has a Warp drive had CTsw US approval? or European approval.

[johnr]

I am arranging a trip from Perth W Australia to the easten states & around the top end of Aus . Probably a 5000 mile trip. Most of the country aitstrips are gravel/ dirt.

I know the 2 blade Neuform is not up to the task. I have a Warp drive 3 blade with square tips & nickle leading edges that has already made the trip on my Jodel D11 powered by the Rotax 914.

I have been unable to find an approval for the Warp drive in Australia. I have been told that if there was an approval in the US or else where the authorities would accept that.

I have looked on this site & elswhere but have been unable to find it.

My question: has there ever been an approval granted for a 3 blade Warp drive for the CTsw? & if so where could I download a copy.

John

[johnr]

Hi Roger, How is the weather over there at this time of the year?.Thanks for the info . If Flight Design approved the Warp Drive in 2006 then that is the approval I am looking for.

If it has been approved & there is no instruction to remove the prop then all I need is a copy of that original approval. I will show that to the Australian authorities & they can make the descision.

The logical reasoning is that if there are still CTs flying with the Warp drive & they have not been grounded with the removal of a previous approval then it must still be approved.

To return to the bush strips in Australia, some have a lot of pea gravel which is extremly hard stone, it would not lose in the contact with any composite material. My experience from the previous trip

where I had no damage to the warp drive with stone chips & even though one of the strips had not been mowed & had tufts of long grass there was no visable damage to the blades.

It is most frustrating when legislation that is supposed to be there for safety is preventing you from keeping safe.

Another example, I have friends who would like to fit a fuel flow gauge on a Ctsw which has analogue instruments, they wanted to use the MGL unit but it has no approval, calls to Flight Design

indicate that the cost for approval may be as high as $2000. This will prevent the fitting of an item that would enhance safety.

John

[N89WD]

Hi John,

 

Back in 2005 through 2007 the Warp 66" 3 blade was approved. I and several others had them. They will no longer approve the Warp. They think it a step backwards. I know, where do they get this stuff. The right tool for the right job in your case. I would not however use a Warp with a nickel edge. The inertia is too heavy. Rotax wants a 68" Warp or less and no nickle edges. I now have a Sensenich 68" 3 blade and I still have my Warp which I guess I should put up for sale. If you do use a warp for your trip take some super glue, baking soda and sandpaper. If you do get a nick you can fill it with the supper glue and backing soda , then sand it to conform.

 

Rog, I have the nickle warp, no problems. How are you liking your Sensenich 68" 3 blade & why?

[Jim]

Do you need an LOA to install something that was a factory option at the time your aircraft was built? I'm not clear on that. Seems to me that as long as the installation is done in accordance with the maintenance manual and is signed off by the proper authority, it would not be a modification. Has FD actually rescinded approval of the Warp Drive or are they just not supporting it any more?

[Ed Cesnalis]

Roger,

 

What problems have 912s encountered that FD blames on the Warp Drive?

[Jim]

Roger, I think you're wrong. Here's the definition of major repair, alteration, or maintenance straight of of ASTM F2483.9919-1

 

3.1.10 major repair, alteration, or maintenance—any repair,

alteration, or maintenance for which instructions to

complete the task excluded from the maintenance manual(s)

supplied to the consumer are considered major.

[chanik]

Do you need an LOA to install something that was a factory option at the time your aircraft was built? I'm not clear on that. Seems to me that as long as the installation is done in accordance with the maintenance manual and is signed off by the proper authority, it would not be a modification. Has FD actually rescinded approval of the Warp Drive or are they just not supporting it any more?

A propeller change is a major alteration IF the prop is not described in the AOI or maintenance manual that came with your plane (14 CFR 43 appendix A). I see even in my 2006 maintenence manual, the WARP is referred to. I have a pdf of the CTSW maintenence manual from 2008 and the warp is not mentioned. You only need an LOA for a major so legally it all comes down to whether or not the Warp is referenced in your manuals. FD has not issued a service directive to remove warps so no problem there. 14 CFR 91.327 b 5,6,7 governs alterations and such, but the description of manufacturer issued LOAs is in the ASTM standard F2483 (not online).

[Jim]

Roger, the ASTM standard I quoted is crystal clear. And if FD thinks the Warp Drive prop is unsafe they can easily issue a safety bulletin. And if they think it's a bad fit they can issue a service bulletin. I don't see either.

[Jim]

I'm done here.

[N89WD]

Rog, how's the new prop & why? How much installed?

[paul m]

Not suggesting this is in any way authoritative, but as I was googling for information to understand what you guys are talking about, I came across an article (p 27-31) in this online publication. In the last paragraph, she states that "[major repairs].....includes installation of new avionics or any propeller change." http://viewer.zmags.com/publication/6d3a4a62#/6d3a4a62/29

[paul m]

The part I don't understand Roger, and can sympathize with, is if a part was originally offered against other choices, if I later decide i wanted the other choice, why shouldn't that be fine? For example, If I could have taken delivery of a plane with one of three prop choices (or autopilots, etc...) then clearly all three choices have been tested and ASTM "certified". Don't see why new testing (or an LOA) is needed in that case. I would understand however a requirement that requires a mechanic of certain experience or training to do the work, but not whether I can do the work at all.

 

Paul

[Jim]

Then just show us the FAR or ASTM standard that confirms your statement.

[chanik]

It seems difficult to discuss any of these regulatory issues without the discussion becoming heated. It is the main reason that I have a policy of always “quoting scripture”, meaning the specific regs, when I respond to any of these threads because

1) Going direct to the source is the only way to be sure I’m being accurate, not just repeating hearsay

2) The FARs are the only thing you can be legitimately violated for

3) Forewarned is forearmed. IOTW, knowing the rules well is the best defense to ward off a hypothetical illegitimate violation

 

I do not doubt that Roger had the experience he describes and that a DAR said he needed an LOA. I also know that my FAA examiner had to have me explain the regulations to him about how to convert S-LSA to E-LSA. And that the ROTAX A&P fiasco started with the FAA violating a mechanic for not having ROTAX training, a position they then reversed 180deg since that amounts to letting an OEM modify 14CFR 43.3 about qualifications. http://www.midwestflyer.com/?p=4654

So it is easy to get conflicting opinions, but you should realize that before the FAA can violate you, they HAVE TO figure out a specific section in 14 CFR and state exactly how you broke it. That is the fundamental basis of administrative law which covers all federal regulations. So for instance, any explicit failure to follow the FD AOI is a violation of 14cfr 91.327 d. Ignoring a safety directive violates 91.327 b4. Everything else FD has to say can be ignored with (legal) impunity. Major repair and alteration is well defined in part 43. Now I’ll quote from 91.327 “(5) Each alteration accomplished after the aircraft's date of manufacture meets the applicable and current consensus standard and has been authorized…” Well, the warp has been authorized as is easily proven if it is in your official manuals.

 

So someone from the FAA could stroll up and tell you how much trouble you are in for the new Warp and failing to repack your parachute or whatever but in my experience nothing disarms a bureaucrat or other authority figure like being able to calmly and nicely recite the relevant regulations better than they can, and clearly show they have no prima facie case. ( use that term for added effect)

[Jim]

It's time for more than reading and talk to the pros from more than one source. They all can't be wrong.

 

It seems to me that they have been in the past. As I've said before, nothing is certain until the FAA general council makes a determination.

 

Disclaimer - Nothing I have said should be interpreted as legal advice. See a lawyer for legal advice.

 

I'm done here. Again.

[Rogerck]

My 2006 CTSW is registered as an ELSA. If at some point I wanted to change from the Neuform to a Warp, would this be considered a major alteration that required an FAA inspection or approval? Also, any opinions on how the Sensenich composite compares with the Warp?

 

Roger Kuhn

[Mac Bowden]

Interesting conversation about this topic.I don't doubt Rogers advice for one monent but how come FD have one set of rules for USA and another for U.K? If you check out this link you'll see that the CAA and FD sanction WarpDrive on CTsw......

http://www.bmaa.org/files/bm72_1_flight_design_ctsw.pdf

As for me, I've had a WarpDrive on for the past 4 years with about 450 hours on it and apart from some small dings on the nickle edge caused by some 'agricultural' strips the prop is still in great shape.

[johnr]

Hi Roger & all interested owners.,

I really appreciate the advice that comes out of these discussions, it gave me a hint of where to look for the reference to Warp Drive .

It is on page 14 of the Flight Design MM for the CT2K & CTSW.

I feel there is an excellent argument that the Warp Drive can be fitted to any aircraft that was supplied with that maintenance manual.

Page 13 gives the standard equipment for the various configurations. Page 13 includes "engine 912 UL2 (80hp)

Page 14 is headed with Equipment it lists optional equipment the last 2 items are as follows

 

Add-on Warp Drive 3 blade prop.w.L/E protection with HPL-R hub

Add-on CR3-65-47-101.6 Neuform 3 Blade Prop. Black& White

 

It could easily be argued that if this EXTRAS list can only be fitted if it is ordered & fitted as original equipment if

we get sick of the red & white Neuform we cannot change to the Black & White one.

 

I am quite desperate to fit the Warp Drive . I have sent a copy of page 13,14 & 15 to the authorities & hope that they have

enough common sense to approve the fitment of the prop. The difference may easily be in the interpretation & I am in Australia.

We are more closely aligned to the UK & it is good news to hear that they are fitting the Warp Drive in the UK. It may be a wise

move to send a copy of that also.

Thanks again to all who have added to this post.

John.

[FastEddieB]

In my E-LSA operating limitations, after a major alteration I am required to fly solo within a specified area for 5 hours.

 

I think my operating limitations were derived from boilerplate, so this may be pretty common.

[Mike]

Nearly all ct's in the Uk are fitted with the warp drive prop ive only seen a couple that wasn't

 

Mike

[paul m]

For the US S-LSA crowd...does anyone worry about a denial of coverage as a result of this issue in the event of an accident? For example if a Warp Drive flies off during flight and injures someone on the ground, would you worry that lack of an LOA would be a possible reason for denial? (I know most insurance policies on LSA still reference being certificated by the FAA under a Standard Airworthiness Certificate or something similar so we're already starting off behind the 8 ball, but let's ignore that for now).

[Jim]

I've been pretty clear on why I believe an LOA is not required on my particular plane. No LOA, no problem. That said, if FD thought there was a safety problem with the Warp Drive propeller, they could issue a Safety Bulletin or a Service Bulletin. Which I would take very seriously.

[chanik]

G’d day Roger,

 

I think this is where we will just have to disagree. I was talking about S-LSA and am, indeed, arguing solely from reference the FARs. I would further assert that all legal rights and obligations can be discerned just by a careful reading of those rules. That is really the basis for all administrative law and the concept of rule of law in general. So, sorry to be stubborn, but I only make, or tend to be swayed by, arguments framed in the context of the FARs. Rainbow is quite good at referencing their articles back to the FARs, BTW so I suspect they would aggree with this approach

 

In that vein, the E-LSA is a different case. THE AOI doesn’t count anymore, just your oplims. A prop change is a major change by part 43 and by reference to 21.93. The oplims will follow the guidelines in FAA 8130 for aircraft certification. A major change drops you back into phase 1 flight testing. You could just note it in the engine log but the proper way to handle it is to call a DAR or your local FSDO and have them come out and inspect your shiny new prop. They will likely assign a 5hr phase 1 (but might just sign it off if you showed it had been approved by FD) where you would record rpms, climb rates etc to verify and note in the logs it is still 14cfr 91.319 compliant. Section 144 part 6 of 8130.2f basically covers it. http://www.faa.gov/documentLibrary/media/Order/Order%208130.2F%20incorp%20with%20Chg%203.pdf

This would also be true for a Sensenich, BTW or any other prop. Since FD isn’t mommy anymore, their approval or disapproval doesn’t matter.

[chanik]

For the US S-LSA crowd...does anyone worry about a denial of coverage as a result of this issue in the event of an accident? For example if a Warp Drive flies off during flight and injures someone on the ground, would you worry that lack of an LOA would be a possible reason for denial? (I know most insurance policies on LSA still reference being certificated by the FAA under a Standard Airworthiness Certificate or something similar so we're already starting off behind the 8 ball, but let's ignore that for now).

Insurance can only deny you if the FAA violates you. BTW even a safety bulletin would not compel you to remove the prop if one were issued, only a safety directive does that. SBs legally need to be read and considered. If FD issued a SB saying they wanted Warps removed because they were worried about hub cracks or something, a mechanic could log something like that they carefully inspected the hub according to Warp drive maintenance manual and legally leave the thing on. If FD issued a SD though saying the same thing, then you have to remove it.

[chanik]

Hi Kurt,

<snip>

 

If someone can show where I'm wrong with the all the agencies involved and get an LOA from FD for a Warp then you're far ahead of me. Now if FD changed it's mind today they could offer a Warp for a CTSW or a CT2K only because that is all they were ever approved for. They were never approved or tested for an LS so it would cost FD a ton of money to get all the test time flown off to be able to even offer it on an LS so it would comply with the ASTM standards.

Recall, I was pointing out that there is a legal loophole where and if FD had approved the warp in the AOI. Otherwise, I agree with the need for the LOA. My guess is most of the people you asked didn't realize this. regulatory law is turgid stuff but it is still just english. The full line I cited in 91.327 5 states that AFTER manufacture an alteration is permissable if the part has been approved by the manufacturer. Past tense. If it is listed in your manual and FD has not issued a SD to pull it, then it falls under 91.327 section 5 as a permissable alteration. Full stop. If it is NOT in your manual, then you have no evidence FD approved that prop for your plane so without an LOA, you are doing a major alteration and the FAA could easily violate you if they were grouchy.