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 23:24:02 -0500 Message-ID: X-Original-Return-Path: Received: from imo-d23.mx.aol.com ([205.188.139.137] verified) by logan.com (CommuniGate Pro SMTP 5.1.3) with ESMTP id 1703213 for lml@lancaironline.net; Fri, 22 Dec 2006 23:03:51 -0500 Received-SPF: pass receiver=logan.com; client-ip=205.188.139.137; envelope-from=Sky2high@aol.com Received: from Sky2high@aol.com by imo-d23.mx.aol.com (mail_out_v38_r7.6.) id q.ce1.68edff4 (41812) for ; Fri, 22 Dec 2006 23:03:00 -0500 (EST) From: Sky2high@aol.com X-Original-Message-ID: X-Original-Date: Fri, 22 Dec 2006 23:02:58 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="-----------------------------1166846578" X-Mailer: 9.0 Security Edition for Windows sub 5358 X-Spam-Flag: NO -------------------------------1166846578 Content-Type: text/plain; charset="UTF-8" Content-Transfer-Encoding: quoted-printable Content-Language: en In a message dated 12/22/2006 8:23:40 P.M. Central Standard Time, =20 VTAILJEFF@aol.com writes: 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 on= ly=20 needs an annual inspection by an IA to return it to an airworthy condition. Jeff, =20 Jim is not saying that at all. The only use of the repairman certificate=20 that was obtained for the builder of a specific airplane is to conduct an=20 annual "condition" inspection, and then only using Appendix D of Part 43 as= a=20 minimal guideline. There are no requirements to check ADs because none eve= r=20 apply to an amateur built experimental aircraft since there is no aircraft=20= type=20 data sheet - it is a one-off aircraft. There are no 337's either since the= re=20 is no type data sheet that it could reference. =20 Lacking an annual condition inspection for the experimental aircraft (may b= e=20 performed by the named repairman) is the same as lacking an annual =20 inspection (must be performed by an A&P and signed off by an AI) on a STC'd=20= aircraft=20 and merely results in the aircraft being considered not airworthy (a=20 legal/insurance term).=20 =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= 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 manufactur= er's=20 manuals and other approved instructions."=20 Exactly! Read the paragraph in italics again. That type certificated=20 engine isn't going into an aircraft that has "pertinent aircraft data sheet= s" nor=20 is the engine "installed, operated and maintained as prescribed by the=20 approved manufacturer's manuals....." Hmmmmmm, which manufacturer - the en= gine or=20 the aircraft? Most engine operation manuals prepared by the engine=20 manufacturer defer to the operating instructions in the aircraft manufactur= er's=20 approved POH. =20 Merry Christmas=20 =20 I look forward to another confusing year, =20 =20 Scott Krueger AKA Grayhawk Lancair N92EX IO320 SB 89/96 Aurora, IL (KARR) A man has got to know his limitations unless he is completely befuddled. =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= =20 each engine, propeller, rotor, and appliance of an aircraft. The records mus= t =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 sinc= e=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) =20 including, for each, the method of compliance, the AD number, and revision =20= date. If=20 the 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 period= s=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 =20 paragraph (d) of this section for inspection upon request of any law enforc= ement=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 =20 =20 -------------------------------1166846578 Content-Type: text/html; charset="UTF-8" Content-Transfer-Encoding: quoted-printable Content-Language: en
In a message dated 12/22/2006 8:23:40 P.M. Central Standard Time,=20 VTAILJEFF@aol.com writes:
<= FONT=20 style=3D"BACKGROUND-COLOR: transparent" face=3DArial color=3D#000000 size= =3D2>
Maybe I am misinterpreting your message but, I think you are overstep= ping=20 the purpose of an annual inspection on an aircraft or engine by saying tha= t 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 goe= s=20 over its annual period it becomes experimental and can only be returned=20 to its normal standard airworthiness status by Cessna. That is not th= e=20 case. It only needs an annual inspection by an IA to return it to an airwo= rthy=20 condition.
Jeff,
 
Jim is not saying that at all.  The only use of the repairman=20 certificate that was obtained for the builder of a specific airplane is= to=20 conduct an annual "condition" inspection, and then only using Appendix=20= D of=20 Part 43 as a minimal guideline.  There are no requirements to check ADs= =20 because none ever apply to an amateur built experimental aircraft since= =20 there is no aircraft type data sheet - it is a one-off aircraft.  There= are=20 no 337's either since there is no type data sheet that it could reference.
 
Lacking an annual condition inspection for the experimental aircra= ft=20 (may be performed by the named repairman) is the same as lacking an ann= ual=20 inspection (must be performed by an A&P and signed off by an AI) on a ST= C'd=20 aircraft and merely results in the aircraft being considered not airwor= thy=20 (a legal/insurance term). 
<= FONT=20 style=3D"BACKGROUND-COLOR: transparent" face=3DArial color=3D#000000 size= =3D2>
 
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=20 requirement for a "continuous" paper trail. The regs do not say "aircraft=20= and=20 engines must have an annual inspection every twelve months". They say "no=20 person may operate an aircraft unless in the last twelve calendar months".= ..=20 (big difference). BTW, I don't see any regulations separating engines= =20 into "normal and experimental" categories like aircraft. If you know of an= y=20 please advise.
?
  
 
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 T= ype=20 Certificate Data Sheet for  TSIO 520 engine)
 
"Engines of models described herein conforming with this data she= et=20 (which is a part of type certificate No. E7CE) and other approved data on=20= file=20 with the Federal Aviation Administration, meet the minimum standards for u= se=20 in 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=20 manufacturer's manuals and other approved instructions."=20
Exactly!  Read the paragraph in italics again.  That type=20 certificated engine isn't going into an aircraft that has "pertine= nt=20 aircraft data sheets" nor is the engine "installed, operated and maintained=20= as=20 prescribed by the approved manufacturer's manuals....."  Hmmmmmm= ,=20 which manufacturer - the engine or the aircraft?  Most engine operation= =20 manuals prepared by the engine manufacturer defer to the operating instructi= ons=20 in the aircraft manufacturer's approved POH.
 
Merry Christmas
 
I look forward to another confusing year,
 
Scott Krueger=20 AKA Grayhawk
Lancair N92EX IO320 SB 89/96
Aurora, IL (KARR)

A m= an=20 has got to know his limitations unless he is completely=20 befuddled.
 
<= FONT=20 style=3D"BACKGROUND-COLOR: transparent" face=3DArial color=3D#000000 size= =3D2>
 
I have seen no language in the regulations that suggest what you= say=20 in that an engine becomes "experimental" if an IA does not do its annual o= r=20 needs to be torn down and inspected if it is not maintained in a continuou= s=20 airworthy condition by an A&P. The engine can be returned to service b= y an=20 IA simply by doing a one time annual  inspection confirming it confor= ms=20 to its TCDS and approving it for return to service. The owner of an=20 experimental aircraft is required to keep records of all maintenance,=20 preventative maintenance and insepections per Part 91 (see below) just as=20= an=20 owner of a normal category aircraft is required to keep records. If t= he=20 IA thinks that the engine contains non approved parts then it is the=20= IA's=20 perogative not to sign it off for use in a normal certificated category=20 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=20= and=20 records of the 100-hour, annual, progressive, and other required or approv= ed=20 inspections, as appropriate, for each aircraft (including the airframe) an= d=20 each engine, propeller, rotor, and appliance of an aircraft. The records m= ust=20 include=E2=80=94

(i) A description (or reference to data acceptable to the Administrator= ) 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 propel= ler,=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 aircra= ft=20 which are required to be overhauled on a specified time basis.

(iv) The current inspection status of the aircraft, including the time=20 since the last inspection required by the inspection program under which t= he=20 aircraft and its appliances are maintained.

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

(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=20 periods 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 y= ear=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 sol= d.=20

(3) A list of defects furnished to a registered owner or operator under= =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 t= o be=20 kept by this section available for inspection by the Administrator or any=20 authorized representative of the National Transportation Safety Board (NTS= B).=20 In addition, the owner or operator shall present Form 337 described in=20 paragraph (d) of this section for inspection upon request of any law=20 enforcement officer.

(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 modifie= d=20 aircraft by the owner or operator

 
 
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