Anticept Posted October 30, 2013 Report Share Posted October 30, 2013 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.) Doug: I need the Columbus FSDO to be bound by something. They are the ones who will determine my fate if something happens! We can go all day citing references, but the only ones that will mean anything are the ones I can slap down at my local FSDO's desk and say "This is what your BOSS said... (mildly nsfw link)". Link to comment Share on other sites More sharing options...
Roger Lee Posted October 30, 2013 Report Share Posted October 30, 2013 If you need a difineite answer call the FAA in OK and give the FSDO the name of that person and tell the FSDO to call and see for himself. I had a FSDO tell me something 8 years ago about LSA that affected me and I knew he was wrong, but he didn't care. I told him to call the people upstairs and gave him the phone number and the persons name. Then I got to do what I wanted. FSDO's don't keep up on changing times like they do in OK. Link to comment Share on other sites More sharing options...
Roger Lee Posted October 31, 2013 Report Share Posted October 31, 2013 From our Rotax Canadian friends. Darn I posted documentation. I'm slipping. Canadian AN BO41 on condition inspection.pdf ROAN guidelines for going on-condition.pdf Link to comment Share on other sites More sharing options...
Anticept Posted October 31, 2013 Report Share Posted October 31, 2013 If you need a difineite answer call the FAA in OK and give the FSDO the name of that person and tell the FSDO to call and see for himself. I had a FSDO tell me something 8 years ago about LSA that affected me and I knew he was wrong, but he didn't care. I told him to call the people upstairs and gave him the phone number and the persons name. Then I got to do what I wanted. FSDO's don't keep up on changing times like they do in OK. Yeah... generally this doesn't go over well with the local FSDO. They don't care about talking with people from higher up, they want documentation. I think it's to protect THEIR butts if AFS 800 were to come down on them. Our local FSDO is very lenient on matters. But they are just like any FAA office, they are an immovable object once they make a decision. I just don't want that immovable object parking on top of me. Anyways, your documents are interesting. I'll give them further reading later. Link to comment Share on other sites More sharing options...
Anticept Posted October 31, 2013 Report Share Posted October 31, 2013 CTLSi (and Roger): We're training under part 61, not 141, so the differences are minor. We're wanting to additionally train under 141, but until we have that rating, we can effectively be considered private operation, part 91. And yes, I did buy a new engine. Among the reasons is, it's nice to have spare parts for how much our CTs fly. I swear, they spend more time wheels off than wheels on the ground! Link to comment Share on other sites More sharing options...
procharger Posted October 31, 2013 Author Report Share Posted October 31, 2013 Everything went South after the second post, oh well, at least remember to vote for our next pres??? see ya Procharger Link to comment Share on other sites More sharing options...
Anticept Posted October 31, 2013 Report Share Posted October 31, 2013 Yeah we did get carried away lol . Maybe a moderator can split the topic? Link to comment Share on other sites More sharing options...
Doug G. Posted October 31, 2013 Report Share Posted October 31, 2013 Yeah, that's never happened before! Link to comment Share on other sites More sharing options...
Anticept Posted October 31, 2013 Report Share Posted October 31, 2013 Ladies and gentlemen, I made my calls to the people on high, and I have received the same information that Roger has claimed. I do not know why I am thinking i have talked to AFS 610 about requiring an engine replacement in a previous discussion, what I have heard from them over the phone is completely different from what i recall. It may have been a discussion with another office, or maybe with someone from the manufacturers; i am not sure because it was over a year ago. Here is what i have been told: the interpretation provided, basically reinforces that the manufacturer cannot add additional stipulations that the FARs do not already state. Additionally, common accepted industry maintenance practices are acceptable to maintain your S-LSA, including on condition inspections of an engine. In fact, if you already have data to support a repair you are performing, including the use of references such as AC 43.13, then you are not required to contact the manufacturer for the work you are performing. You ARE required to have manufacturer support for activities that you do NOT have data for. This was not meant to be a limitation to allow strict control by manufacturers, rather it is a regulation that requires you to have data for whatever work you are performing. It was summed up to me by AFS 610 as follows: S-LSA are operated in the same manner as any other part 91 aircraft. Additionally, part 91.327 is only a PILOT requirement. Those performing maintenance are not bound by this part, a technicality that i had forgotten about! When performing maintenance on an aircraft, those of us putting on our mechanic hats are only bound by regulations in part 43! And, as the interpretation states, a mechanic may use the methods prescribed in the mfg maintenance manual, in whole or in part; 43 does not mandate that they must use it SOLELY. This means TBO can be ignored. This revelation is actually very wonderful to me. One of the things that i really did not like about S-LSA was the insane restrictions placed upon us by the mfg. The FAA seems to be on our side on this one, telling the manufacturers they are full of it, and they can't mandate all of this extra crap. Keep in mind, this does not immunize you from civil suits. As a flight school, I will still follow TBO. But, as a person who will keep a CT for himself, this makes private ownership of an S-LSA much more appealing. Finally, i am going to compile references, interpretations, regulations, etc in a post here on this forum for everyone to save if an inspector ever tries to tell you that you must follow TBO, etc. That will be my redemption for spreading false information . This will take time for me to compile, but i will try to make it bullet proof. Link to comment Share on other sites More sharing options...
FredG Posted October 31, 2013 Report Share Posted October 31, 2013 Anticept - thanks for checking and communicating the message. I think we are all pleased to hear a common theme from several pro's. Fred Link to comment Share on other sites More sharing options...
Ed Cesnalis Posted October 31, 2013 Report Share Posted October 31, 2013 Just to be clear, personal use SLSA are or are not subject to: overhaul at TBO 100 hour inspection 25 hour inspection 5-year rubber replacement Chute repack ?? Link to comment Share on other sites More sharing options...
Anticept Posted October 31, 2013 Report Share Posted October 31, 2013 CT: dont ignore the engine 25 hour. That will void your warranty. Again, I will compile data for us. I do not want to answer your questions CT, unless i have a reference that clearly backs it up. I want to make sure that you have legal backing to defend yourself if you need to. Link to comment Share on other sites More sharing options...
Ed Cesnalis Posted October 31, 2013 Report Share Posted October 31, 2013 I missed my 25 hour back in 2006 and my warranty is up. Link to comment Share on other sites More sharing options...
Anticept Posted October 31, 2013 Report Share Posted October 31, 2013 I missed my 25 hour back in 2006 and my warranty is up. Too late for that now then! Link to comment Share on other sites More sharing options...
Doug G. Posted October 31, 2013 Report Share Posted October 31, 2013 I look forward to your compilation. (My engine warranty is no longer a factor either.) I take this to mean that a comparable (simple) part is a comparable part even if FD or Rotax has a part number attached to it. As long as it fits Part 43 definition. Link to comment Share on other sites More sharing options...
FlyingMonkey Posted October 31, 2013 Report Share Posted October 31, 2013 What is included in the 25 hour exactly? Link to comment Share on other sites More sharing options...
Roger Lee Posted October 31, 2013 Report Share Posted October 31, 2013 For the 25 hr. just print out the inspection pages in the Line maint. manual and use that. Then document that you did the 25 hr. with hopefully more than two lines for the entry. Link to comment Share on other sites More sharing options...
Anticept Posted November 1, 2013 Report Share Posted November 1, 2013 Like what? http://ctflier.com/public/style_emoticons/#EMO_DIR#/smile.png I forgot to answer this. Aside from cosmetic changes just to be silly, this: Link to comment Share on other sites More sharing options...
Madhatter Posted November 1, 2013 Report Share Posted November 1, 2013 The FSDO in my area is not the least bit interested in being involved in LSA aircraft. I have discussed it with the chief of our FSDO. Most of the new inspectors here have very little field experience in aviation and are limited on their approval authorizations. They are geared towards type certificated aircraft and avoid LSA issues. I believe most would expect compliance with approved maintenance procedures they are familiar with for non commercial part 91 aircraft. I follow manufacturers recommendations as much as possible but sometimes common sense must prevail. The FAR's were not written for the mechanics, they were written for the lawyers. The comes from the person who writes the FAR's in Washington. I maintain aircraft with only one goal in mind, safety. You can never comply with every legal requirement in aircraft maintenance because the plane would never leave the hangar. As an IA you find that there is a lot of grey area in aircraft maintenance but experience and common sense will make the aircraft safe. After 40 yrs in aviation I have found not much is black and white. Link to comment Share on other sites More sharing options...
FlyingMonkey Posted November 1, 2013 Report Share Posted November 1, 2013 I forgot to answer this. Aside from cosmetic changes just to be silly (whiskers!), this: One interesting thing about the Cri-Cri, at least from my understanding: FAA does not require a multi-engine rating for them, becasue they only have a single seat. I guess "go ahead and kill yourself as long as you don't take anybody with you" is the reasoning. Link to comment Share on other sites More sharing options...
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