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Maintenance, again
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wild.blue(at)verizon.net
Guest

Posted: Tue Aug 08, 2006 7:20 am Post subject: Maintenance, again

Scooter--

  

 As you see, there is some serious disagreement about what sort of maintenance an owner/pilot who is not an A&P is allowed by FAR to perform, to say nothing about what is SAFE or smart for untrained people to do to your airplane.  Your widow won't care about the legal niceties.

  

 Read the Operating Limitations that accompany your Airworthiness Certificate.  They will clearly tell you that the airplane must be maintained in accordance with 14 CFR Part 43--NO EXCEPTIONS.  Dennis and I respectfully disagree about this.  In particular, IMHO, his assertion that Part 43 flat doesn't apply and therefore anyone can perform any sort of maintenance or repair is especially dangerous advice.  With FAA type certificated aircraft, with their shelves of manuals and reams of AD's and Service Bulletins, ALL repairs, major and minor, must be performed by an A&P.  ALL major repairs must also be APPROVED by an A&P with Inspection Authorization AND the feds, on a case by case basis, specifically for the particular airplane being repaired.  It's amazing what simple things the feds consider major repairs.  ALL repairs have to be done in conformance to the mfrs recommendations and APPROVED data.  This even applies to repairs/mods for which an STC has been approved.  That's why every Cessna has a stack of 337's in its records.  If an A&P with IA can't install a steel nut in place of a brass nut, even if it has an approved STC, without specific FAA approval of that particular installation on your particular Cessna or 747, common sense should tell you not to try to perform repairs or modifications on your Yak or CJ if you're not an A&P.  In fact, if you read your Ops Limitations you'll find they tell you the FAA must approve ALL major repairs/modifications to the aircraft.  Historical experience is on the side of the FAA.  The fortuitous fact that the feds usually choose not to involve themselves unless there is a smoking hole and dead pedestrians should NOT lull you into thinking you can install that new race modified M-14 or Ford V-8 with those high compression pistons from EBay and juiced up axial flow supercharger mod from JC Whitney, super lightweight condolling wheel, high RPM rebofelther and that fancy new propeller you designed on the back of a napkin and built out of old Styrofoam cups and Super Glue.  Got a test program?  Are you a qualified engineering test pilot?  Even if it was legal it's probably not smart.  And vice versa.  Especially vice versa.  That's why we have an FAA--all the dead amateurs who tried and the pedestrians they killed.

  

 If Part 43 doesn't apply, why is a Condition Inspection required and why must it be performed by an A&P?

  

 You've read Jim Selby's concern about getting Yak-18 Russian manuals translated into English.  If anyone can perform any old sorts of repairs, not just maintenance, why would the feds care if you have manuals in Russian or English or any other language?  Don't need no stinkin' manuals!  Watfo--you gonna do all the repairs and mods your way on your own any way--ain't and don't need no friggin' manuals for that!  

  

 Look: lots of Experimental Exhibition aircraft not only are required to have manuals (in English), they are required to have an FAA APPROVED maintenance program, just like an airliner.  Yes, the FAA can be a pain.

  

 Those of us who are A&P's cringe when owner maintained/repaired/modified/hacked-up aircraft show up in our shops.  Some are Yaks/CJ's.  Granted, lots of things can be and should be done by owners and are allowed by FAR.  Some owners are meticulous and professional in their work.  Most are not.  Sad to say, but even some licensed people do shoddy work.  Owners are worse.  If you think pop can and shingle nail field repairs by Chinese/Russian "wholesalers" are bad, look at some owner performed repairs/mods.  Owners need to do the things most won't pay others to do for them:  keep it clean, keep it dry, keep fresh oil in the tank, air (nitrogen) in the tires, money in the bank--preventive maintenance.  That's why the FAR's allow owners (if they are pilots) to perform preventive maintenance.  Get a professional you know and trust to do the rest.  The next time somebody crashes his Experimental Exhibition airplane into an ice cream parlor or a school and kills a bunch of kids there will be hell to pay, especially if it has been owner maintained and modified.  Even if the pilot/owner/maintainer/repairer/modifier is a Republican (no offense) it won't help.

  

 Be smart, be safe.  If you don't know what you're doing, don't do it.  After all, It's your life and your family's lives that are at stake.

  

 Jerry Painter

threein60(at)yahoo.com
Guest

Posted: Tue Aug 08, 2006 9:21 am Post subject: Maintenance, again

This may be on of those issues that goes on for ever because when you talk to 5 different FAA Field offices, you may get 5 different answers.  Jerry must have gotten the same lecture I have over the years.  Besides being an A&P, I have re-certified other former military aircraft (OH-58, UH-1, AH-1, Chipmunks) into Experimental Exhibition.  In order to do this, I had to prove that all repairs and modifications were done IAW the manufactures maintenance manuals and produce them upon inspection of the aircraft.  Furthermore, It was written in my certificate papers that ALL repairs and Phase maintenance must be done IAW Manuf MM or an Approved checklist that incorporated 43-13 App D.  At no time was I told after certification that you are good to go and do anything you wish.  

   

  If a person buys a second hand experimental aircraft (RV-, they must have all maintenance signed off by an A&P.  Or  aircraft are no different since we, the owners, didn't build them.  Only owner/builders are exempt from A&P sign offs.  That is the line of thought the FAA goes by.  

   

  That being said, Not all A&P are qualified to work on Cessna's never mind CJs or Yaks.  You should always chose wisely but even great A&Ps still need manuals!

   

   

   

   

   

   

   

   

   

   

   

  



Jerry Painter <wild.blue(at)verizon.net> wrote:

   	  Quote: 	
		        v\:* {behavior:url (#default#vml);}      v\:* {   BEHAVIOR: url (#default#vml)  }         FLAVOR00-NONE-0000-0000-000000000000  4.0  ;              Scooter--

   

  As you see, there is some serious disagreement about what sort of maintenance an owner/pilot who is not an A&P is allowed by FAR to perform, to say nothing about what is SAFE or smart for untrained people to do to your airplane.  Your widow won't care about the legal niceties.

   

  Read the Operating Limitations that accompany your Airworthiness Certificate.  They will clearly tell you that the airplane must be maintained in accordance with 14 CFR Part 43--NO EXCEPTIONS.  Dennis and I respectfully disagree about this.  In particular, IMHO, his  assertion that Part 43 flat doesn't apply and therefore anyone can perform any sort of maintenance or repair is especially dangerous advice.  With FAA type certificated aircraft, with their shelves of manuals and reams of AD's and Service Bulletins, ALL repairs, major and minor, must be performed by an A&P.  ALL major repairs must also be APPROVED by an A&P with Inspection Authorization AND the feds, on a case by case basis, specifically for the particular airplane being repaired.  It's amazing what simple things the feds consider major repairs.  ALL repairs have to be done in conformance to the mfrs recommendations and APPROVED data.  This even applies to repairs/mods for which an STC has been approved.  That's why every Cessna has a stack of 337's in its records.  If an A&P with IA can't install a steel nut in place of a brass nut, even if it has an approved STC, without specific FAA approval of that particular  installation on your particular Cessna or 747, common sense should tell you not to try to perform repairs or modifications on your Yak or CJ if you're not an A&P.  In fact, if you read your Ops Limitations you'll find they tell you the FAA must approve ALL major repairs/modifications to the aircraft.  Historical experience is on the side of the FAA.  The fortuitous fact that the feds usually choose not to involve themselves unless there is a smoking hole and dead pedestrians should NOT lull you into thinking you can install that new race modified M-14 or Ford V-8 with those high compression pistons from EBay and juiced up axial flow supercharger mod from JC Whitney, super lightweight condolling wheel, high RPM rebofelther and that fancy new propeller you designed on the back of a napkin and built out of old Styrofoam cups and Super Glue.  Got a test program?  Are you a qualified engineering test pilot?  Even if it was legal  it's probably not smart.  And vice versa.  Especially vice versa.  That's why we have an FAA--all the dead amateurs who tried and the pedestrians they killed.

   

  If Part 43 doesn't apply, why is a Condition Inspection required and why must it be performed by an A&P?

   

  You've read Jim Selby's concern about getting Yak-18 Russian manuals translated into English.  If anyone can perform any old sorts of repairs, not just maintenance, why would the feds care if you have manuals in Russian or English or any other language?  Don't need no stinkin' manuals!  Watfo--you gonna do all the repairs and mods your way on your own any way--ain't and don't need no friggin' manuals for that!  

   

  Look: lots of Experimental Exhibition aircraft not only are required to have manuals (in English), they are required to have an FAA APPROVED maintenance program,  just like an airliner.  Yes, the FAA can be a pain.

   

  Those of us who are A&P's cringe when owner maintained/repaired/modified/hacked-up aircraft show up in our shops.  Some are Yaks/CJ's.  Granted, lots of things can be and should be done by owners and are allowed by FAR.  Some owners are meticulous and professional in their work.  Most are not.  Sad to say, but even some licensed people do shoddy work.  Owners are worse.  If you think pop can and shingle nail field repairs by Chinese/Russian "wholesalers" are bad, look at some owner performed repairs/mods.  Owners need to do the things most won't pay others to do for them:  keep it clean, keep it dry, keep fresh oil in the tank, air (nitrogen) in the tires, money in the bank--preventive maintenance.  That's why the FAR's allow owners (if they are pilots) to perform preventive maintenance.  Get a professional you know and trust to  do the rest.  The next time somebody crashes his Experimental Exhibition airplane into an ice cream parlor or a school and kills a bunch of kids there will be hell to pay, especially if it has been owner maintained and modified.  Even if the pilot/owner/maintainer/repairer/modifier is a Republican (no offense) it won't help.

   

  Be smart, be safe.  If you don't know what you're doing, don't do it.  After all, It's your life and your family's lives that are at stake.

   

  Jerry Painter

                	


Larry Pine

Scooter

Joined: 10 Jan 2006
Posts: 155

Posted: Tue Aug 08, 2006 10:45 am Post subject: Re: Maintenance, again

The following about my Operating Limitations is incorrect:  "They will clearly tell you that the airplane must be maintained in accordance with 14 CFR Part 43--NO EXCEPTIONS".  In fact they say that the aircraft must be inspected per part 43 - not maintained per 43.



As for working on experimental amateur built aircraft:  anyone can do this - not just the builder.

threein60(at)yahoo.com
Guest

Posted: Tue Aug 08, 2006 10:56 am Post subject: Maintenance, again

Experimental is not Experimental Exhibition!  

   

   

  



flir47 <me262pilot(at)comcast.net> wrote: 

  [quote]--> Yak-List message posted by: "flir47" 



FYI........



FAR Part 43.1 (b) specifically excludes experimental aircraft so the FAA is incorrect in stating you are held to any part or appendix of Part 43. It states "This part does not apply to any aircraft for which an experimental airworthiness certificate has been issued, unless a different kind of airworthiness certificate had been previously issued for that aircraft". I stress the word aircraft so that is not interpreted to include an engine.

What about major repairs and alterations? First you never have to fill out a form 337 for an experimental aircraft. Repairs major or minor can be done by anyone,  remember Part 43.1 (b). However, alterations are different. If you alter the aircraft with a different propeller or engine, for example, then it is not the aircraft for which you received an airworthiness certificate. This would also apply to changing pistons or magnetos. It is a new and untested airplane. If you change propellers you must notify the FAA (not by a 337) of your change.

Your aircraft's operating limitations should have a statement such as the following in regard to major changes: "The FAA Cognizant Flight Standards Office must be notified, and their response received in writing, prior to flying this aircraft after incorporating a major change as defined by FAR 21.93

If you do not have such a statement on your operating limitations then you can claim you do not have to notify the FAA. However, EAA suggest you do so even if you do not have this limitation.

The FAA inspector will make a determination as to whether he need to come out and inspect the  change and/or assign a new flight-test period. If the inspector gives you an OK by letter (which is often done) you should note the date, time, name and change in your aircraft logbook. If the inspector wants to inspect the aircraft, it is the same as an FAA certified A&P. So far to EAA's knowledge this has never happened on an amateur built aircraft. Most operating limitations contain a statement that says and annual "condition" inspection must be performed per the scope and detail of FAR Part 43 Appendix D. It also states that an FAA certificated A&P or repairman must perform this inspection. Note it says "A&P or Repairman". It does not require an IA.

Let me clarify this. Anyone can work on an experimental aircraft and sign off the work. However the annual "condition" inspection must be completed by an A&P or a

repairman.



Sincerely,

Experimental Aircraft Association

Earl Lawrence

Government Programs  Specialist

Also....

If you do not have such a statement on your operating limitations, then you can claim you do not have to notify the FAA. However, EAA suggests that you do so even if you do not have this limitation.



The FAA inspector will make a determination as to whether he needs to come out and inspect the change and/or assign a new test-flight period. If the inspector gives you an OK by letter (which is often done), you should note the date, time, name, and change in your aircraft log book. If the inspector wants to inspect the aircraft, it is the same as when you first received your airworthiness certificate. You start all over. It is a new airplane. This information is covered in the FAA ORDER 8130.2C paragraph 142 "Issuance Of Experimental Operating Limitations." Every FAA inspector has a copy of this ORDER.



If the aircraft received its original airworthiness certificate based on the fact that the engine was certified and you  alter it in any manner that would render it no longer within certification requirements, then you must notify the FAA of your change and receive an approval.



Look at it this way, you may use any combination of parts you wish to build your aircraft. However, once you receive your airworthiness certificate you cannot alter it without getting the FAA to reinspect the "new" aircraft.



ADs apply to all aircraft, aircraft assemblies and parts the AD is written against, no matter what type of aircraft they are installed in. The key to this statement is, "that the AD is written against." For example, if an AD is written against a particular make, model and serial number propeller, it only applies to that particular make model and serial number. It applies to that particular make model and serial number propeller no matter what aircraft it is installed on. Now this is where I complicate things. You, as an amateur builder, remove the data plate of that propeller, send  it to the FAA, the FAA notifies the manufacturer, and you make it a Ross propeller model R1, serial number 001. Now the propeller is no longer the propeller listed in the AD, so it does not apply. The FAA may, however, issue a new AD against the Ross propeller model R1 serial number 001. To date the FAA has never done this, but they can.



If you install an electronic ignition system on a Lycomming engine, you are still responsible for ADs on other accessories on the engine and the engine itself if you have the component listed on the AD on your engine. And, of course, if you haven't changed its designation to the Ross model R1 serial number 001. In general, you can say if your AC received its airworthiness certificate based on the fact it had a certified engine, then the ADs apply. If you received an airworthiness certificate based on the fact that your engine was not certified, then the ADs don't apply.



Isn't this fun?!



Now about who can do work on  amateur-built aircraft. Anyone can normally work on an experimental aircraft and sign off the work, including your two-year-old son. Some FAA field inspectors do not believe this. Remember FAR Part 43.1(b) "This part does not apply to any aircraft for which an experimental airworthiness certificate has been issued." The operating limitations that each experimental aircraft must have are what replaces Part 43. Each set of operating limitations is different. However, an FAA inspector has the power to place a requirement in the operating limitations that all work must be done by an FAA certified A&P. So far to EAA's knowledge, this has never happened on an amateur built aircraft. Most operating limitations contain a statement that says an annual "condition" inspection must be performed per the scope and detail of FAR Part 43 Appendix D. It also states that an FAA certificated A&P or repairman must perform this inspection. Note it says, "A&P or Repai!

rman." It  size=4>Larry Pine



  		How low will we go? Check out Yahoo! Messenger’s low  PC-to-Phone call rates.

rvfltd(at)televar.com
Guest

Posted: Tue Aug 08, 2006 11:30 am Post subject: Maintenance, again

In reading this it is obvious that Mr. Lawrence was talking about kit built

and scratch built aircraft and not experimental exhibition aircraft.  What

portion of this applies to our Yaks and Nanchangs?  Who has a email for Earl

Lawrence?



Always Yakin,

Doug Sapp



--

Scooter

Joined: 10 Jan 2006
Posts: 155

Posted: Tue Aug 08, 2006 11:57 am Post subject: Re: Maintenance, again

Not true.  Experimental is a category that includes exhibition, research and development, amateur built, air racing, etc.  All aircraft fall into one of these categories.  No aircraft is purely experimental.

 	



 	  threein60(at)yahoo.com wrote: 	
		  Experimental is not Experimental Exhibition!

viperdoc(at)mindspring.co
Guest

Posted: Tue Aug 08, 2006 12:22 pm Post subject: Maintenance, again

My operating limitations reads as follows: Only FAA certified mechanics

with appropriate ratings are authorized by ~43.3 or appropriately rated

repair stations may perform inspections required by these operation

limitations.  It also states, Aircraft instruments and equipment installed

and used under ~ 91.205 must be inspected and maintained in accordance with

the applicabe requirements of parts 43 and 91. Any maintenance or

inspection of this equipment must be recorded in the aircraft maintenance

records.

I inturpt inspections to mean examine not maintain. Nothing is said about

only FAA mechanics with appropriate ratings are required to maintain this

aircraft.

There is nothing stated concerning all maintenance must only be performed

by a rated A&P. It does need to signed off by an A&P after an annual

condition inspection but the A&P does not have to do all the work.

Maintenance can be performed by the owner operator as I understand it. Most

of the A&P's I know are more than happy to have me do all the work and then

inspect it after or in the process of accomplishment of the condition

inspection. Now the smart YAK/CJ driver should ,when a question arises

about the maintenance of their aircraft, ask an appropriate A&P for advise.

Chances are though, you generally know more about that aircraft than he

does. So you end up calling the knowledge of the yak-list, the likes of

Doug Sapp, Carl Hayes, Dennis Savarese, George Coy, and Steve Culp, ect for

the necessary guidance. Atleast that is the way it goes in my neck of the

woods.

As those that know me will say, I am an OCS personality, so I take very

good care of my aircraft anyway.

Doc

 	  Quote: 	
		   [Original Message]

 From: Scooter <yakk52(at)verizon.net>

 To: <yak-list(at)matronics.com>

 Date: 8/8/2006 1:55:36 PM

 Subject: Re: Maintenance, again



 



 The following about my Operating Limitations is incorrect:  "They will

clearly tell you that the airplane must be maintained in accordance with 14
	


CFR Part 43--NO EXCEPTIONS".  In fact they say that the aircraft must be

inspected per part 43 - not maintained per 43.

 	  Quote: 	
		  

 As for working on experimental amateur built aircraft:  anyone can do

this - not just the builder.
	


 	  Quote: 	
		  



 Read this topic online here:



 http://forums.matronics.com/viewtopic.php?p=53441#53441

threein60(at)yahoo.com
Guest

Posted: Tue Aug 08, 2006 12:26 pm Post subject: Maintenance, again

The basic argument comes down to this...  Lets start with the category that gives you the most latitude.... Homebuilt experimental!  The FAA states that " The builder of a certified experimental aircraft, who holds a repairmans certificate for that aircraft, may perform the maintenance and conditional inspection required by the operating limitations.  Condition inspections will be performed in the same scope as FAR 43, App D.  The aircraft Aircraft will be identified on the repairman certificate by make, model serial number, and certification date."

   

  As second hand owner is not given a repairmans certificate for that aircraft since he is not the original builder.  This dove tails now into Experimental Exhibition.  Since none of us are the original builders or out aircraft, we are not given repaimans certificates.  Hence that is where licensed A&P come in.  

   

   I think there is so much confusion on this, I would suggest contact your local field office (disguise your voice) and ask them since you would fall under their jurisdiction.  What ever they say, go for that!



   

   

   

   

   

  

doug sapp <rvfltd(at)televar.com> wrote:

  [quote]--> Yak-List message posted by: "doug sapp" 



In reading this it is obvious that Mr. Lawrence was talking about kit built

and scratch built aircraft and not experimental exhibition aircraft. What

portion of this applies to our Yaks and Nanchangs? Who has a email for Earl

Lawrence?



Always Yakin,

Doug Sapp



--

ScottA

Joined: 05 Jan 2006
Posts: 100
Location: Park City, UT

Posted: Tue Aug 08, 2006 12:32 pm Post subject: Re: Maintenance, again

Anyone can work on/change/modify an experimental aircraft (of course depending on mod may need more test flight approval).  No YAK or CJ owners will ever have a builder repairman certificate (unless you can convince you built 51%) so they will need an AP (not IA) to sign off the "condition" inspection.  The repairman certificate that is available to other custom aircraft builders does not transfer with the airplane - only that one person can do the condition inspection, but he could do it for the new owner if he wanted to (unlikely).  At least that is the way it is in this area of the US.



FWIW

Scott

rvfltd(at)televar.com
Guest

Posted: Tue Aug 08, 2006 1:28 pm Post subject: Maintenance, again

Yes I0 understand your point, but the question I was trying to get at and hopefully get0 a answer was what exactly is the EAA's legal folk's position and understanding0 of the regs when applied specifically to our aircraft. 0 

  

 Should0 10 of us contact our FSDO's we will get 10 different answers, how they ever got0 the name "Flight Standards"  I'll never know.

  

 

Always Yakin,

Doug Sapp  [quote]   --

dhanshew(at)cinci.rr.com
Guest

Posted: Tue Aug 08, 2006 1:57 pm Post subject: Maintenance, again

[quote] --

dhanshew(at)cinci.rr.com
Guest

Posted: Tue Aug 08, 2006 2:13 pm Post subject: Maintenance, again

My0 advice for what it's worth (which ain't much). Don't knob dick it. Leave it be.0 Do what you've been doing in a reasonable and contentious manner as you would0 normally do. A fed's word means nothing but what serves the purpose at the time.0 Right now we are about to rewrite the Part 25 landing certification regulations0 via a NPRM no one had time to comment on (to include Boeing) simply because0 a poor unfortunate kid got killed at MDW. Instead of doing it right and0 addressing the regulation and buttressing it with appropriate data we'll be0 forced into one size fits all as a ironclad solution to a very complex problem.0 They will have an NTSB judge adjudicate the matter outside the realm of real0 numbers just because it "feels" like the right thing to do. That is how it works0 now. No facts just what feels right. Every year it gets harder and harder to0 predict what the FAA will do in reaction to something because instead of waiting0 for tombstones they are trying to beat the ambulance to the0 morgue. They have become virulently proactive to the point that a0 strait jacket seems comfortable. Open a door for them and they will be in it0 with both feet, a battalion of lawyers, and Dr. Phil for good measure. Leave the0 matter alone - for what it is worth.

 [quote]   --

rvfltd(at)televar.com
Guest

Posted: Tue Aug 08, 2006 3:15 pm Post subject: Maintenance, again

Steve,

 I0 don't advocate going to the Feds for anything, but would like to know the0 EAA's (read it carefully Steve I said EAA, NOT FAA)0 interpretation of the regs.  Many times the EAA and the AOPA's staff has0 stepped in between the feds and a Joe pilot and the outcome has ended up much0 more favorable for old Joe than if he would have been left to his own0 devices.  Should one of our Joe's need help it would be good to know where0 competent help might be found.   I cannot believe you don't0 agree.  

  

 Hello0 to Donna, best from Omak.

  

 

Always Yakin,

Doug Sapp0  [quote]   --

fougapilot(at)hotmail.com
Guest

Posted: Tue Aug 08, 2006 3:44 pm Post subject: Maintenance, again

Earl Lawrence knows his stuff. He helped me quite a lot a few years back 

when the FAA wanted to pull the CofA of a Fouga Jet I flew. I delt with the 

feds for weeks, and all was settled within 24hrs of Earl getting involved. 

He made the Albany FSDO back down with a one page fax...



D

dsavarese(at)elmore.rr.co
Guest

Posted: Tue Aug 08, 2006 3:49 pm Post subject: Maintenance, again

It is still Experimental Larry.  If you look at the0 Application for Airworthiness certificate (FAA FORM 8130-6),  http://forms.faa.gov/forms/faa8130-6d.pdf,0 by "Experimental" , it says "Indicate Operations To Be Performed".  Then0 you check the box next to EXPERIMENTAL for which operation your EXPERIMENTAL0 aircraft will be performing.  They are:

 Research and Development, Amateur Built, Exhibition, Air0 Racing, Crew Training, Market Survey, Operating (primary category) Kit built0 aircraft.  Based on your comment, which one of these Operations do qualify0 as Experimental?

 Dennis

  

 [quote]   ---

dsavarese(at)elmore.rr.co
Guest

Posted: Tue Aug 08, 2006 3:51 pm Post subject: Maintenance, again

Where does it say "Homebuilt, Experimental" on FAA form0 8130-6, the Application for Airworthiness Certificate?

 Dennis

  

 [quote]   ---

rvfltd(at)televar.com
Guest

Posted: Tue Aug 08, 2006 4:11 pm Post subject: Maintenance, again

Dan,

Do you have his email info?



Always Yakin,

Doug Sapp



--

dhanshew(at)cinci.rr.com
Guest

Posted: Tue Aug 08, 2006 4:23 pm Post subject: Maintenance, again

Call0 me an embittered soul. I work with lots of feds. Some I even like. I don't0 consider them priests though. Too many people nowadays bear their souls like0 Oprah and then wonder why it doesn't result in the answer they wanted. Once the0 FAA has a foot in your arse, they will inevitably run it up to the knee and then0 ask if that hurts. EAA and AOPA ok, I down with that. Sure ask them. I'm sure0 they have no desire to rat someone out. I'm to the point anymore that all the0 good feds that knew something are long gone, replaced by people looking for a0 CYA to a secure non-airline (or PBGC financed) pension.

 [quote]   --

L39parts(at)hotmail.com
Guest

Posted: Tue Aug 08, 2006 4:42 pm Post subject: Maintenance, again

I'd like you to re-read the first paragraph of your0 post.  If this statement is true:  "ALL repairs0 have to be done in conformance to the mfrs recommendations and APPROVED0 data."   then no CJ or Yak can fly because There is no approved0 data.  None, no type certificate, no STCs, no ADs, no manuals, no0 nothing that has been approved by the FAA or any agency recognized by the0 FAA.   It's just like experimental homebuilt, just like experimental0 R&D, etc.  The owner/pilot is on his own in determining that the0 aircraft is in a safe condition for flight.

  

 As to why the condition inspection is required:  It's0 not, unless your ops limits, which are an attachment to and a part of your0 airworthiness certificate require it (and of course they do require0 it).

  

 Why did the fed ask for manuals?  I can think of two0 reasons, he doesn't want to sign the airworthiness certificate so he's making up0 excuses or maybe he can't read either. 

    ---

AV8ORJWC

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

Posted: Tue Aug 08, 2006 5:01 pm Post subject: Maintenance, again

Jerry, this is the most comprehensive and accurate presentation of what is clearly misunderstood by owner/pilots of warbirds.  As an A & P for a major regional airline, it amazes me how many will cling to anyone’s interpretation that suits their purpose.  Warbird loses at KHIO and KOSH this year alone has the legal eagles reviewing this exact issue.  

Aging Aircraft is a whole nother area which was clearly addressed at OSH this year.  Sorry Dennis, your dog won’t hunt with any FAA FSDO General Manager in CONUS. You may slip it by the good ole boys in your backyard and find a lot of willing converts to the mantra but Jerry is clearly “On Target”.    

John Cox  

From: owner-yak-list-server(at)matronics.com [mailto:owner-yak-list-server(at)matronics.com] On Behalf Of Jerry Painter

 Sent: Tuesday, August 08, 2006 8:19 AM

 To: yak-list(at)matronics.com

 Subject: Maintenance, again  

  

              

Scooter--   

      

    

      

As you see, there   is some serious disagreement about what sort of maintenance an owner/pilot   who is not an A&P is allowed by FAR to perform, to say nothing about what   is SAFE or smart for untrained people to do to your airplane.  Your   widow won't care about the legal niceties.   

      

    

      

Read the   Operating Limitations that accompany your Airworthiness Certificate.    They will clearly tell you that the airplane must be maintained in accordance   with 14 CFR Part 43--NO EXCEPTIONS.  Dennis and I respectfully   disagree about this.  In particular, IMHO, his assertion that Part 43   flat doesn't apply and therefore anyone can perform any sort of maintenance   or repair is especially dangerous advice.  With FAA type certificated   aircraft, with their shelves of manuals and reams of AD's and Service   Bulletins, ALL repairs, major and minor, must be performed by an   A&P.  ALL major repairs must also be APPROVED by an A&P with   Inspection Authorization AND the feds, on a case by case   basis, specifically for the particular airplane being repaired.    It's amazing what simple things the feds consider major repairs.  ALL   repairs have to be done in conformance to the mfrs recommendations and   APPROVED data.  This even applies to repairs/mods for which an STC has   been approved.  That's why every Cessna has a stack of 337's in its   records.  If an A&P with IA can't install a steel nut in place of a   brass nut, even if it has an approved STC, without specific FAA approval of   that particular installation on your particular Cessna or 747, common sense   should tell you not to try to perform repairs or modifications on your Yak or   CJ if you're not an A&P.  In fact, if you read your Ops Limitations   you'll find they tell you the FAA must approve ALL major   repairs/modifications to the aircraft.  Historical experience is on the   side of the FAA.  The fortuitous fact that the feds usually choose not   to involve themselves unless there is a smoking hole and dead   pedestrians should NOT lull you into thinking you can install that new race   modified M-14 or Ford V-8 with those high compression pistons from EBay and   juiced up axial flow supercharger mod from JC Whitney, super lightweight   condolling wheel, high RPM rebofelther and that fancy new propeller you   designed on the back of a napkin and built out of old Styrofoam cups and   Super Glue.  Got a test program?  Are you a qualified engineering   test pilot?  Even if it was legal it's probably not smart.  And   vice versa.  Especially vice versa.  That's why we have an FAA--all   the dead amateurs who tried and the pedestrians they killed.   

      

    

      

If Part 43   doesn't apply, why is a Condition Inspection required and why must it be   performed by an A&P?   

      

    

      

You've read Jim   Selby's concern about getting Yak-18 Russian manuals translated into   English.  If anyone can perform any old sorts of repairs, not just   maintenance, why would the feds care if you have manuals in Russian or   English or any other language?  Don't need no   stinkin' manuals!  Watfo--you gonna do all the repairs and mods   your way on your own any way--ain't and don't need no friggin' manuals for   that!     

      

    

      

Look: lots   of Experimental Exhibition aircraft not only are required to have manuals (in   English), they are required to have an FAA APPROVED maintenance program, just   like an airliner.  Yes, the FAA can be a pain.   

      

    

      

Those of us who   are A&P's cringe when owner maintained/repaired/modified/hacked-up   aircraft show up in our shops.  Some are Yaks/CJ's.  Granted, lots   of things can be and should be done by owners and are allowed by FAR.    Some owners are meticulous and professional in their work.  Most are   not.  Sad to say, but even some licensed people do shoddy work.    Owners are worse.  If you think pop can and shingle nail field repairs   by Chinese/Russian "wholesalers" are bad, look at some owner   performed repairs/mods.  Owners need to do the things most won't pay   others to do for them:  keep it clean, keep it dry, keep fresh oil in   the tank, air (nitrogen) in the tires, money in the bank--preventive   maintenance.  That's why the FAR's allow owners (if they are pilots) to   perform preventive maintenance.  Get a professional you know and trust   to do the rest.  The next time somebody crashes his Experimental   Exhibition airplane into an ice cream parlor or a school and kills a bunch of   kids there will be hell to pay, especially if it has been owner maintained   and modified.  Even if the pilot/owner/maintainer/repairer/modifier is a   Republican (no offense) it won't help.   

      

    

      

Be smart, be   safe.  If you don't know what you're doing, don't do it.  After   all, It's your life and your family's lives that are at stake.   

      

    

      

Jerry Painter

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