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Thread: Engine change

  1. #11

    Join Date
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    Quote Originally Posted by Dana View Post
    It does, kind of. My operating limitations (issued 2016) say, "After incorporating a major change as described in 21.93, the aircraft owner is required to reestablish compliance..." So even though 21.93 doesn't explicitly apply to experimentals, the definition of "major change" does apply if referenced in the op limitations:
    In FAAspeak, that's called "incorporated by reference to"

    "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”... ".

  2. #12

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    Oct 2011
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    Just curious, does your experimental operating limitations also reference FAR43 ?
    I don't see a need to notify the FAA or do a Form 337 when a mechanic finds a non approved engine and then installs the approved engine (on a Type certificated airplane). It only requires a log book entry.

    So why would installing an approved engine (defined here only as same model as original) need FAA notification?

  3. #13

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    Oct 2014
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    Quote Originally Posted by Bill Berson View Post
    Just curious, does your experimental operating limitations also reference FAR43 ?
    Mine does (2002) and most (if not all) of those that I deal with do as well. They reference it in the section regarding Condition Inspections, and talk about Part 43 Appendix D (the checklist for annual inspections). So yeah - they "reference" it, even if one could claim that they don't make it regulatory since they generally say "... the following or a similarly worded statement:".

    Quote Originally Posted by Bill Berson View Post
    I don't see a need to notify the FAA or do a Form 337 when a mechanic finds a non approved engine and then installs the approved engine (on a Type certificated airplane). It only requires a log book entry.
    I don't deal with TC'd aircraft, so I don't know all the intricacies of what is and is not required - I can't speak to that. But since a TC'd aircraft has a specific, known configuration, that's different than an EAB aircraft that has a series of changes logged from some not necessarily well defined starting point, even if completely legal.

    Quote Originally Posted by Bill Berson View Post
    So why would installing an approved engine (defined here only as same model as original) need FAA notification?
    Because EAB aircraft are not the same as TC'd aircraft; there is no "type" or "original configuration" - there is only "what is it NOW", and we're not talking about logic, necessarily, we're talking about what the rules say.

    Now as pretty much everyone here has said, if you're putting on a new engine, it would be smart to perform at LEAST the 5 hour minimum Phase I that might be required, and do so near the airport.

    But the issue of legality arose, and to be legal, given the court's interpretation of the FAA's rules and given the rational interpretation of what the OL's SAY, major changes involve any change that has an "appreciable effect", whatever that is (and there have been MANY articles written on that interpretation) and IMO an engine change, even back to one that the plane used to have in some previous incarnation, is a major change from the current incarnation.

    With respect to engines, although Part 43 Appendix A does NOT apply to EAB aircraft, it does explicitly list an engine change as a major change, so it would be relatively difficult to argue that an engine change does not meet the definition of major change per Part 21.93, even if not explicitly called out in 21.93. Not saying that you couldn't argue it, but given the court rulings so far, I wouldn't be betting on you winning that argument.

    My conservative $0.02 interpretation - YMMV.

  4. #14
    Contacted Baltimore FSDO this morning. I'm gonna do this right. I re-skinned the fuselage in Alclad so that's a major change anyway. My OL is from 86 and has incorrect references and some weird requirement to wear a parachute. In the end it will all be correct and everyone is happy. Thanks for the responses

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