I'm confused about the maintenance and annuals on an experimental I purchase.

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10-17-2014, 06:55 PM
Marc Zeitlin

Quote:

Originally Posted by martymayes

There is no such thing as a "major repair" (as defined in part 43) on a homebuilt.

Well, yeah, not necessarily as defined in part 43, Appendix A, but my Op-Limits explicitly state:

After incorporating a major change as described in Part 21.93, the aircraft oner is required to re-establish compliance with Part 91.319. Blah, Blah, Blah..., here's how to do it..."

Now, Part 21.93 says:

(a) In addition to changes in type design specified in paragraph (b) of this section, changes in type design are classified as minor and major. A "minor change" is one that has no appreciable effect on the weight, balance, structural strength, reliability, operational characteristics, or other characteristics affecting the airworthiness of the product. All other changes are "major changes" (except as provided in paragraph (b) of this section).

Obviously, there are no changes in "type design" for E/AB aircraft, but there are major and minor changes as defined in the second sentence above. So, _IF_ some change to the E/AB aircraft, after the original AC is issued, has no appreciable (where "appreciable" is obviously open to some interpretation) effect on the <stuff listed above> then it's minor and needs no compliance action as listed in the Op-Limits. But if it DOES have "appreciable" affect, then it's considered a "major change" and compliance must be re-established per the OL's.

Not knowing exactly what Dana is proposing, it's hard to say whether I'd consider it major or minor, but let's say it's major. If the inspecting A&P believes the repair/fix/change to be SAFE, he signs off the CI. Then Dana uses the procedure in his OL's in re-establishing compliance with 91.319.

In either case (major or minor), the only difference is in whether Dana needs to re-establish per the OL's - the A&P only needs to determine whether what he sees after the work is done is SAFE.

Quote:

Originally Posted by martymayes

Good luck Dana but I don't see this turning out positive. I'd get another A&P to do the inspection.

Agreed.
10-17-2014, 07:20 PM
martymayes

Quote:

Originally Posted by Marc Zeitlin

Well, yeah, not necessarily as defined in part 43, Appendix A, but my Op-Limits explicitly state:

After incorporating a major change .

I agree, operating limitations have instructions regarding a major "change" for which they use a definition similar to major alteration in Part 43. But nothing about major repair.

Major change is meant for installing a different engine or new wing. Will the flight characteristics be different? If so, the FAA says have to revisit the test period to ensure compliance with 91.319(b)

You can take a crashed homebuilt, make repairs as necessary to put it back together and fly it. The FAA doesn't define that repair as major or minor. The repairs are no different than performing maintenance. There is no minimum standard of performance, obligation to record the repairs in any kind of record, nor any requirement to report anything to the FAA. As long as it is essentially the same aircraft and someone will sign off a condition inspection, it's good to go. That's all Dana is trying to do here, make some repairs so the plane is safe to fly. That's being interrupted with unrealistic expectations.
10-17-2014, 08:34 PM
Dana

Quote:

Originally Posted by Marc Zeitlin

Well, yeah, not necessarily as defined in part 43, Appendix A, but my Op-Limits explicitly state:

After incorporating a major change as described in Part 21.93, the aircraft oner is required to re-establish compliance with Part 91.319. Blah, Blah, Blah..., here's how to do it..."

My op limitations are worded a bit differently: "Any major change to this aircraft, as defined by FAR21.93, invalidates the Special Airworthiness Certificate issued for this aircraft."

Quote:

Not knowing exactly what Dana is proposing, it's hard to say whether I'd consider it major or minor, but let's say it's major. If the inspecting A&P believes the repair/fix/change to be SAFE, he signs off the CI. Then Dana uses the procedure in his OL's in re-establishing compliance with 91.319.

Basically, the original trailing edge strips (top and bottom of the recess where the aileron pivots) curled up about 1/8-1/4" under fabric tension. It's hard to say if the glue joints broke, because a previous owner attempted a repair, though there's nothing in the aircraft log. This allowed the fabric to slip slightly, breaking the glue holding the fabric to the ribs (all that was specified by Fisher). The builder also used very light rib stitching, which was insufficient to hold the fabric once the glue failed, and that stitching broke. I plan to pull the trailing edge strips (and thus the fabric, which is still attached securely to the trailing edge strips) back into place, and secure them with new additional gussets, an improvement over the original design (a change other builders have done from the outset as I mentioned above), and then redo the rib stitching using the proper lacing cord.

It could be considered a "major repair", but not a "major change"; adding the new gussets isn't much different, as I see it, from putting doubler plates on a cracked spar repair, unless you consider it an "appreciable change to structural strength" since it wasn't strong enough when it was broken...
10-17-2014, 11:45 PM
Bill Berson

Dana, I would ask the A&P to sign the log as is and let you take full control of the repair liability away from him.
He could sign it: "I certify that this aircraft has been inspected in accordance with a condition inspection and a list of discrepancies has been submitted to the owner."
If the inspection is completed and a list of discrepancies is provided, you don't need to look for another A&P.
10-18-2014, 06:22 AM
Dana

Quote:

Originally Posted by Bill Berson

Dana, I would ask the A&P to sign the log as is and let you take full control of the repair liability away from him.
He could sign it: "I certify that this aircraft has been inspected in accordance with a condition inspection and a list of discrepancies has been submitted to the owner."
If the inspection is completed and a list of discrepancies is provided, you don't need to look for another A&P.

No, that was discussed above... unless the A&P signs off that the aircraft is "in a condition for safe operation", it can't be flown, period.
10-18-2014, 07:18 AM
1600vw

Quote:

Originally Posted by Bill Berson

Dana, I would ask the A&P to sign the log as is and let you take full control of the repair liability away from him.
He could sign it: "I certify that this aircraft has been inspected in accordance with a condition inspection and a list of discrepancies has been submitted to the owner."
If the inspection is completed and a list of discrepancies is provided, you don't need to look for another A&P.

Yes this is correct. The inspection has been done. All that has to be done is fix the list of discrepancies. If you watch or listen to that webinar I posted he states this. The inspection has been done, it just has some discrepancies. Fix those and you do not need another inspection, its been done.

Tony
10-18-2014, 07:52 AM
martymayes

Quote:

Originally Posted by 1600vw

Yes this is correct. The inspection has been done. All that has to be done is fix the list of discrepancies. If you watch or listen to that webinar I posted he states this. The inspection has been done, it just has some discrepancies. Fix those and you do not need another inspection, its been done.

Correct based on what? A webinar? Is it possible the webinar information is incorrect?

Can you point to instructions in the operating limitations that instruct one on how to sign off a condition inspection with discrepancies? Bueller? Bueller? Anyone?

How does one sign off a condition inspection when one of the "conditions" that must be met is that the aircraft be in condition for safe operation?
10-18-2014, 08:02 AM
Marc Zeitlin

Quote:

Originally Posted by Dana

My op limitations are worded a bit differently: "Any major change to this aircraft, as defined by FAR21.93, invalidates the Special Airworthiness Certificate issued for this aircraft."

Uggghhh. Yeah, those were an earlier version of OL's - there are 3-5 different versions, depending upon when they were written. Those are obviously the worst, and clearly the incentive with them is to never log ANYTHING, because _IF_ anything is interpreted as a "major change", you need to get a new AC.

If I were you, I'd work with the local FSDO to get a new set of OL's for the plane - IIRC, the latest version requires notification of the local FSDO and approval of your test plan, but doesn't invalidate the AC.

Quote:

Originally Posted by Dana

Basically, the original trailing edge strips... It could be considered a "major repair", but not a "major change"; adding the new gussets isn't much different, as I see it, from putting doubler plates on a cracked spar repair, unless you consider it an "appreciable change to structural strength" since it wasn't strong enough when it was broken...

I could probably be convinced that this is not a "Major Change" per 21.93. But I'd still recommend getting new OL's.

I also agree with you, as you point out to Bill Berson, unless the signoff explicitly states "in a condition for safe operation", it's not in CI and not legal to fly. I believe that 1600vw is incorrect, no matter what he heard in a webinar. The OL's are very clear as to what language needs to be used, and what wording has to be in the logbook in order for the plane to be legal. Unless the owner has the Repairman's Certificate (in which case, he wouldn't be asking an A&P for the inspection), he can't sign the aircraft off as being "in a condition for safe operation". So him fixing the discrepancies after Bill's suggested wording is a good thing, but doesn't make the plane legal.

When I do a CI and find safety discrepancies, I give the owner a list of things to fix. After they're fixed and I've verified that they are fixed (or I've fixed them), I then sign off the logs with the appropriate wording. If they're not fixed, I don't sign the plane off as "in a condition for safe operation". Simple as that.
10-18-2014, 08:32 AM
1600vw

Quote:

Originally Posted by martymayes

Correct based on what? A webinar? Is it possible the webinar information is incorrect?

Can you point to instructions in the operating limitations that instruct one on how to sign off a condition inspection with discrepancies? Bueller? Bueller? Anyone?

How does one sign off a condition inspection when one of the "conditions" that must be met is that the aircraft be in condition for safe operation?

You bet I trust the speaker in a webinar put on by the EAA before any random comment on the internet. Joe gave his e-mail. E-mail him and ask the question you poss.

Tony
10-18-2014, 08:39 AM
martymayes

Quote:

Originally Posted by Marc Zeitlin

If I were you, I'd work with the local FSDO to get a new set of OL's for the plane - IIRC, the latest version requires notification of the local FSDO and approval of your test plan, but doesn't invalidate the AC.

Correct, however notification of the FSDO is required only to ensure suitability of the test area. (Ref: Order 8130.2F Chg. 3)

(19) After incorporating a major change as described in § 21.93, the aircraft owner is required to reestablish compliance with § 91.319(b) and notify the geographically responsible FSDO of the location of the proposed test area. The aircraft owner must obtain concurrence from the FSDO as to the suitability of the proposed test area. If the major change includes installing a different type of engine (reciprocating to turbine) or a change of a fixed-pitch from or to a controllable propeller, the aircraft owner must fill out a revised Form 8130-6 to update the aircraft’s file in the FAA Aircraft Registry. All operations must be conducted under day VFR conditions in a sparsely populated area. The aircraft must remain in flight test for a minimum of 5 hours. The FSDO may require additional time (more than 5 hours) depending on the extent of the modification. Persons nonessential to the flight must not be carried. The aircraft owner must make a detailed logbook entry describing the change before the test flight. Following satisfactory completion of the required number of flight hours in the flight test area, the pilot must certify in the records that the aircraft has been shown to comply with § 91.319(b). Compliance with § 91.319(b) must be recorded in the aircraft records with the following, or a similarly worded, statement:

I would classify repaired rib stitching as having 'no appreciable effect on the weight, balance, structural strength, reliability, operational characteristics, or other characteristics affecting [safe operation] of the product' so I would not elevate it to major change status. Just do it. And I wouldn't bother with new operating limitations at this point. The currently issued limitations will work fine.

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