location: Soldotna AK
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| Posted: Thu Jul 16, 2009 7:59 am Post subject: Re: owner performed maintenance |
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Guy gets the gold star on this one... again...
Take mine for instance. I bought a wrecked, previously flown and N# and signed off. I was able to rebuild the aircraft, to include replacing tubes, welding, tearing apart wings and rebuilding, and generally putting in more work, and doing more difficult tasks than it took to build the plane to begin with. The FAA inspector as well as the local AI I use was aware that I was doing the entire rebuild, INCLUDING the engine. The only thing that I had to have someone else do, was the condition inspection when I got her done.
I did not have the original Air Worthiness only a copy and my AI would not sign it off. We applied for a replacement and the FAA inspector decided he wanted to come down and take a look at the plane ( I am certain he just wanted to get out of the office) At any rate, he spent 10 minutes looking over my rebuild book, 2 minutes looking at the plane, then handed me the air worthiness cert. He would not have done so, had there been an issue with me being the only one in the rebuild pics, the only one to put entries into the log books, and the only one to state that I did every single bit of the work myself. He simply said good job, have fun, and stay SAFE!
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_________________
DO NOT ARCHIVE
Leonard Perry aka SNAKE
Soldotna AK
Avid "C" / Mk IV
582 (147 hrs and counting on the rebuild)
IVO IFA
Full Lotus 1450
#1 snake oil salesman since 1-22-2009
I would rather die trying to live, than to live trying not to die.... |
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Paul A. Franz, P.E.
Joined: 02 Dec 2008
Posts: 280
Location: Bellevue WA
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| Posted: Thu Jul 16, 2009 8:43 am Post subject: owner performed maintenance |
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On Thu, July 16, 2009 5:04 am, Catz631(at)aol.com wrote:
| Quote: | Paul,
We are talking apples and oranges here. My Kitfox,as an example, is
licensed as an amateur built experimental aircraft. As such I can do all the
maintenance on the aircraft (with some exceptions). I am not hampered by a list
of preventative maintenance items IF I was the original builder I could also
do the annual condition inspection. However I am not the builder so I have
to have an A&P do that.
|
Did you read the article I posted? It is pretty clear and unambiguous to me. You can
perform no more work on the Experimental than you can on a certified aircraft since
you are neither an A&P or hold a repairman's certificate for your aircraft.
Enforcement of this seems to be almost completely lacking but it would come to a head
should an insurance or accident investigation occur.
| Quote: | As stated previously this has been this way for a
long time and is one of the benefits of owning an experimental aircraft.
|
Don't kid yourself. That is simply not true. You are allowed to perform only minor
repairs and there is a specifically defined list of the scope of these 31 items. I
have appended it to this posting. If you have any doubts, you can phone the FAA or
just read the appropriate FAR's and CFR's listed in the article.
| Quote: | Now IF my aircraft was licensed as an ELSA (or SLSA) that is a different
story. I believe that is what you are referring to. This whole thing is a
very confusing issue as illustrated in the many forums held at Lakeland and
Sebring on that very subject.
|
As previously explained, there are some enhancements available if you take the
required training classes for ELSA. But if your aircraft was originally registered as
Experimental you cannot change it to ELSA for the purpose of this privilege.
Here's the article again. Read it over.
<http://www.globalair.com/articles/cox/article.asp>
If you question any aspect of it call the FAA for guidance. Quoting near the end of
the article:
Get to know your Local FAA FISDO Personnel
There are nine domestic FAA Regions that are home to 83 Flight Standards District
Offices (FSDO's) in the U.S.A.
Each FSDO is staffed by knowledgeable Maintenance Inspectors, who have been trained to
oversee, assist and provide you with guidance in the field of aircraft maintenance.
To get the location of your FSDO office, call the FAA Aviation Safety Hotline at:
1-866-835-53222.
The 31 items that you CAN do yourself
1. Removal, installation, and repair of landing gear tires.
2. Replacing elastic shock absorber cords on landing gear.
3. Servicing landing gear shock struts by adding oil, air, or both.
4. Servicing landing gear wheel bearings, such as cleaning and greasing.
5. Replacing defective safety wiring or cotter keys.
6. Lubrication not requiring disassembly other than removal of nonstructural items
such as cover plates, cowlings, and fairings.
7. Making simple fabric patches not requiring rib stitching or the removal of
structural parts or control surfaces. In the case of balloons, the making of small
fabric repairs to envelopes (as defined in, and in accordance with, the balloon
manufacturers' instructions) not requiring load tape repair or replacement.
8. Replenishing hydraulic fluid in the hydraulic reservoir.
9. Refinishing decorative coating of fuselage, balloon baskets, wings tail group
surfaces (excluding balanced control surfaces), fairings, cowlings, landing gear,
cabin, or cockpit interior when removal or disassembly of any primary structure or
operating system is not required.
10. Applying preservative or protective material to components where no disassembly of
any primary structure or operating system is involved and where such coating is not
prohibited or is not contrary to good practices.
11. Repairing upholstery and decorative furnishings of the cabin, cockpit, or balloon
basket interior when the repairing does not require disassembly of any primary
structure or operating system or interfere with an operating system or affect the
primary structure of the aircraft.
12. Making small simple repairs to fairings, nonstructural cover plates, cowlings, and
small patches and reinforcements not changing the contour so as to interfere with
proper air flow.
13. Replacing side windows where that work does not interfere with the structure or
any operating system such as controls, electrical equipment, etc.
14. Replacing safety belts.
15. Replacing seats or seat parts with replacement parts approved for the aircraft,
not involving disassembly of any primary structure or operating system.
16. Trouble shooting and repairing broken circuits in landing light wiring circuits.
17. Replacing bulbs, reflectors, and lenses of position and landing lights.
18. Replacing wheels and skis where no weight and balance computation is involved.
19. Replacing any cowling not requiring removal of the propeller or disconnection of
flight controls.
20. Replacing or cleaning spark plugs and setting of spark plug gap clearance.
21. Replacing any hose connection except hydraulic connections.
22. Replacing prefabricated fuel lines.
23. Cleaning or replacing fuel and oil strainers or filter elements.
24. Replacing and servicing batteries.
25. Cleaning of balloon burner pilot and main nozzles in accordance with the balloon
manufacturer's instructions.
26. Replacement or adjustment of nonstructural standard fasteners incidental to
operations.
27. The interchange of balloon baskets and burners on envelopes when the basket or
burner is designated as interchangeable in the balloon type certificate data and the
baskets and burners are specifically designed for quick removal and installation.
28. The installations of anti-misfueling devices to reduce the diameter of fuel tank
filler openings provided the specific device has been made a part of the aircraft type
certificate data by the aircraft manufacturer, the aircraft manufacturer has provided
FAA-approved instructions for installation of the specific device, and installation
does not involve the disassembly of the existing tank filler opening.
29. Removing, checking, and replacing magnetic chip detectors.
30. Removing and replacing self-contained, front instrument panel-mounted navigation
and communication devices that employ tray-mounted connectors that connect the unit
when the unit is installed into the instrument panel, (excluding automatic flight
control systems, transponders and microwave frequency distance measuring equipment
(DME)). The approved unit must be designed to be readily and repeatedly removed and
replaced, and pertinent instructions must be provided. Prior to the unit's intended
use, an operational check must be performed in accordance with the applicable sections
of part 91.
31. Updating self-contained, front instrument panel-mounted Air Traffic Control (ATC)
navigational software data bases (excluding those of automatic flight control systems,
transponders and microwave frequency distance measuring equipment (DME), provided no
disassembly of the unit is required and pertinent instructions are provided. Prior to
the unit's intended use, an operational check must be performed in accordance with
applicable sections of part 91.
--
Paul A. Franz
Registration/Aircraft - N14UW/Merlin GT
Engine/Prop - Rotax 914/NSI CAP
Bellevue WA
Government is the great fiction, through which everybody endeavors
to live at the expense of everybody else.
-- Frederic Bastiat, French Economist (1801-1850)
"It is the duty of every good citizen to use all the opportunities
which occur to him, for preserving documents relating to the history of
our country."
-- Thomas Jefferson, letter to Hugh P. Taylor, October 4, 1823
"The aim of every political constitution is, or ought to be, first
to obtain for rulers men who possess most wisdom to discern, and
most virtue to pursue, the common good of the society; and in the
next place, to take the most effectual precautions for keeping them
virtuous whilst they continue to hold their public trust."
--Alexander Hamilton or James Madison, Federalist No. 57, 19 February 1788
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_________________
Paul A. Franz, P.E.
Registration/Aircraft - N14UW/Merlin GT
Engine/Prop - Rotax 914/NSI CAP
Bellevue WA
425.241.1618 Cell
425.440.9505 Office |
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matronics(at)bob.brennan.
Guest
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| Posted: Thu Jul 16, 2009 8:56 am Post subject: owner performed maintenance |
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|
John,
Sorry but I am missing your point here. Is there anything that I said in my posting that these references or you disagree with? Or is possibly wrong or mis-stated? I appreciate any corrections if they are needed but you'll need to be more specific.
Thanks,
bob
From: owner-kitfox-list-server(at)matronics.com [mailto:owner-kitfox-list-server(at)matronics.com] On Behalf Of John W. Hart
Sent: 16 July 2009 10:25 am
To: kitfox-list(at)matronics.com
Subject: RE: owner performed maintenance
Bob,
Your attention is invited to Title 14: Part 43 -MAINTENANCE, PREVENTIVE MAINTENANCE, REBUILDING, AND ALTERATION, Paragraph 43.1 (d).
URL: http://ecfr.gpoaccess.gov/cgi/t/text/text-idx?c=ecfr&sid=ac58ea778437f87fb6cef7d984262c50&rgn=div8&view=text&node=14:1.0.1.3.21.0.363.1&idno=14
,
It clearly states: ” (b) This part does not apply to any aircraft for which the FAA has issued an experimental certificate, unless the FAA has previously issued a different kind of airworthiness certificate for that aircraft.”
Amateur built Experimental aircraft are issued a “Special airworthiness certificate “ denoting Experimental.
Also, in Title 14: Part 43 -MAINTENANCE, PREVENTIVE MAINTENANCE, REBUILDING, AND ALTERATION, Paragraph 43.1 (d). (Same URL), expounds on Light Sport Category maintenance and alterations.
John Hart
KF IV, NSI Subaru
A&P
From: owner-kitfox-list-server(at)matronics.com [mailto:owner-kitfox-list-server(at)matronics.com] On Behalf Of Bob Brennan
Sent: Thursday, July 16, 2009 7:36 AM
To: kitfox-list(at)matronics.com
Subject: RE: owner performed maintenance
Dick,
If your aircraft has an Airworthiness Certification (not "licensed") as SLSA you have the same restrictions as to what you can do on it as any factory built STC (Standard Type Certificate) aircraft such as a Piper or Cessna. However an SLSA aircraft owner has the unique ability to do a 1-time change to ELSA certification (can never change it back to SLSA). The SLSA/now ELSA aircraft is still bound by STC approvals and restrictions regarding parts and modifications, but the owner now can do the work and inspections him/herself.
An ELSA aircraft has few restrictions as to parts and modifications although it is always wise to stick to the kit manufacturer's recommendations and airworthiness notifications, which for any Experimental aircraft are not mandatory like they are with STC aircraft.
I think the confusion comes in when people here offer opinion off the top of their heads. Sorry to be such a stickler for facts but here is the link to the FAA site regarding Airworthiness Certification and all the implications, which I hope I am summarising in a more readable form in this thread(?)
http://www.faa.gov/aircraft/air_cert/airworthiness_certification/
Bob Brennan - N717GB
ELSA Repairman, inspection rated
1991 UK Model 2 ELSA Kitfox taildragger
Rotax 582 with 3 blade GSC prop
Wrightsville Pa
From: owner-kitfox-list-server(at)matronics.com [mailto:owner-kitfox-list-server(at)matronics.com] On Behalf Of Catz631(at)aol.com
Sent: 16 July 2009 8:04 am
To: kitfox-list(at)matronics.com
Subject: Re: owner performed maintenance
Paul,
We are talking apples and oranges here. My Kitfox,as an example, is licensed as an amateur built experimental aircraft. As such I can do all the maintenance on the aircraft (with some exceptions). I am not hampered by a list of preventative maintenance items IF I was the original builder I could also do the annual condition inspection. However I am not the builder so I have to have an A&P do that. As stated previously this has been this way for a long time and is one of the benefits of owning an experimental aircraft.
Now IF my aircraft was licensed as an ELSA (or SLSA) that is a different story. I believe that is what you are referring to. This whole thing is a very confusing issue as illustrated in the many forums held at Lakeland and Sebring on that very subject.
Dick Maddux
Fox 4
Milton,Fl
Can love help you live longer? Find out now.
| Quote: | | href="http://www.matronics.com/Navigator?Kitfox-List">http://www.matronhref="http://forums.matronics.com">http://forums.matronics.comhref="http://www.matronics.com/contribution">http://www.matronics.com/c |
0123456789 | Quote: | | href="http://www.matronics.com/Navigator?Kitfox-List">http://www.matronhref="http://forums.matronics.com">http://forums.matronics.com |
0 | Quote: | | href="http://www.matronics.com/Navigator?Kitfox-List">http://www.matronhref="http://forums.matronics.com">http://forums.matronics.com |
1 | Quote: | | href="http://www.matronics.com/Navigator?Kitfox-List">http://www.matronhref="http://forums.matronics.com">http://forums.matronics.com |
2 | Quote: | | href="http://www.matronics.com/Navigator?Kitfox-List">http://www.matronhref="http://forums.matronics.com">http://forums.matronics.com |
3
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4 [quote][b]
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helili(at)chahtatushka.ne
Guest
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| Posted: Thu Jul 16, 2009 9:27 am Post subject: owner performed maintenance |
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|
Bob,
The first sentence in your previous posting, “
If your aircraft has an Airworthiness Certification (not "licensed") as SLSA you have the same restrictions as to what you can do on it as any factory built STC (Standard Type Certificate) aircraft such as a Piper or Cessna.”, prompted my response. Experimental Amateur Built aircraft are not issued a “standard airworthiness certificate” or “licensed” as SLSA, therefore the provisions of FAR 43.1 (b) applies, rather than the part of your statement, “have the same restrictions as to what you can do on it as any factory built STC (Standard Type Certificate) aircraft such as a Piper or Cessna” .
John Hart
From: owner-kitfox-list-server(at)matronics.com [mailto:owner-kitfox-list-server(at)matronics.com] On Behalf Of Bob Brennan
Sent: Thursday, July 16, 2009 11:53 AM
To: kitfox-list(at)matronics.com
Subject: RE: owner performed maintenance
John,
Sorry but I am missing your point here. Is there anything that I said in my posting that these references or you disagree with? Or is possibly wrong or mis-stated? I appreciate any corrections if they are needed but you'll need to be more specific.
Thanks,
bob
From: owner-kitfox-list-server(at)matronics.com [mailto:owner-kitfox-list-server(at)matronics.com] On Behalf Of John W. Hart
Sent: 16 July 2009 10:25 am
To: kitfox-list(at)matronics.com
Subject: RE: owner performed maintenance
Bob,
Your attention is invited to Title 14: Part 43 -MAINTENANCE, PREVENTIVE MAINTENANCE, REBUILDING, AND ALTERATION, Paragraph 43.1 (d).
URL: http://ecfr.gpoaccess.gov/cgi/t/text/text-idx?c=ecfr&sid=ac58ea778437f87fb6cef7d984262c50&rgn=div8&view=text&node=14:1.0.1.3.21.0.363.1&idno=14
,
It clearly states: ” (b) This part does not apply to any aircraft for which the FAA has issued an experimental certificate, unless the FAA has previously issued a different kind of airworthiness certificate for that aircraft.”
Amateur built Experimental aircraft are issued a “Special airworthiness certificate “ denoting Experimental.
Also, in Title 14: Part 43 -MAINTENANCE, PREVENTIVE MAINTENANCE, REBUILDING, AND ALTERATION, Paragraph 43.1 (d). (Same URL), expounds on Light Sport Category maintenance and alterations.
John Hart
KF IV, NSI Subaru
A&P
From: owner-kitfox-list-server(at)matronics.com [mailto:owner-kitfox-list-server(at)matronics.com] On Behalf Of Bob Brennan
Sent: Thursday, July 16, 2009 7:36 AM
To: kitfox-list(at)matronics.com
Subject: RE: owner performed maintenance
Dick,
If your aircraft has an Airworthiness Certification (not "licensed") as SLSA you have the same restrictions as to what you can do on it as any factory built STC (Standard Type Certificate) aircraft such as a Piper or Cessna. However an SLSA aircraft owner has the unique ability to do a 1-time change to ELSA certification (can never change it back to SLSA). The SLSA/now ELSA aircraft is still bound by STC approvals and restrictions regarding parts and modifications, but the owner now can do the work and inspections him/herself.
An ELSA aircraft has few restrictions as to parts and modifications although it is always wise to stick to the kit manufacturer's recommendations and airworthiness notifications, which for any Experimental aircraft are not mandatory like they are with STC aircraft.
I think the confusion comes in when people here offer opinion off the top of their heads. Sorry to be such a stickler for facts but here is the link to the FAA site regarding Airworthiness Certification and all the implications, which I hope I am summarising in a more readable form in this thread(?)
http://www.faa.gov/aircraft/air_cert/airworthiness_certification/
Bob Brennan - N717GB
ELSA Repairman, inspection rated
1991 UK Model 2 ELSA Kitfox taildragger
Rotax 582 with 3 blade GSC prop
Wrightsville Pa
From: owner-kitfox-list-server(at)matronics.com [mailto:owner-kitfox-list-server(at)matronics.com] On Behalf Of Catz631(at)aol.com
Sent: 16 July 2009 8:04 am
To: kitfox-list(at)matronics.com
Subject: Re: owner performed maintenance
Paul,
We are talking apples and oranges here. My Kitfox,as an example, is licensed as an amateur built experimental aircraft. As such I can do all the maintenance on the aircraft (with some exceptions). I am not hampered by a list of preventative maintenance items IF I was the original builder I could also do the annual condition inspection. However I am not the builder so I have to have an A&P do that. As stated previously this has been this way for a long time and is one of the benefits of owning an experimental aircraft.
Now IF my aircraft was licensed as an ELSA (or SLSA) that is a different story. I believe that is what you are referring to. This whole thing is a very confusing issue as illustrated in the many forums held at Lakeland and Sebring on that very subject.
Dick Maddux
Fox 4
Milton,Fl
Can love help you live longer? Find out now.
| Quote: | | href="http://www.matronics.com/Navigator?Kitfox-List">http://www.matronhref="http://forums.matronics.com">http://forums.matronics.comhref="http://www.matronics.com/contribution">http://www.matronics.com/c http://www.matronics.com/Navigator?Kitfox-Listhttp://forums.matronics.comhttp://www.matronics.com/contribution |
0123456789 | Quote: | | href="http://www.matronics.com/Navigator?Kitfox-List">http://www.matronhref="http://forums.matronics.com">http://forums.matronics.com |
0 | Quote: | | href="http://www.matronics.com/Navigator?Kitfox-List">http://www.matronhref="http://forums.matronics.com">http://forums.matronics.com |
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matronics(at)bob.brennan.
Guest
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| Posted: Thu Jul 16, 2009 9:45 am Post subject: owner performed maintenance |
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John,
I was simply correcting Dick Maddux's previous statement "Now IF my aircraft was licensed as an ELSA (or SLSA) that is a different story." by clarifying that an ELSA or SLSA Airworthiness certification is not a "license". A manufacturer can get a license to build SLSA aircraft that can then be issued SLSA Certificates, but the aircraft is never "licensed". Just trying to cut down on the confusion here and keep the facts straight mate, and to point out that maintenance and inspection privileges for an owner of an ELSA aircraft and an owner of an SLSA aircraft have very little in common, in case someone thinks they are the same thing. I also wanted to point out the little-known fact that an owner of an SLSA aircraft has the option to convert it to ELSA, which is important for some listers considering buying kits or factory pre-builts.
bob
From: owner-kitfox-list-server(at)matronics.com [mailto:owner-kitfox-list-server(at)matronics.com] On Behalf Of John W. Hart
Sent: 16 July 2009 1:24 pm
To: kitfox-list(at)matronics.com
Subject: RE: owner performed maintenance
Bob,
The first sentence in your previous posting, “
If your aircraft has an Airworthiness Certification (not "licensed") as SLSA you have the same restrictions as to what you can do on it as any factory built STC (Standard Type Certificate) aircraft such as a Piper or Cessna.”, prompted my response. Experimental Amateur Built aircraft are not issued a “standard airworthiness certificate” or “licensed” as SLSA, therefore the provisions of FAR 43.1 (b) applies, rather than the part of your statement, “have the same restrictions as to what you can do on it as any factory built STC (Standard Type Certificate) aircraft such as a Piper or Cessna” .
John Hart
From: owner-kitfox-list-server(at)matronics.com [mailto:owner-kitfox-list-server(at)matronics.com] On Behalf Of Bob Brennan
Sent: Thursday, July 16, 2009 11:53 AM
To: kitfox-list(at)matronics.com
Subject: RE: owner performed maintenance
John,
Sorry but I am missing your point here. Is there anything that I said in my posting that these references or you disagree with? Or is possibly wrong or mis-stated? I appreciate any corrections if they are needed but you'll need to be more specific.
Thanks,
bob
From: owner-kitfox-list-server(at)matronics.com [mailto:owner-kitfox-list-server(at)matronics.com] On Behalf Of John W. Hart
Sent: 16 July 2009 10:25 am
To: kitfox-list(at)matronics.com
Subject: RE: owner performed maintenance
Bob,
Your attention is invited to Title 14: Part 43 -MAINTENANCE, PREVENTIVE MAINTENANCE, REBUILDING, AND ALTERATION, Paragraph 43.1 (d).
URL: http://ecfr.gpoaccess.gov/cgi/t/text/text-idx?c=ecfr&sid=ac58ea778437f87fb6cef7d984262c50&rgn=div8&view=text&node=14:1.0.1.3.21.0.363.1&idno=14
,
It clearly states: ” (b) This part does not apply to any aircraft for which the FAA has issued an experimental certificate, unless the FAA has previously issued a different kind of airworthiness certificate for that aircraft.”
Amateur built Experimental aircraft are issued a “Special airworthiness certificate “ denoting Experimental.
Also, in Title 14: Part 43 -MAINTENANCE, PREVENTIVE MAINTENANCE, REBUILDING, AND ALTERATION, Paragraph 43.1 (d). (Same URL), expounds on Light Sport Category maintenance and alterations.
John Hart
KF IV, NSI Subaru
A&P
From: owner-kitfox-list-server(at)matronics.com [mailto:owner-kitfox-list-server(at)matronics.com] On Behalf Of Bob Brennan
Sent: Thursday, July 16, 2009 7:36 AM
To: kitfox-list(at)matronics.com
Subject: RE: owner performed maintenance
Dick,
If your aircraft has an Airworthiness Certification (not "licensed") as SLSA you have the same restrictions as to what you can do on it as any factory built STC (Standard Type Certificate) aircraft such as a Piper or Cessna. However an SLSA aircraft owner has the unique ability to do a 1-time change to ELSA certification (can never change it back to SLSA). The SLSA/now ELSA aircraft is still bound by STC approvals and restrictions regarding parts and modifications, but the owner now can do the work and inspections him/herself.
An ELSA aircraft has few restrictions as to parts and modifications although it is always wise to stick to the kit manufacturer's recommendations and airworthiness notifications, which for any Experimental aircraft are not mandatory like they are with STC aircraft.
I think the confusion comes in when people here offer opinion off the top of their heads. Sorry to be such a stickler for facts but here is the link to the FAA site regarding Airworthiness Certification and all the implications, which I hope I am summarising in a more readable form in this thread(?)
http://www.faa.gov/aircraft/air_cert/airworthiness_certification/
Bob Brennan - N717GB
ELSA Repairman, inspection rated
1991 UK Model 2 ELSA Kitfox taildragger
Rotax 582 with 3 blade GSC prop
Wrightsville Pa
From: owner-kitfox-list-server(at)matronics.com [mailto:owner-kitfox-list-server(at)matronics.com] On Behalf Of Catz631(at)aol.com
Sent: 16 July 2009 8:04 am
To: kitfox-list(at)matronics.com
Subject: Re: owner performed maintenance
Paul,
We are talking apples and oranges here. My Kitfox,as an example, is licensed as an amateur built experimental aircraft. As such I can do all the maintenance on the aircraft (with some exceptions). I am not hampered by a list of preventative maintenance items IF I was the original builder I could also do the annual condition inspection. However I am not the builder so I have to have an A&P do that. As stated previously this has been this way for a long time and is one of the benefits of owning an experimental aircraft.
Now IF my aircraft was licensed as an ELSA (or SLSA) that is a different story. I believe that is what you are referring to. This whole thing is a very confusing issue as illustrated in the many forums held at Lakeland and Sebring on that very subject.
Dick Maddux
Fox 4
Milton,Fl
Can love help you live longer? Find out now.
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akflyer
Joined: 07 May 2007
Posts: 574
Location: Soldotna AK
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| Posted: Thu Jul 16, 2009 10:23 am Post subject: Re: owner performed maintenance |
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sooo, some guy posts an article (we all know that ALL publications including the local newspapers) never get ANYTHING wrong, so therefore it is the gospel. I could care less what some other guys puts in an article, the only thing that matters is the FARs, and they must be read in its entirety,you cant quit at the first paragraph for 99% of the time. There is usually some sort of an exception at the end.. something like, unless or except if blah blah blah.
Just some more snake oil to chew on... I feel yet another award waiting in the wings to be handed out on this issue LOL
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_________________
DO NOT ARCHIVE
Leonard Perry aka SNAKE
Soldotna AK
Avid "C" / Mk IV
582 (147 hrs and counting on the rebuild)
IVO IFA
Full Lotus 1450
#1 snake oil salesman since 1-22-2009
I would rather die trying to live, than to live trying not to die.... |
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helili(at)chahtatushka.ne
Guest
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| Posted: Thu Jul 16, 2009 10:27 am Post subject: owner performed maintenance |
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No disagreement in your below statement. I took your previous post to include Experimental Amateur Built, so I wanted to point out that Experimental Amateur built is a âwhole ânother ball gameâ. Even so, an owner of an Experimental  Amateur Built cannot do an annual condition inspection unless he/she meets at least one of the following qualifications:
<![if !supportLists]>1. <![endif]>Built the aircraft and is issued a Repairman Certificate for that aircraft by make, model, and serial number.
<![if !supportLists]>2. <![endif]>Holds an A&P Certificate.
<![if !supportLists]>3. <![endif]>Owns/operates a Repair station with appropriate endorsements.
As far as I know, those are the only ways an owner may legally complete an annual condition inspection on an Experimental Amateur built aircraft. There are no courses such as provided for in the Light Sport Category that will allow otherwise.
As I read and understand FAR Part 43, there are no restrictions on working on, or modifying an Experimental Amateur Built aircraft, other than the catch all stipulation in the Operating Limitations issued to every Experimental Amateur Built aircraft:
âAfter incorporating a major change as described in § 21.93, the aircraft owner is required to reestablish compliance with § 91.319(b) and notify the geographically responsible FSDO of the location of the proposed test area. The aircraft owner must obtain concurrence from the FSDO as to the suitability of the proposed test area. If the major change includes installing a different type of engine (reciprocating to turbine) or a change of a fixed-pitch from or to a controllable propeller, the aircraft owner must fill out a revised Form 8130â6 to update the aircraftâs file in the FAA Aircraft Registry. All operations must be conducted under day VFR conditions in a sparsely populated area.â
John Hart
KF IV
NSI Subaru
Wilburton, OK
From: owner-kitfox-list-server(at)matronics.com [mailto:owner-kitfox-list-server(at)matronics.com] On Behalf Of Bob Brennan
Sent: Thursday, July 16, 2009 12:41 PM
To: kitfox-list(at)matronics.com
Subject: RE: owner performed maintenance
John,
I was simply correcting Dick Maddux's previous statement "Now IF my aircraft was licensed as an ELSA (or SLSA) that is a different story." by clarifying that an ELSA or SLSA Airworthiness certification is not a "license". A manufacturer can get a license to build SLSA aircraft that can then be issued SLSA Certificates, but the aircraft is never "licensed". Just trying to cut down on the confusion here and keep the facts straight mate, and to point out that maintenance and inspection privileges for an owner of an ELSA aircraft and an owner of an SLSA aircraft have very little in common, in case someone thinks they are the same thing. I also wanted to point out the little-known fact that an owner of an SLSA aircraft has the option to convert it to ELSA, which is important for some listers considering buying kits or factory pre-builts.
bob
From: owner-kitfox-list-server(at)matronics.com [mailto:owner-kitfox-list-server(at)matronics.com] On Behalf Of John W. Hart
Sent: 16 July 2009 1:24 pm
To: kitfox-list(at)matronics.com
Subject: RE: owner performed maintenance
Bob,
The first sentence in your previous posting, â
If your aircraft has an Airworthiness Certification (not "licensed") as SLSA you have the same restrictions as to what you can do on it as any factory built STC (Standard Type Certificate) aircraft such as a Piper or Cessna.â, prompted my response. Experimental Amateur Built aircraft are not issued a âstandard airworthiness certificateâ or âlicensedâ as SLSA, therefore the provisions of FAR 43.1 (b) applies, rather than the part of your statement, âhave the same restrictions as to what you can do on it as any factory built STC (Standard Type Certificate) aircraft such as a Piper or Cessnaâ .
John Hart
[quote][b]
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akflyer
Joined: 07 May 2007
Posts: 574
Location: Soldotna AK
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| Posted: Thu Jul 16, 2009 10:33 am Post subject: Re: owner performed maintenance |
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below is a copy and paste of an INTERNET article that I found after very quick google search.. I will also paste the link to the site.
Maintaining Your Airplane
As I mentioned in the previous section, a condition inspection is required every 12 calendar months on amateur-built aircraft. This check is similar to an annual inspection required by FAR Part 43 on production airplanes. The Phase 2 Operating Limitations specifically refer to FAR Part 43, Appendix D, as the guide to performing this inspection. The inspection can be performed by any licensed A & P mechanic, an FAA Approved Repair Station, or by the builder of the airplane provided the builder obtains a "Repairmanâs Certificate" from the FAA. FAA Advisory Circular 65-23A is available for information concerning application and privileges of this certificate. In short, the primary builder of the airplane is eligible to apply for this certificate which then permits inspection of the airplane and a logbook endorsement of the condition check. It is noteworthy that the primary builder must be one person. If a group of people builds an airplane, only one can be designated as the primary builder. In addition, the issuance of the repairmanâs certificate only applies to the one airplane that has been built by the primary builder and no other airplane regardless of same type, etc..
Normal maintenance on an experimental airplane can be performed virtually by anyone regardless of credentials. Once again, this does not apply to the condition check previously discussed. You can perform maintenance items on the engine whether or not it is "certified". Once a certified engine is placed on an amateur-built aircraft and is operated, it no longer conforms to its type design. This means that the engine can no longer be placed on any aircraft other than an amateur-built until it has been inspected and found to meet its type design. It also must be found to be in a condition for safe operation "airworthy". Once again, common sense should rule. We do not want to overhaul an engine on our airplane unless we are equipped to do so with tools and proper knowledge.
I will point out that FAR Part 43 specifically states that the rules of that part do not apply to amateur-built airplanes. With that in mind, anyone can maintain the airplane. However, remember in our earlier discussion that Part 43, Appendix D was referenced in Phase 2 operating limitations presented to the builder at the time of inspection. It is referenced as a guide to be used in conducting condition inspections. That means Part 43, Appendix D does apply to the condition inspection because of this reference. The FAA has further clarified AD (Airworthiness Directives) as they apply to amateur-built airplanes. Airworthiness Directives cannot apply to any part on an amateur-built airplane unless that specific airplane is cited along with who should do the work and to what standards. The reason for this is because once an approved part is placed on an experimental airplane it is no longer considered an approved part. Again, let me emphasis that just because a regulation does not require an action it still may be prudent and within our best interest to conform to an AD note. We are striving to improve the safety record of this industry and in all cases we must act on the side of common sense and good practice.
http://exp-aircraft.com/library/alexande/rules.html
seems pretty clear to me, and is right in line with the FARs as I have read them and understand them.
I get to take tests every year on CFRs, codes etc to make sure that in my position I can properly read, comprehend and apply the regs codes etc, to keep us in compliance with the law DEC DOT etc. So far I have aced every test, including ones I took last week.
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_________________
DO NOT ARCHIVE
Leonard Perry aka SNAKE
Soldotna AK
Avid "C" / Mk IV
582 (147 hrs and counting on the rebuild)
IVO IFA
Full Lotus 1450
#1 snake oil salesman since 1-22-2009
I would rather die trying to live, than to live trying not to die.... |
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thesupe(at)hotmail.com
Guest
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| Posted: Thu Jul 16, 2009 11:57 am Post subject: owner performed maintenance |
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I'm not going to quote the FARs C but will tell what I have been through with doing work on an experimental airplane. Almost 4 years ago C I swapped out the 532 in my Avid B for a 582. FAA had to do an inspection of the airplane because the plane had a pre 1991 airworthyness certifcate. The FAA inspector was completly aware that I had done all the work myself and not under the supervison of an AnP either. He looked at my log books and had no problem with me doing the work. 2 1/2 years ago C I bought an Avid MK IV that had sat for a number of years without being flown. It hadn't had the complete 40 hrs Phase one time flown off it so because I moved it to a different FSDOs location C another FAA inspection had to be done on the plane. Different inspector came up to my place from the Minneapolis FSFO. I had taken the engine out of the plane and had new seals installed in the engine and then replaced it and this inspector was completly aware of that because I told him so. He had no problem with me doing the work either. A year later C I replaced the 582 engine with a Jabiru engine and informed the FSDO of the engine change as required by my operating limitations. Again not a problem for the Minneapolis FSDO. I really don't think Minnesota"s FSDO has a different set of rules than the rest of the U.S. Take care all C I have to get back to work on the plane! (I'm recovering the MK IV) Jim Chuk Avids C Kitfox 4 Mn
&g=======
Windows Live: Keep your life in sync. Check it out. [quote][b]
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lcfitt(at)sbcglobal.net
Guest
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| Posted: Fri Jul 17, 2009 10:52 am Post subject: owner performed maintenance |
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I guess I am a bit confused here. Is the yearly inspection for an ELSA called an annual condition inspection? Is an ELSA Repairman Certificate the same as an Experimental Repairman Certificate? What is specified in the log book entry after an inspection in both cases.
My take on the maintenance issue, and this has been consistent since I first began my first build in 1993 is that anyone can do maintenance on a homebuilt. The only licensed person specified is for the log book entry after a required inspection. An example" I hold a repairman certificate and am laid up with a broken leg. My neighbor who owns a J3 comes over and using my check list inspects my airplane. I am satisfied with his inspection and sign the log book beginning with the standard text, "I certify that this aircraft has been inspected according to...". Some one tell me where I have violated the FARs.
Or in another situation I am a non builder owner of a Kitfox and do an annual inspection according to the builder's check list. I then have my neighbor who is an A&P make the indorsement in the log book and he writes, "I certify that this aircraft has been inspected according to...". Where have I violated the FARs.
Opinions in responses are great, but I respectfully claim the privelage of ignoring them. If someone can give an authoritative response, either with specific reference to an FAR - unambiguous - or a personal experience with an FAA representative, you just might be able to get me to at least consider other possibiliities.
Lowell
--- On Wed, 7/15/09, Bob Brennan <matronics(at)bob.brennan.name> wrote:
[quote]
From: Bob Brennan <matronics(at)bob.brennan.name>
Subject: FW: Re: owner performed maintenance
To: kitfox-list(at)matronics.com
Date: Wednesday, July 15, 2009, 7:33 PM
--> Kitfox-List message posted by: "Bob Brennan" <matronics(at)bob.brennan.name (matronics(at)bob.brennan.name)>
Jim,
Sorry but it is confusing to the list to say "you can do anything except the
annual Condition Inspection." There are specific things you can do which
have already been listed in this thread. Specifically anything that will
cause the Annual Condition Inspection to fail are things you should not do,
and technically can not do.
As a certified repairman and inspector for my own airplane I am aware of
what I should and should not do to it, and can and cannot do to it, for
instance rebuild the engine without further training. An A&P inspector has
the responsibility to tell kit builders what they can and cannot do, and
should and should not have done to an airplane they did not build.
Better to stick with the list of 31 things you *can* do than announce to the
list that you can do "anything", don't you think?
Bob Brennan - N717GB
ELSA Repairman, inspection rated
1991 UK Model 2 ELSA Kitfox taildragger
Rotax 582 with 3 blade GSC prop
Wrightsville Pa
--
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matronics(at)bob.brennan.
Guest
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| Posted: Fri Jul 17, 2009 11:45 am Post subject: owner performed maintenance |
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Lowell,
I can answer the ELSA questions with authority, the EAB answers are my opinion from my experiences and research into becoming an ELSA Repairman.
> Is the yearly inspection for an ELSA called an annual condition inspection?
Yes
> Is an ELSA Repairman Certificate the same as an Experimental Repairman Certificate?
Yes, with the exceptions that the Rating states "Repairman Light Sport Aircraft" and the Limitation: Inspection section specifies a certificated ELSA aircraft, owned by the certificate holder.
> What is specified in the log book entry after an inspection in both cases
The same wording for both "“I certify that this aircraft has been inspected on [insert date] in accordance with the scope and detail of appendix D to part 43, and was found to be in a condition for safe operation.” "
<start opinion>
In both of your cases below the licensed Repairman is signing the logbook legally and is solely responsible for the truth of the statement he/she is assigning his/her certificate number to. If you trust your neighbor's work and you sign the logbook it is legal. If you have an A&P friend who trusts your work and signs your logbook it is legal. The only thing that is not legal is if the logbook is signed by someone without the proper certification.
On discussing this very thing with my DAR friend the whole thing boils down to the certificated person who puts his/her certificate number in the logbook sincerely believes, by whatever method, that the aircraft "was found to be in a condition for safe operation". If that same airplane falls apart the next day in mid-air due to something that should have been picked up by the simplest inspection then I suspect the Inspector's "ass is grass", and the FAA will not want to hear "but I trusted my neighbor with the J3 Cub". The neighbor will not risk liability, and the inspection was legal.
<end opinion>
Authority for ELSA limitations quoted: www.sportpilot.info/sp/ELSA_Operating_Limitations.doc
Bob Brennan - N717GB
ELSA Repairman, inspection rated
1991 UK Model 2 ELSA Kitfox taildragger
Rotax 582 with 3 blade GSC prop
Wrightsville Pa
From: owner-kitfox-list-server(at)matronics.com [mailto:owner-kitfox-list-server(at)matronics.com] On Behalf Of Lowell FITT
Sent: 17 July 2009 2:47 pm
To: kitfox-list(at)matronics.com
Subject: Re: FW: Re: owner performed maintenance
I guess I am a bit confused here. Is the yearly inspection for an ELSA called an annual condition inspection? Is an ELSA Repairman Certificate the same as an Experimental Repairman Certificate? What is specified in the log book entry after an inspection in both cases.
My take on the maintenance issue, and this has been consistent since I first began my first build in 1993 is that anyone can do maintenance on a homebuilt. The only licensed person specified is for the log book entry after a required inspection. An example" I hold a repairman certificate and am laid up with a broken leg. My neighbor who owns a J3 comes over and using my check list inspects my airplane. I am satisfied with his inspection and sign the log book beginning with the standard text, "I certify that this aircraft has been inspected according to...". Some one tell me where I have violated the FARs.
Or in another situation I am a non builder owner of a Kitfox and do an annual inspection according to the builder's check list. I then have my neighbor who is an A&P make the indorsement in the log book and he writes, "I certify that this aircraft has been inspected according to...". Where have I violated the FARs.
Opinions in responses are great, but I respectfully claim the privelage of ignoring them. If someone can give an authoritative response, either with specific reference to an FAR - unambiguous - or a personal experience with an FAA representative, you just might be able to get me to at least consider other possibiliities.
Lowell
--- On Wed, 7/15/09, Bob Brennan <matronics(at)bob.brennan.name> wrote:
[quote]
From: Bob Brennan <matronics(at)bob.brennan.name>
Subject: FW: Re: owner performed maintenance
To: kitfox-list(at)matronics.com
Date: Wednesday, July 15, 2009, 7:33 PM
--> Kitfox-List message posted by: "Bob Brennan" <matronics(at)bob.brennan.name (matronics(at)bob.brennan.name)>
Jim,
Sorry but it is confusing to the list to say "you can do anything except the
annual Condition Inspection." There are specific things you can do which
have already been listed in this thread. Specifically anything that will
cause the Annual Condition Inspection to fail are things you should not do,
and technically can not do.
As a certified repairman and inspector for my own airplane I am aware of
what I should and should not do to it, and can and cannot do to it, for
instance rebuild the engine without further training. An A&P inspector has
the responsibility to tell kit builders what they can and cannot do, and
should and should not have done to an airplane they did not build.
Better to stick with the list of 31 things you *can* do than announce to the
list that you can do "anything", don't you think?
Bob Brennan - N717GB
ELSA Repairman, inspection rated
1991 UK Model 2 ELSA Kitfox taildragger
Rotax 582 with 3 blade GSC prop
Wrightsville Pa
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lcfitt(at)sbcglobal.net
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| Posted: Fri Jul 17, 2009 6:55 pm Post subject: owner performed maintenance |
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Thanks Bob, I think your understanding pretty much parallels mine. I think the whole thing revolves around a measure of trust and common sense.
The guy across the street has a Mooney. He commutes to the Bay Area in it and also is the holder of an ATP certificate that he acquired for convenience and economics. I wouldn't trust him to do an annual on my Kitfox. Nor for that matter the FBO on the field nor the Stearman expert up the valley. I just have a problem thinking that their training and experience transfers to my Kitfox.
Further, I have friends that do not actually perform a formal inspection. With the continual maintenance and "under the hood" work they do on their airplanes, they feel they have a pretty good feel for the condition of the airplane and sign off the log book as required. I suspect the annual inspection has it's most value with the owner or renter that only knows how to add oil, prime and crank as far as the mechanics of the airplane is concerned. I recall the Citabria I checked out in needing a 20 year overdue BFR. On the pre-flight check list was this step - open the oil filler door, check the oil level and add oil if necessary and check for any loose or frayed wires in the engine compartmene. I had to laugh out loud as the view from the door opening showed the filler neck and a dark void surrounging it. But true to the instructions, I checked. I doubt the owner of any experimental airplane is that ignorant of what is under the hood.
Lowell
--- On Fri, 7/17/09, Bob Brennan <matronics(at)bob.brennan.name> wrote:
[quote]
From: Bob Brennan <matronics(at)bob.brennan.name>
Subject: RE: FW: Re: owner performed maintenance
To: kitfox-list(at)matronics.com
Date: Friday, July 17, 2009, 12:42 PM
Lowell,
I can answer the ELSA questions with authority, the EAB answers are my opinion from my experiences and research into becoming an ELSA Repairman.
> Is the yearly inspection for an ELSA called an annual condition inspection?
Yes
> Is an ELSA Repairman Certificate the same as an Experimental Repairman Certificate?
Yes, with the exceptions that the Rating states "Repairman Light Sport Aircraft" and the Limitation: Inspection section specifies a certificated ELSA aircraft, owned by the certificate holder.
> What is specified in the log book entry after an inspection in both cases
The same wording for both "âI certify that this aircraft has been inspected on [insert date] in accordance with the scope and detail of appendix D to part 43, and was found to be in a condition for safe operation.â "
<start opinion>
In both of your cases below the licensed Repairman is signing the logbook legally and is solely responsible for the truth of the statement he/she is assigning his/her certificate number to. If you trust your neighbor's work and you sign the logbook it is legal. If you have an A&P friend who trusts your work and signs your logbook it is legal. The only thing that is not legal is if the logbook is signed by someone without the proper certification.
On discussing this very thing with my DAR friend the whole thing boils down to the certificated person who puts his/her certificate number in the logbook sincerely believes, by whatever method, that the aircraft "was found to be in a condition for safe operation". If that same airplane falls apart the next day in mid-air due to something that should have been picked up by the simplest inspection then I suspect the Inspector's "ass is grass", and the FAA will not want to hear "but I trusted my neighbor with the J3 Cub". The neighbor will not risk liability, and the inspection was legal.
<end opinion>
Authority for ELSA limitations quoted: www.sportpilot.info/sp/ELSA_Operating_Limitations.doc
Bob Brennan - N717GB
ELSA Repairman, inspection rated
1991 UK Model 2 ELSA Kitfox taildragger
Rotax 582 with 3 blade GSC prop
Wrightsville Pa
From: owner-kitfox-list-server(at)matronics.com [mailto:owner-kitfox-list-server(at)matronics.com] On Behalf Of Lowell FITT
Sent: 17 July 2009 2:47 pm
To: kitfox-list(at)matronics.com
Subject: Re: FW: Re: owner performed maintenance
I guess I am a bit confused here. Is the yearly inspection for an ELSA called an annual condition inspection? Is an ELSA Repairman Certificate the same as an Experimental Repairman Certificate? What is specified in the log book entry after an inspection in both cases.
My take on the maintenance issue, and this has been consistent since I first began my first build in 1993 is that anyone can do maintenance on a homebuilt. The only licensed person specified is for the log book entry after a required inspection. An example" I hold a repairman certificate and am laid up with a broken leg. My neighbor who owns a J3 comes over and using my check list inspects my airplane. I am satisfied with his inspection and sign the log book beginning with the standard text, "I certify that this aircraft has been inspected according to...". Some one tell me where I have violated the FARs.
Or in another situation I am a non builder owner of a Kitfox and do an annual inspection according to the builder's check list. I then have my neighbor who is an A&P make the indorsement in the log book and he writes, "I certify that this aircraft has been inspected according to...". Where have I violated the FARs.
Opinions in responses are great, but I respectfully claim the privelage of ignoring them. If someone can give an authoritative response, either with specific reference to an FAR - unambiguous - or a personal experience with an FAA representative, you just might be able to get me to at least consider other possibiliities.
Lowell
--- On Wed, 7/15/09, Bob Brennan <matronics(at)bob.brennan.name> wrote:
[quote]
From: Bob Brennan <matronics(at)bob.brennan.name>
Subject: FW: Re: owner performed maintenance
To: kitfox-list(at)matronics.com
Date: Wednesday, July 15, 2009, 7:33 PM
--> Kitfox-List message posted by: "Bob Brennan" <matronics(at)bob.brennan.name>
Jim,
Sorry but it is confusing to the list to say "you can do anything except the
annual Condition Inspection." There are specific things you can do which
have already been listed in this thread. Specifically anything that will
cause the Annual Condition Inspection to fail are things you should not do,
and technically can not do.
As a certified repairman and inspector for my own airplane I am aware of
what I should and should not do to it, and can and cannot do to it, for
instance rebuild the engine without further training. An A&P inspector has
the responsibility to tell kit builders what they can and cannot do, and
should and should not have done to an airplane they did not build.
Better to stick with the list of 31 things you *can* do than announce to the
list that you can do "anything", don't you think?
Bob Brennan - N717GB
ELSA Repairman, inspection rated
1991 UK Model 2 ELSA Kitfox taildragger
Rotax 582 with 3 blade GSC prop
Wrightsville Pa
--
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