bicyclop(at)pacbell.net
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 Posted: Wed Jul 13, 2011 11:12 am Post subject: Operating limitations. was Viking Engine |
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Charlie,
You did indeed say so. Sorry that I didn't refer back to your e-mail when I wrote mine. I would have seen that.
I agree that very few operational changes would require phase 1. I also think that people should be very careful with fueling and fuel system changes (and other powerplant changes), regardless of the regulatory requirements. Prudence should dictate that no passengers be carried while doing new things. I imposed a 5 hour no passenger period on myself when I overhauled our engine, not out of any requirement, but from an abundance of caution.
Don't know if they changed because of 9-11. My oplims are actually much less restrictive than the earlier version. True, I have to notify, but the earlier version basically just said no no no. Van Nuys FSDO, in a populated area, is indeed hard to deal with. When I asked for new oplims, they tried to tell me that I couldn't operate an experimental aircraft from my home field and 3 others - at all, phase 1 or 2! I told them that they were exceeding their authority and sicced the EAA on them. It them took a week and a half to do what should have been a 45 minute piece of over the counter paperwork, but they did cough it up. As soon as I was clear, the EAA took it up with FAA, DC and the FSDO got their wrist slapped. From what I hear, the FSDO would still like to prohibit ex, but can't until somebody gives them an excuse.
We all need to be careful not to provide these kinds of people an reason to jump on us. Case in point; the guy that attempted to fly for the first time with a supercharger engaged on a 5 hour old Velocity a few years back and crashed into a house on his first flight out of North Las Vegas. One killed aboard and two on the ground. Not only did the local FSDO later prohibit phase 1 from there, but there was an attempt to legislate as well.
This is scary reading:
http://aircrashed.com/cause/cLAX08LA274.shtml
Pax,
Ed Holyoke
On 7/13/2011 6:47 AM, Charlie England wrote: [quote] In my post, I think that I specifically said that the fuel pump change would be considered a major alteration. (That assumes that the change is made *after* the plane has left phase 1 testing.)
My point was that there's a difference between airframe changes and operational changes. The only operational change I can think of that would require re-entering phase 1 would be adding an acro capability, because most homebuilt oplims have traditionally had specific exclusions for any acro maneuvers that aren't tested and documented in phase 1.
I was told that the latest version of oplims, that require notifying the FSDO & getting approval of the test area, came about after 9-11 when hyper-monitoring of just about everything became common. For re-entering phase one under the new oplims, my FSDO just wants a fax with the request & the requested test area, & they respond with a fax. They are very accommodating with the size/shape of the area, mainly requiring that we stay away from controlled airspace if we aren't based at a controlled field (no need to fly in the controlled airspace). A FSDO in a higher traffic area would likely be more restrictive.
Charlie
On 07/13/2011 12:06 AM, Ed Holyoke wrote: [quote] John,
Once again, most of the newer oplims specify that they must be notified and concur with the test flight area. You don't request a new phase 1 period. The best way is to walk it in and get the signature on your letter, then you're not waiting for them to respond by mail, snail or otherwise.
Charlie, you might be right about changing fuel not being an alteration, however Appendix A does say that "conversions of any sort for the purpose of using a fuel of a rating or grade other than that listed in the engine specifications" is a major alteration. That would seem to include removing the engine driven fuel pump and adding a second boost pump to take it's place. If the engine doesn't have a data plate on it, well maybe, but only because it doesn't have any specifications, not because it isn't an alteration. Speaking of Lycomings, here. Auto conversions are a bit of a different story, of course.
Ed Holyoke
On 7/12/2011 8:16 PM, John Cox wrote: [quote] [quote]--> AeroElectric-List message posted by: "John Cox" <johnwcox(at)pacificnw.com> (johnwcox(at)pacificnw.com) Here is a kernel of value. The Inspector told me If you write and send the statement of work and request for a new Phase One via USPS, they respond USPS. If you email it, they respond by email. As a former letter carrier, the speed of light is just a tad quicker. I doubt if you send it FEDEX they would respond in kind, so chose wisely. Waiting to hear back. John --
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