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pdn8r(at)yahoo.com
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 Posted: Sat Nov 14, 2009 5:42 am Post subject: EAA info to Tech Counselors Re: XL |
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Received the below from EAA regarding the XL. Answers some questions being asked about who can perform the upgrades.
Dear EAA Technical Counselor;<?xml:namespace prefix = o ns = "urn:schemas-microsoft-com:office:office" />
I’m sure you are all aware that there have been a number of accidents involving Zenith CH 601XL and related aircraft in which the aircraft suffered an in-flight structural failure or breakup. This situation has resulted in the FAA’s issuance of [url=mhtml:{AFEFE507-23AC-4B51-A138-6B0DECDA139E}mid://00000003/!x-usc:http://rgl.faa.gov/Regulatory_and_Guidance_Library/rgSAIB.nsf/(LookupSAIBs)/CE-10-08?OpenDocument]Special Airworthiness Information Bulletin[/url] (SAIB) CE-10-08 and the release by Aircraft Manufacturing & Design LLC (AMD) of a [url=mhtml:{AFEFE507-23AC-4B51-A138-6B0DECDA139E}mid://00000003/!x-usc:http://www.newplane.com/amd_downloads/SAFETY%20ALERT%20November%207%202009.pdf]safety alert dated November 7th, 2009[/url].
Chris Heinz, designer of the CH 601XL and CH 650 aircraft issued a [url=mhtml:{AFEFE507-23AC-4B51-A138-6B0DECDA139E}mid://00000003/!x-usc:http://www.zenithair.com/zodiac/xl/data/qa-chris-heintz-1a.pdf]Question and Answer document[/url] addressing the issue in which he urges all owners/operators of these aircraft to comply with the AMD service directive even if they are not required by regulation to do so. The following is a quote from the Q&A document;
“Owners of an SLSA (AMD-built) Zodiac must comply with the factory-issued Safety Alert. Owners of a self-built “Experimental” Zodiac are officially the manufacturer of their aircraft and are therefore technically free to install (or not) the upgrades. As the designer of the aircraft, I am strongly urging all owners who operate their CH 601 XL/CH 650 to install the upgrades now being proposed before the next flight. You, more than anyone, know how damaging and demoralizing the doubts and questions regarding the aircraft have been; how they have affected the confidence that many have in the design. Stronger airplanes and better prepared pilots should help us all restore the reputation and desirability of these airplanes you have put so much of yourself into. If for no other reason, install the “Upgrade Package” to maximize resale value of your project: I anticipate that the cost of the Upgrade will be much lower that the increase in resale value”.
EAA urges you to share this info with builders and owners/operators of Zenith CH 601XL and CH 650 in your area. You may also wish to make them aware of the [url=mhtml:{AFEFE507-23AC-4B51-A138-6B0DECDA139E}mid://00000003/!x-usc:http://www.zenithair.com/zodiac/xl/data/doc369.pdf]independent analysis[/url] of the design, as well as the [url=mhtml:{AFEFE507-23AC-4B51-A138-6B0DECDA139E}mid://00000003/!x-usc:http://www.zenithair.com/zodiac/xl/data/6-ZU-1-2-3%20NOV%208.pdf]drawings outlining the upgrade[/url] outlined in the AMD safety alert. Be sure to remind owners of the SLSA aircraft that they are required to comply with the safety directive. While owners of ELSA and amateur-built versions of the design are not specifically required to comply with the safety directive, you should remind them that they are required to maintain and operate their aircraft in a condition for safe operation and the safety of flight issues pointed out in the safety directive must be addressed in some fashion. Note that Chris Heinz strongly urges owners of experimental versions of the aircraft to install the upgrades. EAA concurs with this recommendation.
You may wish to remind owners of the experimental-certificated aircraft that the safety directive’s requirement for an A&P mechanic make the modifications only applies to the SLSA versions of the aircraft. Owners of the experimental aircraft are not bound by this requirement and are free to perform the upgrade themselves.
EAA will continue to post updates on this issue on our website, [url=mhtml:{AFEFE507-23AC-4B51-A138-6B0DECDA139E}mid://00000003/!x-usc:http://www.eaa.org/]www.eaa.org[/url]. Encourage builders, owners and operators of these aircraft to visit the website often for new developments. The current story can be seen [url=mhtml:{AFEFE507-23AC-4B51-A138-6B0DECDA139E}mid://00000003/!x-usc:http://www.eaa.org/news/2009/2009-11-09_Zodica%20Issued%20Alert.asp]here[/url].
Thanks for your continued dedication to your fellow EAA members.
Regards,
Joe
Joe Norris
EAA 113615 Lifetime
Homebuilders Community Manager
EAA—The Spirit of Aviation
Bill Pagan EAA Tech Counselor #4395
601XL QBK/Corvair/N565BW (RES)
[quote][b]
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leinad
Joined: 19 Sep 2006
Posts: 283
Location: Central Virginia
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| Posted: Sat Nov 14, 2009 8:12 am Post subject: Re: EAA info to Tech Counselors Re: XL |
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Paul,
I think you're going by old news. The document you are referring to (the one to tech counselors) also says that Experimental builders are free to incorporate the changes or not, as the builder is the "manufacturer". The FAA has since said they will issue no new airworthiness certificates on planes of the 601xl design until the AMD modifications are complied with Experimental or otherwise.
It seams clear Zenith is not interperetting these rulings the way I am, or they wouldn't be about to sell kits to all sorts of builders and owners. I just wish the ruling were more explicit that the experimental builder doesn't have to comply with the "must be done by an FAA certified mechanic" and "must be approved" by parts of the AMD safety alert. I don't find vague words like "consistent with" helpful when I'm about to undergo a couple month effort the FAA could use to deny my airworthiness certificate on a technicality.
I think I may ask for the EAA's help in getting the FAA to clarify their language.
Dan
[quote="pdn8r(at)yahoo.com"]Received the below from EAA regarding the XL. Answers some questions being asked about who can perform the upgrades.
Dear EAA Technical Counselor;<xml>
I’m sure you are all aware that there have been a number of accidents involving Zenith CH 601XL and related aircraft in which the aircraft suffered an in-flight structural failure or breakup.� This situation has resulted in the FAA’s issuance of [url=mhtml:{AFEFE507-23AC-4B51-A138-6B0DECDA139E}mid://00000003/!x-usc:http://rgl.faa.gov/Regulatory_and_Guidance_Library/rgSAIB.nsf/(LookupSAIBs)/CE-10-08?OpenDocument]Special Airworthiness Information Bulletin[/url] (SAIB) CE-10-08 and the release by Aircraft Manufacturing & Design LLC (AMD) of a [url=mhtml:{AFEFE507-23AC-4B51-A138-6B0DECDA139E}mid://00000003/!x-usc:http://www.newplane.com/amd_downloads/SAFETY%20ALERT%20November%207%202009.pdf]safety alert dated November 7th, 2009[/url].
Chris Heinz, designer of the CH 601XL and CH 650 aircraft issued a [url=mhtml:{AFEFE507-23AC-4B51-A138-6B0DECDA139E}mid://00000003/!x-usc:http://www.zenithair.com/zodiac/xl/data/qa-chris-heintz-1a.pdf]Question and Answer document[/url] addressing the issue in which he urges all owners/operators of these aircraft to comply with the AMD service directive even if they are not required by regulation to do so. The following is a quote from the Q&A document;
“Owners of an SLSA (AMD-built) Zodiac must comply with the factory-issued Safety Alert. Owners of a self-built “Experimental” Zodiac are officially the manufacturer of their aircraft and are therefore technically free to install (or not) the upgrades. As the designer of the aircraft, I am strongly urging all owners who operate their CH 601 XL/CH 650 to install the upgrades now being proposed before the next flight. You, more than anyone, know how damaging and demoralizing the doubts and questions regarding the aircraft have been; how they have affected the confidence that many have in the design. Stronger airplanes and better prepared pilots should help us all restore the reputation and desirability of these airplanes you have put so much of yourself into. If for no other reason, install the “Upgrade Package” to maximize resale value of your project: I anticipate that the cost of the Upgrade will be much lower that the increase in resale value”.
EAA urges you to share this info with builders and owners/operators of Zenith CH 601XL and CH 650 in your area. You may also wish to make them aware of the [url=mhtml:{AFEFE507-23AC-4B51-A138-6B0DECDA139E}mid://00000003/!x-usc:http://www.zenithair.com/zodiac/xl/data/doc369.pdf]independent analysis[/url] of the design, as well as the [url=mhtml:{AFEFE507-23AC-4B51-A138-6B0DECDA139E}mid://00000003/!x-usc:http://www.zenithair.com/zodiac/xl/data/6-ZU-1-2-3%20NOV%208.pdf]drawings outlining the upgrade[/url] outlined in the AMD safety alert. Be sure to remind owners of the SLSA aircraft that they are required to comply with the safety directive. While owners of ELSA and amateur-built versions of the design are not specifically required to comply with the safety directive, you should remind them that they are required to maintain and operate their aircraft in a condition for safe operation and the safety of flight issues pointed out in the safety directive must be addressed in some fashion. Note that Chris Heinz strongly urges owners of experimental versions of the aircraft to install the upgrades. EAA concurs with this recommendation.
You may wish to remind owners of the experimental-certificated aircraft that the safety directive’s requirement for an A&P mechanic make the modifications only applies to the SLSA versions of the aircraft. Owners of the experimental aircraft are not bound by this requirement and are free to perform the upgrade themselves.
EAA will continue to post updates on this issue on our website, [url=mhtml:{AFEFE507-23AC-4B51-A138-6B0DECDA139E}mid://00000003/!x-usc:http://www.eaa.org/]www.eaa.org[/url]. Encourage builders, owners and operators of these aircraft to visit the website often for new developments. The current story can be seen [url=mhtml:{AFEFE507-23AC-4B51-A138-6B0DECDA139E}mid://00000003/!x-usc:http://www.eaa.org/news/2009/2009-11-09_Zodica%20Issued%20Alert.asp]here[/url].
Thanks for your continued dedication to your fellow EAA members.
Regards,
Joe
Joe Norris
EAA 113615 Lifetime
Homebuilders Community Manager
EAA—The Spirit of Aviation
Bill Pagan EAA Tech Counselor #4395
601XL QBK/Corvair/N565BW (RES)
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z601a(at)anemicaardvark.c
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| Posted: Sat Nov 14, 2009 8:57 am Post subject: EAA info to Tech Counselors Re: XL |
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I agree that the wording and situation is confusing.
Suggestion: Contact your local FSDO for clarification. They're the ones who
are responsible, and the ones who will determine if what you did is
acceptable. They are responsible for all general aviation modifiation and
repair in their region of authority, and all mechanics and DARs in their
region effectively report to them. If the EAA tells us something, we do it,
and the FSDO does not agree, we're up the creek.
While the EAA can be quite helpful, what they tell us does not have the force
of an FAA interpretation. If what the FSDO says still makes no sense, it may
be time to seek help from the EAA in resolving the issue so that all FSDOs
are in agreement, and are telling us the same thing. But that's different and
distinct from asking the EAA what we should do.
The FSDOs are supposed to be in agreement, and giving the same guidance. I've
found in practice that this is not always the case, and that it is sometimes
necessary to elevate the issue to a higher level. FSDOs, like the rest of us,
sometimes unintentionally put their own interpretation on things.
Therefore, please do not take the following as guidance, but as an opinion:
what I would have expected is that, since this is a major modification, the
work done to LSAs and ELSAs should be done by a person certificated to
perform major modifications to those aircraft.
EABs not yet licensed should have the modifications approved at the time of
DAR inspection. That is, the builder would do the modifications at the time
of construction.
I would have expected that experimentals already licensed could be modified by
the person building that aircraft, if he/she holds a repairman's certificate
for that aircraft. If the FSDO takes a different interpretation, that is a
departure from existing FAA rules, and it is time for the bigger guns to step
in, and get things resolved.
I would also expect that those building from plans could fabricate equivalent
parts, and would not need to buy the upgrade kit from Zenith.
I don't believe Zenith can police who is doing the modifcation, or to what
aircraft. That being the case, I don't find it surprising that they would be
willing to sell the "upgrade" kit to anyone.
But I emphasize: the FSDO is in charge, and we must either do what they
ultimately agree is required, or we won't get are aircraft approved. If
someone brings me one of these things for the modifications, the first thing
I'm going to do is call the local FSDO for guidance. I, too, find what we
have confusing, and I'd be reluctant to sign a log book based on it.
--
=============================================
Do not archive.
=============================================
Jim B Belcher
BS, MS Physics, Math, Computer Science
A&P/IA
Retired aerospace technical manager
Mathematics and alcohol do not mix.
Do not drink and derive.
=============================================
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