REFLECTOR: Maintenance

[aminetech at bluefrog.com]

Thanks, all.  This is very helpful.  The EAA told me in writing that the engine is non-certified whether the data plate is there or not.  If an authority questions my maintenance, it seems like I need to take the position of respectfully asking him to show me the reg that says I can't do the maintenance.  Now for my final question.. Do I have to sign my entries?  The builder did not.  He only signed the annuals.  For that matter do I have to make entries at all?  Of course I think it's a good idea.

John

--- scottb33333 at gmail.com wrote:

From: "Scott Baker" <scottb33333 at gmail.com>
To: "Velocity Aircraft Owners and Builders list" <reflector at tvbf.org>
Subject: Re: REFLECTOR: Maintenance
Date: Sat, 23 Apr 2011 09:27:55 -0400

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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