Sky Arrow Annual - mostly ROTAX

[Doug Hereford]

Anticept,

I have some questions about your scenarios. If the plane is an LSA, it cannot have a retractable gear unless it is a sea plane or glider, FAR 1. Why don't you pull the gear box and send it off? In the retractable gear situation, I assume you have a sea plane or glider? Is there an approved procedure for pinning the gear? If not you have made an unapproved alteration. If so, then I would say it is good to go without a permit, assuming the gear retract system is altered IAW the MFG approved procedures to include placards, etc. Also, in a special flight permit, it is the FAA that assigns additional limitations not the mechanic. If it is a sea plane or glider that does not have an approved alteration procedure for the gear, then you have an unsafe condition. Before I pinned that gear I would get a procedure and approval from the manufacturer to stiff leg it due to the gear box condition described to them. Then perform the stiff leg procedure as directed. Then you would be good to go. I would still advise the owner to get a special flight permit, as this alteration likely does not meet the applicable consensus standard. Without the permit, the operator would be in violation of his operating limitations with no approval. If the MFG is silent, you are stuck.

In this case, I have you use Roger's "fuzzy puppy" approach..........I will not accept liability for pinning the gear without approval.

 

I am not intimately familiar with the window attachment features here, but this sounds non-structural to me. It also doesn't seem like something that would effect visibility. I think it could be argued that it is not an unsafe condition at all (not saying you would be wrong to recommend it be repaired). If you are worried that the window could leave the aircraft while in flight and strike/foul additional critical components, then you have an unsafe condition, and the aircraft cannot be flown. If the window could fall in and injure or incapacitate the pilot, you have an unsafe condition, and the aircraft cannot be flown. If it is structural, then you have an unsafe condition and the aircraft cannot be flown. Again, if you feel that there is no other option but to fly the aircraft, I would contact the MGF and get an alteration approval to add some type of shoring to the window. I would then advise the owner to get a special flight permit to cover the potential non-compliance with ASTM.

 

In both of these cases, the sign off would read: I certify that I have inspected this aircraft IAW inspection procedures xyz whatever is applicable checklist, and a signed discrepancy list has been provided to the owner this date. I am careful to use the word "discrepancy" and not "unairworthy item". This latitude is given in 43.11(a)(5). Technically we don't have airworthy or unairworthy items in SLSA.

The list would include the fact that the two alterations do not meet the applicable consensus standards, details about the reasons for them as well as copies of all of the tech data from the mfg. I have been involved in dozens of special flight permits, I think the FAA would issue in these two cases without any problems.

I do not know about every single LSA out there, but I cannot think of one that cannot be trailered somewhere also. The owner and I would have a long talk about that before we went down either of these other two roads. I would also remind him that these little encumbrances are a by product of SLSA.

 

To me the bottom line is if it is unsafe, it cannot get a flight permit in the SLSA or standard world.

 

Doug Hereford.

[Doug Hereford]

Roger,

I almost forgot, with regard to what you were taught in school on the "approved return to service" stuff.......................The FAA does not approve repairmen training courses................they are merely accepted. There is a big difference in the two concepts.

 

If you are referring to Carol Carpenter's training course, my advice is to trust but verify when it comes to regulatory matters.

 

Doug Hereford

 

P.S. to all..............Go Royals again! Sorry, but we swept the Sox!

[Roger Lee]

Hi Doug,

 

"The FAA does not approve repairmen training courses.

 

Read the second and fifth paragraphs:

 

http://www.faa.gov/documentLibrary/media/Order/8000.84B.pdf

 

Your accepted is just semantics with approve, but the FAA will not accept anyone to get their repairman certificate that has not gone through a class they have not approved and or accepted. Approve or accept = same thing for our context. 

 

If they didn't then anyone and everyone would be doing it. You must submit and get approved a 120 hr. repairman class syllabus. This is another thing we were taught and I confirmed with Edsel Ford.

An FAA person sat completely through the first Rainbow Aviation course. It had to be approved to be able to allow them to certify that students met the minimum requirement that the FAA wanted included and that they did indeed have a true 120 hr. course. Without an approved certificate from let's say Rainbow you can't apply for an repairman certificate through the FAA. Certain aspects must be included within that course.

[Doug Hereford]

I know you don't believe me Roger, but there is a big difference between accepted and approved in the aviation world. It is not semantics. I don't care if the FAA sat in. They have set in on numerous courses I have taken as well (accepted courses). This alone is not evidence of anything.

14 CFR part 65.107 does not require the repairman training course to be approved at all, ever.

The FAA does not approve things that they do not have to. It costs a lot of money. If they sat in on your course, it was likely because they didn't know what they were doing with regard to SLSA in the first place.

 

Doug Hereford

[Roger Lee]

I'm enjoying this,

 

Here is another item to ponder.

 

"FAA Legal did reference Part 65.81 which basically states that a mechanic or a repairman may not perform any task unless he has satisfactorily performed the work concerned at an earlier date- the “you can’t do it unless you’ve done it before” rule. If this is the case, the regulations say “(the mechanic) may show his ability to do it by performing it to the satisfaction of the Administrator or under the direct supervision of a certificated and appropriately rated mechanic or a certificated repairman who has had previous experience in the specific operation concerned.” For example, if you have successfully changed the oil in a Continental engine then you have successfully performed that work before and you may legally change the oil in a Rotax engine."

 

Fair enough on oil change and the simple things.

How about the FD required 2 year wing pull inspection.  Darn few mechanics have pulled wings off a GA plane. So if an A&P has never performed this similar procedure then he really can't do this particular inspection?

 

I have had a maybe 2 dozen A&P's call me and ask how to change the pitch on our props because it is something they have never done?

 

So where does this put these A&P's or repairman who have never done these task at all or anything close to similar?

[Roger Lee]

Hi Doug,

 

Call Carol Carpenter at Rainbow Aviation (530) 824-0644 and see what she says. She went through all this red tape and I'll abide by her comments.

 

"but there is a big difference between accepted and approved in the aviation world."

 

Agreed in some areas, but not for the classes. If the FAA doesn't accept or approve your class it's worthless.

[Doug Hereford]

Roger,

I assume that you are not an A&P. How do you know what they have or have not done? That being said, if a mechanic approves an aircraft for return to service after wing R&R, and they have never successfully completed the task before, they are squarely in violation of 65.81. It has been a long time since I was in A&P school. The entire process was over two years in length as I recall though. There are a lot of tasks that have to be performed including assembly processes.

You may be out driving your headlights on this one Roger. That is the politest way I can phrase it. My hat is off to those A&Ps who called. They had the good judgment to "know what they didn't know". They may have still violated 65.81 even using your advise.

 

Doug G had a scenario on this very subject earlier if you had cared to read it.

 

I have reams on correspondence with Carol, and have all of her contact info. I can say without hesitation, that she was wrong on every subject that we discussed (over the course of 1 1/2 years). I kept all of the emails.

 

Doug Hereford

[Roger Lee]

Hi Doug,

 

Sorry this was the long way around to get info to support previous post.

 

 

Before I go forward there are absolutely great A&P's out there and ones that took the time to get to know LSA. My comments are here for the few to prove the point we have been debating.

 

 

"I assume that you are not an A&P. How do you know what they have or have not done? That being said, if a mechanic approves an aircraft for return to service after wing R&R, and they have never successfully completed the task before, they are squarely in violation of 65.81. It has been a long time since I was in A&P school. The entire process was over two years in length as I recall though. There are a lot of tasks that have to be performed including assembly processes.
You may be out driving your headlights on this one Roger. That is the politest way I can phrase it. My hat is off to those A&Ps who called. They had the good judgment to "know what they didn't know". They may have still violated 65.81 even using your advise."

 

"How do you know what they have or have not done? "

It was just a general statement that IF they had never done this procedure.

 

Bingo, IAW just bit the dust. You hit the nail on the head and this happens with several things on different LSA aircraft and more frequently than you know. I get to see it and talk to these guys on a regular basis. I take about 10 tech calls per day. I absolutely love to help people and I'm on call 12 hours a day, but from the calls I get it is easy to see that many haven't performed that or any similar task. 

 

Let's add gearbox inspection, Dynon updates seem to be there for many, stab balancing for many, carb sync, gearbox friction torque, crankshaft overload clutch check. I know no A&P's have done that procedure before and it's on their Rotax check list to perform for certain serial numbers, but if they don't use that list like too many don't how would you know. 

 

And here is a simple one that all A&P's have done, worked on or repaired brakes and maybe even installed some. Who can argue this one, ceratinly not me.

But I just had an A&P install a set of Matco brakes on the wrong sides and upside down, but the label said IAW.

Now you know why I'm so adamant and passionate about education and documentation.

 

and

 

Your quote:

"That being said, if a mechanic approves an aircraft for return to service after wing R&R, and they have never successfully completed the task before, they are squarely in violation of 65.81."

 

So you just said IAW was not a correct statement.

 

Why does this happen because the mechanic just doesn't know. It happens all the time which goes back to my objection with the anemic stand alone term IAW.  They just didn't know.

So bottom line is many A&P's, "It has been a long time since I was in A&P school", which fits a lot of older A&P's and leaves quite a few hanging out on that limb unknowingly.

 

Our aviation section at our college here has added LSA to help alleviate these deficiencies. 

[Anticept]

Hi Doug!

 

These are purely hypothetical situations, meant to highlight what I am referring to with unairworthy signoffs. In my first scenario, I am referring to a standard aircraft with retractable gear. I have not been trained to work with removal and installation of a gearbox, and that is why I feel that such an aircraft should go to a shop equipped for it. As for gear pinning: I understand that an approved procedure is required. I know the airliners have a way to pin the gear for safety on the ground while working on the systems in the wheel bay. I am not certain, but I thought I've seen some retracts have a similar function. That, however, is nitpicking a part of our conversation that I feel we should not be focused on, as my statement was not about the validity of such a procedure.

 

As for unsafe conditions regarding the window: I often consider, during my inspections, whether or not items that I am writing up will make it with significant safety margin to the next inspection. Unairworthy signoffs are my way of getting the owner to move the aircraft to another shop to have the problem fixed, before it does become unsafe.

[FastEddieB]

BTW, each year I consider installing my new style fuel pump, which I bought some years ago.

 

And each year I put it off again. And I did again this year. I just can't see messing with a pump that's working fine.

[Doug Hereford]

Anticept,

Airlines will always operate under the provisions of an Approved Minimum Equipment List which may offer provisions to disable the gear retraction feature (with certain operational and maintenance conditions met. I am the director of maintenance for two of these such airlines. That is a very different situation, and a whole other topic.

Anyway, my answer to your hypothetical situation is the best I have. Take it or leave it.

 

Roger,

You have truly stumped me. I have no idea what you are talking about.

 

Eddie,

I agree. If it ain't broke, keep inspecting it.

 

Doug Hereford

 

Doug Hereford

[Roger Lee]

What has been the hot topic of debate for this thread? (not Eddie's compression).

 

IAW, documentation and you just said if they have never done the task before  they are in violation which means IAW was worthless.

It just took me a while to get you to say IAW may be a poor term if they are in violation which happens a lot.

[Doug Hereford]

Roger,

To be clear. You have NOT gotton me to say anything. I continue to stand by every single thing that I have said. My positions are unchanged by any of your replies due in large part to the fact that I do not comprehend what you are saying.

Still stumped.

 

Doug Hereford

[Anticept]

Hi Doug!

 

What I'm saying is, I've seen unairworthy signoffs used on an inspection so it doesn't have to come back to their shop and start over. It's perfectly reasonable to use the unairworthy signoff and ferry permits to relocate an aircraft to fix a discrepancy before returning it to normal flight operations. 21.197(a)(1) are one of the provisions for a ferry permit, and I have seen used many times in this manner. The specifics I laid out in my hypothetical situation could be picked apart and write volumes on the validity of each, but that wasn't intended to be within the scope of discussion. They were for illustrative purposes for using the unairworthy and ferry permit combination to complete an inspection and ensure a discrepancy is repaired at an appropriately qualified facility. Should the aircraft be safe for that ferry flight, is of course, relying heavily on our judgement.

 

This started because I was originally asking, does experimental and LSA have an equivalent unairworthy signoff for an inspection? For whatever reason that I make that signoff isn't within the scope of discussion, I would just like to know if there is such a thing.

[Doug Hereford]

Anticept,

I tried to answer you whether based on actual or hypothetical. Reread my previous post. I told you what I would have used as a sign off, and referenced a "discrepancy" list as required by 43.11. In both of your cases, the owner would have gotten full credit for the inspection that I did, and I believe that all of his and my liabilities would have been covered.

I freely admit that this could be viewed as a bit gray from a regulatory point of view which is why I said that I may be coming off a little evasive. It is also why I wish more maintenance types would chime in with suggestions. If there is a better way to handle this than what I have proposed......................please, get it out there. I gave this issued serious thought because as a business, you always want to provide options to you customers. All most every flight permit that I have been associated with involved getting a non-compliant aircraft into my shop, and not out of it.

 

I assumed that you were talking about LSA aircraft in both cases since that is where the question started.

 

The difference I see Standard vs LSA with regard to non-approval for return to service after an inspection, lies in what I had posted earlier..................................Unapproved alterations, repairs, and possibly overflown ADs SDs and Airworthiness limitations. The latter are gray because LSA MFGs don't properly address them.

 

Doug Hereford

[Tom Baker]

Tom, Anticept,

I will fall on my sword.................my answer is going to seem evasive on this one.

My approach to this situation has fallen back on 14 CFR part 43.11(a)(5). I will cut and paste from Government Printing Office Title 14

 

§43.11 Content, form, and disposition of records for inspections conducted under parts 91 and 125 and §§135.411(a)(1) and 135.419 of this chapter.

 

(a) Maintenance record entries. The person approving or disapproving for return to service an aircraft, airframe, aircraft engine, propeller, appliance, or component part after any inspection performed in accordance with part 91, 125, §135.411(a)(1), or §135.419 shall make an entry in the maintenance record of that equipment containing the following information:

 

 

(5) Except for progressive inspections, if the aircraft is not approved for return to service because of needed maintenance, noncompliance with applicable specifications, airworthiness directives, or other approved data, the following or a similarly worded statement—“I certify that this aircraft has been inspected in accordance with (insert type) inspection and a list of discrepancies and unairworthy items dated (date) has been provided for the aircraft owner or operator.”

 

Now, if I read item 15 of the SLSA operating limitations however, there is not option to find the aircraft in anything other than a "condition for safe operation".

As a practical matter, this does make some sense to me because if during a condition inspection, an unsafe condition is discovered, the aircraft should not be ferried anyway. Where I see a dilemma is when during an inspection, an unauthorized repair or alteration is found (aircraft does not meet specifications). One might also argue about an overflown airworthiness directive (approved data?). Since SLSA MFG's seem to be reluctant to address ADs or airworthiness limitations, it is a question to me also.

 

Don't know if this passes the litmus test or not, but it is where I have ended up when contemplating this scenario.

Chime in please

 

Doug Hereford

 

Doug, I agree with you assessment on making the signoff per 43.11. I don't agree with you comment regarding the item 15 on the operating limitations. The operating limitations do not govern the mechanic. They govern the person operating the aircraft. If the signoff doesn't say the airplane is in a "condition for safe operation" then they can't operate the aircraft. This doesn't mean the mechanic has to sign it off that way. The exception would be they could operate it by issuance of a special flight permit.

 

Roger, if you do an inspection you must sign it off in the aircraft records as either in a condition for safe operation, or that it has items that are unsafe making it NOT in a condition for safe operation. By regulation you can not just decide you will not sign it off. If you choose to not sign it off you have more legal exposure than signing it off as unsafe. By signing it off as unsafe you put all the weight on the shoulders of the owner.

As for signing things off IAW it is required by regulation. If you do an inspection it must be IAW some procedure. The same holds true for maintenance. In the case of a SLSA it is the manufacturers maintenance and inspection procedures.

[Doug Hereford]

Tom,

I may have not been clear, but we are saying the same thing. I agree with your statement that the limitations are for the pilot. The burden to create that statement does however fall in the inspector. It is because of those limitations that I would recommend the pilot obtain a special flight permit before operation after the above scenarios.

 

Doug Hereford

[Roger Lee]

Hi Tom,

 

"As for signing things off IAW it is required by regulation. If you do an inspection it must be IAW some procedure. The same holds true for maintenance. In the case of a SLSA it is the manufacturers maintenance and inspection procedures."

 

MY issue isn't with the term IAW and never has been in our discussions. It is with the mechanics that don't know what all that includes because they haven't looked at a check list, SB or a manual. I get to see this all the time, but they still use IAW and obviously it wasn't..

 

This is my only complaint, not the wording, but the mechanic using it and not doing it.

 

 

"If you do an inspection you must sign it off in the aircraft records as either in a condition for safe operation, or that it has items that are unsafe making it NOT in a condition for safe operation."

 

Okay I'll agree to that.

[Mike Koerner]

Roger,

I appreciate the descriptive language you used in filling out my logbooks after a performing a condition inspection on my aircraft.

Mike Koerner 

[FastEddieB]

And I think it was earlier in this thread that Roger asked me if I did not appreciate the detailed, descriptive logbook entry he made for work he did when he did my hose changes and a few other items.

 

I most certainly do - it's the mark of a professional.

[Roger Lee]

"And I think it was earlier in this thread that Roger asked me if I did not appreciate the detailed, descriptive logbook entry he made for work he did when he did my hose changes and a few other items."

 

 

 

Not at all Eddie.  It never crossed my mind. We have always been good and I always respect your ideas. Your one of my favorite "peeps".  

 

This is why I really dislike just printed words to discuss things that may be passionate, emotional or otherwise deep in thought types of subjects.

 

Just for the record I never get mad, upset or mean any malice towards anyone when we discuss subjects and I'm always willing to help anyone after we may have a difference of opinion exchange.

 

It's just two people sharing ideas.

[FastEddieB]

 

Not at all Eddie.  It never crossed my mind. We have always been good and I always respect your ideas. Your one of my favorite "peeps".  

 

This is why I really dislike just printed words to discuss things that may be passionate, emotional or otherwise deep in thought types of subjects.

 

Just for the record I never get mad, upset or mean any malice towards anyone when we discuss subjects and I'm always willing to help anyone after we may have a difference of opinion exchange.

 

It's just two people sharing ideas.

 

Thanks from a peep!

 

And I meant nothing negative in my prior post - I just realized that I had never fully responded to a question, which is kinda rude.

[Tom Baker]

I will say it again, because I am the one who jumped on Roger for picking on the three line inspection entry.

I have no issue with long and detailed maintenance entries, I even make them myself when needed. My whole point was by regulation long detailed maintenance entries don't belong in an inspection signoff. The FAA may be OK with detailed maintenance entries being placed in an inspection signoff, but as Roger says don't you want to do it right instead of just OK.

[FastEddieB]

I thought some might be curious as to what an annual might run if you do it yourself (E-LSA with 16 hour course):

 

 

Notes:

 

1) The cost of the oil and filter was actually a bit less. A few years ago a fellow was selling over a case of the Aeroshell, a bunch of filters and some Decalin for a very good price and I've been working through that supply for a long time. For the spreadsheet I just used the first prices I found online.

 

2) Normally add about $20 for new plugs. Mine had less than 35 hours on them so it seemed silly to toss them.

 

3) Every fifth year or so there will be a lot of added expense for the hose change, so one might want to factor that in on a pro-rata bases.

 

4) Of course, I used some supplies - silicone spray oil, CorrosionX, White lithium spray grease, Pledge, K&N filter oil, safety wire, etc. etc. A trivial expense overall. The TorqueSeal will last a while, though it is prone to drying up.

 

5) And finally, I value my time as without value. Being retired, not too far from the truth!

[Top Cat]

Eddie,

 

  How much were the courses you took that qualify you to do the annual and servicing. Do you factor them into the cost? Not that it matters much being retired (as I well know) although those courses allow you to do the work yourself.

 

 What tools would you say I needed t acquire in order to perform the routine servicing and annual condition inspection?

 

Now that I've moved to a much nicer enclosed hangar I'd feel more comfortable in attending a service course to start with.

 

It's good that you post your costs and experiences doing the work s that's all pert of the light sport 'mission.