Today's Message Index:
----------------------
1. 05:31 AM - Re: FSDO changing operating limitations on pre-moratorium aircra (A. Dennis Savarese)
2. 05:48 AM - Re: FSDO changing operating limitations on pre-moratorium aircra (A. Dennis Savarese)
3. 07:20 AM - Re: Experimental Class (Bitterlich, Mark G CIV Det Cherry Point, MALS-14 64E)
4. 07:21 AM - Re: Fw: X-ponder squawk - (Bitterlich, Mark G CIV Det Cherry Point, MALS-14 64E)
5. 07:29 AM - Re: FSDO changing operating limitations on pre-moratorium aircra (Bitterlich, Mark G CIV Det Cherry Point, MALS-14 64E)
6. 07:32 AM - Re: FSDO changing operating limitations on pre-moratorium aircra (Bitterlich, Mark G CIV Det Cherry Point, MALS-14 64E)
7. 08:17 AM - Re: FSDO changing operating limitations on pre-moratorium aircra (Pete Fowler)
8. 09:02 AM - Re: Re: FSDO changing operating limitations on pre-moratorium aircra (A. Dennis Savarese)
9. 10:34 AM - Re: FSDO changing operating limitations on pre-moratorium aircra (William Halverson)
10. 11:33 AM - Re: FSDO changing operating limitations on pre-moratorium aircra (A. Dennis Savarese)
11. 11:37 AM - Re: FSDO changing operating limitations on pre-moratorium aircra (Tom Elliott)
12. 11:47 AM - Re: FSDO changing operating limitations on pre-moratorium aircra (A. Dennis Savarese)
13. 12:09 PM - Re: FSDO changing operating limitations on pre-moratorium aircra (Eric Wobschall)
14. 07:55 PM - Yak 18t (bigglesusa)
15. 09:00 PM - Re: Experimental Class (bill wade)
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| Subject: | Re: FSDO changing operating limitations on pre-moratorium aircra |
Peter,
My comment is the FSDO does not need to understand what Pre Moratorium
means. All they have to do is read the words in the Order. If the
aircraft received its Special Airworthiness Certificate prior to July 9,
1993, it is not affected by the Order. It doesn't matter what it means.
The words are quite clear.
FAA Order 8130.2F Change 4. Paragraph d and e are the important
paragraphs with paragraph e begin the most important. (Page 166) It
reads:
d. Experimental Airworthiness Certification Moratorium. On July 9, 1993,
a moratorium was established because of a dramatic increase in
applications for special airworthiness certificates and SFAs for
non-U.S.-manufactured aircraft that did not hold TCs issued under =A7
21.29. The moratorium was lifted on August 18, 1993, with interim
guidance provided to certificate these aircraft. Although the moratorium
was established for non-U.S.-manufactured aircraft, this policy will be
used when issuing a special airworthiness certificate for the
experimental purpose(s) of exhibition or air racing, regardless of the
country of manufacture.
e. Effectivity. Aircraft that received original airworthiness
certification before July 9, 1993, are NOT affected by this order unless
the original airworthiness certification purpose changes, for example,
from R&D to exhibition. Those aircraft, except for purpose changes, will
not be affected until the FAA works with the public to determine the
best strategy to certificate all experimental exhibition and/or air
racing aircraft in accordance with the new policy. The policy
established in this order will not be used in these cases unless
specifically requested by the applicant.
I think the operative words that require explanation and justification
by your FSDO are: "Those aircraft, except for purpose changes, will not
be affected until the FAA works with the public to determine the best
strategy to certificate all experimental exhibition and/or air racing
aircraft in accordance with the new policy."
If a new policy has been established which we or EAA or WBA are not
aware of, ask your FSDO to give you a copy of this new policy. It also
says in the last sentence, "The policy established in this order will
not be used in these cases unless specifically requested by the
applicant."
Since you have not requested a purpose change, like from Exhibition to
Air Racing, the FSDO should be able to give you a bonafide reason to
reissue your OL's.
Any aircraft issued a new Experiment Exhibition Special Airworthiness
Certificate today will be issued Operating Limitations in accordance
with the present FAA Order, 8130.2F Change 4. Thus, the FSDO has to use
the latest version of the Order to issue or change OL's. The latest
version contradicts what your FSDO decided to do with your OL's
Finally, and most important of all is the statement "Aircraft that
received original airworthiness certification before July 9, 1993, are
NOT affected by this order unless the original airworthiness
certification purpose changes, for example, from R&D to exhibition."
ARE NOT AFFECTED BY THIS ORDER is in English and is quite plain and
simple to understand. The English language is not subject
interpretation.
I will be anxious to hear what the EAA/WBA has to say as well as your
FSDO when you present your case to them.
Dennis
----- Original Message -----
From: Pete Fowler
To: yak-list@matronics.com
Sent: Saturday, May 22, 2010 10:06 AM
Subject: Yak-List: FSDO changing operating limitations on
pre-moratorium aircra
While I can't get in touch with the people who can help over the
weekend, I thought I'd post this for reference.
I have a pre-moratorium Nanchang with operating limitations that have
few limitations (virtually none) that the aircraft has been operating
under since 1991.
Out of the blue my local FSDO called and said they had my "new
operating limitations". I went and reviewed them at the FSDO and
politely declined to accept or sign them and am contacting EAA warbirds
and another source at the FAA who I haven't heard back from yet but, in
a nutshell, the FSDO is trying to put all the limitations on my plane
that are "normal" for Nanchangs but is markedly different than the ones
I have. The only thing they left in there was that there is no range
restriction. I don't and they don't understand what pre-moratorium
really means in terms of what they can and can't do.
So I'm wondering if anyone knows the actual regulations that cover
re-writing operating limitations. The plane has had no configuration
change, nor did I request a change of operating limitations so am
wondering under what regulation the FSDO can not only re-write but add a
lot of contradictory and confusing limitations (suddenly it's VFR day
only but later it's VFR only if not equipped for night VFR, stuff like
that). I know there are a lot of opinions but I'd like to be able to
read the actual regulations regarding this but can't seem to find
anything on the FAA website due to an overwhelming number of hits on the
search.
--------
N4183E
http://nanchangcjs.yuku.com/
Read this topic online here:
http://forums.matronics.com/viewtopic.php?p=298512#298512
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| Subject: | Re: FSDO changing operating limitations on pre-moratorium aircra |
Researching Change 5 to 8130.2F, issued in April of 2010, paragraph's
"d" and "e" on page 166 are identical to Change 4. Therefore, in my
previous email, replace the words "Change 4" with the words "Change 5".
FWIW, the word "moratorium" only appears in these two paragraphs in the
entire Order.
Dennis
----- Original Message -----
From: A. Dennis Savarese
To: yak-list@matronics.com
Sent: Sunday, May 23, 2010 7:29 AM
Subject: Re: Yak-List: FSDO changing operating limitations on
pre-moratorium aircra
Peter,
My comment is the FSDO does not need to understand what Pre Moratorium
means. All they have to do is read the words in the Order. If the
aircraft received its Special Airworthiness Certificate prior to July 9,
1993, it is not affected by the Order. It doesn't matter what it means.
The words are quite clear.
FAA Order 8130.2F Change 4. Paragraph d and e are the important
paragraphs with paragraph e begin the most important. (Page 166) It
reads:
d. Experimental Airworthiness Certification Moratorium. On July 9,
1993, a moratorium was established because of a dramatic increase in
applications for special airworthiness certificates and SFAs for
non-U.S.-manufactured aircraft that did not hold TCs issued under =A7
21.29. The moratorium was lifted on August 18, 1993, with interim
guidance provided to certificate these aircraft. Although the moratorium
was established for non-U.S.-manufactured aircraft, this policy will be
used when issuing a special airworthiness certificate for the
experimental purpose(s) of exhibition or air racing, regardless of the
country of manufacture.
e. Effectivity. Aircraft that received original airworthiness
certification before July 9, 1993, are NOT affected by this order unless
the original airworthiness certification purpose changes, for example,
from R&D to exhibition. Those aircraft, except for purpose changes, will
not be affected until the FAA works with the public to determine the
best strategy to certificate all experimental exhibition and/or air
racing aircraft in accordance with the new policy. The policy
established in this order will not be used in these cases unless
specifically requested by the applicant.
I think the operative words that require explanation and justification
by your FSDO are: "Those aircraft, except for purpose changes, will not
be affected until the FAA works with the public to determine the best
strategy to certificate all experimental exhibition and/or air racing
aircraft in accordance with the new policy."
If a new policy has been established which we or EAA or WBA are not
aware of, ask your FSDO to give you a copy of this new policy. It also
says in the last sentence, "The policy established in this order will
not be used in these cases unless specifically requested by the
applicant."
Since you have not requested a purpose change, like from Exhibition to
Air Racing, the FSDO should be able to give you a bonafide reason to
reissue your OL's.
Any aircraft issued a new Experiment Exhibition Special Airworthiness
Certificate today will be issued Operating Limitations in accordance
with the present FAA Order, 8130.2F Change 4. Thus, the FSDO has to use
the latest version of the Order to issue or change OL's. The latest
version contradicts what your FSDO decided to do with your OL's
Finally, and most important of all is the statement "Aircraft that
received original airworthiness certification before July 9, 1993, are
NOT affected by this order unless the original airworthiness
certification purpose changes, for example, from R&D to exhibition."
ARE NOT AFFECTED BY THIS ORDER is in English and is quite plain and
simple to understand. The English language is not subject
interpretation.
I will be anxious to hear what the EAA/WBA has to say as well as your
FSDO when you present your case to them.
Dennis
----- Original Message -----
From: Pete Fowler
To: yak-list@matronics.com
Sent: Saturday, May 22, 2010 10:06 AM
Subject: Yak-List: FSDO changing operating limitations on
pre-moratorium aircra
While I can't get in touch with the people who can help over the
weekend, I thought I'd post this for reference.
I have a pre-moratorium Nanchang with operating limitations that
have few limitations (virtually none) that the aircraft has been
operating under since 1991.
Out of the blue my local FSDO called and said they had my "new
operating limitations". I went and reviewed them at the FSDO and
politely declined to accept or sign them and am contacting EAA warbirds
and another source at the FAA who I haven't heard back from yet but, in
a nutshell, the FSDO is trying to put all the limitations on my plane
that are "normal" for Nanchangs but is markedly different than the ones
I have. The only thing they left in there was that there is no range
restriction. I don't and they don't understand what pre-moratorium
really means in terms of what they can and can't do.
So I'm wondering if anyone knows the actual regulations that cover
re-writing operating limitations. The plane has had no configuration
change, nor did I request a change of operating limitations so am
wondering under what regulation the FSDO can not only re-write but add a
lot of contradictory and confusing limitations (suddenly it's VFR day
only but later it's VFR only if not equipped for night VFR, stuff like
that). I know there are a lot of opinions but I'd like to be able to
read the actual regulations regarding this but can't seem to find
anything on the FAA website due to an overwhelming number of hits on the
search.
--------
N4183E
http://nanchangcjs.yuku.com/
Read this topic online here:
http://forums.matronics.com/viewtopic.php?p=298512#298512
http://www.matronics==================
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href="http://forums.matronics.com">http://forums.matronics.com
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Message 3
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| Subject: | Experimental Class |
Please feel free (and requested) to ask your FSDO anything for me or
anyone else!
The plot thickens from an event that happened while at the Cherry Point
Air show, which I am presently attending with both aircraft. I was run
to ground, ALSO by no less than 5 FAA Reps, when I made the comment that
we could operate with the door off for a Camera operator wanting to take
HD pictures of the show as a "Media Ride" ... This morphed into a full
blown ramp check... Which is another story ... One that will bring tears
of laughter and also anger to to many... But I will save that for
another time.
In the course of the conversation, this particular FAA Safety Rep
EMPHATICALLY stated that since the engine that was in my experimental
aircraft was a certified engine, all AD's HAD to be complied with. No
option. Period. This was of course his opinion, but he said he had
FARS to support it. He was very VERY emphatic about this...
They all chastised me because there was nothing in the POH that stated I
could operate with the door off. I then pointed out there was nothing
in the POH about pulling Gliders either, but there was plenty of detail
about how to maintain the system in the MAINTENANCE MANUAL! There was
also nothing in the POH about raising the rear hatch and putting in
stretchers, but there was plenty in the MAINT. MANUAL about how to
maintain that system as well. And then today, I showed them a picture
of 3 military operative jumping out of an active duty Yugoslavian
UTVA-66 with.. The door off.
This FAA FSDO is clearly trying to apply FAR's that apply to U.S. built
aircraft to mine. They actually started quoting from the regs about
aircraft built before this year and after that year, and what the
companies had to comply with, etc. I just shook my head and said: "Do
you understand that Yugoslavia does not care what your laws were, then
or now? That is why this aircraft is EXPERIMENTAL?
Anyway, I kept it cool and just said: "SURE OK YES ANYTHING YOU WANT".
But you sure are right about the different FSDO's. The best advice in
the world is to never go to the FAA with a question. Know the answers
to all questions beforehand and have references to what makes you right
at hand!
Mark
-----Original Message-----
From: owner-yak-list-server@matronics.com
[mailto:owner-yak-list-server@matronics.com] On Behalf Of
cjpilot710@aol.com
Sent: Friday, May 21, 2010 11:28 PM
Subject: Re: Yak-List: Experimental Class
Mark,
One of the things I've noted (and you may have too) is that
interpretations of FARs differ from FSDO to FSDO. Case in point I once
sent a copy to another new CJ-6 owner of my operating letter that was
approved by the Orlando FSDO. His FSDO read mine, than told him that IF
I ever came into their jurisdiction, they would personally ground my
airplane!!!!
I called my FSDO and the handler of my CJ. He told me not to worry,
that that FSDO really had NO juridiction over me, as far as operating
letters.
We also run into this with flying the B24 from time to time. Again the
Orlando FSDO handles our operation. Just last week in BUR we were
ramped checked by no less than 5 feds. We spent more time BSing about
the airplanes, than them digging into every piece of paper we had.
Most of the time these guys don't really know what they are looking at.
Sometimes its better to apologies for something than try to get
straighten it out before it happens. They may not really want the work
load.
One way to cover yourself is that in your operating letter, you could
put that the engine will be maintained according to a manufactures
manuals -such and such. That way even if the engine is questioned, you
can "assure" the FAA guy, that you do have a plan, that has already been
approved.
I didn't know the POM was required to be in the airplane at all times.
The operating letter, yes but not the manual. I wonder if that's is a
FSDO inconsistency.
Careful on the translation manual trick, they may ask you if you can
speak the lingo ;-) Wooops.
"Confusion, thy name is FAA"
I'll try to call my FSDO guy with a question or two if you like. But
again it may be his own FSDO interpretation.
Pappy
-----Original Message-----
From: Bitterlich, Mark G CIV Det Cherry Point, MALS-14 64E
<mark.bitterlich@navy.mil>
Sent: Thu, May 20, 2010 9:09 pm
Subject: RE: Yak-List: Experimental Class
Pappy, thanks for taking the time to write back. I am very interested
in your perspective. I know this is off topic and I apologize to all,
but I know the people on this list that I trust and respect, so I come
here when I need an expert in an area that I know NOTHING about, and
this is one of them.
My UTVA-66 has a GSO-480 Lycoming. However, as you mentioned with your
Pitts, the aircraft itself is Experimental. Experimental Exhibition of
course. The FAA has not said a word to me either, but I have to wonder!
My experience with the FSDO folks is that in many cases it is easier to
just say "no" than it is to go out on a limb and give a blessing on
something they are not sure of. In fact, my experience has been that
you better know more than they do when you ask them to do ANYTHING.
But, I know that is unfair and many FSDO's have wonderful folks. Let me
just pause here and say that the FAA came up running to me today... At
the Cherry Point Airshow, when I took the door off the UTVA-66 for the
Combat Camera guys so they could get good video. Oh my GOSH! FIVE OF
THEM came up. Talk about being ganged up on! But in reality they were
really quite nice... Although they nailed me for my pilots license not
being signed (OMG!) and also.... And they got me dead cold to rights on
this one... I did not have the Pilots Operating Manual in the aircraft.
Darn it. I promised I would have it in there tomorrow and they said
they would come back and check it. Just for grins, I am going to br
ing them the UNTRANSLATED version written in Yugoslavian. Ought to be
fun.
In any case, a lot of the CJ-6 guys are here too. -1, -2, -3 and -4 !!!
I think they want to gang up on my 50! Anyway, hope to be able to have
the dogfight so many want to see the result of! :-)
Anyway... Pappy, I still really am confused about this.
Mark
-----Original Message-----
From: owner-yak-list-server@matronics.com
[mailto:owner-yak-list-server@matronics.com
<mailto:owner-yak-list-server@matronics.com?> ] On Behalf Of
cjpilot710@aol.com
Sent: Thursday, May 20, 2010 1:22 PM
Subject: Re: Yak-List: Experimental Class
Good questions Mark.
My speculations would be:
1. If the engine installed has no modifications what so ever done, than
its treated like a certified engine.
That would mean a annual inspection by an IA and
maintenance plus inspections per the manufacture.
2. Any engine that has never been certified OR a certified engine that
has had a modification done, would be considered "Experimental".
However a call to either the EAA or FSDO guys would more likely give you
a better answer than mine.
I know I put a Lyc 360 with no mods in my Pitts S1C, I built. The FAA
never said one word about the engine. The whole airplane was
"Experimental" as far as they were concern. As we all know
"interpretation" is not an FAA norm.
Jim "Pappy" Goolsby
-----Original Message-----
From: Bitterlich, Mark G CIV Det Cherry Point, MALS-14 64E
<mark.bitterlich@navy.mil>
Sent: Wed, May 19, 2010 7:54 pm
Subject: Yak-List: Experimental Class
--> Point,
MALS-14 64E" <mark.bitterlich@navy.mil>
A question for the legal Eagles out there. I have been told that if an
Experimental Aircraft has a "Certified" engine type, then that engine is
required to undergo all requirements that it normally would have were it
to be installed in a fully certified aircraft.
Ok... Then that brings up the question:
1. Is this true?
2. If it is, then what makes an engine itself "Experimental" ??
I really do not quite understand this aspect....
Mark Bitterlich
-----Original Message-----
From: owner-yak-list-server@matronics.com
[mailto:owner-yak-list-server@matronics.com
<mailto:owner-yak-list-server@matronics.com?>
<mailto:owner-yak-list-server@matronics.com
<mailto:owner-yak-list-server@matronics.com?> ?> ] On Behalf Of
KingCJ6@aol.com
Sent: Wednesday, May 19, 2010 1:33 AM
The beauty of our "experimental" class!
Dave
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Message 4
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| Subject: | Fwd: X-ponder squawk - |
A really interesting story!
There are two types of encoder interfaces these days, the new serial
method, which should not be impacted by this problem, and the old Grey
Code method using multiple wires that very easily could suffer from EMI
like this.
Most interfaces using grey code (my own aircraft included) do not use
shielded wire. This little story is a good reason to rethink that and
start using shielded wire! It is highly likely that this story was
caused by the individual wires from the encoder to the tranponder having
RF ride on them and get into the transponder where they were
interpretted as a level change. The RF also might have gotten into the
encoder and caused this to happen too, but less likely.
Shielded wiring... Including power... Is the very clear answer. Darn...
Now we understand why the airlines want those cell phones off! :-)
Mark
-----Original Message-----
From: owner-yak-list-server@matronics.com
[mailto:owner-yak-list-server@matronics.com] On Behalf Of
cjpilot710@aol.com
Sent: Saturday, May 22, 2010 10:45 AM
Subject: Yak-List: Fwd: X-ponder squawk -
Received from pilot friend--(general aviation)
Transponder: Garmin 320
Encoder: Ameri King 350
I thought I would post this for others flying small airplanes. I
spent a week this month chasing a frustrating problem in my PA-12. It
all started about two weeks ago as I was approaching Bowman field (LOU).
As I approached the pattern the tower asked me to "say altitude". I told
them 1500 feet. The tower replied that I was showing 1900 feet. A moment
later they showed 1200 feet. Basically on every radar sweep they showed
a different altitude. After flying around a bit it was clear that my
Transponder or encoder was all over the place. Ironically my biannual
transponder check was due and I had my radio man coming to the hanger
the next day. I called him to inform him that I now also had a squawk
with the system. After explaining the problem he suggested I re-rack the
encoder as well as the transponder. He figured there was a good chance
something was loose. So I climbed under the dash and re-racked both
instruments. For good measure I blew compressed air over all the
connections. I then took the airplane around the pattern and asked the
tower to tell me what they saw. There was no change, my altitude was all
over the place.
I called my radio man back and told him the results. He
suggested that I should replace the encoder. So I grabbed the Aircraft
Spruce book and spent some money. I waited 3 days for the new encoder
and when it arrived I swapped out the old unit for the new. My flight
around the pattern revealed that the problem still existed. Basically
the altitude being transmitted from my airplane was hopping up and down
as much as 700 feet.
I called my radio man again and told him the news. It was clear
the encoder was not the issue. He suggested swapping out the transponder
with a similar unit. I was able to locate an airplane with a Garmin 320
like mine. To get the replacement transponder I flew to a grass strip
just west of Lexington, KY. The gentleman who owned the replacement
transponder was very generous. I landed by his hanger and within ten
minutes was back in the air with the replacement transponder. I climbed
up to 3000 feet, called Louisville Approach and asked them what they
saw. Unfortunately they saw me all over the sky. I descended back to the
grass runway, swapped out the transponders and headed back to Bowman. It
was clearly not a transponder problem.
I called my radio man and he decided the next thing to check
would be the wire harness running from the encoder to the transponder. I
contorted myself back under the dash and removed the harness. We tested
each of the 9 wires and could not find a problem, but just to be safe we
replaced the harness with a new one. At that point I had to leave for
work and my radio man stayed behind. His plan was to hook the encoder up
to the transponder and power everything up on the work bench to see if
it worked. With his test equipment he pumped up the system to watch it
climb. The encoder seemed to be working just fine, and then while it was
climbing his cell phone rang. When it rang the encoder altitude jumped a
few hundred feet. After he took the call he continued to watch the
encoder. Each time he spoke the encoder jumped.
You probably know where this is going. I have an I-phone and yes
I always have it with me in the airplane. I usually do not use it but I
stow it in a map pocket and it stays on.
We put the airplane back together. I flew around in the pattern
for fifteen minutes (Iphone off) while the tower watched my altitude. It
was rock solid right on the money. I landed and then turned on my
Iphone. I took off again and immediately the tower saw my altitude
jumping all over the place. While talking with the tower I turned the
phone off and immediately things returned to normal.
My radio man has never encountered this anomaly but is convinced
the phone is the culprit. I am as well. By the way the encoder is made
by Ameri King. I have an old Ack unit that we put in after discovering
this problem and the Iphone does not effect the Ack unit.
Hopefully this information will prevent someone else from
chasing their tale.
Message 5
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| Subject: | FSDO changing operating limitations on pre-moratorium aircra |
I know this for a fact, and it is LAW.
NO FSDO CAN ADD TO THE CURRENT OPERATING LIMITATIONS WHEN TRANSFERRING
AN AIRCRAFT FROM ONE FSDO TO ANOTHER. Mine tried to do that, and I
nailed them to the cross on it and told them it was illegal. They took
out their "new" limitations they had "added".
However, I do not know whether a CURRENT FSDO can just walk up and add
crap to your operating limitations, but I don't THINK they can.
My FSDO told me TODAY that you can also get current limitations REMOVED
(line by line) if you can justify the reasons, but it is their decision
on whether to accept your request, and they ALSO said that all of our
aircraft are initially assigned a GENERIC set of operating limitations
"just because". This is what appears that they are trying to do to you.
And there is indeed a whole slew of them.
I think you are taking exactly the right actions. If you have a current
set of operating limitations that are valid, and also a current
airworthiness certificate, unless they are revoked, you don't HAVE to do
anything.
Please keep us up to date on this one~!
Mark
-----Original Message-----
From: owner-yak-list-server@matronics.com
[mailto:owner-yak-list-server@matronics.com] On Behalf Of Pete Fowler
Sent: Saturday, May 22, 2010 11:07 AM
Subject: Yak-List: FSDO changing operating limitations on pre-moratorium
aircra
While I can't get in touch with the people who can help over the
weekend, I thought I'd post this for reference.
I have a pre-moratorium Nanchang with operating limitations that have
few limitations (virtually none) that the aircraft has been operating
under since 1991.
Out of the blue my local FSDO called and said they had my "new operating
limitations". I went and reviewed them at the FSDO and politely declined
to accept or sign them and am contacting EAA warbirds and another source
at the FAA who I haven't heard back from yet but, in a nutshell, the
FSDO is trying to put all the limitations on my plane that are "normal"
for Nanchangs but is markedly different than the ones I have. The only
thing they left in there was that there is no range restriction. I don't
and they don't understand what pre-moratorium really means in terms of
what they can and can't do.
So I'm wondering if anyone knows the actual regulations that cover
re-writing operating limitations. The plane has had no configuration
change, nor did I request a change of operating limitations so am
wondering under what regulation the FSDO can not only re-write but add a
lot of contradictory and confusing limitations (suddenly it's VFR day
only but later it's VFR only if not equipped for night VFR, stuff like
that). I know there are a lot of opinions but I'd like to be able to
read the actual regulations regarding this but can't seem to find
anything on the FAA website due to an overwhelming number of hits on the
search.
--------
N4183E
http://nanchangcjs.yuku.com/
Read this topic online here:
http://forums.matronics.com/viewtopic.php?p=298512#298512
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| Subject: | FSDO changing operating limitations on pre-moratorium aircra |
A much better answer than mine! Thanks Dennis!
Mark
-----Original Message-----
From: owner-yak-list-server@matronics.com [mailto:owner-yak-list-server@matronics.com] On Behalf Of A. Dennis Savarese
Sent: Sunday, May 23, 2010 8:29 AM
Subject: Re: Yak-List: FSDO changing operating limitations on pre-moratorium aircra
Peter,
My comment is the FSDO does not need to understand what Pre Moratorium means.
All they have to do is read the words in the Order. If the aircraft received
its Special Airworthiness Certificate prior to July 9, 1993, it is not affected
by the Order. It doesn't matter what it means. The words are quite clear.
FAA Order 8130.2F Change 4. Paragraph d and e are the important paragraphs with
paragraph e begin the most important. (Page 166) It reads:
d. Experimental Airworthiness Certification Moratorium. On July 9, 1993, a moratorium
was established because of a dramatic increase in applications for special
airworthiness certificates and SFAs for non-U.S.-manufactured aircraft that
did not hold TCs issued under 21.29. The moratorium was lifted on August 18,
1993, with interim guidance provided to certificate these aircraft. Although
the moratorium was established for non-U.S.-manufactured aircraft, this policy
will be used when issuing a special airworthiness certificate for the experimental
purpose(s) of exhibition or air racing, regardless of the country of manufacture.
e. Effectivity. Aircraft that received original airworthiness certification before
July 9, 1993, are NOT affected by this order unless the original airworthiness
certification purpose changes, for example, from R&D to exhibition. Those
aircraft, except for purpose changes, will not be affected until the FAA works
with the public to determine the best strategy to certificate all experimental
exhibition and/or air racing aircraft in accordance with the new policy. The
policy established in this order will not be used in these cases unless specifically
requested by the applicant.
I think the operative words that require explanation and justification by your
FSDO are: "Those aircraft, except for purpose changes, will not be affected until
the FAA works with the public to determine the best strategy to certificate
all experimental exhibition and/or air racing aircraft in accordance with the
new policy."
If a new policy has been established which we or EAA or WBA are not aware of, ask
your FSDO to give you a copy of this new policy. It also says in the last
sentence, "The policy established in this order will not be used in these cases
unless specifically requested by the applicant."
Since you have not requested a purpose change, like from Exhibition to Air Racing,
the FSDO should be able to give you a bonafide reason to reissue your OL's.
Any aircraft issued a new Experiment Exhibition Special Airworthiness Certificate
today will be issued Operating Limitations in accordance with the present FAA
Order, 8130.2F Change 4. Thus, the FSDO has to use the latest version of the
Order to issue or change OL's. The latest version contradicts what your FSDO
decided to do with your OL's
Finally, and most important of all is the statement "Aircraft that received original
airworthiness certification before July 9, 1993, are NOT affected by this
order unless the original airworthiness certification purpose changes, for example,
from R&D to exhibition." ARE NOT AFFECTED BY THIS ORDER is in English
and is quite plain and simple to understand. The English language is not subject
interpretation.
I will be anxious to hear what the EAA/WBA has to say as well as your FSDO when
you present your case to them.
Dennis
----- Original Message -----
From: Pete Fowler <mailto:pfdesign1@cox.net>
To: yak-list@matronics.com
Sent: Saturday, May 22, 2010 10:06 AM
Subject: Yak-List: FSDO changing operating limitations on pre-moratorium aircra
While I can't get in touch with the people who can help over the weekend, I thought
I'd post this for reference.
I have a pre-moratorium Nanchang with operating limitations that have few limitations
(virtually none) that the aircraft has been operating under since 1991.
Out of the blue my local FSDO called and said they had my "new operating limitations".
I went and reviewed them at the FSDO and politely declined to accept
or sign them and am contacting EAA warbirds and another source at the FAA who
I haven't heard back from yet but, in a nutshell, the FSDO is trying to put all
the limitations on my plane that are "normal" for Nanchangs but is markedly
different than the ones I have. The only thing they left in there was that there
is no range restriction. I don't and they don't understand what pre-moratorium
really means in terms of what they can and can't do.
So I'm wondering if anyone knows the actual regulations that cover re-writing
operating limitations. The plane has had no configuration change, nor did I request
a change of operating limitations so am wondering under what regulation
the FSDO can not only re-write but add a lot of contradictory and confusing limitations
(suddenly it's VFR day only but later it's VFR only if not equipped
for night VFR, stuff like that). I know there are a lot of opinions but I'd like
to be able to read the actual regulations regarding this but can't seem to
find anything on the FAA website due to an overwhelming number of hits on the
search.
--------
N4183E
http://nanchangcjs.yuku.com/
Read this topic online here:
http://forums.matronics.com/viewtopic.php?p=298512#298512
http://www.matronics========================<; via the Web href="http://forums.matronics.com">http://forums.matronics.com
_p; generous bsp; href="http://www.matronics.com/contribution">http://www.matronics.com/c================
Message 7
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| Subject: | Re: FSDO changing operating limitations on pre-moratorium aircra |
Thanks very much Dennis, at the end of the day it's easiest to point to the actual
regulation and simply cite it! Apparently word had already gotten around the
local FAA guys that I was "causing trouble" by not accepting the changes [Rolling
Eyes]
On the plus side, I did my first formation flying yesterday with Craig Ekberg so
it reminded my why this hassle is worth it!
--------
N4183E
http://nanchangcjs.yuku.com/
Read this topic online here:
http://forums.matronics.com/viewtopic.php?p=298590#298590
Message 8
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| Subject: | Re: FSDO changing operating limitations on pre-moratorium |
aircra
Regarding the FAA, it's a matter of what is right. Even though they
have the power, that doesn't make them right no matter what.
Fly Safe.
Dennis
----- Original Message -----
From: Pete Fowler
To: yak-list@matronics.com
Sent: Sunday, May 23, 2010 10:16 AM
Subject: Yak-List: Re: FSDO changing operating limitations on
pre-moratorium aircra
Thanks very much Dennis, at the end of the day it's easiest to point
to the actual regulation and simply cite it! Apparently word had already
gotten around the local FAA guys that I was "causing trouble" by not
accepting the changes [Rolling Eyes]
On the plus side, I did my first formation flying yesterday with Craig
Ekberg so it reminded my why this hassle is worth it!
--------
N4183E
http://nanchangcjs.yuku.com/
Read this topic online here:
http://forums.matronics.com/viewtopic.php?p=298590#298590
Message 9
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| Subject: | Re: FSDO changing operating limitations on pre-moratorium |
aircra
Does the FAA intend to eliminate the experimental catagory altogether and replace
it with type certificates for _all_ aircraft? Isn't that the implication of
this:
"Those aircraft, except for purpose changes, will not be affected until the FAA
works with the public to determine the best strategy to certificate all experimental
exhibition and/or air racing aircraft in accordance with the new policy."
+-----Original Message-----
+From: owner-yak-list-server@matronics.com [mailto:owner-yak-list-server@matronics.com] On Behalf Of A. Dennis Savarese
+Sent: Sunday, May 23, 2010 8:29 AM
+To: yak-list@matronics.com
+Subject: Re: Yak-List: FSDO changing operating limitations on pre-moratorium aircra
+
+Peter,
+
+My comment is the FSDO does not need to understand what Pre Moratorium means.
All they have to do is read the words in the Order. If the aircraft received
its Special Airworthiness Certificate prior to July 9, 1993, it is not affected
by the Order. It doesn't matter what it means. The words are quite clear.
+
+FAA Order 8130.2F Change 4. Paragraph d and e are the important paragraphs with
paragraph e begin the most important. (Page 166) It reads:
+
+d. Experimental Airworthiness Certification Moratorium. On July 9, 1993, a moratorium
was established because of a dramatic increase in applications for special
airworthiness certificates and SFAs for non-U.S.-manufactured aircraft that
did not hold TCs issued under 21.29. The moratorium was lifted on August 18,
1993, with interim guidance provided to certificate these aircraft. Although
the moratorium was established for non-U.S.-manufactured aircraft, this policy
will be used when issuing a special airworthiness certificate for the experimental
purpose(s) of exhibition or air racing, regardless of the country of manufacture.
+e. Effectivity. Aircraft that received original airworthiness certification before
July 9, 1993, are NOT affected by this order unless the original airworthiness
certification purpose changes, for example, from R&D to exhibition. Those
aircraft, except for purpose changes, will not be affected until the FAA works
with the public to determine the best strategy to certificate all experimental
exhibition and/or air racing aircraft in accordance with the new policy. The
policy established in this order will not be used in these cases unless specifically
requested by the applicant.
+
+I think the operative words that require explanation and justification by your
FSDO are: "Those aircraft, except for purpose changes, will not be affected until
the FAA works with the public to determine the best strategy to certificate
all experimental exhibition and/or air racing aircraft in accordance with the
new policy."
+
Message 10
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| Subject: | Re: FSDO changing operating limitations on pre-moratorium |
aircra
Eliminating the Experimental category is highly unlikely. However,
changing the purpose such as Exhibition or Amateur Built or Air Racing
into some other grouping I guess could happen. God only knows how or
what the FAA is thinking.
Dennis
----- Original Message -----
From: William Halverson
To: yak-list@matronics.com
Sent: Sunday, May 23, 2010 12:30 PM
Subject: Re: Yak-List: FSDO changing operating limitations on
pre-moratorium aircra
<william@netpros.net>
Does the FAA intend to eliminate the experimental catagory altogether
and replace it with type certificates for _all_ aircraft? Isn't that
the implication of this:
"Those aircraft, except for purpose changes, will not be affected
until the FAA works with the public to determine the best strategy to
certificate all experimental exhibition and/or air racing aircraft in
accordance with the new policy."
+-----Original Message-----
+From: owner-yak-list-server@matronics.com
[mailto:owner-yak-list-server@matronics.com] On Behalf Of A. Dennis
Savarese
+Sent: Sunday, May 23, 2010 8:29 AM
+To: yak-list@matronics.com
+Subject: Re: Yak-List: FSDO changing operating limitations on
pre-moratorium aircra
+
+Peter,
+
+My comment is the FSDO does not need to understand what Pre
Moratorium means. All they have to do is read the words in the Order.
If the aircraft received its Special Airworthiness Certificate prior to
July 9, 1993, it is not affected by the Order. It doesn't matter what
it means. The words are quite clear.
+
+FAA Order 8130.2F Change 4. Paragraph d and e are the important
paragraphs with paragraph e begin the most important. (Page 166) It
reads:
+
+d. Experimental Airworthiness Certification Moratorium. On July 9,
1993, a moratorium was established because of a dramatic increase in
applications for special airworthiness certificates and SFAs for
non-U.S.-manufactured aircraft that did not hold TCs issued under =A7
21.29. The moratorium was lifted on August 18, 1993, with interim
guidance provided to certificate these aircraft. Although the moratorium
was established for non-U.S.-manufactured aircraft, this policy will be
used when issuing a special airworthiness certificate for the
experimental purpose(s) of exhibition or air racing, regardless of the
country of manufacture.
+e. Effectivity. Aircraft that received original airworthiness
certification before July 9, 1993, are NOT affected by this order unless
the original airworthiness certification purpose changes, for example,
from R&D to exhibition. Those aircraft, except for purpose changes, will
not be affected until the FAA works with the public to determine the
best strategy to certificate all experimental exhibition and/or air
racing aircraft in accordance with the new policy. The policy
established in this order will not be used in these cases unless
specifically requested by the applicant.
+
+I think the operative words that require explanation and
justification by your FSDO are: "Those aircraft, except for purpose
changes, will not be affected until the FAA works with the public to
determine the best strategy to certificate all experimental exhibition
and/or air racing aircraft in accordance with the new policy."
+
Message 11
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| Subject: | FSDO changing operating limitations on pre-moratorium |
aircra
And he is thinking how in the Hell did I create those fools!
Tom Elliott
CJ-6A NX63727
702-595-2680
_____
From: owner-yak-list-server@matronics.com
[mailto:owner-yak-list-server@matronics.com] On Behalf Of A. Dennis
Savarese
Sent: Sunday, May 23, 2010 11:34 AM
Subject: Re: Yak-List: FSDO changing operating limitations on
pre-moratorium
aircra
Eliminating the Experimental category is highly unlikely. However,
changing
the purpose such as Exhibition or Amateur Built or Air Racing into some
other grouping I guess could happen. God only knows how or what the
FAA is
thinking.
Dennis
----- Original Message -----
From: William <mailto:william@netpros.net> Halverson
Sent: Sunday, May 23, 2010 12:30 PM
Subject: Re: Yak-List: FSDO changing operating limitations on
pre-moratorium
aircra
<william@netpros.net>
Does the FAA intend to eliminate the experimental catagory altogether
and
replace it with type certificates for _all_ aircraft? Isn't that the
implication of this:
"Those aircraft, except for purpose changes, will not be affected until
the
FAA works with the public to determine the best strategy to certificate
all
experimental exhibition and/or air racing aircraft in accordance with
the
new policy."
+-----Original Message-----
+From: owner-yak-list-server@matronics.com
[mailto:owner-yak-list-server@matronics.com] On Behalf Of A. Dennis
Savarese
+Sent: Sunday, May 23, 2010 8:29 AM
+To: yak-list@matronics.com
+Subject: Re: Yak-List: FSDO changing operating limitations on
pre-moratorium aircra
+
+Peter,
+
+My comment is the FSDO does not need to understand what Pre Moratorium
means. All they have to do is read the words in the Order. If the
aircraft
received its Special Airworthiness Certificate prior to July 9, 1993, it
is
not affected by the Order. It doesn't matter what it means. The words
are
quite clear.
+
+FAA Order 8130.2F Change 4. Paragraph d and e are the important
paragraphs
with paragraph e begin the most important. (Page 166) It reads:
+
+d. Experimental Airworthiness Certification Moratorium. On July 9,
1993, a
moratorium was established because of a dramatic increase in
applications
for special airworthiness certificates and SFAs for
non-U.S.-manufactured
aircraft that did not hold TCs issued under =A7 21.29. The moratorium
was
lifted on August 18, 1993, with interim guidance provided to certificate
these aircraft. Although the moratorium was established for
non-U.S.-manufactured aircraft, this policy will be used when issuing a
special airworthiness certificate for the experimental purpose(s) of
exhibition or air racing, regardless of the country of manufacture.
+e. Effectivity. Aircraft that received original airworthiness
certification
before July 9, 1993, are NOT affected by this order unless the original
airworthiness certification purpose changes, for example, from R&D to
exhibition. Those aircraft, except for purpose changes, will not be
affected
until the FAA works with the public to determine the best strategy to
certificate all experimental exhibition and/or air racing aircraft in
accordance with the new policy. The policy established in this order
will
not be used in these cases unless specifically requested by the
applicant.
+
+I think the operative words that require explanation and justification
by
your FSDO are: "Those aircraft, except for purpose changes, will not be
affected until the FAA works with the public to determine the best
strategy
to certificate all experimental exhibition and/or air racing aircraft in
accordance with the new policy."
+ nbsp; Navigator Photoshare, and
href="http://www.matronics.com/Navigator?Yak-List">http://www.matronics
====
===================<; via the
Web
href="http://forums.matronics.com">http://forums.matronics.com
_p; generous bsp;
href="http://www.matronics.com/contribution">http://www.matronics.com/c
====
===========
Message 12
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| Subject: | Re: FSDO changing operating limitations on pre-moratorium |
aircra
Well said Tom! :-)
Dennis
----- Original Message -----
From: Tom Elliott
To: yak-list@matronics.com
Sent: Sunday, May 23, 2010 1:36 PM
Subject: RE: Yak-List: FSDO changing operating limitations on
pre-moratorium aircra
And he is thinking how in the Hell did I create those fools!
Tom Elliott
CJ-6A NX63727
702-595-2680
-------------------------------------------------------------------------
---
From: owner-yak-list-server@matronics.com
[mailto:owner-yak-list-server@matronics.com] On Behalf Of A. Dennis
Savarese
Sent: Sunday, May 23, 2010 11:34 AM
To: yak-list@matronics.com
Subject: Re: Yak-List: FSDO changing operating limitations on
pre-moratorium aircra
Eliminating the Experimental category is highly unlikely. However,
changing the purpose such as Exhibition or Amateur Built or Air Racing
into some other grouping I guess could happen. God only knows how or
what the FAA is thinking.
Dennis
----- Original Message -----
From: William Halverson
To: yak-list@matronics.com
Sent: Sunday, May 23, 2010 12:30 PM
Subject: Re: Yak-List: FSDO changing operating limitations on
pre-moratorium aircra
<william@netpros.net>
Does the FAA intend to eliminate the experimental catagory
altogether and replace it with type certificates for _all_ aircraft?
Isn't that the implication of this:
"Those aircraft, except for purpose changes, will not be affected
until the FAA works with the public to determine the best strategy to
certificate all experimental exhibition and/or air racing aircraft in
accordance with the new policy."
+-----Original Message-----
+From: owner-yak-list-server@matronics.com
[mailto:owner-yak-list-server@matronics.com] On Behalf Of A. Dennis
Savarese
+Sent: Sunday, May 23, 2010 8:29 AM
+To: yak-list@matronics.com
+Subject: Re: Yak-List: FSDO changing operating limitations on
pre-moratorium aircra
+
+Peter,
+
+My comment is the FSDO does not need to understand what Pre
Moratorium means. All they have to do is read the words in the Order.
If the aircraft received its Special Airworthiness Certificate prior to
July 9, 1993, it is not affected by the Order. It doesn't matter what
it means. The words are quite clear.
+
+FAA Order 8130.2F Change 4. Paragraph d and e are the important
paragraphs with paragraph e begin the most important. (Page 166) It
reads:
+
+d. Experimental Airworthiness Certification Moratorium. On July
9, 1993, a moratorium was established because of a dramatic increase in
applications for special airworthiness certificates and SFAs for
non-U.S.-manufactured aircraft that did not hold TCs issued under =A7
21.29. The moratorium was lifted on August 18, 1993, with interim
guidance provided to certificate these aircraft. Although the moratorium
was established for non-U.S.-manufactured aircraft, this policy will be
used when issuing a special airworthiness certificate for the
experimental purpose(s) of exhibition or air racing, regardless of the
country of manufacture.
+e. Effectivity. Aircraft that received original airworthiness
certification before July 9, 1993, are NOT affected by this order unless
the original airworthiness certification purpose changes, for example,
from R&D to exhibition. Those aircraft, except for purpose changes, will
not be affected until the FAA works with the public to determine the
best strategy to certificate all experimental exhibition and/or air
racing aircraft in accordance with the new policy. The policy
established in this order will not be used in these cases unless
specifically requested by the applicant.
+
+I think the operative words that require explanation and
justification by your FSDO are: "Those aircraft, except for purpose
changes, will not be affected until the FAA works with the public to
determine the best strategy to certificate all experimental exhibition
and/or air racing aircraft in accordance with the new policy."
+ nbsp; Navigator Photoshare, and
href="http://www.matronics.com/Navigator?Yak-List">http://www.matronics
========================<
; via the Web
href="http://forums.matronics.com">http://forums.matronics.com
_p; generous bsp;
href="http://www.matronics.com/contribution">http://www.matronics.com/c
================
href="http://www.matronics.com/Navigator?Yak-List">http://www.matronics
.com/Navigator?Yak-List
href="http://forums.matronics.com">http://forums.matronics.com
href="http://www.matronics.com/contribution">http://www.matronics.com/c
Message 13
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| Subject: | Re: FSDO changing operating limitations on pre-moratorium |
aircra
I have to say... Knock on wood... our FSDO (Rochester-23) is nothing
but helpful with EE stuff... always seems to try to find ways to make
it work. I guess we're lucky.
On May 23, 2010, at 2:46 PM, A. Dennis Savarese wrote:
> Well said Tom! :-)
> Dennis
> ----- Original Message -----
> From: Tom Elliott
> To: yak-list@matronics.com
> Sent: Sunday, May 23, 2010 1:36 PM
> Subject: RE: Yak-List: FSDO changing operating limitations on pre-
> moratorium aircra
>
> And he is thinking how in the Hell did I create those fools!
>
> Tom Elliott
> CJ-6A NX63727
> 702-595-2680
>
>
> From: owner-yak-list-server@matronics.com
[mailto:owner-yak-list-server@matronics.com
> ] On Behalf Of A. Dennis Savarese
> Sent: Sunday, May 23, 2010 11:34 AM
> To: yak-list@matronics.com
> Subject: Re: Yak-List: FSDO changing operating limitations on pre-
> moratorium aircra
>
> Eliminating the Experimental category is highly unlikely. However,
> changing the purpose such as Exhibition or Amateur Built or Air
> Racing into some other grouping I guess could happen. God only
> knows how or what the FAA is thinking.
> Dennis
> ----- Original Message -----
> From: William Halverson
> To: yak-list@matronics.com
> Sent: Sunday, May 23, 2010 12:30 PM
> Subject: Re: Yak-List: FSDO changing operating limitations on pre-
> moratorium aircra
>
<william@netpros.net
> >
>
>
> Does the FAA intend to eliminate the experimental catagory
> altogether and replace it with type certificates for _all_
> aircraft? Isn't that the implication of this:
>
> "Those aircraft, except for purpose changes, will not be affected
> until the FAA works with the public to determine the best strategy
> to certificate all experimental exhibition and/or air racing
> aircraft in accordance with the new policy."
>
>
> +-----Original Message-----
> +From: owner-yak-list-server@matronics.com
[mailto:owner-yak-list-server@matronics.com
> ] On Behalf Of A. Dennis Savarese
> +Sent: Sunday, May 23, 2010 8:29 AM
> +To: yak-list@matronics.com
> +Subject: Re: Yak-List: FSDO changing operating limitations on pre-
> moratorium aircra
> +
> +Peter,
> +
> +My comment is the FSDO does not need to understand what Pre
> Moratorium means. All they have to do is read the words in the
> Order. If the aircraft received its Special Airworthiness
> Certificate prior to July 9, 1993, it is not affected by the Order.
> It doesn't matter what it means. The words are quite clear.
> +
> +FAA Order 8130.2F Change 4. Paragraph d and e are the important
> paragraphs with paragraph e begin the most important. (Page 166)
> It reads:
> +
> +d. Experimental Airworthiness Certification Moratorium. On July 9,
> 1993, a moratorium was established because of a dramatic increase in
> applications for special airworthiness certificates and SFAs for non-
> U.S.-manufactured aircraft that did not hold TCs issued under =A7
> 21.29. The moratorium was lifted on August 18, 1993, with interim
> guidance provided to certificate these aircraft. Although the
> moratorium was established for non-U.S.-manufactured aircraft, this
> policy will be used when issuing a special airworthiness certificate
> for the experimental purpose(s) of exhibition or air racing,
> regardless of the country of manufacture.
> +e. Effectivity. Aircraft that received original airworthiness
> certification before July 9, 1993, are NOT affected by this order
> unless the original airworthiness certification purpose changes, for
> example, from R&D to exhibition. Those aircraft, except for purpose
> changes, will not be affected until the FAA works with the public to
> determine the best strategy to certificate all experimental
> exhibition and/or air racing aircraft in accordance with the new
> policy. The policy established in this order will not be used in
> these cases unless specifically requested by the applicant.
> +
> +I think the operative words that require explanation and
> justification by your FSDO are: "Those aircraft, except for purpose
> changes, will not be affected until the FAA works with the public to
> determine the best strategy to certificate all experimental
> exhibition and/or air racing aircraft in accordance with the new
> policy."
> + nbsp; Navigator Photoshare, and
href="http://www.matronics.com/Navigator?Yak-List
> ">http://www.matronics=================
=======<; via the Web
> href="http://forums.matronics.com">http://forums.matronics.com
> _p; generous bsp;
href="http://www.matronics.com/contribution
> ">http://www.matronics.com/c===============
=
>
>
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href="http://www.matronics.com/Navigator?Yak-List">http://www.matronhref
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href="http://www.matronics.com/Navigator?Yak-List">http://www.matronics.
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Message 14
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Has anyone a FOM in English for my 18T which I can buy /download please ?
I have the unofficial version from UK but am not sure whether my FSDO will accept
it.
--------
'Le temps mange la vie'
Read this topic online here:
http://forums.matronics.com/viewtopic.php?p=298672#298672
Message 15
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| Subject: | Re: Experimental Class |
Mark when we did an IAR 823 the FAA examiner stated that if the engine had
a data plate it was a certified engine if it didn't it was experimental, I
-left -the plate intact and did (do) the AD's Lycoming IO-540. =0A-Bi
ll Wade=0A=0A=0A=0A________________________________=0AFrom: "Bitterlich, Ma
rk G CIV Det Cherry Point, MALS-14 64E" <mark.bitterlich@navy.mil>=0ATo: ya
k-list@matronics.com=0ASent: Sun, May 23, 2010 10:15:58 AM=0ASubject: RE: Y
h, Mark G CIV Det Cherry Point, MALS-14 64E" <mark.bitterlich@navy.mil>=0A
=0APlease feel free (and requested) to ask your FSDO anything for me or=0Aa
nyone else!- =0A=0AThe plot thickens from an event that happened while at
the Cherry Point=0AAir show, which I am presently attending with both airc
raft.- I was run=0Ato ground, ALSO by no less than 5 FAA Reps, when I mad
e the comment that=0Awe could operate with the door off for a Camera operat
or wanting to take=0AHD pictures of the show as a "Media Ride" ... This mor
phed into a full=0Ablown ramp check... Which is another story ... One that
will bring tears=0Aof laughter and also anger to to many... But I will save
that for=0Aanother time.- =0A=0AIn the course of the conversation, this
particular FAA Safety Rep=0AEMPHATICALLY stated that since the engine that
was in my experimental=0Aaircraft was a certified engine, all AD's HAD to b
e complied with.- No=0Aoption.- Period.- This was of course his opini
on, but he said he had=0AFARS to support it.- He was very VERY emphatic a
bout this... =0A=0AThey all chastised me because there was nothing in the P
OH that stated I=0Acould operate with the door off.- I then pointed out t
here was nothing=0Ain the POH about pulling Gliders either, but there was p
lenty of detail=0Aabout how to maintain the system in the MAINTENANCE MANUA
L!- There was=0Aalso nothing in the POH about raising the rear hatch and
putting in=0Astretchers, but there was plenty in the MAINT. MANUAL about ho
w to=0Amaintain that system as well.- And then today, I showed them a pic
ture=0Aof 3 military operative jumping out of an active duty Yugoslavian=0A
UTVA-66 with.. The door off.- =0A=0AThis FAA FSDO is clearly trying to ap
ply FAR's that apply to U.S. built=0Aaircraft to mine.- They actually sta
rted quoting from the regs about=0Aaircraft built before this year and afte
r that year, and what the=0Acompanies had to comply with, etc.- I just sh
ook my head and said: "Do=0Ayou understand that Yugoslavia does not care wh
at your laws were, then=0Aor now?- That is why this aircraft is EXPERIMEN
TAL?- =0A=0AAnyway, I kept it cool and just said: "SURE OK YES ANYTHING Y
OU WANT".- =0A=0ABut you sure are right about the different FSDO's.- Th
e best advice in=0Athe world is to never go to the FAA with a question.-
Know the answers=0Ato all questions beforehand and have references to what
makes you right=0Aat hand!- =0A=0AMark=0A=0A=0A-----Original Message-----
=0AFrom: owner-yak-list-server@matronics.com=0A[mailto:owner-yak-list-serve
r@matronics.com] On Behalf Of=0Acjpilot710@aol.com=0ASent: Friday, May 21,
2010 11:28 PM=0ATo: yak-list@matronics.com=0ASubject: Re: Yak-List: Experim
ental Class=0A=0AMark,=0A=0AOne of the things I've noted (and you may have
too) is that=0Ainterpretations of FARs differ from FSDO to FSDO.- Case in
point I once=0Asent a copy to another new CJ-6 owner of my operating lette
r that was=0Aapproved by the Orlando FSDO.- His FSDO read mine, than told
him that IF=0AI ever came into their jurisdiction, they would personally g
round my=0Aairplane!!!!=0A=0AI called my FSDO and the handler of my CJ.-
He told me not to worry,=0Athat that FSDO really had NO juridiction over me
, as far as operating=0Aletters.=0AWe also run into this with flying the B2
4 from time to time.- Again the=0AOrlando FSDO handles our operation.-
Just last week in BUR we were=0Aramped checked by no less than 5 feds.- W
e spent more time BSing about=0Athe airplanes, than them digging into every
piece of paper we had.=0A=0AMost of the time these guys don't really know
what they are looking at.=0ASometimes its better to apologies for something
than try to get=0Astraighten it out before it happens.- They may not rea
lly want the work=0Aload.=0A=0AOne way to cover yourself is that in your op
erating letter, you could=0Aput that the engine will be maintained accordin
g to a manufactures=0Amanuals -such and such.- That way even if the engin
e is questioned, you=0Acan "assure" the FAA guy, that you do have a plan, t
hat has already been=0Aapproved.- =0A=0AI didn't know the POM was require
d to be in the airplane at all times.=0AThe operating letter, yes but not t
he manual.- I wonder if that's is a=0AFSDO inconsistency.=0A=0ACareful on
the translation manual trick, they may ask you if you can=0Aspeak the ling
o ;-)- Wooops.=0A=0A"Confusion, thy name is FAA"=0A=0AI'll try to call my
FSDO guy with a question or two if you like.- But=0Aagain it may be his
own FSDO interpretation.=0A=0APappy=0A=0A=0A=0A-----Original Message-----
=0AFrom: Bitterlich, Mark G CIV Det Cherry Point, MALS-14 64E=0A<mark.bitte
rlich@navy.mil>=0ATo: yak-list@matronics.com=0ASent: Thu, May 20, 2010 9:09
pm=0ASubject: RE: Yak-List: Experimental Class=0A=0A=0APappy, thanks for t
aking the time to write back.- I am very interested=0Ain your perspective
.- I know this is off topic and I apologize to all,=0Abut I know the peop
le on this list that I trust and respect, so I come=0Ahere when I need an e
xpert in an area that I know NOTHING about, and=0Athis is one of them.-
=0A=0AMy UTVA-66 has a GSO-480 Lycoming.- However, as you mentioned with
your=0APitts, the aircraft itself is Experimental.- Experimental Exhibiti
on of=0Acourse.- The FAA has not said a word to me either, but I have to
wonder!=0A=0A=0AMy experience with the FSDO folks is that in many cases it
is easier to=0Ajust say "no" than it is to go out on a limb and give a bles
sing on=0Asomething they are not sure of.- In fact, my experience has bee
n that=0Ayou better know more than they do when you ask them to do ANYTHING
.=0ABut, I know that is unfair and many FSDO's have wonderful folks.- Let
me=0Ajust pause here and say that the FAA came up running to me today... A
t=0Athe Cherry Point Airshow, when I took the door off the UTVA-66 for the
=0ACombat Camera guys so they could get good video.- Oh my GOSH!- FIVE
OF=0ATHEM came up.- Talk about being ganged up on!- But in reality they
were=0Areally quite nice... Although they nailed me for my pilots license
not=0Abeing signed (OMG!) and also.... And they got me dead cold to rights
on=0Athis one... I did not have the Pilots Operating Manual in the aircraft
.=0ADarn it.- I promised I would have it in there tomorrow and they said
=0Athey would come back and check it.- Just for grins, I am going to br
=0Aing them the UNTRANSLATED version written in Yugoslavian.- Ought to be
=0Afun.- =0A=0AIn any case, a lot of the CJ-6 guys are here too.- -1, -
2, -3 and -4 !!!=0AI think they want to gang up on my 50!- Anyway, hope t
o be able to have=0Athe dogfight so many want to see the result of!- :-)
=0A=0AAnyway... Pappy, I still really am confused about this.- =0A=0AMark
=0A=0A=0A-----Original Message-----=0AFrom: owner-yak-list-server@matronics
.com=0A[mailto:owner-yak-list-server@matronics.com=0A<mailto:owner-yak-list
-server@matronics.com?> ] On Behalf Of=0Acjpilot710@aol.com=0ASent: Thursda
y, May 20, 2010 1:22 PM=0ATo: yak-list@matronics.com=0ASubject: Re: Yak-Lis
t: Experimental Class=0A=0AGood questions Mark.=0A=0AMy speculations would
be:=0A1. If the engine installed has no modifications what so ever done, th
an=0Aits treated like a certified engine.- =0A- - - - - - -
- - That would mean a annual inspection by an IA and=0Amaintenance plu
s inspections per the manufacture.=0A2. Any engine that has never been cert
ified OR a certified engine that=0Ahas had a modification done, would be co
nsidered "Experimental".=0A=0AHowever a call to either the EAA or FSDO guys
would more likely give you=0Aa better answer than mine.=0A=0AI know I put
a Lyc 360 with no mods in my Pitts S1C, I built.- The FAA=0Anever said on
e word about the engine.- The whole airplane was=0A"Experimental" as far
as they were concern.- As we all know=0A"interpretation" is not an FAA no
rm.=0A=0AJim "Pappy" Goolsby=0A=0A=0A=0A=0A=0A=0A-----Original Message-----
=0AFrom: Bitterlich, Mark G CIV Det Cherry Point, MALS-14 64E=0A<mark.bitte
rlich@navy.mil>=0ATo: yak-list@matronics.com=0ASent: Wed, May 19, 2010 7:54
pm=0ASubject: Yak-List: Experimental Class=0A=0A=0A--> Yak-List message po
sted by: "Bitterlich, Mark G CIV Det Cherry =0A--> Point,=0AMALS-14 64E" <m
ark.bitterlich@navy.mil>=0A=0AA question for the legal Eagles out there.-
I have been told that if an=0AExperimental Aircraft has a "Certified" engi
ne type, then that engine is=0Arequired to undergo all requirements that it
normally would have were it=0Ato be installed in a fully certified aircraf
t. =0A=0AOk... Then that brings up the question: =0A=0A1.- Is this true?
=0A2.- If it is, then what makes an engine itself "Experimental" ?? =0A
=0AI really do not quite understand this aspect.... =0A=0AMark Bitterlich
=0A=0A-----Original Message-----=0AFrom: owner-yak-list-server@matronics.co
m=0A[mailto:owner-yak-list-server@matronics.com=0A<mailto:owner-yak-list-se
rver@matronics.com?>=0A<mailto:owner-yak-list-server@matronics.com=0A<mailt
o:owner-yak-list-server@matronics.com?> ?> ] On Behalf Of=0AKingCJ6@aol.com
=0ASent: Wednesday, May 19, 2010 1:33 AM=0ATo: yak-list@matronics.com=0A=0A
The beauty of our "experimental" class!=0A=0A=0A=0ADave- =0A=0A=0A==
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or?Yak-List=0A====================
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ontribution=0A====================
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