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Thread: Why do people call Condition Inspections " Annuals"

  1. #21
    Jeff Point's Avatar
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    Quote Originally Posted by Sam Buchanan View Post
    But experimentals don't have type certificates. Consequently, it is impossible to have a "certificated" engine in an experimental. Having said that, it is possible to maintain an engine and prop to the same standards as it would have been maintained in a type certificated airframe, but the engine is no longer "certificated".
    Bingo. Taking it a step further, because the engine is no longer "certificated" the moment that you bolt it to an E-AB, AD compliance is not required in order to maintain "certification" because there is no certification. This does not address the wisdom of compliance, just the legal requirements.
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  2. #22

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    Quote Originally Posted by Marc Zeitlin View Post
    ...From AC39-7D, released on 3/2/2012, section 9 explicitly states:

    "... Unless stated otherwise (see subparagraph 9b of this AC), ADs only apply to type-certificated (TC) aircraft,including ADs issued for an engine, propeller, and appliance."

    This is VERY clear that if the FAA wants an AD to apply to an non-TC'd aircraft, they have to explicitly say so. Part (9b), referenced above, states:

    "The AD applicability statement will identify if the AD applies to non-TC’d aircraft or engines, propellers, and appliances installed thereon."...

    AC39-7D, "...ADs apply only to type-certificated aircraft, including ADs issued for an engine, propeller, and appliance." Spot on target.

    And this becomes even more clear when compared to the previous version, AC39-7C:

    "8. 8. APPLICABILITY OF AD's...Unless specifically stated, AD's apply to the make and model set forth in the applicability statement regardless of the classification or category of the airworthiness certificate issued for the aircraft..."


    I had some worries about the D model at first. Started a thread on the subject back then:

    http://eaaforums.org/showthread.php?...ess+directives

    Mostly because I didn't know enough about the subject (yep, that happens a lot.) C model vs D model. Pretty significant change. Very obvious what they meant when the two versions are compared. Very doubtful it wasn't intentional. The C model was about 17 years old when killed. Some of us didn't know Charlie very well. And many of those who did know him missed his obituary.

  3. #23
    cub builder's Avatar
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    Quote Originally Posted by Jeff Point View Post
    Bingo. Taking it a step further, because the engine is no longer "certificated" the moment that you bolt it to an E-AB, AD compliance is not required in order to maintain "certification" because there is no certification. This does not address the wisdom of compliance, just the legal requirements.
    That may or may not be true, but when your E-AB aircraft sporting a Lycoming engine on the nose is involved in an incident, the FAA inspector is going to go right to the engine log and look for A.D compliance. You may not agree with him gigging you and the A&P that signed your condition inspection (if you don't have a Repairman Certificate), but regardless of whether you agree or not, you and whoever signed the condition inspection will be on defense. I have seen it happen.

    In this case, the non-certificated the wood prop failed where it had recently picked up a rock ding and threw some 6" off one tip. The pilot executed a forced landing, but was unable to get squared up on his intended landing site causing damage to the landing gear and some minor damage to the airframe. The FAA inspector Insisted on a review of the engine logs for AD compliance even though it wasn't relevant to the failure and the engine was undamaged. The owner conveniently lost to logs so as to not involve the A&P that had signed the logs (it was not up to date on it's A.D.s). The log book was found at a later date after the FAA had lost interest.

    Lesson for me as an A&P (and it wasn't me that had signed the CI), if you have a certificated engine on the front of your plane and bring it to me for a CI, it's going to comply with the AD list for that engine. If you don't like it, then find an A&P that's willing to risk his license to save you a couple of $$.

    We can discuss interpretation of regulations to our little hearts delight here in the blogosphere, but in the real world, someone's likely to be on the hook for non-compliance. You can be right, but it's still costly, time consuming and aggravating to prove the FAA inspector to be wrong. As an A&P, I find having conversations with the FAA and NTSB following accidents to be one of the less enjoyable parts of the job. And I sure don't want be on the defensive if I have to have one of those conversations.

    -Cub Builder
    Last edited by cub builder; 04-16-2015 at 12:55 PM.

  4. #24
    Sam Buchanan's Avatar
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    Quote Originally Posted by cub builder View Post
    That may or may not be true, but when your E-AB aircraft sporting a Lycoming engine on the nose is involved in an incident, the FAA inspector is going to go right to the engine log and look for A.D compliance. You may not agree with him gigging you and the A&P that signed your condition inspection (if you don't have a Repairman Certificate), but regardless of whether you agree or not, you and whoever signed the condition inspection will be on defense. I have seen it happen.

    In this case, the non-certificated the wood prop failed where it had recently picked up a rock ding and threw some 6" off one tip. The pilot executed a forced landing, but was unable to get squared up on his intended landing site causing damage to the landing gear and some minor damage to the airframe. The FAA inspector Insisted on a review of the engine logs for AD compliance even though it wasn't relevant to the failure and the engine was undamaged. The owner conveniently lost to logs so as to not involve the A&P that had signed the logs (it was not up to date on it's A.D.s). The log book was found at a later date after the FAA had lost interest.

    Lesson for me as an A&P (and it wasn't me that had signed the CI), if you have a certificated engine on the front of your plane and bring it to me for a CI, it's going to comply with the AD list for that engine. If you don't like it, then find an A&P that's willing to risk his license to save you a couple of $$.

    We can discuss interpretation of regulations to our little hearts delight here in the blogosphere, but in the real world, someone's likely to be on the hook for non-compliance. You can be right, but it's still costly, time consuming and aggravating to prove the FAA inspector to be wrong. As an A&P, I find having conversations with the FAA and NTSB following accidents to be one of the less enjoyable parts of the job. And I sure don't want be on the defensive if I have to have one of those conversations.

    -Cub Builder
    I suppose the question that begs to be asked is....at what point does a Lycoming cease being certificated?

    Do automotive spark plugs cause it to lose "certificated" status? What about an experimental ignition system? Aftermarket (non-TSO'ed) exhaust system? An alternator from a 1978 Honda Civic (that is what is on my O-320)? High compression pistons that never were installed by the factory in that particular engine? A home-brew remote oil fiter adapter?

    And what about those of us burning automotive gas in our "Lycomings"?

    How is "certificated" engine defined by the over-reaching FAA inspectors since no such animal exists on an aircraft with an experimental airworthiness certificate?
    Last edited by Sam Buchanan; 04-16-2015 at 04:12 PM.
    Sam Buchanan
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  5. #25
    cub builder's Avatar
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    Quote Originally Posted by Sam Buchanan View Post
    I suppose the question that begs to be asked is....at what point does a Lycoming cease being certificated?
    It is my understanding the answer is "When it no longer has a Lycoming or Continental Data Plate." But you would do better to talk to your local FSDO about their interpretation to that question.

    Quote Originally Posted by Sam Buchanan View Post
    Do automotive spark plugs cause it to lose "certificated" status? What about an experimental ignition system? Aftermarket (non-TSO'ed) exhaust system? An alternator from a 1978 Honda Civic (that is what is on my O-320)? High compression pistons that never were installed by the factory in that particular engine? A home-brew remote oil fiter adapter?

    And what about those of us burning automotive gas in our "Lycomings"?
    Using Automotive spark plugs and an automotive harness to adapt to them would exempt you from a spark plug or ignition harness A.D. since there won't be any out there against the automotive Spark plugs. An aftermarket or home brewed exhaust would exempt you from an A.D. against that exhaust; again because there won't be an A.D. against a non-TSO exhaust system. But, just because you have an aftermarket or home brewed exhaust doesn't mean I wouldn't look at it for problems and recommend fixing it if there are problems. Same is true for your home brewed oil filter assembly. The alternator is part of the Airframe accessories, so that doesn't apply since we're talking Engine A.D.s and your E-AB airframe sure isn't going to have any A.D.s. But if you had an alternator that had known issues, I'd certainly bring it to your attention as well.

    Quote Originally Posted by Sam Buchanan View Post
    How do you define "certificated" engine since no such animal exists on an aircraft with an experimental airworthiness certificate?
    IMHO, Certificated engines do exist in the Experimental world. The FAA recognizes such, which is why you can have a 25 hour phase 1 test period if you use a certificated engine/prop combination on your E-AB aircraft. That is exactly what I did on one of my E-AB aircraft. The engine and prop were in the same combination as they would have been when installed in a certificated aircraft. The engine and prop both met the standards for their individual Type Certificates (including STCs) when they were installed into my aircraft (although I completed a field overhaul to new standards prior to installation). IMHO, if the engine is built and maintained in compliance with it's Type Certificate, then it is still a certificated engine. As such, I would have no problem with mounting it back into a certificated aircraft. I keep seeing people stating otherwise in the forums, but I would respectfully disagree. If it meets the standard of it's type certificate, it can be used as such.

    So let's be clear about something here. There is what you may be able to get away with legally, and then there's the issue of asking a mechanic to put his license at risk by signing for an engine that's not up to snuff on it's A.D.s. Those are two different subjects. I've never had an owner offer to indemnify me as a mechanic if the FAA decides they don't like something I signed for, and I don't get to go back and bill the owner for the time I'm going to waste dealing with the FAA because the owner didn't think complying with A.D.s was a necessity.

    FWIW, I was wearing an airplane builder hat some 30 years before I got my A&P hat, so I believe I do see both sides of the coin here. For the purposes of this discussion, I've been wearing my A&P hat since the discussion started out with Tony's favorite subject of bashing us ignorant A&Ps. But I must admit, I have had problems tying my shoes in the morning since acquiring the license.

    -Cub Builder
    A&P, Former EAA Technical Counselor, Former EAA Flight Advisor

  6. #26
    Jeff Point's Avatar
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    Sounds like you had a bad experience with an inspector who didn't know the regs. I don't blame you for being gun shy, but the regs don't change because one inspector misinterprets them.
    Jeff Point
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  7. #27

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    Read FAR 39:
    The FAA issues Airworthiness Directives when an unsafe "condition" is found in a product, and the condition is likely to exist or develop in other products of the same type design.

    Since each EA-B airframe is one of a kind, there is no need for the FAA to advise other owners of same type design since only one exists and there is no type design.
    But the FAA must issue an AD for a defective engine, if the engine was made under a Type Certificate since other of these engines are likely to have the same problem.
    The owner is primarily responsible for maintaining the aircraft in airworthy "condition" including compliance with AD's (see FAR 91.403). I can't find any excemption for EA-B from this AD compliance requirement found in FAR 91.403.

    Ultralights are excempt from AD's because ultralights are excempt from FAR91 entirely. (91.1)

  8. #28

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    Quote Originally Posted by Bill Berson View Post
    Read FAR 39:
    The FAA issues Airworthiness Directives when an unsafe "condition" is found in a product, and the condition is likely to exist or develop in other products of the same type design.

    Since each EA-B airframe is one of a kind, there is no need for the FAA to advise other owners of same type design since only one exists and there is no type design.
    But the FAA must issue an AD for a defective engine, if the engine was made under a Type Certificate since other of these engines are likely to have the same problem.
    The owner is primarily responsible for maintaining the aircraft in airworthy "condition" including compliance with AD's (see FAR 91.403). I can't find any excemption for EA-B from this AD compliance requirement found in FAR 91.403.
    You guys arguing that AD's always apply to EAB aircraft might want to read this:

    http://starduster.aircraftspruce.com...ges/25960.html

    which covers the EAA's position on it - I imagine they've spent a good deal more time analyzing the regs than we have, and their position is that they do NOT apply (legally) and that the FAA is clear in their INTENT on that. The new AC merely clarifies that position. Yes, that message is 10 years old, but other than the new AC, nothing has changed in that time period.

    As Jeff Point points out (well, that reads strangely) one (or a few) people misinterpreting the rules doesn't change the rules.

    I always RECOMMEND that the owner research and comply with AD's on their engines/appliances if necessary when I do CI's, but I don't require it, as the regs don't require it.

  9. #29

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    Quote Originally Posted by FlyingRon View Post
    Same reason people call Flight Reviews 'Biennials.'
    And cross tip screw drivers as "Phillips head" and adjustable wrenches as "Crescent wrenches."
    The opinions and statements of this poster are largely based on facts and portray a possible version of the actual events.

  10. #30
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    Quote Originally Posted by Frank Giger View Post
    And cross tip screw drivers as "Phillips head" ...
    I always thought a "Phillips Screwdriver" was Vodka and Milk of Magnesia... :-)

    Ron Wanttaja

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