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threein60(at)yahoo.com
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 Posted: Wed Aug 09, 2006 3:27 pm Post subject: Last attempt then I'm out!! (maintenance) |
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It is amazing how venomous some of you get with your comments. A legit question was asked pertaining to maintenance and who can accomplish it. There are a few on here that have direct experience in this field and others that know what they have been told and if you disagree you are pulling stuff out your ass or being told you have no clue what you are talking about. I will try this again and we’ll see how it goes. I have contacted two different FSDOs that I am familiar with and have done work with and as predicted, I got two different answers. So let me share with you exactly what I have been told and you make your own mind up.
<?xml:namespace prefix = o ns = "urn:schemas-microsoft-com:office:office" />
First the question came up, Why is the FAA requiring maintenance manuals. As quoted by someone on line…. They are worthless! FAA Order 8130.2F (64-2) states on the initial inspection of the aircraft by an inspector “A review of military maintenance manuals and modification records affecting the subject aircraft is current status and maintenance, for example, the military equivalent to the FAA AD’s.”
Next, who can perform maintenance on an experimental Exhibition aircraft? FAA Order 8130.2F States, “The ability of civilian operators to maintain and operate these aircraft depends on their background and experience, training and facilities, availability of technical manuals and design information, and the complexity of the aircraft involved. To this end and to the maximum extent feasible, it is the policy off the FAA to recognize the most complete sources of maintenance and training and to encourage owners, operators, and flightcrew to use these sources and successfully complete required training from a recognized training organization.”
What must be done… FAA Order 8130.2F section 10 (C-4) States, “Aircraft under 800HP must be inspected each year in accordance with an inspection plan that contains the scope and detail of appendix D to Part 43.”
What is an improved inspection plan? There are four main types but two are the most common as called out in FAA 8300.10. You can either submit your own maintenance program letter that includes the scope and detail of appendix 43.13 app D, or you can choose to comply with the inspection program recommended by the applicable military service under FAR sect 91.409 (f) (3).
As to exhibition experimental the same as experimenal. Exibition is a sub catogory or experimental. We do not abid to Experimetal (homebuilt) maintenance rules. Only those spelled out in your letter of limitations and 8130. They are not the same. In Experimetal (homebuilt) it does say that you will perform an annual inspection and signed off by an appropriate authoried person or shop. That is not stated in 8130.
FAA Order 8130, is a boiler plate outline for Certification and Operation of aircraft under the Experimental purposes of Exhibition and Air Racing. These are the parts that the FAA must include in your letter or limitations. As you see there are some big holes as to who can do what. I was told by the Arizona FSDO that the inspector has latitude to add more requirements then are written on this boiler plate. AZ does not add a line for who should do maintenance. <?xml:namespace prefix = st1 ns = "urn:schemas-microsoft-com:office:smarttags" />Alabama on the other had does. No other FARs or Orders pertain directly with our aircraft and maintenance. That is it! Bottom line, there is no one set way of doing anything because it is not spelled out on 8130. You must do what ever your own operating limitations states. The rest is your ability and conscience.
Ready for the snakes and venom again.!!!
Larry Pine
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dsavarese(at)elmore.rr.co
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| Posted: Wed Aug 09, 2006 5:20 pm Post subject: Last attempt then I'm out!! (maintenance) |
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Larry,
Please indicate the applicable paragraph or paragraphs in0 8130.2F that states FAA approved maintenance manuals are required for issuance0 of the Special Airworthiness Certificate in the Experimental Exhibition0 category.
Dennis
[quote] ---
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dsavarese(at)elmore.rr.co
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| Posted: Wed Aug 09, 2006 5:28 pm Post subject: Last attempt then I'm out!! (maintenance) |
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Larry,
Inspected to the "scope and detail of FAR 43 Appendix D" is0 all that is required. Period. It only means that any inspection plan0 must meet the scope and detail of Appendix D. There is nothing that says0 "approved" anywhere. You can write your own inspection plan as long as0 it meets the "scope and detail of Appendix D". You are really taking0 this to extreme.
Dennis
[quote] ---
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L39parts(at)hotmail.com
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| Posted: Wed Aug 09, 2006 6:22 pm Post subject: Last attempt then I'm out!! (maintenance) |
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I agree with most of this, but you quote FAA Order 8130.2F section 10 (C-4) , “Aircraft0 under 800HP must be inspected each year in accordance with an inspection plan0 that contains the scope and detail of appendix D to Part 43". 0 Quoting the regs/orders is good, but then you go off on a tangent in0 the next paragraph by asking "What is an improved inspection0 plan?"
An improved inspection plan would be one that is0 better than the old one. On a related note, an APPROVED maintenace plan is0 what is required for piston exhibition planes of over 800 HP and for jets. 0 It has to be submitted to FSDO and get their stamp on it.
[quote] ---
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threein60(at)yahoo.com
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| Posted: Wed Aug 09, 2006 6:26 pm Post subject: Last attempt then I'm out!! (maintenance) |
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Dennis,
I gave you the facts directly from the FAA. You make your own mind up as to how you view them. I was told (By the FAA) 43.13 does not apply to Exhibition Experimental. It can be used as a guide line buy 43.13 pertains to certified aircraft. The letter below should have been great news to all that do there own maintenance. Do what ever is on you letter of limitations and that is it. If not listed... NO A&P, NO IA, just you and your good judgment. This was directly from the Feds themself. I didn't make it up. Trust me! Dennis if you wish contact me off line and I will give you the name and number of my FSDO contact and you can ask..
I believe the work APPROVED is actually in 91.409. Everyone in this catagory should read Order 8130.2
"A. Dennis Savarese" <dsavarese(at)elmore.rr.com> wrote:
[quote] Larry,
Inspected to the "scope and detail of FAR 43 Appendix D" is all that is required. Period. It only means that any inspection plan must meet the scope and detail of Appendix D. There is nothing that says "approved" anywhere. You can write your own inspection plan as long as it meets the "scope and detail of Appendix D". You are really taking this to extreme.
Dennis
[quote] ---
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dsavarese(at)elmore.rr.co
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| Posted: Wed Aug 09, 2006 6:45 pm Post subject: Last attempt then I'm out!! (maintenance) |
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Larry,
FWIW, I have read and re-read not only 8130.2F and ALL of its0 predecessors for the last 8 years. Why? Because I have had0 to understand and interpret them inside and out. And I have0 cussed and discussed all the issues you refer to more times than I care to think0 about. Now I am out of this discussion...........
Dennis
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threein60(at)yahoo.com
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| Posted: Wed Aug 09, 2006 6:47 pm Post subject: Last attempt then I'm out!! (maintenance) |
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I am so trying trying to get out of this conversation!! It states that to register in Exh Exp, one of the requirments it to submit an approved maintenance plan. So what is approved? That is where the other section comes in 91. This section is for inspector and what they need to look at in order to certify aircraft. Look folks I has just trying to get at the truth because it is not written, it is left open to interpretation. That is where the problem is. 8130 is a boiler plate or template. Not the end all bet all. The inspector as room to add other requirments as he sees fit.
OK this time I mean it I'm out!! Have fun!!
Ron Davis <L39parts(at)hotmail.com> wrote:
[quote] I agree with most of this, but you quote FAA Order 8130.2F section 10 (C-4) , “Aircraft under 800HP must be inspected each year in accordance with an inspection plan that contains the scope and detail of appendix D to Part 43". Quoting the regs/orders is good, but then you go off on a tangent in the next paragraph by asking "What is an improved inspection plan?"
An improved inspection plan would be one that is better than the old one. On a related note, an APPROVED maintenace plan is what is required for piston exhibition planes of over 800 HP and for jets. It has to be submitted to FSDO and get their stamp on it.
[quote] ---
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L39parts(at)hotmail.com
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| Posted: Thu Aug 10, 2006 4:33 pm Post subject: Last attempt then I'm out!! (maintenance) |
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Read what you wrote- the part in quotes. The0 word approved is not in there for prop planes. It is in the section on0 jets, but if you're talking CJs, it doesn't say "approved maintenance0 plan". If you don't beleive what you wrote, read the order (page0 166).
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