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This is NOT about Ducts or radiators.{:>)
But, realizing that there are a number of new guys on the
list, when I came across this information in my files, I thought it might serve
to remind us all about compliance with FAA and Insurance
requirements.
I must admit, I undoubtedly violated the
major modification rule a number of times early on in my numerous efforts to
improve performance and cooling, fortunately without having an accident or
incident. But, I saw the light and got my operating limitations modified
to permit me to make major modifications without FAA
recertification/Inspection.
In any case, if interested, you might want to start by
reviewing the document AVEMCO Policy on Modifications.doc - I'm not certain
whether other insurance companies all have the same exclusion but its
likely.
This file is regarding a lawsuit between an
experimental aircraft owner and AVEMCO insurance company. In a nut
shell, the company was not held liable because the aircraft owner had made
several modifications to his fuel system (considered a Major Modification) prior
to the crash without notifying the FAA and/or having them recertify the
aircraft. You might find it interesting and informative
reading.
I don't know what the "operating Limitations" of your
aircraft documentation contains. BUT, if it does not explicitly contain a
paragraph that reads something like the one below, then if you made a major
change and do not get FAA recertification, you may find your insurance is
worthless in addition to having to answer to the FAA. This change to
operating limitations only requires that you fly 5 hours to test the
modification, collected some basic performance information and then enter a
statement (below in bold print) in your log book and you are legal. BUT,
YOU MUST HAVE THAT APPROVED AUTHORITY IN YOUR OPERATING LIMITATION.
Now at the time there was discussion in the FAA about
making this a boiler plate statement in all NEW operating limitations (but, I
don't know if that ever happened) and even if they did, if you have an older
operating limitation which does not contain it - you are NOT
covered.
I have attached several documents with more information
for those interested.
The following is an extract of a portion of my letter to the
FAA requesting this modification to my Operating Limitations.
.....to conform with 8130.2D Para 134b(17), as follows: "After incorporating
a major change as described in FAR 21.93, the aircraft owner is required to
re-establish compliance with FAR 91.319(b). All operations will be conducted day
VFR in a sparsely populated area. The aircraft must remain in flight test for a
minimum of 5 hours. Person’s non-essential to the flight shall not be carried.
The aircraft owner shall make a detailed log book entry describing the major
change prior to the test flight. Following satisfactory completion of the
required number of flight hours in the flight test area, the pilot shall certify
in the records that the aircraft has been shown to comply with FAR 91.319(b).
Compliance with FAR 91.319(b) shall be recorded in the aircraft records with the
following or similarly worded statement: I certify that the prescribed flight
test hours have been completed and the aircraft is controllable throughout its
normal range of speeds and throughout all maneuvers to be executed, has no
hazardous operating characteristics or design features, and is safe for
operation. The following aircraft operating data has been demonstrated during
the flight-testing: Speeds Vso______, Vx_______, and Vy________, and the weight
___________, and CG location_________ at which they were
obtained."
Best Regards
Ed
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