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

[AviatorKeith]

I'm having trouble understanding the rules with respect to maintaining an E-LSA or EAB Zodiac 601HD. I originally wanted to build this aircraft but it was for the wrong reasons. I'm no builder. No time, less patience than needed. I spoke to a gentleman who told me he once built an RV6 for $35k more than he purchased one for later. I just want to own the equivalent of an S-LSA for a fraction of the price, if that's even possible. So, if an aircraft is built by someone else, is there any way I can be certified to maintain it and annual it? If I have to build 51% of it, I will, but again, I'm not interested in building.

This is confusing and with it currently being a buyer's market, I'd like to know exactly what I'm in for as far as ownership costs and the like. Forgive me if this question has been asked a thousand times. As a matter of fact, I would settle for a link to a comprehensive explanation to this E-LSA/EAB/S-LSA "who's on first" quandry.

Educate me, please.

[Neil]

If you purchase an Experimental category aircraft you can do the work on the aircraft but the work must be signed off by a licensed mechanic. (A&P) If you (and any number of your closest friends)do 51% of the work on an Experimental Amateur Built aircraft you (or any one of those friends as long as they were not paid) may apply for the repairman's certificate for that airplane. The certificate is not good for any other aircraft even if that aircraft is identical in every way.

Like you I am a little foggy on some of the wording in the Light Sport arena but if the term Experimental is attached I would bet the above applies.

[Racegunz]

Okay here's the scoop, if you don't want to build but you want to escape the racket that is associated with the A/P annuals or conditionals then your choice is left to an ELSA registered aircraft then you must take the 16 hr lightsport maint/inspection course, (there is a specific name for the course it escapes me right now) .After passing you will be able to do the condition inspection on any ELSA registered airplane. I believe but don't quote me that there are some 601"s registered as ELSA.

[CarlOrton]

And to further clarify: Anyone can do any work on any experimental, even if they didn't build it. It's the annual condition inspection that must be performed by EITHER an A&P (no IA required) OR one of the original builders if they have the repairman's certificate FOR THAT AIRCRAFT. Racegunz is correct in that you can take the course for the ELSA repairman certificate.

[martymayes]

I would settle for a link to a comprehensive explanation to this E-LSA/EAB/S-LSA "who's on first" quandry.

Educate me, please.


Here ya go: http://www.sportpilot.org/learn/

[rwanttaja]

If you purchase an Experimental category aircraft you can do the work on the aircraft but the work must be signed off by a licensed mechanic. (A&P)

Clarification: The work does not have to be specifically signed off by an A&P...it is not necessary to gain A&P approval before returning the airplane to service. Rather, during the next Conditional Inspection, the A&P will assess whether the aircraft is airworthy, INCLUDING the work that you'd done.

I'm in exactly that situation: I extensively modified the electrical system of my Fly Baby, and have been flying it with no problems for the past two months. My Condition Inspection is due, and I've told my A&P about the modifications and warned him that the annual might take a bit more time as he examines my work.


If you (and any number of your closest friends)do 51% of the work on an Experimental Amateur Built aircraft you (or any one of those friends as long as they were not paid) may apply for the repairman's certificate for that airplane.

Clarification: By "51% of the work," Neil is refering to the original construction of the aircraft. It does not refer to work you perform on a completed homebuilt (e.g., one with an airworthiness certificate) that you purchased. In other words, you can't get a Repairman Certificate by working on a flying homebuilt that you purchased.


Like you I am a little foggy on some of the wording in the Light Sport arena but if the term Experimental is attached I would bet the above applies.

Not precisely. Anyone can maintain an Experimental Light Sport aircraft, just like an Experimental Amateur-Build. The annual condition inspections of ELSAs must be performed either by a licensed A&P or the holder of a Light Sport - Inspector Repairman Certificate. Anyone (not just the builder) can take a 16-hour course and earn that type of Certificate, and can use it to perform the condition inspection on ANY ELSA that they own.

In other words, if you buy an ELSA, you can take a course that will permit you to perform the condition inspections. That doesn't happen with Experimental Amateur Built repairman certificates; you must be associated with the building of THAT exact aircraft, like Neil says.

Ron Wanttaja

[AviatorKeith]

In other words, if you buy an ELSA, you can take a course that will permit you to perform the condition inspections. That doesn't happen with Experimental Amateur Built repairman certificates; you must be associated with the building of THAT exact aircraft, like Neil says.

Ron Wanttaja
So, other than weight and cruise speed, how else do you distinguish between a E-LSA and an E-AB? Is this classification solely determined by how the 601HD I purchase was registered originally by the builder?

[martymayes]

Is this classification solely determined by how the 601HD I purchase was registered originally by the builder?No, the builder didn't have a choice when he registered the airplane. The 601HD is amateur built, as that's the only classification that fits.


So, other than weight and cruise speed, how else do you distinguish between a E-LSA and an E-AB?

An E-LSA is built from a kit that doesn't necessarily meet AB criteria and it's based on a model that conforms to LSA consensus standards.

[AviatorKeith]

No, the builder didn't have a choice when he registered the airplane. The 601HD is amateur built, as that's the only classification that fits.



An E-LSA is built from a kit that doesn't necessarily meet AB criteria and it's based on a model that conforms to LSA consensus standards.

Still confused because the 601HD is a kit that can be built to LSA standards.

[rwanttaja]

Still confused because the 601HD is a kit that can be built to LSA standards.
It's due to a problem with FAA terminology, where they use the same phrase for a definition as the certification category.

If you look in 14CFR Part 1 (http://ecfr.gpoaccess.gov/cgi/t/text/text-idx?c=ecfr&rgn=div5&view=text&node=14:1.0.1.1.1&idno=14#14:1.0.1.1.1.0.1.1), you'll see "Light Sport Aircraft" defined:

Light-sport aircraft means an aircraft, other than a helicopter or powered-lift that, since its original certification, has continued to meet the following:

(1) A maximum takeoff weight of not more than—

(i) 1,320 pounds (600 kilograms) for aircraft not intended for operation on water; or
(ii) 1,430 pounds (650 kilograms) for an aircraft intended for operation on water.

(2) A maximum airspeed in level flight with maximum continuous power (VH) of not more than 120 knots CAS under standard atmospheric conditions at sea level.
(3)...

The definition goes on with a total of thirteen defining characteristics of a Light Sport Airplane. This diagram sums it up:
2047


What you won't see in there is ANYTHING related to certification, who can work on them, etc. That's because the "Light Sport Aircraft" is used to determine what a Sport Pilot is allowed to fly. ANY airplane, regardless of certification, meeting the Light Sport definition can be flown by a Sport Pilot.

At the same time, the FAA instituted two new certification classes in the Special category: Special Light Sport Aircraft (SLSA) and Experimental Light Sport Aircraft (ELSA). These aircraft meet the Part 1 LSA definition; in addition, they are designed and constructed in accordance with an Industry standard.

To gain certification as an Experimental Light Sport Aircraft, the manufacturer has to build an example of the airplane and prove that it complies with the requirements for Special Light Sport Aircraft. Once that is accomplished, the manufacturer can either sell the airplane ready-to-fly (Special Light Sport) or as a builder-assembled kit (Experimental Light Sport). The ELSA aircraft differ from the Experimental Amateur-Built category in that there is no "51%" rule. The seller of an ELSA kit can sell it at any level of completion.

The big difference is that the builder of an ELSA is not allowed to make any deviations in the construction of the aircraft... if the original manufacturer used a Rotax 912, the builder must also use a Rotax 912 of the identical model. If the kit manufacturer installed an ICOM A200 radio, the ELSA builder must ALSO install an ICOM A200... and not add anything, either.

Now, once the builder's ELSA is signed off by the FAA, that airplane is officially in the Experimental category, and the owner can make any changes they desire. But it must totally comply with the original aircraft at the time of certification.

OK, how does this affect the Zenith CH601HD?

The Zenith airplanes are Experimental Amateur-Built kits only. They meet the Part 1 definition of Light Sport Aircraft, hence they can be flown by Sport Pilots. However, they are licensed as Experimental Amateur-Built aircraft, and hence examples must comply with the "51% rule".

A ready-to-fly SLSA version of the CH601HD is sold by Aircraft Design and Manufacturing. As far as I know, an ELSA kit is not available. However, the owner of an SLSA can change it to the ELSA category if desired.

The best example of how it all works is the Vans RV-12. Vans designed the RV-12 in accordance with the rules for SLSA, got one example approved, and now sells ELSA RV-12 kits. However, Vans *also* got the RV-12 kits approved under the 51% rule for Experimental Amateur-Built. If you buy an RV-12 kit, you can build it EITHER as ELSA or EX-AB.

The difference?

If ELSA, you cannot deviate from the construction manual for any reason. Once you get an airworthiness certificate, you can then make changes. You can do all the maintenance yourself, and can attend a 16-hour course that allows you to perform the annual inspections on any ELSA that you own. If you sell the RV-12, the new owner can take the same course and will then be approved to perform annuals on the aircraft he purchased. Or, anyone can hire an A&P or a person holding a Light Sport Maintenance rating to do the annual.

If you build it as Experimental Amateur-Built, you can deviate from the plans all you want, and, like the ELSA, you can do all the maintenance yourself once completed. As the builder, you can apply for a Repairman Certificate that permits you to perform the annual condition inspection *on that aircraft alone*. If you sell the completed aircraft, the new owner cannot receive a Repairman Certificate...he or she must either have you do the annuals, or hire an A&P to do them.

Ron Wanttaja

[martymayes]

A ready-to-fly SLSA version of the CH601HD is sold by Aircraft Design and Manufacturing.


Great explanation Ron but the airplane sold by AMD is a 601XL, not sure I would say it's an SLSA version of the 601HD. There are quite different, the wings for example have nothing in common. The 601XL is the subject of an FAA SAIB and a lot of bad press with wing and/or flutter issues. The 601HD has an excellent service history as a homebuilt only airplane.

[Bill Berson]

For a homebuilt (E-AB), it is possible to buy a project that has been assembled by other amateurs builders. Then the buyer (final builder) could complete the final 5% and register the aircraft as the builder and apply for a repairman certificate. He must also provide proof that the previous owner/builders did a total of 51% or more.

That's my take from EAA forum discussions.

[AviatorKeith]

Thanks for breaking it all down for me, rwanttaja. We need an "evangelical" emoticon, because alas, brother, I see the light.(no pun intended...really.)
:)

I'm not even sure Zenith sells the 601HD kit any more. What I know so far is that it's a good looking plane with great visibility and and advertised useful load that would accomodate me and occasionally my largest son, a 6'1" 220lb 14 year old. If he can fit, any of my friends and family can.

I spoke to a gentleman at Warrenton Fauquier Airport(HWY) who had built a Pulsar. Beautiful plane, but super small cockpit. I also met a Sonex owner, took a peek and concluded there is NO WAY I could fit in one of those either. The 601HD seems larger by comparison and hopefully would accomodate me and my kid or at least me. My mission is 99% solo so maybe the Zodiac I can own and fly Sport Pilot and if I qualify medically to pursue my PPL, I can rent larger planes after I'm certified to fly them.


It's due to a problem with FAA terminology, where they use the same phrase for a definition as the certification category.

If you look in 14CFR Part 1 (http://ecfr.gpoaccess.gov/cgi/t/text/text-idx?c=ecfr&rgn=div5&view=text&node=14:1.0.1.1.1&idno=14#14:1.0.1.1.1.0.1.1), you'll see "Light Sport Aircraft" defined:

Light-sport aircraft means an aircraft, other than a helicopter or powered-lift that, since its original certification, has continued to meet the following:

(1) A maximum takeoff weight of not more than—

(i) 1,320 pounds (600 kilograms) for aircraft not intended for operation on water; or
(ii) 1,430 pounds (650 kilograms) for an aircraft intended for operation on water.

(2) A maximum airspeed in level flight with maximum continuous power (VH) of not more than 120 knots CAS under standard atmospheric conditions at sea level.
(3)...

The definition goes on with a total of thirteen defining characteristics of a Light Sport Airplane. This diagram sums it up:
2047


What you won't see in there is ANYTHING related to certification, who can work on them, etc. That's because the "Light Sport Aircraft" is used to determine what a Sport Pilot is allowed to fly. ANY airplane, regardless of certification, meeting the Light Sport definition can be flown by a Sport Pilot.

At the same time, the FAA instituted two new certification classes in the Special category: Special Light Sport Aircraft (SLSA) and Experimental Light Sport Aircraft (ELSA). These aircraft meet the Part 1 LSA definition; in addition, they are designed and constructed in accordance with an Industry standard.

To gain certification as an Experimental Light Sport Aircraft, the manufacturer has to build an example of the airplane and prove that it complies with the requirements for Special Light Sport Aircraft. Once that is accomplished, the manufacturer can either sell the airplane ready-to-fly (Special Light Sport) or as a builder-assembled kit (Experimental Light Sport). The ELSA aircraft differ from the Experimental Amateur-Built category in that there is no "51%" rule. The seller of an ELSA kit can sell it at any level of completion.

The big difference is that the builder of an ELSA is not allowed to make any deviations in the construction of the aircraft... if the original manufacturer used a Rotax 912, the builder must also use a Rotax 912 of the identical model. If the kit manufacturer installed an ICOM A200 radio, the ELSA builder must ALSO install an ICOM A200... and not add anything, either.

Now, once the builder's ELSA is signed off by the FAA, that airplane is officially in the Experimental category, and the owner can make any changes they desire. But it must totally comply with the original aircraft at the time of certification.

OK, how does this affect the Zenith CH601HD?

The Zenith airplanes are Experimental Amateur-Built kits only. They meet the Part 1 definition of Light Sport Aircraft, hence they can be flown by Sport Pilots. However, they are licensed as Experimental Amateur-Built aircraft, and hence examples must comply with the "51% rule".

A ready-to-fly SLSA version of the CH601HD is sold by Aircraft Design and Manufacturing. As far as I know, an ELSA kit is not available. However, the owner of an SLSA can change it to the ELSA category if desired.

The best example of how it all works is the Vans RV-12. Vans designed the RV-12 in accordance with the rules for SLSA, got one example approved, and now sells ELSA RV-12 kits. However, Vans *also* got the RV-12 kits approved under the 51% rule for Experimental Amateur-Built. If you buy an RV-12 kit, you can build it EITHER as ELSA or EX-AB.

The difference?

If ELSA, you cannot deviate from the construction manual for any reason. Once you get an airworthiness certificate, you can then make changes. You can do all the maintenance yourself, and can attend a 16-hour course that allows you to perform the annual inspections on any ELSA that you own. If you sell the RV-12, the new owner can take the same course and will then be approved to perform annuals on the aircraft he purchased. Or, anyone can hire an A&P or a person holding a Light Sport Maintenance rating to do the annual.

If you build it as Experimental Amateur-Built, you can deviate from the plans all you want, and, like the ELSA, you can do all the maintenance yourself once completed. As the builder, you can apply for a Repairman Certificate that permits you to perform the annual condition inspection *on that aircraft alone*. If you sell the completed aircraft, the new owner cannot receive a Repairman Certificate...he or she must either have you do the annuals, or hire an A&P to do them.

Ron Wanttaja

[martymayes]

I'm not even sure Zenith sells the 601HD kit any more.

Pretty sure they do if you are interested in building.

[pshadwick]

Pretty sure they do if you are interested in building.


They sell the updated version (CH650) as either a kit or plans built.

[martymayes]

They sell the updated version (CH650) as either a kit or plans built.

They still advertise the 601HD on the website, the price of the plans and kit are listed here...... http://www.zenithair.com/zodiac/6-price.html .....along with the $300 rudder kit. Is all this information obsolete?

[Greeneyes2141]

I've had a very hard time getting a conditional inspection done on my EAB. Is their a data base with all of the A&P mechanics by state or region so I could find one , my FBO wants to charge the same as a certified aircraft. $ 1200. To start, I've seen advertising for conditional inspections for as little as $ 400, just not around southdakota, any help, thanks

[martymayes]

A&P's won't keep their address up to date so it's hard to find an accurate database. Best bet is ask around like at an EAA chapter.

[WLIU]

I will note that A&P IA's have to keep their addresses more up to date as they have more of a connection to an FAA FSDO.

$1200 is about a day and a half of shop time. You can cut that down by delivering to the mechanic an airplane that has all of the covers, failings, and cowlings removed, and then put them all back on yourself. Likely cut 4 -5 hours of shop time off the bill depending on how many screws are involved. Plus you get to look at everything before the mechanic so that you are less apt to be surprised by a neglected maintenance item that the mechanic points out. You can do all of the lube, brakes, and other typical owner maintenance instead of the mechanic and cut another hour or two off the bill for shop time. Most mechanics are happy to have you do all of the "monkey work", especially if it involves stretching down into the tailcone or laying on your back on top of the rudder pedals, looking up with a light in one hand, a can of lube in the other, with excess lube dripping on your face.

And you want a mechanic who works on homebuilts regularly. Some mechanics with backgrounds working on mostly larger normal and transport category airplanes seem buffalo'ed by airplanes like RV's for which a service manual does not exist. Not sure why but we see it regularly.

Best of luck,

Wes
N78PS

[Marc Zeitlin]

I've had a very hard time getting a conditional inspection done on my EAB. Is their a data base with all of the A&P mechanics by state or region ...

I found this:

http://www.landings.com/_landings/pages/search/certs-ap.html

And did a search in my local area - found me, and a whole lot of other folks that I didn't know were here.


... my FBO wants to charge the same as a certified aircraft. $ 1200. To start, I've seen advertising for conditional...It's a "Condition" inspection - not a "Conditional" inspection - it's not "conditional" on anything - you're checking the "condition" of the aircraft.

inspections for as little as $ 400...Well, I generally work on canard composite aircraft (Varieze, Long-EZ, COZY, etc.) aircraft, and my Condition Inspection fee starts at $750, and that covers the first 10 hours of work. On more complex aircraft, such as a Berkut, the fee is $1150 to start, and covers the first 15 hours. My auto mechanics charge $80 - $110/hr., so I don't feel bad about charging folks $75/hr. to work on specialized aircraft. Rates will probably rise in 2015 :-).

I will say this - I've seen people get a CI signoff for $150, and your quote of $400 is still pretty low - it implies a very low hourly rate, or very few hours. I find that even if the owner removes all the panels, cowls, etc. as has been recommended (and as I recommend) and does ALL the preventive maintenance and keeps the plane in great shape, it's at LEAST 8 - 10 hours to complete the inspection correctly, so I have no idea how an A&P can do an inspection on a whole plane in 2 -5 hours, unless it's a VERY simple aircraft.

This is one of those "you get what you pay for" deals - if you just want a pencil whipping signoff, go for the cheapest price. If you actually want a good inspection, check with other folks in your area for an A&P who's knowledgeable about YOUR type of airplane - not just any A&P.

My $0.02.

[Mike Switzer]

I found this:

http://www.landings.com/_landings/pages/search/certs-ap.html

And did a search in my local area - found me, and a whole lot of other folks that I didn't know were here.

Out of curiosity I did a local search & I noticed that several of the people listed are deceased.

[Marc Zeitlin]

Out of curiosity I did a local search & I noticed that several of the people listed are deceased.You don't think they'd be able to do a good job for you? I'm guessing they probably wouldn't answer the phone when you call to get some references... You'd have to move on to one of the live ones (who would hopefully do a better job, although they'd charge more).

Assuming that the database "Landings" uses is pulled from the FAA, one would have to ask how the FAA determines when someone expires...

[Frank Giger]

Alternately one could join their local EAA chapter and find out which of those jokers is an A&P. At worst you'll get a fellow who knows what a Condition Inspection is and so won't waste a lot of time trying to do an annual, and at best a deal in trade (but be ready give some presentations/classes on aviation stuff and learn more about maintenance than you probably want to).

At any rate you'll find people who can tell you or help you do the owner level maintenance stuff; packing bearings seems to have become a lost art to most of the world as an example.

[Mike Switzer]

Assuming that the database "Landings" uses is pulled from the FAA, one would have to ask how the FAA determines when someone expires...

I'm not sure they do, which is strange considering at least one of the guys on the list died in an aircraft accident.

I just mentioned it because I know of a couple cases where the widow got pretty upset when someone called looking for the deceased husband.

[1600vw]

Alternately one could join their local EAA chapter and find out which of those jokers is an A&P. At worst you'll get a fellow who knows what a Condition Inspection is and so won't waste a lot of time trying to do an annual, and at best a deal in trade (but be ready give some presentations/classes on aviation stuff and learn more about maintenance than you probably want to).

At any rate you'll find people who can tell you or help you do the owner level maintenance stuff; packing bearings seems to have become a lost art to most of the world as an example.

You would be surprised how many A&P's I have spoke with that did not know about a Condition Inspection or that it only takes an A&P to sign the log books for one. A couple months ago I was at a friends place. He is an A&P and does Annuals at his place.

I asked him if he knew anything about Condition Inspections and if he did them. He did not say a word. After a few mins I explained about condition inspections he knew nothing about what I was speaking. After I was done he said. I will have to ask about this.

I saw him a few weeks later and he said indeed I was right about Condition Inspections.

One thing that would help, is if those that fly experimental would stop calling there Condition Inspections, Annuals.

Jokers...I have not found any of them. Just good people.

Tony

[Frank Giger]

Well I can testify that there's one at mine. ;) You're correct, though, I should have used the word characters.

The point is that the good people of the local EAA chapter will probably know and recommend an A&P that is familiar with Condition Inspections and is willing to look at Experimentals - if there isn't an A&P in the membership itself.

I consider it one of the best kept secrets that an EAA chapter is as valuable, if not more valuable, to an owner of an airplane that wants to learn about what makes it work and how to maintain it as it does to a builder. We have a couple spam can owners that would never entertain building an airplane in our chapter that come for that reason, and we're glad to have them; everybody knows something others don't (in my case I know what questions to ask about how to do stuff).

[Bill Berson]

What is a proper log book entry for a condition inspection when the A&P finds discrepancies? (Unairworthy)

For example, if the owner wants to do the work on his own or sell the plane as is, or doesn't choose to have the inspecting A&P to do the repairs.

[Marc Zeitlin]

What is a proper log book entry for a condition inspection when the A&P finds discrepancies? (Unairworthy)

For example, if the owner wants to do the work on his own or sell the plane as is, or doesn't choose to have the inspecting A&P to do the repairs.As stated earlier, there is no such thing as an "airworthy" experimental amateur-built aircraft, so there's no such thing as an "unairworthy" one. If you bring your plane to an A&P (such as myself) and the A&P doesn't want to sign the plane off as "in a condition for safe flight", you get the list of issues that cause him to feel that way, pay him for his time, and take the plane home or to someone else, assuming that you're still within the last CI period.

You don't let the A&P write anything in the logbook - you get a separate document (that you paid for) that lists the things that need to be done to the plane. And I say this as an A&P. This is one reason not to leave the CI for the last day of the month in which the last one expires - if the planes OUT of CI, you'll have to either take it apart and put it on a trailer to get it somewhere else, or else get a ferry permit to bring it somewhere else.

And again, I say this as someone that does a LOT of CI's on Exp. Am-Built aircraft. No one can ground your plane - there are only opinions on safety, up until the CI expires - there is no Type Certificate to which an Exp. Am-Built aircraft has to conform.

My $0.02.

[1600vw]

Even if the date on the last CI " Condition Inspection" is not up yet or due. As soon as you start the New CI the old one is void or expired. You will need a ferry permit to move this airplane after you start a CI and you fail it.

Marc its great you do this for people. Most A&P's will not even touch them.

Tony

http://www.eaavideo.org/video.aspx?v=2608772875001

[martymayes]

What is a proper log book entry for a condition inspection when the A&P finds discrepancies? (Unairworthy)

For example, if the owner wants to do the work on his own or sell the plane as is, or doesn't choose to have the inspecting A&P to do the repairs.

If the A&P finds something he feels is doesn't meet the "safe for operation" criteria as specified in the operating limitations, it either gets repaired or the condition inspection is terminated. There is no sign off for an incomplete condition inspection.

The inspecting A&P can certainly give the owner a list of discrepancies, which the owner can promptly throw in the trash can, hop in the plane and fly away.

[martymayes]

Even if the date on the last CI " Condition Inspection" is not up yet or due. As soon as you start the New CI the old one is void or expired. You will need a ferry permit to move this airplane after you start a CI and you fail it.


Absent documentation that says a condition inspection was "started" how would one know?

[1600vw]

No idea. Just what is stated by Joe in the webinar I posted.

I guess you could say this about the inspection its self. Why do it? Just sign the log book, who would know?

Tony

[Marc Zeitlin]

Even if the date on the last CI " Condition Inspection" is not up yet or due. As soon as you start the New CI the old one is void or expired.Where is the regulation that says that? Please be specific.

Starting a CI (whatever that means - there's no logbook entry for "starting" an inspection) has no effect whatsoever on whether the airplane's last CI is still in effect. All the rules say is that the CI expires at the end of the 12th month. There are no rules that say how long a CI can take to perform or when it needs to be started. Only that the airplane is not legal to fly if the last CI has expired.

[Marc Zeitlin]

No idea. Just what is stated by Joe in the webinar I posted.The slides in the webinar lasted about 38 minutes, and I re-watched them all. I saw exactly nothing addressing your claim that a new CI start voids the old one - can you point us to the timeline in the presentation where such a claim was made?

I did not watch the whole Q&A section, but _IF_ anyone stated this without indicating a reference FAR, I beleive that they're incorrect, as I've never seen or come across any such claim or regulation. Lack of evidence is not evidence of lack, but still...

[1600vw]

I believe you have stumbled upon a very big problem in aviation. Ask one person something you get one answer. Ask someone else the same question and you get another answer. You would have to write Joe Gauthier {DAR} a letter and ask him this questions.

[1600vw]

The slides in the webinar lasted about 38 minutes, and I re-watched them all. I saw exactly nothing addressing your claim that a new CI start voids the old one - can you point us to the timeline in the presentation where such a claim was made?

I did not watch the whole Q&A section, but _IF_ anyone stated this without indicating a reference FAR, I beleive that they're incorrect, as I've never seen or come across any such claim or regulation. Lack of evidence is not evidence of lack, but still...

Its in the question and answer section. You missed it.

[Bill Berson]

Hi Marc,
So you give the owner a list of discrepancies but nothing in the log.
What then is the owner supposed to do or what can he do after those discrepancies are cleared by the owner? He should not need to return to the same A&P if across the state or if he sold the airplane. The condition inspection was completed and there is no requirement for the inspector to supervise or dictate standards for the repairs.
Is any owner log entry about the inspection required?

With a certified airplane, I give the owner a list of discrepancies, sign the log as unairworthy as required by the FAR43.11(a)(5). In some cases, the owner can clear the discrepancies (if preventive maintenance) and return the aircraft to service in accordance with 43.7(f). Or can use any other A&P to clear the list. A second inspection is not required.

But experimental is excluded from 43, so I am still confused about proper experimental condition inspection log entry if an owner doesn't want the inspecting A&P to also complete the repairs. It should be possible to pay for an inspection only, without repairs.
Marty may not agree. Where are the rules?

[martymayes]

I believe you have stumbled upon a very big problem in aviation. Ask one person something you get one answer. Ask someone else the same question and you get another answer.

Consensus is a good thing Tony.

[martymayes]

But experimental is excluded from 43, so I am still confused about proper experimental condition inspection log entry if an owner doesn't want the inspecting A&P to also complete the repairs. It should be possible to pay for an inspection only, without repairs.
Marty may not agree. Where are the rules?

Bill, here is the recommended statement for signing off an A-B condition inspection from the operating limitations (item #23 in the most recent revision):

“I certify that this aircraft has been inspected on [insert date] in accordance with the scope and detail of appendix D to part 43, and was found to be in a condition for safe operation.

How do you sign off the condition inspection if part of that statement (the underlined part) is not true?

There is nothing that says any repairs necessary to make the aircraft safe must be performed by the A&P performing the inspection. So I see no reason why the inspecting A&P could not allow the owner or other designated person to make those repairs (unless s/he simply doesn't want to). Of course, those repairs would have to be completed so the aircraft meets the "condition for safe operation" requirement. Only then could the inspecting A&P enter and sign the required statement into the records.

[1600vw]

Consensus is a good thing Tony.

I agree. The problem is not everyone comes to the same consensus.


Bill, here is the recommended statement for signing off an A-B condition inspection from the operating limitations (item #23 in the most recent revision):

“I certify that this aircraft has been inspected on [insert date] in accordance with the scope and detail of appendix D to part 43, and was found to be in a condition for safe operation.

How do you sign off the condition inspection if part of that statement (the underlined part) is not true?

There is nothing that says any repairs necessary to make the aircraft safe must be performed by the A&P performing the inspection. So I see no reason why the inspecting A&P could not allow the owner or other designated person to make those repairs (unless s/he simply doesn't want to). Of course, those repairs would have to be completed so the aircraft meets the "condition for safe operation" requirement. Only then could the inspecting A&P enter and sign the required statement into the records.

This has been stated many times in this thread.

[Bill Berson]

Bill, here is the recommended statement for signing off an A-B condition inspection from the operating limitations (item #23 in the most recent revision):

“I certify that this aircraft has been inspected on [insert date] in accordance with the scope and detail of appendix D to part 43, and was found to be in a condition for safe operation.

How do you sign off the condition inspection if part of that statement (the underlined part) is not true?

There is nothing that says any repairs necessary to make the aircraft safe must be performed by the A&P performing the inspection. So I see no reason why the inspecting A&P could not allow the owner or other designated person to make those repairs (unless s/he simply doesn't want to). Of course, those repairs would have to be completed so the aircraft meets the "condition for safe operation" requirement. Only then could the inspecting A&P enter and sign the required statement into the records.
The proper record entry is described in FAR 43.11(a)(5): For unairworthy it requires: "I certify that this aircraft has been inspected in accordance with [condition] inspection and a list of discrepancies and unairworthy items dated (date) has been provided for the aircraft owner or operator".

FAR 43.11(a) states persons shall make an entry after any inspection, approving or disapproving.

May not be the common practice, but seems to be the law until I see otherwise.

[martymayes]

The proper record entry is described in FAR 43.11(a)(5): For unairworthy it requires: "I certify that this aircraft has been inspected in accordance with [condition] inspection and a list of discrepancies and unairworthy items dated (date) has been provided for the aircraft owner or operator".

FAR 43.11(a) states persons shall make an entry after any inspection, approving or disapproving.

May not be the common practice, but seems to be the law until I see otherwise.

Unfortunately it's not the law because as you stated earlier, the applicability section of Part 43 excludes E/AB aircraft and that exclusion includes 43.11(a)(5).

That's why the operating limitations for an E/AB aircraft include a paragraph on how to perform and sign off the required inspection. Absent that, there would be no rules to follow.


I'm sure the others will point out there are no airworthiness standards for E/AB aircraft, ergo, they can't be found unairworthy.

[Marc Zeitlin]

Unfortunately...Why "unfortunately"? Do you think that E/AB aircraft should be subject to all the rules that certificated aircraft are? And if so, how would that even work, without TC's and specifications? What about one-off aircraft?

... it's not the law because as you stated earlier, the applicability section of Part 43 excludes E/AB aircraft and that exclusion includes 43.11(a)(5).
That's why the operating limitations for an E/AB aircraft include a paragraph on how to perform and sign off the required inspection. Absent that, there would be no rules to follow.
I'm sure the others will point out there are no airworthiness standards for E/AB aircraft, ergo, they can't be found unairworthy.You just did :-).

I'm with Marty on this one for the reasons he states - Part 43 exempts E/AB aircraft.

In any case, however, 43.11(a) says:

"The person approving or disapproving for return to service an aircraft, airframe, aircraft engine, propeller, appliance, or component part after any inspection performed in accordance with part 91, 125, Sec. 135.411(a)(1), or Sec. 135.419 shall make an entry..."

So, as long as I'm not "disapproving for return to service" the <item in question> I'd argue that the requirement for a logbook entry doesn't apply. And "unairworthy" blah, blah, blah per above.

If I wanted to put a list of "discrepancies" (as noted in 43.411(a)(5) in the logbook, that would be a possibility (if the owner was OK with it), but none of it is prescriptive. The owner can take the plane (still legal to fly [however un-smart it may be] until the current CI expires) go home, fix it (or pay someone else to fix it) and then bring it back to me to show me the discrepancies are fixed, and I can then sign it off. Or, he can pay someone else to inspect the plane again, if he didn't like me or what I told him I thought needed to be done. I cannot ground his plane - I can only refuse to sign off a CI if I deem it unsafe. Now, that's the same as grounding _IF_ the current CI has expired, which is why I said that folks shouldn't wait until the last day of the month to get their CI's signed off :-).

[martymayes]

Do you think that E/AB aircraft should be subject to all the rules that certificated aircraft are?

No, I don't think that at all.

[Bill Berson]

Unfortunately it's not the law because as you stated earlier, the applicability section of Part 43 excludes E/AB aircraft and that exclusion includes 43.11(a)(5).

That's why the operating limitations for an E/AB aircraft include a paragraph on how to perform and sign off the required inspection. Absent that, there would be no rules to follow.


I'm sure the others will point out there are no airworthiness standards for E/AB aircraft, ergo, they can't be found unairworthy.
Here is what I found in Order 8130-2F, see below. In three places it says condition inspections must be recorded. It also says "similarly worded", which gives the A&P some authority to change the wording, I think.
So I am asking what is common practice for the A&P that finds unairworthy items on a condition inspection?


from 8130-2F page 165:

(22) No person must operate this aircraft unless within the preceding 12 calendar months it hashad a condition inspection performed in accordance with the scope and detail of appendix D to part 43,or other FAA-approved programs, and was found to be in a condition for safe operation. As part of thecondition inspection, cockpit instruments must be appropriately marked and needed placards installed inaccordance with § 91.9. In addition, system-essential controls must be in good condition, securelymounted, clearly marked, and provide for ease of operation. This inspection will be recorded in theaircraft maintenance records.
(23) Condition inspections must be recorded in the aircraft maintenance records showing thefollowing, or a similarly worded, statement: “I certify that this aircraft has been inspected on [insertdate] in accordance with the scope and detail of appendix D to part 43, and was found to be in acondition for safe operation.” The entry will include the aircraft’s total time-in-service, and the name,signature, certificate number, and type of certificate held by the person performing the inspection.
NOTE: Limitations 24 and 25 will be issued in lieu of limitations 22 and 23for turbine-powered amateur-built aircraft.
(24) This aircraft must not be operated unless it is inspected and maintained in accordance withan inspection program selected, established, identified, and used as set forth in § 91.409(e), (f), (g),
and (h). This inspection must be recorded in the aircraft maintenance records.
(25) Inspections must be recorded in the aircraft maintenance records showing the following,or a similarly worded, statement: “I certify that this aircraft has been inspected on [insert date] inaccordance with the scope and detail of the [identify program, title] FSDO-approved program dated________, and found to be in a condition for safe operation.” The entry will include the aircraft’s totaltime-in-service (cycles if appropriate), and the name, signature, certificate number, and type ofcertificate held by the person performing the inspection.

[Marc Zeitlin]

Here is what I found in Order 8130-2F, see below. In three places it says condition inspections must be recorded.Yep. And if I finish a CI and am ready to sign the airplane off as safe, then I record it in the logbook. I don't regard the CI as being complete until the plane is safe to fly, so I don't record it if it isn't.

What if someone asks me to take a look at their plane and I see something I regard as unsafe? Do I hunt down their logbook and put an entry in it? No... I don't regard the fact that they've asked me to do a CI as being different - there's no clock running, or setpoint created at that time. To me, the recording is required at the END of the CI, and in my interpretation, that only occurs when the plane is safe to fly and documented to be so.


It also says "similarly worded", which gives the A&P some authority to change the wording, I think.It does, but I always write exactly what that aircraft's Op-Limits specify the wording to be - I haven't found any reason to change it yet.


So I am asking what is common practice for the A&P that finds unairworthy items on a condition inspection?I can't tell you what everyone does, but I can tell you what _I_ do. I give the owner a list of discrepancies that I think make the plane unsafe. I never use the word "unairworthy", because it doesn't mean anything in the context of an E/AB aircraft, as we've discussed. I tell the owner that I wouldn't fly the plane if <X> and <Y> aren't addressed, ask if they want me to address them and tell them what it will cost to do so. So far, everyone has had me do the work, but if they didn't, I'm not going to hold either the aircraft or the logbook hostage. They can pay me for my time and take the plane.

Since the pilot is responsible for the aircraft being ready to fly (meaning safe and legal), and the owner is responsible for maintenance, all I can do is give them the information required for them to be safe. What they do with that information is up to them. And since there are differences of opinions as to what's safe (given some of the stuff I've seen that's been signed off before I get to the plane, there's a WIDE range of opinion), I cannot say with absolute certainty that I'm correct - there is no Type Certificate to which the aircraft must conform - just my opinion of safety, based on aeronautical knowledge and AC43-13, etc.

My $0.02. I'm sure you'll find A&P's with different interpretations of the rules and of what makes aircraft safe to fly.

[Bill Berson]

Hi Marc,
I haven't inspected and signed a Homebuilt log in these last 30 years, but I may again in the future. Things have changed and I am learning the new rules here from you and Marty. I don't think the word "condition" was used 30 years ago.

But my experience with the FAA leads me to say that not signing logs after an inspection is completed will not go over well with the FAA.
It seems the operating limitations should be more clear about what is a proper log entry when an A&P finds discrepancies on a Homebuilt.

There is quite a bit more to say on this topic, but I need to get to work now on my Homebuilt. More later perhaps.

[Dana]

Another wrinkle: What constitutes "condition"?

I contacted a local A&P to do the condition inspection on the Fisher 404 I recently purchased. He owns two homebuilts himself, but has little experience with wood structures. Along with some easily corrected minor issues, he found one significant structural issue that I think is actually a deficiency in the original design, reported by other owners and builders. I have a plan to repair it, making some changes to repair the damage and make it stronger than it was originally (I'm not an A&P but as an aeronautical engineer I do have the ability to evaluate the changes I'm making). The problem is that from his perspective, the repairs I'm proposing are not "by the book" (i.e. AC43-13). He said, in part, "Since it is a non-standard approach and a major repair, I need you to demonstrate how it effects a repair back to the original plane's specifications without change to the flight characteristics... Using non-standard repair techniques will make you a test pilot. If I agree to sign off, that also puts me in the position of an approving design authority for a test platform. I am uncomfortable with that arrangement."

The change I'm making is actually very similar to the modifications other builders have made during the original construction. In that case, presumably he would have no issue with it. If the repairs had been made before he had seen the plane in its original condition, also presumably it would not have been an issue. I can't see him as an "approving design authority"; even the DAR at the initial signoff doesn't evaluate the design, just the condition.

[Marc Zeitlin]

Another wrinkle: What constitutes "condition"?... The change I'm making is actually very similar to the modifications other builders have made during the original construction. In that case, presumably he would have no issue with it. If the repairs had been made before he had seen the plane in its original condition, also presumably it would not have been an issue. I can't see him as an "approving design authority"; even the DAR at the initial signoff doesn't evaluate the design, just the condition.As someone who signs off CI's on E/AB aircraft, personally I agree with your position on this matter. ALL I am doing when I sign off an aircraft is saying that in my professional opinion, the aircraft is in a condition for safe operation. I'm NOT validating the design or any modifications done to the plane UNLESS, in my opinion, something is unsafe.

Give you an example - I was asked to do a CI on a Wheeler Express 2000. Found that the rudders were actuated by two push-pull cables - the kind normally used for throttle control. 25 lb. capability, per specs. We could put both feet flat on the rudder pedals, push hard, and still move the TE of the rudder 2" in either direction due to play in the system. After some investigation, I determined that this was EXACTLY PER PLANS regarding the installation. Holy crap. To me, as an A&P and an Aeronautical engineer, this was a clear design defect - just begging for flutter. I declined to do the CI.

On the other hand, I see a zillion Varieze, Long-EZ and COZY's, which, being plans-built, are all customized to some extent, some with some reasonably large mods. I make a judgement, based on AC43.13, engineering knowledge, A&P experience, etc. as to whether the aircraft, AS-IS, is "in a condition for safe flight". If yes, I sign it off. If not, I don't, and make a recommendation as to what to change.

So, yeah - I agree with your position on this matter. If he doesn't think that what you're going to do is SAFE, that's a different story. But if it just doesn't conform to some original plans specification, that's not within his purview, IMO.

[martymayes]

"The problem is that from his perspective, the repairs I'm proposing are not "by the book" (i.e. AC43-13). He said, in part, [I]"Since it is a non-standard approach and a major repair, I need you to demonstrate how it effects a repair back to the original plane's specifications without change to the flight characteristics..."

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



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

[Marc Zeitlin]

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.


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

[martymayes]

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.

[Dana]

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."


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...

[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.

[Dana]

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.

[1600vw]

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

[martymayes]

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?

[Marc Zeitlin]

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.


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.

[1600vw]

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

[martymayes]

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.

[martymayes]

You bet I trust the speaker in a webinar put on by the EAA before any random comment on the internet.

Not a random comment. Straight out of an FAA publication - Order 8130.2F Chg. 3:

(23) Condition inspections must be recorded in the aircraft maintenance records showing the following, or a similarly worded, statement: “I certify that this aircraft has been inspected on [insert date] in accordance with the scope and detail of appendix D to part 43, and was found to be in a condition for safe operation.” The entry will include the aircraft’s total time-in-service, and the name, signature, certificate number, and type of certificate held by the person performing the inspection.

I'm not the sharpest knife in the drawer but I fail to see where an alternate method of signing off a condition inspection is described, permitted and/or acceptable. That's why I asked for someone to point out a reference which supports a different method of recording a condition inspection. Otherwise, it's a fallacy.

[Bill Berson]

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.
Well, that is how I would sign your log because it puts the burden for repairs on you. Of course it can't be flown till the repair entry is made.
I have signed logs this way with certified airplanes and the FAA approved the log entry because it is the proper procedure when the inspector can't sign it off as airworthy or "condition for safe operation".

[Marc Zeitlin]

Well, that is how I would sign your log because it puts the burden for repairs on you. Of course it can't be flown till the repair entry is made.
I have signed logs this way with certified airplanes and the FAA approved the log entry because it is the proper procedure when the inspector can't sign it off as airworthy or "condition for safe operation".Yes, but with a certificated aircraft, if you say "discrepancies so-and-so must be corrected", only an A&P can perform that work and then the A&P can sign it off as being done (unless it's major and you need an IA, blah, blah).

With an E/AB aircraft, only the RC holder or an A&P can sign it off for a CI, even though ANYONE can actually perform the work and sign the logbooks as having performed the work.

So even if you leave it to the owner to DO the work, without an A&P signoff of "in a condition for safe operation", the plane's not legal, because YOU didn't use that wording in the logs when you signed it. He'll either need you to sign it again or get another A&P to sign it off correctly and legally.

So the owner can make the "repair" entry, certainly, but that doesn't make the plane legal to fly.

[martymayes]

Well, that is how I would sign your log because it puts the burden for repairs on you. Of course it can't be flown till the repair entry is made.
I have signed logs this way with certified airplanes and the FAA approved the log entry because it is the proper procedure when the inspector can't sign it off as airworthy or "condition for safe operation".

And that works with certified airplanes because of the rules in Part 43. Anybody can look up the regs and understand the process.

With an E/AB those regs don't apply. Operating limitations provide guidance for the periodic inspection and sign off and that's what we are obligated to follow. Anyone should be able to look at the OL and understand the process.

[Dana]

Today I talked to a different A&P who understands the difference between what's required for certificated aircraft required to follow an STC'd covering process and what's required for experimentals, so all is good.

Yes, it's different for a certificated aircraft. Years ago I had an annual done on my Taylorcraft; we had to cut the fabric to remove some bird nests from the wings. I flew it home with duct tape, a ferry permit, and a note in the logbook to the effect that "when the fabric is properly repaired the aircraft will be considered airworthy." But as you point out that still required an A&P to sign off the final repairs, unlike an experimental.

When I bought the plane I had to go to the FSDO for a replacement airworthiness certificate. I asked about the test area in the op limitations (the original test area was 3000 miles away from me). He said they could issue me a new set of limitations with a new test area but they might require a new DAR inspection, so he advised me to leave well enough alone unless necessary.

[Bill Berson]

Yes, but with a certificated aircraft, if you say "discrepancies so-and-so must be corrected", only an A&P can perform that work and then the A&P can sign it off as being done (unless it's major and you need an IA, blah, blah).

With an E/AB aircraft, only the RC holder or an A&P can sign it off for a CI, even though ANYONE can actually perform the work and sign the logbooks as having performed the work.

So even if you leave it to the owner to DO the work, without an A&P signoff of "in a condition for safe operation", the plane's not legal, because YOU didn't use that wording in the logs when you signed it. He'll either need you to sign it again or get another A&P to sign it off correctly and legally.

So the owner can make the "repair" entry, certainly, but that doesn't make the plane legal to fly.
Not exactly. The owner of a Type Certificated aircraft can perform a long list of repairs and replace parts listed in 43 app A (preventive maintenance)
If the discrepancies list included items such as:
1) spark plugs worn
2) elastic shock cords worn
3)protective coating needed on engine mount
4)simple fabric patches
etc.
The owner can replace or repair these items and sign the logbook listing these repairs.
In this case, all the items qualify under preventive maintenance. So the owner can also return the aircraft to service under 43.7(f). There is no need for a mechanic to check and approve repairs listed under preventive maintenance.

[Bill Berson]

And that works with certified airplanes because of the rules in Part 43. Anybody can look up the regs and understand the process.

With an E/AB those regs don't apply. Operating limitations provide guidance for the periodic inspection and sign off and that's what we are obligated to follow. Anyone should be able to look at the OL and understand the process.
Yeh, we should be able to look and understand but it isn't that simple. Just look at FAR91.405 where it requires all aircraft be "repaired as prescribed in part 43". There is no exemption for E/AB for repairs in 91.405.

And the Condition inspection requires the inspection be in accordance with the Scope and Detail of part 43 (app D).

So the above two points contradicts where it says experimental are exempt, as mentioned in FAR43.1(b).

[1600vw]

Not a random comment. Straight out of an FAA publication - Order 8130.2F Chg. 3:

(23) Condition inspections must be recorded in the aircraft maintenance records showing the following, or a similarly worded, statement: “I certify that this aircraft has been inspected on [insert date] in accordance with the scope and detail of appendix D to part 43, and was found to be in a condition for safe operation.” The entry will include the aircraft’s total time-in-service, and the name, signature, certificate number, and type of certificate held by the person performing the inspection.

I'm not the sharpest knife in the drawer but I fail to see where an alternate method of signing off a condition inspection is described, permitted and/or acceptable. That's why I asked for someone to point out a reference which supports a different method of recording a condition inspection. Otherwise, it's a fallacy.

Airplane "A" goes in for Condition inspection. A&P does the inspection and hands the owner a list of things needing addressed. The owner addresses those things on the list. The A&P does not have to do another inspection, its been done. All that needs done is the list of problems need to be repaired or fixed. Another Condition Inspection does not need to be done, it was done and the A&P handed the problems or things needed fixed " discrepancies " to the owner. The inspection is done with discrepancies. No need for another inspection. Its been done.

[Dana]

Not exactly. The owner of a Type Certificated aircraft can perform a long list of repairs and replace parts listed in 43 app A (preventive maintenance)
If the discrepancies list included items such as:

The owner can replace or repair these items and sign the logbook listing these repairs.
In this case, all the items qualify under preventive maintenance. So the owner can also return the aircraft to service under 43.7(f). There is no need for a mechanic to check and approve repairs listed under preventive maintenance.

True. But most of those things aren't things that would cause the failure of an annual inspection, or would be quick fixes the IA would fix in the course of the inspection. But yes, the IA could pass it with discrepancies that the owner could fix himself.


Airplane "A" goes in for Condition inspection. A&P does the inspection and hands the owner a list of things needing addressed. The owner addresses those things on the list. The A&P does not have to do another inspection, its been done. All that needs done is the list of problems need to be repaired or fixed. Another Condition Inspection does not need to be done, it was done and the A&P handed the problems or things needed fixed " discrepancies " to the owner. The inspection is done with discrepancies. No need for another inspection. Its been done.

The problem there is that the A&P has to make an entry in the logbook stating, "I certify that this aircraft has been inspected on (date) in accordance with the scope and detail of FAR43, Appendix D, and found to be in a condition for safe operation." The operating limitations require that or similar wording. Any discrepancies and it's not "in a condition for safe operation" at that point so that logbook entry can't be made.

[1600vw]

The problem there is that the A&P has to make an entry in the logbook stating, "I certify that this aircraft has been inspected on (date) in accordance with the scope and detail of FAR43, Appendix D, and found to be in a condition for safe operation." The operating limitations require that or similar wording. Any discrepancies and it's not "in a condition for safe operation" at that point so that logbook entry can't be made.

Right but another Condition inspection is not needed. All that is needed is to look over the discrepancies and see if they have been addressed, then sign the log book. The Condition Inspection has been done. Another is not needed.

[martymayes]

Right but another Condition inspection is not needed. All that is needed is to look over the discrepancies and see if they have been addressed, then sign the log book. The Condition Inspection has been done. Another is not needed.


So you agree that a condition inspection can not be "signed off" with discrepancies?

[rwanttaja]

The problem there is that the A&P has to make an entry in the logbook stating, "I certify that this aircraft has been inspected on (date) in accordance with the scope and detail of FAR43, Appendix D, and found to be in a condition for safe operation." The operating limitations require that or similar wording. Any discrepancies and it's not "in a condition for safe operation" at that point so that logbook entry can't be made.

My personal experience is that I open up the airplane and do the routine maintenance stuff and fix the stuff I find before the A&P arrives. He gets there, goes through the airplane, says, "Fix this and this and this" and goes away.

I fix the items and give him a call. He comes out, checks my work, then puts sticker in the logbooks with the "condition for safe operation" wording and signs it. I then give him pieces of green paper.

This is often done in a day, or might take ~2 weeks or more depending on what was found.

Ron Wanttaja

[Bill Berson]

And 91.403(b)also requires all aircraft maintenance be performed as prescribed under applicable regulations including Part 43.

Do the operating limitations prescribe maintenance rules or just the inspection?

[Bill Berson]

True. But most of those things aren't things that would cause the failure of an annual inspection, or would be quick fixes the IA would fix in the course of the inspection. But yes, the IA could pass it with discrepancies that the owner could fix himself.



The problem there is that the A&P has to make an entry in the logbook stating, "I certify that this aircraft has been inspected on (date) in accordance with the scope and detail of FAR43, Appendix D, and found to be in a condition for safe operation." The operating limitations require that or similar wording. Any discrepancies and it's not "in a condition for safe operation" at that point so that logbook entry can't be made.
An IA does the inspection but may or may not do any of the repairs. The repairs can be done by any qualified person. The reason for discrepancies list is so that the owner can choose any and all of the specialists needed to complete the repairs.
In the case of E/AB, the owner can choose anyone or himself for every repair, not just the list of preventive maintenance.

My original question was : what if you decided the fabric repair was too much trouble and you decide to simply sell as is?
I believe an FAA attorney might say you are required to transfer a list of discrepancies to the buyer.

[1600vw]

An IA does the inspection but may or may not do any of the repairs. The repairs can be done by any qualified person. The reason for discrepancies list is so that the owner can choose any and all of the specialists needed to complete the repairs.
In the case of E/AB, the owner can choose anyone or himself for every repair, not just the list of preventive maintenance.

My original question was : what if you decided the fabric repair was too much trouble and you decide to simply sell as is?
I believe an FAA attorney might say you are required to transfer a list of discrepancies to the buyer.

No IA needed.

[Bill Berson]

No IA needed.
Yeh, my discussion with Dana was referring to Type certificated aircraft in that comment.
For E/AB, an A&P or owner with Repairman can perform the 12 month inspection.
But the inspection is separate from repairs and lubrication. The person who signs the record for the 12 month inspection is NOT required to be the person that completes the repairs or service.
In the case of E/AB, anyone can do the repairs (major or minor) without supervision or any inspection of the completed work (as I see it). This is unique to E/AB.

A major change might require an inspection from the FAA or DAR. But a major repair is not a major change.

I am still sifting through the rules today.
I believe it all starts with FAR Part 91 which details flight and maintenance and inspection rules for airplanes*.
I am now trying to find the regulation that requires an E/AB owner to retain and hold the Operating Limitations.
I think the Operating Limitations must be linked with the Airworthiness Certificate somehow, but what is the regulation?
I don't think FAA Orders are regulations, but this is where I am a bit unclear.

*ultralights are "vehicles", not airplanes, so ultralights are exempt from Part 91

[Frank Giger]

Right but another Condition inspection is not needed. All that is needed is to look over the discrepancies and see if they have been addressed, then sign the log book. The Condition Inspection has been done. Another is not needed.

I think y'all are typing past each other!

Let's say that I have an A&P look over my aircraft, and he spots that the throttle cable is seriously binding or frayed. At that point he says "whoa, that's an unsafe condition" and if I've handed him my log books writes that he did the inspection and found it as a descrepency. He doesn't write it's in a safe condition to operate.

Why would he write anything in the log book? Because he's trained to write in log books any time he does an inspection. Chances are that the vast majority of the time he deals with type certified aircraft and that's where his mind is!

Anyhow, so I replace the throttle cable and bring it back to him.

Naturally he doesn't go back to square one and start the whole inspection over (assuming the repair is done in a timely manner); he notes it was repaired, and assuming that was the only gig that would cause it to be unsafe in his opinion, then puts down the Magic Words.

The inspection date for the twelve month clock would be, if I understand things right, when he signs off on it as in safe condition, not when he did the initial inspection.

[Bill Berson]

The difference is the mechanic assumes some liability for your throttle cable installation.
If you did it wrong and he didn't find the flaw, he could be held responsible because he is supposedly more "professional" and is open to a law suit from your wife or son if you are dead.
If you sign it off and return it to service, he would not be liable for that repair.
More mechanics would do inspections if not held liable for owner work. That's the whole point of my alternative sign off comments.

[martymayes]

If you sign it off and return it to service, he would not be liable for that repair.

Bill, I notice you use the phrase "return to service"

How would a person that doesn't hold an airman certificate return a homebuilt to service? How could they be held liable if there is no way to track them down after the fact?

[Bill Berson]

Bill, I notice you use the phrase "return to service"

How would a person that doesn't hold an airman certificate return a homebuilt to service? How could they be held liable if there is no way to track them down after the fact?
I don't know if a Homebuilt owner needs any airman certificate, but for Type cerficated aircraft a Private certificate will do.

"A person holding at least a private pilot certificate may approve an aircraft for return to service after performing preventive maintenance"... (43.7(f) )

It is very clear that parts of Part 43 do apply to E/AB such as appendix D for the inspection. So I don't see why other parts of 43 would not be allowable or required as well.

[1600vw]

I don't know if a Homebuilt owner needs any airman certificate, but for Type cerficated aircraft a Private certificate will do.

"A person holding at least a private pilot certificate may approve an aircraft for return to service after performing preventive maintenance"... (43.7(f) )

It is very clear that parts of Part 43 do apply to E/AB such as appendix D for the inspection. So I don't see why other parts of 43 would not be allowable or required as well.

Its in the wording.