Today's Message Index:
----------------------
1. 12:14 AM - Re: Yak 18t (Didier BLOUZARD)
2. 06:54 AM - Re: Experimental Class (William Halverson)
3. 07:20 AM - Re: Yak 18t (SC)
4. 07:53 AM - Re: Experimental Class (A. Dennis Savarese)
5. 07:58 AM - Re: FSDO changing operating limitations on pre-moratorium a (Pete Fowler)
6. 08:10 AM - Re: Experimental Class (Bitterlich, Mark G CIV Det Cherry Point, MALS-14 64E)
7. 08:34 AM - Re: Re: FSDO changing operating limitations on pre-moratorium a (A. Dennis Savarese)
8. 08:37 AM - Re: Experimental Class (Bitterlich, Mark G CIV Det Cherry Point, MALS-14 64E)
9. 08:39 AM - Re: Experimental Class (Bitterlich, Mark G CIV Det Cherry Point, MALS-14 64E)
10. 08:51 AM - Re: Experimental Class (A. Dennis Savarese)
11. 08:51 AM - Re: Re: FSDO changing operating limitations on pre-moratorium a (A. Dennis Savarese)
12. 12:00 PM - First Certification (bigglesusa)
13. 12:44 PM - Re: Experimental Class (Roger Kemp M.D.)
14. 12:47 PM - Re: Experimental Class (John Cox)
15. 01:04 PM - Re: Experimental Class (Bitterlich, Mark G CIV Det Cherry Point, MALS-14 64E)
16. 01:15 PM - Re: Experimental Class (A. Dennis Savarese)
17. 01:23 PM - Re: Experimental Class (Bitterlich, Mark G CIV Det Cherry Point, MALS-14 64E)
18. 02:48 PM - Re: Yak 18t (Didier Blouzard)
19. 02:55 PM - Re: FSDO changing operating limitations on pre-moratorium aircra (jb92563)
20. 05:28 PM - Re: Experimental Class (racemech11)
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| Subject: | First Certification |
As my 18T nears first Experimental certification I would appreciate any advice
re Program Letter and which Richmond VA FSDO examiner would be most sympathetic
! I am watching current posts on this subject with trepidation
--------
'Le temps mange la vie'
Read this topic online here:
http://forums.matronics.com/viewtopic.php?p=298747#298747
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| Subject: | Experimental Class |
Smart move...rethinking flying media rides. As for stirring the FSDO
pot...remember they get paid to make you unhappy.
doc
-----Original Message-----
From: owner-yak-list-server@matronics.com
[mailto:owner-yak-list-server@matronics.com] On Behalf Of Bitterlich, Mark G
CIV Det Cherry Point, MALS-14 64E
Sent: Monday, May 24, 2010 10:10 AM
Subject: RE: Yak-List: Experimental Class
MALS-14 64E" <mark.bitterlich@navy.mil>
Interestingly enough, this FSDO agent (John) ... All on his own ...
Started talking about exactly that. His exact words: "Some people have
actually removed their data plates thinking that doing so will make the
engine 'experimental' and thus not have to comply with AD's. This is
anything but true. I have FAR's that specifically state ... " and so on
and so on. I just nodded my head and tried not to argue.
In talking with another pilot at the air show, he stated that at Reno,
the "remove the data plate thing" is done ALL the time and nearly every
engine out there is minus the data plate, and the FAA inspectors at that
event understand this perfectly and the reasons why.
For the record, I believe complying with engine AD's is a smart move.
99.99% of the time. That still leaves that 0.01% open though. My only
reason for even discussing this is simply to accomplish a couple of
things.
1. Learn from others more expert than myself, and I have already learned
a ton... Thanks to all, both on this list and off.
2. Make others aware of what Pappy said, which was dead on the money....
That each FSDO seems to go about interpreting rules different ways, and
to be prepared for that.
3. That I personally think the Greensboro FSDO is attempting to do #2
above right now regarding the engine issue.
One more question.
I have a list of Operating Limitations a yard long telling me
specifically what I can NOT do. None of them address operating with the
door off. The FAA says I can not do that because it is not mentioned in
the pilots operating handbook. Well, excuse me, this is a military
light attack aircraft built in Yugoslavia. It also has a factory
installed glider tow hook.. .and not one mention of how to go about
pulling gliders in the POH. The FAA says they have a specific list of
aircraft that can operate with the door removed. Of course this list is
of CERTIFICATED AIRCRAFT. But they say this does not matter, and it
must be in my POH. Just FYI, the door on the UTVA-66 (either one)
weighs about 10 pounds, is not structural in any way, has Plexiglas
sliding windows that are allowed to be open in flight at any speed. I
have pictures of Yugoslavian military jumping out of the darn thing with
the doors off, as well as Yugoslavian parachute clubs making hundreds of
jumps out of it.
Regardless, what seems very clear to me is that the FAA here is trying
apply rules made in this country and applied to certificated aircraft,
to an aircraft made in another country, that knew nothing about these
rules, did not care about them anyway, and is fact is now bombed out of
existence, so it is kind of hard to go back and talk to them and get a
note saying: "Yeah, of course it can fly with the door off, that's why
we put that big strong re-enforcement metal around the outside of the
whole door frame (which yes... It does have).
My plan is to flood the FAA in Greensboro with very polite paperwork
requesting a whole slew of operating limitations be removed and "operate
with the door off" status approved in writing. I want to be able to
pull gliders and I want to be able to drop sky-divers, and no... I do
not intend to do it for hire.
Anyway, I am really re-thinking flying Media Rides at air shows.
Mark Bitterlich
-----Original Message-----
From: owner-yak-list-server@matronics.com
[mailto:owner-yak-list-server@matronics.com] On Behalf Of bill wade
Sent: Sunday, May 23, 2010 23:59
Subject: Re: Yak-List: 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.
Bill Wade
________________________________
From: "Bitterlich, Mark G CIV Det Cherry Point, MALS-14 64E"
<mark.bitterlich@navy.mil>
Sent: Sun, May 23, 2010 10:15:58 AM
Subject: RE: Yak-List: Experimental Class
--> Point, MALS-14 64E" <mark.bitterlich@navy.mil>
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
===================================
get=_blank>http://www.matronics.com/Navigator?Yak-List
==========
tp://forums.matronics.com
===================================
_blank>http://www.matronics.com/contribution
=========also available via the -Matt
Drall===========
Message 14
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| Subject: | Experimental Class |
Mark, let me put a log on the slow burning fire. Just to keep the
audience warm.
As an A&P with I/A, a career airline mechanic who works on prop driven
beasts by night and as a spare time EAA Tech Advisory, here are a few
tenets that I have operated with.
1. Mechanics, Owners and yes FAA Inspectors are human and make mistakes
(Occasionally).
2. Certificated Aircraft / Certificated Engines and Certificated Props
or Appliances are called that because they were manufactured and
required to be maintained by the manufacturer to a TCDS -Type
Certificate Data Sheet. Non compliance knocks them out of that category
until brought back into compliance. Often that takes more money that
timely compliance would have in the first place.
3. Not all "once certificated" aircraft engines remain certificated
throughout their life, but might morph into Experimental engines quite
quickly. Data plates are not necessarily the determinate.
4. Experimental Aircraft ownership allows those owners/operators to
change "at will" powerplants/props/accessories that do not alter the
power output more than 10%. Airframe mods are somewhat similar but
separately phrased.
5. Engines which alter the aircraft's output more than 10% require
additional "proof of concept" testing after introduction.
6. ADs are a mandatory requirement on Certificated Aircraft and/or
certificated engines while attached to those aircraft. An Experimental
Aircraft can continue to operate after the certificated engine becomes
Non-compliant - it reverts to an Experimental engine while Non-Compliant
until "Brought Back". You don't ever have to bring it back!
7. SB - Service Bulletins and SLs - Service Letters are advisory in
nature. Not a bad idea to acknowledge their existence.
8. Insurance Underwriters like to make non-compliance a "Voidable
cancellation clause" in some aircraft policies.
9. By their classification, Experimental Aircraft are not required to
comply with ADs.
10. Asking yourself why not comply to directives is a good thing to do
frequently.
11. Anyone can do maintenance on any Experimental aircraft.
Competency/proper tools and clear concise instructions are not required
(it is really True!). Only the Conditional Inspection might require
someone of certificated status (Repairman/Mechanic) to make a statement
on its condition to be insurable and compliant at that one unique moment
in time. From that point the responsibility is on the Operator who
places it into flight. I personally shudder at some of the work that I
see on inspections. then I remember.... It's just Experimental in
category.
12. It is the owner/operator/builder/manufacturer's responsibility to
provide necessary documents on the respective components and their
proper maintenance to every individual who must then document all work
performed on the aircraft. Most experimental aircraft have almost
nothing to reference.
Now back to the real world. There was a brief glimpse of sanity back in
1987 when Allan McArtor was the FAA Administrator under then President
Reagan. He was a former Thunderbird and had as a personal mission a
desire to level the playing field with errant, pompous Inspectors. He
wanted a focus back to promoting General Aviation with less on
enforcement and heavy handed interpretations. I think they were too
much like Dirty Harry at the time. He made available his personal
direct phone number in DC. Mr. McArtor projected the authoritive opinion
that all FSDOs and their employees worked for the General Public - you.
Somewhere along the route of the previous 30 years, that tenet got lost.
Today Randy Babbitt is the closest thing to bringing the FAA back to
meeting the needs of the general public. I believe he is more
approachable than Marion Blakely and receptive to assisting our
interests. Congress is beginning to listen.
His advise (McArtor's), document the wrong you have been served "In
Writing", deliver it to your Congressman or US Senator and begin a
process called "Congressionalizing a federal employee". Better yet, just
call him - The FAA Administrator. The process was/is slow, the results
were surprising to all including the errant Inspectors who got thrown
under the bus. Everyone should be singing to the same sheet of music.
I have seen the impact on such a local inspector who lost his way with a
friend. The inspector moved to Germany, the friend to Iowa. I
personally have picked up the phone and watched the system work here in
the Northwest Mountain Region on two occasions. There is little reason
it cannot work across the entire country.
Experimental Aircraft is a remarkable category. Nowhere does it say you
need a certificated engine or propeller. I will await official word
that my tenet #9 is incorrect. A logbook entry of the transition from
Certificated engine, modified and now Experimental on this date with
these operational hours should be enough.
Fly Safe, Fly Often, Fly compliant
John Cox
-----Original Message-----
From: owner-yak-list-server@matronics.com
[mailto:owner-yak-list-server@matronics.com] On Behalf Of Bitterlich,
Mark G CIV Det Cherry Point, MALS-14 64E
Sent: Monday, May 24, 2010 8:39 AM
Subject: RE: Yak-List: Experimental Class
Point, MALS-14 64E" <mark.bitterlich@navy.mil>
Answer: When the engine has been modified in such a way that the AD
does not apply. Not saying that this makes my personal view right... In
fact I defer to your greater knowledge (times 100).
Mark
Message 15
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| Subject: | Experimental Class |
That's why I am planning on hiring someone else to do it.
Film at 11.
Mark
-----Original Message-----
From: owner-yak-list-server@matronics.com
[mailto:owner-yak-list-server@matronics.com] On Behalf Of Roger Kemp
M.D.
Sent: Monday, May 24, 2010 15:44
Subject: RE: Yak-List: Experimental Class
--> <viperdoc@mindspring.com>
Smart move...rethinking flying media rides. As for stirring the FSDO
pot...remember they get paid to make you unhappy.
doc
-----Original Message-----
From: owner-yak-list-server@matronics.com
[mailto:owner-yak-list-server@matronics.com] On Behalf Of Bitterlich,
Mark G CIV Det Cherry Point, MALS-14 64E
Sent: Monday, May 24, 2010 10:10 AM
Subject: RE: Yak-List: Experimental Class
--> Point,
MALS-14 64E" <mark.bitterlich@navy.mil>
Interestingly enough, this FSDO agent (John) ... All on his own ...
Started talking about exactly that. His exact words: "Some people have
actually removed their data plates thinking that doing so will make the
engine 'experimental' and thus not have to comply with AD's. This is
anything but true. I have FAR's that specifically state ... " and so on
and so on. I just nodded my head and tried not to argue.
In talking with another pilot at the air show, he stated that at Reno,
the "remove the data plate thing" is done ALL the time and nearly every
engine out there is minus the data plate, and the FAA inspectors at that
event understand this perfectly and the reasons why.
For the record, I believe complying with engine AD's is a smart move.
99.99% of the time. That still leaves that 0.01% open though. My only
reason for even discussing this is simply to accomplish a couple of
things.
1. Learn from others more expert than myself, and I have already learned
a ton... Thanks to all, both on this list and off.
2. Make others aware of what Pappy said, which was dead on the money....
That each FSDO seems to go about interpreting rules different ways, and
to be prepared for that.
3. That I personally think the Greensboro FSDO is attempting to do #2
above right now regarding the engine issue.
One more question.
I have a list of Operating Limitations a yard long telling me
specifically what I can NOT do. None of them address operating with the
door off. The FAA says I can not do that because it is not mentioned in
the pilots operating handbook. Well, excuse me, this is a military
light attack aircraft built in Yugoslavia. It also has a factory
installed glider tow hook.. .and not one mention of how to go about
pulling gliders in the POH. The FAA says they have a specific list of
aircraft that can operate with the door removed. Of course this list is
of CERTIFICATED AIRCRAFT. But they say this does not matter, and it
must be in my POH. Just FYI, the door on the UTVA-66 (either one)
weighs about 10 pounds, is not structural in any way, has Plexiglas
sliding windows that are allowed to be open in flight at any speed. I
have pictures of Yugoslavian military jumping out of the darn thing with
the doors off, as well as Yugoslavian parachute clubs making hundreds of
jumps out of it.
Regardless, what seems very clear to me is that the FAA here is trying
apply rules made in this country and applied to certificated aircraft,
to an aircraft made in another country, that knew nothing about these
rules, did not care about them anyway, and is fact is now bombed out of
existence, so it is kind of hard to go back and talk to them and get a
note saying: "Yeah, of course it can fly with the door off, that's why
we put that big strong re-enforcement metal around the outside of the
whole door frame (which yes... It does have).
My plan is to flood the FAA in Greensboro with very polite paperwork
requesting a whole slew of operating limitations be removed and "operate
with the door off" status approved in writing. I want to be able to
pull gliders and I want to be able to drop sky-divers, and no... I do
not intend to do it for hire.
Anyway, I am really re-thinking flying Media Rides at air shows.
Mark Bitterlich
-----Original Message-----
From: owner-yak-list-server@matronics.com
[mailto:owner-yak-list-server@matronics.com] On Behalf Of bill wade
Sent: Sunday, May 23, 2010 23:59
Subject: Re: Yak-List: 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.
Bill Wade
________________________________
From: "Bitterlich, Mark G CIV Det Cherry Point, MALS-14 64E"
<mark.bitterlich@navy.mil>
Sent: Sun, May 23, 2010 10:15:58 AM
Subject: RE: Yak-List: Experimental Class
--> Point, MALS-14 64E" <mark.bitterlich@navy.mil>
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 16
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| Subject: | Re: Experimental Class |
John,
I enjoyed reading your excellent post.
For my own files, can you cite the FAR, Order, etc. that your tenet #4
and #5 are derived from?
Thanks very much.
Dennis
----- Original Message -----
From: John Cox
To: yak-list@matronics.com
Sent: Monday, May 24, 2010 2:45 PM
Subject: RE: Yak-List: Experimental Class
Mark, let me put a log on the slow burning fire. Just to keep the
audience warm.
As an A&P with I/A, a career airline mechanic who works on prop driven
beasts by night and as a spare time EAA Tech Advisory, here are a few
tenets that I have operated with.
1. Mechanics, Owners and yes FAA Inspectors are human and make
mistakes
(Occasionally).
2. Certificated Aircraft / Certificated Engines and Certificated
Props
or Appliances are called that because they were manufactured and
required to be maintained by the manufacturer to a TCDS -Type
Certificate Data Sheet. Non compliance knocks them out of that
category
until brought back into compliance. Often that takes more money that
timely compliance would have in the first place.
3. Not all "once certificated" aircraft engines remain certificated
throughout their life, but might morph into Experimental engines quite
quickly. Data plates are not necessarily the determinate.
4. Experimental Aircraft ownership allows those owners/operators to
change "at will" powerplants/props/accessories that do not alter the
power output more than 10%. Airframe mods are somewhat similar but
separately phrased.
5. Engines which alter the aircraft's output more than 10% require
additional "proof of concept" testing after introduction.
6. ADs are a mandatory requirement on Certificated Aircraft and/or
certificated engines while attached to those aircraft. An
Experimental
Aircraft can continue to operate after the certificated engine becomes
Non-compliant - it reverts to an Experimental engine while
Non-Compliant
until "Brought Back". You don't ever have to bring it back!
7. SB - Service Bulletins and SLs - Service Letters are advisory in
nature. Not a bad idea to acknowledge their existence.
8. Insurance Underwriters like to make non-compliance a "Voidable
cancellation clause" in some aircraft policies.
9. By their classification, Experimental Aircraft are not required to
comply with ADs.
10. Asking yourself why not comply to directives is a good thing to
do
frequently.
11. Anyone can do maintenance on any Experimental aircraft.
Competency/proper tools and clear concise instructions are not
required
(it is really True!). Only the Conditional Inspection might require
someone of certificated status (Repairman/Mechanic) to make a
statement
on its condition to be insurable and compliant at that one unique
moment
in time. From that point the responsibility is on the Operator who
places it into flight. I personally shudder at some of the work that I
see on inspections. then I remember.... It's just Experimental in
category.
12. It is the owner/operator/builder/manufacturer's responsibility to
provide necessary documents on the respective components and their
proper maintenance to every individual who must then document all work
performed on the aircraft. Most experimental aircraft have almost
nothing to reference.
Now back to the real world. There was a brief glimpse of sanity back
in
1987 when Allan McArtor was the FAA Administrator under then President
Reagan. He was a former Thunderbird and had as a personal mission a
desire to level the playing field with errant, pompous Inspectors. He
wanted a focus back to promoting General Aviation with less on
enforcement and heavy handed interpretations. I think they were too
much like Dirty Harry at the time. He made available his personal
direct phone number in DC. Mr. McArtor projected the authoritive
opinion
that all FSDOs and their employees worked for the General Public -
you.
Somewhere along the route of the previous 30 years, that tenet got
lost.
Today Randy Babbitt is the closest thing to bringing the FAA back to
meeting the needs of the general public. I believe he is more
approachable than Marion Blakely and receptive to assisting our
interests. Congress is beginning to listen.
His advise (McArtor's), document the wrong you have been served "In
Writing", deliver it to your Congressman or US Senator and begin a
process called "Congressionalizing a federal employee". Better yet,
just
call him - The FAA Administrator. The process was/is slow, the results
were surprising to all including the errant Inspectors who got thrown
under the bus. Everyone should be singing to the same sheet of music.
I have seen the impact on such a local inspector who lost his way with
a
friend. The inspector moved to Germany, the friend to Iowa. I
personally have picked up the phone and watched the system work here
in
the Northwest Mountain Region on two occasions. There is little
reason
it cannot work across the entire country.
Experimental Aircraft is a remarkable category. Nowhere does it say
you
need a certificated engine or propeller. I will await official word
that my tenet #9 is incorrect. A logbook entry of the transition from
Certificated engine, modified and now Experimental on this date with
these operational hours should be enough.
Fly Safe, Fly Often, Fly compliant
John Cox
-----Original Message-----
From: owner-yak-list-server@matronics.com
[mailto:owner-yak-list-server@matronics.com] On Behalf Of Bitterlich,
Mark G CIV Det Cherry Point, MALS-14 64E
Sent: Monday, May 24, 2010 8:39 AM
To: yak-list@matronics.com
Subject: RE: Yak-List: Experimental Class
Point, MALS-14 64E" <mark.bitterlich@navy.mil>
Answer: When the engine has been modified in such a way that the AD
does not apply. Not saying that this makes my personal view right...
In
fact I defer to your greater knowledge (times 100).
Mark
Message 17
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| Subject: | Experimental Class |
John,
This was a very informative and very interesting posting. To put it
mildly.
Thank you for writing it.
Questions: "ADs are a mandatory requirement on Certificated Aircraft
and/or certificated engines while attached to those aircraft."
My GSO-480 Lycoming engine and Hartzell prop was sold under contract to
Yugoslavia who put it in an aircraft of their own design. Thus the
engine was never put in a U.S. Certificated aircraft and was brought
into this country in Experimental Exhibition status from Canada. So
when you say: "While attached to those aircraft", what aircraft are you
referring to? An original certificated aircraft, which if that is what
you meant... Mine never was... So, ???? I am guessing I still need to
make the logbook entry.
Lastly... When you have an FAA inspector who refuses to listen and
instead just talks... And expects you to sit there at his feet kissing
them in the process... Your recourse is as you point out?
A very powerful post. Again, thank you.
Mark
-----Original Message-----
From: owner-yak-list-server@matronics.com
[mailto:owner-yak-list-server@matronics.com] On Behalf Of John Cox
Sent: Monday, May 24, 2010 15:45
Subject: RE: Yak-List: Experimental Class
Mark, let me put a log on the slow burning fire. Just to keep the
audience warm.
As an A&P with I/A, a career airline mechanic who works on prop driven
beasts by night and as a spare time EAA Tech Advisory, here are a few
tenets that I have operated with.
1. Mechanics, Owners and yes FAA Inspectors are human and make mistakes
(Occasionally).
2. Certificated Aircraft / Certificated Engines and Certificated Props
or Appliances are called that because they were manufactured and
required to be maintained by the manufacturer to a TCDS -Type
Certificate Data Sheet. Non compliance knocks them out of that category
until brought back into compliance. Often that takes more money that
timely compliance would have in the first place.
3. Not all "once certificated" aircraft engines remain certificated
throughout their life, but might morph into Experimental engines quite
quickly. Data plates are not necessarily the determinate.
4. Experimental Aircraft ownership allows those owners/operators to
change "at will" powerplants/props/accessories that do not alter the
power output more than 10%. Airframe mods are somewhat similar but
separately phrased.
5. Engines which alter the aircraft's output more than 10% require
additional "proof of concept" testing after introduction.
6. ADs are a mandatory requirement on Certificated Aircraft and/or
certificated engines while attached to those aircraft. An Experimental
Aircraft can continue to operate after the certificated engine becomes
Non-compliant - it reverts to an Experimental engine while Non-Compliant
until "Brought Back". You don't ever have to bring it back!
7. SB - Service Bulletins and SLs - Service Letters are advisory in
nature. Not a bad idea to acknowledge their existence.
8. Insurance Underwriters like to make non-compliance a "Voidable
cancellation clause" in some aircraft policies.
9. By their classification, Experimental Aircraft are not required to
comply with ADs.
10. Asking yourself why not comply to directives is a good thing to do
frequently.
11. Anyone can do maintenance on any Experimental aircraft.
Competency/proper tools and clear concise instructions are not required
(it is really True!). Only the Conditional Inspection might require
someone of certificated status (Repairman/Mechanic) to make a statement
on its condition to be insurable and compliant at that one unique moment
in time. From that point the responsibility is on the Operator who
places it into flight. I personally shudder at some of the work that I
see on inspections. then I remember.... It's just Experimental in
category.
12. It is the owner/operator/builder/manufacturer's responsibility to
provide necessary documents on the respective components and their
proper maintenance to every individual who must then document all work
performed on the aircraft. Most experimental aircraft have almost
nothing to reference.
Now back to the real world. There was a brief glimpse of sanity back in
1987 when Allan McArtor was the FAA Administrator under then President
Reagan. He was a former Thunderbird and had as a personal mission a
desire to level the playing field with errant, pompous Inspectors. He
wanted a focus back to promoting General Aviation with less on
enforcement and heavy handed interpretations. I think they were too
much like Dirty Harry at the time. He made available his personal
direct phone number in DC. Mr. McArtor projected the authoritive opinion
that all FSDOs and their employees worked for the General Public - you.
Somewhere along the route of the previous 30 years, that tenet got lost.
Today Randy Babbitt is the closest thing to bringing the FAA back to
meeting the needs of the general public. I believe he is more
approachable than Marion Blakely and receptive to assisting our
interests. Congress is beginning to listen.
His advise (McArtor's), document the wrong you have been served "In
Writing", deliver it to your Congressman or US Senator and begin a
process called "Congressionalizing a federal employee". Better yet, just
call him - The FAA Administrator. The process was/is slow, the results
were surprising to all including the errant Inspectors who got thrown
under the bus. Everyone should be singing to the same sheet of music.
I have seen the impact on such a local inspector who lost his way with a
friend. The inspector moved to Germany, the friend to Iowa. I
personally have picked up the phone and watched the system work here in
the Northwest Mountain Region on two occasions. There is little reason
it cannot work across the entire country.
Experimental Aircraft is a remarkable category. Nowhere does it say you
need a certificated engine or propeller. I will await official word
that my tenet #9 is incorrect. A logbook entry of the transition from
Certificated engine, modified and now Experimental on this date with
these operational hours should be enough.
Fly Safe, Fly Often, Fly compliant
John Cox
-----Original Message-----
From: owner-yak-list-server@matronics.com
[mailto:owner-yak-list-server@matronics.com] On Behalf Of Bitterlich,
Mark G CIV Det Cherry Point, MALS-14 64E
Sent: Monday, May 24, 2010 8:39 AM
Subject: RE: Yak-List: Experimental Class
Point, MALS-14 64E" <mark.bitterlich@navy.mil>
Answer: When the engine has been modified in such a way that the AD
does not apply. Not saying that this makes my personal view right... In
fact I defer to your greater knowledge (times 100).
Mark
Message 18
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Hi,
try to look the fom on my website :
http://www.wonder-wings.fr/index.php?part=11
Tell me if these are the same as mine. The FOm has been accepted by the
HACAA (Hungarian CAA) and is official for my CofA
regards
Didier
2010/5/24 SC <thecookoos@gmail.com>
>
> Hi Didier
> I have the Unofficial FOM Issue 1.1 and am quite happy with it but not su
re
> yet about FAA. Did the French authority accept this version.
> Will let you know what I receive.
> Regards
>
> Franklin VA (and UK)
>
> -----Original Message-----
> From: owner-yak-list-server@matronics.com
> [mailto:owner-yak-list-server@matronics.com] On Behalf Of Didier BLOUZARD
> Sent: Monday, May 24, 2010 3:14 AM
> To: yak-list@matronics.com
> Subject: Re: Yak-List: Yak 18t
>
m
> >
>
> I have some material but I think it might be the UK.one
> Would be interested also in another version
>
> Didier Blouzard
> +33 6 2424 3672
>
> Le 24 mai 2010 =C4=85 04:54, "bigglesusa" <thecookoos@gmail.com> a =C3=A9
crit :
>
> >
> > 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
> >
> >
> >
> >
> >
> >
> >
> >
> >
> >
>
>
===========
===========
===========
===========
>
>
--
Didier BLOUZARD
didier.blouzard@gmail.com
0624243672
Message 19
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| Subject: | Re: FSDO changing operating limitations on pre-moratorium aircra |
I am also going through something similar with My Experimental Exhibition Motor
Glider.
When I bought the aircraft I moved it to a different FSDO's jurisdiction so i thought
I had to update the Operating Limitations.
The FAA fellows initial response was that he did not find any direction requiring
me to do that.
But I did find my special airwothiness cert and Op limitations date did not match
and wanted to rectify the situation.
I had SA Cert dated 1991 and Op Lim's dated 1993.
I was informed that the FAA had no record of any of them in their archives since
1984!
Did they conveniently loose all the unlimited special airworthy certs from Scottdale,AZ
before archiving. ...jeez what the heck is going on!
Called the AZ FSDO and they did not have them either.
So now it looks like I will have to apply again. and go through the hassle all
over, because nobody in the FAA knows much about self launch gliders (motor gliders)
I did find it good to hear that the FAA can not arbitrarily change your Op Lims,
but what if they lose them?
Frustrated,
Ray
--------
Ray
Kolb UltraStar (Cuyuna UL-202)
Moni MotorGlider
Schreder HP-11 Glider
Grob 109 Motorglider
Do Not Archive
Read this topic online here:
http://forums.matronics.com/viewtopic.php?p=298776#298776
Message 20
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| Subject: | Re: Experimental Class |
Let me put my .02 cents worth in and it is just my understanding. I think, as you
can see, there are many with an understanding and somewhere in them is the
real truth.
Be very careful with the way your operating limitations are written. Usually, if
it is a certified product, such as an airframe, engine, prop, etc. and is moving
into the experimental category, the limitations will state that the product
will be maintained in accordance with Part 43.
If this statement is included in your operating limitations, you are required to
comply with A.D.'s (my understanding of this stuff.)
Read this topic online here:
http://forums.matronics.com/viewtopic.php?p=298795#298795
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