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Program Letter
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mark.bitterlich(at)navy.m
Guest

Posted: Mon Apr 18, 2011 7:37 am Post subject: Program Letter

DARN GOOD ADVICE!  



--

keithmckinley

Joined: 11 Aug 2008
Posts: 434

Posted: Tue May 24, 2011 4:00 pm Post subject: Re: Program Letter

 	  k7wx wrote: 	
		   As you are not REQUIRED to carry a copy

 of the letter with you when traveling

 

 -- 	




I know this subject is beat up but I've looked and can't find anything regarding whether the PL needs to be with the airplane or not. I carry mine but didn't think it was required. Then again, it seems that the PL may be an addendum to the ops limits and that is required.....



Keith

mark.bitterlich(at)navy.m
Guest

Posted: Tue May 24, 2011 4:22 pm Post subject: Program Letter

Every FISDO interprets rules differently, which is why there are

lawyers.  Sigh.  



I asked MY FISDO and they say it is not required to be carried in the

aircraft.  They also mentioned other FISDO's might not agree with them

and if you are traveling outside of your area, it might be wise to carry

it.  Makes sense to me.  



Bottom line in my humble opinion is:  Your Operating Limitations spell

out exactly what you are required to do.  Those Operating Limitations

tell you that a Program Letter must be written and submitted to the FAA

every year.  They do not say that you are required to carry that Program

Letter with you.  



It also gets sticky if you still have your 300 mile limit in your

Operating Limitations.  Do you?  If you do, then if where you are going

is outside of that limit and your destination is not on your submitted

program letter, you must send in a modification to your program letter.

If you do that, I would always carry that with me just to prove to the

FAA that I did things right.  



I have had that limitation REMOVED from my Operating Limitations.  That

said, if I go somewhere distant, I still think I would send in a

notification to the FAA of where I was going.  You're not asking

permission, you're just keeping them informed, and I don't see any

reason not to do that and it tends to show you are working with them

instead of against them.  



That said.... there are also those that say that the less the FAA knows

about what you do, the better.  



I suspect the best answer is just to take the path of least resistance.

Ask your local FISDO their opinion on the matter.  



Mark Bitterlich

--

keithmckinley

Joined: 11 Aug 2008
Posts: 434

Posted: Tue May 24, 2011 5:14 pm Post subject: Re: Program Letter

Mark,



Thanks for the feedback.



No 300 mile restriction. No doubt it is easier to play nice with the Fed's and yes it does pay dividends, but sometimes I think it's important  to make sure they interpret things correctly and realize (as inspectors) they don't make the rules. More than anything, I just have an aversion to ass kissing.......but not to protecting my own ass!



Semper Fi



Keith

keithmckinley

Joined: 11 Aug 2008
Posts: 434

Posted: Tue May 24, 2011 6:00 pm Post subject: Re: Program Letter

Mark,



Thanks for the feedback.



No 300 mile restriction. No doubt it is easier to play nice with the Fed's and yes it does pay dividends, but sometimes I think it's important  to make sure they interpret things correctly and realize (as inspectors) they don't make the rules. More than anything, I just have an aversion to ass kissing.......but not to protecting my own ass!



Semper Fi



Keith

k7wx

Joined: 24 May 2010
Posts: 117

Posted: Tue May 24, 2011 6:37 pm Post subject: Program Letter

Hello Keith,

This is actually what I wrote.

Warren

On Apr 15, 2011, at 12:24 PM, Warren Hill wrote:

 	  Quote: 	
		   When I first got my CJ, one of the local CJ gurus told me to anticipate getting ramp checked at every event attended. Told me to have a plastic folder in the aft cockpit that contained:

   Copy of license and current medical.

   Copy from logbook: Last BFR, last annual, warbird FFA inspection logbook entry.

   Phase 2 operating limitations.

   Current insurance info.

   Picture of expiratory date tag(s) of parachute(s).

   Program letter for current year. 

   Registration & special airworthiness certificate. 

   Copy of FAST card, if you have one. 

 Warren

On May 24, 2011, at 5:00 PM, keithmckinley wrote:

 	  Quote: 	

 k7wx wrote:

> As you are not REQUIRED to carry a copy

> of the letter with you when traveling

> 

> --

 I know this subject is beat up but I've looked and can't find anything regarding whether the PL needs to be with the airplane or not. I carry mine but didn't think it was required. Then again, it seems that the PL may be an addendum to the ops limits and that is required.....

 Keith

 --------

 Keith McKinley

 700HS

 KFIT

 Read this topic online here:

 http://forums.matronics.com/viewtopic.php?p=340846#340846

dsavarese0812(at)bellsout
Guest

Posted: Tue May 24, 2011 6:49 pm Post subject: Program Letter

Here's something to think about.

The program letter and modifications which you may send by fax are in 

fact part of the Operating Limitations for the airplane.  We all know 

you are required to carry the OL's in the airplane at all times.  Since 

the Program Letter is actually a part of the OL's, then IMHO, it is also 

required to be carried in the airplane.



Unfortunately, when the FAA removed the 300/600 NM proficiency area, 

they failed to include the elimination of the Program Letter, which 

would have made logical sense.  ie: if you don't have any restrictions 

as to where you can fly, they why do you need a Program Letter to attend 

an event?



When you attend an event that may also be attended by the FAA (typically 

when there is wavered airspace) and they ask to see your aircraft's 

paperwork as well as you pilot certificate and current medical form, 

when you hand him/her the aircraft's Operating Limitations he/she will 

also ask to see your Program Letter or modification for this specific 

event.  If you do not have your Program Letter with the specific event 

on it or a modification/update to the program letter which you submitted 

to your FSDO with you, the FAA person may not permit you to stay at the 

event.   I had this happen to me about 5 years ago.  Thus, when I sent 

my program letter in to the FSDO each year, I automatically put a copy 

in the airplane along with any modifications.

Dennis



On 5/24/2011 9:00 PM, keithmckinley wrote:

 	  Quote: 	
		   



 Mark,



 Thanks for the feedback.



 No 300 mile restriction. No doubt it is easier to play nice with the Fed's and yes it does pay dividends, but sometimes I think it's important  to make sure they interpret things correctly and realize (as inspectors) they don't make the rules. More than anything, I just have an aversion to ass kissing.......but not to protecting my own ass!



 Semper Fi



 Keith



 --------

 Keith McKinley

 700HS

 KFIT





 Read this topic online here:



 http://forums.matronics.com/viewtopic.php?p=340874#340874

keithmckinley

Joined: 11 Aug 2008
Posts: 434

Posted: Tue May 24, 2011 7:08 pm Post subject: Re: Program Letter

well said.

Rich Langer

Joined: 10 Apr 2007
Posts: 26
Location: Florida

Posted: Wed May 25, 2011 5:08 am Post subject: Re: Program Letter

Dennis, just to clarify, do you mean an addition to your program letter is required to attend an event even if you are within the 300/600 mi. proficiency area? Secondly, if you have had the 300/600 mi. limit removed from your O.L.'s are you now required to list every event you go to, no matter what the distance?

dsavarese0812(at)bellsout
Guest

Posted: Wed May 25, 2011 5:39 am Post subject: Program Letter

Yes, that is correct.  There is nothing in the OL's that says if you are 

attending an event within the 300/600 mile proficiency area, a copy of 

your Program Letter (or modification adding the event) is not required. 

It's a ridiculous rule, but I checked with the EAA on this issue and 

they said the requirement to have your program letter showing the event 

you are attending even if it is within the 300 mile proficiency area was 

never eliminated with the elimination of the 300/600 mile proficiency area.



Yes, this is also true even if you have had your OL's updated to remove 

the 300/600 mile proficiency area.  The requirement for an annual 

Program Letter or modifications to add an event remain in place.   Read 

you OL's.   If "Program Letter" is still in the OL's, then you must 

submit one annually, plus submit updates as required regardless of the 

distance of the event you are attending from your home base airport.

Dennis

On 5/25/2011 8:08 AM, Rich Langer wrote:

 	  Quote: 	
		   



 Dennis, just to clarify, do you mean an addition to your program letter is required to attend an event even if you are within the 300/600 mi. proficiency area? Secondly, if you have had the 300/600 mi. limit removed from your O.L.'s are you now required to list every event you go to, no matter what the distance?





 Read this topic online here:



 http://forums.matronics.com/viewtopic.php?p=340917#340917

mark.bitterlich(at)navy.m
Guest

Posted: Wed May 25, 2011 5:52 am Post subject: Program Letter

Concur ABSOLUTELY



Mark

--

mark.bitterlich(at)navy.m
Guest

Posted: Wed May 25, 2011 6:07 am Post subject: Program Letter

Dennis, I respectfully disagree with your point of view in this one

area. 



You mentioned: 



"The program letter and modifications which you may send by fax are in 

fact part of the Operating Limitations for the airplane.  We all know 

you are required to carry the OL's in the airplane at all times.  Since 

the Program Letter is actually a part of the OL's, then IMHO, it is also



required to be carried in the airplane."



The Operating Limitations also require a Conditional Inspection every

year.  By the same logic, you would also need to carry along a copy of

your Conditional Inspection, or copies of your aircraft logbooks, etc.

My opinion on dealing with the FAA on things like this is when they say:

"We need to see a copy of your Program Letter or modification of same,

and if you don't have it with you, you must leave."  



 NUMBER ONE: !!! Reply with:  "Please quote the Regulation that

specifically states I must carry a copy of my Program Letter with me.

If you cannot quote me the exact regulation that requires me to do this,

I respectfully submit you have no authority to demand it from me".  



You must carry a copy of your Operating Limitations.  READ THEM!  Break

them out and have the FAA Inspector SHOW YOU on the Operating

Limitations where it says what he is saying.  THE BURDON OF PROOF IS ON

THE FAA, not on your to prove you are innocent.  Sometimes certain FAA

Inspectors forget that fact.  Some Inspectors also assume that anything

they say is automatically correct.  Anything you say is automatically

wrong.  You need to know your regulations and you also need the phone

number to the EAA's Govt. Hotline.  Ask for Randy Hanson.  



NUMBER TWO: If they still play nasty....   Go back to the motel, do a

handwritten modification to your Program Letter on a paper napkin, go

down to the Hotel Desk and FAX IT to your local FISDO.  The go back to

the airport and hand that FAA Inspector the paper napkin and bit him a

fond farewell.  I am not being sarcastic here.  OK. The paper napkin

part is supposed to be a joke (OK who-ever from the FAA READS THIS?  A

JOKE!  PLEASE?  Good grief).  



Not that I think you're wrong about carrying the stuff along.  The FAA

CONSTANTLY (!!!) interprets things differently and they can come up with

the strangest things (flying with my door off, etc) and you have to go

to the ends of the Earth to get them to see things a little bit

differently.  



Just saying.  I think being polite but not cowardly is the best

approach... my 2 cents. 



Mark

 



--

dsavarese0812(at)bellsout
Guest

Posted: Wed May 25, 2011 6:07 am Post subject: Program Letter

For those that want to see the latest and greatest version of the FAA 

Order 8130.2x, on April 16, 2011 the FAA 8130.2G became effective. The 

Yak 52 and CJ6 now fall into a new grouping method they have 

established; Group 2. Within the groups is a matrix chart that 

established what Operating Limitation must be included in the OL's for a 

aircraft in that group.



Unfortunately, guess what remains.....the infamous Program Letter 

requirement. Here are the exact words from the FAA Order which answers 

the question whether the Program Letter and any amendments must be 

carried in the airplane.



"....(3) The owner operator must submit an annual program letter to the 

geographically

responsible FSDO where the aircraft is based. All operations must be 

conducted in accordance

with these limitations and the program letter. A copy of the current 

program letter and any

amendments must be carried on board the aircraft any time that the 

aircraft is being operated.

The program letter must include the following information:

(a) The aircraft’s home base.

(b) The name of the person responsible for the operation and maintenance 

of the

aircraft.

(c) A list of events at which the aircraft will be exhibited (the list 

may be amended

as necessary).

(d) For Group 6 and Group 7 aircraft, the proficiency area. The 

proficiency area

may be depicted using a map or it may be described by geographic 

landmarks, airports, or aids to

navigation.

(4) The pilot in command of this aircraft must hold an appropriate 

category and class

rating.



Hope this helps.

Dennis



On 5/25/2011 8:50 AM, Bitterlich, Mark G CIV Det Cherry Point, MALS-14 

64E wrote:

[quote] 



 Concur ABSOLUTELY



 Mark

 --

dsavarese0812(at)bellsout
Guest

Posted: Wed May 25, 2011 6:17 am Post subject: Program Letter

Mark, I respectfully request you read my next posting on the subject.  



On 5/25/2011 9:04 AM, Bitterlich, Mark G CIV Det Cherry Point, MALS-14 

64E wrote:

[quote] 



 Dennis, I respectfully disagree with your point of view in this one

 area.



 You mentioned:



 "The program letter and modifications which you may send by fax are in

 fact part of the Operating Limitations for the airplane.  We all know

 you are required to carry the OL's in the airplane at all times.  Since

 the Program Letter is actually a part of the OL's, then IMHO, it is also



 required to be carried in the airplane."



 The Operating Limitations also require a Conditional Inspection every

 year.  By the same logic, you would also need to carry along a copy of

 your Conditional Inspection, or copies of your aircraft logbooks, etc.

 My opinion on dealing with the FAA on things like this is when they say:

 "We need to see a copy of your Program Letter or modification of same,

 and if you don't have it with you, you must leave."



   NUMBER ONE: !!! Reply with:  "Please quote the Regulation that

 specifically states I must carry a copy of my Program Letter with me.

 If you cannot quote me the exact regulation that requires me to do this,

 I respectfully submit you have no authority to demand it from me".



 You must carry a copy of your Operating Limitations.  READ THEM!  Break

 them out and have the FAA Inspector SHOW YOU on the Operating

 Limitations where it says what he is saying.  THE BURDON OF PROOF IS ON

 THE FAA, not on your to prove you are innocent.  Sometimes certain FAA

 Inspectors forget that fact.  Some Inspectors also assume that anything

 they say is automatically correct.  Anything you say is automatically

 wrong.  You need to know your regulations and you also need the phone

 number to the EAA's Govt. Hotline.  Ask for Randy Hanson.



 NUMBER TWO: If they still play nasty....   Go back to the motel, do a

 handwritten modification to your Program Letter on a paper napkin, go

 down to the Hotel Desk and FAX IT to your local FISDO.  The go back to

 the airport and hand that FAA Inspector the paper napkin and bit him a

 fond farewell.  I am not being sarcastic here.  OK. The paper napkin

 part is supposed to be a joke (OK who-ever from the FAA READS THIS?  A

 JOKE!  PLEASE?  Good grief).



 Not that I think you're wrong about carrying the stuff along.  The FAA

 CONSTANTLY (!!!) interprets things differently and they can come up with

 the strangest things (flying with my door off, etc) and you have to go

 to the ends of the Earth to get them to see things a little bit

 differently.



 Just saying.  I think being polite but not cowardly is the best

 approach... my 2 cents.



 Mark





 --

mark.bitterlich(at)navy.m
Guest

Posted: Wed May 25, 2011 6:24 am Post subject: Program Letter

This is new.  Very new.  It also seems to have changed what was written

before and specifically says what you are saying is true Dennis. 



I think this should be run before the EAA for their comments.  You or me

Dennis? 



Mark

--

mark.bitterlich(at)navy.m
Guest

Posted: Wed May 25, 2011 6:28 am Post subject: Program Letter

Just did    



--

dsavarese0812(at)bellsout
Guest

Posted: Wed May 25, 2011 6:47 am Post subject: Program Letter

I think it is quite clear.  The Program Letter must be carried in the 

airplane at all times.

Dennis

On 5/25/2011 9:22 AM, Bitterlich, Mark G CIV Det Cherry Point, MALS-14 

64E wrote:

[quote] 



 This is new.  Very new.  It also seems to have changed what was written

 before and specifically says what you are saying is true Dennis.



 I think this should be run before the EAA for their comments.  You or me

 Dennis?



 Mark

 --

dsavarese0812(at)bellsout
Guest

Posted: Wed May 25, 2011 6:51 am Post subject: Program Letter

For those that are operating under the older 8130.2F, here is a 

paragraph that is included in all of the groups, including ours, Group 

III.  Just for grins, see if there is a paragraph in your own OL's that 

says something like the following".



"....(2) No person may operate this aircraft for other than the purpose 

of meeting the requirements

of § 91.319(b), as stated in the program letter (required by § 21.193) 

for this aircraft. This aircraft must

be operated in accordance with applicable air traffic and general 

operating rules of part 91, as well as all

additional limitations herein prescribed under the provisions of § 

91.319(e). These operating limitations

are a part of the special airworthiness certificate, and are to be 

carried in the aircraft at all times

and made available to the pilot in command of the aircraft.

(Applicability: All)

Dennis

On 5/25/2011 9:26 AM, Bitterlich, Mark G CIV Det Cherry Point, MALS-14 

64E wrote:

[quote] 



 Just did  



 --

dsavarese0812(at)bellsout
Guest

Posted: Wed May 25, 2011 7:11 am Post subject: Program Letter

Any new Special Airworthiness Certificates and Operating Limitations 

will be issued under 8130.2G.  This includes any request for the change 

to eliminate the 300/600 mile proficiency area that may currently be in 

your existing OL's.

Dennis



On 5/25/2011 9:48 AM, A. Dennis Savarese wrote:

[quote] 

 <dsavarese0812(at)bellsouth.net>



 For those that are operating under the older 8130.2F, here is a 

 paragraph that is included in all of the groups, including ours, Group 

 III.  Just for grins, see if there is a paragraph in your own OL's 

 that says something like the following".



 "....(2) No person may operate this aircraft for other than the 

 purpose of meeting the requirements

 of § 91.319(b), as stated in the program letter (required by § 21.193) 

 for this aircraft. This aircraft must

 be operated in accordance with applicable air traffic and general 

 operating rules of part 91, as well as all

 additional limitations herein prescribed under the provisions of § 

 91.319(e). These operating limitations

 are a part of the special airworthiness certificate, and are to be 

 carried in the aircraft at all times

 and made available to the pilot in command of the aircraft.

 (Applicability: All)

 Dennis

 On 5/25/2011 9:26 AM, Bitterlich, Mark G CIV Det Cherry Point, MALS-14 

 64E wrote:

> 

> Point, MALS-14 64E"<mark.bitterlich(at)navy.mil>

>

> Just did  

>

> --

mark.bitterlich(at)navy.m
Guest

Posted: Wed May 25, 2011 11:28 am Post subject: Program Letter

Yes, but that does not say you have to carry your Program Letter Dennis.  It says you have to carry your OPERATING LIMITATIONS in the aircraft.  



Just FYI, under the OLD rules .... I contacted the EAA and the local FAA, the Montana FAA, the Seattle FAA and all of them said you did NOT have to carry your program letter with you.  I am sure you were told that you did have to.  



It falls into the "whatever you feel is right category" and it also fell into "who interprets the rules" category.  



On the other hand, the new rules you just posted are a whole different thing.  I read them, they seem quite clear!  That said, I never EVER take what ANYONE says on the Yak List regarding rules and regulations as gospel.  Even when I read things myself!  I always ask for second opinions, third opinions, and even FORTH opinions!   I always dig very deeply when it comes to rules.  



I sent your quote to the EAA Government Division (Randy Hanson) for confirmation or interpretation.  As I said, what you posted seems very clear and is a definite change in policy and adds a new requirement to all of us.  But I'll still be interested in what the EAA says.  

Mark

--

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