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Thread: Updating operating limitations?

  1. #1
    Dana's Avatar
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    Updating operating limitations?

    Some time ago I recall seeing something about getting operating limitations replaced with the new wording, but I can't find it. My plane was originally built in 1992, with the operating limitations from that era, including a complete prohibition on flight over densely populated areas or congested airways (what is a "congested airway", anyway?) except for takeoff and landing, any major change invalidates the airworthiness certificate instead of just going back to phase 1, and a test area 3000 miles from where I live. What is involved in getting the FAA to issue me new limitations?

  2. #2
    cub builder's Avatar
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    The biggest issue with the old Operating Limitations like you have, and like I have on my first plane (1996) is that the operating limitations spell out the test area for phase 1 testing in the operating limitations rather than referencing a document or approval by the local FSDO. Under such, if you were to move to another part of the country, then make a modification to your aircraft that requires phase 1 testing for some specified period of time, legally, you would have to transport your aircraft back to where you originally performed the phase 1 testing as spelled out in your Operating Limitations. Under the newer OL, it allows the local FSDO to assign a new phase 1 test area without issuing you new OL paperwork. When I discussed this with the local FSDO in the past, they wanted me to send them my OL and said they would have a new OL sent out to me within 2 weeks. I would have been on board if I could walk in and exchange papers, but I wasn't willing to ground my plane for 2 weeks to make the change, so retained my old OL. Some day in the future, I plan to relocate, so will need to make the change.

    -Cub Builder

  3. #3

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    Quote Originally Posted by cub builder View Post
    The biggest issue with the old Operating Limitations like you have, and like I have on my first plane (1996) is that the operating limitations spell out the test area for phase 1 testing in the operating limitations rather than referencing a document or approval by the local FSDO. Under such, if you were to move to another part of the country, then make a modification to your aircraft that requires phase 1 testing for some specified period of time, legally, you would have to transport your aircraft back to where you originally performed the phase 1 testing as spelled out in your Operating Limitations. Under the newer OL, it allows the local FSDO to assign a new phase 1 test area without issuing you new OL paperwork. When I discussed this with the local FSDO in the past, they wanted me to send them my OL and said they would have a new OL sent out to me within 2 weeks. I would have been on board if I could walk in and exchange papers, but I wasn't willing to ground my plane for 2 weeks to make the change, so retained my old OL. Some day in the future, I plan to relocate, so will need to make the change.

    -Cub Builder

    Why not make a copy of your OL and send that to them . Retain the original in your airplane. I keep my original OL in my house and have a copy in my airplane. All it would take is for someone to climb aboard my airplane when I am not around and take the OL or any of the documents that must be in my airplane and ruin my day, week, month. This is why I keep copies in my airplane. If someone said I want to see the originals, fine I will show them. But really the copies look just like the original. The only thing I do not do this with is the registration. But I do have a copy of said registration.

    Tony

  4. #4
    cub builder's Avatar
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    Quote Originally Posted by 1600vw View Post
    Why not make a copy of your OL and send that to them . Retain the original in your airplane.
    Tony
    The FAA wants the originals back and I'm not currently in the mood to play FAA games, nor has the mood struck in the last 9 years since the FAA told me they would like to replace my OLs. Since I haven't moved in the last 30 years, it hasn't been a problem. As you may have noticed from the other thread about Operating Limitations, the FAA keeps changing them. I don't see the need to try to hit a moving target until it's necessary. Since mine are legal, there's no need to change yet. I'll deal with it next time I plan to have the plane grounded for an extended period of time for upgrades, which would really be the only time I would go back to phase 1 anyway. My current OL is 2 pages long. The OL for the last plane I built was 15 pages of lawyer speak. I'd rather have the 2 page OL.

    -Cub Builder

  5. #5
    Dana's Avatar
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    The issue with mine is that I can't even put it back into phase 1; anything that would require that (i.e. major change) would "invalidate the airworthiness certificate." And I'd like to remove the limitation on flight over densely populated areas.

    I don't even have the original copy of the op limitations; they (and the airworthiness certificate) were missing when I bought the plane. The local FSDO issued me a replacement AC and gave me a copy of the original op limitations from their records.

    I guess I'll have to contact them and ask how to proceed. If it requires sending stuff back, I'll just wait until winter when it's too cold to fly an open cockpit anyway.

  6. #6

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    Dana keep us posted. This is a very interesting subject that effects a lot of us. My OL was written or given in 2004 and its just as you say. I want this changed as well. Over all these years I am sure we are not the only two who have to deal or dealing with this. Second hand airplane moved across the country.

    No one in their right mind will take an airplane some thousand miles to fly off another phase 1. Its just not happening.

    Tony

  7. #7

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    Quote Originally Posted by cub builder View Post
    The FAA wants the originals back and I'm not currently in the mood to play FAA games, nor has the mood struck in the last 9 years since the FAA told me they would like to replace my OLs. Since I haven't moved in the last 30 years, it hasn't been a problem. As you may have noticed from the other thread about Operating Limitations, the FAA keeps changing them. I don't see the need to try to hit a moving target until it's necessary. Since mine are legal, there's no need to change yet. I'll deal with it next time I plan to have the plane grounded for an extended period of time for upgrades, which would really be the only time I would go back to phase 1 anyway. My current OL is 2 pages long. The OL for the last plane I built was 15 pages of lawyer speak. I'd rather have the 2 page OL.

    -Cub Builder
    If they want the originals, make copies and send them the originals. Having this paper work redone will not make your airworthy certificate void. Your registration will not be void, your OL are changing, when you get them you get new instructions on how you operate your airplane. Until then operate according to your current OL instructions.

    How I would do it.

    Tony

  8. #8

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    I've had them reissued on 3 different planes over the last 25 years, & the local FSDO always let me fax my request, created new lims based on current policy, and had me bring the existing ones in person for a swap. Every FSDO seems to be different in their policies but it might be worth a try to fax them a copy of your lims & request for new lims, and offer to bring the originals in person for a swap.

    Charlie

  9. #9
    Dana's Avatar
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    I emailed the local FSDO, I'll see what they say. I had to go there in person to get the new AC, they wanted to look at the logbooks. Hopefully they won't hassle me about not having the original OLs (they gave me the copy, after all), and hopefully I won't have to go there in person... it means wasting a vacation day from work that I'd rather save for fun things.

  10. #10

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    Dana why would they give you a hard time for not have originals? After all you could loose all documents and contact the FAA to send you copies of everything they have issued for your airplane. I purchased an airplane without all its paper work. I sent a letter to OK city asking for all documents for my new to me airplane. They sent me all documents on file.

    Tony

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