Al Downs Posted August 2, 2012 Report Share Posted August 2, 2012 Do I need an approval from Flight Design to replace my landing light with the LED one mentioned on this forum? I also need to know what kind of oil temps should I be seeing. It is about 85 degrees today and on climb I was seeing 223-230. Should it be this high? I would go to the low side of the yellow. I only went to 3000 feet for some practice maneuvers. Link to comment Share on other sites More sharing options...
Roger Lee Posted August 2, 2012 Report Share Posted August 2, 2012 Hi Al, Each plane is a little different on temps, but your 220F- 235F temps for an 85F OAT is well within the norm. 230F is not high for the Rotax and up to 240F could still be normal depending on the circumstances. Technically you would have to get an LOA if you went by the letter of the law, but I don't think anyone has. I wouldn't see an issue with it personally. Chanik, (Kurt) has a good handle on this. Link to comment Share on other sites More sharing options...
chanik Posted August 2, 2012 Report Share Posted August 2, 2012 The FAA has said that basic things like tire and light bulb changes are OK by owner. They have never cited anyone for changing type of bulb so it is presumed to be fine Link to comment Share on other sites More sharing options...
Roger Lee Posted August 2, 2012 Report Share Posted August 2, 2012 Here's just a tidbit that many people don't know and many don't follow. (Right from the FAA's lips) If a Mfg. assigns a product number to a part then technically it must be purchased through the MFG even if you can but the identical part next door. Once a part number is assigned your locked in. That said it would be tough for a MFG or the FAA to prove it wasn't purchased from an MFG unless it had a recorded serial number. Your not required to keep receipts. Link to comment Share on other sites More sharing options...
Doug G. Posted August 3, 2012 Report Share Posted August 3, 2012 FAR citation on that Roger? Link to comment Share on other sites More sharing options...
Roger Lee Posted August 3, 2012 Report Share Posted August 3, 2012 Just a chat with the head of LSA in Oklahoma. He's a friend of mine and my go to guy when I need an answer that isn't readily known in the field. I get tips as to what new things are coming, things like that. It's what the GA guys has has to abide by and we do to, but probably many don't. I never had an issue with it so long as it was the same part. Sometimes the aircraft MFG. gets the part and puts it through some special testing and certifies it. Link to comment Share on other sites More sharing options...
chanik Posted August 3, 2012 Report Share Posted August 3, 2012 Not exactly. If a MFG calls out a certain part manufactured to a Technical Standard Order then you (mostly) must use that particular part number. However it could be manufactured by different vendors and there is no requirement to purchase direct from the MFG even if only they make said part so long as the paperwork is in order that tracks the part back to a legit, Production Certificated OEM. Any special testing required would have to be folded into the TSO part approval process which involves review of the test plan before awarding a production certificate (PC) for that particular TSO'd part. Even then, there is a process to substitute similar TSO'd parts after careful review. http://rgl.faa.gov/Regulatory_and_Guidance_Library/rgAdvisoryCircular.nsf/1ab39b4ed563b08985256a35006d56af/ceba7446f88ecfa1862569c3004ba827/$FILE/ATTZVBXH/ac20-41a.pdf It is all tangential however since all of this pertains just to GA. In the simple, unfettered world of S-LSA you are merely required to follow specific part guidance from the manufacturer insofar as they provide it in their maintenance manual or service directives. Link to comment Share on other sites More sharing options...
Roger Lee Posted August 3, 2012 Report Share Posted August 3, 2012 Hi Kurt, Your talking about same part numbers from two different suppliers that are the same. If the aircraft Mfg assigns its own part number different from another MFG then that part has to come from the aircraft Mfg. Link to comment Share on other sites More sharing options...
Tom Baker Posted August 3, 2012 Report Share Posted August 3, 2012 So that means that since Flight Design and Rotax have part numbers for all the parts needed for the rubber replacement that they are the only place to get them from? Link to comment Share on other sites More sharing options...
chanik Posted August 3, 2012 Report Share Posted August 3, 2012 So something like a CTSW elevator assembly is unlikely to be made by anyone else, of course. But if I find a surplus one on ebay, I can buy it and use it. The difference to GA and their TSO'd parts is that the ebay part needs to have supporting documentation before I can bolt it onto my Cessna. Link to comment Share on other sites More sharing options...
sandpiper Posted August 3, 2012 Report Share Posted August 3, 2012 Maybe some good reasons to go E-LSA?? Link to comment Share on other sites More sharing options...
Jim Meade Posted August 3, 2012 Report Share Posted August 3, 2012 Just a chat with the head of LSA in Oklahoma. He's a friend of mine and my go to guy when I need an answer that isn't readily known in the field. I get tips as to what new things are coming, things like that. It's what the GA guys has has to abide by and we do to, but probably many don't. I never had an issue with it so long as it was the same part. Sometimes the aircraft MFG. gets the part and puts it through some special testing and certifies it. Edsel Ford? Link to comment Share on other sites More sharing options...
Roger Lee Posted August 3, 2012 Report Share Posted August 3, 2012 Hi Tom, Two things here. One is the Mfg can't force you to use just any part from them. There are rules. An example is that Rotax says you have to change the entire fuel pump assembly (pump and hose) with their replacement. Not true. They can't mandate that so the hose alone can be changed. Not even FD can mandate that. It doesn't fall within the FAA parameters and rules. Second: FD does not have all the parts to there aircraft in the books with part numbers. Some don't have part numbers. Some parts FD gets from FD Germany and some local and they may be the same. Technically Rotax can't mandate anything because they aren't the aircraft Mfg and the aircraft Mfg can only mandate so much. They can't add or subtract from what the FAA already has in writing in place without an FAA rule change. It's just most people don't know where the rules start and stop and who has the final say from what's written in a maint. manual. I'm like everyone else. I agree with some rules and not others, but until they get changed it's what we have to work with. Link to comment Share on other sites More sharing options...
LS Bruce Posted August 4, 2012 Report Share Posted August 4, 2012 That's ironic, the only rubber part to fail (twice!) on my CTLS, was the fuel pump(s) rubber diaphragm! Link to comment Share on other sites More sharing options...
Roger Lee Posted August 4, 2012 Report Share Posted August 4, 2012 They just had a coolant hose fail and flew another 15-20 minutes in NM. I'll know more about this failure shortly. Link to comment Share on other sites More sharing options...
chanik Posted August 4, 2012 Report Share Posted August 4, 2012 Maybe some good reasons to go E-LSA?? As an ELSA convert, which gets me out from the tyranny of the AOI, I would say that still I rarely and very cautiously deviate from any manufacturer suggestions. OEMs have to practice CYA (to protect themselves from the average suer) so they are often slow and/or reluctant to approve things like the ducati fix and overzealous about marginal things like fluffing up the parachute. But I've been an engineer a long time so have run lots of experiments in my lifetime. Most don't work out quite as expected. Link to comment Share on other sites More sharing options...
Doug G. Posted August 4, 2012 Report Share Posted August 4, 2012 the Mfg can't force you to use just any part from them. There are rules. An example is that Rotax says you have to change the entire fuel pump assembly (pump and hose) with their replacement. Not true. They can't mandate that so the hose alone can be changed. Not even FD can mandate that. I don't understand this Roger. ? Link to comment Share on other sites More sharing options...
Roger Lee Posted August 4, 2012 Report Share Posted August 4, 2012 It means many of the rules we thought we had to abide by and laid out by SLSA Mfg's. aren't binding. They are only recommendations even though they look to be mandatory because they go against the FAA rules. An SLSA Mfg must stay within the FAA rules and can't over or under regulate their product. The problem has come that we as owners haven't known what we had to abide by and what we don't have to abide by because of confusing info from the aircraft Mfg's, supporting Mfg's (i..e Rotax and others) the FAA and other people in the field. It is a confusing road at times, but little by little it's getting sorted out. Link to comment Share on other sites More sharing options...
Doug Hereford Posted August 4, 2012 Report Share Posted August 4, 2012 To all: Pilots wishing to perform preventive maintenance functions on their aircraft would be well to review FAR part 43, and specifically Appendix A which lists all of the items that are legally considered preventive maintenance. Replacing bulbs in navigational and landing lamps is a preventive maintenance function as defined in FAR 43 app. A ©(17). Therefore an owner/operator with a sport-pilot certificate can perform this function. Ref FAR sect. 43.3. Technically speaking, other bulb (say dome lamp, or annunciator lamps)changes do not fall within preventive maintenance, and cannot legally be changed by a sport pilot (SLSA aircraft). Regardless of who changes the lamp, an appropriate maintenance record entry must be made, and the aircraft approved for return to service as required by FAR sect. 43.5. As for having to buy certain P/N's only from the MFG........................... Please give specific regulatory citiation Roger as was already asked for. There are plenty of used aircraft parts sources out there. There parts can be appropriately and legally used. As someone eluded to earlier, part traceability is very important. The person approving an aircraft for return to service after replacing a part (say a stabilator) is legally responsible for that maintenance. If he/she can't show traceability to approved/accepted source, they could be in violation of FAR 43.13(. Furthermore, the aircraft may no longer meet its certification basis (ASTM consensus standard in the case of SLSA) which is a condition of its airworthiness. Aldowns, As for the LED lamp alteration on an SLSA..................... Get a LOA! Doug Hereford Link to comment Share on other sites More sharing options...
Roger Lee Posted August 4, 2012 Report Share Posted August 4, 2012 Hi Doug, I can't as it was a direct conversation with the FAA. The FAA stated that once a part is given a specific part number from that Aircraft MFG then it could potentially have additional testing and because of that it needs to come from them. If the aircraft MFG has no part number assigned by them and it is available from somewhere else then it can be purchased from the alternative source. The FAA also told me that a purchase receipt is not required and that a logbook entry is sufficient and meets the law. The items like stabs (specific parts) aren't good examples because it is specific to FD and it has a MFG part number and was originally tested by the aircraft MFG for the aircraft certification. Why not use the Odyssey PC310 battery as an example. Link to comment Share on other sites More sharing options...
Tom Baker Posted August 4, 2012 Report Share Posted August 4, 2012 Hi Doug, I can't as it was a direct conversation with the FAA. The FAA stated that once a part is given a specific part number from that Aircraft MFG then it could potentially have additional testing and because of that it needs to come from them. If the aircraft MFG has no part number assigned by them and it is available from somewhere else then it can be purchased from the alternative source. The FAA also told me that a purchase receipt is not required and that a logbook entry is sufficient and meets the law. The items like stabs (specific parts) aren't good examples because it is specific to FD and it has a MFG part number and was originally tested by the aircraft MFG for the aircraft certification. Why not use the Odyssey PC310 battery as an example. A better example would be nav lights. Link to comment Share on other sites More sharing options...
Roger Lee Posted August 4, 2012 Report Share Posted August 4, 2012 Here is the page out of the CTSW parts manual. It has an assigned FD part number. According from what the FAA told me, you need to get these from FD or get a letter saying it was okay to buy direct. That said I know several who have purchased direct and there is no way to know the difference since a receipt is not mandatory. If you put on other types of lights (different equipment) then an LOA is technically needed. I have seen enough CT's and different mods to know all didn't have an LOA. It's up to the owner. CTSW Lights.pdf Link to comment Share on other sites More sharing options...
Doug Hereford Posted August 4, 2012 Report Share Posted August 4, 2012 Roger , I think what the FAA may have intended to say is that you must not alter the aircraft by installing parts not approved by the MFG. If a person is able to procure the correct P/N's as called for in the IPC from a source other than FD. That would be perfectly legal. Example would be: I have a stock of FD P/N landing lamps, and sell one to my customer. Or a salvaged servicable part is procured from a third party source and installed. The burden still falls on the person approving for return to service to insure that the aircraft is in conformity with ASTM consensus standards, not altered without MFG authorization, and in a condition for safe operation. Doug Hereford Link to comment Share on other sites More sharing options...
chanik Posted August 5, 2012 Report Share Posted August 5, 2012 Basically correct. The wiggle room comes with the mechanic's interpretation of equivalent parts. So if FD specifies a certain fuel hose form Gates, you can buy that fuel hose wherever you like or you can use a hose manufactured to the same ATSM standard (there are non-FAA CFRs too that govern fuel hoses). If you want to use a similar hose that has 'Barricade' liner, you would be safer to get an LOA but the FAA is likely to leave you alone on that one if they are both USCG type A hoses or whatever FD specifies. In the GA world, your room for interpretation is far more limited since the item has to be made and documented exactly to the TSO spec and by an OEM with a production certificate or PMA. Bulbs are far less critical and have no CFRs associated so while an LOA would be nice, the FAA has never cited anyone for changing bulb type. On the practical side LOAs are a PITA since FD bascially has to research the issue, do some testing, absorb the liability however small and for all that makes about $0 in revenue. Plus next month there will be a different, better LED bulb out there. Link to comment Share on other sites More sharing options...
Doug Hereford Posted August 6, 2012 Report Share Posted August 6, 2012 Chanik, I recommended a LOA for the LED landing lamp for two reasons. First is because I do know of ASI's who seem to be on point with regard to LED lamps. If one of those types of inspectors was familiar with the CT, and saw one taxi in with an LED lamp, I can invision a possibility for a discussion with the pilot. Doubtful that it would go anywhere, but landing lamps may as well have a bulls-eye on them when you are on the ramp. An LED dome lamp alteration for example would be much more benign. Second is that while you may have an in depth knowledge of the engineering side of lighting technology, many do not. You know as well as I do that lamps are not as simple as they appear. Electrical load (not much of a consideration with LED) vibration resistance, light intensity and color, mounting, and connection provisions can all be factors when altering a light system. In general, I think it would be a poor practice for an SLSA owner to under estimate lighting systems, and freelance alterations to them. Plus, like it or not, if you are SLSA and want to perform any alteration, LOA is the system you have. Many people seem more than willing to argue for manufacturer control when it suits their personal purposes. I am only arguing for it when it is legally required. As for parts equivalency, I have to agree with what I think the FAA guy who talked to Roger was trying to say. If a MFG specifies their P/N, and does not give reference to a standard P/N also, then it should not be assumed that the parts are equivalent. I do agree with your hose example. Most all incandescent bulbs used in GA actually fall under the heading of "standard" parts, as they are manufacturered to a recognized industry spec. (AN, MS, NAS, etc..........) They usually won't have a TSO or PMA cert associated with them unless they are a part of an assembly. Most of the LED assys. that I have delt with carry a aircraft MFG P/N due to the fact that they are an assy. designed for some specific application, and not used elsewhere. I am aware of some PAR 36 LED lamps out there that do have FAA approval which is of course not necessarily required for SLSA. Everyone is (or should be aware) that TSO's and /or PMA parts can/do exist on SLSA, and as such, they are subject to the regulatory requirements associated with these FAA approvals. Owners flying around with GTX-330 transponders for example, should be aware that there is an Airworthiness Directive against these units. Your maintenance provider should be researching this at each Condition inspection. Technically speaking, FD should have issued a Safety Directive to transmit the AD to the field (whole other topic). Doug Hereford Link to comment Share on other sites More sharing options...
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