REFLECTOR: Maintenance

Reiff Lorenz Reiff at Lorenz.com
Sat Apr 23 09:02:52 CDT 2011


Scott, 

You are correct. Form 337 is the wrong form to use for experimentals. I read the section incorrectly.

If your operating limitations state:

     "The FAA cognizant Flight Standards Office must be notified, and their response 
      received in writing, prior to flying this aircraft after incorporating a major change 
       as defined by FAR 21.93." 

Then you must notify the FAA after a major change, but it would not be done on a form 337.

Thanks for setting me straight!

Reiff



-----Original Message-----
From: reflector-bounces at tvbf.org [mailto:reflector-bounces at tvbf.org] On Behalf Of Scott Baker
Sent: Saturday, April 23, 2011 9:28 AM
To: Velocity Aircraft Owners and Builders list
Subject: Re: REFLECTOR: Maintenance

http://www.wanttaja.com/avlinks/MAINT.HTM
http://v2.ez.org/maintena.htm
http://exp-aircraft.com/library/alexande/rules.html

In response to John's question regarding FAA specific documentation that speaks to maintaining Experimental aircraft - the FAA has little to say on the subject.  Information regarding rules as applied to Experimental aircraft are often unclear and open to interpretation.  See links above for articles from several expert authors on the subject of performing maintenance on Experimental aircraft.

Contrary to Reiff's comment, it is my understanding that a FAA Form 337 does not apply to Experimental aircraft, and as such never needs to be submitted to the FAA.  I have heard stories from FSDO inspectors who "thought" that Experimental aircraft should be subject to reporting major repairs or alterations using a Form 337.  Tactful discussions with these inspectors brought to light that Form 337 simply does not apply to Experimental aircraft.

I was under the common conception that certified engines such as those manufactured by Lycoming, Continental, Franklin, etc, once installed in an Experimental airframe, are from that moment on considered 'Experimental' 
engines.  The following comes from noted author Ron Alexander ..."Normal maintenance on an experimental airplane can be performed virtually by anyone regardless of credentials.  Once again, this does not apply to the condition check previously discussed.  You can perform maintenance items on the engine whether or not it is "certified".  Once a certified engine is placed on an amateur-built aircraft and is operated, it no longer conforms to its type design.  This means that the engine can no longer be placed on any aircraft other than an amateur-built until it has been inspected and found to meet its type design. It also must be found to be in a condition for safe operation 'airworthy'".  Airworthiness Directives (AD's) that are issued to certified engines and accessories, under this line of thinking, would not apply to the same 'certified' engine when installed in an Experimental airframe (because the engine is also considered 'Experimental').

Earl Lawrence, EAA Government Programs Office, offers a difference of opinion that speaks to the whether a certified engine is considered 'certified' or 'experimental' when it is installed in an Experimental airframe.  The distinction is important as it relates to rules relating to engine maintenance.  Lawrence says that if the 'certified' dataplate is kept on the engine, it remains a 'certified' engine when installed in an Experimental airframe - and as such, is subject to Airworthiness Directives. 
The same logic applies to certified propellers and engine accessories.  His article does not get into the legalities as who is authorized to work on 'certified' engines in Experimental aircraft, or if a FAA Form 337 is required to make a major alterations, i.e. when installing an electronic ignition.  If someone on the Reflector has solid information about this, please share.  Consider the following article written by attorney Stephen Prentice on the subject, http://www.amtonline.com/print/Aircraft-Maintenance-Technology/Fuzzy-Regulations/1$5963. 
All that is needed to convert a 'certified' engine to an 'experimental' 
engine is the removal of the original engine dataplate.  Considering the conflicts in legal opinions (and the ramifications thereof), it seems to me that the best choice for an amateur-builder to make is to remove the engine manufacturer's dataplate so that the engine is without question considered 'experimental'.  You can always keep the dataplate and have it re-installed to bring it back to 'certified' life if you should want to sell the engine in the future.  Please allow me to say that regardless if an engine is considered 'certified' or 'experimental', it is a smart move to comply with all AD's.

Scott B.



----- Original Message -----
From: "Reiff Lorenz" <Reiff at lorenz.com>
To: "Velocity Aircraft Owners and Builders list" <reflector at tvbf.org>
Sent: Friday, April 22, 2011 9:45 PM
Subject: Re: REFLECTOR: Maintenance


>
> John,
>
> Anyone can do construction, maintenance, and repairs on an experimental 
> aircraft and sign the log books. No qualifications of any kind are 
> required. You can do it, your wife can do it, her friend can help,  the 
> neighbor's kid down the street can sign the logs. Anyone is allowed as far 
> as the FAA is concerned. You may need to notify the FAA using form 337 if 
> the repairs include a major change, but again, anyone can do the major 
> change, sign the logs, and notify the FAA.
>
> Some people may try to quote FAR Part 43.1 (b) but that entire section 
> specifically excludes experimental aircraft.
>
> A repairman's certificate or A&P rating is only required to do the annual 
> condition inspection on an experimental aircraft.
>
> Reiff Lorenz

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