REFLECTOR: AMATEUR-BUILT MAINTENANCE

[steve korney]

Here is some more info that Mack asked my to forward to you all...

Mack... I had my secretary re-type your letter because the fax was so small 
my scanner had a hard time with it...

Thanks Mack for the GOOD info...



Subject:  		Operating limitations
Date:  		3/10/06 9:08
From:  		jnorris at eaa.org
To:			mmurp16900 at aol.com

Hi Mack:

As per our conversation on the phone today regarding operating limitations, 
I offer the following comments.

It is important for owners and operators of experimental aircraft to know 
that the operating limitations that are issued to the aircraft are specific 
to that aircraft. Operating limitations issued on a given date were issued 
in accordance with guidance that was current at that time.  This guidance 
has changed over the years, so operating limitations issued on different 
dates may very well contain different limitations.  What is important for 
the owner/operator to understand is that they must follow whatever is called 
out in the operating limitations issued to their aircraft, even if the 
limitations differ from what the current policy call out.  (Grandfathered 
in)

An example of this is the requirements for incorporating a major change.  
The policy on this issue has varied greatly over the years, so there are 
many different versions of the procedure for incorporating a major change on 
an experimental aircraft.  As a basis for comparison, allow me to quote the 
current version of the guidance, as found in FAA Order 8130.2F.  Change 1, 
dated 4-1-05.

"(19) After incorporating a major change as described in 21.93, the aircraft 
owner is required to re-establish compliance with 91.319(b) and notify the 
geographically responsible FSDO of the location of the proposed test area.  
The aircraft owner must obtain concurrence from the FSDO as to the 
suitability of the proposed test area.  If the major change includes 
installing a different type of engine, (reciprocating to turbine) or a 
change of a fixed-pitch from or to a controllable propeller, the aircraft 
owner must fill out a revised Form 8130-6 to update the aircraft's file in 
the FAA Aircraft Registry.  All operations must be conducted under day VFR 
conditions in a sparsely populated area.  The aircraft must remain in flight 
test for a minimum of 5 hours.  The FSDO may require additional time (more 
than 5 hours) depending on the extent of the modification. Persons 
non-essential to the flight must not be carried.  The aircraft owner must 
make a detailed logbook entry describing the change before the test flight.  
Following satisfactory completion of the required number of flight hours, in 
the flight test area, the pilot must certify in the records that the 
aircraft has been shown to comply with 91.319(b).  Compliance with 91.319(b) 
must be recorded in he aircraft records with the following, or a similarly 
worded, statement: "I certify that the prescribed flight test hours have 
been completed and the aircraft is controllable throughout its normal range 
of speeds and throughout all maneuvers to be executed, has no hazardous 
characteristics or design features, and is safe for operation. The following 
aircraft operating data has been demonstrated during the flight testing:  
Speed VSO , VX, and VY, and the weight, and CG location  at which they were 
obtained.

As mentioned above, there have been many variations of this procedure over 
the years.  Early operating limitations contained the following language.

"A major change invalidates this airworthiness certificate."

Over the years, the policy on major changes has evolved from this short 
statement, though various versions of contacting the FAA, to a point where 
for a few years, owners/operators were allowed to incorporate a major change 
without contacting the FAA at all.  That version allowed the major change to 
be incorporated with only logbook entries made by the owner/operator and a 5 
hour flight-test period.  As you can see from the current version posted 
above, this policy has re-introduced contact with the cognizant FSDO, but 
only for approval of the proposed flight-test area.

The bottom line here though , is that the owner/operator must follow the 
procedure called out in the operating limitations that were issued to 
his/her individual aircraft, regardless of what the current version of the 
guidance calls out.  If the aircraft's operating limitations say that a 
major change invalidates the airworthiness certificate, then that is the way 
it is for that aircraft, even though a different aircraft of the same design 
might have operating limitations that say something different.  The 
owner/operator MUST follow the limitations issued to the individual aircraft 
in question. (Grandfathered in)

If an owner wishes to have the aircraft's operating limitations changed or 
modified in any way, they may do so by contacting the cognizant FSDO or MIDO 
office.  They will make application for a new airworthiness certificate and 
will be issued operating limitations that are in line with the current 
guidance.

Hope this helps!  As always, let me know if you have further questions.

Joe Norris
EAA AVIATION SERVICES
EAS AVIATION CENTER, OSHKOSH, WI
888-322-4636, extension 6806
jnorris at eaa.org


Best... Steve



----Original Message Follows----
From: MMurp16900 at aol.com
Reply-To: Velocity Aircraft Owners and Builders list <reflector at tvbf.org>
To: reflector at tvbf.org
Subject: Re: REFLECTOR: AMATEUR-BUILT MAINTENANCE
Date: Sat, 11 Mar 2006 20:14:43 EST

Hi Steve
subject fax
  My Fax  is down so I had a neighbor FAX you some  interesting info. from 
EAA
Will you post on reflector ?
Thanks
Mack


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