Matronics Email Lists :: View topic

Matronics Email Lists
Web Forum Interface to the Matronics Email Lists

Get Email Distribution Too! FAQ Search Memberlist Usergroups Register

Profile Log in to check your private messages Log in

Maintenance, again
Goto page Previous 1, 2

Matronics Email Lists Forum Index -> Yak-List

View previous topic :: View next topic

Author Message

L39parts(at)hotmail.com
Guest

Posted: Tue Aug 08, 2006 5:02 pm Post subject: Maintenance, again

It's not at all clear he was talking only about experimental- amateur built. 

Very few regs are different for experimental-exhibition.



---

dsavarese(at)elmore.rr.co
Guest

Posted: Tue Aug 08, 2006 5:03 pm Post subject: Maintenance, again

Well said Ron.

 Dennis

  

 [quote]   ---

L39parts(at)hotmail.com
Guest

Posted: Tue Aug 08, 2006 5:12 pm Post subject: Maintenance, again

No, no, no. CJs are not experimental- amateur0 built, so don't read those regs to see what you can do on a CJ.  You are0 not qualified to extrapolate the regs from one category to another.

  

 One of those no's is for the "ask the feds"0 comment.  If you ask a low level bureaucrat if you can do something they0 will always say no because it is the easy answer and the safest (for him)0 answer.

  

 Read, or in your case find someone who can0 read, the requirements and do what they says.  When they say they0 don't apply to experimental planes- they don't apply.  Don't read the tax0 code and extrapolate what you think that means when you're trying to sail a0 boat.

 [quote]   ---

L39parts(at)hotmail.com
Guest

Posted: Tue Aug 08, 2006 5:21 pm Post subject: Maintenance, again

You are aware, Doug, that the EAA has a warbird0 division?  They fly experimental exhibition planes, so it's hard to imagine0 that the EAA hasn't heard of these regs, read them, analyzed them,0 etc.

  

 The only way you will get a good answer from a low0 level bureaucrat is to ask him to show you the regs that apply to your0 question.  No is the easy answer, it is the safe answer, and it is the0 answer you will get if you ask if you can do something.  If you don't think0 this is true, ask a fed if it's ok for you to clean the spark plugs in your0 Cessna.  We all know FAR 43 allows this, it's clearly written.  See if0 you can get the fed to say "yes".  It's not in their0 nature. 

  

 [quote]   ---

AV8ORJWC

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

Posted: Tue Aug 08, 2006 5:27 pm Post subject: Maintenance, again

Allan McArtor (1987-1990), was the last FAA administrator to publicly try and bring errant FSDOs in line with one consistent national voice.  5 errant Field Offices do not alter the legal interpretation in Washington, DC where the rubber meets the road.  And they have to look to their Regional office to cover their wild ass personal interpretation if requested to do so.  Getting such a read “in writing” is a physical impossibility and leads to this “Wives’ Tale”.  

   

Only Owner/Builders of Experimentals can do a few of the A & P responsibilities.  Unless being the individual who actually created the bird, being one of the owners in a series of owners and performing Minor and Major Alteration is not a privilege of Warbird owners, no mater how ‘Po or which FSDO the bird flies from.  

   

John Cox  

         

  

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

 Sent: Tuesday, August 08, 2006 10:21 AM

 To: yak-list(at)matronics.com

 Subject: Re: Yak-List: 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: 	
		  0    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   

                           

                

                

                

        	
  



 

     

[i]Larry Pine[/i]

L39parts(at)hotmail.com
Guest

Posted: Tue Aug 08, 2006 5:41 pm Post subject: Maintenance, again

me262pilot(at)comcast.net



I got Earl's address off the posting, but then I guess I'm better at 

research than some people.



---

AV8ORJWC

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

Posted: Tue Aug 08, 2006 6:16 pm Post subject: Maintenance, again

Mr. Lawrence’s title can certainly intimidate and I am impressed as well with the range of his detail. However, this exact subject was specifically addressed to William O’Brien (Chief of Airworthiness) in exhaustive detail at the IA Renewal Seminar held in Portland, OR back in October, 2003.  I was a wild eyed A & P student attending his Part 147 Approved Training School.  I guess I need to see a written authorization and not one from one of the five errant FSDOs or from the internet– one from legal in Washington, DC.  

   

Any individual doing repair services must have the training (yes it can be OJT and it can be a grandchild), the experience, the tools and the yes the correct manuals in the language of the individual attempting to affect repair regardless of their title while performing such work. I think that is where this post began. To sign for such work, the individual must have authorization and have witnessed and/or supervised such activity.  A repairman cannot complete and sign for a Conditional Inspection as implied by Mr. Lawrence. No way.  The written documentation reads that a certified A & P mechanic or Repair Station are the only two compliant entries.  Having held a repairman’s certificate with an approved station, I have firsthand experience from attempting to sign such an authorization in my previous life. This requirement means that only the individual(s) with that Repair Station having such an Inspection Authorization (at that time) may endorse a Return to Service entry.  

   

Experimental Exhibition is not Experimental Kit-build and there lies the continued confusion with Mr. Lawrence’s excellent post.  Each pilot/operator must take responsibility prior to flight, to ensure that the required maintenance is done compliant with the correct written authorization.  Just how wide is the pilots behind? The FAA FSDO Letter of Authorization may indeed require compliance with Part 43.  The scope of the inspection is another matter as documented in Part 43, Appendix D.  Experimental Kit Builders who acquire a Repairman Certificate only have such authority while remaining the owner of that specific aircraft they created.  Experimental Exhibition Warbird Owners, to the best of my knowledge and experience are not granted such authority.  Their authority lies within the scope of Preventative Maintenance and only preventative maintenance.  When it comes to the Minor and Major Alteration or Repair, well now if they are being supervised, all bets are off.  

   

The question before you gentlemen and ladies is…. May you legally perform Minor or Major alterations as a “Po Boy” on an aircraft holding an Experimental Warbird Certificate?  Get it in writing and please post the FAA legal response here.  Each side will hold dear to their beliefs no matter how weakly based in written authorization.  The only “Get out of Jail” card is the one in written form from headquarters legal FAA – DC.  

   

John Cox – “Foto”  

Heavy Check A & P        

  

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

 Sent: Tuesday, August 08, 2006 11:56 AM

 To: yak-list(at)matronics.com

 Subject: Re: Re: 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>[i]Larry Pine[/i]  	
  

        

  

How low will we go? Check out Yahoo! Messenger’s low [url=http://us.rd.yahoo.com/mail_us/taglines/postman8/*http:/us.rd.yahoo.com/evt=39663/*http:/voice.yahoo.com]PC-to-Phone call rates.[/url]

AV8ORJWC

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

Posted: Tue Aug 08, 2006 6:29 pm Post subject: Maintenance, again

There is an (S) on the end, so you see there are many differing standards by District for changing geography, culture, dialect and inflection.  No S, then only one single clear interpretation nationwide.  

   

John  

         

  

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

 Sent: Tuesday, August 08, 2006 2:09 PM

 To: yak-list(at)matronics.com

 Subject: RE: Re: Maintenance, again  

  

     

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

    

   

    

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

    

   

  

Always Yakin,

 Doug Sapp   [quote]  

-----Original Message-----

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

 Sent: Tuesday, August 08, 2006 1:26 PM

 To: yak-list(at)matronics.com

 Subject: RE: Re: 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

 

 --

rvfltd(at)televar.com
Guest

Posted: Tue Aug 08, 2006 6:49 pm Post subject: Maintenance, again

This0 is like herding cats, I quit.

  

 

Always Yakin,

Doug Sapp  [quote]   --

threein60(at)yahoo.com
Guest

Posted: Tue Aug 08, 2006 6:50 pm Post subject: Maintenance, again

John has said it all!  and I agree!!



"John W. Cox" <johnwcox(at)pacificnw.com> wrote:   	  Quote: 	
		                 Mr. Lawrence’s title can certainly intimidate and I am impressed as well with the range of his detail. However, this exact subject was specifically addressed to William O’Brien (Chief of Airworthiness) in exhaustive detail at the IA Renewal Seminar held in Portland, OR back in October, 2003.  I was a wild eyed A & P student attending his Part 147 Approved Training School.  I guess I need to see a written authorization and not one from one of the five errant FSDOs or from the internet– one from legal in Washington, DC.

   

  Any individual doing  repair services must have the training (yes it can be OJT and it can be a grandchild), the experience, the tools and the yes the correct manuals in the language of the individual attempting to affect repair regardless of their title while performing such work. I think that is where this post began. To sign for such work, the individual must have authorization and have witnessed and/or supervised such activity.  A repairman cannot complete and sign for a Conditional Inspection as implied by Mr. Lawrence. No way.  The written documentation reads that a certified A & P mechanic or Repair Station are the only two compliant entries.  Having held a repairman’s certificate with an approved station, I have firsthand experience from attempting to sign such an authorization in my previous life. This requirement means that only the individual(s) with that Repair Station having such an Inspection Authorization (at that time) may endorse a Return to Service  entry.

   

  Experimental Exhibition is not Experimental Kit-build and there lies the continued confusion with Mr. Lawrence’s excellent post.  Each pilot/operator must take responsibility prior to flight, to ensure that the required maintenance is done compliant with the correct written authorization.  Just how wide is the pilots behind? The FAA FSDO Letter of Authorization may indeed require compliance with Part 43.  The scope of the inspection is another matter as documented in Part 43, Appendix D.  Experimental Kit Builders who acquire a Repairman Certificate only have such authority while remaining the owner of that specific aircraft they created.  Experimental  Exhibition Warbird Owners, to the best of my knowledge and experience are not granted such authority.  Their authority lies within the scope of Preventative Maintenance and only preventative maintenance.  When it comes to the Minor and Major Alteration or Repair, well now if they are being supervised, all bets are off.

   

  The question before you gentlemen and ladies is…. May you legally perform Minor or Major alterations as a “Po Boy” on an aircraft holding an Experimental Warbird Certificate?  Get it in writing and please post the FAA legal response here.  Each side will hold dear to their beliefs no matter how weakly based in written authorization.  The only “Get out  of Jail” card is the one in written form from headquarters legal FAA – DC.

   

  John Cox – “Foto”

  Heavy Check A & P

        

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

Sent: Tuesday, August 08, 2006 11:56 AM

To: yak-list(at)matronics.com

Subject: Re: Re: 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>[i]Larry Pine[/i]

	
    

      

   How low will we go? Check out Yahoo! Messenger’s low [url=http://us.rd.yahoo.com/mail_us/taglines/postman8/*http:/us.rd.yahoo.com/evt=39663/*http:/voice.yahoo.com]PC-to-Phone call rates.[/url]



	


Larry Pine



  		Yahoo! Music Unlimited - Access over 1 million songs. [url=http://pa.yahoo.com/*http://us.rd.yahoo.com/evt=36035/*http://music.yahoo.com/unlimited/  ]Try it free.[/url]

viperdoc(at)mindspring.co
Guest

Posted: Tue Aug 08, 2006 7:24 pm Post subject: Maintenance, again

Last time I looked, the cats win everytime.

 Doc

  

 



  

 [quote] ---

viperdoc(at)mindspring.co
Guest

Posted: Tue Aug 08, 2006 9:59 pm Post subject: Maintenance, again

Somewhere in the melie, the question got lost. The question was "does anyone have  translate maintenance manuals for a YAK-18T since their FSDO was requesting it before issuing a certificate?" This evolved into who can perform maintenance on a Warbird (read experimental exhibition). Somewhere in there we have arrived at only an A&P can perform minor or major alterations and/or repairs. The final statement was "all bets are off if these are performed under supervision." 

Well, in my neck of the woods, these acts of preventative maintenance are performed under the supervision  of an certificated A&P or repair station as clearly stated in the FAR 43.3 (d). The fact of the matter is though, I and my hanger mates know more about the aircraft than the A&P. But least the A&P's union get overly concerned, the $ bills are paid to the A&P for his supervisory services and his endorsement in the log books.

Now since we are trying herd cats and rope all the goats, if one goes to the FAA.gov website they will find that FAR section 43.1 (3)[(b) 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.]

Now then I did a search for catagories of experimental aircraft for which none could be found using the FAA's search engine. So out of curiosity, I looked up FAR 23 which defines Airworthiness Standards finding as follows: " 



Federal Aviation Regulation



Part 23 AIRWORTHINESS STANDARDS: NORMAL, UTILITY, ACROBATIC, AND COMMUTER CATEGORY AIRPLANES

Subpart A--General

 

Well the above clearly does not apply to Experimental Aircraft certification. My operating limitations letter defines my aircraft as "Experimental Exhibition". Now looking at FAR part 21.191, the catagories of experimental aircraft certification are defined as:



Federal Aviation Regulations



Part 21 CERTIFICATION PROCEDURES FOR PRODUCTS AND PARTS

Subpart H--Airworthiness Certificates

Sec. 21.191



Experimental certificates.



Experimental certificates are issued for the following purposes:

(a) Research and development. Testing new aircraft design concepts, new aircraft equipment, new aircraft installations, new aircraft operating techniques, or new uses for aircraft.

(b) Showing compliance with regulations. Conducting flight tests and other operations to show compliance with the airworthiness regulations including flights to show compliance for issuance of type and supplemental type certificates, flights to substantiate major design changes, and flights to show compliance with the function and reliability requirements of the regulations.

(c) Crew training. Training of the applicant's flight crews.

(d) Exhibition. Exhibiting the aircraft's flight capabilities, performance, or unusual characteristics at air shows, motion picture, television, and similar productions, and the maintenance of exhibition flight proficiency, including (for persons exhibiting aircraft) flying to and from such air shows and productions.

(e) Air racing. Participating in air races, including (for such participants) practicing for such air races and flying to and from racing events.

(f) Market surveys. Use of aircraft for purposes of conducting market surveys, sales demonstrations, and customer crew training only as provided in Sec. 21.195.

(g) Operating amateur-built aircraft. Operating an aircraft the major portion of which has been fabricated and assembled by persons who undertook the construction project solely for their own education or recreation.

[(h) Operating primary kit-built aircraft.] Operating a primary category aircraft that meets the criteria of Sec. 21.24(a)(1) that was assembled by a person from a kit manufactured by the holder of a production certificate for that kit, without the supervision and quality control of the production certificate holder under Sec. 21.184(a).

[ (i) Operating light-sport aircraft. Operating a light-sport aircraft that- 

(1) Has not been issued a U.S. or foreign airworthiness certificate and does not meet the provisions of §103.1 of this chapter. An experimental certificate will not be issued under this paragraph for these aircraft after January 31, 2008; 

(2) Has been assembled- 

(i) From an aircraft kit for which the applicant can provide the information required by §21.193 (e); and 

(ii) In accordance with manufacturer's assembly instructions that meet an applicable consensus standard; or (3) Has been previously issued a special airworthiness certificate in the light- sport category under 

§21.190.]



Now looking farther, FAR part 21.193 farther defines certification procedures for an experimental aircraft defined as follows:



Federal Aviation Regulations

Part 21 CERTIFICATION PROCEDURES FOR PRODUCTS AND PARTS

Subpart H--Airworthiness Certificates

Sec. 21.193



Experimental certificates: general.



An applicant for an experimental certificate must submit the following information:

(a) A statement, in a form and manner prescribed by the Administrator setting forth the purpose for which the aircraft is to be used.

(b) Enough data (such as photographs) to identify the aircraft.

(c) Upon inspection of the aircraft, any pertinent information found necessary by the Administrator to safeguard the general public.

(d) In the case of an aircraft to be used for experimental purposes--

(1) The purpose of the experiment;

(2) The estimated time or number of flights required for the experiment;

(3) The areas over which the experiment will be conducted; and

(4) Except for aircraft converted from a previously certificated type without appreciable change in the external configuration, three-view drawings or three-view dimensioned photographs of the aircraft.

[(e) In the case of a light-sport aircraft assembled from a kit to be certificated in accordance with §21.191 (i)(2), an applicant must provide the following: 

(1) Evidence that an aircraft of the same make and model was manufactured and assembled by the aircraft kit manufacturer and issued a special airworthiness certificate in the light-sport category. 

(2) The aircraft's operating instructions. 

(3) The aircraft's maintenance and inspection procedures. 

(4) The manufacturer's statement of compliance for the aircraft kit used in the aircraft assembly that meets §21.190 (c), except that instead of meeting §21.190 (c)(7), the statement must identify assembly instructions for the aircraft that meet an applicable consensus standard. 

(5) The aircraft's flight training supplement. 

(6) In addition to paragraphs (e)(1) through (e)(5) of this section, for an aircraft kit manufactured outside of the United States, evidence that the aircraft kit was manufactured in a country with which the United States has a Bilateral Airworthiness Agreement concerning airplanes or a Bilateral Aviation Safety Agreement with associated Implementation Procedures for Airworthiness concerning airplanes, or an equivalent airworthiness agreement. ]



IF I inturpt this correctly, the sections (a),(b) and (c) would apply to our aircraft as to certification, hence the operating limitations letter. A pretty wide brush is given to the Adminstrator to safeguard the general public. Nowhere in this thesis have I found anything concerning the maintenance being performed by a certificated A&P only. I only found that the annual "condition inspection" shall be performed by the appropriately certificated FAA mechanic or inspection station.

So, we are back to what is stated in FAR 43.1 (3)[bThis 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.] concerning periodic maintenance on experimental aircraft. That being since FAR 21.191 defines our aircraft as being certificated as"EXPERIMENTAL". The "Exhibition" is defined as the purpose of the certificate only. My "Operation Program Letter for the Special Certificate of Airworthiness, Experimental-Exhibition" difines my aircraft as EXPERIMENTAL. Therefore, it holds an "experimental' certificate!

So this leads us back to what started this "Goat Rope", who can perform maintenance on an "EXPERIMENTAL" aircraft? I CAN and you can!

Now am I stupid...no...I do seek the appropriate council and guidance from my A&P and the other YAK gerus when needing to perform preventative maintenance on my "EXPERIMENTAL" aircraft who's purpose is "exhibition". I prefer to keep my rosey pink ars in the current whole condition not spread as parts strained thru the back side of a smoking hole because of my stupidity. So saying all that, I have my A&P look over what I have done to hopefully make sure that I have not overlooked something.

Gentlemen: Open the Gates! The goats are off and running along with the cats continuing to be unrulely! 43.1 (3) [b] says it all in black and white with gray being excluded.

Doc

dsavarese(at)elmore.rr.co
Guest

Posted: Wed Aug 09, 2006 3:34 am Post subject: Maintenance, again

Roger has clearly expounded on my first reply to Larry in0 which I also said to read FAR 43.1(b).  Well done Roger.

 Dennis

  

 [quote]   ---

david(at)mcgirt.net
Guest

Posted: Wed Aug 09, 2006 5:22 am Post subject: Maintenance, again

So basically what you are all telling me, I did pay to much for my car

insurance..  damn..



0



0



0



0



( FOR THOSE A LITTLE TO WOUND TIGHT, THAT WAS A JOKE )



0



0



0



Good healthy discussion though.

David



0



0



0



  _____ 0



From: owner-yak-list-server(at)matronics.com

[mailto:owner-yak-list-server(at)matronics.com] On Behalf Of A. Dennis Savarese

Sent: Wednesday, August 09, 2006 7:34 AM

To: yak-list(at)matronics.com

Subject: Re: Re: Maintenance, again



0



Roger has clearly expounded on my first reply to Larry in which I also said

to read FAR 43.1(b).  Well done Roger.



Dennis



0



---

n13472(at)aol.com
Guest

Posted: Wed Aug 09, 2006 1:33 pm Post subject: Maintenance, again

Strange thing here it appears that the BULK of the people that think A/P's are required for our

   aircraft are "A&P's" EH a little protectionisom at work.

    

   Tom Elliott

 CJ-6A

 NX63727

 SANDY VALLEY NV

    

  

 --

L39parts(at)hotmail.com
Guest

Posted: Wed Aug 09, 2006 5:48 pm Post subject: Maintenance, again

I seem to be having some problems with my computer-0 not a single FAR came through.  Read 14CFR65.104.  It0 says:

  

 "(b) The holder of a repairman certificate0 (experimental aircraft builder) may perform condition inspections on the  aircraft constructed by the holder in accordace with the operating limitations0 of that aircraft."

  

 This does not apply to experimental- exhibition0 aircraft.  The ops limits of all of those that I have read say that the0 condition inspection must done by an A&P,  not an IA.

  

 But I'll call you if I ever need a D0 check.

 [quote]   ---

Display posts from previous:

	Matronics Email Lists Forum Index -> Yak-List	All times are GMT - 8 Hours Goto page Previous 1, 2
Page 2 of 2

Jump to:

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