Refurbishment documentation requirements . . . and what makes sense

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12-20-2011, 10:09 PM
bwilson4web

Refurbishment documentation requirements . . . and what makes sense

Hi,

So the Nov/Dec 2008 FAAAviation News, pp. 28-29, "Nuts, Bolts, and Electrons" by Martin Bailey goes out of its way to state:

Quote:

1. The repair or alteration form specified in sections ... is not required to be completed for products no produced under an FAA approval; 2. Major repairs and major alterations for products not produced under an FAA approval are not required to be recorded in accordance with appendix B of this part; and 3. The listing of major alternations and major repairs specified in paragraphs ... of appendix .,.,. is not applicable to products not produced under an FAA approval. . . . performing maintenance on an Experimental Light Sport Aircraft . . .

I believe this is directed at one specific class of experimental plane, the ones that meet the two-seat, limited stall speed and top speed requirements.

In my case, I bought N19WT which was built by W. Triplett and G. Gillingham. I believe I am still required to document any changes and modification following the 'repair or alteration' form, right?

I have the "Engine Log EL-13P" that after the engine has sections titled "AIRWORTHINESS DIRECTIVE/FACTOR BULLETIN COMPLIANCE RECORD" and "INSPECTION & MAINTENANCE RECORD." Now this is fine, 25 year old document whose pages are somewhat fading and showing age effects. However, this source document is not something I want to 'mess with' without an A&P sign-off. Also, we've got more modern, electronic mechanisms for making a backup copy of this document.

So my first question before I call my FAA rep, are there any guidelines for making an electronic, backup copy of this paper document so the copy can be recognized as a substitute should the original suffer damage or other loss? In fact, I want to do this for every critical piece of paper associated with this plane.

Are there guidelines for electronic forms, signature and tracking of aircraft records including the repairs and modifications?

In 25 years, we've learned a lot of lessons for this 25 year old, experimental airplane. The aircraft plans copyright has passed through at least four owners and now I understand has been sold to an Italian gentleman . . . who has yet to announce himself. But the ~200 or so Dragonfly owners have built up a considerable body of knowledge about what works and I intend to follow many of their recommendations.

It has been my practice to find out what 'documentation is required' before expending major work on a project and making sure the documentation is generated before and as part of the build. I intend to follow the same practice once the work shed is ready to start my refurbishment work. But it helps to understand what is needed and pay as much attention to paperwork WHILE I do my work.

Thanks, Bob Wilson
12-21-2011, 01:34 PM
Dave Prizio

The note you cite applies to Experimental Light Sport (E-LSA) aircraft. That is a variety of aircraft distinct and separate from Experimental Amateur Built aircraft and has different requirements. If you have an E/AB airplane, then your should look to your operating limitations for requirements relating to major modifications. Typically you will be required to make logbook entries for the installation and testing of any major modification and secure the approval of your local FSDO for re-entering Phase I flight testing -- they will designate a flight test area and duration of the test period. The particulars of the major modification do not otherwise need to be reported to the FAA in any form.

This is not at all like the reporting requirements for reporting major modifications to certificated airplanes. E-LSAs have different requirements for modifications which in some ways are even more stringent than for certificated airplanes, but they do not apply to E/AB airplanes.

Dave Prizio
12-22-2011, 06:36 AM
bwilson4web

Thank you!

Quote:

Originally Posted by Dave Prizio

The note you cite applies to Experimental Light Sport (E-LSA) aircraft. That is a variety of aircraft distinct and separate from Experimental Amateur Built aircraft and has different requirements. If you have an E/AB airplane, then your should look to your operating limitations for requirements relating to major modifications. Typically you will be required to make logbook entries for the installation and testing of any major modification and secure the approval of your local FSDO for re-entering Phase I flight testing -- they will designate a flight test area and duration of the test period. The particulars of the major modification do not otherwise need to be reported to the FAA in any form.

This is not at all like the reporting requirements for reporting major modifications to certificated airplanes. E-LSAs have different requirements for modifications which in some ways are even more stringent than for certificated airplanes, but they do not apply to E/AB airplanes.

Three months ago, I was just an observer but after buying N19WT, I've got a lot to learn including the paperwork, terms and terminology.

Bob Wilson