Today's Message Index:
----------------------
1. 06:11 AM - Re: Program Letter (Rich Langer)
2. 06:39 AM - Re: Re: Program Letter (A. Dennis Savarese)
3. 06:52 AM - Re: Re: Program Letter (Bitterlich, Mark G CIV Det Cherry Point, MALS-14 64E)
4. 07:07 AM - Re: Re: Program Letter (Bitterlich, Mark G CIV Det Cherry Point, MALS-14 64E)
5. 07:07 AM - Re: Re: Program Letter (A. Dennis Savarese)
6. 07:17 AM - Re: Re: Program Letter (A. Dennis Savarese)
7. 07:24 AM - Re: Re: Program Letter (Bitterlich, Mark G CIV Det Cherry Point, MALS-14 64E)
8. 07:28 AM - Re: Re: Program Letter (Bitterlich, Mark G CIV Det Cherry Point, MALS-14 64E)
9. 07:47 AM - Re: Re: Program Letter (A. Dennis Savarese)
10. 07:51 AM - Re: Re: Program Letter (A. Dennis Savarese)
11. 08:11 AM - Re: Re: Program Letter (A. Dennis Savarese)
12. 12:28 PM - Re: Re: Program Letter (Bitterlich, Mark G CIV Det Cherry Point, MALS-14 64E)
13. 12:29 PM - Re: Re: Program Letter (Bitterlich, Mark G CIV Det Cherry Point, MALS-14 64E)
14. 12:40 PM - Re: Re: Program Letter (Jim Griffin)
15. 12:58 PM - Re: Re: Program Letter (Bitterlich, Mark G CIV Det Cherry Point, MALS-14 64E)
16. 01:06 PM - Re: Re: Program Letter (cjpilot710@aol.com)
17. 01:07 PM - Re: Re: Program Letter (Jim Griffin)
18. 03:02 PM - Re: Re: Program Letter (Roger Kemp M.D.)
19. 03:26 PM - Re: Re: Program Letter (Bitterlich, Mark G CIV Det Cherry Point, MALS-14 64E)
20. 03:37 PM - Re: Re: Program Letter (A. Dennis Savarese)
21. 03:37 PM - Re: Re: Program Letter (A. Dennis Savarese)
22. 03:40 PM - Re: Re: Program Letter (Bitterlich, Mark G CIV Det Cherry Point, MALS-14 64E)
23. 03:49 PM - Re: Re: Program Letter (Bitterlich, Mark G CIV Det Cherry Point, MALS-14 64E)
24. 03:52 PM - Re: Re: Program Letter (Bitterlich, Mark G CIV Det Cherry Point, MALS-14 64E)
25. 03:58 PM - Re: Re: Program Letter (Bitterlich, Mark G CIV Det Cherry Point, MALS-14 64E)
26. 04:17 PM - Re: Re: Program Letter (Bitterlich, Mark G CIV Det Cherry Point, MALS-14 64E)
27. 04:31 PM - Re: Spam:*******, Re: Re: Program Letter (Curtis White)
28. 04:56 PM - Re: Re: Program Letter (Jim Griffin)
29. 05:45 PM - Re: Re: Program Letter (A. Dennis Savarese)
30. 06:09 PM - Re: Re: Program Letter (A. Dennis Savarese)
31. 06:19 PM - Re: Re: Program Letter (A. Dennis Savarese)
32. 06:52 PM - Re: Re: Program Letter (Jj)
33. 07:50 PM - Re: Re: Program Letter (Jim Griffin)
34. 09:04 PM - Re: Re: Program Letter (Roger Kemp M.D.)
35. 09:04 PM - Re: Re: Program Letter (Roger Baker)
Message 1
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| Subject: | Re: Program Letter |
Dennis, just to clarify, do you mean an addition to your program letter is required
to attend an event even if you are within the 300/600 mi. proficiency area?
Secondly, if you have had the 300/600 mi. limit removed from your O.L.'s are
you now required to list every event you go to, no matter what the distance?
Read this topic online here:
http://forums.matronics.com/viewtopic.php?p=340917#340917
Message 2
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| Subject: | Re: Program Letter |
Yes, that is correct. There is nothing in the OL's that says if you are
attending an event within the 300/600 mile proficiency area, a copy of
your Program Letter (or modification adding the event) is not required.
It's a ridiculous rule, but I checked with the EAA on this issue and
they said the requirement to have your program letter showing the event
you are attending even if it is within the 300 mile proficiency area was
never eliminated with the elimination of the 300/600 mile proficiency area.
Yes, this is also true even if you have had your OL's updated to remove
the 300/600 mile proficiency area. The requirement for an annual
Program Letter or modifications to add an event remain in place. Read
you OL's. If "Program Letter" is still in the OL's, then you must
submit one annually, plus submit updates as required regardless of the
distance of the event you are attending from your home base airport.
Dennis
On 5/25/2011 8:08 AM, Rich Langer wrote:
> --> Yak-List message posted by: "Rich Langer"<rlanger2@comcast.net>
>
> Dennis, just to clarify, do you mean an addition to your program letter is required
to attend an event even if you are within the 300/600 mi. proficiency area?
Secondly, if you have had the 300/600 mi. limit removed from your O.L.'s
are you now required to list every event you go to, no matter what the distance?
>
>
> Read this topic online here:
>
> http://forums.matronics.com/viewtopic.php?p=340917#340917
>
>
Message 3
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| Subject: | Re: Program Letter |
Concur ABSOLUTELY
Mark
-----Original Message-----
From: owner-yak-list-server@matronics.com
[mailto:owner-yak-list-server@matronics.com] On Behalf Of keithmckinley
Sent: Tuesday, May 24, 2011 10:00 PM
Subject: Yak-List: Re: Program Letter
<keith.mckinley@townisp.com>
Mark,
Thanks for the feedback.
No 300 mile restriction. No doubt it is easier to play nice with the
Fed's and yes it does pay dividends, but sometimes I think it's
important to make sure they interpret things correctly and realize (as
inspectors) they don't make the rules. More than anything, I just have
an aversion to ass kissing.......but not to protecting my own ass!
Semper Fi
Keith
--------
Keith McKinley
700HS
KFIT
Read this topic online here:
http://forums.matronics.com/viewtopic.php?p=340874#340874
Message 4
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| Subject: | Re: Program Letter |
Dennis, I respectfully disagree with your point of view in this one
area.
You mentioned:
"The program letter and modifications which you may send by fax are in
fact part of the Operating Limitations for the airplane. We all know
you are required to carry the OL's in the airplane at all times. Since
the Program Letter is actually a part of the OL's, then IMHO, it is also
required to be carried in the airplane."
The Operating Limitations also require a Conditional Inspection every
year. By the same logic, you would also need to carry along a copy of
your Conditional Inspection, or copies of your aircraft logbooks, etc.
My opinion on dealing with the FAA on things like this is when they say:
"We need to see a copy of your Program Letter or modification of same,
and if you don't have it with you, you must leave."
NUMBER ONE: !!! Reply with: "Please quote the Regulation that
specifically states I must carry a copy of my Program Letter with me.
If you cannot quote me the exact regulation that requires me to do this,
I respectfully submit you have no authority to demand it from me".
You must carry a copy of your Operating Limitations. READ THEM! Break
them out and have the FAA Inspector SHOW YOU on the Operating
Limitations where it says what he is saying. THE BURDON OF PROOF IS ON
THE FAA, not on your to prove you are innocent. Sometimes certain FAA
Inspectors forget that fact. Some Inspectors also assume that anything
they say is automatically correct. Anything you say is automatically
wrong. You need to know your regulations and you also need the phone
number to the EAA's Govt. Hotline. Ask for Randy Hanson.
NUMBER TWO: If they still play nasty.... Go back to the motel, do a
handwritten modification to your Program Letter on a paper napkin, go
down to the Hotel Desk and FAX IT to your local FISDO. The go back to
the airport and hand that FAA Inspector the paper napkin and bit him a
fond farewell. I am not being sarcastic here. OK. The paper napkin
part is supposed to be a joke (OK who-ever from the FAA READS THIS? A
JOKE! PLEASE? Good grief).
Not that I think you're wrong about carrying the stuff along. The FAA
CONSTANTLY (!!!) interprets things differently and they can come up with
the strangest things (flying with my door off, etc) and you have to go
to the ends of the Earth to get them to see things a little bit
differently.
Just saying. I think being polite but not cowardly is the best
approach... my 2 cents.
Mark
-----Original Message-----
From: owner-yak-list-server@matronics.com
[mailto:owner-yak-list-server@matronics.com] On Behalf Of A. Dennis
Savarese
Sent: Tuesday, May 24, 2011 10:47 PM
Subject: Re: Yak-List: Re: Program Letter
<dsavarese0812@bellsouth.net>
Here's something to think about.
The program letter and modifications which you may send by fax are in
fact part of the Operating Limitations for the airplane. We all know
you are required to carry the OL's in the airplane at all times. Since
the Program Letter is actually a part of the OL's, then IMHO, it is also
required to be carried in the airplane.
Unfortunately, when the FAA removed the 300/600 NM proficiency area,
they failed to include the elimination of the Program Letter, which
would have made logical sense. ie: if you don't have any restrictions
as to where you can fly, they why do you need a Program Letter to attend
an event?
When you attend an event that may also be attended by the FAA (typically
when there is wavered airspace) and they ask to see your aircraft's
paperwork as well as you pilot certificate and current medical form,
when you hand him/her the aircraft's Operating Limitations he/she will
also ask to see your Program Letter or modification for this specific
event. If you do not have your Program Letter with the specific event
on it or a modification/update to the program letter which you submitted
to your FSDO with you, the FAA person may not permit you to stay at the
event. I had this happen to me about 5 years ago. Thus, when I sent
my program letter in to the FSDO each year, I automatically put a copy
in the airplane along with any modifications.
Dennis
On 5/24/2011 9:00 PM, keithmckinley wrote:
> --> Yak-List message posted by:
"keithmckinley"<keith.mckinley@townisp.com>
>
> Mark,
>
> Thanks for the feedback.
>
> No 300 mile restriction. No doubt it is easier to play nice with the
Fed's and yes it does pay dividends, but sometimes I think it's
important to make sure they interpret things correctly and realize (as
inspectors) they don't make the rules. More than anything, I just have
an aversion to ass kissing.......but not to protecting my own ass!
>
> Semper Fi
>
> Keith
>
> --------
> Keith McKinley
> 700HS
> KFIT
>
>
> Read this topic online here:
>
> http://forums.matronics.com/viewtopic.php?p=340874#340874
>
>
Message 5
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| Subject: | Re: Program Letter |
For those that want to see the latest and greatest version of the FAA
Order 8130.2x, on April 16, 2011 the FAA 8130.2G became effective. The
Yak 52 and CJ6 now fall into a new grouping method they have
established; Group 2. Within the groups is a matrix chart that
established what Operating Limitation must be included in the OL's for a
aircraft in that group.
Unfortunately, guess what remains.....the infamous Program Letter
requirement. Here are the exact words from the FAA Order which answers
the question whether the Program Letter and any amendments must be
carried in the airplane.
"....(3) The owner operator must submit an annual program letter to the
geographically
responsible FSDO where the aircraft is based. All operations must be
conducted in accordance
with these limitations and the program letter. A copy of the current
program letter and any
amendments must be carried on board the aircraft any time that the
aircraft is being operated.
The program letter must include the following information:
(a) The aircrafts home base.
(b) The name of the person responsible for the operation and maintenance
of the
aircraft.
(c) A list of events at which the aircraft will be exhibited (the list
may be amended
as necessary).
(d) For Group 6 and Group 7 aircraft, the proficiency area. The
proficiency area
may be depicted using a map or it may be described by geographic
landmarks, airports, or aids to
navigation.
(4) The pilot in command of this aircraft must hold an appropriate
category and class
rating.
Hope this helps.
Dennis
On 5/25/2011 8:50 AM, Bitterlich, Mark G CIV Det Cherry Point, MALS-14
64E wrote:
> --> Yak-List message posted by: "Bitterlich, Mark G CIV Det Cherry Point, MALS-14
64E"<mark.bitterlich@navy.mil>
>
> Concur ABSOLUTELY
>
> Mark
>
>
> -----Original Message-----
> From: owner-yak-list-server@matronics.com
> [mailto:owner-yak-list-server@matronics.com] On Behalf Of keithmckinley
> Sent: Tuesday, May 24, 2011 10:00 PM
> To: yak-list@matronics.com
> Subject: Yak-List: Re: Program Letter
>
> --> Yak-List message posted by: "keithmckinley"
> <keith.mckinley@townisp.com>
>
> Mark,
>
> Thanks for the feedback.
>
> No 300 mile restriction. No doubt it is easier to play nice with the
> Fed's and yes it does pay dividends, but sometimes I think it's
> important to make sure they interpret things correctly and realize (as
> inspectors) they don't make the rules. More than anything, I just have
> an aversion to ass kissing.......but not to protecting my own ass!
>
> Semper Fi
>
> Keith
>
> --------
> Keith McKinley
> 700HS
> KFIT
>
>
> Read this topic online here:
>
> http://forums.matronics.com/viewtopic.php?p=340874#340874
>
>
Message 6
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|
| Subject: | Re: Program Letter |
Mark, I respectfully request you read my next posting on the subject. :-)
On 5/25/2011 9:04 AM, Bitterlich, Mark G CIV Det Cherry Point, MALS-14
64E wrote:
> --> Yak-List message posted by: "Bitterlich, Mark G CIV Det Cherry Point, MALS-14
64E"<mark.bitterlich@navy.mil>
>
> Dennis, I respectfully disagree with your point of view in this one
> area.
>
> You mentioned:
>
> "The program letter and modifications which you may send by fax are in
> fact part of the Operating Limitations for the airplane. We all know
> you are required to carry the OL's in the airplane at all times. Since
> the Program Letter is actually a part of the OL's, then IMHO, it is also
>
> required to be carried in the airplane."
>
> The Operating Limitations also require a Conditional Inspection every
> year. By the same logic, you would also need to carry along a copy of
> your Conditional Inspection, or copies of your aircraft logbooks, etc.
> My opinion on dealing with the FAA on things like this is when they say:
>
>
> "We need to see a copy of your Program Letter or modification of same,
> and if you don't have it with you, you must leave."
>
> NUMBER ONE: !!! Reply with: "Please quote the Regulation that
> specifically states I must carry a copy of my Program Letter with me.
> If you cannot quote me the exact regulation that requires me to do this,
> I respectfully submit you have no authority to demand it from me".
>
> You must carry a copy of your Operating Limitations. READ THEM! Break
> them out and have the FAA Inspector SHOW YOU on the Operating
> Limitations where it says what he is saying. THE BURDON OF PROOF IS ON
> THE FAA, not on your to prove you are innocent. Sometimes certain FAA
> Inspectors forget that fact. Some Inspectors also assume that anything
> they say is automatically correct. Anything you say is automatically
> wrong. You need to know your regulations and you also need the phone
> number to the EAA's Govt. Hotline. Ask for Randy Hanson.
>
> NUMBER TWO: If they still play nasty.... Go back to the motel, do a
> handwritten modification to your Program Letter on a paper napkin, go
> down to the Hotel Desk and FAX IT to your local FISDO. The go back to
> the airport and hand that FAA Inspector the paper napkin and bit him a
> fond farewell. I am not being sarcastic here. OK. The paper napkin
> part is supposed to be a joke (OK who-ever from the FAA READS THIS? A
> JOKE! PLEASE? Good grief).
>
> Not that I think you're wrong about carrying the stuff along. The FAA
> CONSTANTLY (!!!) interprets things differently and they can come up with
> the strangest things (flying with my door off, etc) and you have to go
> to the ends of the Earth to get them to see things a little bit
> differently.
>
> Just saying. I think being polite but not cowardly is the best
> approach... my 2 cents.
>
> Mark
>
>
> -----Original Message-----
> From: owner-yak-list-server@matronics.com
> [mailto:owner-yak-list-server@matronics.com] On Behalf Of A. Dennis
> Savarese
> Sent: Tuesday, May 24, 2011 10:47 PM
> To: yak-list@matronics.com
> Subject: Re: Yak-List: Re: Program Letter
>
> --> Yak-List message posted by: "A. Dennis Savarese"
> <dsavarese0812@bellsouth.net>
>
> Here's something to think about.
> The program letter and modifications which you may send by fax are in
> fact part of the Operating Limitations for the airplane. We all know
> you are required to carry the OL's in the airplane at all times. Since
> the Program Letter is actually a part of the OL's, then IMHO, it is also
>
> required to be carried in the airplane.
>
> Unfortunately, when the FAA removed the 300/600 NM proficiency area,
> they failed to include the elimination of the Program Letter, which
> would have made logical sense. ie: if you don't have any restrictions
> as to where you can fly, they why do you need a Program Letter to attend
>
> an event?
>
> When you attend an event that may also be attended by the FAA (typically
>
> when there is wavered airspace) and they ask to see your aircraft's
> paperwork as well as you pilot certificate and current medical form,
> when you hand him/her the aircraft's Operating Limitations he/she will
> also ask to see your Program Letter or modification for this specific
> event. If you do not have your Program Letter with the specific event
> on it or a modification/update to the program letter which you submitted
>
> to your FSDO with you, the FAA person may not permit you to stay at the
> event. I had this happen to me about 5 years ago. Thus, when I sent
> my program letter in to the FSDO each year, I automatically put a copy
> in the airplane along with any modifications.
> Dennis
>
> On 5/24/2011 9:00 PM, keithmckinley wrote:
>> --> Yak-List message posted by:
> "keithmckinley"<keith.mckinley@townisp.com>
>> Mark,
>>
>> Thanks for the feedback.
>>
>> No 300 mile restriction. No doubt it is easier to play nice with the
> Fed's and yes it does pay dividends, but sometimes I think it's
> important to make sure they interpret things correctly and realize (as
> inspectors) they don't make the rules. More than anything, I just have
> an aversion to ass kissing.......but not to protecting my own ass!
>> Semper Fi
>>
>> Keith
>>
>> --------
>> Keith McKinley
>> 700HS
>> KFIT
>>
>>
>>
>>
>> Read this topic online here:
>>
>> http://forums.matronics.com/viewtopic.php?p=340874#340874
>>
>>
>>
>>
>>
>>
>>
>>
>>
>>
>>
>
>
Message 7
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| Subject: | Re: Program Letter |
This is new. Very new. It also seems to have changed what was written
before and specifically says what you are saying is true Dennis.
I think this should be run before the EAA for their comments. You or me
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: Wednesday, May 25, 2011 10:04 AM
Subject: Re: Yak-List: Re: Program Letter
<dsavarese0812@bellsouth.net>
For those that want to see the latest and greatest version of the FAA
Order 8130.2x, on April 16, 2011 the FAA 8130.2G became effective. The
Yak 52 and CJ6 now fall into a new grouping method they have
established; Group 2. Within the groups is a matrix chart that
established what Operating Limitation must be included in the OL's for a
aircraft in that group.
Unfortunately, guess what remains.....the infamous Program Letter
requirement. Here are the exact words from the FAA Order which answers
the question whether the Program Letter and any amendments must be
carried in the airplane.
"....(3) The owner operator must submit an annual program letter to the
geographically
responsible FSDO where the aircraft is based. All operations must be
conducted in accordance
with these limitations and the program letter. A copy of the current
program letter and any
amendments must be carried on board the aircraft any time that the
aircraft is being operated.
The program letter must include the following information:
(a) The aircraft's home base.
(b) The name of the person responsible for the operation and maintenance
of the
aircraft.
(c) A list of events at which the aircraft will be exhibited (the list
may be amended
as necessary).
(d) For Group 6 and Group 7 aircraft, the proficiency area. The
proficiency area
may be depicted using a map or it may be described by geographic
landmarks, airports, or aids to
navigation.
(4) The pilot in command of this aircraft must hold an appropriate
category and class
rating.
Hope this helps.
Dennis
On 5/25/2011 8:50 AM, Bitterlich, Mark G CIV Det Cherry Point, MALS-14
64E wrote:
> --> Yak-List message posted by: "Bitterlich, Mark G CIV Det Cherry
Point, MALS-14 64E"<mark.bitterlich@navy.mil>
>
> Concur ABSOLUTELY
>
> Mark
>
>
> -----Original Message-----
> From: owner-yak-list-server@matronics.com
> [mailto:owner-yak-list-server@matronics.com] On Behalf Of
keithmckinley
> Sent: Tuesday, May 24, 2011 10:00 PM
> To: yak-list@matronics.com
> Subject: Yak-List: Re: Program Letter
>
> --> Yak-List message posted by: "keithmckinley"
> <keith.mckinley@townisp.com>
>
> Mark,
>
> Thanks for the feedback.
>
> No 300 mile restriction. No doubt it is easier to play nice with the
> Fed's and yes it does pay dividends, but sometimes I think it's
> important to make sure they interpret things correctly and realize
(as
> inspectors) they don't make the rules. More than anything, I just have
> an aversion to ass kissing.......but not to protecting my own ass!
>
> Semper Fi
>
> Keith
>
> --------
> Keith McKinley
> 700HS
> KFIT
>
>
> Read this topic online here:
>
> http://forums.matronics.com/viewtopic.php?p=340874#340874
>
>
Message 8
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|
| Subject: | Re: Program Letter |
Just did :-)
-----Original Message-----
From: owner-yak-list-server@matronics.com
[mailto:owner-yak-list-server@matronics.com] On Behalf Of A. Dennis
Savarese
Sent: Wednesday, May 25, 2011 10:15 AM
Subject: Re: Yak-List: Re: Program Letter
<dsavarese0812@bellsouth.net>
Mark, I respectfully request you read my next posting on the subject.
:-)
On 5/25/2011 9:04 AM, Bitterlich, Mark G CIV Det Cherry Point, MALS-14
64E wrote:
> --> Yak-List message posted by: "Bitterlich, Mark G CIV Det Cherry
Point, MALS-14 64E"<mark.bitterlich@navy.mil>
>
> Dennis, I respectfully disagree with your point of view in this one
> area.
>
> You mentioned:
>
> "The program letter and modifications which you may send by fax are in
> fact part of the Operating Limitations for the airplane. We all know
> you are required to carry the OL's in the airplane at all times.
Since
> the Program Letter is actually a part of the OL's, then IMHO, it is
also
>
> required to be carried in the airplane."
>
> The Operating Limitations also require a Conditional Inspection every
> year. By the same logic, you would also need to carry along a copy of
> your Conditional Inspection, or copies of your aircraft logbooks, etc.
> My opinion on dealing with the FAA on things like this is when they
say:
>
>
> "We need to see a copy of your Program Letter or modification of same,
> and if you don't have it with you, you must leave."
>
> NUMBER ONE: !!! Reply with: "Please quote the Regulation that
> specifically states I must carry a copy of my Program Letter with me.
> If you cannot quote me the exact regulation that requires me to do
this,
> I respectfully submit you have no authority to demand it from me".
>
> You must carry a copy of your Operating Limitations. READ THEM!
Break
> them out and have the FAA Inspector SHOW YOU on the Operating
> Limitations where it says what he is saying. THE BURDON OF PROOF IS
ON
> THE FAA, not on your to prove you are innocent. Sometimes certain FAA
> Inspectors forget that fact. Some Inspectors also assume that
anything
> they say is automatically correct. Anything you say is automatically
> wrong. You need to know your regulations and you also need the phone
> number to the EAA's Govt. Hotline. Ask for Randy Hanson.
>
> NUMBER TWO: If they still play nasty.... Go back to the motel, do a
> handwritten modification to your Program Letter on a paper napkin, go
> down to the Hotel Desk and FAX IT to your local FISDO. The go back to
> the airport and hand that FAA Inspector the paper napkin and bit him a
> fond farewell. I am not being sarcastic here. OK. The paper napkin
> part is supposed to be a joke (OK who-ever from the FAA READS THIS? A
> JOKE! PLEASE? Good grief).
>
> Not that I think you're wrong about carrying the stuff along. The FAA
> CONSTANTLY (!!!) interprets things differently and they can come up
with
> the strangest things (flying with my door off, etc) and you have to go
> to the ends of the Earth to get them to see things a little bit
> differently.
>
> Just saying. I think being polite but not cowardly is the best
> approach... my 2 cents.
>
> Mark
>
>
> -----Original Message-----
> From: owner-yak-list-server@matronics.com
> [mailto:owner-yak-list-server@matronics.com] On Behalf Of A. Dennis
> Savarese
> Sent: Tuesday, May 24, 2011 10:47 PM
> To: yak-list@matronics.com
> Subject: Re: Yak-List: Re: Program Letter
>
> --> Yak-List message posted by: "A. Dennis Savarese"
> <dsavarese0812@bellsouth.net>
>
> Here's something to think about.
> The program letter and modifications which you may send by fax are in
> fact part of the Operating Limitations for the airplane. We all know
> you are required to carry the OL's in the airplane at all times.
Since
> the Program Letter is actually a part of the OL's, then IMHO, it is
also
>
> required to be carried in the airplane.
>
> Unfortunately, when the FAA removed the 300/600 NM proficiency area,
> they failed to include the elimination of the Program Letter, which
> would have made logical sense. ie: if you don't have any restrictions
> as to where you can fly, they why do you need a Program Letter to
attend
>
> an event?
>
> When you attend an event that may also be attended by the FAA
(typically
>
> when there is wavered airspace) and they ask to see your aircraft's
> paperwork as well as you pilot certificate and current medical form,
> when you hand him/her the aircraft's Operating Limitations he/she will
> also ask to see your Program Letter or modification for this specific
> event. If you do not have your Program Letter with the specific event
> on it or a modification/update to the program letter which you
submitted
>
> to your FSDO with you, the FAA person may not permit you to stay at
the
> event. I had this happen to me about 5 years ago. Thus, when I sent
> my program letter in to the FSDO each year, I automatically put a copy
> in the airplane along with any modifications.
> Dennis
>
> On 5/24/2011 9:00 PM, keithmckinley wrote:
>> --> Yak-List message posted by:
> "keithmckinley"<keith.mckinley@townisp.com>
>> Mark,
>>
>> Thanks for the feedback.
>>
>> No 300 mile restriction. No doubt it is easier to play nice with the
> Fed's and yes it does pay dividends, but sometimes I think it's
> important to make sure they interpret things correctly and realize
(as
> inspectors) they don't make the rules. More than anything, I just have
> an aversion to ass kissing.......but not to protecting my own ass!
>> Semper Fi
>>
>> Keith
>>
>> --------
>> Keith McKinley
>> 700HS
>> KFIT
>>
>>
>>
>>
>> Read this topic online here:
>>
>> http://forums.matronics.com/viewtopic.php?p=340874#340874
>>
>>
>>
>>
>>
>>
>>
>>
>>
>>
>>
>
>
Message 9
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| Subject: | Re: Program Letter |
I think it is quite clear. The Program Letter must be carried in the
airplane at all times.
Dennis
On 5/25/2011 9:22 AM, Bitterlich, Mark G CIV Det Cherry Point, MALS-14
64E wrote:
> --> Yak-List message posted by: "Bitterlich, Mark G CIV Det Cherry Point, MALS-14
64E"<mark.bitterlich@navy.mil>
>
> This is new. Very new. It also seems to have changed what was written
> before and specifically says what you are saying is true Dennis.
>
> I think this should be run before the EAA for their comments. You or me
> 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: Wednesday, May 25, 2011 10:04 AM
> To: yak-list@matronics.com
> Subject: Re: Yak-List: Re: Program Letter
>
> --> Yak-List message posted by: "A. Dennis Savarese"
> <dsavarese0812@bellsouth.net>
>
> For those that want to see the latest and greatest version of the FAA
> Order 8130.2x, on April 16, 2011 the FAA 8130.2G became effective. The
> Yak 52 and CJ6 now fall into a new grouping method they have
> established; Group 2. Within the groups is a matrix chart that
> established what Operating Limitation must be included in the OL's for a
>
> aircraft in that group.
>
> Unfortunately, guess what remains.....the infamous Program Letter
> requirement. Here are the exact words from the FAA Order which answers
> the question whether the Program Letter and any amendments must be
> carried in the airplane.
>
> "....(3) The owner operator must submit an annual program letter to the
> geographically
> responsible FSDO where the aircraft is based. All operations must be
> conducted in accordance
> with these limitations and the program letter. A copy of the current
> program letter and any
> amendments must be carried on board the aircraft any time that the
> aircraft is being operated.
> The program letter must include the following information:
> (a) The aircraft's home base.
> (b) The name of the person responsible for the operation and maintenance
>
> of the
> aircraft.
> (c) A list of events at which the aircraft will be exhibited (the list
> may be amended
> as necessary).
> (d) For Group 6 and Group 7 aircraft, the proficiency area. The
> proficiency area
> may be depicted using a map or it may be described by geographic
> landmarks, airports, or aids to
> navigation.
> (4) The pilot in command of this aircraft must hold an appropriate
> category and class
> rating.
>
> Hope this helps.
> Dennis
>
> On 5/25/2011 8:50 AM, Bitterlich, Mark G CIV Det Cherry Point, MALS-14
> 64E wrote:
>> --> Yak-List message posted by: "Bitterlich, Mark G CIV Det Cherry
> Point, MALS-14 64E"<mark.bitterlich@navy.mil>
>> Concur ABSOLUTELY
>>
>> Mark
>>
>>
>> -----Original Message-----
>> From: owner-yak-list-server@matronics.com
>> [mailto:owner-yak-list-server@matronics.com] On Behalf Of
> keithmckinley
>> Sent: Tuesday, May 24, 2011 10:00 PM
>> To: yak-list@matronics.com
>> Subject: Yak-List: Re: Program Letter
>>
>> --> Yak-List message posted by: "keithmckinley"
>> <keith.mckinley@townisp.com>
>>
>> Mark,
>>
>> Thanks for the feedback.
>>
>> No 300 mile restriction. No doubt it is easier to play nice with the
>> Fed's and yes it does pay dividends, but sometimes I think it's
>> important to make sure they interpret things correctly and realize
> (as
>> inspectors) they don't make the rules. More than anything, I just have
>> an aversion to ass kissing.......but not to protecting my own ass!
>>
>> Semper Fi
>>
>> Keith
>>
>> --------
>> Keith McKinley
>> 700HS
>> KFIT
>>
>>
>>
>>
>> Read this topic online here:
>>
>> http://forums.matronics.com/viewtopic.php?p=340874#340874
>>
>>
>>
>>
>>
>>
>>
>>
>>
>>
>>
>>
>>
>>
>>
>>
>
>
Message 10
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|
| Subject: | Re: Program Letter |
For those that are operating under the older 8130.2F, here is a
paragraph that is included in all of the groups, including ours, Group
III. Just for grins, see if there is a paragraph in your own OL's that
says something like the following".
"....(2) No person may operate this aircraft for other than the purpose
of meeting the requirements
of 91.319(b), as stated in the program letter (required by 21.193)
for this aircraft. This aircraft must
be operated in accordance with applicable air traffic and general
operating rules of part 91, as well as all
additional limitations herein prescribed under the provisions of
91.319(e). These operating limitations
are a part of the special airworthiness certificate, and are to be
carried in the aircraft at all times
and made available to the pilot in command of the aircraft.
(Applicability: All)
Dennis
On 5/25/2011 9:26 AM, Bitterlich, Mark G CIV Det Cherry Point, MALS-14
64E wrote:
> --> Yak-List message posted by: "Bitterlich, Mark G CIV Det Cherry Point, MALS-14
64E"<mark.bitterlich@navy.mil>
>
> Just did :-)
>
> -----Original Message-----
> From: owner-yak-list-server@matronics.com
> [mailto:owner-yak-list-server@matronics.com] On Behalf Of A. Dennis
> Savarese
> Sent: Wednesday, May 25, 2011 10:15 AM
> To: yak-list@matronics.com
> Subject: Re: Yak-List: Re: Program Letter
>
> --> Yak-List message posted by: "A. Dennis Savarese"
> <dsavarese0812@bellsouth.net>
>
> Mark, I respectfully request you read my next posting on the subject.
> :-)
>
> On 5/25/2011 9:04 AM, Bitterlich, Mark G CIV Det Cherry Point, MALS-14
> 64E wrote:
>> --> Yak-List message posted by: "Bitterlich, Mark G CIV Det Cherry
> Point, MALS-14 64E"<mark.bitterlich@navy.mil>
>> Dennis, I respectfully disagree with your point of view in this one
>> area.
>>
>> You mentioned:
>>
>> "The program letter and modifications which you may send by fax are in
>> fact part of the Operating Limitations for the airplane. We all know
>> you are required to carry the OL's in the airplane at all times.
> Since
>> the Program Letter is actually a part of the OL's, then IMHO, it is
> also
>> required to be carried in the airplane."
>>
>> The Operating Limitations also require a Conditional Inspection every
>> year. By the same logic, you would also need to carry along a copy of
>> your Conditional Inspection, or copies of your aircraft logbooks, etc.
>> My opinion on dealing with the FAA on things like this is when they
> say:
>>
>> "We need to see a copy of your Program Letter or modification of same,
>> and if you don't have it with you, you must leave."
>>
>> NUMBER ONE: !!! Reply with: "Please quote the Regulation that
>> specifically states I must carry a copy of my Program Letter with me.
>> If you cannot quote me the exact regulation that requires me to do
> this,
>> I respectfully submit you have no authority to demand it from me".
>>
>> You must carry a copy of your Operating Limitations. READ THEM!
> Break
>> them out and have the FAA Inspector SHOW YOU on the Operating
>> Limitations where it says what he is saying. THE BURDON OF PROOF IS
> ON
>> THE FAA, not on your to prove you are innocent. Sometimes certain FAA
>> Inspectors forget that fact. Some Inspectors also assume that
> anything
>> they say is automatically correct. Anything you say is automatically
>> wrong. You need to know your regulations and you also need the phone
>> number to the EAA's Govt. Hotline. Ask for Randy Hanson.
>>
>> NUMBER TWO: If they still play nasty.... Go back to the motel, do a
>> handwritten modification to your Program Letter on a paper napkin, go
>> down to the Hotel Desk and FAX IT to your local FISDO. The go back to
>> the airport and hand that FAA Inspector the paper napkin and bit him a
>> fond farewell. I am not being sarcastic here. OK. The paper napkin
>> part is supposed to be a joke (OK who-ever from the FAA READS THIS? A
>> JOKE! PLEASE? Good grief).
>>
>> Not that I think you're wrong about carrying the stuff along. The FAA
>> CONSTANTLY (!!!) interprets things differently and they can come up
> with
>> the strangest things (flying with my door off, etc) and you have to go
>> to the ends of the Earth to get them to see things a little bit
>> differently.
>>
>> Just saying. I think being polite but not cowardly is the best
>> approach... my 2 cents.
>>
>> Mark
>>
>>
>>
>>
>> -----Original Message-----
>> From: owner-yak-list-server@matronics.com
>> [mailto:owner-yak-list-server@matronics.com] On Behalf Of A. Dennis
>> Savarese
>> Sent: Tuesday, May 24, 2011 10:47 PM
>> To: yak-list@matronics.com
>> Subject: Re: Yak-List: Re: Program Letter
>>
>> --> Yak-List message posted by: "A. Dennis Savarese"
>> <dsavarese0812@bellsouth.net>
>>
>> Here's something to think about.
>> The program letter and modifications which you may send by fax are in
>> fact part of the Operating Limitations for the airplane. We all know
>> you are required to carry the OL's in the airplane at all times.
> Since
>> the Program Letter is actually a part of the OL's, then IMHO, it is
> also
>> required to be carried in the airplane.
>>
>> Unfortunately, when the FAA removed the 300/600 NM proficiency area,
>> they failed to include the elimination of the Program Letter, which
>> would have made logical sense. ie: if you don't have any restrictions
>> as to where you can fly, they why do you need a Program Letter to
> attend
>> an event?
>>
>> When you attend an event that may also be attended by the FAA
> (typically
>> when there is wavered airspace) and they ask to see your aircraft's
>> paperwork as well as you pilot certificate and current medical form,
>> when you hand him/her the aircraft's Operating Limitations he/she will
>> also ask to see your Program Letter or modification for this specific
>> event. If you do not have your Program Letter with the specific event
>> on it or a modification/update to the program letter which you
> submitted
>> to your FSDO with you, the FAA person may not permit you to stay at
> the
>> event. I had this happen to me about 5 years ago. Thus, when I sent
>> my program letter in to the FSDO each year, I automatically put a copy
>> in the airplane along with any modifications.
>> Dennis
>>
>> On 5/24/2011 9:00 PM, keithmckinley wrote:
>>> --> Yak-List message posted by:
>> "keithmckinley"<keith.mckinley@townisp.com>
>>> Mark,
>>>
>>> Thanks for the feedback.
>>>
>>> No 300 mile restriction. No doubt it is easier to play nice with the
>> Fed's and yes it does pay dividends, but sometimes I think it's
>> important to make sure they interpret things correctly and realize
> (as
>> inspectors) they don't make the rules. More than anything, I just have
>> an aversion to ass kissing.......but not to protecting my own ass!
>>> Semper Fi
>>>
>>> Keith
>>>
>>> --------
>>> Keith McKinley
>>> 700HS
>>> KFIT
>>>
>>>
>>>
>>>
>>> Read this topic online here:
>>>
>>> http://forums.matronics.com/viewtopic.php?p=340874#340874
>>>
>>>
>>>
>>>
>>>
>>>
>>>
>>>
>>>
>>>
>>>
>>
>>
>>
>>
>>
>>
>>
>>
>
>
Message 11
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|
| Subject: | Re: Program Letter |
Any new Special Airworthiness Certificates and Operating Limitations
will be issued under 8130.2G. This includes any request for the change
to eliminate the 300/600 mile proficiency area that may currently be in
your existing OL's.
Dennis
On 5/25/2011 9:48 AM, A. Dennis Savarese wrote:
> <dsavarese0812@bellsouth.net>
>
> For those that are operating under the older 8130.2F, here is a
> paragraph that is included in all of the groups, including ours, Group
> III. Just for grins, see if there is a paragraph in your own OL's
> that says something like the following".
>
> "....(2) No person may operate this aircraft for other than the
> purpose of meeting the requirements
> of 91.319(b), as stated in the program letter (required by 21.193)
> for this aircraft. This aircraft must
> be operated in accordance with applicable air traffic and general
> operating rules of part 91, as well as all
> additional limitations herein prescribed under the provisions of
> 91.319(e). These operating limitations
> are a part of the special airworthiness certificate, and are to be
> carried in the aircraft at all times
> and made available to the pilot in command of the aircraft.
> (Applicability: All)
> Dennis
>
>
> On 5/25/2011 9:26 AM, Bitterlich, Mark G CIV Det Cherry Point, MALS-14
> 64E wrote:
>> --> Yak-List message posted by: "Bitterlich, Mark G CIV Det Cherry
>> Point, MALS-14 64E"<mark.bitterlich@navy.mil>
>>
>> Just did :-)
>>
>> -----Original Message-----
>> From: owner-yak-list-server@matronics.com
>> [mailto:owner-yak-list-server@matronics.com] On Behalf Of A. Dennis
>> Savarese
>> Sent: Wednesday, May 25, 2011 10:15 AM
>> To: yak-list@matronics.com
>> Subject: Re: Yak-List: Re: Program Letter
>>
>> --> Yak-List message posted by: "A. Dennis Savarese"
>> <dsavarese0812@bellsouth.net>
>>
>> Mark, I respectfully request you read my next posting on the subject.
>> :-)
>>
>> On 5/25/2011 9:04 AM, Bitterlich, Mark G CIV Det Cherry Point, MALS-14
>> 64E wrote:
>>> --> Yak-List message posted by: "Bitterlich, Mark G CIV Det Cherry
>> Point, MALS-14 64E"<mark.bitterlich@navy.mil>
>>> Dennis, I respectfully disagree with your point of view in this one
>>> area.
>>>
>>> You mentioned:
>>>
>>> "The program letter and modifications which you may send by fax are in
>>> fact part of the Operating Limitations for the airplane. We all know
>>> you are required to carry the OL's in the airplane at all times.
>> Since
>>> the Program Letter is actually a part of the OL's, then IMHO, it is
>> also
>>> required to be carried in the airplane."
>>>
>>> The Operating Limitations also require a Conditional Inspection every
>>> year. By the same logic, you would also need to carry along a copy of
>>> your Conditional Inspection, or copies of your aircraft logbooks, etc.
>>> My opinion on dealing with the FAA on things like this is when they
>> say:
>>>
>>> "We need to see a copy of your Program Letter or modification of same,
>>> and if you don't have it with you, you must leave."
>>>
>>> NUMBER ONE: !!! Reply with: "Please quote the Regulation that
>>> specifically states I must carry a copy of my Program Letter with me.
>>> If you cannot quote me the exact regulation that requires me to do
>> this,
>>> I respectfully submit you have no authority to demand it from me".
>>>
>>> You must carry a copy of your Operating Limitations. READ THEM!
>> Break
>>> them out and have the FAA Inspector SHOW YOU on the Operating
>>> Limitations where it says what he is saying. THE BURDON OF PROOF IS
>> ON
>>> THE FAA, not on your to prove you are innocent. Sometimes certain FAA
>>> Inspectors forget that fact. Some Inspectors also assume that
>> anything
>>> they say is automatically correct. Anything you say is automatically
>>> wrong. You need to know your regulations and you also need the phone
>>> number to the EAA's Govt. Hotline. Ask for Randy Hanson.
>>>
>>> NUMBER TWO: If they still play nasty.... Go back to the motel, do a
>>> handwritten modification to your Program Letter on a paper napkin, go
>>> down to the Hotel Desk and FAX IT to your local FISDO. The go back to
>>> the airport and hand that FAA Inspector the paper napkin and bit him a
>>> fond farewell. I am not being sarcastic here. OK. The paper napkin
>>> part is supposed to be a joke (OK who-ever from the FAA READS THIS? A
>>> JOKE! PLEASE? Good grief).
>>>
>>> Not that I think you're wrong about carrying the stuff along. The FAA
>>> CONSTANTLY (!!!) interprets things differently and they can come up
>> with
>>> the strangest things (flying with my door off, etc) and you have to go
>>> to the ends of the Earth to get them to see things a little bit
>>> differently.
>>>
>>> Just saying. I think being polite but not cowardly is the best
>>> approach... my 2 cents.
>>>
>>> Mark
>>>
>>>
>>>
>>>
>>> -----Original Message-----
>>> From: owner-yak-list-server@matronics.com
>>> [mailto:owner-yak-list-server@matronics.com] On Behalf Of A. Dennis
>>> Savarese
>>> Sent: Tuesday, May 24, 2011 10:47 PM
>>> To: yak-list@matronics.com
>>> Subject: Re: Yak-List: Re: Program Letter
>>>
>>> --> Yak-List message posted by: "A. Dennis Savarese"
>>> <dsavarese0812@bellsouth.net>
>>>
>>> Here's something to think about.
>>> The program letter and modifications which you may send by fax are in
>>> fact part of the Operating Limitations for the airplane. We all know
>>> you are required to carry the OL's in the airplane at all times.
>> Since
>>> the Program Letter is actually a part of the OL's, then IMHO, it is
>> also
>>> required to be carried in the airplane.
>>>
>>> Unfortunately, when the FAA removed the 300/600 NM proficiency area,
>>> they failed to include the elimination of the Program Letter, which
>>> would have made logical sense. ie: if you don't have any restrictions
>>> as to where you can fly, they why do you need a Program Letter to
>> attend
>>> an event?
>>>
>>> When you attend an event that may also be attended by the FAA
>> (typically
>>> when there is wavered airspace) and they ask to see your aircraft's
>>> paperwork as well as you pilot certificate and current medical form,
>>> when you hand him/her the aircraft's Operating Limitations he/she will
>>> also ask to see your Program Letter or modification for this specific
>>> event. If you do not have your Program Letter with the specific event
>>> on it or a modification/update to the program letter which you
>> submitted
>>> to your FSDO with you, the FAA person may not permit you to stay at
>> the
>>> event. I had this happen to me about 5 years ago. Thus, when I sent
>>> my program letter in to the FSDO each year, I automatically put a copy
>>> in the airplane along with any modifications.
>>> Dennis
>>>
>>> On 5/24/2011 9:00 PM, keithmckinley wrote:
>>>> --> Yak-List message posted by:
>>> "keithmckinley"<keith.mckinley@townisp.com>
>>>> Mark,
>>>>
>>>> Thanks for the feedback.
>>>>
>>>> No 300 mile restriction. No doubt it is easier to play nice with the
>>> Fed's and yes it does pay dividends, but sometimes I think it's
>>> important to make sure they interpret things correctly and realize
>> (as
>>> inspectors) they don't make the rules. More than anything, I just have
>>> an aversion to ass kissing.......but not to protecting my own ass!
>>>> Semper Fi
>>>>
>>>> Keith
>>>>
>>>> --------
>>>> Keith McKinley
>>>> 700HS
>>>> KFIT
>>>>
>>>>
>>>>
>>>>
>>>> Read this topic online here:
>>>>
>>>> http://forums.matronics.com/viewtopic.php?p=340874#340874
>>>>
>>>>
>>>>
>>>>
>>>>
>>>>
>>>>
>>>>
>>>>
>>>>
>>>>
>>>
>>>
>>>
>>>
>>>
>>>
>>>
>>>
>>
>>
>>
>>
>>
>>
>>
>>
>>
>
>
Message 12
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|
| Subject: | Re: Program Letter |
Yes, but that does not say you have to carry your Program Letter Dennis. It says
you have to carry your OPERATING LIMITATIONS in the aircraft.
Just FYI, under the OLD rules .... I contacted the EAA and the local FAA, the Montana
FAA, the Seattle FAA and all of them said you did NOT have to carry your
program letter with you. I am sure you were told that you did have to.
It falls into the "whatever you feel is right category" and it also fell into "who
interprets the rules" category.
On the other hand, the new rules you just posted are a whole different thing.
I read them, they seem quite clear! That said, I never EVER take what ANYONE
says on the Yak List regarding rules and regulations as gospel. Even when I read
things myself! I always ask for second opinions, third opinions, and even
FORTH opinions! I always dig very deeply when it comes to rules.
I sent your quote to the EAA Government Division (Randy Hanson) for confirmation
or interpretation. As I said, what you posted seems very clear and is a definite
change in policy and adds a new requirement to all of us. But I'll still
be interested in what the EAA says.
Mark
-----Original Message-----
From: owner-yak-list-server@matronics.com [mailto:owner-yak-list-server@matronics.com] On Behalf Of A. Dennis Savarese
Sent: Wednesday, May 25, 2011 10:49 AM
Subject: Re: Yak-List: Re: Program Letter
For those that are operating under the older 8130.2F, here is a
paragraph that is included in all of the groups, including ours, Group
III. Just for grins, see if there is a paragraph in your own OL's that
says something like the following".
"....(2) No person may operate this aircraft for other than the purpose
of meeting the requirements
of 91.319(b), as stated in the program letter (required by 21.193)
for this aircraft. This aircraft must
be operated in accordance with applicable air traffic and general
operating rules of part 91, as well as all
additional limitations herein prescribed under the provisions of
91.319(e). These operating limitations
are a part of the special airworthiness certificate, and are to be
carried in the aircraft at all times
and made available to the pilot in command of the aircraft.
(Applicability: All)
Dennis
On 5/25/2011 9:26 AM, Bitterlich, Mark G CIV Det Cherry Point, MALS-14
64E wrote:
> --> Yak-List message posted by: "Bitterlich, Mark G CIV Det Cherry Point, MALS-14
64E"<mark.bitterlich@navy.mil>
>
> Just did :-)
>
> -----Original Message-----
> From: owner-yak-list-server@matronics.com
> [mailto:owner-yak-list-server@matronics.com] On Behalf Of A. Dennis
> Savarese
> Sent: Wednesday, May 25, 2011 10:15 AM
> To: yak-list@matronics.com
> Subject: Re: Yak-List: Re: Program Letter
>
> --> Yak-List message posted by: "A. Dennis Savarese"
> <dsavarese0812@bellsouth.net>
>
> Mark, I respectfully request you read my next posting on the subject.
> :-)
>
> On 5/25/2011 9:04 AM, Bitterlich, Mark G CIV Det Cherry Point, MALS-14
> 64E wrote:
>> --> Yak-List message posted by: "Bitterlich, Mark G CIV Det Cherry
> Point, MALS-14 64E"<mark.bitterlich@navy.mil>
>> Dennis, I respectfully disagree with your point of view in this one
>> area.
>>
>> You mentioned:
>>
>> "The program letter and modifications which you may send by fax are in
>> fact part of the Operating Limitations for the airplane. We all know
>> you are required to carry the OL's in the airplane at all times.
> Since
>> the Program Letter is actually a part of the OL's, then IMHO, it is
> also
>> required to be carried in the airplane."
>>
>> The Operating Limitations also require a Conditional Inspection every
>> year. By the same logic, you would also need to carry along a copy of
>> your Conditional Inspection, or copies of your aircraft logbooks, etc.
>> My opinion on dealing with the FAA on things like this is when they
> say:
>>
>> "We need to see a copy of your Program Letter or modification of same,
>> and if you don't have it with you, you must leave."
>>
>> NUMBER ONE: !!! Reply with: "Please quote the Regulation that
>> specifically states I must carry a copy of my Program Letter with me.
>> If you cannot quote me the exact regulation that requires me to do
> this,
>> I respectfully submit you have no authority to demand it from me".
>>
>> You must carry a copy of your Operating Limitations. READ THEM!
> Break
>> them out and have the FAA Inspector SHOW YOU on the Operating
>> Limitations where it says what he is saying. THE BURDON OF PROOF IS
> ON
>> THE FAA, not on your to prove you are innocent. Sometimes certain FAA
>> Inspectors forget that fact. Some Inspectors also assume that
> anything
>> they say is automatically correct. Anything you say is automatically
>> wrong. You need to know your regulations and you also need the phone
>> number to the EAA's Govt. Hotline. Ask for Randy Hanson.
>>
>> NUMBER TWO: If they still play nasty.... Go back to the motel, do a
>> handwritten modification to your Program Letter on a paper napkin, go
>> down to the Hotel Desk and FAX IT to your local FISDO. The go back to
>> the airport and hand that FAA Inspector the paper napkin and bit him a
>> fond farewell. I am not being sarcastic here. OK. The paper napkin
>> part is supposed to be a joke (OK who-ever from the FAA READS THIS? A
>> JOKE! PLEASE? Good grief).
>>
>> Not that I think you're wrong about carrying the stuff along. The FAA
>> CONSTANTLY (!!!) interprets things differently and they can come up
> with
>> the strangest things (flying with my door off, etc) and you have to go
>> to the ends of the Earth to get them to see things a little bit
>> differently.
>>
>> Just saying. I think being polite but not cowardly is the best
>> approach... my 2 cents.
>>
>> Mark
>>
>>
>>
>>
>> -----Original Message-----
>> From: owner-yak-list-server@matronics.com
>> [mailto:owner-yak-list-server@matronics.com] On Behalf Of A. Dennis
>> Savarese
>> Sent: Tuesday, May 24, 2011 10:47 PM
>> To: yak-list@matronics.com
>> Subject: Re: Yak-List: Re: Program Letter
>>
>> --> Yak-List message posted by: "A. Dennis Savarese"
>> <dsavarese0812@bellsouth.net>
>>
>> Here's something to think about.
>> The program letter and modifications which you may send by fax are in
>> fact part of the Operating Limitations for the airplane. We all know
>> you are required to carry the OL's in the airplane at all times.
> Since
>> the Program Letter is actually a part of the OL's, then IMHO, it is
> also
>> required to be carried in the airplane.
>>
>> Unfortunately, when the FAA removed the 300/600 NM proficiency area,
>> they failed to include the elimination of the Program Letter, which
>> would have made logical sense. ie: if you don't have any restrictions
>> as to where you can fly, they why do you need a Program Letter to
> attend
>> an event?
>>
>> When you attend an event that may also be attended by the FAA
> (typically
>> when there is wavered airspace) and they ask to see your aircraft's
>> paperwork as well as you pilot certificate and current medical form,
>> when you hand him/her the aircraft's Operating Limitations he/she will
>> also ask to see your Program Letter or modification for this specific
>> event. If you do not have your Program Letter with the specific event
>> on it or a modification/update to the program letter which you
> submitted
>> to your FSDO with you, the FAA person may not permit you to stay at
> the
>> event. I had this happen to me about 5 years ago. Thus, when I sent
>> my program letter in to the FSDO each year, I automatically put a copy
>> in the airplane along with any modifications.
>> Dennis
>>
>> On 5/24/2011 9:00 PM, keithmckinley wrote:
>>> --> Yak-List message posted by:
>> "keithmckinley"<keith.mckinley@townisp.com>
>>> Mark,
>>>
>>> Thanks for the feedback.
>>>
>>> No 300 mile restriction. No doubt it is easier to play nice with the
>> Fed's and yes it does pay dividends, but sometimes I think it's
>> important to make sure they interpret things correctly and realize
> (as
>> inspectors) they don't make the rules. More than anything, I just have
>> an aversion to ass kissing.......but not to protecting my own ass!
>>> Semper Fi
>>>
>>> Keith
>>>
>>> --------
>>> Keith McKinley
>>> 700HS
>>> KFIT
>>>
>>>
>>>
>>>
>>> Read this topic online here:
>>>
>>> http://forums.matronics.com/viewtopic.php?p=340874#340874
>>>
>>>
>>>
>>>
>>>
>>>
>>>
>>>
>>>
>>>
>>>
>>
>>
>>
>>
>>
>>
>>
>>
>
>
Message 13
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|
| Subject: | Re: Program Letter |
So does 8130.2G apply to those of us that were issued Special Airworthiness Certificates
under 8130.2F or not?
Mark
-----Original Message-----
From: owner-yak-list-server@matronics.com [mailto:owner-yak-list-server@matronics.com] On Behalf Of A. Dennis Savarese
Sent: Wednesday, May 25, 2011 11:09 AM
Subject: Re: Yak-List: Re: Program Letter
Any new Special Airworthiness Certificates and Operating Limitations
will be issued under 8130.2G. This includes any request for the change
to eliminate the 300/600 mile proficiency area that may currently be in
your existing OL's.
Dennis
On 5/25/2011 9:48 AM, A. Dennis Savarese wrote:
> <dsavarese0812@bellsouth.net>
>
> For those that are operating under the older 8130.2F, here is a
> paragraph that is included in all of the groups, including ours, Group
> III. Just for grins, see if there is a paragraph in your own OL's
> that says something like the following".
>
> "....(2) No person may operate this aircraft for other than the
> purpose of meeting the requirements
> of 91.319(b), as stated in the program letter (required by 21.193)
> for this aircraft. This aircraft must
> be operated in accordance with applicable air traffic and general
> operating rules of part 91, as well as all
> additional limitations herein prescribed under the provisions of
> 91.319(e). These operating limitations
> are a part of the special airworthiness certificate, and are to be
> carried in the aircraft at all times
> and made available to the pilot in command of the aircraft.
> (Applicability: All)
> Dennis
>
>
> On 5/25/2011 9:26 AM, Bitterlich, Mark G CIV Det Cherry Point, MALS-14
> 64E wrote:
>> --> Yak-List message posted by: "Bitterlich, Mark G CIV Det Cherry
>> Point, MALS-14 64E"<mark.bitterlich@navy.mil>
>>
>> Just did :-)
>>
>> -----Original Message-----
>> From: owner-yak-list-server@matronics.com
>> [mailto:owner-yak-list-server@matronics.com] On Behalf Of A. Dennis
>> Savarese
>> Sent: Wednesday, May 25, 2011 10:15 AM
>> To: yak-list@matronics.com
>> Subject: Re: Yak-List: Re: Program Letter
>>
>> --> Yak-List message posted by: "A. Dennis Savarese"
>> <dsavarese0812@bellsouth.net>
>>
>> Mark, I respectfully request you read my next posting on the subject.
>> :-)
>>
>> On 5/25/2011 9:04 AM, Bitterlich, Mark G CIV Det Cherry Point, MALS-14
>> 64E wrote:
>>> --> Yak-List message posted by: "Bitterlich, Mark G CIV Det Cherry
>> Point, MALS-14 64E"<mark.bitterlich@navy.mil>
>>> Dennis, I respectfully disagree with your point of view in this one
>>> area.
>>>
>>> You mentioned:
>>>
>>> "The program letter and modifications which you may send by fax are in
>>> fact part of the Operating Limitations for the airplane. We all know
>>> you are required to carry the OL's in the airplane at all times.
>> Since
>>> the Program Letter is actually a part of the OL's, then IMHO, it is
>> also
>>> required to be carried in the airplane."
>>>
>>> The Operating Limitations also require a Conditional Inspection every
>>> year. By the same logic, you would also need to carry along a copy of
>>> your Conditional Inspection, or copies of your aircraft logbooks, etc.
>>> My opinion on dealing with the FAA on things like this is when they
>> say:
>>>
>>> "We need to see a copy of your Program Letter or modification of same,
>>> and if you don't have it with you, you must leave."
>>>
>>> NUMBER ONE: !!! Reply with: "Please quote the Regulation that
>>> specifically states I must carry a copy of my Program Letter with me.
>>> If you cannot quote me the exact regulation that requires me to do
>> this,
>>> I respectfully submit you have no authority to demand it from me".
>>>
>>> You must carry a copy of your Operating Limitations. READ THEM!
>> Break
>>> them out and have the FAA Inspector SHOW YOU on the Operating
>>> Limitations where it says what he is saying. THE BURDON OF PROOF IS
>> ON
>>> THE FAA, not on your to prove you are innocent. Sometimes certain FAA
>>> Inspectors forget that fact. Some Inspectors also assume that
>> anything
>>> they say is automatically correct. Anything you say is automatically
>>> wrong. You need to know your regulations and you also need the phone
>>> number to the EAA's Govt. Hotline. Ask for Randy Hanson.
>>>
>>> NUMBER TWO: If they still play nasty.... Go back to the motel, do a
>>> handwritten modification to your Program Letter on a paper napkin, go
>>> down to the Hotel Desk and FAX IT to your local FISDO. The go back to
>>> the airport and hand that FAA Inspector the paper napkin and bit him a
>>> fond farewell. I am not being sarcastic here. OK. The paper napkin
>>> part is supposed to be a joke (OK who-ever from the FAA READS THIS? A
>>> JOKE! PLEASE? Good grief).
>>>
>>> Not that I think you're wrong about carrying the stuff along. The FAA
>>> CONSTANTLY (!!!) interprets things differently and they can come up
>> with
>>> the strangest things (flying with my door off, etc) and you have to go
>>> to the ends of the Earth to get them to see things a little bit
>>> differently.
>>>
>>> Just saying. I think being polite but not cowardly is the best
>>> approach... my 2 cents.
>>>
>>> Mark
>>>
>>>
>>>
>>>
>>> -----Original Message-----
>>> From: owner-yak-list-server@matronics.com
>>> [mailto:owner-yak-list-server@matronics.com] On Behalf Of A. Dennis
>>> Savarese
>>> Sent: Tuesday, May 24, 2011 10:47 PM
>>> To: yak-list@matronics.com
>>> Subject: Re: Yak-List: Re: Program Letter
>>>
>>> --> Yak-List message posted by: "A. Dennis Savarese"
>>> <dsavarese0812@bellsouth.net>
>>>
>>> Here's something to think about.
>>> The program letter and modifications which you may send by fax are in
>>> fact part of the Operating Limitations for the airplane. We all know
>>> you are required to carry the OL's in the airplane at all times.
>> Since
>>> the Program Letter is actually a part of the OL's, then IMHO, it is
>> also
>>> required to be carried in the airplane.
>>>
>>> Unfortunately, when the FAA removed the 300/600 NM proficiency area,
>>> they failed to include the elimination of the Program Letter, which
>>> would have made logical sense. ie: if you don't have any restrictions
>>> as to where you can fly, they why do you need a Program Letter to
>> attend
>>> an event?
>>>
>>> When you attend an event that may also be attended by the FAA
>> (typically
>>> when there is wavered airspace) and they ask to see your aircraft's
>>> paperwork as well as you pilot certificate and current medical form,
>>> when you hand him/her the aircraft's Operating Limitations he/she will
>>> also ask to see your Program Letter or modification for this specific
>>> event. If you do not have your Program Letter with the specific event
>>> on it or a modification/update to the program letter which you
>> submitted
>>> to your FSDO with you, the FAA person may not permit you to stay at
>> the
>>> event. I had this happen to me about 5 years ago. Thus, when I sent
>>> my program letter in to the FSDO each year, I automatically put a copy
>>> in the airplane along with any modifications.
>>> Dennis
>>>
>>> On 5/24/2011 9:00 PM, keithmckinley wrote:
>>>> --> Yak-List message posted by:
>>> "keithmckinley"<keith.mckinley@townisp.com>
>>>> Mark,
>>>>
>>>> Thanks for the feedback.
>>>>
>>>> No 300 mile restriction. No doubt it is easier to play nice with the
>>> Fed's and yes it does pay dividends, but sometimes I think it's
>>> important to make sure they interpret things correctly and realize
>> (as
>>> inspectors) they don't make the rules. More than anything, I just have
>>> an aversion to ass kissing.......but not to protecting my own ass!
>>>> Semper Fi
>>>>
>>>> Keith
>>>>
>>>> --------
>>>> Keith McKinley
>>>> 700HS
>>>> KFIT
>>>>
>>>>
>>>>
>>>>
>>>> Read this topic online here:
>>>>
>>>> http://forums.matronics.com/viewtopic.php?p=340874#340874
>>>>
>>>>
>>>>
>>>>
>>>>
>>>>
>>>>
>>>>
>>>>
>>>>
>>>>
>>>
>>>
>>>
>>>
>>>
>>>
>>>
>>>
>>
>>
>>
>>
>>
>>
>>
>>
>>
>
>
Message 14
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|
| Subject: | Re: Program Letter |
I recently talked to my FSDO about changing my 300 mile limits. He is a
helpful guy and sent me a copy of what the new op limits look like on
someone elses plane. In it, the program letter must list who is responsible
for maintenance for the plane. He also asked me for a printed maintenance
program. I have included a copy. Check paragraph 3.
Jim Griffin
----- Original Message -----
From: "A. Dennis Savarese" <dsavarese0812@bellsouth.net>
Sent: Wednesday, May 25, 2011 10:08 AM
Subject: Re: Yak-List: Re: Program Letter
<dsavarese0812@bellsouth.net>
Any new Special Airworthiness Certificates and Operating Limitations
will be issued under 8130.2G. This includes any request for the change
to eliminate the 300/600 mile proficiency area that may currently be in
your existing OL's.
Dennis
On 5/25/2011 9:48 AM, A. Dennis Savarese wrote:
> <dsavarese0812@bellsouth.net>
>
> For those that are operating under the older 8130.2F, here is a paragraph
> that is included in all of the groups, including ours, Group III. Just
> for grins, see if there is a paragraph in your own OL's that says
> something like the following".
>
> "....(2) No person may operate this aircraft for other than the purpose of
> meeting the requirements
> of 91.319(b), as stated in the program letter (required by 21.193) for
> this aircraft. This aircraft must
> be operated in accordance with applicable air traffic and general
> operating rules of part 91, as well as all
> additional limitations herein prescribed under the provisions of
> 91.319(e). These operating limitations
> are a part of the special airworthiness certificate, and are to be carried
> in the aircraft at all times
> and made available to the pilot in command of the aircraft.
> (Applicability: All)
> Dennis
>
>
> On 5/25/2011 9:26 AM, Bitterlich, Mark G CIV Det Cherry Point, MALS-14 64E
> wrote:
>> --> Yak-List message posted by: "Bitterlich, Mark G CIV Det Cherry
>> Point, MALS-14 64E"<mark.bitterlich@navy.mil>
>>
>> Just did :-)
>>
>> -----Original Message-----
>> From: owner-yak-list-server@matronics.com
>> [mailto:owner-yak-list-server@matronics.com] On Behalf Of A. Dennis
>> Savarese
>> Sent: Wednesday, May 25, 2011 10:15 AM
>> To: yak-list@matronics.com
>> Subject: Re: Yak-List: Re: Program Letter
>>
>> --> Yak-List message posted by: "A. Dennis Savarese"
>> <dsavarese0812@bellsouth.net>
>>
>> Mark, I respectfully request you read my next posting on the subject.
>> :-)
>>
>> On 5/25/2011 9:04 AM, Bitterlich, Mark G CIV Det Cherry Point, MALS-14
>> 64E wrote:
>>> --> Yak-List message posted by: "Bitterlich, Mark G CIV Det Cherry
>> Point, MALS-14 64E"<mark.bitterlich@navy.mil>
>>> Dennis, I respectfully disagree with your point of view in this one
>>> area.
>>>
>>> You mentioned:
>>>
>>> "The program letter and modifications which you may send by fax are in
>>> fact part of the Operating Limitations for the airplane. We all know
>>> you are required to carry the OL's in the airplane at all times.
>> Since
>>> the Program Letter is actually a part of the OL's, then IMHO, it is
>> also
>>> required to be carried in the airplane."
>>>
>>> The Operating Limitations also require a Conditional Inspection every
>>> year. By the same logic, you would also need to carry along a copy of
>>> your Conditional Inspection, or copies of your aircraft logbooks, etc.
>>> My opinion on dealing with the FAA on things like this is when they
>> say:
>>>
>>> "We need to see a copy of your Program Letter or modification of same,
>>> and if you don't have it with you, you must leave."
>>>
>>> NUMBER ONE: !!! Reply with: "Please quote the Regulation that
>>> specifically states I must carry a copy of my Program Letter with me.
>>> If you cannot quote me the exact regulation that requires me to do
>> this,
>>> I respectfully submit you have no authority to demand it from me".
>>>
>>> You must carry a copy of your Operating Limitations. READ THEM!
>> Break
>>> them out and have the FAA Inspector SHOW YOU on the Operating
>>> Limitations where it says what he is saying. THE BURDON OF PROOF IS
>> ON
>>> THE FAA, not on your to prove you are innocent. Sometimes certain FAA
>>> Inspectors forget that fact. Some Inspectors also assume that
>> anything
>>> they say is automatically correct. Anything you say is automatically
>>> wrong. You need to know your regulations and you also need the phone
>>> number to the EAA's Govt. Hotline. Ask for Randy Hanson.
>>>
>>> NUMBER TWO: If they still play nasty.... Go back to the motel, do a
>>> handwritten modification to your Program Letter on a paper napkin, go
>>> down to the Hotel Desk and FAX IT to your local FISDO. The go back to
>>> the airport and hand that FAA Inspector the paper napkin and bit him a
>>> fond farewell. I am not being sarcastic here. OK. The paper napkin
>>> part is supposed to be a joke (OK who-ever from the FAA READS THIS? A
>>> JOKE! PLEASE? Good grief).
>>>
>>> Not that I think you're wrong about carrying the stuff along. The FAA
>>> CONSTANTLY (!!!) interprets things differently and they can come up
>> with
>>> the strangest things (flying with my door off, etc) and you have to go
>>> to the ends of the Earth to get them to see things a little bit
>>> differently.
>>>
>>> Just saying. I think being polite but not cowardly is the best
>>> approach... my 2 cents.
>>>
>>> Mark
>>>
>>>
>>>
>>>
>>> -----Original Message-----
>>> From: owner-yak-list-server@matronics.com
>>> [mailto:owner-yak-list-server@matronics.com] On Behalf Of A. Dennis
>>> Savarese
>>> Sent: Tuesday, May 24, 2011 10:47 PM
>>> To: yak-list@matronics.com
>>> Subject: Re: Yak-List: Re: Program Letter
>>>
>>> --> Yak-List message posted by: "A. Dennis Savarese"
>>> <dsavarese0812@bellsouth.net>
>>>
>>> Here's something to think about.
>>> The program letter and modifications which you may send by fax are in
>>> fact part of the Operating Limitations for the airplane. We all know
>>> you are required to carry the OL's in the airplane at all times.
>> Since
>>> the Program Letter is actually a part of the OL's, then IMHO, it is
>> also
>>> required to be carried in the airplane.
>>>
>>> Unfortunately, when the FAA removed the 300/600 NM proficiency area,
>>> they failed to include the elimination of the Program Letter, which
>>> would have made logical sense. ie: if you don't have any restrictions
>>> as to where you can fly, they why do you need a Program Letter to
>> attend
>>> an event?
>>>
>>> When you attend an event that may also be attended by the FAA
>> (typically
>>> when there is wavered airspace) and they ask to see your aircraft's
>>> paperwork as well as you pilot certificate and current medical form,
>>> when you hand him/her the aircraft's Operating Limitations he/she will
>>> also ask to see your Program Letter or modification for this specific
>>> event. If you do not have your Program Letter with the specific event
>>> on it or a modification/update to the program letter which you
>> submitted
>>> to your FSDO with you, the FAA person may not permit you to stay at
>> the
>>> event. I had this happen to me about 5 years ago. Thus, when I sent
>>> my program letter in to the FSDO each year, I automatically put a copy
>>> in the airplane along with any modifications.
>>> Dennis
>>>
>>> On 5/24/2011 9:00 PM, keithmckinley wrote:
>>>> --> Yak-List message posted by:
>>> "keithmckinley"<keith.mckinley@townisp.com>
>>>> Mark,
>>>>
>>>> Thanks for the feedback.
>>>>
>>>> No 300 mile restriction. No doubt it is easier to play nice with the
>>> Fed's and yes it does pay dividends, but sometimes I think it's
>>> important to make sure they interpret things correctly and realize
>> (as
>>> inspectors) they don't make the rules. More than anything, I just have
>>> an aversion to ass kissing.......but not to protecting my own ass!
>>>> Semper Fi
>>>>
>>>> Keith
>>>>
>>>> --------
>>>> Keith McKinley
>>>> 700HS
>>>> KFIT
>>>>
>>>>
>>>>
>>>>
>>>> Read this topic online here:
>>>>
>>>> http://forums.matronics.com/viewtopic.php?p=340874#340874
>>>>
>>>>
>>>>
>>>>
>>>>
>>>>
>>>>
>>>>
>>>>
>>>>
>>>>
>>>
>>>
>>>
>>>
>>>
>>>
>>>
>>>
>>
>>
>>
>>
>>
>>
>>
>>
>>
>
>
Message 15
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| LIST | Reply to LIST Regarding this Message |
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|
| Subject: | Re: Program Letter |
Yep. It also was a copy of operating limitations on an aircraft that received
it's Special Airworthiness Certificate after 8130.2G came out.
My Operating Limitations don't say a lot of what is contained in your example.
So, does that mean I need to ask the FAA for a NEW set of operating limitations?
I would not think so, but I am asking for guidance from people who's job it is
to know.
Mark
-----Original Message-----
From: owner-yak-list-server@matronics.com [mailto:owner-yak-list-server@matronics.com] On Behalf Of Jim Griffin
Sent: Wednesday, May 25, 2011 3:36 PM
Subject: Re: Yak-List: Re: Program Letter
I recently talked to my FSDO about changing my 300 mile limits. He is a helpful
guy and sent me a copy of what the new op limits look like on someone elses plane.
In it, the program letter must list who is responsible for maintenance for
the plane. He also asked me for a printed maintenance program. I have included
a copy. Check paragraph 3.
Jim Griffin
----- Original Message -----
From: "A. Dennis Savarese" <dsavarese0812@bellsouth.net>
Sent: Wednesday, May 25, 2011 10:08 AM
Subject: Re: Yak-List: Re: Program Letter
<dsavarese0812@bellsouth.net>
Any new Special Airworthiness Certificates and Operating Limitations will be issued
under 8130.2G. This includes any request for the change to eliminate the
300/600 mile proficiency area that may currently be in your existing OL's.
Dennis
On 5/25/2011 9:48 AM, A. Dennis Savarese wrote:
> <dsavarese0812@bellsouth.net>
>
> For those that are operating under the older 8130.2F, here is a
> paragraph that is included in all of the groups, including ours, Group
> III. Just for grins, see if there is a paragraph in your own OL's
> that says something like the following".
>
> "....(2) No person may operate this aircraft for other than the
> purpose of meeting the requirements of 91.319(b), as stated in the
> program letter (required by 21.193) for this aircraft. This aircraft
> must be operated in accordance with applicable air traffic and general
> operating rules of part 91, as well as all additional limitations
> herein prescribed under the provisions of 91.319(e). These operating
> limitations are a part of the special airworthiness certificate, and
> are to be carried in the aircraft at all times and made available to
> the pilot in command of the aircraft.
> (Applicability: All)
> Dennis
>
>
> On 5/25/2011 9:26 AM, Bitterlich, Mark G CIV Det Cherry Point, MALS-14
> 64E
> wrote:
>> --> Yak-List message posted by: "Bitterlich, Mark G CIV Det Cherry
>> Point, MALS-14 64E"<mark.bitterlich@navy.mil>
>>
>> Just did :-)
>>
>> -----Original Message-----
>> From: owner-yak-list-server@matronics.com
>> [mailto:owner-yak-list-server@matronics.com] On Behalf Of A. Dennis
>> Savarese
>> Sent: Wednesday, May 25, 2011 10:15 AM
>> To: yak-list@matronics.com
>> Subject: Re: Yak-List: Re: Program Letter
>>
>> --> Yak-List message posted by: "A. Dennis Savarese"
>> <dsavarese0812@bellsouth.net>
>>
>> Mark, I respectfully request you read my next posting on the subject.
>> :-)
>>
>> On 5/25/2011 9:04 AM, Bitterlich, Mark G CIV Det Cherry Point,
>> MALS-14 64E wrote:
>>> --> Yak-List message posted by: "Bitterlich, Mark G CIV Det Cherry
>> Point, MALS-14 64E"<mark.bitterlich@navy.mil>
>>> Dennis, I respectfully disagree with your point of view in this one
>>> area.
>>>
>>> You mentioned:
>>>
>>> "The program letter and modifications which you may send by fax are
>>> in fact part of the Operating Limitations for the airplane. We all
>>> know you are required to carry the OL's in the airplane at all times.
>> Since
>>> the Program Letter is actually a part of the OL's, then IMHO, it is
>> also
>>> required to be carried in the airplane."
>>>
>>> The Operating Limitations also require a Conditional Inspection
>>> every year. By the same logic, you would also need to carry along a
>>> copy of your Conditional Inspection, or copies of your aircraft logbooks, etc.
>>> My opinion on dealing with the FAA on things like this is when they
>> say:
>>>
>>> "We need to see a copy of your Program Letter or modification of
>>> same, and if you don't have it with you, you must leave."
>>>
>>> NUMBER ONE: !!! Reply with: "Please quote the Regulation that
>>> specifically states I must carry a copy of my Program Letter with me.
>>> If you cannot quote me the exact regulation that requires me to do
>> this,
>>> I respectfully submit you have no authority to demand it from me".
>>>
>>> You must carry a copy of your Operating Limitations. READ THEM!
>> Break
>>> them out and have the FAA Inspector SHOW YOU on the Operating
>>> Limitations where it says what he is saying. THE BURDON OF PROOF IS
>> ON
>>> THE FAA, not on your to prove you are innocent. Sometimes certain
>>> FAA Inspectors forget that fact. Some Inspectors also assume that
>> anything
>>> they say is automatically correct. Anything you say is
>>> automatically wrong. You need to know your regulations and you also
>>> need the phone number to the EAA's Govt. Hotline. Ask for Randy Hanson.
>>>
>>> NUMBER TWO: If they still play nasty.... Go back to the motel, do a
>>> handwritten modification to your Program Letter on a paper napkin,
>>> go down to the Hotel Desk and FAX IT to your local FISDO. The go
>>> back to the airport and hand that FAA Inspector the paper napkin and
>>> bit him a fond farewell. I am not being sarcastic here. OK. The
>>> paper napkin part is supposed to be a joke (OK who-ever from the FAA
>>> READS THIS? A JOKE! PLEASE? Good grief).
>>>
>>> Not that I think you're wrong about carrying the stuff along. The
>>> FAA CONSTANTLY (!!!) interprets things differently and they can come
>>> up
>> with
>>> the strangest things (flying with my door off, etc) and you have to
>>> go to the ends of the Earth to get them to see things a little bit
>>> differently.
>>>
>>> Just saying. I think being polite but not cowardly is the best
>>> approach... my 2 cents.
>>>
>>> Mark
>>>
>>>
>>>
>>>
>>> -----Original Message-----
>>> From: owner-yak-list-server@matronics.com
>>> [mailto:owner-yak-list-server@matronics.com] On Behalf Of A. Dennis
>>> Savarese
>>> Sent: Tuesday, May 24, 2011 10:47 PM
>>> To: yak-list@matronics.com
>>> Subject: Re: Yak-List: Re: Program Letter
>>>
>>> --> Yak-List message posted by: "A. Dennis Savarese"
>>> <dsavarese0812@bellsouth.net>
>>>
>>> Here's something to think about.
>>> The program letter and modifications which you may send by fax are
>>> in fact part of the Operating Limitations for the airplane. We all
>>> know you are required to carry the OL's in the airplane at all times.
>> Since
>>> the Program Letter is actually a part of the OL's, then IMHO, it is
>> also
>>> required to be carried in the airplane.
>>>
>>> Unfortunately, when the FAA removed the 300/600 NM proficiency area,
>>> they failed to include the elimination of the Program Letter, which
>>> would have made logical sense. ie: if you don't have any
>>> restrictions as to where you can fly, they why do you need a Program
>>> Letter to
>> attend
>>> an event?
>>>
>>> When you attend an event that may also be attended by the FAA
>> (typically
>>> when there is wavered airspace) and they ask to see your aircraft's
>>> paperwork as well as you pilot certificate and current medical form,
>>> when you hand him/her the aircraft's Operating Limitations he/she
>>> will also ask to see your Program Letter or modification for this
>>> specific event. If you do not have your Program Letter with the
>>> specific event on it or a modification/update to the program letter
>>> which you
>> submitted
>>> to your FSDO with you, the FAA person may not permit you to stay at
>> the
>>> event. I had this happen to me about 5 years ago. Thus, when I sent
>>> my program letter in to the FSDO each year, I automatically put a
>>> copy in the airplane along with any modifications.
>>> Dennis
>>>
>>> On 5/24/2011 9:00 PM, keithmckinley wrote:
>>>> --> Yak-List message posted by:
>>> "keithmckinley"<keith.mckinley@townisp.com>
>>>> Mark,
>>>>
>>>> Thanks for the feedback.
>>>>
>>>> No 300 mile restriction. No doubt it is easier to play nice with
>>>> the
>>> Fed's and yes it does pay dividends, but sometimes I think it's
>>> important to make sure they interpret things correctly and realize
>> (as
>>> inspectors) they don't make the rules. More than anything, I just
>>> have an aversion to ass kissing.......but not to protecting my own ass!
>>>> Semper Fi
>>>>
>>>> Keith
>>>>
>>>> --------
>>>> Keith McKinley
>>>> 700HS
>>>> KFIT
>>>>
>>>>
>>>>
>>>>
>>>> Read this topic online here:
>>>>
>>>> http://forums.matronics.com/viewtopic.php?p=340874#340874
>>>>
>>>>
>>>>
>>>>
>>>>
>>>>
>>>>
>>>>
>>>>
>>>>
>>>>
>>>
>>>
>>>
>>>
>>>
>>>
>>>
>>>
>>
>>
>>
>>
>>
>>
>>
>>
>>
>
>
Message 16
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|
| Subject: | Re: Program Letter |
Hmmmm
Hmmmmmmmmmmm. For 56 years I've lived under the CARs FARs under the CAA
&
now FAA. At no time ever have the regs ever been "clear". It was sort
of
a life long fantasy that someday I would "know it all" and be able to
quote to the less experienced around me that "this means that because it
says
so". Alas no such luck. The very science of flight has not change (lift
,
drag, power etc) since the Wrights figured it out, but regs - - - - -.
So
at some point I'll be turning in my medical, than pondering the roots of
grass overhead. And above that will be my younger cohorts pondering - -
-
not the wonder of flight - - - but the inconsistency of the GDMF FARs.
Jim "Pappy" Goolsby
In a message dated 5/25/2011 3:40:47 P.M. Eastern Daylight Time,
jgriffint28@cox.net writes:
I recently talked to my FSDO about changing my 300 mile limits. He is a
helpful guy and sent me a copy of what the new op limits look like on
someone elses plane. In it, the program letter must list who is
responsible
for maintenance for the plane. He also asked me for a printed maintenance
program. I have included a copy. Check paragraph 3.
Jim Griffin
----- Original Message -----
From: "A. Dennis Savarese" <dsavarese0812@bellsouth.net>
Sent: Wednesday, May 25, 2011 10:08 AM
Subject: Re: Yak-List: Re: Program Letter
--> Yak-List message posted by: "A. Dennis Savarese"
<dsavarese0812@bellsouth.net>
Any new Special Airworthiness Certificates and Operating Limitations
will be issued under 8130.2G. This includes any request for the change
to eliminate the 300/600 mile proficiency area that may currently be in
your existing OL's.
Dennis
On 5/25/2011 9:48 AM, A. Dennis Savarese wrote:
> <dsavarese0812@bellsouth.net>
>
> For those that are operating under the older 8130.2F, here is a
paragraph
> that is included in all of the groups, including ours, Group III. Just
> for grins, see if there is a paragraph in your own OL's that says
> something like the following".
>
> "....(2) No person may operate this aircraft for other than the purpose
of
> meeting the requirements
> of =A7 91.319(b), as stated in the program letter (required by =A7 21.1
93)
for
> this aircraft. This aircraft must
> be operated in accordance with applicable air traffic and general
> operating rules of part 91, as well as all
> additional limitations herein prescribed under the provisions of =A7
> 91.319(e). These operating limitations
> are a part of the special airworthiness certificate, and are to be
carried
> in the aircraft at all times
> and made available to the pilot in command of the aircraft.
> (Applicability: All)
> Dennis
>
>
> On 5/25/2011 9:26 AM, Bitterlich, Mark G CIV Det Cherry Point, MALS-14
64E
> wrote:
>> --> Yak-List message posted by: "Bitterlich, Mark G CIV Det Cherry
>> Point, MALS-14 64E"<mark.bitterlich@navy.mil>
>>
>> Just did :-)
>>
>> -----Original Message-----
>> From: owner-yak-list-server@matronics.com
>> [mailto:owner-yak-list-server@matronics.com] On Behalf Of A. Dennis
>> Savarese
>> Sent: Wednesday, May 25, 2011 10:15 AM
>> To: yak-list@matronics.com
>> Subject: Re: Yak-List: Re: Program Letter
>>
>> --> Yak-List message posted by: "A. Dennis Savarese"
>> <dsavarese0812@bellsouth.net>
>>
>> Mark, I respectfully request you read my next posting on the subject.
>> :-)
>>
>> On 5/25/2011 9:04 AM, Bitterlich, Mark G CIV Det Cherry Point, MALS-14
>> 64E wrote:
>>> --> Yak-List message posted by: "Bitterlich, Mark G CIV Det Cherry
>> Point, MALS-14 64E"<mark.bitterlich@navy.mil>
>>> Dennis, I respectfully disagree with your point of view in this one
>>> area.
>>>
>>> You mentioned:
>>>
>>> "The program letter and modifications which you may send by fax are
in
>>> fact part of the Operating Limitations for the airplane. We all know
>>> you are required to carry the OL's in the airplane at all times.
>> Since
>>> the Program Letter is actually a part of the OL's, then IMHO, it is
>> also
>>> required to be carried in the airplane."
>>>
>>> The Operating Limitations also require a Conditional Inspection every
>>> year. By the same logic, you would also need to carry along a copy
of
>>> your Conditional Inspection, or copies of your aircraft logbooks, et
c.
>>> My opinion on dealing with the FAA on things like this is when they
>> say:
>>>
>>> "We need to see a copy of your Program Letter or modification of same
,
>>> and if you don't have it with you, you must leave."
>>>
>>> NUMBER ONE: !!! Reply with: "Please quote the Regulation that
>>> specifically states I must carry a copy of my Program Letter with me.
>>> If you cannot quote me the exact regulation that requires me to do
>> this,
>>> I respectfully submit you have no authority to demand it from me".
>>>
>>> You must carry a copy of your Operating Limitations. READ THEM!
>> Break
>>> them out and have the FAA Inspector SHOW YOU on the Operating
>>> Limitations where it says what he is saying. THE BURDON OF PROOF IS
>> ON
>>> THE FAA, not on your to prove you are innocent. Sometimes certain FA
A
>>> Inspectors forget that fact. Some Inspectors also assume that
>> anything
>>> they say is automatically correct. Anything you say is automatically
>>> wrong. You need to know your regulations and you also need the phone
>>> number to the EAA's Govt. Hotline. Ask for Randy Hanson.
>>>
>>> NUMBER TWO: If they still play nasty.... Go back to the motel, do
a
>>> handwritten modification to your Program Letter on a paper napkin, go
>>> down to the Hotel Desk and FAX IT to your local FISDO. The go back
to
>>> the airport and hand that FAA Inspector the paper napkin and bit him
a
>>> fond farewell. I am not being sarcastic here. OK. The paper napkin
>>> part is supposed to be a joke (OK who-ever from the FAA READS THIS?
A
>>> JOKE! PLEASE? Good grief).
>>>
>>> Not that I think you're wrong about carrying the stuff along. The FA
A
>>> CONSTANTLY (!!!) interprets things differently and they can come up
>> with
>>> the strangest things (flying with my door off, etc) and you have to
go
>>> to the ends of the Earth to get them to see things a little bit
>>> differently.
>>>
>>> Just saying. I think being polite but not cowardly is the best
>>> approach... my 2 cents.
>>>
>>> Mark
>>>
>>>
>>>
>>>
>>> -----Original Message-----
>>> From: owner-yak-list-server@matronics.com
>>> [mailto:owner-yak-list-server@matronics.com] On Behalf Of A. Dennis
>>> Savarese
>>> Sent: Tuesday, May 24, 2011 10:47 PM
>>> To: yak-list@matronics.com
>>> Subject: Re: Yak-List: Re: Program Letter
>>>
>>> --> Yak-List message posted by: "A. Dennis Savarese"
>>> <dsavarese0812@bellsouth.net>
>>>
>>> Here's something to think about.
>>> The program letter and modifications which you may send by fax are in
>>> fact part of the Operating Limitations for the airplane. We all know
>>> you are required to carry the OL's in the airplane at all times.
>> Since
>>> the Program Letter is actually a part of the OL's, then IMHO, it is
>> also
>>> required to be carried in the airplane.
>>>
>>> Unfortunately, when the FAA removed the 300/600 NM proficiency area,
>>> they failed to include the elimination of the Program Letter, which
>>> would have made logical sense. ie: if you don't have any restriction
s
>>> as to where you can fly, they why do you need a Program Letter to
>> attend
>>> an event?
>>>
>>> When you attend an event that may also be attended by the FAA
>> (typically
>>> when there is wavered airspace) and they ask to see your aircraft's
>>> paperwork as well as you pilot certificate and current medical form,
>>> when you hand him/her the aircraft's Operating Limitations he/she wil
l
>>> also ask to see your Program Letter or modification for this specific
>>> event. If you do not have your Program Letter with the specific even
t
>>> on it or a modification/update to the program letter which you
>> submitted
>>> to your FSDO with you, the FAA person may not permit you to stay at
>> the
>>> event. I had this happen to me about 5 years ago. Thus, when I sen
t
>>> my program letter in to the FSDO each year, I automatically put a co
py
>>> in the airplane along with any modifications.
>>> Dennis
>>>
>>> On 5/24/2011 9:00 PM, keithmckinley wrote:
>>>> --> Yak-List message posted by:
>>> "keithmckinley"<keith.mckinley@townisp.com>
>>>> Mark,
>>>>
>>>> Thanks for the feedback.
>>>>
>>>> No 300 mile restriction. No doubt it is easier to play nice with the
>>> Fed's and yes it does pay dividends, but sometimes I think it's
>>> important to make sure they interpret things correctly and realize
>> (as
>>> inspectors) they don't make the rules. More than anything, I just hav
e
>>> an aversion to ass kissing.......but not to protecting my own ass!
>>>> Semper Fi
>>>>
>>>> Keith
>>>>
>>>> --------
>>>> Keith McKinley
>>>> 700HS
>>>> KFIT
>>>>
>>>>
>>>>
>>>>
>>>> Read this topic online here:
>>>>
>>>> http://forums.matronics.com/viewtopic.php?p=340874#340874
>>>>
>>>>
>>>>
>>>>
>>>>
>>>>
>>>>
>>>>
>>>>
>>>>
>>>>
>>>
>>>
>>>
>>>
>>>
>>>
>>>
>>>
>>
>>
>>
>>
>>
>>
>>
>>
>>
>
>
Message 17
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| LIST | Reply to LIST Regarding this Message |
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|
| Subject: | Re: Program Letter |
I neglected to add that the program letter must be in the plane. Refer to
previously sent attachment.
Jim Griffin
----- Original Message -----
From: "Jim Griffin" <jgriffint28@cox.net>
Sent: Wednesday, May 25, 2011 2:36 PM
Subject: Re: Yak-List: Re: Program Letter
I recently talked to my FSDO about changing my 300 mile limits. He is a
helpful guy and sent me a copy of what the new op limits look like on
someone elses plane. In it, the program letter must list who is responsible
for maintenance for the plane. He also asked me for a printed maintenance
program. I have included a copy. Check paragraph 3.
Jim Griffin
----- Original Message -----
From: "A. Dennis Savarese" <dsavarese0812@bellsouth.net>
Sent: Wednesday, May 25, 2011 10:08 AM
Subject: Re: Yak-List: Re: Program Letter
<dsavarese0812@bellsouth.net>
Any new Special Airworthiness Certificates and Operating Limitations
will be issued under 8130.2G. This includes any request for the change
to eliminate the 300/600 mile proficiency area that may currently be in
your existing OL's.
Dennis
On 5/25/2011 9:48 AM, A. Dennis Savarese wrote:
> <dsavarese0812@bellsouth.net>
>
> For those that are operating under the older 8130.2F, here is a paragraph
> that is included in all of the groups, including ours, Group III. Just
> for grins, see if there is a paragraph in your own OL's that says
> something like the following".
>
> "....(2) No person may operate this aircraft for other than the purpose of
> meeting the requirements
> of 91.319(b), as stated in the program letter (required by 21.193) for
> this aircraft. This aircraft must
> be operated in accordance with applicable air traffic and general
> operating rules of part 91, as well as all
> additional limitations herein prescribed under the provisions of
> 91.319(e). These operating limitations
> are a part of the special airworthiness certificate, and are to be carried
> in the aircraft at all times
> and made available to the pilot in command of the aircraft.
> (Applicability: All)
> Dennis
>
>
> On 5/25/2011 9:26 AM, Bitterlich, Mark G CIV Det Cherry Point, MALS-14 64E
> wrote:
>> --> Yak-List message posted by: "Bitterlich, Mark G CIV Det Cherry
>> Point, MALS-14 64E"<mark.bitterlich@navy.mil>
>>
>> Just did :-)
>>
>> -----Original Message-----
>> From: owner-yak-list-server@matronics.com
>> [mailto:owner-yak-list-server@matronics.com] On Behalf Of A. Dennis
>> Savarese
>> Sent: Wednesday, May 25, 2011 10:15 AM
>> To: yak-list@matronics.com
>> Subject: Re: Yak-List: Re: Program Letter
>>
>> --> Yak-List message posted by: "A. Dennis Savarese"
>> <dsavarese0812@bellsouth.net>
>>
>> Mark, I respectfully request you read my next posting on the subject.
>> :-)
>>
>> On 5/25/2011 9:04 AM, Bitterlich, Mark G CIV Det Cherry Point, MALS-14
>> 64E wrote:
>>> --> Yak-List message posted by: "Bitterlich, Mark G CIV Det Cherry
>> Point, MALS-14 64E"<mark.bitterlich@navy.mil>
>>> Dennis, I respectfully disagree with your point of view in this one
>>> area.
>>>
>>> You mentioned:
>>>
>>> "The program letter and modifications which you may send by fax are in
>>> fact part of the Operating Limitations for the airplane. We all know
>>> you are required to carry the OL's in the airplane at all times.
>> Since
>>> the Program Letter is actually a part of the OL's, then IMHO, it is
>> also
>>> required to be carried in the airplane."
>>>
>>> The Operating Limitations also require a Conditional Inspection every
>>> year. By the same logic, you would also need to carry along a copy of
>>> your Conditional Inspection, or copies of your aircraft logbooks, etc.
>>> My opinion on dealing with the FAA on things like this is when they
>> say:
>>>
>>> "We need to see a copy of your Program Letter or modification of same,
>>> and if you don't have it with you, you must leave."
>>>
>>> NUMBER ONE: !!! Reply with: "Please quote the Regulation that
>>> specifically states I must carry a copy of my Program Letter with me.
>>> If you cannot quote me the exact regulation that requires me to do
>> this,
>>> I respectfully submit you have no authority to demand it from me".
>>>
>>> You must carry a copy of your Operating Limitations. READ THEM!
>> Break
>>> them out and have the FAA Inspector SHOW YOU on the Operating
>>> Limitations where it says what he is saying. THE BURDON OF PROOF IS
>> ON
>>> THE FAA, not on your to prove you are innocent. Sometimes certain FAA
>>> Inspectors forget that fact. Some Inspectors also assume that
>> anything
>>> they say is automatically correct. Anything you say is automatically
>>> wrong. You need to know your regulations and you also need the phone
>>> number to the EAA's Govt. Hotline. Ask for Randy Hanson.
>>>
>>> NUMBER TWO: If they still play nasty.... Go back to the motel, do a
>>> handwritten modification to your Program Letter on a paper napkin, go
>>> down to the Hotel Desk and FAX IT to your local FISDO. The go back to
>>> the airport and hand that FAA Inspector the paper napkin and bit him a
>>> fond farewell. I am not being sarcastic here. OK. The paper napkin
>>> part is supposed to be a joke (OK who-ever from the FAA READS THIS? A
>>> JOKE! PLEASE? Good grief).
>>>
>>> Not that I think you're wrong about carrying the stuff along. The FAA
>>> CONSTANTLY (!!!) interprets things differently and they can come up
>> with
>>> the strangest things (flying with my door off, etc) and you have to go
>>> to the ends of the Earth to get them to see things a little bit
>>> differently.
>>>
>>> Just saying. I think being polite but not cowardly is the best
>>> approach... my 2 cents.
>>>
>>> Mark
>>>
>>>
>>>
>>>
>>> -----Original Message-----
>>> From: owner-yak-list-server@matronics.com
>>> [mailto:owner-yak-list-server@matronics.com] On Behalf Of A. Dennis
>>> Savarese
>>> Sent: Tuesday, May 24, 2011 10:47 PM
>>> To: yak-list@matronics.com
>>> Subject: Re: Yak-List: Re: Program Letter
>>>
>>> --> Yak-List message posted by: "A. Dennis Savarese"
>>> <dsavarese0812@bellsouth.net>
>>>
>>> Here's something to think about.
>>> The program letter and modifications which you may send by fax are in
>>> fact part of the Operating Limitations for the airplane. We all know
>>> you are required to carry the OL's in the airplane at all times.
>> Since
>>> the Program Letter is actually a part of the OL's, then IMHO, it is
>> also
>>> required to be carried in the airplane.
>>>
>>> Unfortunately, when the FAA removed the 300/600 NM proficiency area,
>>> they failed to include the elimination of the Program Letter, which
>>> would have made logical sense. ie: if you don't have any restrictions
>>> as to where you can fly, they why do you need a Program Letter to
>> attend
>>> an event?
>>>
>>> When you attend an event that may also be attended by the FAA
>> (typically
>>> when there is wavered airspace) and they ask to see your aircraft's
>>> paperwork as well as you pilot certificate and current medical form,
>>> when you hand him/her the aircraft's Operating Limitations he/she will
>>> also ask to see your Program Letter or modification for this specific
>>> event. If you do not have your Program Letter with the specific event
>>> on it or a modification/update to the program letter which you
>> submitted
>>> to your FSDO with you, the FAA person may not permit you to stay at
>> the
>>> event. I had this happen to me about 5 years ago. Thus, when I sent
>>> my program letter in to the FSDO each year, I automatically put a copy
>>> in the airplane along with any modifications.
>>> Dennis
>>>
>>> On 5/24/2011 9:00 PM, keithmckinley wrote:
>>>> --> Yak-List message posted by:
>>> "keithmckinley"<keith.mckinley@townisp.com>
>>>> Mark,
>>>>
>>>> Thanks for the feedback.
>>>>
>>>> No 300 mile restriction. No doubt it is easier to play nice with the
>>> Fed's and yes it does pay dividends, but sometimes I think it's
>>> important to make sure they interpret things correctly and realize
>> (as
>>> inspectors) they don't make the rules. More than anything, I just have
>>> an aversion to ass kissing.......but not to protecting my own ass!
>>>> Semper Fi
>>>>
>>>> Keith
>>>>
>>>> --------
>>>> Keith McKinley
>>>> 700HS
>>>> KFIT
>>>>
>>>>
>>>>
>>>>
>>>> Read this topic online here:
>>>>
>>>> http://forums.matronics.com/viewtopic.php?p=340874#340874
>>>>
>>>>
>>>>
>>>>
>>>>
>>>>
>>>>
>>>>
>>>>
>>>>
>>>>
>>>
>>>
>>>
>>>
>>>
>>>
>>>
>>>
>>
>>
>>
>>
>>
>>
>>
>>
>>
>
>
Message 18
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| PREVIOUS | Skip to PREVIOUS Message |
| NEXT | Skip to NEXT Message |
| LIST | Reply to LIST Regarding this Message |
| SENDER | Reply to SENDER Regarding this Message |
|
| Subject: | Re: Program Letter |
What's all the hoop La? Make a copy and put it in the airplane.
Doc
-----Original Message-----
From: owner-yak-list-server@matronics.com
[mailto:owner-yak-list-server@matronics.com] On Behalf Of A. Dennis Savarese
Sent: Wednesday, May 25, 2011 10:09 AM
Subject: Re: Yak-List: Re: Program Letter
--> <dsavarese0812@bellsouth.net>
Any new Special Airworthiness Certificates and Operating Limitations will be
issued under 8130.2G. This includes any request for the change to eliminate
the 300/600 mile proficiency area that may currently be in your existing
OL's.
Dennis
On 5/25/2011 9:48 AM, A. Dennis Savarese wrote:
> <dsavarese0812@bellsouth.net>
>
> For those that are operating under the older 8130.2F, here is a
> paragraph that is included in all of the groups, including ours, Group
> III. Just for grins, see if there is a paragraph in your own OL's
> that says something like the following".
>
> "....(2) No person may operate this aircraft for other than the
> purpose of meeting the requirements of 91.319(b), as stated in the
> program letter (required by 21.193) for this aircraft. This aircraft
> must be operated in accordance with applicable air traffic and general
> operating rules of part 91, as well as all additional limitations
> herein prescribed under the provisions of 91.319(e). These operating
> limitations are a part of the special airworthiness certificate, and
> are to be carried in the aircraft at all times and made available to
> the pilot in command of the aircraft.
> (Applicability: All)
> Dennis
>
>
> On 5/25/2011 9:26 AM, Bitterlich, Mark G CIV Det Cherry Point, MALS-14
> 64E wrote:
>> --> Yak-List message posted by: "Bitterlich, Mark G CIV Det Cherry
>> Point, MALS-14 64E"<mark.bitterlich@navy.mil>
>>
>> Just did :-)
>>
>> -----Original Message-----
>> From: owner-yak-list-server@matronics.com
>> [mailto:owner-yak-list-server@matronics.com] On Behalf Of A. Dennis
>> Savarese
>> Sent: Wednesday, May 25, 2011 10:15 AM
>> To: yak-list@matronics.com
>> Subject: Re: Yak-List: Re: Program Letter
>>
>> --> Yak-List message posted by: "A. Dennis Savarese"
>> <dsavarese0812@bellsouth.net>
>>
>> Mark, I respectfully request you read my next posting on the subject.
>> :-)
>>
>> On 5/25/2011 9:04 AM, Bitterlich, Mark G CIV Det Cherry Point,
>> MALS-14 64E wrote:
>>> --> Yak-List message posted by: "Bitterlich, Mark G CIV Det Cherry
>> Point, MALS-14 64E"<mark.bitterlich@navy.mil>
>>> Dennis, I respectfully disagree with your point of view in this one
>>> area.
>>>
>>> You mentioned:
>>>
>>> "The program letter and modifications which you may send by fax are
>>> in fact part of the Operating Limitations for the airplane. We all
>>> know you are required to carry the OL's in the airplane at all times.
>> Since
>>> the Program Letter is actually a part of the OL's, then IMHO, it is
>> also
>>> required to be carried in the airplane."
>>>
>>> The Operating Limitations also require a Conditional Inspection
>>> every year. By the same logic, you would also need to carry along a
>>> copy of your Conditional Inspection, or copies of your aircraft
logbooks, etc.
>>> My opinion on dealing with the FAA on things like this is when they
>> say:
>>>
>>> "We need to see a copy of your Program Letter or modification of
>>> same, and if you don't have it with you, you must leave."
>>>
>>> NUMBER ONE: !!! Reply with: "Please quote the Regulation that
>>> specifically states I must carry a copy of my Program Letter with me.
>>> If you cannot quote me the exact regulation that requires me to do
>> this,
>>> I respectfully submit you have no authority to demand it from me".
>>>
>>> You must carry a copy of your Operating Limitations. READ THEM!
>> Break
>>> them out and have the FAA Inspector SHOW YOU on the Operating
>>> Limitations where it says what he is saying. THE BURDON OF PROOF IS
>> ON
>>> THE FAA, not on your to prove you are innocent. Sometimes certain
>>> FAA Inspectors forget that fact. Some Inspectors also assume that
>> anything
>>> they say is automatically correct. Anything you say is
>>> automatically wrong. You need to know your regulations and you also
>>> need the phone number to the EAA's Govt. Hotline. Ask for Randy Hanson.
>>>
>>> NUMBER TWO: If they still play nasty.... Go back to the motel, do a
>>> handwritten modification to your Program Letter on a paper napkin,
>>> go down to the Hotel Desk and FAX IT to your local FISDO. The go
>>> back to the airport and hand that FAA Inspector the paper napkin and
>>> bit him a fond farewell. I am not being sarcastic here. OK. The
>>> paper napkin part is supposed to be a joke (OK who-ever from the FAA
>>> READS THIS? A JOKE! PLEASE? Good grief).
>>>
>>> Not that I think you're wrong about carrying the stuff along. The
>>> FAA CONSTANTLY (!!!) interprets things differently and they can come
>>> up
>> with
>>> the strangest things (flying with my door off, etc) and you have to
>>> go to the ends of the Earth to get them to see things a little bit
>>> differently.
>>>
>>> Just saying. I think being polite but not cowardly is the best
>>> approach... my 2 cents.
>>>
>>> Mark
>>>
>>>
>>>
>>>
>>> -----Original Message-----
>>> From: owner-yak-list-server@matronics.com
>>> [mailto:owner-yak-list-server@matronics.com] On Behalf Of A. Dennis
>>> Savarese
>>> Sent: Tuesday, May 24, 2011 10:47 PM
>>> To: yak-list@matronics.com
>>> Subject: Re: Yak-List: Re: Program Letter
>>>
>>> --> Yak-List message posted by: "A. Dennis Savarese"
>>> <dsavarese0812@bellsouth.net>
>>>
>>> Here's something to think about.
>>> The program letter and modifications which you may send by fax are
>>> in fact part of the Operating Limitations for the airplane. We all
>>> know you are required to carry the OL's in the airplane at all times.
>> Since
>>> the Program Letter is actually a part of the OL's, then IMHO, it is
>> also
>>> required to be carried in the airplane.
>>>
>>> Unfortunately, when the FAA removed the 300/600 NM proficiency area,
>>> they failed to include the elimination of the Program Letter, which
>>> would have made logical sense. ie: if you don't have any
>>> restrictions as to where you can fly, they why do you need a Program
>>> Letter to
>> attend
>>> an event?
>>>
>>> When you attend an event that may also be attended by the FAA
>> (typically
>>> when there is wavered airspace) and they ask to see your aircraft's
>>> paperwork as well as you pilot certificate and current medical form,
>>> when you hand him/her the aircraft's Operating Limitations he/she
>>> will also ask to see your Program Letter or modification for this
>>> specific event. If you do not have your Program Letter with the
>>> specific event on it or a modification/update to the program letter
>>> which you
>> submitted
>>> to your FSDO with you, the FAA person may not permit you to stay at
>> the
>>> event. I had this happen to me about 5 years ago. Thus, when I sent
>>> my program letter in to the FSDO each year, I automatically put a
>>> copy in the airplane along with any modifications.
>>> Dennis
>>>
>>> On 5/24/2011 9:00 PM, keithmckinley wrote:
>>>> --> Yak-List message posted by:
>>> "keithmckinley"<keith.mckinley@townisp.com>
>>>> Mark,
>>>>
>>>> Thanks for the feedback.
>>>>
>>>> No 300 mile restriction. No doubt it is easier to play nice with
>>>> the
>>> Fed's and yes it does pay dividends, but sometimes I think it's
>>> important to make sure they interpret things correctly and realize
>> (as
>>> inspectors) they don't make the rules. More than anything, I just
>>> have an aversion to ass kissing.......but not to protecting my own ass!
>>>> Semper Fi
>>>>
>>>> Keith
>>>>
>>>> --------
>>>> Keith McKinley
>>>> 700HS
>>>> KFIT
>>>>
>>>>
>>>>
>>>>
>>>> Read this topic online here:
>>>>
>>>> http://forums.matronics.com/viewtopic.php?p=340874#340874
>>>>
>>>>
>>>>
>>>>
>>>>
>>>>
>>>>
>>>>
>>>>
>>>>
>>>>
>>>
>>>
>>>
>>>
>>>
>>>
>>>
>>>
>>
>>
>>
>>
>>
>>
>>
>>
>>
>
>
Message 19
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|
| Subject: | Re: Program Letter |
No Hoopla. Put the copy in your airplane and DOC! DON'T DO ANY TAIL SLIDES EITHER!
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: Wednesday, May 25, 2011 5:58 PM
Subject: RE: Yak-List: Re: Program Letter
What's all the hoop La? Make a copy and put it in the airplane.
Doc
-----Original Message-----
From: owner-yak-list-server@matronics.com
[mailto:owner-yak-list-server@matronics.com] On Behalf Of A. Dennis Savarese
Sent: Wednesday, May 25, 2011 10:09 AM
Subject: Re: Yak-List: Re: Program Letter
--> <dsavarese0812@bellsouth.net>
Any new Special Airworthiness Certificates and Operating Limitations will be
issued under 8130.2G. This includes any request for the change to eliminate
the 300/600 mile proficiency area that may currently be in your existing
OL's.
Dennis
On 5/25/2011 9:48 AM, A. Dennis Savarese wrote:
> <dsavarese0812@bellsouth.net>
>
> For those that are operating under the older 8130.2F, here is a
> paragraph that is included in all of the groups, including ours, Group
> III. Just for grins, see if there is a paragraph in your own OL's
> that says something like the following".
>
> "....(2) No person may operate this aircraft for other than the
> purpose of meeting the requirements of 91.319(b), as stated in the
> program letter (required by 21.193) for this aircraft. This aircraft
> must be operated in accordance with applicable air traffic and general
> operating rules of part 91, as well as all additional limitations
> herein prescribed under the provisions of 91.319(e). These operating
> limitations are a part of the special airworthiness certificate, and
> are to be carried in the aircraft at all times and made available to
> the pilot in command of the aircraft.
> (Applicability: All)
> Dennis
>
>
> On 5/25/2011 9:26 AM, Bitterlich, Mark G CIV Det Cherry Point, MALS-14
> 64E wrote:
>> --> Yak-List message posted by: "Bitterlich, Mark G CIV Det Cherry
>> Point, MALS-14 64E"<mark.bitterlich@navy.mil>
>>
>> Just did :-)
>>
>> -----Original Message-----
>> From: owner-yak-list-server@matronics.com
>> [mailto:owner-yak-list-server@matronics.com] On Behalf Of A. Dennis
>> Savarese
>> Sent: Wednesday, May 25, 2011 10:15 AM
>> To: yak-list@matronics.com
>> Subject: Re: Yak-List: Re: Program Letter
>>
>> --> Yak-List message posted by: "A. Dennis Savarese"
>> <dsavarese0812@bellsouth.net>
>>
>> Mark, I respectfully request you read my next posting on the subject.
>> :-)
>>
>> On 5/25/2011 9:04 AM, Bitterlich, Mark G CIV Det Cherry Point,
>> MALS-14 64E wrote:
>>> --> Yak-List message posted by: "Bitterlich, Mark G CIV Det Cherry
>> Point, MALS-14 64E"<mark.bitterlich@navy.mil>
>>> Dennis, I respectfully disagree with your point of view in this one
>>> area.
>>>
>>> You mentioned:
>>>
>>> "The program letter and modifications which you may send by fax are
>>> in fact part of the Operating Limitations for the airplane. We all
>>> know you are required to carry the OL's in the airplane at all times.
>> Since
>>> the Program Letter is actually a part of the OL's, then IMHO, it is
>> also
>>> required to be carried in the airplane."
>>>
>>> The Operating Limitations also require a Conditional Inspection
>>> every year. By the same logic, you would also need to carry along a
>>> copy of your Conditional Inspection, or copies of your aircraft
logbooks, etc.
>>> My opinion on dealing with the FAA on things like this is when they
>> say:
>>>
>>> "We need to see a copy of your Program Letter or modification of
>>> same, and if you don't have it with you, you must leave."
>>>
>>> NUMBER ONE: !!! Reply with: "Please quote the Regulation that
>>> specifically states I must carry a copy of my Program Letter with me.
>>> If you cannot quote me the exact regulation that requires me to do
>> this,
>>> I respectfully submit you have no authority to demand it from me".
>>>
>>> You must carry a copy of your Operating Limitations. READ THEM!
>> Break
>>> them out and have the FAA Inspector SHOW YOU on the Operating
>>> Limitations where it says what he is saying. THE BURDON OF PROOF IS
>> ON
>>> THE FAA, not on your to prove you are innocent. Sometimes certain
>>> FAA Inspectors forget that fact. Some Inspectors also assume that
>> anything
>>> they say is automatically correct. Anything you say is
>>> automatically wrong. You need to know your regulations and you also
>>> need the phone number to the EAA's Govt. Hotline. Ask for Randy Hanson.
>>>
>>> NUMBER TWO: If they still play nasty.... Go back to the motel, do a
>>> handwritten modification to your Program Letter on a paper napkin,
>>> go down to the Hotel Desk and FAX IT to your local FISDO. The go
>>> back to the airport and hand that FAA Inspector the paper napkin and
>>> bit him a fond farewell. I am not being sarcastic here. OK. The
>>> paper napkin part is supposed to be a joke (OK who-ever from the FAA
>>> READS THIS? A JOKE! PLEASE? Good grief).
>>>
>>> Not that I think you're wrong about carrying the stuff along. The
>>> FAA CONSTANTLY (!!!) interprets things differently and they can come
>>> up
>> with
>>> the strangest things (flying with my door off, etc) and you have to
>>> go to the ends of the Earth to get them to see things a little bit
>>> differently.
>>>
>>> Just saying. I think being polite but not cowardly is the best
>>> approach... my 2 cents.
>>>
>>> Mark
>>>
>>>
>>>
>>>
>>> -----Original Message-----
>>> From: owner-yak-list-server@matronics.com
>>> [mailto:owner-yak-list-server@matronics.com] On Behalf Of A. Dennis
>>> Savarese
>>> Sent: Tuesday, May 24, 2011 10:47 PM
>>> To: yak-list@matronics.com
>>> Subject: Re: Yak-List: Re: Program Letter
>>>
>>> --> Yak-List message posted by: "A. Dennis Savarese"
>>> <dsavarese0812@bellsouth.net>
>>>
>>> Here's something to think about.
>>> The program letter and modifications which you may send by fax are
>>> in fact part of the Operating Limitations for the airplane. We all
>>> know you are required to carry the OL's in the airplane at all times.
>> Since
>>> the Program Letter is actually a part of the OL's, then IMHO, it is
>> also
>>> required to be carried in the airplane.
>>>
>>> Unfortunately, when the FAA removed the 300/600 NM proficiency area,
>>> they failed to include the elimination of the Program Letter, which
>>> would have made logical sense. ie: if you don't have any
>>> restrictions as to where you can fly, they why do you need a Program
>>> Letter to
>> attend
>>> an event?
>>>
>>> When you attend an event that may also be attended by the FAA
>> (typically
>>> when there is wavered airspace) and they ask to see your aircraft's
>>> paperwork as well as you pilot certificate and current medical form,
>>> when you hand him/her the aircraft's Operating Limitations he/she
>>> will also ask to see your Program Letter or modification for this
>>> specific event. If you do not have your Program Letter with the
>>> specific event on it or a modification/update to the program letter
>>> which you
>> submitted
>>> to your FSDO with you, the FAA person may not permit you to stay at
>> the
>>> event. I had this happen to me about 5 years ago. Thus, when I sent
>>> my program letter in to the FSDO each year, I automatically put a
>>> copy in the airplane along with any modifications.
>>> Dennis
>>>
>>> On 5/24/2011 9:00 PM, keithmckinley wrote:
>>>> --> Yak-List message posted by:
>>> "keithmckinley"<keith.mckinley@townisp.com>
>>>> Mark,
>>>>
>>>> Thanks for the feedback.
>>>>
>>>> No 300 mile restriction. No doubt it is easier to play nice with
>>>> the
>>> Fed's and yes it does pay dividends, but sometimes I think it's
>>> important to make sure they interpret things correctly and realize
>> (as
>>> inspectors) they don't make the rules. More than anything, I just
>>> have an aversion to ass kissing.......but not to protecting my own ass!
>>>> Semper Fi
>>>>
>>>> Keith
>>>>
>>>> --------
>>>> Keith McKinley
>>>> 700HS
>>>> KFIT
>>>>
>>>>
>>>>
>>>>
>>>> Read this topic online here:
>>>>
>>>> http://forums.matronics.com/viewtopic.php?p=340874#340874
>>>>
>>>>
>>>>
>>>>
>>>>
>>>>
>>>>
>>>>
>>>>
>>>>
>>>>
>>>
>>>
>>>
>>>
>>>
>>>
>>>
>>>
>>
>>
>>
>>
>>
>>
>>
>>
>>
>
>
Message 20
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| LIST | Reply to LIST Regarding this Message |
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|
| Subject: | Re: Program Letter |
I agree. It does not say you have to carry your Program Letter. That
is why I posted it so as to compare to the new 8130.2G.
Dennis
On 5/25/2011 2:25 PM, Bitterlich, Mark G CIV Det Cherry Point, MALS-14
64E wrote:
> --> Yak-List message posted by: "Bitterlich, Mark G CIV Det Cherry Point, MALS-14
64E"<mark.bitterlich@navy.mil>
>
> Yes, but that does not say you have to carry your Program Letter Dennis. It
says you have to carry your OPERATING LIMITATIONS in the aircraft.
>
> Just FYI, under the OLD rules .... I contacted the EAA and the local FAA, the
Montana FAA, the Seattle FAA and all of them said you did NOT have to carry your
program letter with you. I am sure you were told that you did have to.
>
> It falls into the "whatever you feel is right category" and it also fell into
"who interprets the rules" category.
>
> On the other hand, the new rules you just posted are a whole different thing.
I read them, they seem quite clear! That said, I never EVER take what ANYONE
says on the Yak List regarding rules and regulations as gospel. Even when I
read things myself! I always ask for second opinions, third opinions, and even
FORTH opinions! I always dig very deeply when it comes to rules.
>
> I sent your quote to the EAA Government Division (Randy Hanson) for confirmation
or interpretation. As I said, what you posted seems very clear and is a definite
change in policy and adds a new requirement to all of us. But I'll still
be interested in what the EAA says.
>
>
> Mark
>
>
> -----Original Message-----
> From: owner-yak-list-server@matronics.com [mailto:owner-yak-list-server@matronics.com] On Behalf Of A. Dennis Savarese
> Sent: Wednesday, May 25, 2011 10:49 AM
> To: yak-list@matronics.com
> Subject: Re: Yak-List: Re: Program Letter
>
> --> Yak-List message posted by: "A. Dennis Savarese"<dsavarese0812@bellsouth.net>
>
> For those that are operating under the older 8130.2F, here is a
> paragraph that is included in all of the groups, including ours, Group
> III. Just for grins, see if there is a paragraph in your own OL's that
> says something like the following".
>
> "....(2) No person may operate this aircraft for other than the purpose
> of meeting the requirements
> of 91.319(b), as stated in the program letter (required by 21.193)
> for this aircraft. This aircraft must
> be operated in accordance with applicable air traffic and general
> operating rules of part 91, as well as all
> additional limitations herein prescribed under the provisions of
> 91.319(e). These operating limitations
> are a part of the special airworthiness certificate, and are to be
> carried in the aircraft at all times
> and made available to the pilot in command of the aircraft.
> (Applicability: All)
> Dennis
>
>
> On 5/25/2011 9:26 AM, Bitterlich, Mark G CIV Det Cherry Point, MALS-14
> 64E wrote:
>> --> Yak-List message posted by: "Bitterlich, Mark G CIV Det Cherry Point,
MALS-14 64E"<mark.bitterlich@navy.mil>
>>
>> Just did :-)
>>
>> -----Original Message-----
>> From: owner-yak-list-server@matronics.com
>> [mailto:owner-yak-list-server@matronics.com] On Behalf Of A. Dennis
>> Savarese
>> Sent: Wednesday, May 25, 2011 10:15 AM
>> To: yak-list@matronics.com
>> Subject: Re: Yak-List: Re: Program Letter
>>
>> --> Yak-List message posted by: "A. Dennis Savarese"
>> <dsavarese0812@bellsouth.net>
>>
>> Mark, I respectfully request you read my next posting on the subject.
>> :-)
>>
>> On 5/25/2011 9:04 AM, Bitterlich, Mark G CIV Det Cherry Point, MALS-14
>> 64E wrote:
>>> --> Yak-List message posted by: "Bitterlich, Mark G CIV Det Cherry
>> Point, MALS-14 64E"<mark.bitterlich@navy.mil>
>>> Dennis, I respectfully disagree with your point of view in this one
>>> area.
>>>
>>> You mentioned:
>>>
>>> "The program letter and modifications which you may send by fax are in
>>> fact part of the Operating Limitations for the airplane. We all know
>>> you are required to carry the OL's in the airplane at all times.
>> Since
>>> the Program Letter is actually a part of the OL's, then IMHO, it is
>> also
>>> required to be carried in the airplane."
>>>
>>> The Operating Limitations also require a Conditional Inspection every
>>> year. By the same logic, you would also need to carry along a copy of
>>> your Conditional Inspection, or copies of your aircraft logbooks, etc.
>>> My opinion on dealing with the FAA on things like this is when they
>> say:
>>> "We need to see a copy of your Program Letter or modification of same,
>>> and if you don't have it with you, you must leave."
>>>
>>> NUMBER ONE: !!! Reply with: "Please quote the Regulation that
>>> specifically states I must carry a copy of my Program Letter with me.
>>> If you cannot quote me the exact regulation that requires me to do
>> this,
>>> I respectfully submit you have no authority to demand it from me".
>>>
>>> You must carry a copy of your Operating Limitations. READ THEM!
>> Break
>>> them out and have the FAA Inspector SHOW YOU on the Operating
>>> Limitations where it says what he is saying. THE BURDON OF PROOF IS
>> ON
>>> THE FAA, not on your to prove you are innocent. Sometimes certain FAA
>>> Inspectors forget that fact. Some Inspectors also assume that
>> anything
>>> they say is automatically correct. Anything you say is automatically
>>> wrong. You need to know your regulations and you also need the phone
>>> number to the EAA's Govt. Hotline. Ask for Randy Hanson.
>>>
>>> NUMBER TWO: If they still play nasty.... Go back to the motel, do a
>>> handwritten modification to your Program Letter on a paper napkin, go
>>> down to the Hotel Desk and FAX IT to your local FISDO. The go back to
>>> the airport and hand that FAA Inspector the paper napkin and bit him a
>>> fond farewell. I am not being sarcastic here. OK. The paper napkin
>>> part is supposed to be a joke (OK who-ever from the FAA READS THIS? A
>>> JOKE! PLEASE? Good grief).
>>>
>>> Not that I think you're wrong about carrying the stuff along. The FAA
>>> CONSTANTLY (!!!) interprets things differently and they can come up
>> with
>>> the strangest things (flying with my door off, etc) and you have to go
>>> to the ends of the Earth to get them to see things a little bit
>>> differently.
>>>
>>> Just saying. I think being polite but not cowardly is the best
>>> approach... my 2 cents.
>>>
>>> Mark
>>>
>>>
>>>
>>>
>>> -----Original Message-----
>>> From: owner-yak-list-server@matronics.com
>>> [mailto:owner-yak-list-server@matronics.com] On Behalf Of A. Dennis
>>> Savarese
>>> Sent: Tuesday, May 24, 2011 10:47 PM
>>> To: yak-list@matronics.com
>>> Subject: Re: Yak-List: Re: Program Letter
>>>
>>> --> Yak-List message posted by: "A. Dennis Savarese"
>>> <dsavarese0812@bellsouth.net>
>>>
>>> Here's something to think about.
>>> The program letter and modifications which you may send by fax are in
>>> fact part of the Operating Limitations for the airplane. We all know
>>> you are required to carry the OL's in the airplane at all times.
>> Since
>>> the Program Letter is actually a part of the OL's, then IMHO, it is
>> also
>>> required to be carried in the airplane.
>>>
>>> Unfortunately, when the FAA removed the 300/600 NM proficiency area,
>>> they failed to include the elimination of the Program Letter, which
>>> would have made logical sense. ie: if you don't have any restrictions
>>> as to where you can fly, they why do you need a Program Letter to
>> attend
>>> an event?
>>>
>>> When you attend an event that may also be attended by the FAA
>> (typically
>>> when there is wavered airspace) and they ask to see your aircraft's
>>> paperwork as well as you pilot certificate and current medical form,
>>> when you hand him/her the aircraft's Operating Limitations he/she will
>>> also ask to see your Program Letter or modification for this specific
>>> event. If you do not have your Program Letter with the specific event
>>> on it or a modification/update to the program letter which you
>> submitted
>>> to your FSDO with you, the FAA person may not permit you to stay at
>> the
>>> event. I had this happen to me about 5 years ago. Thus, when I sent
>>> my program letter in to the FSDO each year, I automatically put a copy
>>> in the airplane along with any modifications.
>>> Dennis
>>>
>>> On 5/24/2011 9:00 PM, keithmckinley wrote:
>>>> --> Yak-List message posted by:
>>> "keithmckinley"<keith.mckinley@townisp.com>
>>>> Mark,
>>>>
>>>> Thanks for the feedback.
>>>>
>>>> No 300 mile restriction. No doubt it is easier to play nice with the
>>> Fed's and yes it does pay dividends, but sometimes I think it's
>>> important to make sure they interpret things correctly and realize
>> (as
>>> inspectors) they don't make the rules. More than anything, I just have
>>> an aversion to ass kissing.......but not to protecting my own ass!
>>>> Semper Fi
>>>>
>>>> Keith
>>>>
>>>> --------
>>>> Keith McKinley
>>>> 700HS
>>>> KFIT
>>>>
>>>>
>>>>
>>>>
>>>> Read this topic online here:
>>>>
>>>> http://forums.matronics.com/viewtopic.php?p=340874#340874
>>>>
>>>>
>>>>
>>>>
>>>>
>>>>
>>>>
>>>>
>>>>
>>>>
>>>>
>>>
>>>
>>>
>>>
>>>
>>>
>>>
>>
>>
>>
>>
>>
>>
>>
>>
>
>
Message 21
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| PREVIOUS | Skip to PREVIOUS Message |
| NEXT | Skip to NEXT Message |
| LIST | Reply to LIST Regarding this Message |
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|
| Subject: | Re: Program Letter |
Nope! Only the OL's that you have presently.
Dennis
On 5/25/2011 2:26 PM, Bitterlich, Mark G CIV Det Cherry Point, MALS-14
64E wrote:
> --> Yak-List message posted by: "Bitterlich, Mark G CIV Det Cherry Point, MALS-14
64E"<mark.bitterlich@navy.mil>
>
> So does 8130.2G apply to those of us that were issued Special Airworthiness Certificates
under 8130.2F or not?
>
> Mark
>
>
> -----Original Message-----
> From: owner-yak-list-server@matronics.com [mailto:owner-yak-list-server@matronics.com] On Behalf Of A. Dennis Savarese
> Sent: Wednesday, May 25, 2011 11:09 AM
> To: yak-list@matronics.com
> Subject: Re: Yak-List: Re: Program Letter
>
> --> Yak-List message posted by: "A. Dennis Savarese"<dsavarese0812@bellsouth.net>
>
> Any new Special Airworthiness Certificates and Operating Limitations
> will be issued under 8130.2G. This includes any request for the change
> to eliminate the 300/600 mile proficiency area that may currently be in
> your existing OL's.
> Dennis
>
> On 5/25/2011 9:48 AM, A. Dennis Savarese wrote:
>> --> Yak-List message posted by: "A. Dennis Savarese"
>> <dsavarese0812@bellsouth.net>
>>
>> For those that are operating under the older 8130.2F, here is a
>> paragraph that is included in all of the groups, including ours, Group
>> III. Just for grins, see if there is a paragraph in your own OL's
>> that says something like the following".
>>
>> "....(2) No person may operate this aircraft for other than the
>> purpose of meeting the requirements
>> of 91.319(b), as stated in the program letter (required by 21.193)
>> for this aircraft. This aircraft must
>> be operated in accordance with applicable air traffic and general
>> operating rules of part 91, as well as all
>> additional limitations herein prescribed under the provisions of
>> 91.319(e). These operating limitations
>> are a part of the special airworthiness certificate, and are to be
>> carried in the aircraft at all times
>> and made available to the pilot in command of the aircraft.
>> (Applicability: All)
>> Dennis
>>
>>
>> On 5/25/2011 9:26 AM, Bitterlich, Mark G CIV Det Cherry Point, MALS-14
>> 64E wrote:
>>> --> Yak-List message posted by: "Bitterlich, Mark G CIV Det Cherry
>>> Point, MALS-14 64E"<mark.bitterlich@navy.mil>
>>>
>>> Just did :-)
>>>
>>> -----Original Message-----
>>> From: owner-yak-list-server@matronics.com
>>> [mailto:owner-yak-list-server@matronics.com] On Behalf Of A. Dennis
>>> Savarese
>>> Sent: Wednesday, May 25, 2011 10:15 AM
>>> To: yak-list@matronics.com
>>> Subject: Re: Yak-List: Re: Program Letter
>>>
>>> --> Yak-List message posted by: "A. Dennis Savarese"
>>> <dsavarese0812@bellsouth.net>
>>>
>>> Mark, I respectfully request you read my next posting on the subject.
>>> :-)
>>>
>>> On 5/25/2011 9:04 AM, Bitterlich, Mark G CIV Det Cherry Point, MALS-14
>>> 64E wrote:
>>>> --> Yak-List message posted by: "Bitterlich, Mark G CIV Det Cherry
>>> Point, MALS-14 64E"<mark.bitterlich@navy.mil>
>>>> Dennis, I respectfully disagree with your point of view in this one
>>>> area.
>>>>
>>>> You mentioned:
>>>>
>>>> "The program letter and modifications which you may send by fax are in
>>>> fact part of the Operating Limitations for the airplane. We all know
>>>> you are required to carry the OL's in the airplane at all times.
>>> Since
>>>> the Program Letter is actually a part of the OL's, then IMHO, it is
>>> also
>>>> required to be carried in the airplane."
>>>>
>>>> The Operating Limitations also require a Conditional Inspection every
>>>> year. By the same logic, you would also need to carry along a copy of
>>>> your Conditional Inspection, or copies of your aircraft logbooks, etc.
>>>> My opinion on dealing with the FAA on things like this is when they
>>> say:
>>>> "We need to see a copy of your Program Letter or modification of same,
>>>> and if you don't have it with you, you must leave."
>>>>
>>>> NUMBER ONE: !!! Reply with: "Please quote the Regulation that
>>>> specifically states I must carry a copy of my Program Letter with me.
>>>> If you cannot quote me the exact regulation that requires me to do
>>> this,
>>>> I respectfully submit you have no authority to demand it from me".
>>>>
>>>> You must carry a copy of your Operating Limitations. READ THEM!
>>> Break
>>>> them out and have the FAA Inspector SHOW YOU on the Operating
>>>> Limitations where it says what he is saying. THE BURDON OF PROOF IS
>>> ON
>>>> THE FAA, not on your to prove you are innocent. Sometimes certain FAA
>>>> Inspectors forget that fact. Some Inspectors also assume that
>>> anything
>>>> they say is automatically correct. Anything you say is automatically
>>>> wrong. You need to know your regulations and you also need the phone
>>>> number to the EAA's Govt. Hotline. Ask for Randy Hanson.
>>>>
>>>> NUMBER TWO: If they still play nasty.... Go back to the motel, do a
>>>> handwritten modification to your Program Letter on a paper napkin, go
>>>> down to the Hotel Desk and FAX IT to your local FISDO. The go back to
>>>> the airport and hand that FAA Inspector the paper napkin and bit him a
>>>> fond farewell. I am not being sarcastic here. OK. The paper napkin
>>>> part is supposed to be a joke (OK who-ever from the FAA READS THIS? A
>>>> JOKE! PLEASE? Good grief).
>>>>
>>>> Not that I think you're wrong about carrying the stuff along. The FAA
>>>> CONSTANTLY (!!!) interprets things differently and they can come up
>>> with
>>>> the strangest things (flying with my door off, etc) and you have to go
>>>> to the ends of the Earth to get them to see things a little bit
>>>> differently.
>>>>
>>>> Just saying. I think being polite but not cowardly is the best
>>>> approach... my 2 cents.
>>>>
>>>> Mark
>>>>
>>>>
>>>>
>>>>
>>>> -----Original Message-----
>>>> From: owner-yak-list-server@matronics.com
>>>> [mailto:owner-yak-list-server@matronics.com] On Behalf Of A. Dennis
>>>> Savarese
>>>> Sent: Tuesday, May 24, 2011 10:47 PM
>>>> To: yak-list@matronics.com
>>>> Subject: Re: Yak-List: Re: Program Letter
>>>>
>>>> --> Yak-List message posted by: "A. Dennis Savarese"
>>>> <dsavarese0812@bellsouth.net>
>>>>
>>>> Here's something to think about.
>>>> The program letter and modifications which you may send by fax are in
>>>> fact part of the Operating Limitations for the airplane. We all know
>>>> you are required to carry the OL's in the airplane at all times.
>>> Since
>>>> the Program Letter is actually a part of the OL's, then IMHO, it is
>>> also
>>>> required to be carried in the airplane.
>>>>
>>>> Unfortunately, when the FAA removed the 300/600 NM proficiency area,
>>>> they failed to include the elimination of the Program Letter, which
>>>> would have made logical sense. ie: if you don't have any restrictions
>>>> as to where you can fly, they why do you need a Program Letter to
>>> attend
>>>> an event?
>>>>
>>>> When you attend an event that may also be attended by the FAA
>>> (typically
>>>> when there is wavered airspace) and they ask to see your aircraft's
>>>> paperwork as well as you pilot certificate and current medical form,
>>>> when you hand him/her the aircraft's Operating Limitations he/she will
>>>> also ask to see your Program Letter or modification for this specific
>>>> event. If you do not have your Program Letter with the specific event
>>>> on it or a modification/update to the program letter which you
>>> submitted
>>>> to your FSDO with you, the FAA person may not permit you to stay at
>>> the
>>>> event. I had this happen to me about 5 years ago. Thus, when I sent
>>>> my program letter in to the FSDO each year, I automatically put a copy
>>>> in the airplane along with any modifications.
>>>> Dennis
>>>>
>>>> On 5/24/2011 9:00 PM, keithmckinley wrote:
>>>>> --> Yak-List message posted by:
>>>> "keithmckinley"<keith.mckinley@townisp.com>
>>>>> Mark,
>>>>>
>>>>> Thanks for the feedback.
>>>>>
>>>>> No 300 mile restriction. No doubt it is easier to play nice with the
>>>> Fed's and yes it does pay dividends, but sometimes I think it's
>>>> important to make sure they interpret things correctly and realize
>>> (as
>>>> inspectors) they don't make the rules. More than anything, I just have
>>>> an aversion to ass kissing.......but not to protecting my own ass!
>>>>> Semper Fi
>>>>>
>>>>> Keith
>>>>>
>>>>> --------
>>>>> Keith McKinley
>>>>> 700HS
>>>>> KFIT
>>>>>
>>>>>
>>>>>
>>>>>
>>>>> Read this topic online here:
>>>>>
>>>>> http://forums.matronics.com/viewtopic.php?p=340874#340874
>>>>>
>>>>>
>>>>>
>>>>>
>>>>>
>>>>>
>>>>>
>>>>>
>>>>>
>>>>>
>>>>>
>>>>
>>>>
>>>>
>>>>
>>>>
>>>>
>>>>
>>>
>>>
>>>
>>>
>>>
>>>
>>>
>>>
>>
>>
>>
>>
>
>
Message 22
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| Subject: | Re: Program Letter |
Here is how the EAA Govt. Liason Division interprets these rules. These people
talk to those that MAKE the rules, not to local FISDO's that INTERPRET the rules.
Thus I consider the EAA to be the best experts available unless you know someone
in Washington DC that works for the FAA.
And the answer the EAA writes below is EXACTLY why I took this issue up the chain
to get a better understanding.
What Dennis wrote is of course absolutely correct... he just didn't mention 8130.2G,
paragraph 4107
And Dennis, I also (respectfully :-) once more disagree when you mention that
any changes made to CURRENT Operating Limitations will result in you now being
required to fall under 8130.2G, and thus get a whole NEW set of Operating Limitations.
New Airworthiness Certificate .... yes. 8130.2G applies, and you will get all
new Operating Limitations and ... you will be required to carry your Program Letter
with you, etc.
Removal of an Operating Limitation from an EXISTING list of Operating Limitations
attached to an EXISTING Experimental Airworthiness Certificate written under
8130.2F .... NO!
Mark Bitterlich
p.s. For a complete understanding read the response from the EAA contained below.
-----Original Message-----
From: Randy Hansen [mailto:rhansen@eaa.org]
Sent: Wednesday, May 25, 2011 4:07 PM
Subject: RE: Yak-List: Re: Program Letter
Mark, this is an issue that may differ from aircraft to aircraft based
on the issued operating limitations -
The FAR baseline for this requirement is FAR 21.193 - it says a program
letter must be submitted, it does not mention a annual requirement.
The second baseline is FAR 91.319(i) - it says the administrator may
prescribe additional limitations the administrator feels necessary.
**this means the FAA can change to operating limitations as
necessary to address and resolve safety and operations issues.
FAA Order 8130.2F (effective Nov 2004 - April 2011), limitation (37) -
the operator must submit an annual program letter.
**no requirement that the program letter must be carried on
board.
FAA Order 8130.2G (effective April 2011 - present), limitation (3) the
operator must submit an annual program letter...and a copy of the
program letter and any amendments must be carried on board the aircraft
any time that the aircraft is being operated.
**carrying the program letter is a new requirement.
FAA Order 8130.2G, paragraph 4107 d - states that "all previously issued
airworthiness certificates and operating limitations will remain valid
unless changes are requested by the applicant or reexamined by the FAA
in accordance with 49 U.S.C. 44709."
Bottom line - If your airworthiness certificate and operating
limitations were issued under an earlier edition of 8130.2 (editions A,
B, C, D. E, or F) then you do not have a requirement to carry a program
letter on board the aircraft. And since there is NO requirement to turn
in your existing documents for a new version issued under the new
8130.2G, you do not need to carry your program letter. This new
requirement will only apply to those experimental exhibition aircraft
issued an original airworthiness certificate on/after April 11, 2011.
-----Original Message-----
From: owner-yak-list-server@matronics.com [mailto:owner-yak-list-server@matronics.com] On Behalf Of A. Dennis Savarese
Sent: Wednesday, May 25, 2011 11:09 AM
Subject: Re: Yak-List: Re: Program Letter
Any new Special Airworthiness Certificates and Operating Limitations
will be issued under 8130.2G. This includes any request for the change
to eliminate the 300/600 mile proficiency area that may currently be in
your existing OL's.
Dennis
On 5/25/2011 9:48 AM, A. Dennis Savarese wrote:
> <dsavarese0812@bellsouth.net>
>
> For those that are operating under the older 8130.2F, here is a
> paragraph that is included in all of the groups, including ours, Group
> III. Just for grins, see if there is a paragraph in your own OL's
> that says something like the following".
>
> "....(2) No person may operate this aircraft for other than the
> purpose of meeting the requirements
> of 91.319(b), as stated in the program letter (required by 21.193)
> for this aircraft. This aircraft must
> be operated in accordance with applicable air traffic and general
> operating rules of part 91, as well as all
> additional limitations herein prescribed under the provisions of
> 91.319(e). These operating limitations
> are a part of the special airworthiness certificate, and are to be
> carried in the aircraft at all times
> and made available to the pilot in command of the aircraft.
> (Applicability: All)
> Dennis
>
>
> On 5/25/2011 9:26 AM, Bitterlich, Mark G CIV Det Cherry Point, MALS-14
> 64E wrote:
>> --> Yak-List message posted by: "Bitterlich, Mark G CIV Det Cherry
>> Point, MALS-14 64E"<mark.bitterlich@navy.mil>
>>
>> Just did :-)
>>
>> -----Original Message-----
>> From: owner-yak-list-server@matronics.com
>> [mailto:owner-yak-list-server@matronics.com] On Behalf Of A. Dennis
>> Savarese
>> Sent: Wednesday, May 25, 2011 10:15 AM
>> To: yak-list@matronics.com
>> Subject: Re: Yak-List: Re: Program Letter
>>
>> --> Yak-List message posted by: "A. Dennis Savarese"
>> <dsavarese0812@bellsouth.net>
>>
>> Mark, I respectfully request you read my next posting on the subject.
>> :-)
>>
>> On 5/25/2011 9:04 AM, Bitterlich, Mark G CIV Det Cherry Point, MALS-14
>> 64E wrote:
>>> --> Yak-List message posted by: "Bitterlich, Mark G CIV Det Cherry
>> Point, MALS-14 64E"<mark.bitterlich@navy.mil>
>>> Dennis, I respectfully disagree with your point of view in this one
>>> area.
>>>
>>> You mentioned:
>>>
>>> "The program letter and modifications which you may send by fax are in
>>> fact part of the Operating Limitations for the airplane. We all know
>>> you are required to carry the OL's in the airplane at all times.
>> Since
>>> the Program Letter is actually a part of the OL's, then IMHO, it is
>> also
>>> required to be carried in the airplane."
>>>
>>> The Operating Limitations also require a Conditional Inspection every
>>> year. By the same logic, you would also need to carry along a copy of
>>> your Conditional Inspection, or copies of your aircraft logbooks, etc.
>>> My opinion on dealing with the FAA on things like this is when they
>> say:
>>>
>>> "We need to see a copy of your Program Letter or modification of same,
>>> and if you don't have it with you, you must leave."
>>>
>>> NUMBER ONE: !!! Reply with: "Please quote the Regulation that
>>> specifically states I must carry a copy of my Program Letter with me.
>>> If you cannot quote me the exact regulation that requires me to do
>> this,
>>> I respectfully submit you have no authority to demand it from me".
>>>
>>> You must carry a copy of your Operating Limitations. READ THEM!
>> Break
>>> them out and have the FAA Inspector SHOW YOU on the Operating
>>> Limitations where it says what he is saying. THE BURDON OF PROOF IS
>> ON
>>> THE FAA, not on your to prove you are innocent. Sometimes certain FAA
>>> Inspectors forget that fact. Some Inspectors also assume that
>> anything
>>> they say is automatically correct. Anything you say is automatically
>>> wrong. You need to know your regulations and you also need the phone
>>> number to the EAA's Govt. Hotline. Ask for Randy Hanson.
>>>
>>> NUMBER TWO: If they still play nasty.... Go back to the motel, do a
>>> handwritten modification to your Program Letter on a paper napkin, go
>>> down to the Hotel Desk and FAX IT to your local FISDO. The go back to
>>> the airport and hand that FAA Inspector the paper napkin and bit him a
>>> fond farewell. I am not being sarcastic here. OK. The paper napkin
>>> part is supposed to be a joke (OK who-ever from the FAA READS THIS? A
>>> JOKE! PLEASE? Good grief).
>>>
>>> Not that I think you're wrong about carrying the stuff along. The FAA
>>> CONSTANTLY (!!!) interprets things differently and they can come up
>> with
>>> the strangest things (flying with my door off, etc) and you have to go
>>> to the ends of the Earth to get them to see things a little bit
>>> differently.
>>>
>>> Just saying. I think being polite but not cowardly is the best
>>> approach... my 2 cents.
>>>
>>> Mark
>>>
>>>
>>>
>>>
>>> -----Original Message-----
>>> From: owner-yak-list-server@matronics.com
>>> [mailto:owner-yak-list-server@matronics.com] On Behalf Of A. Dennis
>>> Savarese
>>> Sent: Tuesday, May 24, 2011 10:47 PM
>>> To: yak-list@matronics.com
>>> Subject: Re: Yak-List: Re: Program Letter
>>>
>>> --> Yak-List message posted by: "A. Dennis Savarese"
>>> <dsavarese0812@bellsouth.net>
>>>
>>> Here's something to think about.
>>> The program letter and modifications which you may send by fax are in
>>> fact part of the Operating Limitations for the airplane. We all know
>>> you are required to carry the OL's in the airplane at all times.
>> Since
>>> the Program Letter is actually a part of the OL's, then IMHO, it is
>> also
>>> required to be carried in the airplane.
>>>
>>> Unfortunately, when the FAA removed the 300/600 NM proficiency area,
>>> they failed to include the elimination of the Program Letter, which
>>> would have made logical sense. ie: if you don't have any restrictions
>>> as to where you can fly, they why do you need a Program Letter to
>> attend
>>> an event?
>>>
>>> When you attend an event that may also be attended by the FAA
>> (typically
>>> when there is wavered airspace) and they ask to see your aircraft's
>>> paperwork as well as you pilot certificate and current medical form,
>>> when you hand him/her the aircraft's Operating Limitations he/she will
>>> also ask to see your Program Letter or modification for this specific
>>> event. If you do not have your Program Letter with the specific event
>>> on it or a modification/update to the program letter which you
>> submitted
>>> to your FSDO with you, the FAA person may not permit you to stay at
>> the
>>> event. I had this happen to me about 5 years ago. Thus, when I sent
>>> my program letter in to the FSDO each year, I automatically put a copy
>>> in the airplane along with any modifications.
>>> Dennis
>>>
>>> On 5/24/2011 9:00 PM, keithmckinley wrote:
>>>> --> Yak-List message posted by:
>>> "keithmckinley"<keith.mckinley@townisp.com>
>>>> Mark,
>>>>
>>>> Thanks for the feedback.
>>>>
>>>> No 300 mile restriction. No doubt it is easier to play nice with the
>>> Fed's and yes it does pay dividends, but sometimes I think it's
>>> important to make sure they interpret things correctly and realize
>> (as
>>> inspectors) they don't make the rules. More than anything, I just have
>>> an aversion to ass kissing.......but not to protecting my own ass!
>>>> Semper Fi
>>>>
>>>> Keith
>>>>
>>>> --------
>>>> Keith McKinley
>>>> 700HS
>>>> KFIT
>>>>
>>>>
>>>>
>>>>
>>>> Read this topic online here:
>>>>
>>>> http://forums.matronics.com/viewtopic.php?p=340874#340874
>>>>
>>>>
>>>>
>>>>
>>>>
>>>>
>>>>
>>>>
>>>>
>>>>
>>>>
>>>
>>>
>>>
>>>
>>>
>>>
>>>
>>>
>>
>>
>>
>>
>>
>>
>>
>>
>>
>
>
Message 23
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| Subject: | Re: Program Letter |
Roger that. Your turn to read MY other email. :-)
Love ya, mean it!
And the discussion is pointless really. I have no dog in this fight (per se).
Anyone can do anything they want. If the FAA wants to bust me for not having a
Program Letter in my airplane, let them have at it. Stand in line.
Mark
-----Original Message-----
From: owner-yak-list-server@matronics.com [mailto:owner-yak-list-server@matronics.com] On Behalf Of A. Dennis Savarese
Sent: Wednesday, May 25, 2011 6:35 PM
Subject: Re: Yak-List: Re: Program Letter
Nope! Only the OL's that you have presently.
Dennis
On 5/25/2011 2:26 PM, Bitterlich, Mark G CIV Det Cherry Point, MALS-14
64E wrote:
> --> Yak-List message posted by: "Bitterlich, Mark G CIV Det Cherry Point, MALS-14
64E"<mark.bitterlich@navy.mil>
>
> So does 8130.2G apply to those of us that were issued Special Airworthiness Certificates
under 8130.2F or not?
>
> Mark
>
>
> -----Original Message-----
> From: owner-yak-list-server@matronics.com [mailto:owner-yak-list-server@matronics.com] On Behalf Of A. Dennis Savarese
> Sent: Wednesday, May 25, 2011 11:09 AM
> To: yak-list@matronics.com
> Subject: Re: Yak-List: Re: Program Letter
>
> --> Yak-List message posted by: "A. Dennis Savarese"<dsavarese0812@bellsouth.net>
>
> Any new Special Airworthiness Certificates and Operating Limitations
> will be issued under 8130.2G. This includes any request for the change
> to eliminate the 300/600 mile proficiency area that may currently be in
> your existing OL's.
> Dennis
>
> On 5/25/2011 9:48 AM, A. Dennis Savarese wrote:
>> --> Yak-List message posted by: "A. Dennis Savarese"
>> <dsavarese0812@bellsouth.net>
>>
>> For those that are operating under the older 8130.2F, here is a
>> paragraph that is included in all of the groups, including ours, Group
>> III. Just for grins, see if there is a paragraph in your own OL's
>> that says something like the following".
>>
>> "....(2) No person may operate this aircraft for other than the
>> purpose of meeting the requirements
>> of 91.319(b), as stated in the program letter (required by 21.193)
>> for this aircraft. This aircraft must
>> be operated in accordance with applicable air traffic and general
>> operating rules of part 91, as well as all
>> additional limitations herein prescribed under the provisions of
>> 91.319(e). These operating limitations
>> are a part of the special airworthiness certificate, and are to be
>> carried in the aircraft at all times
>> and made available to the pilot in command of the aircraft.
>> (Applicability: All)
>> Dennis
>>
>>
>> On 5/25/2011 9:26 AM, Bitterlich, Mark G CIV Det Cherry Point, MALS-14
>> 64E wrote:
>>> --> Yak-List message posted by: "Bitterlich, Mark G CIV Det Cherry
>>> Point, MALS-14 64E"<mark.bitterlich@navy.mil>
>>>
>>> Just did :-)
>>>
>>> -----Original Message-----
>>> From: owner-yak-list-server@matronics.com
>>> [mailto:owner-yak-list-server@matronics.com] On Behalf Of A. Dennis
>>> Savarese
>>> Sent: Wednesday, May 25, 2011 10:15 AM
>>> To: yak-list@matronics.com
>>> Subject: Re: Yak-List: Re: Program Letter
>>>
>>> --> Yak-List message posted by: "A. Dennis Savarese"
>>> <dsavarese0812@bellsouth.net>
>>>
>>> Mark, I respectfully request you read my next posting on the subject.
>>> :-)
>>>
>>> On 5/25/2011 9:04 AM, Bitterlich, Mark G CIV Det Cherry Point, MALS-14
>>> 64E wrote:
>>>> --> Yak-List message posted by: "Bitterlich, Mark G CIV Det Cherry
>>> Point, MALS-14 64E"<mark.bitterlich@navy.mil>
>>>> Dennis, I respectfully disagree with your point of view in this one
>>>> area.
>>>>
>>>> You mentioned:
>>>>
>>>> "The program letter and modifications which you may send by fax are in
>>>> fact part of the Operating Limitations for the airplane. We all know
>>>> you are required to carry the OL's in the airplane at all times.
>>> Since
>>>> the Program Letter is actually a part of the OL's, then IMHO, it is
>>> also
>>>> required to be carried in the airplane."
>>>>
>>>> The Operating Limitations also require a Conditional Inspection every
>>>> year. By the same logic, you would also need to carry along a copy of
>>>> your Conditional Inspection, or copies of your aircraft logbooks, etc.
>>>> My opinion on dealing with the FAA on things like this is when they
>>> say:
>>>> "We need to see a copy of your Program Letter or modification of same,
>>>> and if you don't have it with you, you must leave."
>>>>
>>>> NUMBER ONE: !!! Reply with: "Please quote the Regulation that
>>>> specifically states I must carry a copy of my Program Letter with me.
>>>> If you cannot quote me the exact regulation that requires me to do
>>> this,
>>>> I respectfully submit you have no authority to demand it from me".
>>>>
>>>> You must carry a copy of your Operating Limitations. READ THEM!
>>> Break
>>>> them out and have the FAA Inspector SHOW YOU on the Operating
>>>> Limitations where it says what he is saying. THE BURDON OF PROOF IS
>>> ON
>>>> THE FAA, not on your to prove you are innocent. Sometimes certain FAA
>>>> Inspectors forget that fact. Some Inspectors also assume that
>>> anything
>>>> they say is automatically correct. Anything you say is automatically
>>>> wrong. You need to know your regulations and you also need the phone
>>>> number to the EAA's Govt. Hotline. Ask for Randy Hanson.
>>>>
>>>> NUMBER TWO: If they still play nasty.... Go back to the motel, do a
>>>> handwritten modification to your Program Letter on a paper napkin, go
>>>> down to the Hotel Desk and FAX IT to your local FISDO. The go back to
>>>> the airport and hand that FAA Inspector the paper napkin and bit him a
>>>> fond farewell. I am not being sarcastic here. OK. The paper napkin
>>>> part is supposed to be a joke (OK who-ever from the FAA READS THIS? A
>>>> JOKE! PLEASE? Good grief).
>>>>
>>>> Not that I think you're wrong about carrying the stuff along. The FAA
>>>> CONSTANTLY (!!!) interprets things differently and they can come up
>>> with
>>>> the strangest things (flying with my door off, etc) and you have to go
>>>> to the ends of the Earth to get them to see things a little bit
>>>> differently.
>>>>
>>>> Just saying. I think being polite but not cowardly is the best
>>>> approach... my 2 cents.
>>>>
>>>> Mark
>>>>
>>>>
>>>>
>>>>
>>>> -----Original Message-----
>>>> From: owner-yak-list-server@matronics.com
>>>> [mailto:owner-yak-list-server@matronics.com] On Behalf Of A. Dennis
>>>> Savarese
>>>> Sent: Tuesday, May 24, 2011 10:47 PM
>>>> To: yak-list@matronics.com
>>>> Subject: Re: Yak-List: Re: Program Letter
>>>>
>>>> --> Yak-List message posted by: "A. Dennis Savarese"
>>>> <dsavarese0812@bellsouth.net>
>>>>
>>>> Here's something to think about.
>>>> The program letter and modifications which you may send by fax are in
>>>> fact part of the Operating Limitations for the airplane. We all know
>>>> you are required to carry the OL's in the airplane at all times.
>>> Since
>>>> the Program Letter is actually a part of the OL's, then IMHO, it is
>>> also
>>>> required to be carried in the airplane.
>>>>
>>>> Unfortunately, when the FAA removed the 300/600 NM proficiency area,
>>>> they failed to include the elimination of the Program Letter, which
>>>> would have made logical sense. ie: if you don't have any restrictions
>>>> as to where you can fly, they why do you need a Program Letter to
>>> attend
>>>> an event?
>>>>
>>>> When you attend an event that may also be attended by the FAA
>>> (typically
>>>> when there is wavered airspace) and they ask to see your aircraft's
>>>> paperwork as well as you pilot certificate and current medical form,
>>>> when you hand him/her the aircraft's Operating Limitations he/she will
>>>> also ask to see your Program Letter or modification for this specific
>>>> event. If you do not have your Program Letter with the specific event
>>>> on it or a modification/update to the program letter which you
>>> submitted
>>>> to your FSDO with you, the FAA person may not permit you to stay at
>>> the
>>>> event. I had this happen to me about 5 years ago. Thus, when I sent
>>>> my program letter in to the FSDO each year, I automatically put a copy
>>>> in the airplane along with any modifications.
>>>> Dennis
>>>>
>>>> On 5/24/2011 9:00 PM, keithmckinley wrote:
>>>>> --> Yak-List message posted by:
>>>> "keithmckinley"<keith.mckinley@townisp.com>
>>>>> Mark,
>>>>>
>>>>> Thanks for the feedback.
>>>>>
>>>>> No 300 mile restriction. No doubt it is easier to play nice with the
>>>> Fed's and yes it does pay dividends, but sometimes I think it's
>>>> important to make sure they interpret things correctly and realize
>>> (as
>>>> inspectors) they don't make the rules. More than anything, I just have
>>>> an aversion to ass kissing.......but not to protecting my own ass!
>>>>> Semper Fi
>>>>>
>>>>> Keith
>>>>>
>>>>> --------
>>>>> Keith McKinley
>>>>> 700HS
>>>>> KFIT
>>>>>
>>>>>
>>>>>
>>>>>
>>>>> Read this topic online here:
>>>>>
>>>>> http://forums.matronics.com/viewtopic.php?p=340874#340874
>>>>>
>>>>>
>>>>>
>>>>>
>>>>>
>>>>>
>>>>>
>>>>>
>>>>>
>>>>>
>>>>>
>>>>
>>>>
>>>>
>>>>
>>>>
>>>>
>>>>
>>>
>>>
>>>
>>>
>>>
>>>
>>>
>>>
>>
>>
>>
>>
>
>
Message 24
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|
| Subject: | Re: Program Letter |
Roger that.
The only thing I wanted to know really was: "Does this apply to me".
Answer so far: "No it does not".
Sad thing is that if I ever get another Experimental Exhibition aircraft, that
requires a new Special Airworthiness Certificate, it most definitely will.
SIGH!
Mark
-----Original Message-----
From: owner-yak-list-server@matronics.com [mailto:owner-yak-list-server@matronics.com] On Behalf Of A. Dennis Savarese
Sent: Wednesday, May 25, 2011 6:34 PM
Subject: Re: Yak-List: Re: Program Letter
I agree. It does not say you have to carry your Program Letter. That
is why I posted it so as to compare to the new 8130.2G.
Dennis
On 5/25/2011 2:25 PM, Bitterlich, Mark G CIV Det Cherry Point, MALS-14
64E wrote:
> --> Yak-List message posted by: "Bitterlich, Mark G CIV Det Cherry Point, MALS-14
64E"<mark.bitterlich@navy.mil>
>
> Yes, but that does not say you have to carry your Program Letter Dennis. It
says you have to carry your OPERATING LIMITATIONS in the aircraft.
>
> Just FYI, under the OLD rules .... I contacted the EAA and the local FAA, the
Montana FAA, the Seattle FAA and all of them said you did NOT have to carry your
program letter with you. I am sure you were told that you did have to.
>
> It falls into the "whatever you feel is right category" and it also fell into
"who interprets the rules" category.
>
> On the other hand, the new rules you just posted are a whole different thing.
I read them, they seem quite clear! That said, I never EVER take what ANYONE
says on the Yak List regarding rules and regulations as gospel. Even when I
read things myself! I always ask for second opinions, third opinions, and even
FORTH opinions! I always dig very deeply when it comes to rules.
>
> I sent your quote to the EAA Government Division (Randy Hanson) for confirmation
or interpretation. As I said, what you posted seems very clear and is a definite
change in policy and adds a new requirement to all of us. But I'll still
be interested in what the EAA says.
>
>
> Mark
>
>
> -----Original Message-----
> From: owner-yak-list-server@matronics.com [mailto:owner-yak-list-server@matronics.com] On Behalf Of A. Dennis Savarese
> Sent: Wednesday, May 25, 2011 10:49 AM
> To: yak-list@matronics.com
> Subject: Re: Yak-List: Re: Program Letter
>
> --> Yak-List message posted by: "A. Dennis Savarese"<dsavarese0812@bellsouth.net>
>
> For those that are operating under the older 8130.2F, here is a
> paragraph that is included in all of the groups, including ours, Group
> III. Just for grins, see if there is a paragraph in your own OL's that
> says something like the following".
>
> "....(2) No person may operate this aircraft for other than the purpose
> of meeting the requirements
> of 91.319(b), as stated in the program letter (required by 21.193)
> for this aircraft. This aircraft must
> be operated in accordance with applicable air traffic and general
> operating rules of part 91, as well as all
> additional limitations herein prescribed under the provisions of
> 91.319(e). These operating limitations
> are a part of the special airworthiness certificate, and are to be
> carried in the aircraft at all times
> and made available to the pilot in command of the aircraft.
> (Applicability: All)
> Dennis
>
>
> On 5/25/2011 9:26 AM, Bitterlich, Mark G CIV Det Cherry Point, MALS-14
> 64E wrote:
>> --> Yak-List message posted by: "Bitterlich, Mark G CIV Det Cherry Point,
MALS-14 64E"<mark.bitterlich@navy.mil>
>>
>> Just did :-)
>>
>> -----Original Message-----
>> From: owner-yak-list-server@matronics.com
>> [mailto:owner-yak-list-server@matronics.com] On Behalf Of A. Dennis
>> Savarese
>> Sent: Wednesday, May 25, 2011 10:15 AM
>> To: yak-list@matronics.com
>> Subject: Re: Yak-List: Re: Program Letter
>>
>> --> Yak-List message posted by: "A. Dennis Savarese"
>> <dsavarese0812@bellsouth.net>
>>
>> Mark, I respectfully request you read my next posting on the subject.
>> :-)
>>
>> On 5/25/2011 9:04 AM, Bitterlich, Mark G CIV Det Cherry Point, MALS-14
>> 64E wrote:
>>> --> Yak-List message posted by: "Bitterlich, Mark G CIV Det Cherry
>> Point, MALS-14 64E"<mark.bitterlich@navy.mil>
>>> Dennis, I respectfully disagree with your point of view in this one
>>> area.
>>>
>>> You mentioned:
>>>
>>> "The program letter and modifications which you may send by fax are in
>>> fact part of the Operating Limitations for the airplane. We all know
>>> you are required to carry the OL's in the airplane at all times.
>> Since
>>> the Program Letter is actually a part of the OL's, then IMHO, it is
>> also
>>> required to be carried in the airplane."
>>>
>>> The Operating Limitations also require a Conditional Inspection every
>>> year. By the same logic, you would also need to carry along a copy of
>>> your Conditional Inspection, or copies of your aircraft logbooks, etc.
>>> My opinion on dealing with the FAA on things like this is when they
>> say:
>>> "We need to see a copy of your Program Letter or modification of same,
>>> and if you don't have it with you, you must leave."
>>>
>>> NUMBER ONE: !!! Reply with: "Please quote the Regulation that
>>> specifically states I must carry a copy of my Program Letter with me.
>>> If you cannot quote me the exact regulation that requires me to do
>> this,
>>> I respectfully submit you have no authority to demand it from me".
>>>
>>> You must carry a copy of your Operating Limitations. READ THEM!
>> Break
>>> them out and have the FAA Inspector SHOW YOU on the Operating
>>> Limitations where it says what he is saying. THE BURDON OF PROOF IS
>> ON
>>> THE FAA, not on your to prove you are innocent. Sometimes certain FAA
>>> Inspectors forget that fact. Some Inspectors also assume that
>> anything
>>> they say is automatically correct. Anything you say is automatically
>>> wrong. You need to know your regulations and you also need the phone
>>> number to the EAA's Govt. Hotline. Ask for Randy Hanson.
>>>
>>> NUMBER TWO: If they still play nasty.... Go back to the motel, do a
>>> handwritten modification to your Program Letter on a paper napkin, go
>>> down to the Hotel Desk and FAX IT to your local FISDO. The go back to
>>> the airport and hand that FAA Inspector the paper napkin and bit him a
>>> fond farewell. I am not being sarcastic here. OK. The paper napkin
>>> part is supposed to be a joke (OK who-ever from the FAA READS THIS? A
>>> JOKE! PLEASE? Good grief).
>>>
>>> Not that I think you're wrong about carrying the stuff along. The FAA
>>> CONSTANTLY (!!!) interprets things differently and they can come up
>> with
>>> the strangest things (flying with my door off, etc) and you have to go
>>> to the ends of the Earth to get them to see things a little bit
>>> differently.
>>>
>>> Just saying. I think being polite but not cowardly is the best
>>> approach... my 2 cents.
>>>
>>> Mark
>>>
>>>
>>>
>>>
>>> -----Original Message-----
>>> From: owner-yak-list-server@matronics.com
>>> [mailto:owner-yak-list-server@matronics.com] On Behalf Of A. Dennis
>>> Savarese
>>> Sent: Tuesday, May 24, 2011 10:47 PM
>>> To: yak-list@matronics.com
>>> Subject: Re: Yak-List: Re: Program Letter
>>>
>>> --> Yak-List message posted by: "A. Dennis Savarese"
>>> <dsavarese0812@bellsouth.net>
>>>
>>> Here's something to think about.
>>> The program letter and modifications which you may send by fax are in
>>> fact part of the Operating Limitations for the airplane. We all know
>>> you are required to carry the OL's in the airplane at all times.
>> Since
>>> the Program Letter is actually a part of the OL's, then IMHO, it is
>> also
>>> required to be carried in the airplane.
>>>
>>> Unfortunately, when the FAA removed the 300/600 NM proficiency area,
>>> they failed to include the elimination of the Program Letter, which
>>> would have made logical sense. ie: if you don't have any restrictions
>>> as to where you can fly, they why do you need a Program Letter to
>> attend
>>> an event?
>>>
>>> When you attend an event that may also be attended by the FAA
>> (typically
>>> when there is wavered airspace) and they ask to see your aircraft's
>>> paperwork as well as you pilot certificate and current medical form,
>>> when you hand him/her the aircraft's Operating Limitations he/she will
>>> also ask to see your Program Letter or modification for this specific
>>> event. If you do not have your Program Letter with the specific event
>>> on it or a modification/update to the program letter which you
>> submitted
>>> to your FSDO with you, the FAA person may not permit you to stay at
>> the
>>> event. I had this happen to me about 5 years ago. Thus, when I sent
>>> my program letter in to the FSDO each year, I automatically put a copy
>>> in the airplane along with any modifications.
>>> Dennis
>>>
>>> On 5/24/2011 9:00 PM, keithmckinley wrote:
>>>> --> Yak-List message posted by:
>>> "keithmckinley"<keith.mckinley@townisp.com>
>>>> Mark,
>>>>
>>>> Thanks for the feedback.
>>>>
>>>> No 300 mile restriction. No doubt it is easier to play nice with the
>>> Fed's and yes it does pay dividends, but sometimes I think it's
>>> important to make sure they interpret things correctly and realize
>> (as
>>> inspectors) they don't make the rules. More than anything, I just have
>>> an aversion to ass kissing.......but not to protecting my own ass!
>>>> Semper Fi
>>>>
>>>> Keith
>>>>
>>>> --------
>>>> Keith McKinley
>>>> 700HS
>>>> KFIT
>>>>
>>>>
>>>>
>>>>
>>>> Read this topic online here:
>>>>
>>>> http://forums.matronics.com/viewtopic.php?p=340874#340874
>>>>
>>>>
>>>>
>>>>
>>>>
>>>>
>>>>
>>>>
>>>>
>>>>
>>>>
>>>
>>>
>>>
>>>
>>>
>>>
>>>
>>
>>
>>
>>
>>
>>
>>
>>
>
>
Message 25
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| Subject: | Re: Program Letter |
Ok.
I was wrong. The light bulb just went on.
Dennis, you are/were absolutely correct.
If you change your Operating Limitations in ANY way, that means you also are going
to HAVE to obtain a new Special Airworthiness Certificate because the dates
on the two documents MUST MATCH! Darn it, I hate when that happens, but I do
pride myself on at least being able to stand up and admit when I screw up.
So... you change the Operating Limitations, you must get a new Airworthiness Certificate
along with it, and since it ALSO is new, 8130.2G will probably apply.
I say "probably" because I don't even trust my own judgment when it comes to FAA
regulations, and I am not going to bother the EAA anymore with this.
Mark Bitterlich
-----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: Wednesday, May 25, 2011 6:37 PM
Subject: RE: Yak-List: Re: Program Letter
Here is how the EAA Govt. Liason Division interprets these rules. These people
talk to those that MAKE the rules, not to local FISDO's that INTERPRET the rules.
Thus I consider the EAA to be the best experts available unless you know someone
in Washington DC that works for the FAA.
And the answer the EAA writes below is EXACTLY why I took this issue up the chain
to get a better understanding.
What Dennis wrote is of course absolutely correct... he just didn't mention 8130.2G,
paragraph 4107
And Dennis, I also (respectfully :-) once more disagree when you mention that
any changes made to CURRENT Operating Limitations will result in you now being
required to fall under 8130.2G, and thus get a whole NEW set of Operating Limitations.
New Airworthiness Certificate .... yes. 8130.2G applies, and you will get all
new Operating Limitations and ... you will be required to carry your Program Letter
with you, etc.
Removal of an Operating Limitation from an EXISTING list of Operating Limitations
attached to an EXISTING Experimental Airworthiness Certificate written under
8130.2F .... NO!
Mark Bitterlich
p.s. For a complete understanding read the response from the EAA contained below.
-----Original Message-----
From: Randy Hansen [mailto:rhansen@eaa.org]
Sent: Wednesday, May 25, 2011 4:07 PM
Subject: RE: Yak-List: Re: Program Letter
Mark, this is an issue that may differ from aircraft to aircraft based
on the issued operating limitations -
The FAR baseline for this requirement is FAR 21.193 - it says a program
letter must be submitted, it does not mention a annual requirement.
The second baseline is FAR 91.319(i) - it says the administrator may
prescribe additional limitations the administrator feels necessary.
**this means the FAA can change to operating limitations as
necessary to address and resolve safety and operations issues.
FAA Order 8130.2F (effective Nov 2004 - April 2011), limitation (37) -
the operator must submit an annual program letter.
**no requirement that the program letter must be carried on
board.
FAA Order 8130.2G (effective April 2011 - present), limitation (3) the
operator must submit an annual program letter...and a copy of the
program letter and any amendments must be carried on board the aircraft
any time that the aircraft is being operated.
**carrying the program letter is a new requirement.
FAA Order 8130.2G, paragraph 4107 d - states that "all previously issued
airworthiness certificates and operating limitations will remain valid
unless changes are requested by the applicant or reexamined by the FAA
in accordance with 49 U.S.C. 44709."
Bottom line - If your airworthiness certificate and operating
limitations were issued under an earlier edition of 8130.2 (editions A,
B, C, D. E, or F) then you do not have a requirement to carry a program
letter on board the aircraft. And since there is NO requirement to turn
in your existing documents for a new version issued under the new
8130.2G, you do not need to carry your program letter. This new
requirement will only apply to those experimental exhibition aircraft
issued an original airworthiness certificate on/after April 11, 2011.
-----Original Message-----
From: owner-yak-list-server@matronics.com [mailto:owner-yak-list-server@matronics.com] On Behalf Of A. Dennis Savarese
Sent: Wednesday, May 25, 2011 11:09 AM
Subject: Re: Yak-List: Re: Program Letter
Any new Special Airworthiness Certificates and Operating Limitations
will be issued under 8130.2G. This includes any request for the change
to eliminate the 300/600 mile proficiency area that may currently be in
your existing OL's.
Dennis
On 5/25/2011 9:48 AM, A. Dennis Savarese wrote:
> <dsavarese0812@bellsouth.net>
>
> For those that are operating under the older 8130.2F, here is a
> paragraph that is included in all of the groups, including ours, Group
> III. Just for grins, see if there is a paragraph in your own OL's
> that says something like the following".
>
> "....(2) No person may operate this aircraft for other than the
> purpose of meeting the requirements
> of 91.319(b), as stated in the program letter (required by 21.193)
> for this aircraft. This aircraft must
> be operated in accordance with applicable air traffic and general
> operating rules of part 91, as well as all
> additional limitations herein prescribed under the provisions of
> 91.319(e). These operating limitations
> are a part of the special airworthiness certificate, and are to be
> carried in the aircraft at all times
> and made available to the pilot in command of the aircraft.
> (Applicability: All)
> Dennis
>
>
> On 5/25/2011 9:26 AM, Bitterlich, Mark G CIV Det Cherry Point, MALS-14
> 64E wrote:
>> --> Yak-List message posted by: "Bitterlich, Mark G CIV Det Cherry
>> Point, MALS-14 64E"<mark.bitterlich@navy.mil>
>>
>> Just did :-)
>>
>> -----Original Message-----
>> From: owner-yak-list-server@matronics.com
>> [mailto:owner-yak-list-server@matronics.com] On Behalf Of A. Dennis
>> Savarese
>> Sent: Wednesday, May 25, 2011 10:15 AM
>> To: yak-list@matronics.com
>> Subject: Re: Yak-List: Re: Program Letter
>>
>> --> Yak-List message posted by: "A. Dennis Savarese"
>> <dsavarese0812@bellsouth.net>
>>
>> Mark, I respectfully request you read my next posting on the subject.
>> :-)
>>
>> On 5/25/2011 9:04 AM, Bitterlich, Mark G CIV Det Cherry Point, MALS-14
>> 64E wrote:
>>> --> Yak-List message posted by: "Bitterlich, Mark G CIV Det Cherry
>> Point, MALS-14 64E"<mark.bitterlich@navy.mil>
>>> Dennis, I respectfully disagree with your point of view in this one
>>> area.
>>>
>>> You mentioned:
>>>
>>> "The program letter and modifications which you may send by fax are in
>>> fact part of the Operating Limitations for the airplane. We all know
>>> you are required to carry the OL's in the airplane at all times.
>> Since
>>> the Program Letter is actually a part of the OL's, then IMHO, it is
>> also
>>> required to be carried in the airplane."
>>>
>>> The Operating Limitations also require a Conditional Inspection every
>>> year. By the same logic, you would also need to carry along a copy of
>>> your Conditional Inspection, or copies of your aircraft logbooks, etc.
>>> My opinion on dealing with the FAA on things like this is when they
>> say:
>>>
>>> "We need to see a copy of your Program Letter or modification of same,
>>> and if you don't have it with you, you must leave."
>>>
>>> NUMBER ONE: !!! Reply with: "Please quote the Regulation that
>>> specifically states I must carry a copy of my Program Letter with me.
>>> If you cannot quote me the exact regulation that requires me to do
>> this,
>>> I respectfully submit you have no authority to demand it from me".
>>>
>>> You must carry a copy of your Operating Limitations. READ THEM!
>> Break
>>> them out and have the FAA Inspector SHOW YOU on the Operating
>>> Limitations where it says what he is saying. THE BURDON OF PROOF IS
>> ON
>>> THE FAA, not on your to prove you are innocent. Sometimes certain FAA
>>> Inspectors forget that fact. Some Inspectors also assume that
>> anything
>>> they say is automatically correct. Anything you say is automatically
>>> wrong. You need to know your regulations and you also need the phone
>>> number to the EAA's Govt. Hotline. Ask for Randy Hanson.
>>>
>>> NUMBER TWO: If they still play nasty.... Go back to the motel, do a
>>> handwritten modification to your Program Letter on a paper napkin, go
>>> down to the Hotel Desk and FAX IT to your local FISDO. The go back to
>>> the airport and hand that FAA Inspector the paper napkin and bit him a
>>> fond farewell. I am not being sarcastic here. OK. The paper napkin
>>> part is supposed to be a joke (OK who-ever from the FAA READS THIS? A
>>> JOKE! PLEASE? Good grief).
>>>
>>> Not that I think you're wrong about carrying the stuff along. The FAA
>>> CONSTANTLY (!!!) interprets things differently and they can come up
>> with
>>> the strangest things (flying with my door off, etc) and you have to go
>>> to the ends of the Earth to get them to see things a little bit
>>> differently.
>>>
>>> Just saying. I think being polite but not cowardly is the best
>>> approach... my 2 cents.
>>>
>>> Mark
>>>
>>>
>>>
>>>
>>> -----Original Message-----
>>> From: owner-yak-list-server@matronics.com
>>> [mailto:owner-yak-list-server@matronics.com] On Behalf Of A. Dennis
>>> Savarese
>>> Sent: Tuesday, May 24, 2011 10:47 PM
>>> To: yak-list@matronics.com
>>> Subject: Re: Yak-List: Re: Program Letter
>>>
>>> --> Yak-List message posted by: "A. Dennis Savarese"
>>> <dsavarese0812@bellsouth.net>
>>>
>>> Here's something to think about.
>>> The program letter and modifications which you may send by fax are in
>>> fact part of the Operating Limitations for the airplane. We all know
>>> you are required to carry the OL's in the airplane at all times.
>> Since
>>> the Program Letter is actually a part of the OL's, then IMHO, it is
>> also
>>> required to be carried in the airplane.
>>>
>>> Unfortunately, when the FAA removed the 300/600 NM proficiency area,
>>> they failed to include the elimination of the Program Letter, which
>>> would have made logical sense. ie: if you don't have any restrictions
>>> as to where you can fly, they why do you need a Program Letter to
>> attend
>>> an event?
>>>
>>> When you attend an event that may also be attended by the FAA
>> (typically
>>> when there is wavered airspace) and they ask to see your aircraft's
>>> paperwork as well as you pilot certificate and current medical form,
>>> when you hand him/her the aircraft's Operating Limitations he/she will
>>> also ask to see your Program Letter or modification for this specific
>>> event. If you do not have your Program Letter with the specific event
>>> on it or a modification/update to the program letter which you
>> submitted
>>> to your FSDO with you, the FAA person may not permit you to stay at
>> the
>>> event. I had this happen to me about 5 years ago. Thus, when I sent
>>> my program letter in to the FSDO each year, I automatically put a copy
>>> in the airplane along with any modifications.
>>> Dennis
>>>
>>> On 5/24/2011 9:00 PM, keithmckinley wrote:
>>>> --> Yak-List message posted by:
>>> "keithmckinley"<keith.mckinley@townisp.com>
>>>> Mark,
>>>>
>>>> Thanks for the feedback.
>>>>
>>>> No 300 mile restriction. No doubt it is easier to play nice with the
>>> Fed's and yes it does pay dividends, but sometimes I think it's
>>> important to make sure they interpret things correctly and realize
>> (as
>>> inspectors) they don't make the rules. More than anything, I just have
>>> an aversion to ass kissing.......but not to protecting my own ass!
>>>> Semper Fi
>>>>
>>>> Keith
>>>>
>>>> --------
>>>> Keith McKinley
>>>> 700HS
>>>> KFIT
>>>>
>>>>
>>>>
>>>>
>>>> Read this topic online here:
>>>>
>>>> http://forums.matronics.com/viewtopic.php?p=340874#340874
>>>>
>>>>
>>>>
>>>>
>>>>
>>>>
>>>>
>>>>
>>>>
>>>>
>>>>
>>>
>>>
>>>
>>>
>>>
>>>
>>>
>>>
>>
>>
>>
>>
>>
>>
>>
>>
>>
>
>
Message 26
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| LIST | Reply to LIST Regarding this Message |
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|
| Subject: | Re: Program Letter |
And you know what? It just never ends. Just when I thought I had made a mistake,
I might have been wrong. :-)
Read this:
8130.2G says:
(37) When an aircraft's home base is changed or there is a transfer of ownership,
the
new owner/operator will take any or all of the following actions within 30 days:
(a) Submit a new program letter to the geographically responsible FSDO.
(b) If an approved inspection program is specified in these operating limitations,
submit a copy to the geographically responsible FSDO. The gaining FSDO will not
change the
previously approved program unless it can be substantiated that the previously
approved program
no longer meets FAA requirements.
(c) The gaining FSDO will not require the aircraft's airworthiness certificate
or
operating limitations to be reissued, unless the aircraft requires Phase I test
flight operations.
So, I would read that to mean that they won't change the Operating Limitations.
The whole thing is a crock of dog poop. Who knows for sure WHAT anything means.
Good luck... Mark's out of this one. ENOUGH already. I quit.
-----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: Wednesday, May 25, 2011 6:54 PM
Subject: RE: Yak-List: Re: Program Letter
Ok.
I was wrong. The light bulb just went on.
Dennis, you are/were absolutely correct.
If you change your Operating Limitations in ANY way, that means you also are going
to HAVE to obtain a new Special Airworthiness Certificate because the dates
on the two documents MUST MATCH! Darn it, I hate when that happens, but I do
pride myself on at least being able to stand up and admit when I screw up.
So... you change the Operating Limitations, you must get a new Airworthiness Certificate
along with it, and since it ALSO is new, 8130.2G will probably apply.
I say "probably" because I don't even trust my own judgment when it comes to FAA
regulations, and I am not going to bother the EAA anymore with this.
Mark Bitterlich
-----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: Wednesday, May 25, 2011 6:37 PM
Subject: RE: Yak-List: Re: Program Letter
Here is how the EAA Govt. Liason Division interprets these rules. These people
talk to those that MAKE the rules, not to local FISDO's that INTERPRET the rules.
Thus I consider the EAA to be the best experts available unless you know someone
in Washington DC that works for the FAA.
And the answer the EAA writes below is EXACTLY why I took this issue up the chain
to get a better understanding.
What Dennis wrote is of course absolutely correct... he just didn't mention 8130.2G,
paragraph 4107
And Dennis, I also (respectfully :-) once more disagree when you mention that
any changes made to CURRENT Operating Limitations will result in you now being
required to fall under 8130.2G, and thus get a whole NEW set of Operating Limitations.
New Airworthiness Certificate .... yes. 8130.2G applies, and you will get all
new Operating Limitations and ... you will be required to carry your Program Letter
with you, etc.
Removal of an Operating Limitation from an EXISTING list of Operating Limitations
attached to an EXISTING Experimental Airworthiness Certificate written under
8130.2F .... NO!
Mark Bitterlich
p.s. For a complete understanding read the response from the EAA contained below.
-----Original Message-----
From: Randy Hansen [mailto:rhansen@eaa.org]
Sent: Wednesday, May 25, 2011 4:07 PM
Subject: RE: Yak-List: Re: Program Letter
Mark, this is an issue that may differ from aircraft to aircraft based
on the issued operating limitations -
The FAR baseline for this requirement is FAR 21.193 - it says a program
letter must be submitted, it does not mention a annual requirement.
The second baseline is FAR 91.319(i) - it says the administrator may
prescribe additional limitations the administrator feels necessary.
**this means the FAA can change to operating limitations as
necessary to address and resolve safety and operations issues.
FAA Order 8130.2F (effective Nov 2004 - April 2011), limitation (37) -
the operator must submit an annual program letter.
**no requirement that the program letter must be carried on
board.
FAA Order 8130.2G (effective April 2011 - present), limitation (3) the
operator must submit an annual program letter...and a copy of the
program letter and any amendments must be carried on board the aircraft
any time that the aircraft is being operated.
**carrying the program letter is a new requirement.
FAA Order 8130.2G, paragraph 4107 d - states that "all previously issued
airworthiness certificates and operating limitations will remain valid
unless changes are requested by the applicant or reexamined by the FAA
in accordance with 49 U.S.C. 44709."
Bottom line - If your airworthiness certificate and operating
limitations were issued under an earlier edition of 8130.2 (editions A,
B, C, D. E, or F) then you do not have a requirement to carry a program
letter on board the aircraft. And since there is NO requirement to turn
in your existing documents for a new version issued under the new
8130.2G, you do not need to carry your program letter. This new
requirement will only apply to those experimental exhibition aircraft
issued an original airworthiness certificate on/after April 11, 2011.
-----Original Message-----
From: owner-yak-list-server@matronics.com [mailto:owner-yak-list-server@matronics.com] On Behalf Of A. Dennis Savarese
Sent: Wednesday, May 25, 2011 11:09 AM
Subject: Re: Yak-List: Re: Program Letter
Any new Special Airworthiness Certificates and Operating Limitations
will be issued under 8130.2G. This includes any request for the change
to eliminate the 300/600 mile proficiency area that may currently be in
your existing OL's.
Dennis
On 5/25/2011 9:48 AM, A. Dennis Savarese wrote:
> <dsavarese0812@bellsouth.net>
>
> For those that are operating under the older 8130.2F, here is a
> paragraph that is included in all of the groups, including ours, Group
> III. Just for grins, see if there is a paragraph in your own OL's
> that says something like the following".
>
> "....(2) No person may operate this aircraft for other than the
> purpose of meeting the requirements
> of 91.319(b), as stated in the program letter (required by 21.193)
> for this aircraft. This aircraft must
> be operated in accordance with applicable air traffic and general
> operating rules of part 91, as well as all
> additional limitations herein prescribed under the provisions of
> 91.319(e). These operating limitations
> are a part of the special airworthiness certificate, and are to be
> carried in the aircraft at all times
> and made available to the pilot in command of the aircraft.
> (Applicability: All)
> Dennis
>
>
> On 5/25/2011 9:26 AM, Bitterlich, Mark G CIV Det Cherry Point, MALS-14
> 64E wrote:
>> --> Yak-List message posted by: "Bitterlich, Mark G CIV Det Cherry
>> Point, MALS-14 64E"<mark.bitterlich@navy.mil>
>>
>> Just did :-)
>>
>> -----Original Message-----
>> From: owner-yak-list-server@matronics.com
>> [mailto:owner-yak-list-server@matronics.com] On Behalf Of A. Dennis
>> Savarese
>> Sent: Wednesday, May 25, 2011 10:15 AM
>> To: yak-list@matronics.com
>> Subject: Re: Yak-List: Re: Program Letter
>>
>> --> Yak-List message posted by: "A. Dennis Savarese"
>> <dsavarese0812@bellsouth.net>
>>
>> Mark, I respectfully request you read my next posting on the subject.
>> :-)
>>
>> On 5/25/2011 9:04 AM, Bitterlich, Mark G CIV Det Cherry Point, MALS-14
>> 64E wrote:
>>> --> Yak-List message posted by: "Bitterlich, Mark G CIV Det Cherry
>> Point, MALS-14 64E"<mark.bitterlich@navy.mil>
>>> Dennis, I respectfully disagree with your point of view in this one
>>> area.
>>>
>>> You mentioned:
>>>
>>> "The program letter and modifications which you may send by fax are in
>>> fact part of the Operating Limitations for the airplane. We all know
>>> you are required to carry the OL's in the airplane at all times.
>> Since
>>> the Program Letter is actually a part of the OL's, then IMHO, it is
>> also
>>> required to be carried in the airplane."
>>>
>>> The Operating Limitations also require a Conditional Inspection every
>>> year. By the same logic, you would also need to carry along a copy of
>>> your Conditional Inspection, or copies of your aircraft logbooks, etc.
>>> My opinion on dealing with the FAA on things like this is when they
>> say:
>>>
>>> "We need to see a copy of your Program Letter or modification of same,
>>> and if you don't have it with you, you must leave."
>>>
>>> NUMBER ONE: !!! Reply with: "Please quote the Regulation that
>>> specifically states I must carry a copy of my Program Letter with me.
>>> If you cannot quote me the exact regulation that requires me to do
>> this,
>>> I respectfully submit you have no authority to demand it from me".
>>>
>>> You must carry a copy of your Operating Limitations. READ THEM!
>> Break
>>> them out and have the FAA Inspector SHOW YOU on the Operating
>>> Limitations where it says what he is saying. THE BURDON OF PROOF IS
>> ON
>>> THE FAA, not on your to prove you are innocent. Sometimes certain FAA
>>> Inspectors forget that fact. Some Inspectors also assume that
>> anything
>>> they say is automatically correct. Anything you say is automatically
>>> wrong. You need to know your regulations and you also need the phone
>>> number to the EAA's Govt. Hotline. Ask for Randy Hanson.
>>>
>>> NUMBER TWO: If they still play nasty.... Go back to the motel, do a
>>> handwritten modification to your Program Letter on a paper napkin, go
>>> down to the Hotel Desk and FAX IT to your local FISDO. The go back to
>>> the airport and hand that FAA Inspector the paper napkin and bit him a
>>> fond farewell. I am not being sarcastic here. OK. The paper napkin
>>> part is supposed to be a joke (OK who-ever from the FAA READS THIS? A
>>> JOKE! PLEASE? Good grief).
>>>
>>> Not that I think you're wrong about carrying the stuff along. The FAA
>>> CONSTANTLY (!!!) interprets things differently and they can come up
>> with
>>> the strangest things (flying with my door off, etc) and you have to go
>>> to the ends of the Earth to get them to see things a little bit
>>> differently.
>>>
>>> Just saying. I think being polite but not cowardly is the best
>>> approach... my 2 cents.
>>>
>>> Mark
>>>
>>>
>>>
>>>
>>> -----Original Message-----
>>> From: owner-yak-list-server@matronics.com
>>> [mailto:owner-yak-list-server@matronics.com] On Behalf Of A. Dennis
>>> Savarese
>>> Sent: Tuesday, May 24, 2011 10:47 PM
>>> To: yak-list@matronics.com
>>> Subject: Re: Yak-List: Re: Program Letter
>>>
>>> --> Yak-List message posted by: "A. Dennis Savarese"
>>> <dsavarese0812@bellsouth.net>
>>>
>>> Here's something to think about.
>>> The program letter and modifications which you may send by fax are in
>>> fact part of the Operating Limitations for the airplane. We all know
>>> you are required to carry the OL's in the airplane at all times.
>> Since
>>> the Program Letter is actually a part of the OL's, then IMHO, it is
>> also
>>> required to be carried in the airplane.
>>>
>>> Unfortunately, when the FAA removed the 300/600 NM proficiency area,
>>> they failed to include the elimination of the Program Letter, which
>>> would have made logical sense. ie: if you don't have any restrictions
>>> as to where you can fly, they why do you need a Program Letter to
>> attend
>>> an event?
>>>
>>> When you attend an event that may also be attended by the FAA
>> (typically
>>> when there is wavered airspace) and they ask to see your aircraft's
>>> paperwork as well as you pilot certificate and current medical form,
>>> when you hand him/her the aircraft's Operating Limitations he/she will
>>> also ask to see your Program Letter or modification for this specific
>>> event. If you do not have your Program Letter with the specific event
>>> on it or a modification/update to the program letter which you
>> submitted
>>> to your FSDO with you, the FAA person may not permit you to stay at
>> the
>>> event. I had this happen to me about 5 years ago. Thus, when I sent
>>> my program letter in to the FSDO each year, I automatically put a copy
>>> in the airplane along with any modifications.
>>> Dennis
>>>
>>> On 5/24/2011 9:00 PM, keithmckinley wrote:
>>>> --> Yak-List message posted by:
>>> "keithmckinley"<keith.mckinley@townisp.com>
>>>> Mark,
>>>>
>>>> Thanks for the feedback.
>>>>
>>>> No 300 mile restriction. No doubt it is easier to play nice with the
>>> Fed's and yes it does pay dividends, but sometimes I think it's
>>> important to make sure they interpret things correctly and realize
>> (as
>>> inspectors) they don't make the rules. More than anything, I just have
>>> an aversion to ass kissing.......but not to protecting my own ass!
>>>> Semper Fi
>>>>
>>>> Keith
>>>>
>>>> --------
>>>> Keith McKinley
>>>> 700HS
>>>> KFIT
>>>>
>>>>
>>>>
>>>>
>>>> Read this topic online here:
>>>>
>>>> http://forums.matronics.com/viewtopic.php?p=340874#340874
>>>>
>>>>
>>>>
>>>>
>>>>
>>>>
>>>>
>>>>
>>>>
>>>>
>>>>
>>>
>>>
>>>
>>>
>>>
>>>
>>>
>>>
>>
>>
>>
>>
>>
>>
>>
>>
>>
>
>
Message 27
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| PREVIOUS | Skip to PREVIOUS Message |
| NEXT | Skip to NEXT Message |
| LIST | Reply to LIST Regarding this Message |
| SENDER | Reply to SENDER Regarding this Message |
|
| Subject: | Re: Program Letter |
Wow!!! Just when I was ready to sell you some propeller blades!!
----- Original Message -----
From: "Bitterlich, Mark G CIV Det Cherry Point, MALS-14 64E"
<mark.bitterlich@navy.mil>
Sent: Wednesday, May 25, 2011 6:14 PM
Subject: Spam:*******, RE: Yak-List: Re: Program Letter
MALS-14 64E" <mark.bitterlich@navy.mil>
And you know what? It just never ends. Just when I thought I had made a
mistake, I might have been wrong. :-)
Read this:
8130.2G says:
(37) When an aircraft's home base is changed or there is a transfer of
ownership, the
new owner/operator will take any or all of the following actions within 30
days:
(a) Submit a new program letter to the geographically responsible FSDO.
(b) If an approved inspection program is specified in these operating
limitations,
submit a copy to the geographically responsible FSDO. The gaining FSDO will
not change the
previously approved program unless it can be substantiated that the
previously approved program
no longer meets FAA requirements.
(c) The gaining FSDO will not require the aircraft's airworthiness
certificate or
operating limitations to be reissued, unless the aircraft requires Phase I
test flight operations.
So, I would read that to mean that they won't change the Operating
Limitations.
The whole thing is a crock of dog poop. Who knows for sure WHAT anything
means.
Good luck... Mark's out of this one. ENOUGH already. I quit.
-----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: Wednesday, May 25, 2011 6:54 PM
Subject: RE: Yak-List: Re: Program Letter
MALS-14 64E" <mark.bitterlich@navy.mil>
Ok.
I was wrong. The light bulb just went on.
Dennis, you are/were absolutely correct.
If you change your Operating Limitations in ANY way, that means you also are
going to HAVE to obtain a new Special Airworthiness Certificate because the
dates on the two documents MUST MATCH! Darn it, I hate when that happens,
but I do pride myself on at least being able to stand up and admit when I
screw up.
So... you change the Operating Limitations, you must get a new Airworthiness
Certificate along with it, and since it ALSO is new, 8130.2G will probably
apply.
I say "probably" because I don't even trust my own judgment when it comes to
FAA regulations, and I am not going to bother the EAA anymore with this.
Mark Bitterlich
-----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: Wednesday, May 25, 2011 6:37 PM
Subject: RE: Yak-List: Re: Program Letter
MALS-14 64E" <mark.bitterlich@navy.mil>
Here is how the EAA Govt. Liason Division interprets these rules. These
people talk to those that MAKE the rules, not to local FISDO's that
INTERPRET the rules.
Thus I consider the EAA to be the best experts available unless you know
someone in Washington DC that works for the FAA.
And the answer the EAA writes below is EXACTLY why I took this issue up the
chain to get a better understanding.
What Dennis wrote is of course absolutely correct... he just didn't mention
8130.2G, paragraph 4107
And Dennis, I also (respectfully :-) once more disagree when you mention
that any changes made to CURRENT Operating Limitations will result in you
now being required to fall under 8130.2G, and thus get a whole NEW set of
Operating Limitations.
New Airworthiness Certificate .... yes. 8130.2G applies, and you will get
all new Operating Limitations and ... you will be required to carry your
Program Letter with you, etc.
Removal of an Operating Limitation from an EXISTING list of Operating
Limitations attached to an EXISTING Experimental Airworthiness Certificate
written under 8130.2F .... NO!
Mark Bitterlich
p.s. For a complete understanding read the response from the EAA contained
below.
-----Original Message-----
From: Randy Hansen [mailto:rhansen@eaa.org]
Sent: Wednesday, May 25, 2011 4:07 PM
Subject: RE: Yak-List: Re: Program Letter
Mark, this is an issue that may differ from aircraft to aircraft based
on the issued operating limitations -
The FAR baseline for this requirement is FAR 21.193 - it says a program
letter must be submitted, it does not mention a annual requirement.
The second baseline is FAR 91.319(i) - it says the administrator may
prescribe additional limitations the administrator feels necessary.
**this means the FAA can change to operating limitations as
necessary to address and resolve safety and operations issues.
FAA Order 8130.2F (effective Nov 2004 - April 2011), limitation (37) -
the operator must submit an annual program letter.
**no requirement that the program letter must be carried on
board.
FAA Order 8130.2G (effective April 2011 - present), limitation (3) the
operator must submit an annual program letter...and a copy of the
program letter and any amendments must be carried on board the aircraft
any time that the aircraft is being operated.
**carrying the program letter is a new requirement.
FAA Order 8130.2G, paragraph 4107 d - states that "all previously issued
airworthiness certificates and operating limitations will remain valid
unless changes are requested by the applicant or reexamined by the FAA
in accordance with 49 U.S.C. 44709."
Bottom line - If your airworthiness certificate and operating
limitations were issued under an earlier edition of 8130.2 (editions A,
B, C, D. E, or F) then you do not have a requirement to carry a program
letter on board the aircraft. And since there is NO requirement to turn
in your existing documents for a new version issued under the new
8130.2G, you do not need to carry your program letter. This new
requirement will only apply to those experimental exhibition aircraft
issued an original airworthiness certificate on/after April 11, 2011.
-----Original Message-----
From: owner-yak-list-server@matronics.com
[mailto:owner-yak-list-server@matronics.com] On Behalf Of A. Dennis Savarese
Sent: Wednesday, May 25, 2011 11:09 AM
Subject: Re: Yak-List: Re: Program Letter
<dsavarese0812@bellsouth.net>
Any new Special Airworthiness Certificates and Operating Limitations
will be issued under 8130.2G. This includes any request for the change
to eliminate the 300/600 mile proficiency area that may currently be in
your existing OL's.
Dennis
On 5/25/2011 9:48 AM, A. Dennis Savarese wrote:
> <dsavarese0812@bellsouth.net>
>
> For those that are operating under the older 8130.2F, here is a
> paragraph that is included in all of the groups, including ours, Group
> III. Just for grins, see if there is a paragraph in your own OL's
> that says something like the following".
>
> "....(2) No person may operate this aircraft for other than the
> purpose of meeting the requirements
> of 91.319(b), as stated in the program letter (required by 21.193)
> for this aircraft. This aircraft must
> be operated in accordance with applicable air traffic and general
> operating rules of part 91, as well as all
> additional limitations herein prescribed under the provisions of
> 91.319(e). These operating limitations
> are a part of the special airworthiness certificate, and are to be
> carried in the aircraft at all times
> and made available to the pilot in command of the aircraft.
> (Applicability: All)
> Dennis
>
>
> On 5/25/2011 9:26 AM, Bitterlich, Mark G CIV Det Cherry Point, MALS-14
> 64E wrote:
>> --> Yak-List message posted by: "Bitterlich, Mark G CIV Det Cherry
>> Point, MALS-14 64E"<mark.bitterlich@navy.mil>
>>
>> Just did :-)
>>
>> -----Original Message-----
>> From: owner-yak-list-server@matronics.com
>> [mailto:owner-yak-list-server@matronics.com] On Behalf Of A. Dennis
>> Savarese
>> Sent: Wednesday, May 25, 2011 10:15 AM
>> To: yak-list@matronics.com
>> Subject: Re: Yak-List: Re: Program Letter
>>
>> --> Yak-List message posted by: "A. Dennis Savarese"
>> <dsavarese0812@bellsouth.net>
>>
>> Mark, I respectfully request you read my next posting on the subject.
>> :-)
>>
>> On 5/25/2011 9:04 AM, Bitterlich, Mark G CIV Det Cherry Point, MALS-14
>> 64E wrote:
>>> --> Yak-List message posted by: "Bitterlich, Mark G CIV Det Cherry
>> Point, MALS-14 64E"<mark.bitterlich@navy.mil>
>>> Dennis, I respectfully disagree with your point of view in this one
>>> area.
>>>
>>> You mentioned:
>>>
>>> "The program letter and modifications which you may send by fax are in
>>> fact part of the Operating Limitations for the airplane. We all know
>>> you are required to carry the OL's in the airplane at all times.
>> Since
>>> the Program Letter is actually a part of the OL's, then IMHO, it is
>> also
>>> required to be carried in the airplane."
>>>
>>> The Operating Limitations also require a Conditional Inspection every
>>> year. By the same logic, you would also need to carry along a copy of
>>> your Conditional Inspection, or copies of your aircraft logbooks, etc.
>>> My opinion on dealing with the FAA on things like this is when they
>> say:
>>>
>>> "We need to see a copy of your Program Letter or modification of same,
>>> and if you don't have it with you, you must leave."
>>>
>>> NUMBER ONE: !!! Reply with: "Please quote the Regulation that
>>> specifically states I must carry a copy of my Program Letter with me.
>>> If you cannot quote me the exact regulation that requires me to do
>> this,
>>> I respectfully submit you have no authority to demand it from me".
>>>
>>> You must carry a copy of your Operating Limitations. READ THEM!
>> Break
>>> them out and have the FAA Inspector SHOW YOU on the Operating
>>> Limitations where it says what he is saying. THE BURDON OF PROOF IS
>> ON
>>> THE FAA, not on your to prove you are innocent. Sometimes certain FAA
>>> Inspectors forget that fact. Some Inspectors also assume that
>> anything
>>> they say is automatically correct. Anything you say is automatically
>>> wrong. You need to know your regulations and you also need the phone
>>> number to the EAA's Govt. Hotline. Ask for Randy Hanson.
>>>
>>> NUMBER TWO: If they still play nasty.... Go back to the motel, do a
>>> handwritten modification to your Program Letter on a paper napkin, go
>>> down to the Hotel Desk and FAX IT to your local FISDO. The go back to
>>> the airport and hand that FAA Inspector the paper napkin and bit him a
>>> fond farewell. I am not being sarcastic here. OK. The paper napkin
>>> part is supposed to be a joke (OK who-ever from the FAA READS THIS? A
>>> JOKE! PLEASE? Good grief).
>>>
>>> Not that I think you're wrong about carrying the stuff along. The FAA
>>> CONSTANTLY (!!!) interprets things differently and they can come up
>> with
>>> the strangest things (flying with my door off, etc) and you have to go
>>> to the ends of the Earth to get them to see things a little bit
>>> differently.
>>>
>>> Just saying. I think being polite but not cowardly is the best
>>> approach... my 2 cents.
>>>
>>> Mark
>>>
>>>
>>>
>>>
>>> -----Original Message-----
>>> From: owner-yak-list-server@matronics.com
>>> [mailto:owner-yak-list-server@matronics.com] On Behalf Of A. Dennis
>>> Savarese
>>> Sent: Tuesday, May 24, 2011 10:47 PM
>>> To: yak-list@matronics.com
>>> Subject: Re: Yak-List: Re: Program Letter
>>>
>>> --> Yak-List message posted by: "A. Dennis Savarese"
>>> <dsavarese0812@bellsouth.net>
>>>
>>> Here's something to think about.
>>> The program letter and modifications which you may send by fax are in
>>> fact part of the Operating Limitations for the airplane. We all know
>>> you are required to carry the OL's in the airplane at all times.
>> Since
>>> the Program Letter is actually a part of the OL's, then IMHO, it is
>> also
>>> required to be carried in the airplane.
>>>
>>> Unfortunately, when the FAA removed the 300/600 NM proficiency area,
>>> they failed to include the elimination of the Program Letter, which
>>> would have made logical sense. ie: if you don't have any restrictions
>>> as to where you can fly, they why do you need a Program Letter to
>> attend
>>> an event?
>>>
>>> When you attend an event that may also be attended by the FAA
>> (typically
>>> when there is wavered airspace) and they ask to see your aircraft's
>>> paperwork as well as you pilot certificate and current medical form,
>>> when you hand him/her the aircraft's Operating Limitations he/she will
>>> also ask to see your Program Letter or modification for this specific
>>> event. If you do not have your Program Letter with the specific event
>>> on it or a modification/update to the program letter which you
>> submitted
>>> to your FSDO with you, the FAA person may not permit you to stay at
>> the
>>> event. I had this happen to me about 5 years ago. Thus, when I sent
>>> my program letter in to the FSDO each year, I automatically put a copy
>>> in the airplane along with any modifications.
>>> Dennis
>>>
>>> On 5/24/2011 9:00 PM, keithmckinley wrote:
>>>> --> Yak-List message posted by:
>>> "keithmckinley"<keith.mckinley@townisp.com>
>>>> Mark,
>>>>
>>>> Thanks for the feedback.
>>>>
>>>> No 300 mile restriction. No doubt it is easier to play nice with the
>>> Fed's and yes it does pay dividends, but sometimes I think it's
>>> important to make sure they interpret things correctly and realize
>> (as
>>> inspectors) they don't make the rules. More than anything, I just have
>>> an aversion to ass kissing.......but not to protecting my own ass!
>>>> Semper Fi
>>>>
>>>> Keith
>>>>
>>>> --------
>>>> Keith McKinley
>>>> 700HS
>>>> KFIT
>>>>
>>>>
>>>>
>>>>
>>>> Read this topic online here:
>>>>
>>>> http://forums.matronics.com/viewtopic.php?p=340874#340874
>>>>
>>>>
>>>>
>>>>
>>>>
>>>>
>>>>
>>>>
>>>>
>>>>
>>>>
>>>
>>>
>>>
>>>
>>>
>>>
>>>
>>>
>>
>>
>>
>>
>>
>>
>>
>>
>>
>
>
Message 28
| INDEX | Back to Main INDEX |
| PREVIOUS | Skip to PREVIOUS Message |
| NEXT | Skip to NEXT Message |
| LIST | Reply to LIST Regarding this Message |
| SENDER | Reply to SENDER Regarding this Message |
|
| Subject: | Re: Program Letter |
Mark, it just means that the whole Exp exhibition thing is a confusing mess
even to the FAA. According to 37{c} I don't need new Op limits if I sell the
plane or move, but if I ask to have the Op limits changed [no 300 mile
limit] then the program letter and maintenance provision will be included.
Whew!
Jim Griffin
----- Original Message -----
From: "Bitterlich, Mark G CIV Det Cherry Point, MALS-14 64E"
<mark.bitterlich@navy.mil>
Sent: Wednesday, May 25, 2011 6:14 PM
Subject: RE: Yak-List: Re: Program Letter
MALS-14 64E" <mark.bitterlich@navy.mil>
And you know what? It just never ends. Just when I thought I had made a
mistake, I might have been wrong. :-)
Read this:
8130.2G says:
(37) When an aircraft's home base is changed or there is a transfer of
ownership, the
new owner/operator will take any or all of the following actions within 30
days:
(a) Submit a new program letter to the geographically responsible FSDO.
(b) If an approved inspection program is specified in these operating
limitations,
submit a copy to the geographically responsible FSDO. The gaining FSDO will
not change the
previously approved program unless it can be substantiated that the
previously approved program
no longer meets FAA requirements.
(c) The gaining FSDO will not require the aircraft's airworthiness
certificate or
operating limitations to be reissued, unless the aircraft requires Phase I
test flight operations.
So, I would read that to mean that they won't change the Operating
Limitations.
The whole thing is a crock of dog poop. Who knows for sure WHAT anything
means.
Good luck... Mark's out of this one. ENOUGH already. I quit.
-----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: Wednesday, May 25, 2011 6:54 PM
Subject: RE: Yak-List: Re: Program Letter
MALS-14 64E" <mark.bitterlich@navy.mil>
Ok.
I was wrong. The light bulb just went on.
Dennis, you are/were absolutely correct.
If you change your Operating Limitations in ANY way, that means you also are
going to HAVE to obtain a new Special Airworthiness Certificate because the
dates on the two documents MUST MATCH! Darn it, I hate when that happens,
but I do pride myself on at least being able to stand up and admit when I
screw up.
So... you change the Operating Limitations, you must get a new Airworthiness
Certificate along with it, and since it ALSO is new, 8130.2G will probably
apply.
I say "probably" because I don't even trust my own judgment when it comes to
FAA regulations, and I am not going to bother the EAA anymore with this.
Mark Bitterlich
-----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: Wednesday, May 25, 2011 6:37 PM
Subject: RE: Yak-List: Re: Program Letter
MALS-14 64E" <mark.bitterlich@navy.mil>
Here is how the EAA Govt. Liason Division interprets these rules. These
people talk to those that MAKE the rules, not to local FISDO's that
INTERPRET the rules.
Thus I consider the EAA to be the best experts available unless you know
someone in Washington DC that works for the FAA.
And the answer the EAA writes below is EXACTLY why I took this issue up the
chain to get a better understanding.
What Dennis wrote is of course absolutely correct... he just didn't mention
8130.2G, paragraph 4107
And Dennis, I also (respectfully :-) once more disagree when you mention
that any changes made to CURRENT Operating Limitations will result in you
now being required to fall under 8130.2G, and thus get a whole NEW set of
Operating Limitations.
New Airworthiness Certificate .... yes. 8130.2G applies, and you will get
all new Operating Limitations and ... you will be required to carry your
Program Letter with you, etc.
Removal of an Operating Limitation from an EXISTING list of Operating
Limitations attached to an EXISTING Experimental Airworthiness Certificate
written under 8130.2F .... NO!
Mark Bitterlich
p.s. For a complete understanding read the response from the EAA contained
below.
-----Original Message-----
From: Randy Hansen [mailto:rhansen@eaa.org]
Sent: Wednesday, May 25, 2011 4:07 PM
Subject: RE: Yak-List: Re: Program Letter
Mark, this is an issue that may differ from aircraft to aircraft based
on the issued operating limitations -
The FAR baseline for this requirement is FAR 21.193 - it says a program
letter must be submitted, it does not mention a annual requirement.
The second baseline is FAR 91.319(i) - it says the administrator may
prescribe additional limitations the administrator feels necessary.
**this means the FAA can change to operating limitations as
necessary to address and resolve safety and operations issues.
FAA Order 8130.2F (effective Nov 2004 - April 2011), limitation (37) -
the operator must submit an annual program letter.
**no requirement that the program letter must be carried on
board.
FAA Order 8130.2G (effective April 2011 - present), limitation (3) the
operator must submit an annual program letter...and a copy of the
program letter and any amendments must be carried on board the aircraft
any time that the aircraft is being operated.
**carrying the program letter is a new requirement.
FAA Order 8130.2G, paragraph 4107 d - states that "all previously issued
airworthiness certificates and operating limitations will remain valid
unless changes are requested by the applicant or reexamined by the FAA
in accordance with 49 U.S.C. 44709."
Bottom line - If your airworthiness certificate and operating
limitations were issued under an earlier edition of 8130.2 (editions A,
B, C, D. E, or F) then you do not have a requirement to carry a program
letter on board the aircraft. And since there is NO requirement to turn
in your existing documents for a new version issued under the new
8130.2G, you do not need to carry your program letter. This new
requirement will only apply to those experimental exhibition aircraft
issued an original airworthiness certificate on/after April 11, 2011.
-----Original Message-----
From: owner-yak-list-server@matronics.com
[mailto:owner-yak-list-server@matronics.com] On Behalf Of A. Dennis Savarese
Sent: Wednesday, May 25, 2011 11:09 AM
Subject: Re: Yak-List: Re: Program Letter
<dsavarese0812@bellsouth.net>
Any new Special Airworthiness Certificates and Operating Limitations
will be issued under 8130.2G. This includes any request for the change
to eliminate the 300/600 mile proficiency area that may currently be in
your existing OL's.
Dennis
On 5/25/2011 9:48 AM, A. Dennis Savarese wrote:
> <dsavarese0812@bellsouth.net>
>
> For those that are operating under the older 8130.2F, here is a
> paragraph that is included in all of the groups, including ours, Group
> III. Just for grins, see if there is a paragraph in your own OL's
> that says something like the following".
>
> "....(2) No person may operate this aircraft for other than the
> purpose of meeting the requirements
> of 91.319(b), as stated in the program letter (required by 21.193)
> for this aircraft. This aircraft must
> be operated in accordance with applicable air traffic and general
> operating rules of part 91, as well as all
> additional limitations herein prescribed under the provisions of
> 91.319(e). These operating limitations
> are a part of the special airworthiness certificate, and are to be
> carried in the aircraft at all times
> and made available to the pilot in command of the aircraft.
> (Applicability: All)
> Dennis
>
>
> On 5/25/2011 9:26 AM, Bitterlich, Mark G CIV Det Cherry Point, MALS-14
> 64E wrote:
>> --> Yak-List message posted by: "Bitterlich, Mark G CIV Det Cherry
>> Point, MALS-14 64E"<mark.bitterlich@navy.mil>
>>
>> Just did :-)
>>
>> -----Original Message-----
>> From: owner-yak-list-server@matronics.com
>> [mailto:owner-yak-list-server@matronics.com] On Behalf Of A. Dennis
>> Savarese
>> Sent: Wednesday, May 25, 2011 10:15 AM
>> To: yak-list@matronics.com
>> Subject: Re: Yak-List: Re: Program Letter
>>
>> --> Yak-List message posted by: "A. Dennis Savarese"
>> <dsavarese0812@bellsouth.net>
>>
>> Mark, I respectfully request you read my next posting on the subject.
>> :-)
>>
>> On 5/25/2011 9:04 AM, Bitterlich, Mark G CIV Det Cherry Point, MALS-14
>> 64E wrote:
>>> --> Yak-List message posted by: "Bitterlich, Mark G CIV Det Cherry
>> Point, MALS-14 64E"<mark.bitterlich@navy.mil>
>>> Dennis, I respectfully disagree with your point of view in this one
>>> area.
>>>
>>> You mentioned:
>>>
>>> "The program letter and modifications which you may send by fax are in
>>> fact part of the Operating Limitations for the airplane. We all know
>>> you are required to carry the OL's in the airplane at all times.
>> Since
>>> the Program Letter is actually a part of the OL's, then IMHO, it is
>> also
>>> required to be carried in the airplane."
>>>
>>> The Operating Limitations also require a Conditional Inspection every
>>> year. By the same logic, you would also need to carry along a copy of
>>> your Conditional Inspection, or copies of your aircraft logbooks, etc.
>>> My opinion on dealing with the FAA on things like this is when they
>> say:
>>>
>>> "We need to see a copy of your Program Letter or modification of same,
>>> and if you don't have it with you, you must leave."
>>>
>>> NUMBER ONE: !!! Reply with: "Please quote the Regulation that
>>> specifically states I must carry a copy of my Program Letter with me.
>>> If you cannot quote me the exact regulation that requires me to do
>> this,
>>> I respectfully submit you have no authority to demand it from me".
>>>
>>> You must carry a copy of your Operating Limitations. READ THEM!
>> Break
>>> them out and have the FAA Inspector SHOW YOU on the Operating
>>> Limitations where it says what he is saying. THE BURDON OF PROOF IS
>> ON
>>> THE FAA, not on your to prove you are innocent. Sometimes certain FAA
>>> Inspectors forget that fact. Some Inspectors also assume that
>> anything
>>> they say is automatically correct. Anything you say is automatically
>>> wrong. You need to know your regulations and you also need the phone
>>> number to the EAA's Govt. Hotline. Ask for Randy Hanson.
>>>
>>> NUMBER TWO: If they still play nasty.... Go back to the motel, do a
>>> handwritten modification to your Program Letter on a paper napkin, go
>>> down to the Hotel Desk and FAX IT to your local FISDO. The go back to
>>> the airport and hand that FAA Inspector the paper napkin and bit him a
>>> fond farewell. I am not being sarcastic here. OK. The paper napkin
>>> part is supposed to be a joke (OK who-ever from the FAA READS THIS? A
>>> JOKE! PLEASE? Good grief).
>>>
>>> Not that I think you're wrong about carrying the stuff along. The FAA
>>> CONSTANTLY (!!!) interprets things differently and they can come up
>> with
>>> the strangest things (flying with my door off, etc) and you have to go
>>> to the ends of the Earth to get them to see things a little bit
>>> differently.
>>>
>>> Just saying. I think being polite but not cowardly is the best
>>> approach... my 2 cents.
>>>
>>> Mark
>>>
>>>
>>>
>>>
>>> -----Original Message-----
>>> From: owner-yak-list-server@matronics.com
>>> [mailto:owner-yak-list-server@matronics.com] On Behalf Of A. Dennis
>>> Savarese
>>> Sent: Tuesday, May 24, 2011 10:47 PM
>>> To: yak-list@matronics.com
>>> Subject: Re: Yak-List: Re: Program Letter
>>>
>>> --> Yak-List message posted by: "A. Dennis Savarese"
>>> <dsavarese0812@bellsouth.net>
>>>
>>> Here's something to think about.
>>> The program letter and modifications which you may send by fax are in
>>> fact part of the Operating Limitations for the airplane. We all know
>>> you are required to carry the OL's in the airplane at all times.
>> Since
>>> the Program Letter is actually a part of the OL's, then IMHO, it is
>> also
>>> required to be carried in the airplane.
>>>
>>> Unfortunately, when the FAA removed the 300/600 NM proficiency area,
>>> they failed to include the elimination of the Program Letter, which
>>> would have made logical sense. ie: if you don't have any restrictions
>>> as to where you can fly, they why do you need a Program Letter to
>> attend
>>> an event?
>>>
>>> When you attend an event that may also be attended by the FAA
>> (typically
>>> when there is wavered airspace) and they ask to see your aircraft's
>>> paperwork as well as you pilot certificate and current medical form,
>>> when you hand him/her the aircraft's Operating Limitations he/she will
>>> also ask to see your Program Letter or modification for this specific
>>> event. If you do not have your Program Letter with the specific event
>>> on it or a modification/update to the program letter which you
>> submitted
>>> to your FSDO with you, the FAA person may not permit you to stay at
>> the
>>> event. I had this happen to me about 5 years ago. Thus, when I sent
>>> my program letter in to the FSDO each year, I automatically put a copy
>>> in the airplane along with any modifications.
>>> Dennis
>>>
>>> On 5/24/2011 9:00 PM, keithmckinley wrote:
>>>> --> Yak-List message posted by:
>>> "keithmckinley"<keith.mckinley@townisp.com>
>>>> Mark,
>>>>
>>>> Thanks for the feedback.
>>>>
>>>> No 300 mile restriction. No doubt it is easier to play nice with the
>>> Fed's and yes it does pay dividends, but sometimes I think it's
>>> important to make sure they interpret things correctly and realize
>> (as
>>> inspectors) they don't make the rules. More than anything, I just have
>>> an aversion to ass kissing.......but not to protecting my own ass!
>>>> Semper Fi
>>>>
>>>> Keith
>>>>
>>>> --------
>>>> Keith McKinley
>>>> 700HS
>>>> KFIT
>>>>
>>>>
>>>>
>>>>
>>>> Read this topic online here:
>>>>
>>>> http://forums.matronics.com/viewtopic.php?p=340874#340874
>>>>
>>>>
>>>>
>>>>
>>>>
>>>>
>>>>
>>>>
>>>>
>>>>
>>>>
>>>
>>>
>>>
>>>
>>>
>>>
>>>
>>>
>>
>>
>>
>>
>>
>>
>>
>>
>>
>
>
Message 29
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| Subject: | Re: Program Letter |
For almost 18 years now we've never needed an approved inspection
program. The Group III over 800 HP did and so did the jets. But never
the aircraft in the under 800 hp group. Maybe our friendly EAA can shed
some light on why this is necessary now for the Group 2 (formally Group
III under 800 HP). Doesn't make sense.
Dennis
On 5/25/2011 6:53 PM, Jim Griffin wrote:
>
> Mark, it just means that the whole Exp exhibition thing is a confusing
> mess even to the FAA. According to 37{c} I don't need new Op limits if
> I sell the plane or move, but if I ask to have the Op limits changed
> [no 300 mile limit] then the program letter and maintenance provision
> will be included. Whew!
> Jim Griffin
>
>
> ----- Original Message ----- From: "Bitterlich, Mark G CIV Det Cherry
> Point, MALS-14 64E" <mark.bitterlich@navy.mil>
> To: <yak-list@matronics.com>
> Sent: Wednesday, May 25, 2011 6:14 PM
> Subject: RE: Yak-List: Re: Program Letter
>
>
> Point, MALS-14 64E" <mark.bitterlich@navy.mil>
>
> And you know what? It just never ends. Just when I thought I had
> made a mistake, I might have been wrong. :-)
>
> Read this:
>
> 8130.2G says:
> (37) When an aircraft's home base is changed or there is a transfer of
> ownership, the
> new owner/operator will take any or all of the following actions
> within 30 days:
> (a) Submit a new program letter to the geographically responsible FSDO.
> (b) If an approved inspection program is specified in these operating
> limitations,
> submit a copy to the geographically responsible FSDO. The gaining FSDO
> will not change the
> previously approved program unless it can be substantiated that the
> previously approved program
> no longer meets FAA requirements.
> (c) The gaining FSDO will not require the aircraft's airworthiness
> certificate or
> operating limitations to be reissued, unless the aircraft requires
> Phase I test flight operations.
>
> So, I would read that to mean that they won't change the Operating
> Limitations.
>
> The whole thing is a crock of dog poop. Who knows for sure WHAT
> anything means.
>
> Good luck... Mark's out of this one. ENOUGH already. I quit.
>
>
> -----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: Wednesday, May 25, 2011 6:54 PM
> To: yak-list@matronics.com
> Subject: RE: Yak-List: Re: Program Letter
>
> Point, MALS-14 64E" <mark.bitterlich@navy.mil>
>
> Ok.
>
> I was wrong. The light bulb just went on.
>
> Dennis, you are/were absolutely correct.
>
> If you change your Operating Limitations in ANY way, that means you
> also are going to HAVE to obtain a new Special Airworthiness
> Certificate because the dates on the two documents MUST MATCH! Darn
> it, I hate when that happens, but I do pride myself on at least being
> able to stand up and admit when I screw up.
>
> So... you change the Operating Limitations, you must get a new
> Airworthiness Certificate along with it, and since it ALSO is new,
> 8130.2G will probably apply.
>
> I say "probably" because I don't even trust my own judgment when it
> comes to FAA regulations, and I am not going to bother the EAA anymore
> with this.
>
> Mark Bitterlich
>
>
> -----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: Wednesday, May 25, 2011 6:37 PM
> To: yak-list@matronics.com
> Subject: RE: Yak-List: Re: Program Letter
>
> Point, MALS-14 64E" <mark.bitterlich@navy.mil>
>
> Here is how the EAA Govt. Liason Division interprets these rules.
> These people talk to those that MAKE the rules, not to local FISDO's
> that INTERPRET the rules.
>
> Thus I consider the EAA to be the best experts available unless you
> know someone in Washington DC that works for the FAA.
>
> And the answer the EAA writes below is EXACTLY why I took this issue
> up the chain to get a better understanding.
>
> What Dennis wrote is of course absolutely correct... he just didn't
> mention 8130.2G, paragraph 4107
>
> And Dennis, I also (respectfully :-) once more disagree when you
> mention that any changes made to CURRENT Operating Limitations will
> result in you now being required to fall under 8130.2G, and thus get a
> whole NEW set of Operating Limitations.
>
> New Airworthiness Certificate .... yes. 8130.2G applies, and you will
> get all new Operating Limitations and ... you will be required to
> carry your Program Letter with you, etc.
>
> Removal of an Operating Limitation from an EXISTING list of Operating
> Limitations attached to an EXISTING Experimental Airworthiness
> Certificate written under 8130.2F .... NO!
>
> Mark Bitterlich
>
> p.s. For a complete understanding read the response from the EAA
> contained below.
>
>
> -----Original Message-----
> From: Randy Hansen [mailto:rhansen@eaa.org]
> Sent: Wednesday, May 25, 2011 4:07 PM
> To: Bitterlich, Mark G CIV Det Cherry Point, MALS-14 64E
> Subject: RE: Yak-List: Re: Program Letter
>
> Mark, this is an issue that may differ from aircraft to aircraft based
> on the issued operating limitations -
>
> The FAR baseline for this requirement is FAR 21.193 - it says a program
> letter must be submitted, it does not mention a annual requirement.
>
> The second baseline is FAR 91.319(i) - it says the administrator may
> prescribe additional limitations the administrator feels necessary.
> **this means the FAA can change to operating limitations as
> necessary to address and resolve safety and operations issues.
>
> FAA Order 8130.2F (effective Nov 2004 - April 2011), limitation (37) -
> the operator must submit an annual program letter.
> **no requirement that the program letter must be carried on
> board.
>
> FAA Order 8130.2G (effective April 2011 - present), limitation (3) the
> operator must submit an annual program letter...and a copy of the
> program letter and any amendments must be carried on board the aircraft
> any time that the aircraft is being operated.
> **carrying the program letter is a new requirement.
>
> FAA Order 8130.2G, paragraph 4107 d - states that "all previously issued
> airworthiness certificates and operating limitations will remain valid
> unless changes are requested by the applicant or reexamined by the FAA
> in accordance with 49 U.S.C. 44709."
>
> Bottom line - If your airworthiness certificate and operating
> limitations were issued under an earlier edition of 8130.2 (editions A,
> B, C, D. E, or F) then you do not have a requirement to carry a program
> letter on board the aircraft. And since there is NO requirement to turn
> in your existing documents for a new version issued under the new
> 8130.2G, you do not need to carry your program letter. This new
> requirement will only apply to those experimental exhibition aircraft
> issued an original airworthiness certificate on/after April 11, 2011.
>
>
> -----Original Message-----
> From: owner-yak-list-server@matronics.com
> [mailto:owner-yak-list-server@matronics.com] On Behalf Of A. Dennis
> Savarese
> Sent: Wednesday, May 25, 2011 11:09 AM
> To: yak-list@matronics.com
> Subject: Re: Yak-List: Re: Program Letter
>
> <dsavarese0812@bellsouth.net>
>
> Any new Special Airworthiness Certificates and Operating Limitations
> will be issued under 8130.2G. This includes any request for the change
> to eliminate the 300/600 mile proficiency area that may currently be in
> your existing OL's.
> Dennis
>
> On 5/25/2011 9:48 AM, A. Dennis Savarese wrote:
>> <dsavarese0812@bellsouth.net>
>>
>> For those that are operating under the older 8130.2F, here is a
>> paragraph that is included in all of the groups, including ours, Group
>> III. Just for grins, see if there is a paragraph in your own OL's
>> that says something like the following".
>>
>> "....(2) No person may operate this aircraft for other than the
>> purpose of meeting the requirements
>> of 91.319(b), as stated in the program letter (required by 21.193)
>> for this aircraft. This aircraft must
>> be operated in accordance with applicable air traffic and general
>> operating rules of part 91, as well as all
>> additional limitations herein prescribed under the provisions of
>> 91.319(e). These operating limitations
>> are a part of the special airworthiness certificate, and are to be
>> carried in the aircraft at all times
>> and made available to the pilot in command of the aircraft.
>> (Applicability: All)
>> Dennis
>>
>>
>> On 5/25/2011 9:26 AM, Bitterlich, Mark G CIV Det Cherry Point, MALS-14
>> 64E wrote:
>>> --> Yak-List message posted by: "Bitterlich, Mark G CIV Det Cherry
>>> Point, MALS-14 64E"<mark.bitterlich@navy.mil>
>>>
>>> Just did :-)
>>>
>>> -----Original Message-----
>>> From: owner-yak-list-server@matronics.com
>>> [mailto:owner-yak-list-server@matronics.com] On Behalf Of A. Dennis
>>> Savarese
>>> Sent: Wednesday, May 25, 2011 10:15 AM
>>> To: yak-list@matronics.com
>>> Subject: Re: Yak-List: Re: Program Letter
>>>
>>> --> Yak-List message posted by: "A. Dennis Savarese"
>>> <dsavarese0812@bellsouth.net>
>>>
>>> Mark, I respectfully request you read my next posting on the subject.
>>> :-)
>>>
>>> On 5/25/2011 9:04 AM, Bitterlich, Mark G CIV Det Cherry Point, MALS-14
>>> 64E wrote:
>>>> --> Yak-List message posted by: "Bitterlich, Mark G CIV Det Cherry
>>> Point, MALS-14 64E"<mark.bitterlich@navy.mil>
>>>> Dennis, I respectfully disagree with your point of view in this one
>>>> area.
>>>>
>>>> You mentioned:
>>>>
>>>> "The program letter and modifications which you may send by fax are in
>>>> fact part of the Operating Limitations for the airplane. We all know
>>>> you are required to carry the OL's in the airplane at all times.
>>> Since
>>>> the Program Letter is actually a part of the OL's, then IMHO, it is
>>> also
>>>> required to be carried in the airplane."
>>>>
>>>> The Operating Limitations also require a Conditional Inspection every
>>>> year. By the same logic, you would also need to carry along a copy of
>>>> your Conditional Inspection, or copies of your aircraft logbooks, etc.
>>>> My opinion on dealing with the FAA on things like this is when they
>>> say:
>>>>
>>>> "We need to see a copy of your Program Letter or modification of same,
>>>> and if you don't have it with you, you must leave."
>>>>
>>>> NUMBER ONE: !!! Reply with: "Please quote the Regulation that
>>>> specifically states I must carry a copy of my Program Letter with me.
>>>> If you cannot quote me the exact regulation that requires me to do
>>> this,
>>>> I respectfully submit you have no authority to demand it from me".
>>>>
>>>> You must carry a copy of your Operating Limitations. READ THEM!
>>> Break
>>>> them out and have the FAA Inspector SHOW YOU on the Operating
>>>> Limitations where it says what he is saying. THE BURDON OF PROOF IS
>>> ON
>>>> THE FAA, not on your to prove you are innocent. Sometimes certain FAA
>>>> Inspectors forget that fact. Some Inspectors also assume that
>>> anything
>>>> they say is automatically correct. Anything you say is automatically
>>>> wrong. You need to know your regulations and you also need the phone
>>>> number to the EAA's Govt. Hotline. Ask for Randy Hanson.
>>>>
>>>> NUMBER TWO: If they still play nasty.... Go back to the motel, do a
>>>> handwritten modification to your Program Letter on a paper napkin, go
>>>> down to the Hotel Desk and FAX IT to your local FISDO. The go back to
>>>> the airport and hand that FAA Inspector the paper napkin and bit him a
>>>> fond farewell. I am not being sarcastic here. OK. The paper napkin
>>>> part is supposed to be a joke (OK who-ever from the FAA READS THIS? A
>>>> JOKE! PLEASE? Good grief).
>>>>
>>>> Not that I think you're wrong about carrying the stuff along. The FAA
>>>> CONSTANTLY (!!!) interprets things differently and they can come up
>>> with
>>>> the strangest things (flying with my door off, etc) and you have to go
>>>> to the ends of the Earth to get them to see things a little bit
>>>> differently.
>>>>
>>>> Just saying. I think being polite but not cowardly is the best
>>>> approach... my 2 cents.
>>>>
>>>> Mark
>>>>
>>>>
>>>>
>>>>
>>>> -----Original Message-----
>>>> From: owner-yak-list-server@matronics.com
>>>> [mailto:owner-yak-list-server@matronics.com] On Behalf Of A. Dennis
>>>> Savarese
>>>> Sent: Tuesday, May 24, 2011 10:47 PM
>>>> To: yak-list@matronics.com
>>>> Subject: Re: Yak-List: Re: Program Letter
>>>>
>>>> --> Yak-List message posted by: "A. Dennis Savarese"
>>>> <dsavarese0812@bellsouth.net>
>>>>
>>>> Here's something to think about.
>>>> The program letter and modifications which you may send by fax are in
>>>> fact part of the Operating Limitations for the airplane. We all know
>>>> you are required to carry the OL's in the airplane at all times.
>>> Since
>>>> the Program Letter is actually a part of the OL's, then IMHO, it is
>>> also
>>>> required to be carried in the airplane.
>>>>
>>>> Unfortunately, when the FAA removed the 300/600 NM proficiency area,
>>>> they failed to include the elimination of the Program Letter, which
>>>> would have made logical sense. ie: if you don't have any restrictions
>>>> as to where you can fly, they why do you need a Program Letter to
>>> attend
>>>> an event?
>>>>
>>>> When you attend an event that may also be attended by the FAA
>>> (typically
>>>> when there is wavered airspace) and they ask to see your aircraft's
>>>> paperwork as well as you pilot certificate and current medical form,
>>>> when you hand him/her the aircraft's Operating Limitations he/she will
>>>> also ask to see your Program Letter or modification for this specific
>>>> event. If you do not have your Program Letter with the specific event
>>>> on it or a modification/update to the program letter which you
>>> submitted
>>>> to your FSDO with you, the FAA person may not permit you to stay at
>>> the
>>>> event. I had this happen to me about 5 years ago. Thus, when I sent
>>>> my program letter in to the FSDO each year, I automatically put a copy
>>>> in the airplane along with any modifications.
>>>> Dennis
>>>>
>>>> On 5/24/2011 9:00 PM, keithmckinley wrote:
>>>>> --> Yak-List message posted by:
>>>> "keithmckinley"<keith.mckinley@townisp.com>
>>>>> Mark,
>>>>>
>>>>> Thanks for the feedback.
>>>>>
>>>>> No 300 mile restriction. No doubt it is easier to play nice with the
>>>> Fed's and yes it does pay dividends, but sometimes I think it's
>>>> important to make sure they interpret things correctly and realize
>>> (as
>>>> inspectors) they don't make the rules. More than anything, I just have
>>>> an aversion to ass kissing.......but not to protecting my own ass!
>>>>> Semper Fi
>>>>>
>>>>> Keith
>>>>>
>>>>> --------
>>>>> Keith McKinley
>>>>> 700HS
>>>>> KFIT
>>>>>
>>>>>
>>>>>
>>>>>
>>>>> Read this topic online here:
>>>>>
>>>>> http://forums.matronics.com/viewtopic.php?p=340874#340874
>>>>>
>>>>>
>>>>>
>>>>>
>>>>>
>>>>>
>>>>>
>>>>>
>>>>>
>>>>>
>>>>>
>>>>
>>>>
>>>>
>>>>
>>>>
>>>>
>>>>
>>>>
>>>
>>>
>>>
>>>
>>>
>>>
>>>
>>>
>>>
>>
>>
>>
>>
>>
>
>
Message 30
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|
| Subject: | Re: Program Letter |
Jim,
I read the new OL's completely and I don't see anything that says you
have to submit a printed maintenance program to the FAA for the group
your aircraft is certificated in. I do see a maintenance
program/inspection program requirement for the larger airplanes and jets
as specified in paragraph 29. But not for Group 2. Am I missing
something or is your FSDO guy crossing Group boundaries?
As for the requirement to list in the program letter who is responsible
for the maintenance of the airplane, that should not be an issue. Most
everyone will list themselves unless they have a mechanic that does the
work for them.
Dennis
On 5/25/2011 2:36 PM, Jim Griffin wrote:
> I recently talked to my FSDO about changing my 300 mile limits. He is
> a helpful guy and sent me a copy of what the new op limits look like
> on someone elses plane. In it, the program letter must list who is
> responsible for maintenance for the plane. He also asked me for a
> printed maintenance program. I have included a copy. Check paragraph 3.
> Jim Griffin
> ----- Original Message ----- From: "A. Dennis Savarese"
> <dsavarese0812@bellsouth.net>
> To: <yak-list@matronics.com>
> Sent: Wednesday, May 25, 2011 10:08 AM
> Subject: Re: Yak-List: Re: Program Letter
>
>
> <dsavarese0812@bellsouth.net>
>
> Any new Special Airworthiness Certificates and Operating Limitations
> will be issued under 8130.2G. This includes any request for the change
> to eliminate the 300/600 mile proficiency area that may currently be in
> your existing OL's.
> Dennis
>
> On 5/25/2011 9:48 AM, A. Dennis Savarese wrote:
>> <dsavarese0812@bellsouth.net>
>>
>> For those that are operating under the older 8130.2F, here is a
>> paragraph that is included in all of the groups, including ours,
>> Group III. Just for grins, see if there is a paragraph in your own
>> OL's that says something like the following".
>>
>> "....(2) No person may operate this aircraft for other than the
>> purpose of meeting the requirements
>> of 91.319(b), as stated in the program letter (required by
>> 21.193) for this aircraft. This aircraft must
>> be operated in accordance with applicable air traffic and general
>> operating rules of part 91, as well as all
>> additional limitations herein prescribed under the provisions of
>> 91.319(e). These operating limitations
>> are a part of the special airworthiness certificate, and are to be
>> carried in the aircraft at all times
>> and made available to the pilot in command of the aircraft.
>> (Applicability: All)
>> Dennis
>>
>>
>> On 5/25/2011 9:26 AM, Bitterlich, Mark G CIV Det Cherry Point,
>> MALS-14 64E wrote:
>>> --> Yak-List message posted by: "Bitterlich, Mark G CIV Det Cherry
>>> Point, MALS-14 64E"<mark.bitterlich@navy.mil>
>>>
>>> Just did :-)
>>>
>>> -----Original Message-----
>>> From: owner-yak-list-server@matronics.com
>>> [mailto:owner-yak-list-server@matronics.com] On Behalf Of A. Dennis
>>> Savarese
>>> Sent: Wednesday, May 25, 2011 10:15 AM
>>> To: yak-list@matronics.com
>>> Subject: Re: Yak-List: Re: Program Letter
>>>
>>> --> Yak-List message posted by: "A. Dennis Savarese"
>>> <dsavarese0812@bellsouth.net>
>>>
>>> Mark, I respectfully request you read my next posting on the subject.
>>> :-)
>>>
>>> On 5/25/2011 9:04 AM, Bitterlich, Mark G CIV Det Cherry Point, MALS-14
>>> 64E wrote:
>>>> --> Yak-List message posted by: "Bitterlich, Mark G CIV Det Cherry
>>> Point, MALS-14 64E"<mark.bitterlich@navy.mil>
>>>> Dennis, I respectfully disagree with your point of view in this one
>>>> area.
>>>>
>>>> You mentioned:
>>>>
>>>> "The program letter and modifications which you may send by fax are in
>>>> fact part of the Operating Limitations for the airplane. We all know
>>>> you are required to carry the OL's in the airplane at all times.
>>> Since
>>>> the Program Letter is actually a part of the OL's, then IMHO, it is
>>> also
>>>> required to be carried in the airplane."
>>>>
>>>> The Operating Limitations also require a Conditional Inspection every
>>>> year. By the same logic, you would also need to carry along a copy of
>>>> your Conditional Inspection, or copies of your aircraft logbooks, etc.
>>>> My opinion on dealing with the FAA on things like this is when they
>>> say:
>>>>
>>>> "We need to see a copy of your Program Letter or modification of same,
>>>> and if you don't have it with you, you must leave."
>>>>
>>>> NUMBER ONE: !!! Reply with: "Please quote the Regulation that
>>>> specifically states I must carry a copy of my Program Letter with me.
>>>> If you cannot quote me the exact regulation that requires me to do
>>> this,
>>>> I respectfully submit you have no authority to demand it from me".
>>>>
>>>> You must carry a copy of your Operating Limitations. READ THEM!
>>> Break
>>>> them out and have the FAA Inspector SHOW YOU on the Operating
>>>> Limitations where it says what he is saying. THE BURDON OF PROOF IS
>>> ON
>>>> THE FAA, not on your to prove you are innocent. Sometimes certain FAA
>>>> Inspectors forget that fact. Some Inspectors also assume that
>>> anything
>>>> they say is automatically correct. Anything you say is automatically
>>>> wrong. You need to know your regulations and you also need the phone
>>>> number to the EAA's Govt. Hotline. Ask for Randy Hanson.
>>>>
>>>> NUMBER TWO: If they still play nasty.... Go back to the motel, do a
>>>> handwritten modification to your Program Letter on a paper napkin, go
>>>> down to the Hotel Desk and FAX IT to your local FISDO. The go back to
>>>> the airport and hand that FAA Inspector the paper napkin and bit him a
>>>> fond farewell. I am not being sarcastic here. OK. The paper napkin
>>>> part is supposed to be a joke (OK who-ever from the FAA READS THIS? A
>>>> JOKE! PLEASE? Good grief).
>>>>
>>>> Not that I think you're wrong about carrying the stuff along. The FAA
>>>> CONSTANTLY (!!!) interprets things differently and they can come up
>>> with
>>>> the strangest things (flying with my door off, etc) and you have to go
>>>> to the ends of the Earth to get them to see things a little bit
>>>> differently.
>>>>
>>>> Just saying. I think being polite but not cowardly is the best
>>>> approach... my 2 cents.
>>>>
>>>> Mark
>>>>
>>>>
>>>>
>>>>
>>>> -----Original Message-----
>>>> From: owner-yak-list-server@matronics.com
>>>> [mailto:owner-yak-list-server@matronics.com] On Behalf Of A. Dennis
>>>> Savarese
>>>> Sent: Tuesday, May 24, 2011 10:47 PM
>>>> To: yak-list@matronics.com
>>>> Subject: Re: Yak-List: Re: Program Letter
>>>>
>>>> --> Yak-List message posted by: "A. Dennis Savarese"
>>>> <dsavarese0812@bellsouth.net>
>>>>
>>>> Here's something to think about.
>>>> The program letter and modifications which you may send by fax are in
>>>> fact part of the Operating Limitations for the airplane. We all know
>>>> you are required to carry the OL's in the airplane at all times.
>>> Since
>>>> the Program Letter is actually a part of the OL's, then IMHO, it is
>>> also
>>>> required to be carried in the airplane.
>>>>
>>>> Unfortunately, when the FAA removed the 300/600 NM proficiency area,
>>>> they failed to include the elimination of the Program Letter, which
>>>> would have made logical sense. ie: if you don't have any restrictions
>>>> as to where you can fly, they why do you need a Program Letter to
>>> attend
>>>> an event?
>>>>
>>>> When you attend an event that may also be attended by the FAA
>>> (typically
>>>> when there is wavered airspace) and they ask to see your aircraft's
>>>> paperwork as well as you pilot certificate and current medical form,
>>>> when you hand him/her the aircraft's Operating Limitations he/she will
>>>> also ask to see your Program Letter or modification for this specific
>>>> event. If you do not have your Program Letter with the specific event
>>>> on it or a modification/update to the program letter which you
>>> submitted
>>>> to your FSDO with you, the FAA person may not permit you to stay at
>>> the
>>>> event. I had this happen to me about 5 years ago. Thus, when I sent
>>>> my program letter in to the FSDO each year, I automatically put a copy
>>>> in the airplane along with any modifications.
>>>> Dennis
>>>>
>>>> On 5/24/2011 9:00 PM, keithmckinley wrote:
>>>>> --> Yak-List message posted by:
>>>> "keithmckinley"<keith.mckinley@townisp.com>
>>>>> Mark,
>>>>>
>>>>> Thanks for the feedback.
>>>>>
>>>>> No 300 mile restriction. No doubt it is easier to play nice with the
>>>> Fed's and yes it does pay dividends, but sometimes I think it's
>>>> important to make sure they interpret things correctly and realize
>>> (as
>>>> inspectors) they don't make the rules. More than anything, I just have
>>>> an aversion to ass kissing.......but not to protecting my own ass!
>>>>> Semper Fi
>>>>>
>>>>> Keith
>>>>>
>>>>> --------
>>>>> Keith McKinley
>>>>> 700HS
>>>>> KFIT
>>>>>
>>>>>
>>>>>
>>>>>
>>>>> Read this topic online here:
>>>>>
>>>>> http://forums.matronics.com/viewtopic.php?p=340874#340874
>>>>>
>>>>>
>>>>>
>>>>>
>>>>>
>>>>>
>>>>>
>>>>>
>>>>>
>>>>>
>>>>>
>>>>
>>>>
>>>>
>>>>
>>>>
>>>>
>>>>
>>>>
>>>
>>>
>>>
>>>
>>>
>>>
>>>
>>>
>>>
>>
>>
>>
>>
>>
>
>
Message 31
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|
| Subject: | Re: Program Letter |
Jim,
From 8130.2G, Group 2 definition which clearly gives the example of a
Yak 52 in the group at the bottom of the group, it says:
(f) Must be in compliance with the manufacturers or country of origins
maintenance, and/or inspection programs (if provided).
(g) If the manufacturer or country of origin does not provide an inspection
program, the aircraft must have an annual condition inspection that
meets the scope and detail of
14 CFR part 43, appendix D.
Since the manufacturer has not provided maintenance and/or inspection
program, the requirement defaults to paragraph (g), which is the same
old stuff we've always had. ie: Condition inspection that meets the
scope and detail of 14 CFR 43, Appendix D.
On 5/25/2011 3:04 PM, Jim Griffin wrote:
>
> I neglected to add that the program letter must be in the plane. Refer
> to previously sent attachment.
> Jim Griffin
>
>
> ----- Original Message ----- From: "Jim Griffin" <jgriffint28@cox.net>
> To: <yak-list@matronics.com>
> Sent: Wednesday, May 25, 2011 2:36 PM
> Subject: Re: Yak-List: Re: Program Letter
>
>
> I recently talked to my FSDO about changing my 300 mile limits. He is a
> helpful guy and sent me a copy of what the new op limits look like on
> someone elses plane. In it, the program letter must list who is
> responsible
> for maintenance for the plane. He also asked me for a printed maintenance
> program. I have included a copy. Check paragraph 3.
> Jim Griffin
> ----- Original Message ----- From: "A. Dennis Savarese"
> <dsavarese0812@bellsouth.net>
> To: <yak-list@matronics.com>
> Sent: Wednesday, May 25, 2011 10:08 AM
> Subject: Re: Yak-List: Re: Program Letter
>
>
> <dsavarese0812@bellsouth.net>
>
> Any new Special Airworthiness Certificates and Operating Limitations
> will be issued under 8130.2G. This includes any request for the change
> to eliminate the 300/600 mile proficiency area that may currently be in
> your existing OL's.
> Dennis
>
> On 5/25/2011 9:48 AM, A. Dennis Savarese wrote:
>> <dsavarese0812@bellsouth.net>
>>
>> For those that are operating under the older 8130.2F, here is a
>> paragraph
>> that is included in all of the groups, including ours, Group III. Just
>> for grins, see if there is a paragraph in your own OL's that says
>> something like the following".
>>
>> "....(2) No person may operate this aircraft for other than the
>> purpose of
>> meeting the requirements
>> of 91.319(b), as stated in the program letter (required by
>> 21.193) for
>> this aircraft. This aircraft must
>> be operated in accordance with applicable air traffic and general
>> operating rules of part 91, as well as all
>> additional limitations herein prescribed under the provisions of
>> 91.319(e). These operating limitations
>> are a part of the special airworthiness certificate, and are to be
>> carried
>> in the aircraft at all times
>> and made available to the pilot in command of the aircraft.
>> (Applicability: All)
>> Dennis
>>
>>
>> On 5/25/2011 9:26 AM, Bitterlich, Mark G CIV Det Cherry Point,
>> MALS-14 64E
>> wrote:
>>> Point, MALS-14 64E"<mark.bitterlich@navy.mil>
>>>
>>> Just did :-)
>>>
>>> -----Original Message-----
>>> From: owner-yak-list-server@matronics.com
>>> [mailto:owner-yak-list-server@matronics.com] On Behalf Of A. Dennis
>>> Savarese
>>> Sent: Wednesday, May 25, 2011 10:15 AM
>>> To: yak-list@matronics.com
>>> Subject: Re: Yak-List: Re: Program Letter
>>>
>>> <dsavarese0812@bellsouth.net>
>>>
>>> Mark, I respectfully request you read my next posting on the subject.
>>> :-)
>>>
>>> On 5/25/2011 9:04 AM, Bitterlich, Mark G CIV Det Cherry Point, MALS-14
>>> 64E wrote:
>>> Point, MALS-14 64E"<mark.bitterlich@navy.mil>
>>>> Dennis, I respectfully disagree with your point of view in this one
>>>> area.
>>>>
>>>> You mentioned:
>>>>
>>>> "The program letter and modifications which you may send by fax are in
>>>> fact part of the Operating Limitations for the airplane. We all know
>>>> you are required to carry the OL's in the airplane at all times.
>>> Since
>>>> the Program Letter is actually a part of the OL's, then IMHO, it is
>>> also
>>>> required to be carried in the airplane."
>>>>
>>>> The Operating Limitations also require a Conditional Inspection every
>>>> year. By the same logic, you would also need to carry along a copy of
>>>> your Conditional Inspection, or copies of your aircraft logbooks, etc.
>>>> My opinion on dealing with the FAA on things like this is when they
>>> say:
>>>>
>>>> "We need to see a copy of your Program Letter or modification of same,
>>>> and if you don't have it with you, you must leave."
>>>>
>>>> NUMBER ONE: !!! Reply with: "Please quote the Regulation that
>>>> specifically states I must carry a copy of my Program Letter with me.
>>>> If you cannot quote me the exact regulation that requires me to do
>>> this,
>>>> I respectfully submit you have no authority to demand it from me".
>>>>
>>>> You must carry a copy of your Operating Limitations. READ THEM!
>>> Break
>>>> them out and have the FAA Inspector SHOW YOU on the Operating
>>>> Limitations where it says what he is saying. THE BURDON OF PROOF IS
>>> ON
>>>> THE FAA, not on your to prove you are innocent. Sometimes certain FAA
>>>> Inspectors forget that fact. Some Inspectors also assume that
>>> anything
>>>> they say is automatically correct. Anything you say is automatically
>>>> wrong. You need to know your regulations and you also need the phone
>>>> number to the EAA's Govt. Hotline. Ask for Randy Hanson.
>>>>
>>>> NUMBER TWO: If they still play nasty.... Go back to the motel, do a
>>>> handwritten modification to your Program Letter on a paper napkin, go
>>>> down to the Hotel Desk and FAX IT to your local FISDO. The go back to
>>>> the airport and hand that FAA Inspector the paper napkin and bit him a
>>>> fond farewell. I am not being sarcastic here. OK. The paper napkin
>>>> part is supposed to be a joke (OK who-ever from the FAA READS THIS? A
>>>> JOKE! PLEASE? Good grief).
>>>>
>>>> Not that I think you're wrong about carrying the stuff along. The FAA
>>>> CONSTANTLY (!!!) interprets things differently and they can come up
>>> with
>>>> the strangest things (flying with my door off, etc) and you have to go
>>>> to the ends of the Earth to get them to see things a little bit
>>>> differently.
>>>>
>>>> Just saying. I think being polite but not cowardly is the best
>>>> approach... my 2 cents.
>>>>
>>>> Mark
>>>>
>>>>
>>>>
>>>>
>>>> -----Original Message-----
>>>> From: owner-yak-list-server@matronics.com
>>>> [mailto:owner-yak-list-server@matronics.com] On Behalf Of A. Dennis
>>>> Savarese
>>>> Sent: Tuesday, May 24, 2011 10:47 PM
>>>> To: yak-list@matronics.com
>>>> Subject: Re: Yak-List: Re: Program Letter
>>>>
>>>> <dsavarese0812@bellsouth.net>
>>>>
>>>> Here's something to think about.
>>>> The program letter and modifications which you may send by fax are in
>>>> fact part of the Operating Limitations for the airplane. We all know
>>>> you are required to carry the OL's in the airplane at all times.
>>> Since
>>>> the Program Letter is actually a part of the OL's, then IMHO, it is
>>> also
>>>> required to be carried in the airplane.
>>>>
>>>> Unfortunately, when the FAA removed the 300/600 NM proficiency area,
>>>> they failed to include the elimination of the Program Letter, which
>>>> would have made logical sense. ie: if you don't have any restrictions
>>>> as to where you can fly, they why do you need a Program Letter to
>>> attend
>>>> an event?
>>>>
>>>> When you attend an event that may also be attended by the FAA
>>> (typically
>>>> when there is wavered airspace) and they ask to see your aircraft's
>>>> paperwork as well as you pilot certificate and current medical form,
>>>> when you hand him/her the aircraft's Operating Limitations he/she will
>>>> also ask to see your Program Letter or modification for this specific
>>>> event. If you do not have your Program Letter with the specific event
>>>> on it or a modification/update to the program letter which you
>>> submitted
>>>> to your FSDO with you, the FAA person may not permit you to stay at
>>> the
>>>> event. I had this happen to me about 5 years ago. Thus, when I sent
>>>> my program letter in to the FSDO each year, I automatically put a copy
>>>> in the airplane along with any modifications.
>>>> Dennis
>>>>
>>>> On 5/24/2011 9:00 PM, keithmckinley wrote:
>>>> "keithmckinley"<keith.mckinley@townisp.com>
>>>>> Mark,
>>>>>
>>>>> Thanks for the feedback.
>>>>>
>>>>> No 300 mile restriction. No doubt it is easier to play nice with the
>>>> Fed's and yes it does pay dividends, but sometimes I think it's
>>>> important to make sure they interpret things correctly and realize
>>> (as
>>>> inspectors) they don't make the rules. More than anything, I just have
>>>> an aversion to ass kissing.......but not to protecting my own ass!
>>>>> Semper Fi
>>>>>
>>>>> Keith
>>>>>
>>>>> --------
>>>>> Keith McKinley
>>>>> 700HS
>>>>> KFIT
>>>>>
>>>>>
>>>>>
>>>>>
>>>>> Read this topic online here:
>>>>>
>>>>> http://forums.matronics.com/viewtopic.php?p=340874#340874
>>>>>
>>>>>
>>>>>
>>>>>
>>>>>
>>>>>
>>>>>
>>>>>
>>>>>
>>>>>
>>>>>
>>>>
>>>>
>>>>
>>>>
>>>>
>>>>
>>>>
>>>>
>>>
>>>
>>>
>>>
>>>
>>>
>>>
>>>
>>>
>>
>>
>>
>>
>>
>
>
Message 32
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|
| Subject: | Re: Program Letter |
I just got my new OL and AC last week from the Dallas FSDO for Yak 50. Experimental
Exhibition, Group 2. No maintenance program required and actually very pleased
with both my new Operating Limits as well as the FAST and great service
at the FSDO.
Jj
Sent from my iPhone
On May 25, 2011, at 8:06 PM, "A. Dennis Savarese" <dsavarese0812@bellsouth.net>
wrote:
>
> Jim,
> I read the new OL's completely and I don't see anything that says you have to
submit a printed maintenance program to the FAA for the group your aircraft is
certificated in. I do see a maintenance program/inspection program requirement
for the larger airplanes and jets as specified in paragraph 29. But not
for Group 2. Am I missing something or is your FSDO guy crossing Group boundaries?
>
> As for the requirement to list in the program letter who is responsible for the
maintenance of the airplane, that should not be an issue. Most everyone will
list themselves unless they have a mechanic that does the work for them.
> Dennis
>
> On 5/25/2011 2:36 PM, Jim Griffin wrote:
>> I recently talked to my FSDO about changing my 300 mile limits. He is a helpful
guy and sent me a copy of what the new op limits look like on someone elses
plane. In it, the program letter must list who is responsible for maintenance
for the plane. He also asked me for a printed maintenance program. I have included
a copy. Check paragraph 3.
>> Jim Griffin
>> ----- Original Message ----- From: "A. Dennis Savarese" <dsavarese0812@bellsouth.net>
>> To: <yak-list@matronics.com>
>> Sent: Wednesday, May 25, 2011 10:08 AM
>> Subject: Re: Yak-List: Re: Program Letter
>>
>>
>>
>> Any new Special Airworthiness Certificates and Operating Limitations
>> will be issued under 8130.2G. This includes any request for the change
>> to eliminate the 300/600 mile proficiency area that may currently be in
>> your existing OL's.
>> Dennis
>>
>> On 5/25/2011 9:48 AM, A. Dennis Savarese wrote:
>>>
>>> For those that are operating under the older 8130.2F, here is a paragraph that
is included in all of the groups, including ours, Group III. Just for grins,
see if there is a paragraph in your own OL's that says something like the
following".
>>>
>>> "....(2) No person may operate this aircraft for other than the purpose of
meeting the requirements
>>> of 91.319(b), as stated in the program letter (required by 21.193) for this
aircraft. This aircraft must
>>> be operated in accordance with applicable air traffic and general operating
rules of part 91, as well as all
>>> additional limitations herein prescribed under the provisions of 91.319(e).
These operating limitations
>>> are a part of the special airworthiness certificate, and are to be carried
in the aircraft at all times
>>> and made available to the pilot in command of the aircraft.
>>> (Applicability: All)
>>> Dennis
>>>
>>>
>>> On 5/25/2011 9:26 AM, Bitterlich, Mark G CIV Det Cherry Point, MALS-14 64E
wrote:
>>>> --> Yak-List message posted by: "Bitterlich, Mark G CIV Det Cherry Point,
MALS-14 64E"<mark.bitterlich@navy.mil>
>>>>
>>>> Just did :-)
>>>>
>>>> -----Original Message-----
>>>> From: owner-yak-list-server@matronics.com
>>>> [mailto:owner-yak-list-server@matronics.com] On Behalf Of A. Dennis
>>>> Savarese
>>>> Sent: Wednesday, May 25, 2011 10:15 AM
>>>> To: yak-list@matronics.com
>>>> Subject: Re: Yak-List: Re: Program Letter
>>>>
>>>> --> Yak-List message posted by: "A. Dennis Savarese"
>>>> <dsavarese0812@bellsouth.net>
>>>>
>>>> Mark, I respectfully request you read my next posting on the subject.
>>>> :-)
>>>>
>>>> On 5/25/2011 9:04 AM, Bitterlich, Mark G CIV Det Cherry Point, MALS-14
>>>> 64E wrote:
>>>>> --> Yak-List message posted by: "Bitterlich, Mark G CIV Det Cherry
>>>> Point, MALS-14 64E"<mark.bitterlich@navy.mil>
>>>>> Dennis, I respectfully disagree with your point of view in this one
>>>>> area.
>>>>>
>>>>> You mentioned:
>>>>>
>>>>> "The program letter and modifications which you may send by fax are in
>>>>> fact part of the Operating Limitations for the airplane. We all know
>>>>> you are required to carry the OL's in the airplane at all times.
>>>> Since
>>>>> the Program Letter is actually a part of the OL's, then IMHO, it is
>>>> also
>>>>> required to be carried in the airplane."
>>>>>
>>>>> The Operating Limitations also require a Conditional Inspection every
>>>>> year. By the same logic, you would also need to carry along a copy of
>>>>> your Conditional Inspection, or copies of your aircraft logbooks, etc.
>>>>> My opinion on dealing with the FAA on things like this is when they
>>>> say:
>>>>>
>>>>> "We need to see a copy of your Program Letter or modification of same,
>>>>> and if you don't have it with you, you must leave."
>>>>>
>>>>> NUMBER ONE: !!! Reply with: "Please quote the Regulation that
>>>>> specifically states I must carry a copy of my Program Letter with me.
>>>>> If you cannot quote me the exact regulation that requires me to do
>>>> this,
>>>>> I respectfully submit you have no authority to demand it from me".
>>>>>
>>>>> You must carry a copy of your Operating Limitations. READ THEM!
>>>> Break
>>>>> them out and have the FAA Inspector SHOW YOU on the Operating
>>>>> Limitations where it says what he is saying. THE BURDON OF PROOF IS
>>>> ON
>>>>> THE FAA, not on your to prove you are innocent. Sometimes certain FAA
>>>>> Inspectors forget that fact. Some Inspectors also assume that
>>>> anything
>>>>> they say is automatically correct. Anything you say is automatically
>>>>> wrong. You need to know your regulations and you also need the phone
>>>>> number to the EAA's Govt. Hotline. Ask for Randy Hanson.
>>>>>
>>>>> NUMBER TWO: If they still play nasty.... Go back to the motel, do a
>>>>> handwritten modification to your Program Letter on a paper napkin, go
>>>>> down to the Hotel Desk and FAX IT to your local FISDO. The go back to
>>>>> the airport and hand that FAA Inspector the paper napkin and bit him a
>>>>> fond farewell. I am not being sarcastic here. OK. The paper napkin
>>>>> part is supposed to be a joke (OK who-ever from the FAA READS THIS? A
>>>>> JOKE! PLEASE? Good grief).
>>>>>
>>>>> Not that I think you're wrong about carrying the stuff along. The FAA
>>>>> CONSTANTLY (!!!) interprets things differently and they can come up
>>>> with
>>>>> the strangest things (flying with my door off, etc) and you have to go
>>>>> to the ends of the Earth to get them to see things a little bit
>>>>> differently.
>>>>>
>>>>> Just saying. I think being polite but not cowardly is the best
>>>>> approach... my 2 cents.
>>>>>
>>>>> Mark
>>>>>
>>>>>
>>>>>
>>>>>
>>>>> -----Original Message-----
>>>>> From: owner-yak-list-server@matronics.com
>>>>> [mailto:owner-yak-list-server@matronics.com] On Behalf Of A. Dennis
>>>>> Savarese
>>>>> Sent: Tuesday, May 24, 2011 10:47 PM
>>>>> To: yak-list@matronics.com
>>>>> Subject: Re: Yak-List: Re: Program Letter
>>>>>
>>>>> --> Yak-List message posted by: "A. Dennis Savarese"
>>>>> <dsavarese0812@bellsouth.net>
>>>>>
>>>>> Here's something to think about.
>>>>> The program letter and modifications which you may send by fax are in
>>>>> fact part of the Operating Limitations for the airplane. We all know
>>>>> you are required to carry the OL's in the airplane at all times.
>>>> Since
>>>>> the Program Letter is actually a part of the OL's, then IMHO, it is
>>>> also
>>>>> required to be carried in the airplane.
>>>>>
>>>>> Unfortunately, when the FAA removed the 300/600 NM proficiency area,
>>>>> they failed to include the elimination of the Program Letter, which
>>>>> would have made logical sense. ie: if you don't have any restrictions
>>>>> as to where you can fly, they why do you need a Program Letter to
>>>> attend
>>>>> an event?
>>>>>
>>>>> When you attend an event that may also be attended by the FAA
>>>> (typically
>>>>> when there is wavered airspace) and they ask to see your aircraft's
>>>>> paperwork as well as you pilot certificate and current medical form,
>>>>> when you hand him/her the aircraft's Operating Limitations he/she will
>>>>> also ask to see your Program Letter or modification for this specific
>>>>> event. If you do not have your Program Letter with the specific event
>>>>> on it or a modification/update to the program letter which you
>>>> submitted
>>>>> to your FSDO with you, the FAA person may not permit you to stay at
>>>> the
>>>>> event. I had this happen to me about 5 years ago. Thus, when I sent
>>>>> my program letter in to the FSDO each year, I automatically put a copy
>>>>> in the airplane along with any modifications.
>>>>> Dennis
>>>>>
>>>>> On 5/24/2011 9:00 PM, keithmckinley wrote:
>>>>>> --> Yak-List message posted by:
>>>>> "keithmckinley"<keith.mckinley@townisp.com>
>>>>>> Mark,
>>>>>>
>>>>>> Thanks for the feedback.
>>>>>>
>>>>>> No 300 mile restriction. No doubt it is easier to play nice with the
>>>>> Fed's and yes it does pay dividends, but sometimes I think it's
>>>>> important to make sure they interpret things correctly and realize
>>>> (as
>>>>> inspectors) they don't make the rules. More than anything, I just have
>>>>> an aversion to ass kissing.......but not to protecting my own ass!
>>>>>> Semper Fi
>>>>>>
>>>>>> Keith
>>>>>>
>>>>>> --------
>>>>>> Keith McKinley
>>>>>> 700HS
>>>>>> KFIT
>>>>>>
>>>>>>
>>>>>>
>>>>>>
>>>>>> Read this topic online here:
>>>>>>
>>>>>> http://forums.matronics.com/viewtopic.php?p=340874#340874
>>>>>>
>>>>>>
>>>>>>
>>>>>>
>>>>>>
>>>>>>
>>>>>>
>>>>>>
>>>>>>
>>>>>>
>>>>>>
>>>>>
>>>>>
>>>>>
>>>>>
>>>>>
>>>>>
>>>>>
>>>>>
>>>>
>>>>
>>>>
>>>>
>>>>
>>>>
>>>>
>>>>
>>>>
>>>
>>>
>>>
>>>
>>>
>>
>>
>>
>>
>
>
>
>
Message 33
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| LIST | Reply to LIST Regarding this Message |
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|
| Subject: | Re: Program Letter |
Dennis, I used your response in a letter I just sent to my FSDO in OK City.
I will let you know his response. Like I said, he is a helpful guy and this
may be a teachable moment for him as well.
Jim Griffin
----- Original Message -----
From: "A. Dennis Savarese" <dsavarese0812@bellsouth.net>
Sent: Wednesday, May 25, 2011 8:16 PM
Subject: Re: Yak-List: Re: Program Letter
<dsavarese0812@bellsouth.net>
Jim,
From 8130.2G, Group 2 definition which clearly gives the example of a
Yak 52 in the group at the bottom of the group, it says:
(f) Must be in compliance with the manufacturers or country of origins
maintenance, and/or inspection programs (if provided).
(g) If the manufacturer or country of origin does not provide an inspection
program, the aircraft must have an annual condition inspection that
meets the scope and detail of
14 CFR part 43, appendix D.
Since the manufacturer has not provided maintenance and/or inspection
program, the requirement defaults to paragraph (g), which is the same
old stuff we've always had. ie: Condition inspection that meets the
scope and detail of 14 CFR 43, Appendix D.
>>>>>
>>>>>
>>>>>
>>>>>
>>>>>
>>>>>
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Message 34
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| Subject: | Re: Program Letter |
Copy, Mark. Program letter is already in the A/C's don't do tail slides anyway.
All it represents to is out of airspeed, out of energy, out of options, and
out of ideas making for a nice big fat target for a guns snap shot. Why waste
an Atoll or an AIM 9 when a wall of 20 mm will do?!
guess what I'm saying is I could care less about tail slides. ;^))
doc
Sent from my iPad
On May 25, 2011, at 5:22 PM, "Bitterlich, Mark G CIV Det Cherry Point, MALS-14
64E" <mark.bitterlich@navy.mil> wrote:
>
> No Hoopla. Put the copy in your airplane and DOC! DON'T DO ANY TAIL SLIDES
EITHER!
>
>
> 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: Wednesday, May 25, 2011 5:58 PM
> To: yak-list@matronics.com
> Subject: RE: Yak-List: Re: Program Letter
>
>
> What's all the hoop La? Make a copy and put it in the airplane.
> Doc
>
> -----Original Message-----
> From: owner-yak-list-server@matronics.com
> [mailto:owner-yak-list-server@matronics.com] On Behalf Of A. Dennis Savarese
> Sent: Wednesday, May 25, 2011 10:09 AM
> To: yak-list@matronics.com
> Subject: Re: Yak-List: Re: Program Letter
>
> --> <dsavarese0812@bellsouth.net>
>
> Any new Special Airworthiness Certificates and Operating Limitations will be
> issued under 8130.2G. This includes any request for the change to eliminate
> the 300/600 mile proficiency area that may currently be in your existing
> OL's.
> Dennis
>
> On 5/25/2011 9:48 AM, A. Dennis Savarese wrote:
>> <dsavarese0812@bellsouth.net>
>>
>> For those that are operating under the older 8130.2F, here is a
Message 35
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| Subject: | Re: Program Letter |
I think Jim's "helpful guy" is crossing Group boundaries...just as you said. I've
gone through all that many moons ago with an FAA inspector that was really
convinced that such a printed maintenance program was absolutely required. I
showed him the 800 h.p. boundary reg. and he agreed....but it seemed that it
was up to me to educate him. Perhaps that is what Jim is gonna' have to do with
his FAA guy.
Roger Baker____________________________________________
On May 25, 2011, at 6:06 PM, A. Dennis Savarese wrote:
>
> Jim,
> I read the new OL's completely and I don't see anything that says you have to
submit a printed maintenance program to the FAA for the group your aircraft is
certificated in. I do see a maintenance program/inspection program requirement
for the larger airplanes and jets as specified in paragraph 29. But not
for Group 2. Am I missing something or is your FSDO guy crossing Group boundaries?
>
> As for the requirement to list in the program letter who is responsible for the
maintenance of the airplane, that should not be an issue. Most everyone will
list themselves unless they have a mechanic that does the work for them.
> Dennis
>
> On 5/25/2011 2:36 PM, Jim Griffin wrote:
>> I recently talked to my FSDO about changing my 300 mile limits. He is a helpful
guy and sent me a copy of what the new op limits look like on someone elses
plane. In it, the program letter must list who is responsible for maintenance
for the plane. He also asked me for a printed maintenance program. I have included
a copy. Check paragraph 3.
>> Jim Griffin
>> ----- Original Message ----- From: "A. Dennis Savarese" <dsavarese0812@bellsouth.net>
>> To: <yak-list@matronics.com>
>> Sent: Wednesday, May 25, 2011 10:08 AM
>> Subject: Re: Yak-List: Re: Program Letter
>>
>>
>>
>> Any new Special Airworthiness Certificates and Operating Limitations
>> will be issued under 8130.2G. This includes any request for the change
>> to eliminate the 300/600 mile proficiency area that may currently be in
>> your existing OL's.
>> Dennis
>>
>> On 5/25/2011 9:48 AM, A. Dennis Savarese wrote:
>>>
>>> For those that are operating under the older 8130.2F, here is a paragraph that
is included in all of the groups, including ours, Group III. Just for grins,
see if there is a paragraph in your own OL's that says something like the
following".
>>>
>>> "....(2) No person may operate this aircraft for other than the purpose of
meeting the requirements
>>> of 91.319(b), as stated in the program letter (required by 21.193) for this
aircraft. This aircraft must
>>> be operated in accordance with applicable air traffic and general operating
rules of part 91, as well as all
>>> additional limitations herein prescribed under the provisions of 91.319(e).
These operating limitations
>>> are a part of the special airworthiness certificate, and are to be carried
in the aircraft at all times
>>> and made available to the pilot in command of the aircraft.
>>> (Applicability: All)
>>> Dennis
>>>
>>>
>>> On 5/25/2011 9:26 AM, Bitterlich, Mark G CIV Det Cherry Point, MALS-14 64E
wrote:
>>>> --> Yak-List message posted by: "Bitterlich, Mark G CIV Det Cherry Point,
MALS-14 64E"<mark.bitterlich@navy.mil>
>>>>
>>>> Just did :-)
>>>>
>>>> -----Original Message-----
>>>> From: owner-yak-list-server@matronics.com
>>>> [mailto:owner-yak-list-server@matronics.com] On Behalf Of A. Dennis
>>>> Savarese
>>>> Sent: Wednesday, May 25, 2011 10:15 AM
>>>> To: yak-list@matronics.com
>>>> Subject: Re: Yak-List: Re: Program Letter
>>>>
>>>> --> Yak-List message posted by: "A. Dennis Savarese"
>>>> <dsavarese0812@bellsouth.net>
>>>>
>>>> Mark, I respectfully request you read my next posting on the subject.
>>>> :-)
>>>>
>>>> On 5/25/2011 9:04 AM, Bitterlich, Mark G CIV Det Cherry Point, MALS-14
>>>> 64E wrote:
>>>>> --> Yak-List message posted by: "Bitterlich, Mark G CIV Det Cherry
>>>> Point, MALS-14 64E"<mark.bitterlich@navy.mil>
>>>>> Dennis, I respectfully disagree with your point of view in this one
>>>>> area.
>>>>>
>>>>> You mentioned:
>>>>>
>>>>> "The program letter and modifications which you may send by fax are in
>>>>> fact part of the Operating Limitations for the airplane. We all know
>>>>> you are required to carry the OL's in the airplane at all times.
>>>> Since
>>>>> the Program Letter is actually a part of the OL's, then IMHO, it is
>>>> also
>>>>> required to be carried in the airplane."
>>>>>
>>>>> The Operating Limitations also require a Conditional Inspection every
>>>>> year. By the same logic, you would also need to carry along a copy of
>>>>> your Conditional Inspection, or copies of your aircraft logbooks, etc.
>>>>> My opinion on dealing with the FAA on things like this is when they
>>>> say:
>>>>>
>>>>> "We need to see a copy of your Program Letter or modification of same,
>>>>> and if you don't have it with you, you must leave."
>>>>>
>>>>> NUMBER ONE: !!! Reply with: "Please quote the Regulation that
>>>>> specifically states I must carry a copy of my Program Letter with me.
>>>>> If you cannot quote me the exact regulation that requires me to do
>>>> this,
>>>>> I respectfully submit you have no authority to demand it from me".
>>>>>
>>>>> You must carry a copy of your Operating Limitations. READ THEM!
>>>> Break
>>>>> them out and have the FAA Inspector SHOW YOU on the Operating
>>>>> Limitations where it says what he is saying. THE BURDON OF PROOF IS
>>>> ON
>>>>> THE FAA, not on your to prove you are innocent. Sometimes certain FAA
>>>>> Inspectors forget that fact. Some Inspectors also assume that
>>>> anything
>>>>> they say is automatically correct. Anything you say is automatically
>>>>> wrong. You need to know your regulations and you also need the phone
>>>>> number to the EAA's Govt. Hotline. Ask for Randy Hanson.
>>>>>
>>>>> NUMBER TWO: If they still play nasty.... Go back to the motel, do a
>>>>> handwritten modification to your Program Letter on a paper napkin, go
>>>>> down to the Hotel Desk and FAX IT to your local FISDO. The go back to
>>>>> the airport and hand that FAA Inspector the paper napkin and bit him a
>>>>> fond farewell. I am not being sarcastic here. OK. The paper napkin
>>>>> part is supposed to be a joke (OK who-ever from the FAA READS THIS? A
>>>>> JOKE! PLEASE? Good grief).
>>>>>
>>>>> Not that I think you're wrong about carrying the stuff along. The FAA
>>>>> CONSTANTLY (!!!) interprets things differently and they can come up
>>>> with
>>>>> the strangest things (flying with my door off, etc) and you have to go
>>>>> to the ends of the Earth to get them to see things a little bit
>>>>> differently.
>>>>>
>>>>> Just saying. I think being polite but not cowardly is the best
>>>>> approach... my 2 cents.
>>>>>
>>>>> Mark
>>>>>
>>>>>
>>>>>
>>>>>
>>>>> -----Original Message-----
>>>>> From: owner-yak-list-server@matronics.com
>>>>> [mailto:owner-yak-list-server@matronics.com] On Behalf Of A. Dennis
>>>>> Savarese
>>>>> Sent: Tuesday, May 24, 2011 10:47 PM
>>>>> To: yak-list@matronics.com
>>>>> Subject: Re: Yak-List: Re: Program Letter
>>>>>
>>>>> --> Yak-List message posted by: "A. Dennis Savarese"
>>>>> <dsavarese0812@bellsouth.net>
>>>>>
>>>>> Here's something to think about.
>>>>> The program letter and modifications which you may send by fax are in
>>>>> fact part of the Operating Limitations for the airplane. We all know
>>>>> you are required to carry the OL's in the airplane at all times.
>>>> Since
>>>>> the Program Letter is actually a part of the OL's, then IMHO, it is
>>>> also
>>>>> required to be carried in the airplane.
>>>>>
>>>>> Unfortunately, when the FAA removed the 300/600 NM proficiency area,
>>>>> they failed to include the elimination of the Program Letter, which
>>>>> would have made logical sense. ie: if you don't have any restrictions
>>>>> as to where you can fly, they why do you need a Program Letter to
>>>> attend
>>>>> an event?
>>>>>
>>>>> When you attend an event that may also be attended by the FAA
>>>> (typically
>>>>> when there is wavered airspace) and they ask to see your aircraft's
>>>>> paperwork as well as you pilot certificate and current medical form,
>>>>> when you hand him/her the aircraft's Operating Limitations he/she will
>>>>> also ask to see your Program Letter or modification for this specific
>>>>> event. If you do not have your Program Letter with the specific event
>>>>> on it or a modification/update to the program letter which you
>>>> submitted
>>>>> to your FSDO with you, the FAA person may not permit you to stay at
>>>> the
>>>>> event. I had this happen to me about 5 years ago. Thus, when I sent
>>>>> my program letter in to the FSDO each year, I automatically put a copy
>>>>> in the airplane along with any modifications.
>>>>> Dennis
>>>>>
>>>>> On 5/24/2011 9:00 PM, keithmckinley wrote:
>>>>>> --> Yak-List message posted by:
>>>>> "keithmckinley"<keith.mckinley@townisp.com>
>>>>>> Mark,
>>>>>>
>>>>>> Thanks for the feedback.
>>>>>>
>>>>>> No 300 mile restriction. No doubt it is easier to play nice with the
>>>>> Fed's and yes it does pay dividends, but sometimes I think it's
>>>>> important to make sure they interpret things correctly and realize
>>>> (as
>>>>> inspectors) they don't make the rules. More than anything, I just have
>>>>> an aversion to ass kissing.......but not to protecting my own ass!
>>>>>> Semper Fi
>>>>>>
>>>>>> Keith
>>>>>>
>>>>>> --------
>>>>>> Keith McKinley
>>>>>> 700HS
>>>>>> KFIT
>>>>>>
>>>>>>
>>>>>>
>>>>>>
>>>>>> Read this topic online here:
>>>>>>
>>>>>> http://forums.matronics.com/viewtopic.php?p=340874#340874
>>>>>>
>>>>>>
>>>>>>
>>>>>>
>>>>>>
>>>>>>
>>>>>>
>>>>>>
>>>>>>
>>>>>>
>>>>>>
>>>>>
>>>>>
>>>>>
>>>>>
>>>>>
>>>>>
>>>>>
>>>>>
>>>>
>>>>
>>>>
>>>>
>>>>
>>>>
>>>>
>>>>
>>>>
>>>
>>>
>>>
>>>
>>>
>>
>>
>>
>>
>
>
>
>
Roger E. Baker, Managing Director
Panadero Energy Components, LLC
dba PEC AirAssist
760/809-5506
760/730-9244
760/454-4595 fax
f4ffm2@roadrunner.com
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