Hours on our CT's

[procharger]

I would like to remind all members to please post your hours on the page where you can vote, would like to see who is

having problems as the hours creep toward 2000, thanks procharger. Seems that only part of the members have done so.

I am at 1150 hours.

[Anticept]

2005 hours, 08 CTLS.

 

Engine change was just done. Took 60 hours. Some was because i switched from the mechanical vdo to the new sensor, so you have to do some new wiring, and installation of the oil sender relocation kit. Additionally, hoses take a lot of work to run, and we had to put springs in several.

 

Exhaust manifolds like to crack. A lot. Welded several times.

 

Wires like to come loose from some connectors. Twist the wire back on itself in a J, then crimp.

 

200 hr inspections are critical. Especially for a flight school environment. The rear pin sockets for the wings can crack on very hard landings. We have had to do major repair work to them.

 

If you have the tundra option on your CT (reinforced gear legs, attach points, and normal profile or bigger tires), try to land in good grass as much as possible. My CT loves grass, she glides right across it and is gentle on the gear and tires. Plus, it is harder to do a hard landing in grass, the plane bounces.

 

We have had a lot of other little problems, but again, flight school environment. Three accidents. One we think happened, which was before we got her, one was a hard landing bending the nose gear, and one was a collapsed wheel half on takeoff. She keeps on truckin though, she's a very tough little bird!

[FlyingMonkey]

2005 hours, 08 CTLS.

 

Engine change was just done. Took 60 hours. Some was because i switched from the mechanical vdo to the new sensor, so you have to do some new wiring, and installation of the oil sender relocation kit. Additionally, hoses take a lot of work to run, and we had to put springs in several.

 

 

Interesting...was there an engine problem, or did you just replace based on TBO? I think if I had an engine that had worked well for 2000 hours and was still performing well and not showing any signs of near-term failure, I'd probably leave it alone. Of course if compressions were down and it was showing other signs of fatigue, that makes the decision a no-brainer.

 

Did Rotax give you good credit on your old core?

[Anticept]

 

 

Interesting...was there an engine problem, or did you just replace based on TBO? I think if I had an engine that had worked well for 2000 hours and was still performing well and not showing any signs of near-term failure, I'd probably leave it alone. Of course if compressions were down and it was showing other signs of fatigue, that makes the decision a no-brainer.

 

Did Rotax give you good credit on your old core?

 

I still have my core. I bought new because i got a decent deal. I wanted to keep the old one because we're putting a hundred hours a month on each CT (except during winter). I need more of them!

 

Anyways, if you are S-LSA in the USA, you are required to follow manufacturer instructions. FD and Rotax both require 100 hr inspections regardless of use. They require the 5 year hose replacement. Rotax requires the 2000hr TBO replacement. So, it got replaced.

[FlyingMonkey]

Anyways, if you are S-LSA in the USA, you are required to follow manufacturer instructions. FD and Rotax both require 100 hr inspections regardless of use. They require the 5 year hose replacement. Rotax requires the 2000hr TBO replacement. So, it got replaced.

 

The FAA has held routinely that engine manufacturers cannot require overhauls at a set number of hours. The TBO is a recommendation based on the manufacturer's expected lifespan of the engine, it is not a binding requirement. Many engines in certified airplanes go 1.5x or 2x TBO and still run fine and are in complete compliance with the law. I don't think the rule is any different for a S-LSA which has less stringent certification requirements.

[Anticept]

 

 

The FAA has held routinely that engine manufacturers cannot require overhauls at a set number of hours. The TBO is a recommendation based on the manufacturer's expected lifespan of the engine, it is not a binding requirement. Many engines in certified airplanes go 1.5x or 2x TBO and still run fine and are in complete compliance with the law. I don't think the rule is any different for a S-LSA which has less stringent certification requirements.

 

This is for certificated engines and aircraft, because there is no requirement in part 91 to follow manufacturer service bulletins, even if they are marked mandatory. Only the TCDS, FAA approved (there is an official signature if it is approved) airworthiness limitations, or the TCDS are required to be complied with.

 

However, if you are flying a "for hire" operation, like a part 135 operation, there is a regulation requiring you to follow ALL manufacturer recommendations, including replacing the engine at TBO.

 

Per 91.327(d), S-LSA is required to follow manufacturer operating instructions no matter the circumstance. This includes the 2000 hr TBO. In fact, if FD went out of business tomorrow, and you had a spar repair at the end of the week but had no instructions, you would have to take your CT experimental before you could repair it. If you did have instructions however, you could repair it.

 

Also, people forget insurance and liability. While the FAA is lenient, insurance is not. Insurance may use the TBO as an excuse to not to pay out if an accident happens due to engine failure. Liability is even worse. I rent N566FD. We have lots of agreements in place limiting liability to our insurance limits and provisions. That doesn't mean a judge will follow it, and I can still lose my plane to someone with a hard on for suing people.

[FlyingMonkey]

I understand what you are saying about Part 135 operations, and I agree. However, I don't think the 2000hr TBO is an "operating instruction."

[Anticept]

I understand what you are saying about Part 135 operations, and I agree. However, I don't think the 2000hr TBO is an "operating instruction."

 

http://www.aopa.org/asf/publications/inst_reports2.cfm?article=6311

 

LSA regulations do not require compliance with the manufacturer's traditional service bulletins. However, on a LSA, service bulletins are called "safety directives" and they are mandatory. Moreover, while TBO is normally not mandatory on a traditional aircraft engine, it is on an LSA.

 

Trust me on this one Morden. I debate S-LSA a lot with local FAA inspectors. They just leave my flight school alone, because I know more about LSAs than they do. The stuff I know about LSA often has to be discussed with tech ops at AFS 610. In fact, you aren't even supposed to use a different set of tires without an LOA.

 

Also, there is another downside of rotax. They have a 15 year life limit too. It must also be complied with.

[FlyingMonkey]

Just to clarify, are you talking about in the context of flight school operation, personal operation, or both?

[Anticept]

Just to clarify, are you talking about in the context of flight school operation, personal operation, or both?

 

ALL operations. If it is an S-LSA, you have to comply with whatever is written in the engine, airframe, and avionics manuals. The 15 year/2000 tbo is in there.

 

The FAA does have a regulation requiring 100 hour inspections if you use LSAs for flight training, but both rotax and FD require it anyways.

 

FD themselves thinks that rotax is too strict, but because of liability, they follow whatever rotax recommends. Dave has told me that if i have a document from rotax that requires me to change something, i do not need an LOA for it, it will be approved by proxy.

[Roger Lee]

Insurance is not affected in the US for going past TBO for personal use. Already checked and so did the FAA.

[Anticept]

Insurance is not affected in the US for going past TBO for personal use. Already checked and so did the FAA.

 

I know that some insurance agencies will state "Follow manufacturer recommendations" in the agreement, and TBO is a manufacturer recommendation. I do not know how much weight it carries though.

 

Can you provide references to me which support your statement Roger? It's something that I cannot afford any risk on, and I would like to have the applicable regulations in my file for future reference (in case insurance tries to pull anything). I've learned that when dealing with the FAA, even the inspectors will sometimes pull things out of their rear end.

[FlyingMonkey]

Insurance is not affected in the US for going past TBO for personal use. Already checked and so did the FAA.

 

But from a regulatory perspective, is the TBO an operating limit that must be adhered to for SLSA used solely for personal use? In other words, will the FAA try to bust you for it or consider the airplane out of airworthiness?

[Anticept]

But from a regulatory perspective, is the TBO an operating limit that must be adhered to for SLSA used solely for personal use? In other words, will the FAA try to bust you for it or consider the airplane out of airworthiness?

 

Yes, it is regulatory per 91.327.

 

A lot of people don't follow guidelines to the letter though. It's also something that you don't go telling people about if you do. So basically, I have this to say MrMorden: Proceed at your own risk. Those were the words of Lockwood in Florida, and Dave at FDUSA. Since I run a flight school, I prefer to follow regs to the letter. Just don't drag down a mechanic with you in the process (they are not supposed to sign off any inspections as airworthy if it is outside of mfg spec).

 

In the future though, I'm taking my baby experimental when she's paid off and I have another CT to replace her. I'm learning aerospace engineering, and while I love what flight design has done, I'd like to make a few tweaks to her that would really make her fun to fly!

[FlyingMonkey]

Sure, I hear you Anticept. I was just wondering from what Roger said what it really matters if insurance will pay out if you get violated for out of airworthy. I guess it matter to your wallet...

[WmInce]

. . . "I'd like to make a few tweaks to her that would really make her fun to fly!" . . .

 

Like what?

[S3flyer]

There may be another reg I'm missing but 91.327 (http://www.risingup.com/fars/info/part91-327-FAR.shtml) is simply the operating limitation for S-LSA. There is no direct or indirect reference to following recommended TBO. It basically says you need to annually inspect, follow safety directives and ADs. TBO is not mentioned anywhere in the FARs (http://macsblog.com/2011/06/maintenance-regulations%E2%80%94there-aren%E2%80%99t-many/) for personal use aircraft under part 91. Running a commercial op with your plane is a different story.

 

Keep in mind the FAA overruled Rotax on their position that training for maintenance had to be by Rotax. The gist of the ruling is a manufacturer cannot go against the FARs

 

FD could get around this and force an overhaul at TBO by issuing a safety directive. Hope that doesn't happen.

[Anticept]

TBO is not mentioned anywhere in the FARs (http://macsblog.com/...re-aren’t-many/) for personal use aircraft under part 91

 

 

This is for standard certificated aircraft, not S-LSA. Interestingly as well, continental engine's don't actually *require* overhaul at TBO, as it's not in any service bulletins. Lycoming does, however.

 

The FAA's position on S-LSA is you must follow all recommendations by the manufacturers, because the FAA doesn't control S-LSA. It must be built to a consensus standard, and it is the manufacturer's responsibility to ensure that it is maintained to one. Manufacturers will tack on little extras too if they want.

 

Reference the CTLS Aircraft Operating Instructions manual, section 8-5, "8.5. Mandatory aircraft inspections". I quote:

 

The TBO times for the engine and propeller must also be observed. Provision is made for these items in the 100 h and 200 h inspection lists.

 

Sorry about the code block, this blasted forum likes to limit quote blocks per post to 2. Anyways, here's the item in the CTLS Maintenance manual:

 

Engine. Inspect all systems as required in the Maintenance Manualfor ROTAX Engine Type 912 Series.

 

Please reference the Rotax 912 series maintenance manual, chapter 5-10, "TIME LIMITS".

 

The time limit for engine operation will be specified by the TBO.

▲ WARNING: After reaching this time limit, the engine has to be shipped to an authorized ROTAX overhaul facility.

For an overhaul, the engine must be removed from the aircraft, be cleaned, preserved and all openings to be closed to prevent entering of contaminants.

■ CAUTION: A general overhaul is due after a defined period of operation or after a specified calendar life since initial start of operation (whichever comes first).

 

Additionally, this is the copypaste of 91.327(d), as copied from eCFR.gov, with relevant statement in asterisks (I cant bold in code blocks):

 

(d) Each person operating an aircraft issued a special airworthiness certificate in the light-sport category must operate the aircraft in accordance with the aircraft's operating instructions, *****including any provisions for necessary operating equipment specified in the aircraft's equipment list.*****

 

This statement does not mean you must have the equipment on board and operating. It means that any provisions that said equipment have (ex: TBO) must be followed. Aircraft’s operating instructions are NOT operating limitations! Operating instructions are issued by manufacturers (engine, airframe, and accessory). Operating limitations are issued by the FAA.

 

Additionally, I provide you with this FAA link, dated July 2013: http://www.faa.gov/a...t_8July2013.pdf

 

This is of particular importance:

 

What does the special airworthiness certificate in the light-sport category really mean?
It means that there are operating limitations issued to this aircraft that you must be aware of and
comply with. (Ref. 14 CFR § 91.327)
• Operating limitations issued as part of the special airworthiness certificate.
• Placards and markings.
• Pilot’s Operating Handbook (POH) or Aircraft Operating Instructions (AOI).
• Maintenance and inspection procedures.
• Flight training supplement.

 

See that part about maintenance and inspection procedures? Guess who dictates those procedures? The manufacturer!

 

Keep in mind the FAA overruled Rotax on their position that training for maintenance had to be by Rotax. The gist of the ruling is a manufacturer cannot go against the FARs

 

 

I need a reference on that, but I am not surprised, this is a dangerous stance to force people to have to have Rotax maintain their engines. Additionally, try to find an overhaul manual with instructions on splitting the case and opening the clutch. Rotax and it's distributors will refuse to provide it. I was trying to get it for a school project, and when I called, they told me that they only provide this information to authorized overhaul facilities.

[S3flyer]

We read the FARs differently so we'll have to agree to disagree.

 

There should be a reference in the forum to the FAA's position on Rotax training.

[Anticept]

post="25861" timestamp="1383171399"]

We read the FARs differently so we'll have to agree to disagree.

 

There should be a reference in the forum to the FAA's position on Rotax training.

 

It's not a question of whether or not you or I interpret it differently. This is stuff that I have discussed with AFS 610. These guys are who the FSDOs go to for guidance on light sport aircraft.

 

Also, read my post, I edited it and put in more references and information.

 

EDIT: How about a legal interpretation from the Chief Council? Is this proof enough?

 

http://www.faa.gov/a...erpretation.pdf

 

 

The FAA recognizes that some manufacturers have placed what they deem "mandatory"

replacement or overhaul times in their maintenance manuals for S-LSA and that these

provisions may be consistent with consensus standards accepted by the FAA. While

following the intervals set forth in the maintenance manuals is an acceptable means of

maintaining the aircraft under § 43.13(a), a maintenance provider may use another method

that is acceptable to the FAA. The intervals specified in maintenance manuals for S-LSA,

therefore, are not per se mandatory. Consequently, a maintenance provider may develop an

alternative that is acceptable to the FAA and maintain an S-LSA in accordance with those provisions.[/s]

This means that, in itself, the manuals are not mandatory, but if you want to ignore the TBO, you must develop a maintenance program acceptable to the FAA as a substitute. However, good luck trying to get the local FSDO to sign off on this plan, you better brown nose them so hard that you are up to your belly button in fecal matter.

 

 

 

Scratch all that. AFS 610 says that i did not interpret it correctly.

[Roger Lee]

If your in a flight school you're stuck with things private owners are not. In these discussions you have to separate flight schools and private use.

 

Personal use is not required to do the TBO. Yes, I'm sure. I have been over this with the top people down. Rotax or FD can not require any thing above what the FAA regs. already have in place and they can not implement additional policy or regs. concerning SLSA over what the FAA has. The TBO is a recommendation for the private pilots. FAA told me they checked with several insurance companies and the response was they are going with the FAA as a regulatory agency and its regs. This has been posted and researched on a few different sites. Rainbow aviation perused this topic to and was told the same thing. GA is allowed to go past their TBO on condition and so is the private SLSA because Rotax can not set policy.

I don't do documentation anymore. I had 7 years of supplying that and no one still believes you so I now tell everyone to research and call the appropriate people themselves.

 

Overhaul manuals are not distributed to the public and only to the 4 Rotax distributors. They are the only ones authorized to split a case.

 

S3flyer is absolutely 100% correct.

S3flyer, on 30 October 2013 - 01:49 PM, said:

Keep in mind the FAA overruled Rotax on their position that training for maintenance had to be by Rotax. The gist of the ruling is a manufacturer cannot go against the FARs

Rotax has no authority in the US and yes several LSA Mfg's have tried to overstep their bounds.

Anticept:

"The FAA's position on S-LSA is you must follow all recommendations by the manufacturers, because the FAA doesn't control S-LSA."

Only partly correct. They have to follow the FAA FARs, but can not dictate anything beyond that.

Too many people keep trying to mix LSA and GA FARs and don't read all the subsections and sub paragraphs.

You can't issue an SD on a TBO because you can't show it's an in flight or immediate safety hazard and that bears out with GA aircraft that go beyond TBO.

 

MFG's can use the word mandatory, but it has no teeth.

[mocfly]

I have been toying with the idea of selling our engine when we get to about 1200 hrs and buying a crate motor.

 

[Anticept]

Roger:

 

I'll make some calls and get some supporting official documentation. I need official sources because if the local FSDO gets a burr up their butt, I need legal backing. It's not that I doubt your expertise, I just don't think the FSDO will accept "WELL ROGER LEE FROM CTFLIER.COM SAID SO!"

 

 

 

See my edit to my last post about the chief council interpretation of TBOs in S-LSA (link). They overrule ALL, no matter who you, or I, or anyone have talked to. They went round-about with it, basically saying unless you have an acceptable alternative method of maintenance, you have to follow the manufacturer's manual to satisfy 43.13(a). The problem here is, what is acceptable? This turns into a "kiss the local FSDO's butt" fight.

 

EDIT: If we can get a link to the appropriate ATSM (the governing concensus of FD and Rotax) provisions about engine replacement, or lack thereof, that will be more than enough to satisfy the "according to consensus standards" and would very likely satisfy the acceptable maintenance alternative stipulation spelled out in this legal interpretation.

 

It's not that I'm trying to be one of those "I TOLD YOU SO" people. It's that I cannot afford to screw up. The FAA frowns very heavily on mechanics that don't follow the regulations, and I DO NOT want to lose my maintenance and pilot privileges!

[Roger Lee]

I agree that local FSDO's are some of the worst informed and don't always keep up. I haven't talked to a FSDO in 5-6 years. I have some friends and know some of the top guys at the FAA in OK. and thet are the ones I go to for real time answers. If they don't know they will go to legal.

 

Besides if you mention my name to some that may get you shot!

 

Unfortunately we know that flight schools are held to a little stricter set of regs verses the private guys.

[Doug G.]

Anticept, what I read in your link is that TBO can be offset by proving the engine is in good shape and not in need of overhaul. If there has been consistent good maintenance, no sign of excessive wear, good compression and no other indication of issues I would think that would be acceptable to a FSDO. If they won't accept it they cannot accept it on standard certified engines either. (Again, as I read the letter's info.) I will ask that question at our next Wings Safety Seminar of our local FSDO. (If the guy on the mechanical side is there.)