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Program Letter
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mark.bitterlich(at)navy.m
Guest

Posted: Wed May 25, 2011 11:29 am Post subject: Program Letter

So does 8130.2G apply to those of us that were issued Special Airworthiness Certificates under 8130.2F or not?  



Mark

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jgriffint28(at)cox.net
Guest

Posted: Wed May 25, 2011 11:40 am Post subject: 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

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mark.bitterlich(at)navy.m
Guest

Posted: Wed May 25, 2011 11:58 am Post subject: 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





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cjpilot710(at)aol.com
Guest

Posted: Wed May 25, 2011 12:06 pm Post subject: 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(at)cox.net writes:

 [quote]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

---

jgriffint28(at)cox.net
Guest

Posted: Wed May 25, 2011 12:07 pm Post subject: Program Letter

I neglected to add that the program letter must be in the plane. Refer to 

previously sent attachment.

Jim Griffin

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viperdoc(at)mindspring.co
Guest

Posted: Wed May 25, 2011 2:02 pm Post subject: Program Letter

What's all the hoop La? Make a copy and put it in the airplane. 

Doc



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mark.bitterlich(at)navy.m
Guest

Posted: Wed May 25, 2011 2:26 pm Post subject: Program Letter

No Hoopla.  Put the copy in your airplane and DOC!   DON'T DO ANY TAIL SLIDES EITHER!   

Mark

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dsavarese0812(at)bellsout
Guest

Posted: Wed May 25, 2011 2:37 pm Post subject: 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:

[quote] 



 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

 --

dsavarese0812(at)bellsout
Guest

Posted: Wed May 25, 2011 2:37 pm Post subject: 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:

[quote] 



 So does 8130.2G apply to those of us that were issued Special Airworthiness Certificates under 8130.2F or not?



 Mark

 --

mark.bitterlich(at)navy.m
Guest

Posted: Wed May 25, 2011 2:40 pm Post subject: 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.  

--

mark.bitterlich(at)navy.m
Guest

Posted: Wed May 25, 2011 2:49 pm Post subject: 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

--

mark.bitterlich(at)navy.m
Guest

Posted: Wed May 25, 2011 2:52 pm Post subject: 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

--

mark.bitterlich(at)navy.m
Guest

Posted: Wed May 25, 2011 2:58 pm Post subject: 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





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mark.bitterlich(at)navy.m
Guest

Posted: Wed May 25, 2011 3:17 pm Post subject: 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.  



--

jgriffint28(at)cox.net
Guest

Posted: Wed May 25, 2011 3:56 pm Post subject: 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



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dsavarese0812(at)bellsout
Guest

Posted: Wed May 25, 2011 4:45 pm Post subject: 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:

[quote] 



 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



 ---

dsavarese0812(at)bellsout
Guest

Posted: Wed May 25, 2011 5:09 pm Post subject: 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:

[quote] 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

 ---

dsavarese0812(at)bellsout
Guest

Posted: Wed May 25, 2011 5:19 pm Post subject: 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 manufacturer’s or country of origin’s

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:

[quote] 



 I neglected to add that the program letter must be in the plane. Refer 

 to previously sent attachment.

 Jim Griffin

 ---

Jetj01(at)aol.com
Guest

Posted: Wed May 25, 2011 5:52 pm Post subject: 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(at)bellsouth.net> wrote:

[quote] 

 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

> ---

jgriffint28(at)cox.net
Guest

Posted: Wed May 25, 2011 6:50 pm Post subject: 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

---

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