Appendix D of part 43 will suffice in either case. Maybe they are not so different after all.........
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Let's step back about 35 years ago and see how we got here. Prior to 1979 there was no such thing as a "Repairman Certificate". Additionally, A&Ps and IAs could not sign for inspections on E-AB aircraft. Only an FAA Airworthiness Inspector could do inspections on E-AB aircraft. As one can well imagine, that was quickly becoming a problem for the FAA as the E-AB movement took hold and more and more people began building aircraft. The local GADO (General Aviation District Office) started having Inspection meetings where you could fly your E-AB aircraft in to get it's annual inspection. The Inspectors would often times have to inspect 10 or more aircraft in a day. Otherwise, they would have to travel into the field to do the inspections one by one. Obviously, the quality of the inspections in this scenario weren't the best. (Has anyone actually seen an FAA Airworthiness Inspector get their hands dirty?) This was really becoming overwhelming for the GADO offices and something had to change.
I went through one annual inspection with the GADO office under this scenario. I had to fly my non-electric biplane into an ARSA (now class C) airport to the GADO (now FSDO) office so the Airworthiness Inspector could spend 15 minutes looking it over and endorse my logbooks. The inspection was a joke, and quite frankly, having a lot of homebuilts, many non-electric, flying into busy airspace where the GADO offices are located and trying to land with light signals from the tower mixed in with plenty of passenger jet traffic probably wasn't a really great way to operate.
The reality was that the builders were doing their own maintenance, so the FAA decided to issue a Repairman Certificate to give the owners an official blessing to do their own maintenance and sign their own logs. But then there was the issue of how to deal with E-AB aircraft that were no longer owned by the original builder. The FAA decided that since A&Ps possess sufficient knowledge of general principles of aircraft aircraft construction and engine maintenance to perform E-AB inspections, so decided to allow any A&P to perform condition inspections on E-AB aircraft rather than restricting inspections to only A&Ps with an IA (Inspectors Authorization) rating. The FAA didn't have to do this but chose to do this based on he difference between one type of plane being signed off as airworthy vs the other type being signed as serviceable. They could have forced the E-AB community to use mechanics with an IA rating, which would have constricted the E-AB community significantly.
The testing to obtain an A&P license is centered around the technical aspects of performing the job. Knowing and understanding the mechanics of the job is the vast majority of the emphasis. Testing for the IA rating is centered around knowing and understanding the FARs and associated paperwork.
-Cub Builder
If these people do not know the difference between a Condition Inspection and an Annual Inspection they need an education. So give them one, teach them something. If they say they do not want to learn anything new, well they should not be flying anything that goes into the air.
They say the EAB world does great at the maintenance and upkeep of its airplanes. Its in the paper work they lack. This comes from the EAA. I can post a webinar. This is part of that paper work, understanding the difference between a Condition Inspection and an Annual Inspection.
1600vw
Ha. I call my condition inspections annuals everywhere except in the log books. Oddly enough I do them annually which makes for a handy reference. The fact that you don't like verbal short cuts isn't going to change the rest of the world. You make similar inaccuracies without recognizing it, but everyone has been polite enough to not call you out.
March on Don Quixote. I'm sure there at more Windmills to joust. :D
-Cub Builder
http://eaaforums.org/images/misc/quote_icon.png Originally Posted by Bill Berson http://eaaforums.org/images/buttons/viewpost-right.png
Since the FAA has decided that some future AD's can apply to experimental engines, props and accessories, the experimental aircraft owner now has the burden to check. The FAA likely won't send any notice.
Thanks for the link. I believe you are 100% right on what you've posted in this thread.
When I started the other thread a while back, it didn't take long to realize that nobody had any idea what I was whining about. This is it, right here. Strong opinions both sides, with FAAspeak and FAApromises and personal experiences and FAAboogeymen and oh oh oh insurance companies to back them up.
Every E/AB owner being able to comply with all the ADs which MIGHT be brought up after an accident or incident investigation is impossible. No matter when they were issued, no matter what they require. No matter what anybody says. So I shut up and vowed to continue using common sense.
For example. I'm fourth owner of my E/AB. It has Rosenhahn wheels and brakes, salvaged gear legs that look a LOT like they came off a Cessna 140, and rudder pedal assemblies and brake master cylinders that look like they came off a Cessna 150. Say I sign up on the website and find out the FAA has issued ADs against C150 master cylinders and C140 gear. There is no part tag on anything but the Rosenhahn assemblies. But the zealot inspecting the bird claims there's no mistaking those Cessna parts so the AD applies! No way. Way. No way. WAY. Sheesh. Find previous owner's receipt for Autozone O-rings that will fit those cylinders. Nah nah neener, those cylinders have been altered so the AD no longer applies! Prove it. No record of non-A&P routine maintenance is required on E/AB. But with them IN there, I don't NEED to prove it because they are no longer an FAA approved part. Prove it. Right, how? Pull them apart and get the number on the O-ring? Right. In your dreams. Come back next week to see the receipts for Cessna O-rings.
Oh, the (example) Cleveland brake pucks AD I never got because those are Rosenhahn brakes? So now what? Don't have receipt, no part number visible, those must be the original Rosenhahn pucks that have been on there since the plane was new, yup, shur. Replace perfectly good ones? With what? They don't even MAKE Rosenhahn brakes anymore.
What? What about the left mag? It's got a tag. Slick throwaway. We'll pretend there is an AD on that part number to check for incorrect ignition wire attachment that should have been done 150 hours ago. Wait a minute. Right mag? Left hole? What? Oh, the left one failed 75 hours ago, I installed EI on right mag hole, moved right mag to left hole. Impossible. Nope, just drill another hole in the shaft and put on the impulse coupling, wha-lah. So it's been modified, AD no longer applies, right? Plus it's been through a conditional inspection with no defects last year, AND it has the original left mag harness on it anyway. Then why wasn't the tag modified or removed? Can't remove tags without FAA approval? Where did THAT come from? Why were there no tags on the gear legs or brake cylinders?
The (example) landing gear AD? It's on the mounts, not the gear legs, no problem. Note it in the logbook? But it's on CESSNAs not this type aircraft. Why note it? Don't worry, you won't be inspecting it next year.
Don't even start on why there is a Wells voltage regulator and an alternator rebuilt by Joe's Auto Electric or .... oh you get the point.
There is NO current way EVERY E/AB owner can know about, much less comply with, all ADs the FAA may have issued or may someday issue.
So now I do what I did before. I'll STFU and sit back down. :)
I really think that you're worried here (in your examples) about something that can't happen if folks (owners AND FAA/NTSB/Insurance) pay attention to the regs and is extremely unlikely in any case. Since the ONLY AD's that will apply to EAB aircraft are the ones that explicitly say so, all previous AD's for landing gear legs, magnetos, and the like are inapplicable - they don't mention YOUR plane, nor ANY EAB aircraft. Per the AC, no one can claim (rationally) that the FAA intended them to apply, since they've now clarified their intent.
So the only AD's that you should worry about are the FUTURE ones that MAY explicitly call out your plane or generic EAB aircraft. And what people may THINK a thing looks like means nothing if there's no documentation showing what it is (or was, at one point).
IMO, obviously.
Not sure I agree with this - if you know what your plane is made out of, you can come pretty damn close. I've only got one thing (the remnants of an O-360 engine that's been rebuilt with a lot of aftermarket stuff) on my COZY MKIV that I need to keep track of. At least in the canard world, it's engines, mags and carbs - that's it, almost exclusively.