X-Virus-Scanned: clean according to Sophos on Logan.com X-SpamCatcher-Score: 1 [X] Return-Path: Sender: To: lml Date: Fri, 22 Dec 2006 21:22:59 -0500 Message-ID: X-Original-Return-Path: Received: from imo-d21.mx.aol.com ([205.188.144.207] verified) by logan.com (CommuniGate Pro SMTP 5.1.3) with ESMTP id 1702922 for lml@lancaironline.net; Fri, 22 Dec 2006 20:30:36 -0500 Received-SPF: pass receiver=logan.com; client-ip=205.188.144.207; envelope-from=VTAILJEFF@aol.com Received: from VTAILJEFF@aol.com by imo-d21.mx.aol.com (mail_out_v38_r7.6.) id q.cee.526051e (42809) for ; Fri, 22 Dec 2006 20:29:48 -0500 (EST) From: VTAILJEFF@aol.com X-Original-Message-ID: X-Original-Date: Fri, 22 Dec 2006 20:29:46 EST Subject: Re: [LML] Re: Overhauled Engine now labeled "Experimental Only " ?? X-Original-To: lml@lancaironline.net MIME-Version: 1.0 Content-Type: multipart/alternative; boundary="-----------------------------1166837386" X-Mailer: 9.0 SE for Windows sub 5031 X-Spam-Flag: NO -------------------------------1166837386 Content-Type: text/plain; charset="UTF-8" Content-Transfer-Encoding: quoted-printable Content-Language: en =20 In a message dated 12/22/2006 6:26:08 PM Central Standard Time, =20 marv@lancaironline.net writes: All of that needs to be seemless; hence, any deviation of an engine, or accessory to it, not specifically provided for (above) and "annualed" renders the engine experimental and interrupts the "continuous" papertrail provision. So if you do not posess an Inspection Authorization on your A&P, you must have the engine on your experimental torn down and inspected for adherence to the manufacturer's specifications and the TCDS if your ever wish to return it to the Normally certificated community. Jim, =20 Maybe I am misinterpreting your message but, I think you are overstepping =20 the purpose of an annual inspection on an aircraft or engine by saying that=20= if =20 an engine only has "condition" inspection by a repairman then the engine =20 "automatically" becomes experimental. That is like saying if my Cessna goes=20= over =20 its annual period it becomes experimental and can only be returned to its =20 normal standard airworthiness status by Cessna. That is not the case. It onl= y =20 needs an annual inspection by an IA to return it to an airworthy condition. =20 Likewise, my engine does not need an "annual" inspection by an IA to =20 maintain its "continuous" paper trail as you suggest. I see no requirement=20= for a=20 "continuous" paper trail. The regs do not say "aircraft and engines must ha= ve=20 an annual inspection every twelve months". They say "no person may operate =20= an=20 aircraft unless in the last twelve calendar months"... (big difference). BT= W,=20 I don't see any regulations separating engines into "normal and =20 experimental" categories like aircraft. If you know of any please advise. =20 =20 Engines are issued typed certificate data sheets and may be installed in =20 certificated aircraft if they meet the following. (This was taken from a Typ= e =20 Certificate Data Sheet for TSIO 520 engine) =20 "Engines of models described herein conforming with this data sheet (which=20 is a part of type certificate No. E7CE) and other approved data on file wit= h=20 the Federal Aviation Administration, meet the minimum standards for use in =20 certificated aircraft in accordance with pertinent aircraft data sheets and=20= =20 applicable portions of the Federal Aviation Regulations provided they are =20 installed, operated and maintained as prescribed by the approved manufacture= r's =20 manuals and other approved instructions."=20 =20 I have seen no language in the regulations that suggest what you say in tha= t=20 an engine becomes "experimental" if an IA does not do its annual or needs t= o=20 be torn down and inspected if it is not maintained in a continuous airworth= y=20 condition by an A&P. The engine can be returned to service by an IA simply=20 by doing a one time annual inspection confirming it conforms to its TCDS a= nd=20 approving it for return to service. The owner of an experimental aircraft i= s=20 required to keep records of all maintenance, preventative maintenance and=20 insepections per Part 91 (see below) just as an owner of a normal category=20 aircraft is required to keep records. If the IA thinks that the engine cont= ains=20 non approved parts then it is the IA's perogative not to sign it off for us= e in=20 a normal certificated category aircraft.=20 =20 If you have other information or regulations or Advisory Circulars to cite-= -=20 then please do so.=20 =20 Best Holiday Regards, =20 Jeff Edwards =20 =20 Section 91.417: Maintenance records. (a) Except for work performed in accordance with =C2=A7=C2=A7_91.411_=20 (http://www8.landings.com/cgi-bin/get_file?pass=3D12345&FAR/part_91/section_= 91.411.html) and=20 _91.413_=20 (http://www8.landings.com/cgi-bin/get_file?pass=3D12345&FAR/part_91/section_= 91.413.html) , each registered owner or operator shall keep the following=20 records for the periods specified in paragraph (b) of this section: =20 (1) Records of the maintenance, preventive maintenance, and alteration and =20 records of the 100-hour, annual, progressive, and other required or approved= =20 inspections, as appropriate, for each aircraft (including the airframe) and=20 each engine, propeller, rotor, and appliance of an aircraft. The records mu= st =20 include=E2=80=94 =20 (i) A description (or reference to data acceptable to the Administrator) of=20= =20 the work performed; and =20 (ii) The date of completion of the work performed; and =20 (iii) The signature, and certificate number of the person approving the =20 aircraft for return to service. =20 (2) Records containing the following information: =20 (i) The total time in service of the airframe, each engine, each propeller,=20= =20 and each rotor. =20 (ii) The current status of life-limited parts of each airframe, engine, =20 propeller, rotor, and appliance. =20 (iii) The time since last overhaul of all items installed on the aircraft =20 which are required to be overhauled on a specified time basis. =20 (iv) The current inspection status of the aircraft, including the time since= =20 the last inspection required by the inspection program under which the=20 aircraft and its appliances are maintained. =20 (v) The current status of applicable airworthiness directives (AD) including= ,=20 for each, the method of compliance, the AD number, and revision date. If th= e=20 AD involves recurring action, the time and date when the next action is=20 required. =20 (vi) Copies of the forms prescribed by =C2=A7_43.9_=20 (http://www8.landings.com/cgi-bin/get_file?pass=3D12345&FAR/part_43/section_= 43.9.html) (a) of this chapter=20 for each major alteration to the airframe and currently installed engines,=20 rotors, propellers, and appliances. =20 (b) The owner or operator shall retain the following records for the periods= =20 prescribed: =20 (1) The records specified in paragraph (a)(1) of this section shall be =20 retained until the work is repeated or superseded by other work or for 1 yea= r =20 after the work is performed. =20 (2) The records specified in paragraph (a)(2) of this section shall be =20 retained and transferred with the aircraft at the time the aircraft is sold.= =20 (3) A list of defects furnished to a registered owner or operator under=20 =C2=A7_43.11_=20 (http://www8.landings.com/cgi-bin/get_file?pass=3D12345&FAR/part_43/section_= 43.11.html) of this chapter shall be retained until the defects are repair= ed=20 and the aircraft is approved for return to service. =20 (c) The owner or operator shall make all maintenance records required to be=20= =20 kept by this section available for inspection by the Administrator or any =20 authorized representative of the National Transportation Safety Board (NTSB)= . In =20 addition, the owner or operator shall present Form 337 described in paragrap= h=20 (d) of this section for inspection upon request of any law enforcement=20 officer. =20 (d) When a fuel tank is installed within the passenger compartment or a =20 baggage compartment pursuant to part _43_=20 (http://www8.landings.com/cgi-bin/get_file?pass=3D12345&FAR/part_43/toc.html= ) of this chapter, a copy of FAA Form 337=20 shall be kept on board the modified aircraft by the owner or operator. -------------------------------1166837386 Content-Type: text/html; charset="UTF-8" Content-Transfer-Encoding: quoted-printable Content-Language: en
In a message dated 12/22/2006 6:26:08 PM Central Standard Time,=20 marv@lancaironline.net writes:
<= FONT=20 style=3D"BACKGROUND-COLOR: transparent" face=3DArial color=3D#000000 size= =3D2>All of=20 that needs to be seemless; hence, any deviation of an engine, or
 = =20 accessory to it, not specifically provided for (above) and=20 "annualed"
  renders the engine experimental and interrupts the=20 "continuous" papertrail
  provision.

  So if you do no= t=20 posess an Inspection Authorization on your A&P, you must
  hav= e=20 the engine on your experimental torn down and inspected for=20 adherence
  to the manufacturer's specifications and the TCDS if y= our=20 ever wish to
  return it to the Normally certificated=20 community.

Jim,
 
Maybe I am misinterpreting your message but, I think you are oversteppi= ng=20 the purpose of an annual inspection on an aircraft or engine by saying that=20= if=20 an engine only has "condition" inspection by a repairman then the engine=20 "automatically" becomes experimental. That is like saying if my Cessna goes=20= over=20 its annual period it becomes experimental and can only be returned to i= ts=20 normal standard airworthiness status by Cessna. That is not the case. It onl= y=20 needs an annual inspection by an IA to return it to an airworthy=20 condition.
 
Likewise, my engine does not need an "annual" inspection by an IA to=20 maintain its "continuous" paper trail as you suggest.  I see no require= ment=20 for a "continuous" paper trail. The regs do not say "aircraft and engines mu= st=20 have an annual inspection every twelve months". They say "no person may oper= ate=20 an aircraft unless in the last twelve calendar months"... (big difference).=20 BTW, I don't see any regulations separating engines into "normal and=20 experimental" categories like aircraft. If you know of any please=20 advise.  
 
Engines are issued typed certificate data sheets and may be installed i= n=20 certificated aircraft if they meet the following. (This was taken from a Typ= e=20 Certificate Data Sheet for  TSIO 520 engine)
 
"Engines of models described herein conforming with this data sheet= =20 (which is a part of type certificate No. E7CE) and other approved data on fi= le=20 with the Federal Aviation Administration, meet the minimum standards for use= in=20 certificated aircraft in accordance with pertinent aircraft data sheets and=20 applicable portions of the Federal Aviation Regulations provided they are=20 installed, operated and maintained as prescribed by the approved manufacture= r's=20 manuals and other approved instructions."
 
I have seen no language in the regulations that suggest what you s= ay=20 in that an engine becomes "experimental" if an IA does not do its annual or=20 needs to be torn down and inspected if it is not maintained in a continuous=20 airworthy condition by an A&P. The engine can be returned to service by=20= an=20 IA simply by doing a one time annual  inspection confirming it conforms= to=20 its TCDS and approving it for return to service. The owner of an experimenta= l=20 aircraft is required to keep records of all maintenance, preventative=20 maintenance and insepections per Part 91 (see below) just as an owner of a=20 normal category aircraft is required to keep records. If the IA th= inks=20 that the engine contains non approved parts then it is the IA's perogative n= ot=20 to sign it off for use in a normal certificated category aircraft.
 
If you have other information or regulations or Advisory Circulars to=20 cite-- then please do so.
 
Best Holiday Regards,
 
Jeff Edwards
 

Section 91.417: Maintenance records.

(a) Except for work performed in accordance with =C2=A7=C2=A791.411=20 and 91.413,=20 each registered owner or operator shall keep the following records for the=20 periods specified in paragraph (b) of this section:

(1) Records of the maintenance, preventive maintenance, and alteration an= d=20 records of the 100-hour, annual, progressive, and other required or approved= =20 inspections, as appropriate, for each aircraft (including the airframe) and=20= each=20 engine, propeller, rotor, and appliance of an aircraft. The records must=20 include=E2=80=94

(i) A description (or reference to data acceptable to the Administrator)=20= of=20 the work performed; and

(ii) The date of completion of the work performed; and

(iii) The signature, and certificate number of the person approving the=20 aircraft for return to service.

(2) Records containing the following information:

(i) The total time in service of the airframe, each engine, each propelle= r,=20 and each rotor.

(ii) The current status of life-limited parts of each airframe, engine,=20 propeller, rotor, and appliance.

(iii) The time since last overhaul of all items installed on the aircraft= =20 which are required to be overhauled on a specified time basis.

(iv) The current inspection status of the aircraft, including the time si= nce=20 the last inspection required by the inspection program under which the aircr= aft=20 and its appliances are maintained.

(v) The current status of applicable airworthiness directives (AD) includ= ing,=20 for each, the method of compliance, the AD number, and revision date. If the= AD=20 involves recurring action, the time and date when the next action is require= d.=20

(vi) Copies of the forms prescribed by =C2=A743.9(a)=20 of this chapter for each major alteration to the airframe and currently=20 installed engines, rotors, propellers, and appliances.

(b) The owner or operator shall retain the following records for the peri= ods=20 prescribed:

(1) The records specified in paragraph (a)(1) of this section shall be=20 retained until the work is repeated or superseded by other work or for 1 yea= r=20 after the work is performed.

(2) The records specified in paragraph (a)(2) of this section shall be=20 retained and transferred with the aircraft at the time the aircraft is sold.= =20

(3) A list of defects furnished to a registered owner or operator under=20= =C2=A743.11=20 of this chapter shall be retained until the defects are repaired and the=20 aircraft is approved for return to service.

(c) The owner or operator shall make all maintenance records required to=20= be=20 kept by this section available for inspection by the Administrator or any=20 authorized representative of the National Transportation Safety Board (NTSB)= . In=20 addition, the owner or operator shall present Form 337 described in paragrap= h=20 (d) of this section for inspection upon request of any law enforcement offic= er.=20

(d) When a fuel tank is installed within the passenger compartment or a=20 baggage compartment pursuant to part 43=20 of this chapter, a copy of FAA Form 337 shall be kept on board the modified=20 aircraft by the owner or operator.

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