Today's Message Index:
----------------------
1. 03:29 AM - Re: CJ6 pneumatic system emergency operation (Scorch)
2. 04:17 AM - Re: More Maintenance (Craig Payne)
3. 04:34 AM - Re: Re: Maintenance, again (A. Dennis Savarese)
4. 05:21 AM - Re: Re: CJ6 pneumatic system emergency operation (A. Dennis Savarese)
5. 06:22 AM - Re: Re: Maintenance, again (David McGirt)
6. 06:50 AM - Re: Maintenance, again (flir47)
7. 07:18 AM - Re: [Norton AntiSpam] Re: Re: Maintenance, again (Roger Kemp)
8. 07:24 AM - Re: Frank Said.............. (Tim Gagnon)
9. 07:32 AM - Maintenance, Regs, EAA (Jill Gernetzke)
10. 07:33 AM - [Norton AntiSpam] Re: Maintenance, again (Scooter)
11. 07:49 AM - Re: Maintenance, Regs, EAA (Robert Schwartz)
12. 07:56 AM - Re: Maintenance, again (Jill Gernetzke)
13. 08:16 AM - Re: Maintenance, Regs, EAA (David McGirt)
14. 09:37 AM - Re: Commercial rating (Scott Poehlmann)
15. 10:32 AM - RedStar Newletter/Mag (David McGirt)
16. 10:42 AM - Maintenance, again, again (Jerry Painter)
17. 10:43 AM - Re: RedStar Newletter/Mag (Scooter)
18. 11:03 AM - Re: [Norton AntiSpam] Re: Re: Maintenance, again (Bill Walker)
19. 12:03 PM - Re: Maintenance, again, again (Roger Kemp)
20. 12:18 PM - Re: Maintenance, again, again (flir47)
21. 12:20 PM - Re: Maintenance, again, again (David McGirt)
22. 12:23 PM - Re: Re: Maintenance, again, again (ggg6@att.net)
23. 02:33 PM - Re: Re: Maintenance, again (n13472@aol.com)
24. 03:34 PM - Re: Re: Maintenance, Regs, EAA (Craig Payne)
25. 04:27 PM - Last attempt then I'm out!! (maintenance) (Larry Pine)
26. 06:20 PM - Re: Last attempt then I'm out!! (maintenance) (A. Dennis Savarese)
27. 06:28 PM - Re: Last attempt then I'm out!! (maintenance) (A. Dennis Savarese)
28. 06:28 PM - Re: Re: Manuals (Ron Davis)
29. 06:35 PM - Re: Re: RedStar Newletter/Mag (Daniel Fortin)
30. 06:48 PM - Re: Re: Maintenance, again (Ron Davis)
31. 07:22 PM - Re: Last attempt then I'm out!! (maintenance) (Ron Davis)
32. 07:26 PM - Re: Last attempt then I'm out!! (maintenance) (Larry Pine)
33. 07:46 PM - Re: Last attempt then I'm out!! (maintenance) (A. Dennis Savarese)
34. 07:46 PM - No dog in the fight (Joe Enzminger)
35. 07:47 PM - Re: Last attempt then I'm out!! (maintenance) (Larry Pine)
36. 08:00 PM - Re: Maintenance, Regs, EAA (Ron Davis)
37. 10:28 PM - Desert Thunder III (Barry Hancock)
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| Subject: | Re: CJ6 pneumatic system emergency operation |
--> Yak-List message posted by: "Scorch" <greshell@bigpond.net.au>
Thanks Walt and Dennis for your replies. You have increased my understanding greatly.
The second part of my question was poorly written.
What I would really like to know is if the gear is already down, and you need emergency
brake pressure in a hurry (like rolling down the runway with no brakes),
is it an option just to open the emergency valve with the main valve still
open, or will the pressure be lost?
Thanks again
Read this topic online here:
http://forums.matronics.com/viewtopic.php?p=53588#53588
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| Subject: | Re: More Maintenance |
More Maintenance? No not really, I just finished the Digest version of yesterday's
'list and now I know why I chose the digest version. Well, I'm still a po'
boy doing my own wrenching but I can't seem to find that "juiced up axial flow
supercharger mod from JC Whitney" in my catalog; must be a new issue.
BTW, my "styrofoam cup and super glue" prop is doing just fine but needs repaint
since *someone" flew it in the rain coming back from OSH. Those Kevlar layers
I added to the blade back side really stand up to a beating but don't try this
at home without FAA approval :>)
Craig Payne
cpayne@joimail.com
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| Subject: | Re: Maintenance, again |
Roger has clearly expounded on my first reply to Larry in which I also
said to read FAR 43.1(b). Well done Roger.
Dennis
----- Original Message -----
From: Roger Kemp
To: yak-list@matronics.com
Sent: Wednesday, August 09, 2006 12:58 AM
Subject: RE: Yak-List: 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 product ion 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 =A7103.1 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 =A721.193 (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
=A721.190.]
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.
< B>[(e) In the case of a light-sport aircraft assembled from a kit to
be certificated in accordance with =A721.191 (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 =A721.190 (c), except that
instead of meeting =A721.190 (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 manufact ured 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
To: yak-list@matronics.com
Sent: 8/8/2006 10:07:18 PM
Subject: RE: Yak-List: Re: Maintenance, again
[LashBack]
John has said it all! and I agree!!
"John W. Cox" <johnwcox@pacificnw.com> wrote:
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
certificat e with an approved station, I have firsthand experience from
attempting to sign such an authorization in my previous life. This
requirement means that only th e 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 pr
eventative 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
-------------------------------------------------------------------------
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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
To: yak-list@matronics.com
Subject: Re: Yak-List: Re: Maintenance, again
[LashBack]
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 whic h
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 d o 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 no t 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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| Subject: | Re: CJ6 pneumatic system emergency operation |
--> Yak-List message posted by: "A. Dennis Savarese" <dsavarese@elmore.rr.com>
Many, many years ago I was told the emergency system on my Yak 52 was only
to extend the landing gear. That was before I really understood the system.
Then I thought about it and said to myself, "Self, wouldn't it dumb to
design a pneumatic system to extend the gear in an emergency but not be able
to stop the airplane once it was landed. Especially one that also had
pneumatic brakes!" So I tested the emergency system on the ground and
applied the brakes. They really do work with the emergency system air.
To answer your question directly, yes it is permissible to do that. After
you stop, turn off the emergency air valve. Then bleed off the pressure
from the emergency side in order for the landing gear actuators to operate
properly on the main air system again.
Dennis
----- Original Message -----
From: "Scorch" <greshell@bigpond.net.au>
Sent: Wednesday, August 09, 2006 5:29 AM
Subject: Yak-List: Re: CJ6 pneumatic system emergency operation
> --> Yak-List message posted by: "Scorch" <greshell@bigpond.net.au>
>
> Thanks Walt and Dennis for your replies. You have increased my
> understanding greatly.
>
> The second part of my question was poorly written.
> What I would really like to know is if the gear is already down, and you
> need emergency brake pressure in a hurry (like rolling down the runway
> with no brakes), is it an option just to open the emergency valve with the
> main valve still open, or will the pressure be lost?
>
> Thanks again
>
>
> Read this topic online here:
>
> http://forums.matronics.com/viewtopic.php?p=53588#53588
>
>
>
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| Subject: | Re: Maintenance, again |
So basically what you are all telling me, I did pay to much for my car
insurance.. damn..
( FOR THOSE A LITTLE TO WOUND TIGHT, THAT WAS A JOKE )
Good healthy discussion though.
David
_____
From: owner-yak-list-server@matronics.com
[mailto:owner-yak-list-server@matronics.com] On Behalf Of A. Dennis
Savarese
Sent: Wednesday, August 09, 2006 7:34 AM
Subject: Re: Yak-List: Re: Maintenance, again
Roger has clearly expounded on my first reply to Larry in which I also
said
to read FAR 43.1(b). Well done Roger.
Dennis
----- Original Message -----
From: Roger <mailto:viperdoc@mindspring.com> Kemp
Sent: Wednesday, August 09, 2006 12:58 AM
Subject: RE: Yak-List: 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 product ion
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 =A7103.1 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 =A721.193 (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
=A721.190.]
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.
< B>[(e) In the case of a light-sport aircraft assembled from a kit to
be
certificated in accordance with =A721.191 (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 =A721.190 (c), except that instead of
meeting
=A721.190 (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 manufact ured 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 <mailto:threein60@yahoo.com>
Sent: 8/8/2006 10:07:18 PM
Subject: RE: Yak-List: Re: Maintenance, again
[LashBack]
John has said it all! and I agree!!
"John W. Cox" <johnwcox@pacificnw.com> wrote:
Mr. Lawrence=92s 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=92Brien (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=92s certificat e with an approved station, I have
firsthand
experience from attempting to sign such an authorization in my previous
life. This requirement means that only th e 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=92s 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 pr eventative 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=85. May you legally
perform
Minor or Major alterations as a =93Po Boy=94 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 =93Get out of
Jail=94 card
is the one in written form from headquarters legal FAA ' DC.
John Cox ' =93Foto=94
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
[LashBack]
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 whic h 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 d o 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 no t 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=92s low PC-to-Phone
<http://us.rd.yahoo.com/mail_us/taglines/postman8/*http:/us.rd.yahoo.com/
evt
=39663/*http:/voice.yahoo.com> call rates.
Larry Pine
_____
Yahoo! Music Unlimited - Access over 1 million songs. Try
<http://pa.yahoo.com/*http:/us.rd.yahoo.com/evt=36035/*http:/music.yaho
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| Subject: | Re: Maintenance, again |
--> Yak-List message posted by: "flir47" <me262pilot@comcast.net>
Experimental includes Yaks and Chinko planes too. Most A&Ps think they are the
end all and. why would they want you the owner to repair anything? The answer
is they need the money. If youre mechanically handicapped then dont fix the plane.
Forget the rules . Just plain use your head! If someone makes a bad decision on
a repair it can have a severe impact on more than one person. But this is the
same person that will make a bad decision when flying the plane and, will more
than likely kill some people that way too.
Dennis there is no question youre the man when it comes to trouble shooting!!!!
Also, I will assume repair too. But. I know you were not born knowing what you
do. My guess is that you gained this knowledge by working on these planes. These
planes are by far not high tech! Not hard to figure out if you have any mechanical
aptitude. You helped me figure out the issue with the L/G actuators, on
my Russian tool shed that Im flying. I would guess that this is something you
were not trained in but.. you learned from working on these things. The job
of overhaul was a cake walk! Really a joke... no pics needed. Getting at the top
bolt really sucked though.
Any A&P that hides behind properly trained is in for the money only. They were
not properly trained on all types of aircraft as this is not feasible. Usually
they do have common sense and mechanical aptitude. This is enough to get the
job done.
For Gods sake.. A&Ps stop assuming that all people are inbiciles! Only some.
Bottom line Use your head!!!! And do not discuss religion or politics on line.
--------
It's not a real world war untill France surenders!
Read this topic online here:
http://forums.matronics.com/viewtopic.php?p=53611#53611
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| Subject: | Re: Maintenance, again |
Talon,
The greater than 2 hour research was not really from being wound to tight (which
on occasion, I am), it was to actually to bring the FAR's in black and white
(well red on the most important line) infront of all those that were pulling
shit of their asses without really knowing of what they spoke.
That's all,
I your case, you are not paying enough for insurance....you a dangerous young whipper
snapper on that Atlanta Freeway! I've seen you drive! :>)) !
Doc
----- Original Message -----
From: David McGirt
Sent: 8/9/2006 8:35:46 AM
Subject: [Norton AntiSpam] RE: Yak-List: Re: Maintenance, again
So basically what you are all telling me, I did pay to much for my car insurance..
damn..
( FOR THOSE A LITTLE TO WOUND TIGHT, THAT WAS A JOKE )
Good healthy discussion though.
David
From: owner-yak-list-server@matronics.com [mailto:owner-yak-list-server@matronics.com] On Behalf Of A. Dennis Savarese
Sent: Wednesday, August 09, 2006 7:34 AM
Subject: Re: Yak-List: Re: Maintenance, again
Roger has clearly expounded on my first reply to Larry in which I also said to
read FAR 43.1(b). Well done Roger.
Dennis
----- Original Message -----
From: Roger Kemp
Sent: Wednesday, August 09, 2006 12:58 AM
Subject: RE: Yak-List: 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 product ion 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.
< B>[(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 manufact ured 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
[LashBack]
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 certificat e with an
approved station, I have firsthand experience from attempting to sign such an
authorization in my previous life. This requirement means that only th e 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 pr eventative 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
[LashBack]
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 whic h 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 d o 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 no t 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! Messengers low PC-to-Phone call rates.
Larry Pine
Yahoo! Music Unlimited - Access over 1 million songs. Try it free.
Message 8
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| Subject: | Re: Frank Said.............. |
--> Yak-List message posted by: "Tim Gagnon" <NiftyYak50@msn.com>
Frank wrote:
> Yakkers
> I've never had personal a beef with Barry.........
>
> So why did he0 say.................
>
> "next time, ask me for an ARS email list so you0 don't have to deal with the
Franks of the world.........life's too0 short"?
>
> Did he mean to hurt somebody with that0 statement?
>
> As an ARS0 leader he's supposed to be bigger than that and make decisions from
a0 position of moral superiority.
>
> So now he's firing0 high powered shots across the bow of small time ARS members
like0 me?
>
> And for what? Suggesting0 $20 per pic is high?
>
> Leadership skills Barry,0 Leadership skills.....................
>
>
>
> Frank
> Ex-Military, served honorably and continues to do0 so........(yea, I still work
for a living).
>
> Barry0
> Never0 served his country and continues to derive his wealth (and supposed0
moral superiority) from ownership of liberal media. If only you guys knew you'd0
have no respect at all.
What in the hell does being in the service (or not) have to do with being a good
leader? I STILL serve and have seen some crap leadership from the the lowest
of the enlisted ranks all the way up to the folks with little stars on thier
shoulders. I have also seen fantastic leadership in the civilian world.
I think it is disgraceful to point out the fact that someone either chose not serve
or COULD not not serve for whatever reason. You imply that it is some sort
of character flaw. I would rather know someone who has never served than to
know someone who has serve think they are superior to someone who has not.
Frank, I am sure you were a pleasure to serve with. What exactly did you do by
the way? How long were you in?
What have you contributed to the ARS group..your "life saving" advice? Do you even
own an airplane anymore? Do you attend events? Do you host events?
Unfortunately Frank, you have a bit of colored history on this site and for awhile,
you were gone and all was quiet.
Barry, I know you know better..but nearly 100% of all military folks would respect
someones choice whether to serve or not. There are always the exceptions as
you can see.
Read this topic online here:
http://forums.matronics.com/viewtopic.php?p=53622#53622
Message 9
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| Subject: | Maintenance, Regs, EAA |
--> Yak-List message posted by: Jill Gernetzke <jill@m-14p.com>
Group,
Yak/CJ owners need to follow the letter of FAR 43, any applicable ADs
and the requirements of their Operating Limitations - PERIOD. With
that, they are in compliance.
As for the comments of Mr. Lawrence (EAA), you should remember that
starting in 1993 and continuing since then, he, his underling Randy
Hansen and boss Tom Poberezny have supported numerous efforts to keep
Russian and Chinese aircraft out of the U.S. and to keep them from
flying if they are here. This started with the moratorium in 1993.
This is the reason that I have not been to Oshkosh in years and I and
any aircraft I have in control will not be at Oshkosh in the future, as
long as these 3 men are affiliated with the EAA.
Principle is more important than business.
Carl W. Hays
Message 10
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| Subject: | Re: [Norton AntiSpam] Re: Maintenance, again |
--> Yak-List message posted by: "Scooter" <yakk52@verizon.net>
nice job on the research. that was the first post that really laid it all out.
viperdoc(at)mindspring.co wrote:
> Talon,
> The greater than 2 hour research was not really from being wound to tight (which
on occasion, I am), it was to actually to bring the FAR's in black and
> ---
Read this topic online here:
http://forums.matronics.com/viewtopic.php?p=53629#53629
Message 11
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| Subject: | Re: Maintenance, Regs, EAA |
--> Yak-List message posted by: "Robert Schwartz" <schwartzcompany@att.net>
I am a yak and an L29 owner. I have read the comments of carl hayes with
much interest. I have been to Oshkosh with my L29 for last 5 years. The
eastern euorpean warbird community, both jets and props are treated like
second class citizens there. After spending a great deal of fuel cost to
arrive at oshkosh and proudly display my aircraft, the eastern jets are
stuck so far out on the ramp that its beyond the line where they allow any
show goers to walk and thus non of these aircraft can be visited and seen by
the public. I asked about even double parkng non flying jets for show and
they said no room. then comes the T28's and the F86 and suddenly there is
lots of room. We are just outcasts at this event and the young people
today that come as visitors are very interested in seeing these classic
eastern communist era aircrafts. what a shame
ROBERT E. SCHWARTZ
delfin 2819
----- Original Message -----
From: "Jill Gernetzke" <jill@m-14p.com>
Sent: Wednesday, August 09, 2006 9:32 AM
Subject: Yak-List: Maintenance, Regs, EAA
> --> Yak-List message posted by: Jill Gernetzke <jill@m-14p.com>
>
> Group,
>
> Yak/CJ owners need to follow the letter of FAR 43, any applicable ADs and
> the requirements of their Operating Limitations - PERIOD. With that, they
> are in compliance.
>
> As for the comments of Mr. Lawrence (EAA), you should remember that
> starting in 1993 and continuing since then, he, his underling Randy Hansen
> and boss Tom Poberezny have supported numerous efforts to keep Russian and
> Chinese aircraft out of the U.S. and to keep them from flying if they are
> here. This started with the moratorium in 1993.
>
> This is the reason that I have not been to Oshkosh in years and I and any
> aircraft I have in control will not be at Oshkosh in the future, as long
> as these 3 men are affiliated with the EAA.
>
> Principle is more important than business.
>
> Carl W. Hays
>
>
>
Message 12
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| Subject: | Re: Maintenance, again |
--> Yak-List message posted by: Jill Gernetzke <jill@m-14p.com>
Group,
As I watch from the sidelines, I thought I would jump into the fray
with a couple of comments.
Re: Repairs and Logbooks
Logbooks are the life history of your aircraft. If you choose not
document your work and think you are getting away with something, good
for you. Think again when you go to sell the aircraft. I have done
quite a few pre-buy inspections over the years (not just Yaks) and I
can tell you that I hone in on those big, gaping holes in the logbook
history. Like a detective, the story gets pieced together when I put
the hairy eyeball to the aircraft itself. We just had an aircraft in
for maintenance - 40 hours on an overhauled engine - but I noted that
#7 cylinder had been pulled because of the way the locktabs were bent
at the cylinder base nuts. If you're doing maintenance and repairs and
not noting it in the logbook - it may bite you in the end. I am aware
of another Yak that was recently sold and had suffered a hydraulic
lock, owner-repaired. When I queried the new owner, the previous owner
was truthful about it. This is not a game anyone wants to lose, we
play for keeps. Be safe. Be smart.
Secondly, I don't think your A&P signing off your condition inspections
will appreciate you making repairs and not noting them. He/she is the
first one that the remaining loved ones will hang out to dry if you
become a smoking hole. I am all for Yak/CJ owners doing maintenance on
their aircraft, but guidance where necessary is prudent. I think
knowing your aircraft inside and out ultimately makes you a much safer
pilot. However, I have seen some pretty wacky things done over the
years. If you can't afford to maintain the aircraft in a safe manner,
you should not own it.
Jill Gernetzke
M-14P, Incorporated
4905 Flightline Drive
Kingman, AZ 86401 -7417
(928)-681-4400
Fax(928)681-4404
www.m-14p.com
Message 13
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| Subject: | Maintenance, Regs, EAA |
--> Yak-List message posted by: "David McGirt" <david@mcgirt.net>
Robert,
You make a valid point, and I am new to this community/politics, but not a
novice at observation.. and would agree with your observations of the "old
guard" that is clinging to the past..
Just like the WWII aircraft are the mainstay, the Vietnam era aircraft are
having to fight to get noticed, that change is scary to many..
I completely respect Carl's opinion and actions.
To a similar goal, but in a different action - A large group of RedStar
pilots have quietly become one of the largest groups at the major airshows (
Sun-n-Fun, Oshkosh, ect) This did not go unnoticed at Sun-n-Fun this year.
At Oshkosh, we made up a large part of the daily warbird show, and even
broke through, and were the low group on Saturday. In the same vain, there
were 4-8 L-39's up flying during the shows, and some of those in great
formations as well.
Although some of the old guard will not change, I do believe the public, EAA
Members, and fellow pilots are noticing the great machines that we have and
ACTUALLY FLY.. time will win this battle.. Just my opinion.
It is a joy to meet, talk and fly with all the RedStar pilots I come in
contact with.. This is one of the most open and welcoming groups I have
seen, and hope that does not change..
David
PS - Sorry to hijack the topic..
-----Original Message-----
From: owner-yak-list-server@matronics.com
[mailto:owner-yak-list-server@matronics.com] On Behalf Of Robert Schwartz
Sent: Wednesday, August 09, 2006 10:49 AM
Subject: Re: Yak-List: Maintenance, Regs, EAA
--> Yak-List message posted by: "Robert Schwartz" <schwartzcompany@att.net>
I am a yak and an L29 owner. I have read the comments of carl hayes with
much interest. I have been to Oshkosh with my L29 for last 5 years. The
eastern euorpean warbird community, both jets and props are treated like
second class citizens there. After spending a great deal of fuel cost to
arrive at oshkosh and proudly display my aircraft, the eastern jets are
stuck so far out on the ramp that its beyond the line where they allow any
show goers to walk and thus non of these aircraft can be visited and seen by
the public. I asked about even double parkng non flying jets for show and
they said no room. then comes the T28's and the F86 and suddenly there is
lots of room. We are just outcasts at this event and the young people
today that come as visitors are very interested in seeing these classic
eastern communist era aircrafts. what a shame
ROBERT E. SCHWARTZ
delfin 2819
----- Original Message -----
From: "Jill Gernetzke" <jill@m-14p.com>
Sent: Wednesday, August 09, 2006 9:32 AM
Subject: Yak-List: Maintenance, Regs, EAA
> --> Yak-List message posted by: Jill Gernetzke <jill@m-14p.com>
>
> Group,
>
> Yak/CJ owners need to follow the letter of FAR 43, any applicable ADs and
> the requirements of their Operating Limitations - PERIOD. With that, they
> are in compliance.
>
> As for the comments of Mr. Lawrence (EAA), you should remember that
> starting in 1993 and continuing since then, he, his underling Randy Hansen
> and boss Tom Poberezny have supported numerous efforts to keep Russian and
> Chinese aircraft out of the U.S. and to keep them from flying if they are
> here. This started with the moratorium in 1993.
>
> This is the reason that I have not been to Oshkosh in years and I and any
> aircraft I have in control will not be at Oshkosh in the future, as long
> as these 3 men are affiliated with the EAA.
>
> Principle is more important than business.
>
> Carl W. Hays
>
>
>
Message 14
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| Subject: | Re: Commercial rating |
--> Yak-List message posted by: "Scott Poehlmann" <scott-p@texas.net>
Hi Herb,
It's probably already been answered, but the short version is: if you can
get a CFI to do your training in the Yak, then you can do it, if not, then
no. The flight test is a different kettle of fish but again boils down to:
if you can get a DE or Inspector to agree to do the checkride in the Yak,
then you can do it, if not then no. The decision to instruct or examine in a
non-standard category aircraft is at the sole discretion of the
instructor/examiner.
Where are you located?
Scott
----- Original Message -----
From: "Herb Coussons" <drc@wscare.com>
Sent: Tuesday, 08 August, 2006 16:26
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 15
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| Subject: | RedStar Newletter/Mag |
I noticed that we still do not post the PDF version of the newsletter
online, why is that? I have wanted to send a link to a few people, and we
do not have it to link to?
David
Message 16
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| Subject: | Maintenance, again, again |
Cats, indeed...
I'll say it again, again: If you don't know what you're doing, don't do
it.
Don't try to fake it. We don't need rules or attorneys to know that goo
d
judgment is a prerequisite for flying and maintaining airplanes.
We, including the FAA, all know that owners do lots of work on their
airplanes, experimental and type certificated. Some do good work, some d
on
t. We all know that finding a good mechanic is difficult, finding one wh
o
is knowledgeable about CJ's/Yaks is more difficult. Most are expensive
(they have to eat, too), though probably cheaper than the guys who change
the oil in your Toyota or Chevy. The reason for the reams of written
materials required for type certificated a/c is to provide the info peopl
e
need in order to properly maintain the a/c. The most important thing you
learn in A&P school is to read the manuals, bad as many are, and do what
they say--don't try to make it up yourself. Even so, type certificated
airplanes, including airliners, crash because of maintenance problems and
people get killed. We don't have much of that stuff for our Yaks/CJ's, s
o
good judgment is even more necessary than with type certificated aircraft
=2E
The FAA/NTSB usually can't be bothered unless there are dead bodies to co
unt
There has been lots of good information dispensed on this List and some n
ot
so good. Fortunately, we all know airplanes are dangerous, that governme
nts
require them to be designed and built to at least be reasonably reliable
and
tolerant of many faults and we're usually pretty careful not to do stupid
things. Usually. We also know that lots of wonderful airplanes wear an
Experimental sticker, and sometimes they're designed as well as built by
amateurs. More power to them! But some are not so wonderful. I'd love
to
see someone come up with an electronic ignition system (like Klaus Sevier
has) that would work on our engines. The FAA and industry concentrate th
eir
energies on jets and the airlines, where the money is--that's both good a
nd
bad for us. My complaint is that some on this List promote the notion th
at
anyone can and therefore should jump in with both feet when they have no
idea what they're doing. Even if it was legal it wouldn't be smart.
Fate is still the Hunter. A swollen or failed seal can still bite at an
inopportune moment, a nickel part can still kill you. Don't believe
everything you hear or read. If you don't have the training and experien
ce
to be able to exercise the required judgment, don't. Flaming hair and ca
st
iron gonads may not be adequate. Your widow and kids may learn your
insurance company is tickled pink to decline payment because they have
discovered a minor discrepancy...
Let's be careful out there.
Jerry Painter
Wild Blue Aviation
425-876-0865
wild.blue@verizon.net
http://mysite.verizon.net/res0cs5r/index.html
Message 17
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| Subject: | Re: RedStar Newletter/Mag |
--> Yak-List message posted by: "Scooter" <yakk52@verizon.net>
Seems like the new newsletter/mag is a good incentive to get people to join and
stay with RPA. Might be best not to give it away (via a publically accessable
link). It really is nicely done.
Just my 2 cents.
david(at)mcgirt.net wrote:
> I noticed that we still do not post the PDF version of the newsletter online,
why is that? I have wanted to send a link to a few people, and we do not have
it to link to?
>
> David
Read this topic online here:
http://forums.matronics.com/viewtopic.php?p=53668#53668
Message 18
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| Subject: | Re: Maintenance, again |
I agree with Doc, Talon is not paying enough for car insurance, I've
ridden with him!
WB
----- Original Message -----
From: Roger Kemp
To: yak-list@matronics.com
Sent: Wednesday, August 09, 2006 9:17 AM
Subject: RE: [Norton AntiSpam] RE: Yak-List: Re: Maintenance, again
Talon,
The greater than 2 hour research was not really from being wound to
tight (which on occasion, I am), it was to actually to bring the FAR's
in black and white (well red on the most important line) infront of all
those that were pulling shit of their asses without really knowing of
what they spoke.
That's all,
I your case, you are not paying enough for insurance....you a
dangerous young whipper snapper on that Atlanta Freeway! I've seen you
drive! :>)) !
Doc
----- Original Message -----
From: David McGirt
To: yak-list@matronics.com
Sent: 8/9/2006 8:35:46 AM
Subject: [Norton AntiSpam] RE: Yak-List: Re: Maintenance, again
So basically what you are all telling me, I did pay to much for my
car insurance.. damn..
( FOR THOSE A LITTLE TO WOUND TIGHT, THAT WAS A JOKE )
Good healthy discussion though.
David
-------------------------------------------------------------------------
---
From: owner-yak-list-server@matronics.com
[mailto:owner-yak-list-server@matronics.com] On Behalf Of A. Dennis
Savarese
Sent: Wednesday, August 09, 2006 7:34 AM
To: yak-list@matronics.com
Subject: Re: Yak-List: Re: Maintenance, again
Roger has clearly expounded on my first reply to Larry in which I
also said to read FAR 43.1(b). Well done Roger.
Dennis
----- Original Message -----
From: Roger Kemp
To: yak-list@matronics.com
Sent: Wednesday, August 09, 2006 12:58 AM
Subject: RE: Yak-List: 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 solel y 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 product ion 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 =A7103.1 of this
chapter. An experimental certificate will not be issued under this
paragraph for thes e aircraft after January 31, 2008;
(2) Has been assembled-
(i) From an aircraft kit for which the applicant can provide the
information required by =A721.193 (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
=A721.190.]
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 with out appreciable change in the external configuration,
three-view drawings or three-view dimensioned photographs of the
aircraft.
< B>[(e) In the case of a light-sport aircraft assembled from a
kit to be certificated in accordance with =A721.191 (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 =A721.190 (c), except that
instead of meeting =A721.190 (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) th rough (e)(5) of this
section, for an aircraft kit manufactured outside of the United States,
evidence that the aircraft kit was manufact ured 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
To: yak-list@matronics.com
Sent: 8/8/2006 10:07:18 PM
Subject: RE: Yak-List: Re: Maintenance, again
[LashBack]
John has said it all! and I agree!!
"John W. Cox" <johnwcox@pacificnw.com> wrote:
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
certificat e with an approved station, I have firsthand experience from
attempting to sign such an authorization in my previous life. This
requirement means that only th e 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 pr
e ventative 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
To: yak-list@matronics.com
Subject: Re: Yak-List: Re: Maintenance, again
[LashBack]
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 whic h
you received an airworthin ess 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 wa nts 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 d o 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 yo ur 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 no t apply to
any aircraft fo r 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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call rates.
Larry Pine
------------------------------------------------------------------------
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free.
Message 19
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| Subject: | Maintenance, again, again |
Jerry,
You are on the money when you say,"If you don't know what you're doing, don't do
it. Don't try to fake it. We don't need rules or attorneys to know that good
judgment is a prerequisite for flying and maintaining airplanes."
The but here is the permeation through out the list yesterday that an "experimental"
aircraft owner could not work on their airplane without an A&P, which was
not true.
My advice to all is if you do not know what you are doing, do NOT do it without
HELP! Stupid is as Stupid DOES! Just because 43.1 b says you can does not mean
it is smart to do especially if you have not got a clue or as inept as a blue
balled monkey in a troop of horny orangutans!
One thing I always say to myself when I look at something on my plane with the
idea of fixing it "better". Why did the Russians do it this way? I then go to
the exploded drawings and the manual (hard copy and CD) to try to figure it out.
If I can't figure it out I ask others smarter than I. If they can not give
a plausible answer. I leave/fix it the way it was.
So Jerry you are dead on when you said what you said. No disagreement on that,
just disagreed on the part about maintenance by anyone other than an A&P or certified
repair station.
Doc
Message 20
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| Subject: | Re: Maintenance, again, again |
--> Yak-List message posted by: "flir47" <me262pilot@comcast.net>
Jerry one more correction The guy changing oil on my car is making about $8 an
hour. Find me a good A&P for that and Ill never touch my plane again. A&Ps charge
$100 to search for ADs on certified A/C. They are as bad if not worse than
layers. [Shocked]
--------
It's not a real world war untill France surenders!
Read this topic online here:
http://forums.matronics.com/viewtopic.php?p=53694#53694
Message 21
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| Subject: | Maintenance, again, again |
Well put Doc, lets take something that a average owner MIGHT choose to do:
In an effort to help those that may chose to work on some part of the
aircraft, could the A&P's give guidance on the basic and needed information
that should be logged in the logbook
Lets use this example - I want to change the main tires & tubes on my
aircraft, I have bought the exact replacements, replaced the tires and
tubes, and now it is time to properly note this in the logbook,
Date, Time - Part removed + Part put on ( serials? ) Name & Pilot #
David
_____
From: owner-yak-list-server@matronics.com
[mailto:owner-yak-list-server@matronics.com] On Behalf Of Roger Kemp
Sent: Wednesday, August 09, 2006 3:02 PM
Subject: RE: Yak-List: Maintenance, again, again
Jerry,
You are on the money when you say,"If you don't know what you're doing,
don't do it. Don't try to fake it. We don't need rules or attorneys to
know that good judgment is a prerequisite for flying and maintaining
airplanes."
The but here is the permeation through out the list yesterday that an
"experimental" aircraft owner could not work on their airplane without an
A&P, which was not true.
My advice to all is if you do not know what you are doing, do NOT do it
without HELP! Stupid is as Stupid DOES! Just because 43.1 b says you can
does not mean it is smart to do especially if you have not got a clue or as
inept as a blue balled monkey in a troop of horny orangutans!
One thing I always say to myself when I look at something on my plane with
the idea of fixing it "better". Why did the Russians do it this way? I then
go to the exploded drawings and the manual (hard copy and CD) to try to
figure it out. If I can't figure it out I ask others smarter than I. If they
can not give a plausible answer. I leave/fix it the way it was.
So Jerry you are dead on when you said what you said. No disagreement on
that, just disagreed on the part about maintenance by anyone other than an
A&P or certified repair station.
Doc
Message 22
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| Subject: | Re: Maintenance, again, again |
Sounds like you should have the guy who changes the oil on your car to maintain
you airplane.. Gary
-------------- Original message from "flir47" <me262pilot@comcast.net>: --------------
> --> Yak-List message posted by: "flir47"
>
> Jerry one more correction The guy changing oil on my car is making about
> $8 an hour. Find me a good A&P for that and Ill never touch my plane again.
> A&Ps charge $100 to search for ADs on certified A/C. They are as bad if
> not worse than layers. [Shocked]
>
> --------
> It's not a real world war untill France surenders!
>
>
>
>
> Read this topic online here:
>
> http://forums.matronics.com/viewtopic.php?p=53694#53694
>
>
>
>
>
>
>
>
>
>
>
>
>
>
>
>
>
>
<html>
<!-- BEGIN WEBMAIL STATIONERY -->
<head></head>
<body>
<!-- WEBMAIL STATIONERY noneset -->
<DIV></DIV>Sounds like you should have the guy who changes the oil on your car
to maintain you airplane.. Gary<BR>
The Y
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Message 23
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| Subject: | Re: Maintenance, again |
Strange thing here it appears that the BULK of the people that think A/P's are
required for our
aircraft are "A&P's" EH a little protectionisom at work.
Tom Elliott
CJ-6A
NX63727
SANDY VALLEY NV
-----Original Message-----
From: viperdoc@mindspring.com
Sent: Tue, 8 Aug 2006 8:24 PM
Subject: RE: Yak-List: Re: Maintenance, again
Last time I looked, the cats win everytime.
Doc
________________________________________________________________________
Message 24
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| Subject: | Re: Re: Maintenance, Regs, EAA |
>
> We are just outcasts at this event and the young people
> today that come as visitors are very interested in seeing these classic
> eastern communist era aircrafts. what a shame
>
> ROBERT E. SCHWARTZ
> delfin 2819
>
Yaaa! You should have been around in the good ole days, 10-11 years ago. We Chinese
and Eastern bloc guys were the Enemy! Never mind our honorable service in
America's military, the Old Guard shit on us then and still today. I remember
being run out of the WB "Hospitality" room even though I'd paid my share. PRICKS,
then, PRICKS now. I fly to show up those sorry A-holes.
Thank (God, Gods, Allah, Jehovah, etc. insert your choice), we got our act together
and put on the good show. It's been a tough battle but thanks to the L-Bird
guys who have always sufferred, we have friends. Some of these friends flew
5 times the combat missions the Glory Boys did in their Jets, with FAC losses
at 50%. Ask any Nam Grunt, the FAC's are real heros.
Craig Payne
cpayne@joimail.com
Message 25
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| Subject: | Last attempt then I'm out!! (maintenance) |
It is amazing how venomous some of you get with your comments. A legit question
was asked pertaining to maintenance and who can accomplish it. There are a few
on here that have direct experience in this field and others that know what
they have been told and if you disagree you are pulling stuff out your ass or
being told you have no clue what you are talking about. I will try this again
and well see how it goes. I have contacted two different FSDOs that I am familiar
with and have done work with and as predicted, I got two different answers.
So let me share with you exactly what I have been told and you make your
own mind up.
First the question came up, Why is the FAA requiring maintenance manuals. As
quoted by someone on line. They are worthless! FAA Order 8130.2F (64-2) states
on the initial inspection of the aircraft by an inspector A review of military
maintenance manuals and modification records affecting the subject aircraft
is current status and maintenance, for example, the military equivalent to
the FAA ADs.
Next, who can perform maintenance on an experimental Exhibition aircraft? FAA
Order 8130.2F States, The ability of civilian operators to maintain and operate
these aircraft depends on their background and experience, training and facilities,
availability of technical manuals and design information, and the complexity
of the aircraft involved. To this end and to the maximum extent feasible,
it is the policy off the FAA to recognize the most complete sources of maintenance
and training and to encourage owners, operators, and flightcrew to
use these sources and successfully complete required training from a recognized
training organization.
What must be done FAA Order 8130.2F section 10 (C-4) States, Aircraft under 800HP
must be inspected each year in accordance with an inspection plan that contains
the scope and detail of appendix D to Part 43.
What is an improved inspection plan? There are four main types but two are
the most common as called out in FAA 8300.10. You can either submit your own
maintenance program letter that includes the scope and detail of appendix 43.13
app D, or you can choose to comply with the inspection program recommended by
the applicable military service under FAR sect 91.409 (f) (3).
As to exhibition experimental the same as experimenal. Exibition is a sub catogory
or experimental. We do not abid to Experimetal (homebuilt) maintenance
rules. Only those spelled out in your letter of limitations and 8130. They are
not the same. In Experimetal (homebuilt) it does say that you will perform
an annual inspection and signed off by an appropriate authoried person or shop.
That is not stated in 8130.
FAA Order 8130, is a boiler plate outline for Certification and Operation of
aircraft under the Experimental purposes of Exhibition and Air Racing. These
are the parts that the FAA must include in your letter or limitations. As you
see there are some big holes as to who can do what. I was told by the Arizona
FSDO that the inspector has latitude to add more requirements then are written
on this boiler plate. AZ does not add a line for who should do maintenance.
Alabama on the other had does. No other FARs or Orders pertain directly with
our aircraft and maintenance. That is it! Bottom line, there is no one set
way of doing anything because it is not spelled out on 8130. You must do what
ever your own operating limitations states. The rest is your ability and conscience.
Ready for the snakes and venom again.!!!
Larry Pine
---------------------------------
Next-gen email? Have it all with the all-new Yahoo! Mail Beta.
Message 26
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| Subject: | Re: Last attempt then I'm out!! (maintenance) |
Larry,
Please indicate the applicable paragraph or paragraphs in 8130.2F that
states FAA approved maintenance manuals are required for issuance of the
Special Airworthiness Certificate in the Experimental Exhibition
category.
Dennis
----- Original Message -----
From: Larry Pine
To: yak-list@matronics.com
Sent: Wednesday, August 09, 2006 6:09 PM
Subject: Yak-List: Last attempt then I'm out!! (maintenance)
It is amazing how venomous some of you get with your comments. A legit
question was asked pertaining to maintenance and who can accomplish it.
There are a few on here that have direct experience in this field and
others that know what they have been told and if you disagree you are
pulling stuff out your ass or being told you have no clue what you are
talking about. I will try this again and we'll see how it goes. I have
contacted two different FSDOs that I am familiar with and have done work
with and as predicted, I got two different answers. So let me share
with you exactly what I have been told and you make your own mind up.
First the question came up, Why is the FAA requiring maintenance
manuals. As quoted by someone on line.. They are worthless! FAA Order
8130.2F (64-2) states on the initial inspection of the aircraft by an
inspector "A review of military maintenance manuals and modification
records affecting the subject aircraft is current status and
maintenance, for example, the military equivalent to the FAA AD's."
Next, who can perform maintenance on an experimental Exhibition
aircraft? FAA Order 8130.2F States, "The ability of civilian operators
to maintain and operate these aircraft depends on their background and
experience, training and facilities, availability of technical manuals
and design information, and the complexity of the aircraft involved. To
this end and to the maximum extent feasible, it is the policy off the
FAA to recognize the most complete sources of maintenance and training
and to encourage owners, operators, and flightcrew to use these sources
and successfully complete required training from a recognized training
organization."
What must be done. FAA Order 8130.2F section 10 (C-4) States,
"Aircraft under 800HP must be inspected each year in accordance with an
inspection plan that contains the scope and detail of appendix D to Part
43."
What is an improved inspection plan? There are four main types but
two are the most common as called out in FAA 8300.10. You can either
submit your own maintenance program letter that includes the scope and
detail of appendix 43.13 app D, or you can choose to comply with the
inspection program recommended by the applicable military service under
FAR sect 91.409 (f) (3).
As to exhibition experimental the same as experimenal. Exibition is a
sub catogory or experimental. We do not abid to Experimetal (homebuilt)
maintenance rules. Only those spelled out in your letter of limitations
and 8130. They are not the same. In Experimetal (homebuilt) it does say
that you will perform an annual inspection and signed off by an
appropriate authoried person or shop. That is not stated in 8130.
FAA Order 8130, is a boiler plate outline for Certification and
Operation of aircraft under the Experimental purposes of Exhibition and
Air Racing. These are the parts that the FAA must include in your
letter or limitations. As you see there are some big holes as to who
can do what. I was told by the Arizona FSDO that the inspector has
latitude to add more requirements then are written on this boiler plate.
AZ does not add a line for who should do maintenance. Alabama on the
other had does. No other FARs or Orders pertain directly with our
aircraft and maintenance. That is it! Bottom line, there is no one set
way of doing anything because it is not spelled out on 8130. You must
do what ever your own operating limitations states. The rest is your
ability and conscience.
Ready for the snakes and venom again.!!!
Larry Pine
Message 27
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| Subject: | Re: Last attempt then I'm out!! (maintenance) |
Larry,
Inspected to the "scope and detail of FAR 43 Appendix D" is all that is
required. Period. It only means that any inspection plan must meet the
scope and detail of Appendix D. There is nothing that says "approved"
anywhere. You can write your own inspection plan as long as it meets
the "scope and detail of Appendix D". You are really taking this to
extreme.
Dennis
----- Original Message -----
From: Larry Pine
To: yak-list@matronics.com
Sent: Wednesday, August 09, 2006 6:09 PM
Subject: Yak-List: Last attempt then I'm out!! (maintenance)
It is amazing how venomous some of you get with your comments. A legit
question was asked pertaining to maintenance and who can accomplish it.
There are a few on here that have direct experience in this field and
others that know what they have been told and if you disagree you are
pulling stuff out your ass or being told you have no clue what you are
talking about. I will try this again and we'll see how it goes. I have
contacted two different FSDOs that I am familiar with and have done work
with and as predicted, I got two different answers. So let me share
with you exactly what I have been told and you make your own mind up.
First the question came up, Why is the FAA requiring maintenance
manuals. As quoted by someone on line.. They are worthless! FAA Order
8130.2F (64-2) states on the initial inspection of the aircraft by an
inspector "A review of military maintenance manuals and modification
records affecting the subject aircraft is current status and
maintenance, for example, the military equivalent to the FAA AD's."
Next, who can perform maintenance on an experimental Exhibition
aircraft? FAA Order 8130.2F States, "The ability of civilian operators
to maintain and operate these aircraft depends on their background and
experience, training and facilities, availability of technical manuals
and design information, and the complexity of the aircraft involved. To
this end and to the maximum extent feasible, it is the policy off the
FAA to recognize the most complete sources of maintenance and training
and to encourage owners, operators, and flightcrew to use these sources
and successfully complete required training from a recognized training
organization."
What must be done. FAA Order 8130.2F section 10 (C-4) States,
"Aircraft under 800HP must be inspected each year in accordance with an
inspection plan that contains the scope and detail of appendix D to Part
43."
What is an improved inspection plan? There are four main types but
two are the most common as called out in FAA 8300.10. You can either
submit your own maintenance program letter that includes the scope and
detail of appendix 43.13 app D, or you can choose to comply with the
inspection program recommended by the applicable military service under
FAR sect 91.409 (f) (3).
As to exhibition experimental the same as experimenal. Exibition is a
sub catogory or experimental. We do not abid to Experimetal (homebuilt)
maintenance rules. Only those spelled out in your letter of limitations
and 8130. They are not the same. In Experimetal (homebuilt) it does say
that you will perform an annual inspection and signed off by an
appropriate authoried person or shop. That is not stated in 8130.
FAA Order 8130, is a boiler plate outline for Certification and
Operation of aircraft under the Experimental purposes of Exhibition and
Air Racing. These are the parts that the FAA must include in your
letter or limitations. As you see there are some big holes as to who
can do what. I was told by the Arizona FSDO that the inspector has
latitude to add more requirements then are written on this boiler plate.
AZ does not add a line for who should do maintenance. Alabama on the
other had does. No other FARs or Orders pertain directly with our
aircraft and maintenance. That is it! Bottom line, there is no one set
way of doing anything because it is not spelled out on 8130. You must
do what ever your own operating limitations states. The rest is your
ability and conscience.
Ready for the snakes and venom again.!!!
Larry Pine
Message 28
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How many "annuals" have you done on experimentals in those 16 years?
How many "phase" inspections on experimentals? If you've done any
you're ahead of me- and everybody else.
----- Original Message -----
From: Larry Pine
To: yak-list@matronics.com
Sent: Tuesday, August 08, 2006 7:11 PM
Subject: Re: Yak-List: Re: Manuals
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 29
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| Subject: | Re: RedStar Newletter/Mag |
--> Yak-List message posted by: "Daniel Fortin" <fougapilot@hotmail.com>
Dave and Scooter,
The objective was / is to have the Magazine available online. Unfortunately
as this is a volunteer organization, sometimes things take a little longer
then expected. But it is in the plans.
Thanks for the good comments, it is always pleasant to know when your work
is appreciated. My team and I are already working on the fall issue, so look
for it in your mailbox some time in the near future.
In the mean time, if any of you have pictures of OSH / MTW, we could
certainly use some nice shots of our merry bunch.
cheers,
Dan Fortin
>From: "Scooter" <yakk52@verizon.net>
>To: yak-list@matronics.com
>Subject: Yak-List: Re: RedStar Newletter/Mag
>Date: Wed, 9 Aug 2006 10:43:10 -0700
>
>--> Yak-List message posted by: "Scooter" <yakk52@verizon.net>
>
>Seems like the new newsletter/mag is a good incentive to get people to join
>and stay with RPA. Might be best not to give it away (via a publically
>accessable link). It really is nicely done.
>
>Just my 2 cents.
>
>
>david(at)mcgirt.net wrote:
> > I noticed that we still do not post the PDF version of the newsletter
>online, why is that? I have wanted to send a link to a few people, and we
>do not have it to link to?
> >
> > David
>
>
>Read this topic online here:
>
>http://forums.matronics.com/viewtopic.php?p=53668#53668
>
>
Message 30
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| Subject: | Re: Maintenance, again |
I seem to be having some problems with my computer- not a single FAR
came through. Read 14CFR65.104. It says:
"(b) The holder of a repairman certificate (experimental aircraft
builder) may perform condition inspections on the aircraft constructed
by the holder in accordace with the operating limitations of that
aircraft."
This does not apply to experimental- exhibition aircraft. The ops
limits of all of those that I have read say that the condition
inspection must done by an A&P, not an IA.
But I'll call you if I ever need a D check.
----- Original Message -----
From: John W. Cox
To: yak-list@matronics.com
Sent: Tuesday, August 08, 2006 7:16 PM
Subject: RE: Yak-List: 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
To: yak-list@matronics.com
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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rates.
Message 31
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| Subject: | Re: Last attempt then I'm out!! (maintenance) |
I agree with most of this, but you quote FAA Order 8130.2F section 10
(C-4) , "Aircraft under 800HP must be inspected each year in accordance
with an inspection plan that contains the scope and detail of appendix D
to Part 43". Quoting the regs/orders is good, but then you go off on
a tangent in the next paragraph by asking "What is an improved
inspection plan?"
An improved inspection plan would be one that is better than the old
one. On a related note, an APPROVED maintenace plan is what is required
for piston exhibition planes of over 800 HP and for jets. It has to be
submitted to FSDO and get their stamp on it.
----- Original Message -----
From: Larry Pine
To: yak-list@matronics.com
Sent: Wednesday, August 09, 2006 4:09 PM
Subject: Yak-List: Last attempt then I'm out!! (maintenance)
It is amazing how venomous some of you get with your comments. A legit
question was asked pertaining to maintenance and who can accomplish it.
There are a few on here that have direct experience in this field and
others that know what they have been told and if you disagree you are
pulling stuff out your ass or being told you have no clue what you are
talking about. I will try this again and we'll see how it goes. I have
contacted two different FSDOs that I am familiar with and have done work
with and as predicted, I got two different answers. So let me share
with you exactly what I have been told and you make your own mind up.
First the question came up, Why is the FAA requiring maintenance
manuals. As quoted by someone on line.. They are worthless! FAA Order
8130.2F (64-2) states on the initial inspection of the aircraft by an
inspector "A review of military maintenance manuals and modification
records affecting the subject aircraft is current status and
maintenance, for example, the military equivalent to the FAA AD's."
Next, who can perform maintenance on an experimental Exhibition
aircraft? FAA Order 8130.2F States, "The ability of civilian operators
to maintain and operate these aircraft depends on their background and
experience, training and facilities, availability of technical manuals
and design information, and the complexity of the aircraft involved. To
this end and to the maximum extent feasible, it is the policy off the
FAA to recognize the most complete sources of maintenance and training
and to encourage owners, operators, and flightcrew to use these sources
and successfully complete required training from a recognized training
organization."
What must be done. FAA Order 8130.2F section 10 (C-4) States,
"Aircraft under 800HP must be inspected each year in accordance with an
inspection plan that contains the scope and detail of appendix D to Part
43."
What is an improved inspection plan? There are four main types but
two are the most common as called out in FAA 8300.10. You can either
submit your own maintenance program letter that includes the scope and
detail of appendix 43.13 app D, or you can choose to comply with the
inspection program recommended by the applicable military service under
FAR sect 91.409 (f) (3).
As to exhibition experimental the same as experimenal. Exibition is a
sub catogory or experimental. We do not abid to Experimetal (homebuilt)
maintenance rules. Only those spelled out in your letter of limitations
and 8130. They are not the same. In Experimetal (homebuilt) it does say
that you will perform an annual inspection and signed off by an
appropriate authoried person or shop. That is not stated in 8130.
FAA Order 8130, is a boiler plate outline for Certification and
Operation of aircraft under the Experimental purposes of Exhibition and
Air Racing. These are the parts that the FAA must include in your
letter or limitations. As you see there are some big holes as to who
can do what. I was told by the Arizona FSDO that the inspector has
latitude to add more requirements then are written on this boiler plate.
AZ does not add a line for who should do maintenance. Alabama on the
other had does. No other FARs or Orders pertain directly with our
aircraft and maintenance. That is it! Bottom line, there is no one set
way of doing anything because it is not spelled out on 8130. You must
do what ever your own operating limitations states. The rest is your
ability and conscience.
Ready for the snakes and venom again.!!!
Larry Pine
Message 32
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| Subject: | Re: Last attempt then I'm out!! (maintenance) |
Dennis,
I gave you the facts directly from the FAA. You make your own mind up as to
how you view them. I was told (By the FAA) 43.13 does not apply to Exhibition
Experimental. It can be used as a guide line buy 43.13 pertains to certified
aircraft. The letter below should have been great news to all that do there
own maintenance. Do what ever is on you letter of limitations and that is it.
If not listed... NO A&P, NO IA, just you and your good judgment. This was directly
from the Feds themself. I didn't make it up. Trust me! Dennis if you
wish contact me off line and I will give you the name and number of my FSDO contact
and you can ask..
I believe the work APPROVED is actually in 91.409. Everyone in this catagory
should read Order 8130.2
"A. Dennis Savarese" <dsavarese@elmore.rr.com> wrote:
Larry,
Inspected to the "scope and detail of FAR 43 Appendix D" is all that is required.
Period. It only means that any inspection plan must meet the scope and
detail of Appendix D. There is nothing that says "approved" anywhere. You can
write your own inspection plan as long as it meets the "scope and detail of
Appendix D". You are really taking this to extreme.
Dennis
----- Original Message -----
From: Larry Pine
To: yak-list@matronics.com
Sent: Wednesday, August 09, 2006 6:09 PM
Subject: Yak-List: Last attempt then I'm out!! (maintenance)
It is amazing how venomous some of you get with your comments. A legit question
was asked pertaining to maintenance and who can accomplish it. There are a
few on here that have direct experience in this field and others that know what
they have been told and if you disagree you are pulling stuff out your ass
or being told you have no clue what you are talking about. I will try this again
and well see how it goes. I have contacted two different FSDOs that I am
familiar with and have done work with and as predicted, I got two different answers.
So let me share with you exactly what I have been told and you make your
own mind up.
First the question came up, Why is the FAA requiring maintenance manuals. As
quoted by someone on line. They are worthless! FAA Order 8130.2F (64-2) states
on the initial inspection of the aircraft by an inspector A review of military
maintenance manuals and modification records affecting the subject aircraft
is current status and maintenance, for example, the military equivalent to
the FAA ADs.
Next, who can perform maintenance on an experimental Exhibition aircraft? FAA
Order 8130.2F States, The ability of civilian operators to maintain and operate
these aircraft depends on their background and experience, training and facilities,
availability of technical manuals and design information, and the complexity
of the aircraft involved. To this end and to the maximum extent feasible,
it is the policy off the FAA to recognize the most complete sources of maintenance
and training and to encourage owners, operators, and flightcrew to
use these sources and successfully complete required training from a recognized
training organization.
What must be done FAA Order 8130.2F section 10 (C-4) States, Aircraft under 800HP
must be inspected each year in accordance with an inspection plan that contains
the scope and detail of appendix D to Part 43.
What is an improved inspection plan? There are four main types but two are
the most common as called out in FAA 8300.10. You can either submit your own
maintenance program letter that includes the scope and detail of appendix 43.13
app D, or you can choose to comply with the inspection program recommended by
the applicable military service under FAR sect 91.409 (f) (3).
As to exhibition experimental the same as experimenal. Exibition is a sub catogory
or experimental. We do not abid to Experimetal (homebuilt) maintenance
rules. Only those spelled out in your letter of limitations and 8130. They are
not the same. In Experimetal (homebuilt) it does say that you will perform
an annual inspection and signed off by an appropriate authoried person or shop.
That is not stated in 8130.
FAA Order 8130, is a boiler plate outline for Certification and Operation of
aircraft under the Experimental purposes of Exhibition and Air Racing. These
are the parts that the FAA must include in your letter or limitations. As you
see there are some big holes as to who can do what. I was told by the Arizona
FSDO that the inspector has latitude to add more requirements then are written
on this boiler plate. AZ does not add a line for who should do maintenance.
Alabama on the other had does. No other FARs or Orders pertain directly with
our aircraft and maintenance. That is it! Bottom line, there is no one set
way of doing anything because it is not spelled out on 8130. You must do what
ever your own operating limitations states. The rest is your ability and conscience.
Ready for the snakes and venom again.!!!
Larry Pine
Larry Pine
---------------------------------
Stay in the know. Pulse on the new Yahoo.com. Check it out.
Message 33
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| Subject: | Re: Last attempt then I'm out!! (maintenance) |
Larry,
FWIW, I have read and re-read not only 8130.2F and ALL of its
predecessors for the last 8 years. Why? Because I have had to
understand and interpret them inside and out. And I have cussed and
discussed all the issues you refer to more times than I care to think
about. Now I am out of this discussion...........
Dennis
----- Original Message -----
From: Larry Pine
To: yak-list@matronics.com
Sent: Wednesday, August 09, 2006 9:26 PM
Subject: Re: Yak-List: Last attempt then I'm out!! (maintenance)
Dennis,
I gave you the facts directly from the FAA. You make your own mind up
as to how you view them. I was told (By the FAA) 43.13 does not apply
to Exhibition Experimental. It can be used as a guide line buy 43.13
pertains to certified aircraft. The letter below should have been great
news to all that do there own maintenance. Do what ever is on you
letter of limitations and that is it. If not listed... NO A&P, NO IA,
just you and your good judgment. This was directly from the Feds
themself. I didn't make it up. Trust me! Dennis if you wish contact
me off line and I will give you the name and number of my FSDO contact
and you can ask..
I believe the work APPROVED is actually in 91.409. Everyone in this
catagory should read Order 8130.2
"A. Dennis Savarese" <dsavarese@elmore.rr.com> wrote:
Larry,
Inspected to the "scope and detail of FAR 43 Appendix D" is all that
is required. Period. It only means that any inspection plan must meet
the scope and detail of Appendix D. There is nothing that says
"approved" anywhere. You can write your own inspection plan as long as
it meets the "scope and detail of Appendix D". You are really taking
this to extreme.
Dennis
----- Original Message -----
From: Larry Pine
To: yak-list@matronics.com
Sent: Wednesday, August 09, 2006 6:09 PM
Subject: Yak-List: Last attempt then I'm out!! (maintenance)
It is amazing how venomous some of you get with your comments. A
legit question was asked pertaining to maintenance and who can
accomplish it. There are a few on here that have direct experience in
this field and others that know what they have been told and if you
disagree you are pulling stuff out your ass or being told you have no
clue what you are[LashBack] talking about. I will try this again and
we'll see how it goes. I have contacted two different FSDOs that I am
familiar with and have done work with and as predicted, I got two
different answers. So let me share with you exactly what I have been
told and you make your own mind up.
First the question came up, Why is the FAA requiring maintenance
manuals. As quoted by someone on line.. They are worthless! FAA Order
8130.2F (64-2) states on the initial inspection of the aircraft by an
inspector "A review of military maintenance manuals and modification
records affecting the subject aircraft is current status and
maintenance, for example, the military equivalent to the FAA AD's."
Next, who can perform maintenance on an experimental Exhibition
aircraft? FAA Order 8130.2F States, "The ability of civilian operators
to maintain and operate these aircraft depends on their background and
experience, training and facilities, availability of technical manuals
and design information, and the complexity of the aircraft involved. To
this end and to the maximum extent feasible, it is the policy off the
FAA to recognize the most complete sources of maintenance and training
and to encourage owners, operators, and flightcrew to use these sources
and successfully complete required training from a recognized training
organization."
What must be done. FAA Order 8130.2F section 10 (C-4) States,
"Aircraft under 800HP must be inspected each year in accordance with an
inspection plan that contains the scope and detail of appendix D to Part
43."
What is an improved inspection plan? There are four main types
but two are the most common as called out in FAA 8300.10. You can
either submit your own maintenance program letter that includes the
scope and detail of appendix 43.13 app D, or you can choose to comply
with the inspection program recommended by the applicable military
service under FAR sect 91.409 (f) (3).
As to exhibition experimental the same as experimenal. Exibition
is a sub catogory or experimental. We do not abid to Experimetal
(homebuilt) maintenance rules. Only those spelled out in your letter of
limitations and 8130. They are not the same. In Experimetal (homebuilt)
it does say that you will perform an annual inspection and signed off by
an appropriate authoried person or shop. That is not stated in 8130.
FAA Order 8130, is a boiler plate outline for Certification and
Operation of aircraft under the Experimental purposes of Exhibition and
Air Racing. These are the parts that the FAA must include in your
letter or limitations. As you see there are some big holes as to who
can do what. I was told by the Arizona FSDO that the inspector has
latitude to add more requirements then are written on this boiler plate.
AZ does not add a line for who should do maintenance. Alabama on the
other had does. No other FARs or Orders pertain directly with our
aircraft and maintenance. That is it! Bottom line, there is no one set
way of doing anything because it is not spelled out on 8130. You must
do what ever your own operating limitations states. The rest is your
ability and conscience.
Ready for the snakes and venom again.!!!
Larry Pine
Larry Pine
-------------------------------------------------------------------------
-----
Stay in the know. Pulse on the new Yahoo.com. Check it out.
Message 34
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| Subject: | No dog in the fight |
--> Yak-List message posted by: "Joe Enzminger" <panchoandlefty2002@yahoo.com>
A comment, however, on the nature of the discussion and my experience with the
T-34.
A word to the wise - remember that this isn't a "private" discussion. When we
were dealing with the FAA on the T-34 spar issue, we had to do a lot of work to
dispel the notion in the eyes of the FAA that we were a bunch of cowboy pilots
who played fast and loose with the rules and who had no respect for the FAA.
Where did they get that impression? They're sole source of information was reading
our yahoo discussion group. We actually shut down the public list in favor
of a private member only list so that we could have frank and honest discussions
without having to worry too much about who might read it and take one incorrect
point of view and apply it to the whole group. It's not fair and sort
of Orwellian, but it's the facts and the way it works in real life unfortunately.
So remember....anything written here is here for a long time and you can't easily
take it back. My personal point of view is that any discussion of contested
rules interpretation, FSDO's, and the machinations of the FAA are best kept
off a public forum. This would probably be a great discussion to have in person
at the next ARS.
Joe Enzminger
Read this topic online here:
http://forums.matronics.com/viewtopic.php?p=53775#53775
Message 35
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| Subject: | Re: Last attempt then I'm out!! (maintenance) |
I am so trying trying to get out of this conversation!! It states that to register
in Exh Exp, one of the requirments it to submit an approved maintenance plan.
So what is approved? That is where the other section comes in 91. This
section is for inspector and what they need to look at in order to certify aircraft.
Look folks I has just trying to get at the truth because it is not written,
it is left open to interpretation. That is where the problem is. 8130
is a boiler plate or template. Not the end all bet all. The inspector as room
to add other requirments as he sees fit.
OK this time I mean it I'm out!! Have fun!!
Ron Davis <L39parts@hotmail.com> wrote:
I agree with most of this, but you quote FAA Order 8130.2F section 10
(C-4) , Aircraft under 800HP must be inspected each year in accordance with an
inspection plan that contains the scope and detail of appendix D to Part 43".
Quoting the regs/orders is good, but then you go off on a tangent in the
next paragraph by asking "What is an improved inspection plan?"
An improved inspection plan would be one that is better than the old one. On
a related note, an APPROVED maintenace plan is what is required for piston exhibition
planes of over 800 HP and for jets. It has to be submitted to FSDO and
get their stamp on it.
----- Original Message -----
From: Larry Pine
To: yak-list@matronics.com
Sent: Wednesday, August 09, 2006 4:09 PM
Subject: Yak-List: Last attempt then I'm out!! (maintenance)
It is amazing how venomous some of you get with your comments. A legit question
was asked pertaining to maintenance and who can accomplish it. There are a
few on here that have direct experience in this field and others that know what
they have been told and if you disagree you are pulling stuff out your ass
or being told you have no clue what you are talking about. I will try this again
and well see how it goes. I have contacted two different FSDOs that I am
familiar with and have done work with and as predicted, I got two different answers.
So let me share with you exactly what I have been told and you make your
own mind up.
First the question came up, Why is the FAA requiring maintenance manuals. As
quoted by someone on line. They are worthless! FAA Order 8130.2F (64-2) states
on the initial inspection of the aircraft by an inspector A review of military
maintenance manuals and modification records affecting the subject aircraft
is current status and maintenance, for example, the military equivalent to
the FAA ADs.
Next, who can perform maintenance on an experimental Exhibition aircraft? FAA
Order 8130.2F States, The ability of civilian operators to maintain and operate
these aircraft depends on their background and experience, training and facilities,
availability of technical manuals and design information, and the complexity
of the aircraft involved. To this end and to the maximum extent feasible,
it is the policy off the FAA to recognize the most complete sources of maintenance
and training and to encourage owners, operators, and flightcrew to
use these sources and successfully complete required training from a recognized
training organization.
What must be done FAA Order 8130.2F section 10 (C-4) States, Aircraft under 800HP
must be inspected each year in accordance with an inspection plan that contains
the scope and detail of appendix D to Part 43.
What is an improved inspection plan? There are four main types but two are
the most common as called out in FAA 8300.10. You can either submit your own
maintenance program letter that includes the scope and detail of appendix 43.13
app D, or you can choose to comply with the inspection program recommended by
the applicable military service under FAR sect 91.409 (f) (3).
As to exhibition experimental the same as experimenal. Exibition is a sub catogory
or experimental. We do not abid to Experimetal (homebuilt) maintenance
rules. Only those spelled out in your letter of limitations and 8130. They are
not the same. In Experimetal (homebuilt) it does say that you will perform
an annual inspection and signed off by an appropriate authoried person or shop.
That is not stated in 8130.
FAA Order 8130, is a boiler plate outline for Certification and Operation of
aircraft under the Experimental purposes of Exhibition and Air Racing. These
are the parts that the FAA must include in your letter or limitations. As you
see there are some big holes as to who can do what. I was told by the Arizona
FSDO that the inspector has latitude to add more requirements then are written
on this boiler plate. AZ does not add a line for who should do maintenance.
Alabama on the other had does. No other FARs or Orders pertain directly with
our aircraft and maintenance. That is it! Bottom line, there is no one set
way of doing anything because it is not spelled out on 8130. You must do what
ever your own operating limitations states. The rest is your ability and conscience.
Ready for the snakes and venom again.!!!
Larry Pine
Larry Pine
---------------------------------
Get your email and more, right on the new Yahoo.com
Message 36
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| Subject: | Re: Maintenance, Regs, EAA |
--> Yak-List message posted by: "Ron Davis" <L39parts@hotmail.com>
So you can read 14CFR43.1 Applicability, which says in paragraph (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." and conclude that the
person who wrote this didn't know what he was talking about, but ALL OF THE
REST OF PART 43 DOES APPLY?
What color is the sky in your world?
----- Original Message -----
From: "Jill Gernetzke" <jill@m-14p.com>
Sent: Wednesday, August 09, 2006 7:32 AM
Subject: Yak-List: Maintenance, Regs, EAA
> --> Yak-List message posted by: Jill Gernetzke <jill@m-14p.com>
>
> Group,
>
> Yak/CJ owners need to follow the letter of FAR 43, any applicable ADs and
> the requirements of their Operating Limitations - PERIOD. With that, they
> are in compliance.
>
> As for the comments of Mr. Lawrence (EAA), you should remember that
> starting in 1993 and continuing since then, he, his underling Randy Hansen
> and boss Tom Poberezny have supported numerous efforts to keep Russian and
> Chinese aircraft out of the U.S. and to keep them from flying if they are
> here. This started with the moratorium in 1993.
>
> This is the reason that I have not been to Oshkosh in years and I and any
> aircraft I have in control will not be at Oshkosh in the future, as long
> as these 3 men are affiliated with the EAA.
>
> Principle is more important than business.
>
> Carl W. Hays
>
>
>
Message 37
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| Subject: | Desert Thunder III |
Make plans now.... ;)
Gang,
I've taken our formal event description and put it here. Again, all
aircraft are welcome - invite your friends with spam cans! This is a
blast! Even if you're out of the region it will be well worth your
while to commercial in and join in on the fun!
Barry
Desert Thunder III, Oct 26 - 29, 2006
=EF=BC
RedStar Pilot=99s Association
South West Regional
Cochran Regional Airport (KTRM), Palm Desert California
Oct 26 - 29, 2006
Event Description:
A very different event, this fly-in is designed around actual United
States Conventional and Special Operations Combat Crew Mission
Planning an Execution pre-deployment training conducted for flight
crews in and around the deserts of the southwest. The scenarios and
mission rolls are adapted to those most suitable for the aircraft
participating and include a mix of traditional Blue Air Force and
Black Mission rolls as the scenario dictates.
The concept is simple; based on provided intelligence and the
commanders intent, plan an integrated, multi-mission, time sensitive
operational plan and execute against actual non-lethal airborne/
ground threats while adapting to live intelligence updates to achieve
the mission objective. The scenario is designed to achieve some idea
of the requirements, decision making processes and stress involved in
military aviation mission execution. The goals are flight safety,
mission planning & briefing, use of effective flight tactics, radio
discipline, team work in a multi-mission scenario and of course, good
times had by all. Formation skills are required in some roles, but
not all. Some rolls include reacting to opposition air forces
(OPFOR), but strict limitations on full up "air combat" will be in
place; this is not a 1v1 or 1 v many event, but proper reaction to
OPFOR is required for overall mission success.
NO FAST TRAINING IS CONDUCTED AT THIS EVENT.
NO FULL UP ACM TRAINING OR DUELING AT THIS EVENT
Attendance requirements and Mission Rolls:
The event is entirely dependant on both flight crews and ground crews
participating to "flush out" all required rolls to conduct a
successful training scenario. Because of this, if the minimum
critical rolls are not filled, the event may be cancelled - a
decision that will be communicated well prior to the event date to
all registrants. For those with out warbirds or who would just like
to participate in any roll needed, non-piloting rolls are as involved
and fun as any stick and rudder requirement and include:
Joint Operations Task Force Command & Staff
Navigator/Weapons Officer
Airborne Controller
Airborne Radio Officer
Ground Anti-Aircraft Teams
CSAR Recovery/SOF
Red Air Component
Scenario driven events have ample opportunity for different types of
aircraft, SEL/MEL, warbird and non warbird. Scenarios are effectively
realistic, but not restricted by current generation technology or
strict adherence to modern mission rolls. Historical-period scenarios
may be used that effectively reflect the capabilities of the over-all
warbird fleet.
Strike
Air Interdiction
Recon
Bomber
Bomber Escort
SOF/CSAR
Cargo
Tanker
ABCCC (airborne command & control)
Red Air
The JTF (Joint Task Force) and Veteran Involvement:
The JTF Command & Staff will conduct the scenario, provide real time
intel updates and also assume management of the oppositions response
and help effectively conduct post scenario debriefs in a positive
learning environment. JTF has overall opcon (Operational Control) of
the event and veterans from military ground and air combat and
related deployable units are heavily desired! Likewise, veteran
aircrew members are needed as Flight Safety Officers and instructors
in all rolls. The online registration form (click here) will allow us
to recognize supporting veterans.
FAST REQUIREMENT & SUPPORTING INFO:
Please note, some rolls listed on the registration form are noted
with "FST", this is an indication that a FAST qualification card is
required to be assigned to this roll. No FAST training of any type
will be conducted at Desert Thunder (DT). Some mission rolls will
require Tactical Formation and low altitude navigation skill sets
which will be reviewed and practiced in DT.
For those registering for DT, follow on E-Coms will be sent with
required information. The cost of the event is being determined by
participation and support requirements, and will be sent to
registrants in a future e-com. Because of the specialized nature of
this event, many active duty military fliers participate and enhance
the experience through volunteer efforts, we do feel it is the least
we can do to cover their costs of attending the event and repay them
by not allowing them to buy their own drinks while at the event!
To register to attend please click here. If you have any questions,
please feel free to contact me directly... barry@flyredstar.org
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