Today's Message Index:
----------------------
1. 01:12 AM - Re: Cool Yak-50 Pic (Kevin Pilling)
2. 05:11 AM - August 25, 2006 (Daniel Fortin)
3. 07:50 AM - Re: ACF50 in the air system (Robert Starnes)
4. 08:20 AM - Maintenance, again (Jerry Painter)
5. 09:33 AM - Re: ACF50 in the air system (doug sapp)
6. 10:21 AM - Re: Maintenance, again (Larry Pine)
7. 11:22 AM - Re: Maintenance, again (flir47)
8. 11:45 AM - Re: Maintenance, again (Scooter)
9. 11:56 AM - Re: Re: Maintenance, again (Larry Pine)
10. 12:30 PM - Re: Re: Maintenance, again (doug sapp)
11. 12:57 PM - Re: Maintenance, again (Scooter)
12. 01:22 PM - Re: Re: Maintenance, again (Roger Kemp)
13. 01:26 PM - Re: Re: Maintenance, again (Larry Pine)
14. 01:33 PM - Re: Maintenance, again (ScottA)
15. 02:28 PM - Re: Re: Maintenance, again (doug sapp)
16. 02:57 PM - Re: Re: Maintenance, again (Steve & Donna Hanshew)
17. 03:13 PM - Re: Re: Maintenance, again (Steve & Donna Hanshew)
18. 03:18 PM - MAINTENANCE (Steve & Donna Hanshew)
19. 03:27 PM - Commercial rating (Herb Coussons)
20. 04:15 PM - Re: Re: Maintenance, again (doug sapp)
21. 04:23 PM - Re: Helmet? (Ron Davis)
22. 04:44 PM - Re: Re: Maintenance, again (Daniel Fortin)
23. 04:49 PM - Re: Re: Maintenance, again (A. Dennis Savarese)
24. 04:51 PM - Re: Re: Maintenance, again (A. Dennis Savarese)
25. 05:11 PM - Re: Re: Maintenance, again (doug sapp)
26. 05:13 PM - Re: Re: Manuals (Ron Davis)
27. 05:14 PM - Re: Commercial rating (Steve & Donna Hanshew)
28. 05:23 PM - Re: Re: Maintenance, again (Steve & Donna Hanshew)
29. 05:26 PM - Re: Re: Manuals (Ron Davis)
30. 05:42 PM - Re: Maintenance, again (Ron Davis)
31. 06:01 PM - Re: Maintenance, again (John W. Cox)
32. 06:02 PM - Re: Re: Maintenance, again (Ron Davis)
33. 06:03 PM - Re: Maintenance, again (A. Dennis Savarese)
34. 06:12 PM - Re: Re: Maintenance, again (Ron Davis)
35. 06:21 PM - Re: Re: Maintenance, again (Ron Davis)
36. 06:27 PM - Re: Maintenance, again (John W. Cox)
37. 06:38 PM - Re: Commercial rating (Ron Davis)
38. 06:41 PM - Re: Re: Maintenance, again (Ron Davis)
39. 06:56 PM - Frank Says...... (Frank Haertlein)
40. 06:59 PM - Re: Maintenance, again and again (Ron Davis)
41. 07:11 PM - Re: Re: Manuals (Larry Pine)
42. 07:16 PM - Re: Re: Maintenance, again (John W. Cox)
43. 07:29 PM - Re: Re: Maintenance, again (John W. Cox)
44. 07:49 PM - Re: Re: Maintenance, again (doug sapp)
45. 07:50 PM - Re: Re: Maintenance, again (Larry Pine)
46. 08:05 PM - Re: Commercial rating (John W. Cox)
47. 08:24 PM - Re: Re: Maintenance, again (Roger Kemp)
48. 08:54 PM - Frank Said.............. (Frank Haertlein)
49. 10:59 PM - Re: Re: Maintenance, again (Roger Kemp)
Message 1
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| Subject: | Re: Cool Yak-50 Pic |
--> Yak-List message posted by: "Kevin Pilling" <pilling.k@btconnect.com>
Our very own 2006 Aerostars Display Team..... Lead and #2 shown #3,4,5 just
out of frame...... all Yak50's.
Try www.aerostars.co.uk for more images and cool videos from previous
seasons.
kp
----- Original Message -----
From: "Tim Gagnon" <NiftyYak50@msn.com>
Sent: Monday, August 07, 2006 9:35 PM
Subject: Yak-List: Cool Yak-50 Pic
> --> Yak-List message posted by: "Tim Gagnon" <NiftyYak50@msn.com>
>
>
> Read this topic online here:
>
> http://forums.matronics.com/viewtopic.php?p=53171#53171
>
>
>
Message 2
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--> Yak-List message posted by: "Daniel Fortin" <fougapilot@hotmail.com>
Folks,
As of today, there are 9 rooms out of a blocked 30 that have been reserved
by members for the Georgetown Fall Fly-In (October 12 to 15, 2006). Some of
those members have sent me an email to tell me they were planning on
attending, some have not. Not a single individual has registered online
through the RPA website. We even have a new name on the list, I hope if this
person needs any special needs he/she will let us know.
The cut-off date for our rate at the hotel is August 25. After this date,
our rate (69$/night) will no longer be available and the remaining rooms
will be released to the public. Their cancellation policy is 48hrs, so if
you plan on joining us, do reserve your room. you can always cancel it at a
later time.
Cheers,
Dan Fortin
Message 3
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| Subject: | Re: ACF50 in the air system |
--> Yak-List message posted by: Robert Starnes <a35plt@yahoo.com>
yes, I put ACF-50 in all the CJ's I maintain, both as
an airframe spray to prevent/ stop corrosion and also
in the air system. ACF-50 is a water displacer and
will help prevent the water trapped in your system
from corroding up components such as air tanks, check
valves, water separator, snot bottle, etc. just add it
like you would air tool oil when you service your air
system.
-Robert Starnes A&P
__________________________________________________
Message 4
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| Subject: | Maintenance, again |
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 Certific
ate
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 fla
t
doesn't apply and therefore anyone can perform any sort of maintenance or
repair is especially dangerous advice. With FAA type certificated aircra
ft,
with their shelves of manuals and reams of AD's and Service Bulletins, AL
L
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 fed
s,
on a case by case basis, specifically for the particular airplane being
repaired. It's amazing what simple things the feds consider major repair
s.
ALL repairs have to be done in conformance to the mfrs recommendations an
d
APPROVED data. This even applies to repairs/mods for which an STC has be
en
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 y
ou
not to try to perform repairs or modifications on your Yak or CJ if you'r
e
not an A&P. In fact, if you read your Ops Limitations you'll find they t
ell
you the FAA must approve ALL major repairs/modifications to the aircraft.
Historical experience is on the side of the FAA. The fortuitous fact tha
t
the feds usually choose not to involve themselves unless there is a smoki
ng
hole and dead pedestrians should NOT lull you into thinking you can insta
ll
that new race modified M-14 or Ford V-8 with those high compression pisto
ns
from EBay and juiced up axial flow supercharger mod from JC Whitney, supe
r
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. A
nd
vice versa. Especially vice versa. That's why we have an FAA--all the d
ead
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 Russ
ian
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 h
ave
manuals (in English), they are required to have an FAA APPROVED maintenan
ce
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. So
me
are Yaks/CJ's. Granted, lots of things can be and should be done by owne
rs
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 fi
eld
repairs by Chinese/Russian "wholesalers" are bad, look at some owner
performed repairs/mods. Owners need to do the things most won't pay othe
rs
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 i
ce
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. Af
ter
all, It's your life and your family's lives that are at stake.
Jerry Painter
Message 5
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| Subject: | ACF50 in the air system |
--> Yak-List message posted by: "doug sapp" <rvfltd@televar.com>
Guys,
Anything you put in the air system should be looked at very carefully. If
it contains chemicals that will cause the rubber seals in the system to
swell it will cause you a ton of grief. So proceed with caution. My advice
is that if you are hell bent to use something other than what the book calls
for you should at least test whatever you use by applying it to a seal and
watching it for 72 hours or so. I have no experience with ACF50 except to
spray it on the skin laps of my float plane, it may be just fine for use in
the air system, I really have no idea. I do know that in the past month I
have sent new seal to a bunch of guys who commented that all their seals
were loose and sloppy....all swollen up.
Always Yakin,
Doug Sapp
-----Original Message-----
From: owner-yak-list-server@matronics.com
[mailto:owner-yak-list-server@matronics.com]On Behalf Of Robert Starnes
Sent: Tuesday, August 08, 2006 7:50 AM
Subject: Re: Yak-List: ACF50 in the air system
--> Yak-List message posted by: Robert Starnes <a35plt@yahoo.com>
yes, I put ACF-50 in all the CJ's I maintain, both as
an airframe spray to prevent/ stop corrosion and also
in the air system. ACF-50 is a water displacer and
will help prevent the water trapped in your system
from corroding up components such as air tanks, check
valves, water separator, snot bottle, etc. just add it
like you would air tool oil when you service your air
system.
-Robert Starnes A&P
__________________________________________________
Message 6
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| Subject: | Re: 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-8), 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@verizon.net> wrote:
v\:* {behavior:url (#default#vml);} v\:* { BEHAVIOR: url (#default#vml)
} 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
Larry Pine
---------------------------------
Message 7
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| Subject: | Re: Maintenance, again |
--> Yak-List message posted by: "flir47" <me262pilot@comcast.net>
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 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.
I hope this clarifies some of the confusion that is out there.
A&P's Just need the money.....
--------
It's not a real world war untill France surenders!
Read this topic online here:
http://forums.matronics.com/viewtopic.php?p=53434#53434
Message 8
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| Subject: | Re: Maintenance, again |
--> Yak-List message posted by: "Scooter" <yakk52@verizon.net>
The following about my Operating Limitations is incorrect: "They will clearly
tell you that the airplane must be maintained in accordance with 14 CFR Part 43--NO
EXCEPTIONS". In fact they say that the aircraft must be inspected per part
43 - not maintained per 43.
As for working on experimental amateur built aircraft: anyone can do this - not
just the builder.
Read this topic online here:
http://forums.matronics.com/viewtopic.php?p=53441#53441
Message 9
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| Subject: | Re: Maintenance, again |
Experimental is not Experimental Exhibition!
flir47 <me262pilot@comcast.net> wrote:
--> 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 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.
I hope this clarifies some of the confusion that is out there.
A&P's Just need the money.....
--------
It's not a real world war untill France surenders!
Read this topic online here:
http://forums.matronics.com/viewtopic.php?p=53434#53434
Larry Pine
---------------------------------
How low will we go? Check out Yahoo! Messengers low PC-to-Phone call rates.
Message 10
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| Subject: | Re: Maintenance, again |
--> Yak-List message posted by: "doug sapp" <rvfltd@televar.com>
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
-----Original Message-----
From: owner-yak-list-server@matronics.com
[mailto:owner-yak-list-server@matronics.com]On Behalf Of flir47
Sent: Tuesday, August 08, 2006 11:22 AM
Subject: Yak-List: Re: Maintenance, again
--> Yak-List message posted by: "flir47" <me262pilot@comcast.net>
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 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.
I hope this clarifies some of the confusion that is out there.
A&P's Just need the money.....
--------
It's not a real world war untill France surenders!
Read this topic online here:
http://forums.matronics.com/viewtopic.php?p=53434#53434
Message 11
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| Subject: | Re: Maintenance, again |
--> Yak-List message posted by: "Scooter" <yakk52@verizon.net>
Not true. Experimental is a category that includes exhibition, research and development,
amateur built, air racing, etc. All aircraft fall into one of these
categories. No aircraft is purely experimental.
threein60(at)yahoo.com wrote:
> Experimental is not Experimental Exhibition!
>
>
>
>
Read this topic online here:
http://forums.matronics.com/viewtopic.php?p=53454#53454
Message 12
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| Subject: | Re: Maintenance, again |
--> Yak-List message posted by: "Roger Kemp" <viperdoc@mindspring.com>
My operating limitations reads as follows: Only FAA certified mechanics
with appropriate ratings are authorized by ~43.3 or appropriately rated
repair stations may perform inspections required by these operation
limitations. It also states, Aircraft instruments and equipment installed
and used under ~ 91.205 must be inspected and maintained in accordance with
the applicabe requirements of parts 43 and 91. Any maintenance or
inspection of this equipment must be recorded in the aircraft maintenance
records.
I inturpt inspections to mean examine not maintain. Nothing is said about
only FAA mechanics with appropriate ratings are required to maintain this
aircraft.
There is nothing stated concerning all maintenance must only be performed
by a rated A&P. It does need to signed off by an A&P after an annual
condition inspection but the A&P does not have to do all the work.
Maintenance can be performed by the owner operator as I understand it. Most
of the A&P's I know are more than happy to have me do all the work and then
inspect it after or in the process of accomplishment of the condition
inspection. Now the smart YAK/CJ driver should ,when a question arises
about the maintenance of their aircraft, ask an appropriate A&P for advise.
Chances are though, you generally know more about that aircraft than he
does. So you end up calling the knowledge of the yak-list, the likes of
Doug Sapp, Carl Hayes, Dennis Savarese, George Coy, and Steve Culp, ect for
the necessary guidance. Atleast that is the way it goes in my neck of the
woods.
As those that know me will say, I am an OCS personality, so I take very
good care of my aircraft anyway.
Doc
> [Original Message]
> From: Scooter <yakk52@verizon.net>
> To: <yak-list@matronics.com>
> Date: 8/8/2006 1:55:36 PM
> Subject: Yak-List: Re: Maintenance, again
>
> --> Yak-List message posted by: "Scooter" <yakk52@verizon.net>
>
> The following about my Operating Limitations is incorrect: "They will
clearly tell you that the airplane must be maintained in accordance with 14
CFR Part 43--NO EXCEPTIONS". In fact they say that the aircraft must be
inspected per part 43 - not maintained per 43.
>
> As for working on experimental amateur built aircraft: anyone can do
this - not just the builder.
>
>
> Read this topic online here:
>
> http://forums.matronics.com/viewtopic.php?p=53441#53441
>
>
>
>
>
>
>
Message 13
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| Subject: | 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@televar.com> wrote:
--> 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
-----Original Message-----
From: owner-yak-list-server@matronics.com
[mailto:owner-yak-list-server@matronics.com]On Behalf Of flir47
Sent: Tuesday, August 08, 2006 11:22 AM
Subject: Yak-List: Re: Maintenance, again
--> 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 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.
I hope this clarifies some of the confusion that is out there.
A&P's Just need the money.....
--------
It's not a real world war untill France surenders!
Read this topic online here:
http://forums.matronics.com/viewtopic.php?p=53434#53434
Larry Pine
---------------------------------
Next-gen email? Have it all with the all-new Yahoo! Mail Beta.
Message 14
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| Subject: | Re: Maintenance, again |
--> Yak-List message posted by: "ScottA" <s-aldrich@comcast.net>
Anyone can work on/change/modify an experimental aircraft (of course depending
on mod may need more test flight approval). No YAK or CJ owners will ever have
a builder repairman certificate (unless you can convince you built 51%) so they
will need an AP (not IA) to sign off the "condition" inspection. The repairman
certificate that is available to other custom aircraft builders does not
transfer with the airplane - only that one person can do the condition inspection,
but he could do it for the new owner if he wanted to (unlikely). At least
that is the way it is in this area of the US.
FWIW
Scott
Read this topic online here:
http://forums.matronics.com/viewtopic.php?p=53461#53461
Message 15
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| Subject: | 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
-----Original Message-----
From: owner-yak-list-server@matronics.com
[mailto:owner-yak-list-server@matronics.com]On Behalf Of Larry Pine
Sent: Tuesday, August 08, 2006 1:26 PM
To: yak-list@matronics.com
Subject: RE: Yak-List: 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@televar.com> wrote:
--> 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
-----Original Message-----
From: owner-yak-list-server@matronics.com
[mailto:owner-yak-list-server@matronics.com]On Behalf Of flir47
Sent: Tuesday, August 08, 2006 11:22 AM
To: yak-list@matronics.com
Subject: Yak-List: Re: Maintenance, again
--> 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
Message 16
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| Subject: | Re: Maintenance, again |
-----Original Message-----
From: owner-yak-list-server@matronics.com
[mailto:owner-yak-list-server@matronics.com]On Behalf Of doug sapp
Sent: Tuesday, August 08, 2006 5:09 PM
To: yak-list@matronics.com
Subject: RE: Yak-List: 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
-----Original Message-----
From: owner-yak-list-server@matronics.com
[mailto:owner-yak-list-server@matronics.com]On Behalf Of Larry Pine
Sent: Tuesday, August 08, 2006 1:26 PM
To: yak-list@matronics.com
Subject: RE: Yak-List: 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@televar.com> wrote:
--> 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
-----Original Message-----
From: owner-yak-list-server@matronics.com
[mailto:owner-yak-list-server@matronics.com]On Behalf Of flir47
Sent: Tuesday, August 08, 2006 11:22 AM
To: yak-list@matronics.com
Subject: Yak-List: Re: Maintenance, again
--> 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
Message 17
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|
| Subject: | Re: Maintenance, again |
My advice for what it's worth (which ain't much). Don't knob dick it. Leave
it be. Do what you've been doing in a reasonable and contentious manner as
you would normally do. A fed's word means nothing but what serves the
purpose at the time. Right now we are about to rewrite the Part 25 landing
certification regulations via a NPRM no one had time to comment on (to
include Boeing) simply because a poor unfortunate kid got killed at MDW.
Instead of doing it right and addressing the regulation and buttressing it
with appropriate data we'll be forced into one size fits all as a ironclad
solution to a very complex problem. They will have an NTSB judge adjudicate
the matter outside the realm of real numbers just because it "feels" like
the right thing to do. That is how it works now. No facts just what feels
right. Every year it gets harder and harder to predict what the FAA will do
in reaction to something because instead of waiting for tombstones they are
trying to beat the ambulance to the morgue. They have become virulently
proactive to the point that a strait jacket seems comfortable. Open a door
for them and they will be in it with both feet, a battalion of lawyers, and
Dr. Phil for good measure. Leave the matter alone - for what it is worth.
-----Original Message-----
From: owner-yak-list-server@matronics.com
[mailto:owner-yak-list-server@matronics.com]On Behalf Of doug sapp
Sent: Tuesday, August 08, 2006 5:09 PM
To: yak-list@matronics.com
Subject: RE: Yak-List: 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
-----Original Message-----
From: owner-yak-list-server@matronics.com
[mailto:owner-yak-list-server@matronics.com]On Behalf Of Larry Pine
Sent: Tuesday, August 08, 2006 1:26 PM
To: yak-list@matronics.com
Subject: RE: Yak-List: 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@televar.com> wrote:
--> 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
-----Original Message-----
From: owner-yak-list-server@matronics.com
[mailto:owner-yak-list-server@matronics.com]On Behalf Of flir47
Sent: Tuesday, August 08, 2006 11:22 AM
To: yak-list@matronics.com
Subject: Yak-List: Re: Maintenance, again
--> 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
Message 18
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|
My advice for what it's worth (which ain't much). Don't knob dick it. Leave
it be. Do what you've been doing in a reasonable and contentious manner as
you would normally do. A fed's word means nothing but what serves the
purpose at the time. Right now we are about to rewrite the Part 25 landing
certification regulations via a NPRM no one had time to comment on (to
include Boeing) simply because a poor unfortunate kid got killed at MDW.
Instead of doing it right and addressing the regulation and buttressing it
with appropriate data we'll be forced into one size fits all as a ironclad
solution to a very complex problem. They will have an NTSB judge adjudicate
the matter outside the realm of real numbers just because it "feels" like
the right thing to do. That is how it works now. No facts just what feels
right. Every year it gets harder and harder to predict what the FAA will do
in reaction to something because instead of waiting for tombstones they are
trying to beat the ambulance to the morgue. They have become virulently
proactive to the point that a strait jacket seems comfortable. Open a door
for them and they will be in it with both feet, a battalion of lawyers, and
Dr. Phil for good measure. Leave the matter alone - for what it is worth.
Message 19
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|
| Subject: | Commercial rating |
--> Yak-List message posted by: Herb Coussons <drc@wscare.com>
Gang,
I am a private SEL, instrument pilot.
I have committed to getting a commercial rating since I have flown in
a few airshows this year and had to leave fuel funds behind.
(I also need to get busy with my FAST training so I can fly with
everyone at OSH and some of the Red Star groups)
My question is this. Can I get the commercial ticket in my Yak? I
have asked 2 flight instructors locally and both said no. Not based
on it being certified experimental exhibition but some other lame
excuse. I would have thought any CFI would want to spend several
hours in the back seat giving instruction. Is there any FAR that
prohibits taking advanced training or a flight test in our planes?
Surely someone has faced this before - any help is appreciated.
Herb
Message 20
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|
| Subject: | Re: Maintenance, again |
Steve,
I don't advocate going to the Feds for anything, but would like to know the
EAA's (read it carefully Steve I said EAA, NOT FAA) interpretation of the
regs. Many times the EAA and the AOPA's staff has stepped in between the
feds and a Joe pilot and the outcome has ended up much more favorable for
old Joe than if he would have been left to his own devices. Should one of
our Joe's need help it would be good to know where competent help might be
found. I cannot believe you don't agree.
Hello to Donna, best from Omak.
Always Yakin,
Doug Sapp
-----Original Message-----
From: owner-yak-list-server@matronics.com
[mailto:owner-yak-list-server@matronics.com]On Behalf Of Steve & Donna
Hanshew
Sent: Tuesday, August 08, 2006 2:57 PM
To: yak-list@matronics.com
Subject: RE: Yak-List: Re: Maintenance, again
-----Original Message-----
From: owner-yak-list-server@matronics.com
[mailto:owner-yak-list-server@matronics.com]On Behalf Of doug sapp
Sent: Tuesday, August 08, 2006 5:09 PM
To: yak-list@matronics.com
Subject: RE: Yak-List: 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
-----Original Message-----
From: owner-yak-list-server@matronics.com
[mailto:owner-yak-list-server@matronics.com]On Behalf Of Larry Pine
Sent: Tuesday, August 08, 2006 1:26 PM
To: yak-list@matronics.com
Subject: RE: Yak-List: 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@televar.com> wrote:
--> 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
-----Original Message-----
From: owner-yak-list-server@matronics.com
[mailto:owner-yak-list-server@matronics.com]On Behalf Of flir47
Sent: Tuesday, August 08, 2006 11:22 AM
To: yak-list@matronics.com
Subject: Yak-List: Re: Maintenance, again
--> 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
Message 21
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The ruskies used a rectangular 6 conductor connector. If your helmet
has a single short stubby round "helicopter" plug, it's been converted.
The impedance of the eastern speakers and mics is incompatable with US
civil radios (unless they've been changed out). I do know how to wire
the 6 connector plug to US standards, but there's no point.
----- Original Message -----
From: Dr Andre Katz
To: yak-list@matronics.com
Sent: Friday, August 04, 2006 5:55 AM
Subject: RE: Yak-List: Helmet?
talking about helmets I found in Oshkosh an original russian helmet
that fits well but has the russian round cable with four probes and a
small squarish connector. any one knows how to hook them to the original
briz?
thanks
andres
Hans Oortman <pa3arw@euronet.nl> wrote:
--> Yak-List message posted by: "Hans Oortman"
It works fine with me, including the ANR from Flightsuits.
I use their HGU55 since about 4 years and had no problems with it.
But I need to say that we don't use the standard Baklan radio but a
Becker
with PM1000 intercom.
I would recommend a fixed power supply outlet though in the cockpit
(front
and back) Batteries don't run very long...
anr-headsets.com have a nice solution for that.
Fly safe!
Hans
Dutch Yak
Message 22
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| Subject: | Re: Maintenance, again |
--> Yak-List message posted by: "Daniel Fortin" <fougapilot@hotmail.com>
Earl Lawrence knows his stuff. He helped me quite a lot a few years back
when the FAA wanted to pull the CofA of a Fouga Jet I flew. I delt with the
feds for weeks, and all was settled within 24hrs of Earl getting involved.
He made the Albany FSDO back down with a one page fax...
D
Message 23
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| Subject: | Re: Maintenance, again |
It is still Experimental Larry. If you look at the Application for
Airworthiness certificate (FAA FORM 8130-6),
http://forms.faa.gov/forms/faa8130-6d.pdf, by "Experimental" , it says
"Indicate Operations To Be Performed". Then you check the box next to
EXPERIMENTAL for which operation your EXPERIMENTAL aircraft will be
performing. They are:
Research and Development, Amateur Built, Exhibition, Air Racing, Crew
Training, Market Survey, Operating (primary category) Kit built
aircraft. Based on your comment, which one of these Operations do
qualify as Experimental?
Dennis
----- Original Message -----
From: Larry Pine
To: yak-list@matronics.com
Sent: Tuesday, August 08, 2006 1:55 PM
Subject: Re: Yak-List: Re: Maintenance, again
Experimental is not Experimental Exhibition!
flir47 <me262pilot@comcast.net> wrote:
--> 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=1A
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>Larry Pine
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Message 24
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| Subject: | Re: Maintenance, again |
Where does it say "Homebuilt, Experimental" on FAA form 8130-6, the
Application for Airworthiness Certificate?
Dennis
----- Original Message -----
From: Larry Pine
To: yak-list@matronics.com
Sent: Tuesday, August 08, 2006 3:26 PM
Subject: RE: Yak-List: 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@televar.com> wrote:
--> 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
-----Original Message-----
From: owner-yak-list-server@matronics.com
[mailto:owner-yak-list-server@matronics.com]On Behalf Of flir47
Sent: Tuesday, August 08, 2006 11:22 AM
To: yak-list@matronics.com
Subject: Yak-List: Re: Maintenance, again
--> 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[LashBack] 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=1A
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
Message 25
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| Subject: | Re: Maintenance, again |
--> Yak-List message posted by: "doug sapp" <rvfltd@televar.com>
Dan,
Do you have his email info?
Always Yakin,
Doug Sapp
-----Original Message-----
From: owner-yak-list-server@matronics.com
[mailto:owner-yak-list-server@matronics.com]On Behalf Of Daniel Fortin
Sent: Tuesday, August 08, 2006 4:44 PM
Subject: RE: Yak-List: Re: Maintenance, again
--> Yak-List message posted by: "Daniel Fortin" <fougapilot@hotmail.com>
Earl Lawrence knows his stuff. He helped me quite a lot a few years back
when the FAA wanted to pull the CofA of a Fouga Jet I flew. I delt with the
feds for weeks, and all was settled within 24hrs of Earl getting involved.
He made the Albany FSDO back down with a one page fax...
D
Message 26
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Actually, you don't need a maintenance program for a Yak in the
experimental exhibition caategory. And there is no such thing as
"normal" experimental category.
----- Original Message -----
From: Larry Pine
To: yak-list@matronics.com
Sent: Monday, August 07, 2006 10:38 AM
Subject: Re: Yak-List: Re: Manuals
Actually, In experimental exhibition you need the manuals in order to
sign the maintenance off. All work must be done IAW the original or
approved modified maintenance manuals. I think you are referring to
normal experimental catagory where maintenance manuals are not required
only IAW FAR 43.13 APP D.
Larry
N8181C
A&P
Scooter <yakk52@verizon.net> wrote:
--> Yak-List message posted by: "Scooter"
Is this an experimental exhibition aircraft? If so you shouldn't
need any manuals.
jimscjs(at)mbay.net wrote:
> I'm trying to get my Maintanance Manuals for my0 Yak-18
transcribed into English, the FAA won't sign the Plane off till there
in0 English, has anyone had this Problem with the FAA. any Ideas.
>
> Jim
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Message 27
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| Subject: | Commercial rating |
--> Yak-List message posted by: "Steve & Donna Hanshew" <dhanshew@cinci.rr.com>
Herb,
I did my Commercial Pilot rating in our CJ-6A last year. I practiced the
maneuvers, and did check ride prep
with a friend who was a CFI and had a Yak-52.
Not sure where you are located, but I am a CFII and know the DE very well
that gave me my flight check.
Contact me off list: dhanshew@cinci.rr.com
regards, Donna Hanshew
-----Original Message-----
From: owner-yak-list-server@matronics.com
[mailto:owner-yak-list-server@matronics.com]On Behalf Of Herb Coussons
Sent: Tuesday, August 08, 2006 6:27 PM
Subject: Yak-List: Commercial rating
--> Yak-List message posted by: Herb Coussons <drc@wscare.com>
Gang,
I am a private SEL, instrument pilot.
I have committed to getting a commercial rating since I have flown in
a few airshows this year and had to leave fuel funds behind.
(I also need to get busy with my FAST training so I can fly with
everyone at OSH and some of the Red Star groups)
My question is this. Can I get the commercial ticket in my Yak? I
have asked 2 flight instructors locally and both said no. Not based
on it being certified experimental exhibition but some other lame
excuse. I would have thought any CFI would want to spend several
hours in the back seat giving instruction. Is there any FAR that
prohibits taking advanced training or a flight test in our planes?
Surely someone has faced this before - any help is appreciated.
Herb
Message 28
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| Subject: | Re: Maintenance, again |
Call me an embittered soul. I work with lots of feds. Some I even like. I
don't consider them priests though. Too many people nowadays bear their
souls like Oprah and then wonder why it doesn't result in the answer they
wanted. Once the FAA has a foot in your arse, they will inevitably run it up
to the knee and then ask if that hurts. EAA and AOPA ok, I down with that.
Sure ask them. I'm sure they have no desire to rat someone out. I'm to the
point anymore that all the good feds that knew something are long gone,
replaced by people looking for a CYA to a secure non-airline (or PBGC
financed) pension.
-----Original Message-----
From: owner-yak-list-server@matronics.com
[mailto:owner-yak-list-server@matronics.com]On Behalf Of doug sapp
Sent: Tuesday, August 08, 2006 7:15 PM
To: yak-list@matronics.com
Subject: RE: Yak-List: Re: Maintenance, again
Steve,
I don't advocate going to the Feds for anything, but would like to know
the EAA's (read it carefully Steve I said EAA, NOT FAA) interpretation of
the regs. Many times the EAA and the AOPA's staff has stepped in between
the feds and a Joe pilot and the outcome has ended up much more favorable
for old Joe than if he would have been left to his own devices. Should one
of our Joe's need help it would be good to know where competent help might
be found. I cannot believe you don't agree.
Hello to Donna, best from Omak.
Always Yakin,
Doug Sapp
-----Original Message-----
From: owner-yak-list-server@matronics.com
[mailto:owner-yak-list-server@matronics.com]On Behalf Of Steve & Donna
Hanshew
Sent: Tuesday, August 08, 2006 2:57 PM
To: yak-list@matronics.com
Subject: RE: Yak-List: Re: Maintenance, again
-----Original Message-----
From: owner-yak-list-server@matronics.com
[mailto:owner-yak-list-server@matronics.com]On Behalf Of doug sapp
Sent: Tuesday, August 08, 2006 5:09 PM
To: yak-list@matronics.com
Subject: RE: Yak-List: 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
-----Original Message-----
From: owner-yak-list-server@matronics.com
[mailto:owner-yak-list-server@matronics.com]On Behalf Of Larry Pine
Sent: Tuesday, August 08, 2006 1:26 PM
To: yak-list@matronics.com
Subject: RE: Yak-List: 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@televar.com> wrote:
--> 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
-----Original Message-----
From: owner-yak-list-server@matronics.com
[mailto:owner-yak-list-server@matronics.com]On Behalf Of flir47
Sent: Tuesday, August 08, 2006 11:22 AM
To: yak-list@matronics.com
Subject: Yak-List: Re: Maintenance, again
--> 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
Message 29
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Larry,
Experimentals don't have annual inspections, and I've never heard of a
"phase" inspection. Of course I know what you meant, but the point is
that you don't know. You seem to not know a great deal about
experimental planes. For example, what is the point of having a
maintenance manual? It was written by some godless communist that never
heard of the FAA's requirements. The manuals were never been reviewed
or approved by the FAA, so they have no legal standing. The pictures
are handy of course, provided you don't have to pay $20 for them...
----- Original Message -----
From: Larry Pine
To: yak-list@matronics.com
Sent: Monday, August 07, 2006 1:31 PM
Subject: Re: Yak-List: Re: Manuals
You are permitted to work on the aircraft but to only things listed in
the FARs under preventative maintenance or under the supervision of a
A&P. A pilot can make a log book entry about preventative maintenance
performed only. An A&P still must sign off annuals (phase inspections)
and Maintenance items.
Larry
Scooter <yakk52@verizon.net> wrote:
--> Yak-List message posted by: "Scooter"
I almost hate to ask this then: when I (a non-A&P or anything else)
work on my Exp Exhibition aircraft do I need the manuals to sign-off the
maintenance? Or am I not permitted to work on the aircraft?
[quote="threein60(at)yahoo.com"]Actually, In experimental
exhibition you need the manuals in order to sign the maintenance off.
All work must be done IAW the original or
Message 30
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| Subject: | Re: Maintenance, again |
I'd like you to re-read the first paragraph of your post. If this
statement is true: "ALL repairs have to be done in conformance to the
mfrs recommendations and APPROVED data." then no CJ or Yak can fly
because There is no approved data. None, no type certificate, no STCs,
no ADs, no manuals, no nothing that has been approved by the FAA or any
agency recognized by the FAA. It's just like experimental homebuilt,
just like experimental R&D, etc. The owner/pilot is on his own in
determining that the aircraft is in a safe condition for flight.
As to why the condition inspection is required: It's not, unless your
ops limits, which are an attachment to and a part of your airworthiness
certificate require it (and of course they do require it).
Why did the fed ask for manuals? I can think of two reasons, he doesn't
want to sign the airworthiness certificate so he's making up excuses or
maybe he can't read either.
----- Original Message -----
From: Jerry Painter
To: Yak List (yak-list@matronics.com)
Sent: Tuesday, August 08, 2006 8:19 AM
Subject: Yak-List: Maintenance, again
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
Message 31
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| Subject: | Maintenance, again |
Jerry, this is the most comprehensive and accurate presentation of what
is clearly misunderstood by owner/pilots of warbirds. As an A & P for a
major regional airline, it amazes me how many will cling to anyone's
interpretation that suits their purpose. Warbird loses at KHIO and KOSH
this year alone has the legal eagles reviewing this exact issue.
Aging Aircraft is a whole nother area which was clearly addressed at OSH
this year. Sorry Dennis, your dog won't hunt with any FAA FSDO General
Manager in CONUS. You may slip it by the good ole boys in your backyard
and find a lot of willing converts to the mantra but Jerry is clearly
"On Target".
John Cox
From: owner-yak-list-server@matronics.com
[mailto:owner-yak-list-server@matronics.com] On Behalf Of Jerry Painter
Sent: Tuesday, August 08, 2006 8:19 AM
Subject: Yak-List: Maintenance, again
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
Message 32
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| Subject: | Re: Maintenance, again |
--> Yak-List message posted by: "Ron Davis" <L39parts@hotmail.com>
It's not at all clear he was talking only about experimental- amateur built.
Very few regs are different for experimental-exhibition.
----- Original Message -----
From: "doug sapp" <rvfltd@televar.com>
Sent: Tuesday, August 08, 2006 12:29 PM
Subject: RE: Yak-List: Re: Maintenance, again
> --> Yak-List message posted by: "doug sapp" <rvfltd@televar.com>
>
> 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
>
> -----Original Message-----
> From: owner-yak-list-server@matronics.com
> [mailto:owner-yak-list-server@matronics.com]On Behalf Of flir47
> Sent: Tuesday, August 08, 2006 11:22 AM
> To: yak-list@matronics.com
> Subject: Yak-List: Re: Maintenance, again
>
>
> --> Yak-List message posted by: "flir47" <me262pilot@comcast.net>
>
> 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 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.
>
> I hope this clarifies some of the confusion that is out there.
>
> A&P's Just need the money.....
>
> --------
> It's not a real world war untill France surenders!
>
>
> Read this topic online here:
>
> http://forums.matronics.com/viewtopic.php?p=53434#53434
>
>
>
Message 33
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| Subject: | Re: Maintenance, again |
Well said Ron.
Dennis
----- Original Message -----
From: Ron Davis
To: yak-list@matronics.com
Sent: Tuesday, August 08, 2006 7:42 PM
Subject: Re: Yak-List: Maintenance, again
I'd like you to re-read the first paragraph of your post. If this
statement is true: "ALL repairs have to be done in conformance to the
mfrs recommendations and APPROVED data." then no CJ or Yak can fly
because There is no approved data. None, no type certificate, no STCs,
no ADs, no manuals, no nothing that has been approved by the FAA or any
agency recognized by the FAA. It's just like experimental homebuilt,
just like experimental R&D, etc. The owner/pilot is on his own in
determining that the aircraft is in a safe condition for flight.
As to why the condition inspection is required: It's not, unless your
ops limits, which are an attachment to and a part of your airworthiness
certificate require it (and of course they do require it).
Why did the fed ask for manuals? I can think of two reasons, he
doesn't want to sign the airworthiness certificate so he's making up
excuses or maybe he can't read either.
----- Original Message -----
From: Jerry Painter
To: Yak List (yak-list@matronics.com)
Sent: Tuesday, August 08, 2006 8:19 AM
Subject: Yak-List: Maintenance, =ashBack] again
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 fanc y 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
Message 34
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| Subject: | Re: Maintenance, again |
No, no, no. CJs are not experimental- amateur built, so don't read those
regs to see what you can do on a CJ. You are not qualified to
extrapolate the regs from one category to another.
One of those no's is for the "ask the feds" comment. If you ask a low
level bureaucrat if you can do something they will always say no because
it is the easy answer and the safest (for him) answer.
Read, or in your case find someone who can read, the requirements and do
what they says. When they say they don't apply to experimental planes-
they don't apply. Don't read the tax code and extrapolate what you
think that means when you're trying to sail a boat.
----- Original Message -----
From: Larry Pine
To: yak-list@matronics.com
Sent: Tuesday, August 08, 2006 1:26 PM
Subject: RE: Yak-List: 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@televar.com> wrote:
--> 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
-----Original Message-----
From: owner-yak-list-server@matronics.com
[mailto:owner-yak-list-server@matronics.com]On Behalf Of flir47
Sent: Tuesday, August 08, 2006 11:22 AM
To: yak-list@matronics.com
Subject: Yak-List: Re: Maintenance, again
--> 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=1A
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
Message 35
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| Subject: | Re: Maintenance, again |
You are aware, Doug, that the EAA has a warbird division? They fly
experimental exhibition planes, so it's hard to imagine that the EAA
hasn't heard of these regs, read them, analyzed them, etc.
The only way you will get a good answer from a low level bureaucrat is
to ask him to show you the regs that apply to your question. No is the
easy answer, it is the safe answer, and it is the answer you will get if
you ask if you can do something. If you don't think this is true, ask a
fed if it's ok for you to clean the spark plugs in your Cessna. We all
know FAR 43 allows this, it's clearly written. See if you can get the
fed to say "yes". It's not in their nature.
----- Original Message -----
From: doug sapp
To: yak-list@matronics.com
Sent: Tuesday, August 08, 2006 2:09 PM
Subject: RE: Yak-List: 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
-----Original Message-----
From: owner-yak-list-server@matronics.com
[mailto:owner-yak-list-server@matronics.com]On Behalf Of Larry Pine
Sent: Tuesday, August 08, 2006 1:26 PM
To: yak-list@matronics.com
Subject: RE: Yak-List: 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@televar.com> wrote:
--> 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
-----Original Message-----
From: owner-yak-list-server@matronics.com
[mailto:owner-yak-list-server@matronics.com]On Behalf Of flir47
Sent: Tuesday, August 08, 2006 11:22 AM
To: yak-list@matronics.com
Subject: Yak-List: Re: Maintenance, again
--> 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=1A
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
Message 36
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| 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@matronics.com
[mailto:owner-yak-list-server@matronics.com] On Behalf Of Larry Pine
Sent: Tuesday, August 08, 2006 10:21 AM
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-8), 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@verizon.net> wrote:
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
Larry Pine
Message 37
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| Subject: | Re: Commercial rating |
--> Yak-List message posted by: "Ron Davis" <L39parts@hotmail.com>
Second you need to find some better flight instructors. I suggest someone
who likes to fly instead of someone who is building time to join the ranks
of unemployed airline pilots.
But first you need to find an examiner. 14CFR61.45 says:
Required aircraft and equipment. (a) General. Except as provided in
paragraph (a)(2) of this section or when permitted to accomplish the entire
flight increment of the practical test in a flight simulator or a flight
training device, an applicant for a certificate or rating issued under this
part must furnish: (1) An aircraft of U.S. registry for each required test
that-- (i) Is of the category, class, and type, if applicable, for which the
applicant is applying for a certificate or rating; and (ii) Has a current
standard airworthiness certificate or special airworthiness certificate in
the limited, primary, or light-sport category. (2) At the discretion of the
examiner who administers the practical test, the applicant may furnish-- (i)
An aircraft that has a current airworthiness certificate other than a
standard airworthiness certificate or special airworthiness certificate in
the limited, primary, or light-sport category, but that otherwise meets the
requirements of paragraph (a)(1) of this section;
The first part of that says you have to have a standard (not experimental)
plane. (2) says the examiner can let you use your CJ if he wants to. He
doesn't have to, but he can, so find the right examiner first, then find an
instructor who wants to spend several hours in the back seat of a CJ.
----- Original Message -----
From: "Herb Coussons" <drc@wscare.com>
Sent: Tuesday, August 08, 2006 3:26 PM
Subject: Yak-List: Commercial rating
> --> Yak-List message posted by: Herb Coussons <drc@wscare.com>
>
> Gang,
> I am a private SEL, instrument pilot.
>
> I have committed to getting a commercial rating since I have flown in a
> few airshows this year and had to leave fuel funds behind.
> (I also need to get busy with my FAST training so I can fly with everyone
> at OSH and some of the Red Star groups)
>
> My question is this. Can I get the commercial ticket in my Yak? I have
> asked 2 flight instructors locally and both said no. Not based on it
> being certified experimental exhibition but some other lame excuse. I
> would have thought any CFI would want to spend several hours in the back
> seat giving instruction. Is there any FAR that prohibits taking advanced
> training or a flight test in our planes?
>
> Surely someone has faced this before - any help is appreciated.
>
> Herb
>
>
> http://www.matronics.com/Navigator?Yak-List
> Limit Now At: 1MB - 08/08/06 (was 2MB)
>
>
>
Message 38
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| Subject: | Re: Maintenance, again |
--> Yak-List message posted by: "Ron Davis" <L39parts@hotmail.com>
me262pilot@comcast.net
I got Earl's address off the posting, but then I guess I'm better at
research than some people.
----- Original Message -----
From: "doug sapp" <rvfltd@televar.com>
Sent: Tuesday, August 08, 2006 5:11 PM
Subject: RE: Yak-List: Re: Maintenance, again
> --> Yak-List message posted by: "doug sapp" <rvfltd@televar.com>
>
> Dan,
> Do you have his email info?
>
> Always Yakin,
> Doug Sapp
>
> -----Original Message-----
> From: owner-yak-list-server@matronics.com
> [mailto:owner-yak-list-server@matronics.com]On Behalf Of Daniel Fortin
> Sent: Tuesday, August 08, 2006 4:44 PM
> To: yak-list@matronics.com
> Subject: RE: Yak-List: Re: Maintenance, again
>
>
> --> Yak-List message posted by: "Daniel Fortin" <fougapilot@hotmail.com>
>
> Earl Lawrence knows his stuff. He helped me quite a lot a few years back
> when the FAA wanted to pull the CofA of a Fouga Jet I flew. I delt with
> the
> feds for weeks, and all was settled within 24hrs of Earl getting involved.
> He made the Albany FSDO back down with a one page fax...
>
> D
>
>
>
Message 39
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| Subject: | Frank Says...... |
DOC said..........
"Blitz, You are dead on " .
Frank says........
OK, DOC, I'll relent.
In my own defense, I don't think it improper to question what seems to
be a
high price.
I work as hard for my money as the photographer does...maybe more
so........
Here's a free one.... Lower the flaps on your 52 and take a close look
at
the links that lower the flaps. Take a reeeeal close look at the links
(maybe even disassemble them) and look for cracks in the components that
make up the link. If nothing is found it would still serve you well to
keep
reeeeeeal a close eye on this during annuals
Frank
Shame on you for whining about $20 ???
I whine about high gas prices too........should I be ashamed about that
too?
Message 40
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| Subject: | Re: Maintenance, again and again |
I'm not sure what this says, but it appears to be further muddling the
distinctions between amateur built and exhibition.
Be that as it may, I'd like to point out that T. Allan McArtor was the
biggest asshole that has ever run the FAA. Were it not for Liz Dole,
he'd be the biggest asshole even further up the federal chain of
command.
----- Original Message -----
From: John W. Cox
To: yak-list@matronics.com
Sent: Tuesday, August 08, 2006 6:27 PM
Subject: RE: Yak-List: 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@matronics.com
[mailto:owner-yak-list-server@matronics.com] On Behalf Of Larry Pine
Sent: Tuesday, August 08, 2006 10:21 AM
To: yak-list@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-8), 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@verizon.net> wrote:
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
Larry Pine
Message 41
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Actually I know quit a bit. I have been doing it professionally for 16 yrs. Just
because one can buy a plane doesn't give that owner any special authority
in the eyes of the feds. Those that truely want to know how this is viewed by
the feds will find out. Those of you who don't care what they say..... Well
it won't matter anyway. I have no love for the FAA. I think they are out of
date and a hindrence to progress. But the discussion is about how they view
experimental exhibition maintenance.
Ron Davis <L39parts@hotmail.com> wrote: Larry,
Experimentals don't have annual inspections, and I've never heard of a "phase"
inspection. Of course I know what you meant, but the point is that you don't
know. You seem to not know a great deal about experimental planes. For example,
what is the point of having a maintenance manual? It was written by some
godless communist that never heard of the FAA's requirements. The manuals were
never been reviewed or approved by the FAA, so they have no legal standing.
The pictures are handy of course, provided you don't have to pay $20 for them...
----- Original Message -----
From: Larry Pine
To: yak-list@matronics.com
Sent: Monday, August 07, 2006 1:31 PM
Subject: Re: Yak-List: Re: Manuals
You are permitted to work on the aircraft but to only things listed in the FARs
under preventative maintenance or under the supervision of a A&P. A pilot
can make a log book entry about preventative maintenance performed only. An A&P
still must sign off annuals (phase inspections) and Maintenance items.
Larry
Scooter <yakk52@verizon.net> wrote:
--> Yak-List message posted by: "Scooter"
I almost hate to ask this then: when I (a non-A&P or anything else) work on my
Exp Exhibition aircraft do I need the manuals to sign-off the maintenance? Or
am I not permitted to work on the aircraft?
[quote="threein60(at)yahoo.com"]Actually, In experimental exhibition you need the
manuals in order to sign the maintenance off. All work must be done IAW the
original or
Larry Pine
---------------------------------
Message 42
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| Subject: | Re: 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@matronics.com
[mailto:owner-yak-list-server@matronics.com] On Behalf Of Larry Pine
Sent: Tuesday, August 08, 2006 11:56 AM
Subject: Re: Yak-List: Re: Maintenance, again
Experimental is not Experimental Exhibition!
flir47 <me262pilot@comcast.net> wrote:
--> 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>Larry Pine
________________________________
How low will we go? Check out Yahoo! Messenger's low PC-to-Phone call
rates.
<http://us.rd.yahoo.com/mail_us/taglines/postman8/*http:/us.rd.yahoo.com
/evt=39663/*http:/voice.yahoo.com>
Message 43
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| Subject: | Re: 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@matronics.com
[mailto:owner-yak-list-server@matronics.com] On Behalf Of doug sapp
Sent: Tuesday, August 08, 2006 2:09 PM
Subject: RE: Yak-List: 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
-----Original Message-----
From: owner-yak-list-server@matronics.com
[mailto:owner-yak-list-server@matronics.com]On Behalf Of Larry Pine
Sent: Tuesday, August 08, 2006 1:26 PM
To: yak-list@matronics.com
Subject: RE: Yak-List: 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@televar.com> wrote:
--> 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
-----Original Message-----
From: owner-yak-list-server@matronics.com
[mailto:owner-yak-list-server@matronics.com]On Behalf Of
flir47
Sent: Tuesday, August 08, 2006 11:22 AM
To: yak-list@matronics.com
Subject: Yak-List: Re: Maintenance, again
--> 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
Message 44
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|
| Subject: | Re: Maintenance, again |
This is like herding cats, I quit.
Always Yakin,
Doug Sapp
-----Original Message-----
From: owner-yak-list-server@matronics.com
[mailto:owner-yak-list-server@matronics.com]On Behalf Of John W. Cox
Sent: Tuesday, August 08, 2006 7:29 PM
To: yak-list@matronics.com
Subject: RE: Yak-List: Re: 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@matronics.com
[mailto:owner-yak-list-server@matronics.com] On Behalf Of doug sapp
Sent: Tuesday, August 08, 2006 2:09 PM
To: yak-list@matronics.com
Subject: RE: Yak-List: 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
-----Original Message-----
From: owner-yak-list-server@matronics.com
[mailto:owner-yak-list-server@matronics.com]On Behalf Of Larry Pine
Sent: Tuesday, August 08, 2006 1:26 PM
To: yak-list@matronics.com
Subject: RE: Yak-List: 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@televar.com> wrote:
--> 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
-----Original Message-----
From: owner-yak-list-server@matronics.com
[mailto:owner-yak-list-server@matronics.com]On Behalf Of flir47
Sent: Tuesday, August 08, 2006 11:22 AM
To: yak-list@matronics.com
Subject: Yak-List: Re: Maintenance, again
--> 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
Message 45
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|
| Subject: | Re: Maintenance, again |
John has said it all! and I agree!!
"John W. Cox" <johnwcox@pacificnw.com> wrote: Mr. Lawrences 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 OBrien
(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 repairmans 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. Lawrences 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@matronics.com [mailto:owner-yak-list-server@matronics.com] On Behalf Of Larry Pine
Sent: Tuesday, August 08, 2006 11:56 AM
Subject: Re: Yak-List: Re: Maintenance, again
Experimental is not Experimental Exhibition!
flir47 <me262pilot@comcast.net> wrote:
--> 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>Larry Pine
---------------------------------
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Larry Pine
---------------------------------
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Message 46
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| Subject: | Commercial rating |
Herb,
Here is Chapter 10 from the last DPE manual. Review Section 2,Paragraph
3 Procedures, G - Aircraft Requirements. There is no such restriction.
It is a personal decision between the Applicant and the DPE.
John Cox - retired since 2001 as a Commercial DPE
-----Original Message-----
From: owner-yak-list-server@matronics.com
[mailto:owner-yak-list-server@matronics.com] On Behalf Of Herb Coussons
Sent: Tuesday, August 08, 2006 3:27 PM
Subject: Yak-List: Commercial rating
--> Yak-List message posted by: Herb Coussons <drc@wscare.com>
Gang,
I am a private SEL, instrument pilot.
I have committed to getting a commercial rating since I have flown in
a few airshows this year and had to leave fuel funds behind.
(I also need to get busy with my FAST training so I can fly with
everyone at OSH and some of the Red Star groups)
My question is this. Can I get the commercial ticket in my Yak? I
have asked 2 flight instructors locally and both said no. Not based
on it being certified experimental exhibition but some other lame
excuse. I would have thought any CFI would want to spend several
hours in the back seat giving instruction. Is there any FAR that
prohibits taking advanced training or a flight test in our planes?
Surely someone has faced this before - any help is appreciated.
Herb
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Message 47
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| Subject: | Re: Maintenance, again |
Last time I looked, the cats win everytime.
Doc
----- Original Message -----
From: doug sapp
Sent: 8/8/2006 10:05:47 PM
Subject: RE: Yak-List: Re: Maintenance, again
This is like herding cats, I quit.
Always Yakin,
Doug Sapp
-----Original Message-----
From: owner-yak-list-server@matronics.com [mailto:owner-yak-list-server@matronics.com]On Behalf Of John W. Cox
Sent: Tuesday, August 08, 2006 7:29 PM
Subject: RE: Yak-List: Re: 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@matronics.com [mailto:owner-yak-list-server@matronics.com] On Behalf Of doug sapp
Sent: Tuesday, August 08, 2006 2:09 PM
Subject: RE: Yak-List: 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
-----Original Message-----
From: owner-yak-list-server@matronics.com [mailto:owner-yak-list-server@matronics.com]On Behalf Of Larry Pine
Sent: Tuesday, August 08, 2006 1:26 PM
Subject: RE: Yak-List: 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@televar.com> wrote:
--> 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
-----Original Message-----
From: owner-yak-list-server@matronics.com
[mailto:owner-yak-list-server@matronics.com]On Behalf Of flir47
Sent: Tuesday, August 08, 2006 11:22 AM
Subject: Yak-List: Re: Maintenance, again
--> 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
Message 48
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| Subject: | Frank Said.............. |
Yakkers
I've never had personal a beef with Barry.........
So why did he say.................
"next time, ask me for an ARS email list so you don't have to deal with the
Franks of the world.........life's too short"?
Did he mean to hurt somebody with that statement?
As an ARS leader he's supposed to be bigger than that and make decisions
from a position of moral superiority.
So now he's firing high powered shots across the bow of small time ARS
members like me?
And for what? Suggesting $20 per pic is high?
Leadership skills Barry, Leadership skills.....................
Frank
Ex-Military, served honorably and continues to do so........(yea, I still
work for a living).
Barry
Never served his country and continues to derive his wealth (and supposed
moral superiority) from ownership of liberal media. If only you guys knew
you'd have no respect at all.
Message 49
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| Subject: | Re: 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
.
----- Original Message -----
From: Larry Pine
Sent: 8/8/2006 10:07:18 PM
Subject: RE: Yak-List: Re: Maintenance, again
John has said it all! and I agree!!
"John W. Cox" <johnwcox@pacificnw.com> wrote:
Mr. Lawrences 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 OBrien (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 repairmans 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. Lawrences 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@matronics.com [mailto:owner-yak-list-server@matronics.com] On Behalf Of Larry Pine
Sent: Tuesday, August 08, 2006 11:56 AM
Subject: Re: Yak-List: Re: Maintenance, again
Experimental is not Experimental Exhibition!
flir47 <me262pilot@comcast.net> wrote:
--> 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>Larry Pine
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Larry Pine
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