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mark.bitterlich(at)navy.m
Guest

Posted: Wed May 19, 2010 3:55 pm Post subject: Experimental Class

A question for the legal Eagles out there.  I have been told that if an

Experimental Aircraft has a "Certified" engine type, then that engine is

required to undergo all requirements that it normally would have were it

to be installed in a fully certified aircraft. 



Ok... Then that brings up the question: 



1.  Is this true? 

2.  If it is, then what makes an engine itself "Experimental" ?? 



I really do not quite understand this aspect.... 



Mark Bitterlich 



--

Dale

Joined: 30 May 2007
Posts: 178

Posted: Wed May 19, 2010 5:14 pm Post subject: Re: Experimental Class

Depends on the Experimental category the aircraft is licensed in.

Once a engine is installed in a experimental amateur built it would need

to be re-inspected and certified by a approved shop/person/mfg to be re-installed in a certified aircraft so that in itself tells you it does not need to be maintained in a approved manner. Put a certified engine in a homebuilt and you now have a experimental engine.  If not so the re-inspection would not be needed.  There are several categories of experimental aircraft some do not require approved as in amateur built and some do as in testing and certification category's.  The phase 2 can be written in such a way to indicate that requirement also.  Depends on who writes it. Lots of 10-1 pistons installed in engines that are not approved used in lots of experimental aircraft with once certified engines.  Ad's are not issued "normally" on a homebuilt either.

And the AC43 is the only inspection guide required.  The annual inspection in not a airworthy endorsement. Only a scope and detail inspection.

cjpilot710(at)aol.com
Guest

Posted: Thu May 20, 2010 9:23 am Post subject: Experimental Class

Good questions Mark.

    

   My speculations would be:

   1. If the engine installed has no modifications what so ever done, than its treated like a certified engine.  

                      That would mean a annual inspection by an IA and maintenance plus inspections per the manufacture.

   2. Any engine that has never been certified OR a certified engine that has had a modification done, would be considered "Experimental".

    

   However a call to either the EAA or FSDO guys would more likely give you a better answer than mine.

    

   I know I put a Lyc 360 with no mods in my Pitts S1C, I built.  The FAA never said one word about the engine.  The whole airplane was "Experimental" as far as they were concern.  As we all know "interpretation" is not an FAA norm.

    

   Jim "Pappy" Goolsby

    

   

 

  

   

 

 

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mark.bitterlich(at)navy.m
Guest

Posted: Thu May 20, 2010 5:08 pm Post subject: Experimental Class

Ok.... So is the Lycoming GSO-480 engine in my Yugoslavian UTVA-66

CERTIFIED, or experimental?  Do I need an IA to do the inspection on it,

or just an A&P?  If it is in an experimental airplane, do I have to

comply with AD's issued for certified aircraft?  What about the prop?

Phew!  



Mark

 



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mark.bitterlich(at)navy.m
Guest

Posted: Thu May 20, 2010 5:11 pm Post subject: Experimental Class

Pappy, thanks for taking the time to write back.  I am very interested in your perspective.  I know this is off topic and I apologize to all, but I know the people on this list that I trust and respect, so I come here when I need an expert in an area that I know NOTHING about, and this is one of them.  



My UTVA-66 has a GSO-480 Lycoming.  However, as you mentioned with your Pitts, the aircraft itself is Experimental.  Experimental Exhibition of course.  The FAA has not said a word to me either, but I have to wonder!  



My experience with the FSDO folks is that in many cases it is easier to just say "no" than it is to go out on a limb and give a blessing on something they are not sure of.  In fact, my experience has been that you better know more than they do when you ask them to do ANYTHING.  But, I know that is unfair and many FSDO's have wonderful folks.  Let me just pause here and say that the FAA came up running to me today... At the Cherry Point Airshow, when I took the door off the UTVA-66 for the Combat Camera guys so they could get good video.  Oh my GOSH!  FIVE OF THEM came up.  Talk about being ganged up on!  But in reality they were really quite nice... Although they nailed me for my pilots license not being signed (OMG!) and also.... And they got me dead cold to rights on this one... I did not have the Pilots Operating Manual in the aircraft.  Darn it.  I promised I would have it in there tomorrow and they said they would come back and check it.  Just for grins, I am going to br

 ing them the UNTRANSLATED version written in Yugoslavian.  Ought to be fun.  



In any case, a lot of the CJ-6 guys are here too.  -1, -2, -3 and -4 !!!  I think they want to gang up on my 50!  Anyway, hope to be able to have the dogfight so many want to see the result of!   



Anyway... Pappy, I still really am confused about this.  



Mark

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cjpilot710(at)aol.com
Guest

Posted: Fri May 21, 2010 7:30 pm Post subject: Experimental Class

Mark,

    

   One of the things I've noted (and you may have too) is that interpretations of FARs differ from FSDO to FSDO.  Case in point I once sent a copy to another new CJ-6 owner of my operating letter that was approved by the Orlando FSDO.  His FSDO read mine, than told him that IF I ever came into their jurisdiction, they would personally ground my airplane!!!!

    

   I called my FSDO and the handler of my CJ.  He told me not to worry, that that FSDO really had NO juridiction over me, as far as operating letters.

 We also run into this with flying the B24 from time to time.  Again the Orlando FSDO handles our operation.  Just last week in BUR we were ramped checked by no less than 5 feds.  We spent more time BSing about the airplanes, than them digging into every piece of paper we had.

    

   Most of the time these guys don't really know what they are looking at.  Sometimes its better to apologies for something than try to get straighten it out before it happens.  They may not really want the work load.

    

   One way to cover yourself is that in your operating letter, you could put that the engine will be maintained according to a manufactures manuals -such and such.  That way even if the engine is questioned, you can "assure" the FAA guy, that you do have a plan, that has already been approved.  

    

   I didn't know the POM was required to be in the airplane at all times.  The operating letter, yes but not the manual.  I wonder if that's is a FSDO inconsistency.

    

   Careful on the translation manual trick, they may ask you if you can speak the lingo    Wooops.

    

   "Confusion, thy name is FAA"

    

   I'll try to call my FSDO guy with a question or two if you like.  But again it may be his own FSDO interpretation.

    

   Pappy

 

   

 

 

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mark.bitterlich(at)navy.m
Guest

Posted: Sun May 23, 2010 6:20 am Post subject: Experimental Class

Please feel free (and requested) to ask your FSDO anything for me or

anyone else!  



The plot thickens from an event that happened while at the Cherry Point

Air show, which I am presently attending with both aircraft.  I was run

to ground, ALSO by no less than 5 FAA Reps, when I made the comment that

we could operate with the door off for a Camera operator wanting to take

HD pictures of the show as a "Media Ride" ... This morphed into a full

blown ramp check... Which is another story ... One that will bring tears

of laughter and also anger to to many... But I will save that for

another time.  



In the course of the conversation, this particular FAA Safety Rep

EMPHATICALLY stated that since the engine that was in my experimental

aircraft was a certified engine, all AD's HAD to be complied with.  No

option.  Period.  This was of course his opinion, but he said he had

FARS to support it.  He was very VERY emphatic about this... 



They all chastised me because there was nothing in the POH that stated I

could operate with the door off.  I then pointed out there was nothing

in the POH about pulling Gliders either, but there was plenty of detail

about how to maintain the system in the MAINTENANCE MANUAL!  There was

also nothing in the POH about raising the rear hatch and putting in

stretchers, but there was plenty in the MAINT. MANUAL about how to

maintain that system as well.  And then today, I showed them a picture

of 3 military operative jumping out of an active duty Yugoslavian

UTVA-66 with.. The door off.  



This FAA FSDO is clearly trying to apply FAR's that apply to U.S. built

aircraft to mine.  They actually started quoting from the regs about

aircraft built before this year and after that year, and what the

companies had to comply with, etc.  I just shook my head and said: "Do

you understand that Yugoslavia does not care what your laws were, then

or now?  That is why this aircraft is EXPERIMENTAL?  



Anyway, I kept it cool and just said: "SURE OK YES ANYTHING YOU WANT".  



But you sure are right about the different FSDO's.  The best advice in

the world is to never go to the FAA with a question.  Know the answers

to all questions beforehand and have references to what makes you right

at hand!  



Mark

 



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bwade154(at)yahoo.com
Guest

Posted: Sun May 23, 2010 8:00 pm Post subject: Experimental Class

Mark when we did an IAR 823 the FAA examiner stated that if the engine had a data plate it was a certified engine if it didn't it was experimental, I left  the plate intact and did (do) the AD's Lycoming IO-540. 

 Bill Wade

   From: "Bitterlich, Mark G CIV Det Cherry Point, MALS-14 64E" <mark.bitterlich(at)navy.mil>

To: yak-list(at)matronics.com

Sent: Sun, May 23, 2010 10:15:58 AM

Subject: RE: Experimental Class

--> Yak-List message posted by: "Bitterlich, Mark G CIV Det Cherry Point, MALS-14 64E" <mark.bitterlich(at)navy.mil (mark.bitterlich(at)navy.mil)>

Please feel free (and requested) to ask your FSDO anything for me or

anyone else!  

The plot thickens from an event that happened while at the Cherry Point

Air show, which I am presently attending with both aircraft.  I was run

to ground, ALSO by no less than 5 FAA Reps, when I made the comment that

we could  operate with the door off for a Camera operator wanting to take

HD pictures of the show as a "Media Ride" ... This morphed into a full

blown ramp check... Which is another story ... One that will bring tears

of laughter and also anger to to many... But I will save that for

another time.  

In the course of the conversation, this particular FAA Safety Rep

EMPHATICALLY stated that since the engine that was in my experimental

aircraft was a certified engine, all AD's HAD to be complied with.  No

option.  Period.  This was of course his opinion, but he said he had

FARS to support it.  He was very VERY emphatic about this... 

They all chastised me because there was nothing in the POH that stated I

could operate with the door off.  I then pointed out there was nothing

in the POH about pulling Gliders either, but there was plenty of detail

about how to maintain the system in the  MAINTENANCE MANUAL!  There was

also nothing in the POH about raising the rear hatch and putting in

stretchers, but there was plenty in the MAINT. MANUAL about how to

maintain that system as well.  And then today, I showed them a picture

of 3 military operative jumping out of an active duty Yugoslavian

UTVA-66 with.. The door off.  

This FAA FSDO is clearly trying to apply FAR's that apply to U.S. built

aircraft to mine.  They actually started quoting from the regs about

aircraft built before this year and after that year, and what the

companies had to comply with, etc.  I just shook my head and said: "Do

you understand that Yugoslavia does not care what your laws were, then

or now?  That is why this aircraft is EXPERIMENTAL?  

Anyway, I kept it cool and just said: "SURE OK YES ANYTHING YOU WANT".  

But you sure are right about the different FSDO's.  The best  advice in

the world is to never go to the FAA with a question.  Know the answers

to all questions beforehand and have references to what makes you right

at hand!  

Mark

--

William Halverson

Joined: 27 Feb 2010
Posts: 88

Posted: Mon May 24, 2010 5:54 am Post subject: Experimental Class

Soo  .... all this thread is about whether or not someone with a Lycoming IO-540 mounted on an Experimental a/c has to comply with the engine ADs?



I think I see the FAA's point now ...  how does the type of a/c change the need to fix whatever the engine AD addressed?



Or is the issue bigger than that?  Is the issue that the AD process does not apply to experimental a/c?



William Halverson



+--

dsavarese0812(at)bellsout
Guest

Posted: Mon May 24, 2010 6:53 am Post subject: Experimental Class

Maybe the question should be to the owner - Why would you  not want to comply with the AD regardless of the fact the engine  is installed in an Experimental aircraft?

  

 AD's are safety issues and are mandatory.  This link may  help clarify the question - http://home.provide.net/~pratt1/ambuilt/ad.htm

  

 Dennis

 [quote]   ---

mark.bitterlich(at)navy.m
Guest

Posted: Mon May 24, 2010 7:10 am Post subject: Experimental Class

Interestingly enough, this FSDO agent (John) ... All on his own ...

Started talking about exactly that.  His exact words:  "Some people have

actually removed their data plates thinking that doing so will make the

engine 'experimental' and thus not have to comply with AD's.  This is

anything but true.  I have FAR's that specifically state ... " and so on

and so on.  I just nodded my head and tried not to argue.  



In talking with another pilot at the air show, he stated that at Reno,

the "remove the data plate thing" is done ALL the time and nearly every

engine out there is minus the data plate, and the FAA inspectors at that

event understand this perfectly and the reasons why.  



For the record, I believe complying with engine AD's is a smart move.

99.99% of the time.  That still leaves that 0.01% open though.  My only

reason for even discussing this is simply to accomplish a couple of

things. 



1. Learn from others more expert than myself, and I have already learned

a ton... Thanks to all, both on this list and off. 

2. Make others aware of what Pappy said, which was dead on the money....

That each FSDO seems to go about interpreting rules different ways, and

to be prepared for that.  

3. That I personally think the Greensboro FSDO is attempting to do #2

above right now regarding the engine issue.  



One more question.  



I have a list of Operating Limitations a yard long telling me

specifically what I can NOT do.  None of them address operating with the

door off.  The FAA says I can not do that because it is not mentioned in

the pilots operating handbook.  Well, excuse me, this is a military

light attack aircraft built in Yugoslavia.  It also has a factory

installed glider tow hook.. .and not one mention of how to go about

pulling gliders in the POH.  The FAA says they have a specific list of

aircraft that can operate with the door removed.  Of course this list is

of CERTIFICATED AIRCRAFT.  But they say this does not matter, and it

must be in my POH.  Just FYI, the door on the UTVA-66 (either one)

weighs about 10 pounds, is not structural in any way, has Plexiglas

sliding windows that are allowed to be open in flight at any speed.  I

have pictures of Yugoslavian military jumping out of the darn thing with

the doors off, as well as Yugoslavian parachute clubs making hundreds of

jumps out of it.  



Regardless, what seems very clear to me is that the FAA here is trying

apply rules made in this country and applied to certificated aircraft,

to an aircraft made in another country, that knew nothing about these

rules, did not care about them anyway, and is fact is now bombed out of

existence, so it is kind of hard to go back and talk to them and get a

note saying: "Yeah, of course it can fly with the door off, that's why

we put that big strong re-enforcement metal around the outside of the

whole door frame (which yes... It does have). 



My plan is to flood the FAA in Greensboro with very polite paperwork

requesting a whole slew of operating limitations be removed and "operate

with the door off" status approved in writing.  I want to be able to

pull gliders and I want to be able to drop sky-divers, and no...  I do

not intend to do it for hire.  



Anyway, I am really re-thinking flying Media Rides at air shows.  



Mark Bitterlich

 



--

mark.bitterlich(at)navy.m
Guest

Posted: Mon May 24, 2010 7:37 am Post subject: Experimental Class

Actually a GSO-480.  But in a sense you have it correct.  



You're also correct that I would like to know whether the AD process DOES apply to experimental aircraft AND WHAT MAKES AN ACTUAL ENGINE experimental?  



Let's say I want to build an Experimental Engine.  I take a Continental 550, put in a specially prepared crankshaft, use 520 cylinders, higher compression pistons, a roller cam and roller rockers, and use a custom built fuel injection unit.  The only thing really original with the engine is the case.  



Out comes an AD on the 550 that says I must break the case apart and do an inspection on the crank.  Well, I don't USE the stock crank and the AD does not apply to me.  Yet, the FAA is saying that because this engine started life as a certified 550 engine, I *MUST*  comply with this AD even if the engine is modified like I said, installed in a real honest to goodness Experimental A/C, and even if I remove the data plate, I must split the case and sent my custom crank off to have it looked at.  



As I said, 99.99% of the time, actually complying with the AD makes sense and it is smart to comply with it and not argue about it.  However, personally I am very leery of giving up personal freedoms just because some bozo has words come out of his mouth while wearing a "I AM IN CHARGE" badge.  Abuse of authority is a subject I am very familiar with, and I believe the FAA is very capable of doing just that, and has been proven to do so ad nauseam.  



So, in the end, it is not whether the FAA has a point or not, but what is legal and what is not, and how does the written law apply.  Not arguing with you in any sense, just trying to explain where I am coming from and why I am asking. 



Mark

 



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mark.bitterlich(at)navy.m
Guest

Posted: Mon May 24, 2010 7:39 am Post subject: Experimental Class

Answer:  When the engine has been modified in such a way that the AD

does not apply.  Not saying that this makes my personal view right... In

fact I defer to your greater knowledge (times 100).  



Mark

 



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dsavarese0812(at)bellsout
Guest

Posted: Mon May 24, 2010 7:51 am Post subject: Experimental Class

Sounds correct to me.

 Dennis

 [quote]   ---

viperdoc(at)mindspring.co
Guest

Posted: Mon May 24, 2010 11:44 am Post subject: Experimental Class

Smart move...rethinking flying media rides. As for stirring the FSDO

pot...remember they get paid to make you unhappy.

doc



--

AV8ORJWC

Joined: 13 Jul 2006
Posts: 1149
Location: Aurora, Oregon "Home of VANS"

Posted: Mon May 24, 2010 11:47 am Post subject: Experimental Class

Mark, let me put a log on the slow burning fire.  Just to keep the

audience warm.



As an A&P with I/A, a career airline mechanic who works on prop driven

beasts by night and as a spare time EAA Tech Advisory, here are a few

tenets that I have operated with.



1.  Mechanics, Owners and yes FAA Inspectors are human and make mistakes

(Occasionally).

2.  Certificated Aircraft / Certificated Engines and Certificated Props

or Appliances are called that because they were manufactured and

required to be maintained by the manufacturer to a TCDS -Type

Certificate Data Sheet. Non compliance knocks them out of that category

until brought back into compliance.  Often that takes more money that

timely compliance would have in the first place. 

3. Not all "once certificated" aircraft engines remain certificated

throughout their life, but might morph into Experimental engines quite

quickly.  Data plates are not necessarily the determinate.

4. Experimental Aircraft ownership allows those owners/operators to

change "at will" powerplants/props/accessories that do not alter the

power output more than 10%.  Airframe mods are somewhat similar but

separately phrased.

5. Engines which alter the aircraft's output more than 10% require

additional "proof of concept" testing after introduction.

6.  ADs are a mandatory requirement on Certificated Aircraft and/or

certificated engines while attached to those aircraft.  An Experimental

Aircraft can continue to operate after the certificated engine becomes

Non-compliant - it reverts to an Experimental engine while Non-Compliant

until "Brought Back".  You don't ever have to bring it back!

7.  SB - Service Bulletins and SLs - Service Letters are advisory in

nature.  Not a bad idea to acknowledge their existence.

8.  Insurance Underwriters like to make non-compliance a "Voidable

cancellation clause" in some aircraft policies.

9. By their classification, Experimental Aircraft are not required to

comply with ADs.

10.  Asking yourself why not comply to directives is a good thing to do

frequently.

11.  Anyone can do maintenance on any Experimental aircraft.

Competency/proper tools and clear concise instructions are not required

(it is really True!).  Only the Conditional Inspection might require

someone of certificated status (Repairman/Mechanic) to make a statement

on its condition to be insurable and compliant at that one unique moment

in time. From that point the responsibility is on the Operator who

places it into flight. I personally shudder at some of the work that I

see on inspections.  then I remember.... It's just Experimental in

category.

12.  It is the owner/operator/builder/manufacturer's responsibility to

provide necessary documents on the respective components and their

proper maintenance to every individual who must then document all work

performed on the aircraft.  Most experimental aircraft have almost

nothing to reference.



Now back to the real world.  There was a brief glimpse of sanity back in

1987 when Allan McArtor was the FAA Administrator under then President

Reagan.  He was a former Thunderbird and had as a personal mission a

desire to level the playing field with errant, pompous Inspectors.  He

wanted a focus back to promoting General Aviation with less on

enforcement and heavy handed interpretations.  I think they were too

much like Dirty Harry at the time.  He made available his personal

direct phone number in DC. Mr. McArtor projected the authoritive opinion

that all FSDOs and their employees worked for the General Public - you.

Somewhere along the route of the previous 30 years, that tenet got lost.

Today Randy Babbitt is the closest thing to bringing the FAA back to

meeting the needs of the general public.  I believe he is more

approachable than Marion Blakely and receptive to assisting our

interests. Congress is beginning to listen.



His advise (McArtor's), document the wrong you have been served "In

Writing", deliver it to your Congressman or US Senator and begin a

process called "Congressionalizing a federal employee". Better yet, just

call him - The FAA Administrator. The process was/is slow, the results

were surprising to all including the errant Inspectors who got thrown

under the bus.  Everyone should be singing to the same sheet of music.

I have seen the impact on such a local inspector who lost his way with a

friend.  The inspector moved to Germany, the friend to Iowa.  I

personally have picked up the phone and watched the system work here in

the Northwest Mountain Region on two occasions.  There is little reason

it cannot work across the entire country.



Experimental Aircraft is a remarkable category. Nowhere does it say you

need a certificated engine or propeller.  I will await official word

that my tenet #9 is incorrect.  A logbook entry of the transition from

Certificated engine, modified and now Experimental on this date with

these operational hours should be enough.



Fly Safe, Fly Often, Fly compliant



John Cox



--

mark.bitterlich(at)navy.m
Guest

Posted: Mon May 24, 2010 12:04 pm Post subject: Experimental Class

That's why I am planning on hiring someone else to do it.  



Film at 11. 



Mark

 



--

dsavarese0812(at)bellsout
Guest

Posted: Mon May 24, 2010 12:15 pm Post subject: Experimental Class

John,

 I enjoyed reading your excellent post.  

  

 For my own files, can you cite the FAR, Order, etc.  that  your tenet #4 and #5 are derived from?

  

 Thanks very much.

 Dennis

 [quote]   ---

mark.bitterlich(at)navy.m
Guest

Posted: Mon May 24, 2010 12:23 pm Post subject: Experimental Class

John,



This was a very informative and very interesting posting.  To put it

mildly.  



Thank you for writing it.  



Questions: "ADs are a mandatory requirement on Certificated Aircraft

and/or certificated engines while attached to those aircraft."



My GSO-480 Lycoming engine and Hartzell prop was sold under contract to

Yugoslavia who put it in an aircraft of their own design.  Thus the

engine was never put in a U.S. Certificated aircraft and was brought

into this country in Experimental Exhibition status from Canada.  So

when you say:  "While attached to those aircraft", what aircraft are you

referring to?  An original certificated aircraft, which if that is what

you meant... Mine never was... So, ????  I am guessing I still need to

make the logbook entry. 



Lastly... When you have an FAA inspector who refuses to listen and

instead just talks... And expects you to sit there at his feet kissing

them in the process...  Your recourse is as you point out?  



A very powerful post.  Again, thank you. 



Mark

  



 



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racemech11

Joined: 19 Oct 2009
Posts: 10

Posted: Mon May 24, 2010 4:28 pm Post subject: Re: Experimental Class

Let me put my .02 cents worth in and it is just my understanding. I think, as you can see, there are many with an understanding and somewhere in them is the real truth.



Be very careful with the way your operating limitations are written. Usually, if it is a certified product, such as an airframe, engine, prop, etc. and is moving into the experimental category, the limitations will state that the product will be maintained in accordance with Part 43. 



If this statement is included in your operating limitations, you are required to comply with A.D.'s (my understanding of this stuff.)

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