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jim jewell
Joined: 09 Jan 2006
Posts: 82
Location: Kelowna B.C. Canada
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 Posted: Tue Nov 07, 2006 8:41 pm Post subject: MDRA rule change |
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Canadian interest content follows,
My RV6-a is a 180 horse lycoming with C/S night VFR The empty weight came in
at 1135 lb.
A month or two ago I registered my RV6-a with the MOT. The application
included a requested gross weight which I set at 1775 lb.
A week later I received the as applied for registration which now resides in
the aircraft as required. No changes indicated or requested.by the MOT.
My local inspector is an acquaintance. His inspection process was
professional diligent and
helpful in all regards. He is a highly trained aircraft structural AME. by
trade with an all consuming interest in aviation.
Yesterday upon having completed the final inspection process of my RV6-a he
had to inform me of the following;
It has been decided that the maximum gross weight during the 25 hr. flight
test period will be set by the MDRA at the kit manufacturers stated (in my
case 1650 lb.) regardless of the
applicant's requested weight.
It is as yet unclear to me and the inspector exactly how this will effect my
intention to maintain the previously applied for and accepted 1775 maximum
gross weight.
Is this little more than a mild shifting of weight by the MDRA with little
or no effect on the builders?
Will I have to re-test the aircraft for some as yet undetermined additional
flight period?.
It might mean that I have to re-do the gross weight climb test at the
requested 1775 lb. weight.
Will the onus be on me to go through a structural testing regime to prove
the airframe is up to the task.
The first three options can be complied with, the later would of course be
out of the question.
I have no word from the MDRA administration or the local provincial rep. as
to the why's and how's this rule change was arrived at. No advance warning.
No background or explanations offered to the local inspector. No word as to
where this will leave me in dealing with the MOT ? I was informed that after
the 25 hr. test period I will be on my own with the MOT. in this regard.
No opportunity at all to have input on the matter!
My bet is that after turning over one or two rocks in this pile,, a lawyer
will be found !?
Jim in Kelowna
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rv7(at)b4.ca
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| Posted: Tue Nov 07, 2006 11:16 pm Post subject: MDRA rule change |
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On 20:41:18 2006-11-07 "Jim Jewell" <jjewell(at)telus.net> wrote:
| Quote: | A month or two ago I registered my RV6-a with the MOT. The application
included a requested gross weight which I set at 1775 lb.
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What criteria did you use to arrive at this new gross weight? Did you do
any structural analysis of the airframe to confirm that it will handle the
increased gross weight? What will be your aerobatic gross weight? Are you
increasing that as well? What analysis have you done to support those
numbers? Has anyone done analysis to show that the RV-6 will operate
safely at 1775 gross and CAR/FAR Part 23 limits?
| Quote: | Will the onus be on me to go through a structural testing regime to
prove the airframe is up to the task.
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No offense intended, but if you haven't gone through the structural
testing, or know of someone who has, or perhaps have the blessing in
writing from Van's Aircraft, I would go so far as to say you are foolhardy
to request the increased gross weight in the first place. Why not just
request the book gross weight, and load it up with whatever you want to?
It's no safer.
Please keep in mind that when building an RV-6 as per the plans, the kit
manufacturer's engineering analysis limits the airframe to a specific gross
weight. If you have made structural changes to the airframe to raise that
gross weight, you are no longer building a Van's RV-6. You are building a
Jim Jewell Mk. 1, and Transport Canada has every right to request your
engineering justification for every structural piece on the aircraft. If
you haven't made structural changes, you're taking a risk with yourself and
your passengers.
Many RV-6's have been built and registered at gross weights over the Van's
limit. It doesn't make it safe.
-Rob
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jim jewell
Joined: 09 Jan 2006
Posts: 82
Location: Kelowna B.C. Canada
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| Posted: Wed Nov 08, 2006 2:23 am Post subject: MDRA rule change |
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Hi Rob,
As far as the blessing letter from Van goes, a copy of one exists and is
being sent to me to use in defence of my request should I desire to go
forward with the !750 LB propposed gross weight.
"Fortunately, in the case of the RV-6/6A, there is an out. Some years ago
(probably in a weak moment) Vans released a letter suggesting, in some
roundabout language, that operation at weights up to 1750 lbs was
permissible with a reduced CG range at the higher weights. Curt Reimer,
a fellow RV-6er here in Winnipeg, was able to locate a copy of this
letter and we both were able to use it as supporting documentation to
get a gross weight of 1750 lbs authorized for the initial 25hr "test"
period".
No offence taken Rob.
Jim
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khorton01(at)rogers.com
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| Posted: Wed Nov 08, 2006 5:43 am Post subject: MDRA rule change |
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There are two very separate issues here - what is safe? and what is required by the regulations? This is one of many areas where simply complying with the regs is not sufficient to have a safe operation, and just because something is safe does not mean that it is allowed by the regs.
Safety - obviously an increase in weight puts higher loads on the structure, and the aircraft must be operated differently if safe margins are to be maintained. Builders should operate at lower load factors, avoid rough runways and hard landings, avoid strong winds, etc.
Regs - I see nothing in CAR 549 or Airworthiness Manual (AWM) 549 that gives the MDRA a mandate to require engineering analysis for weight increases. AWM 549.19 says:
549.19 Inspections and Maintenance
(a) During fabrication and after final assembly the aircraft shall be inspected for workmanship and general serviceability according to a schedule acceptable to the Minister. Particular attention shall be paid to enclosed areas of the primary structure, which are not visible after final assembly.
Information Note: (Ref. AMA 549/1A, paragraph 7).
Airworthiness Manual Advisory (AMA) 549/1A has been There are two very separate issues here - what is safe? and what is required by the regulations? This is one of many areas where simply complying with the regs is not sufficient to have a safe operation, and just because something is safe does not mean that it is allowed by the regs.
Safety - obviously an increase in weight puts higher loads on the structure, and the aircraft must be operated differently if safe margins are to be maintained. Builders should operate at lower load factors, avoid rough runways and hard landings, avoid strong winds, etc.
Regs - I see nothing in CAR 549 or Airworthiness Manual (AWM) 549 that gives the MDRA a mandate to require engineering analysis for weight increases. AWM 549.19 says:
549.19 Inspections and Maintenance
(a) During fabrication and after final assembly the aircraft shall be inspected for workmanship and general serviceability according to a schedule acceptable to the Minister. Particular attention shall be paid to enclosed areas of the primary structure, which are not visible after final assembly.
Information Note: (Ref. AMA 549/1A, paragraph 7).
Airworthiness Manual Advisory (AMA) 549/1A has been superseded by AMA549/1B, which says:
by AMA549/1B, which says:
3. Background and Discussion .... Given that Transport Canada policy is to keep the airworthiness standards for amateur-built aircraft to a minimum, Chapter 549 of the Airworthiness Manual contains the parameters necessary to define an aircraft as being eligible for designation in this category, and minimum requirements for instruments, equipment and operating information necessary to be eligible for a special C of A for amateur‑built aircraft. ...
The section on Design and Construction makes no mention whatsoever about engineering analysis of structure.
The section on Inspections makes no mention of an assessment of the design from an engineering point of view.
The only limits on weight are the max weight for the category, and the max wing loading to avoid being classifed as a high performance aircraft. It is worth noting that some Canadian RV and Rocket builders have declared max gross weights that mean the aircraft is classified as a high performance aircraft, which means the pilot needs a type rating to legally fly the aircraft. This has not been noticed by Transport Canada, but I fear that an insurance company could use this to claim that the pilot was not qualified to fly the aircraft, and thus they did not have to pay out.
The MDRA should be challenged here. It is OK for them to remind builders that the laws of physics haven't changed since Van designed the aircraft, and that weight increases may reduce safety. But they should not be allowed to require engineering analysis on the fly.
Kevin Horton
Ottawa, Canada
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hansconser(at)gmail.com
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| Posted: Wed Nov 08, 2006 8:50 am Post subject: MDRA rule change |
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Jim, I need a copy of that letter... (Please)
Hans
On Nov 8, 2006, at 3:24 AM, Jim Jewell wrote:
[quote]
Hi Rob,
As far as the blessing letter from Van goes, a copy of one exists and
is being sent to me to use in defence of my request should I desire to
go forward with the !750 LB propposed gross weight.
"Fortunately, in the case of the RV-6/6A, there is an out. Some years
ago
(probably in a weak moment) Vans released a letter suggesting, in some
roundabout language, that operation at weights up to 1750 lbs was
permissible with a reduced CG range at the higher weights. Curt Reimer,
a fellow RV-6er here in Winnipeg, was able to locate a copy of this
letter and we both were able to use it as supporting documentation to
get a gross weight of 1750 lbs authorized for the initial 25hr "test"
period".
No offence taken Rob.
Jim
---
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