REFLECTOR: Maintenance

Sat Apr 23 17:35:37 CDT 2011

As I mentioned radio and altimeter regs(outside part 43)  apply to all 
experimentals.  You shall have your encoder/transponder unit inspected 
bi-annually for vfr/ifr flight into class E or above.  For IFR flight 
you have to have your altimeter and static system plumbing inspected 
bi-annually.  Both of these require a special license that most A&P/IA 
do not have.

Your ELT is also regulated outside part 43.

If your plane is pressurized there are regs outside part 43 that must be 
complied with.

Personally I do log book entry's when I change something. I want a 
record of items that are life limited. If I make an entry,for minor work 
like an oil change, engine appliance change or an AD compliance, or a 
major change like, change the engine or prop I sign it with my Name and 
PPL #, and of course the date and tach info.

Scott

-------- Original Message --------
Subject: Re: REFLECTOR: Maintenance
From: <aminetech at bluefrog.com>
To: Velocity Aircraft Owners and Builders list <reflector at tvbf.org>
Date: 04/23/2011 09:32 AM

> Well, after reading again, according to 43.1 b 2, all of part 43 does not apply to experimental aircraft.  So it looks like there are no regs concerning maintenance, other than what is in the operating limitations.  Is that right?
>
> John
>
> --- aminetech at bluefrog.com wrote:
>
> From:<aminetech at bluefrog.com>
> To: "Velocity Aircraft Owners and Builders list"<reflector at tvbf.org>
> Subject: Re: REFLECTOR: Maintenance
> Date: Sat, 23 Apr 2011 07:52:39 -0700
>
> Thanks.  Actually, I did read your email.  And after further thought, I am withdrawing my question.
>
> John
>
> --- tomfalls6 at gmail.com wrote:
>
> From: "Tom Falls"<tomfalls6 at gmail.com>
> To: "'Velocity Aircraft Owners and Builders list'"<reflector at tvbf.org>
> Subject: Re: REFLECTOR: Maintenance
> Date: Sat, 23 Apr 2011 10:34:06 -0400
>
> For some reason my previous email did not get posted. Below is an excerpt
> from "Ask the DAR" in the July 2010 issue of Kit Planes. Bottom line . . .
> whether a logbook entry is required is in your operating limitations. Tom
>
> Question: I purchased a used Experimental/Amateur-Built aircraft, a RANS S-6
> that had been wrecked, and am rebuilding it. I understand that I must have
> an A&P sign off the repairs because I do not hold the Repairman's
> Certificate. What paperwork do I need to send to the FSDO when it is
> complete? Will I have to place the aircraft back in Phase I flight testing?
>
> Answer: Actually you are not required to have an A&P sign off your repairs.
> Anyone can perform maintenance, repairs and even modifications on an
> Experimental/Amateur-Built aircraft. The only  purpose of the Repairman
> Certificate is to allow performance of the condition inspection. That's not
> to say it wouldn't be prudent to have it inspected by a qualified
> individual, it's just not required. If you were to do modifications to the
> aircraft, you would need to follow your operating limitations. I don't know
> when your S-6's operating limitations were issued. The wording has changed
> somewhat over the years, but there should be a paragraph giving explicit
> instructions on how to handle modifications. If you only do repairs and
> return the aircraft to the original configuration, it will be a simple
> logbook entry. On the other hand, if the aircraft is out of "annual"
> (condition inspection), then it would have to be signed off by an A&P or the
> original builder-if that person holds the Repairman Certificate.
>
> -----Original Message-----
> From: reflector-bounces at tvbf.org [mailto:reflector-bounces at tvbf.org] On
> Behalf Of aminetech at bluefrog.com
> Sent: Saturday, April 23, 2011 10:20 AM
> To: Velocity Aircraft Owners and Builders list
> Subject: Re: REFLECTOR: Maintenance
>
> 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-Regulat
> ions/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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