Working on amateur built aircraft???

I feel confused on a higher level!

I feel confused on a higher level!

Hello Jeff,

I thought that 43.1 B says that part 43 does not apply to amateur built experimental aircraft in which an experimental airworthiness certificate has been issued.

45.11 appears to me to refer to 21.182 as to applicability and as I read it 21.182 does not apply to amateur built experimental aircraft based on 43.1 B and how the airworthiness certificate was issued.

What part am I misinterpreting?

Thank you, Vance
 
I read that stuff to clarify something and walk away more confused.
I hate it .
Stupid FAR/AIM's .
 
Vance the short would be that although the machine is an experimental, some parts are certificated, and some FAA representatives have determined that if it is a certificated part then the AD's apply.

I will see if I can find some information on this matter, but remember, in the end the FAA will always trump with they are correct, leaving you with either accepting that representatives opinion or to go over that representatives head to try to come to your own interpretation. Old story about ask five inspectors for there interpretation and you will have five different answers.
 
Jeff, please let us know what you find out.

I cannot imagine that leaving in place a data plate identifying an engine as certificated is not a bigger sin than removing it. At some point, it's no longer a Continental.
 
AC No: 39-7C AIRWORTHINESS DIRECTIVES

AC No: 39-7C AIRWORTHINESS DIRECTIVES

Advisory Circular 39-7C.

Although, Advisory Circulars do not carry the weight of a regulation they do give guidance concerning there material. They are numbered based on their association. That is to say, advisory circulars dealing with certification would be AC 20-** such as AC20-27G Certification and Operation of Amateur-Built Aircraft. The G denotes the revision number.

For those interested the Advisory Circulars are issued based on there corresponding FAR. In this case FAR 39.

http://rgl.faa.gov/Regulatory_and_Guidance_Library/rgAdvisoryCircular.nsf/0/ea051001b2ce246e862569b500508099/$FILE/AC39-7C.pdf

8. APPLICABILITY OF AD's. Each AD contains an applicability statement specifying the product (aircraft, aircraft engine, propeller, or appliance) to which it applies. Some aircraft owners and operators mistakenly assume that AD's do not apply to aircraft with other than standard airworthiness certificates, i.e., special airworthiness certificates in the restricted, limited, or experimental category. Unless specifically stated, AD's apply to the make and model set forth in the applicability statement regardless of the classification or category of the airworthiness certificate issued for the aircraft. Type certificate and airworthiness certification information are used to identify the product affected. Limitations may be placed on applicability by specifying the serial number or number series to which the AD is applicable. When there is no reference to serial numbers, all serial numbers are affected.

The following are examples of AD applicability statements:

a. "Applies to Smith (Formerly Robin Aero) RA-15-150 series airplanes, certificated in any category." This statement, or one similarly worded, makes the AD applicable to all airplanes of the model listed, regardless of the type of airworthiness certificate issued to the aircraft.​

b. "Applies to Smith (Formerly Robin Aero) RA-15-150 Serial Numbers 15-1081 through 15-1098." This statement, or one similarly worded, specifies certain aircraft by serial number within a specific model and series regardless of the type of airworthiness certificate issued to the aircraft.​
c. "Applies to Smith (Formerly Robin Aero) RA-15-150 series aircraft certificated in all categories excluding experimental aircraft." This statement, or one similarly worded, makes the AD applicable to all airplanes except those issued experimental airworthiness certificates.​

d. "Applicability: Smith (Formerly Robin Aero) RA-15-150 series airplanes; Cessna Models 150, 170, 172, and 175 series airplanes; and Piper PA-28-140 airplanes; certificated in any category, that have been modified in accordance with STC SA807NM using ABLE INDUSTRIES, Inc., (Part No. 1234) muffler kits." This statement, or one similarly worded, makes the AD applicable to all airplanes listed when altered by the supplemental type certificate listed, regardless of the type of airworthiness certificate issued to the aircraft.​

e. Every AD applies to each product identified in the applicability statement, regardless of whether it has been modified, altered, or repaired in the area subject to the requirements of the AD. For products that have been modified, altered, or repaired so that performance of the requirements of the AD is affected, the owner/operator must use the authority provided in the alternative methods of compliance provision of the AD (see paragraph 12) to request approval from the FAA. This approval may address either no action, if the current configuration eliminates the unsafe condition; or, different actions necessary to address the unsafe condition described in the AD. In no case, does the presence of any alteration, modification, or repair remove any product from the applicability of this AD. Performance of the requirements of the AD is “affected” if an operator is unable to perform those requirements in the manner described in the AD. In short, either the requirements of the AD can be performed as specified in the AD and the specified results can be achieved, or they cannot.​

Appreciate the comment Stan and Vance. I do make mistakes on occasion, but these questions expand my understanding also.
 
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In an AD the wording is what nails the experimental,It has been found Bendix,Aero blaster part # XXX-xxxx was manufactured with rubber doughnuts and Bla Bla Bla ,Body of the AD will state the time & conditions to be fixes/inspected, Before further flight/ 500 hours of opperation Bla bla bla " Aircraft certificated in any catagory" ,>\)Bang(/< ,the part thats used on every flying machine is caught up in the mess.$$$$$$$$$$$$
 
This whole thing is another FAA Gray area I have been fighting for 10 years.

If you buy, say, a Lycoming O-320 and it has a data plate... you MUST comply with ADs.
The FAA Administrator say's you can not remove the data plate without permission.

Airboat and salvage people don't care about an FAA Administrator and remove tags all the time (so do MAC rebuilders now and then)

The same is true of propellors and other engine "appliances" (as they call them)

The FAA logic is "ADs indicate a known problem" and trot out the old "In the interest of safety" line and mandate compliance if they have a tag.

I submit that an FAA certified engine (with or without data plate) is much safer for flight than any auto conversion or 2 cycle. But that's just my opinion.

Would you want to fly any engine with known defects?

If any engine or component (appliance) has a data plate, you MUST have an AD compliance list prepared at the time of certification and maintain that list during the life of the aircraft.

This is very similar to the FAA required "Turbine Aircraft Maintenance Program" necessary for turbine powered aircraft (including Amateur-Built Experimental).

My belief is that most turbines, with or without an approved maintenance program, are much safer that an auto conversion or 2 cycle engine in any homebuilt. That's just my opinion.

You MUST have a pre-approved (by your cognizant FSDO or MIDO) Inspection program prior to EAB aircraft certification. Get ready to wait. Each FSDO or MIDO will probably have a different idea of how the program should read. One local program here took 6 months and spanned two inspectors.

I imagine a locally approved program might not meet the expectations of another FSDO and further tighten and thicken the red tape.

While we get buried in papers and delays our foreign competition marches on to world dominance and more jobs here go away.
 
Today went very well.

Today went very well.

The gentleman who built the engine and the shop owner pulled out a 3 inch pile of paperwork and carefully went though the ADs that applied. We have the STC that allowed the installation of the experimental cylinders. We have receipts for all four wristpins, two cylinders and for the oil pump gears. We have numbers for the crankshaft so we don’t have to inspect it for corrosions.

Phil is pleased with the paperwork.

We still have to do the inspection on the fuel injection but that is fairly easy and even though I rebuilt the magnetos we have to check the numbers on the condensers. It is nice to have learned about all this and manage it before it becomes a challenge with Mariah Gale.

This has been an interesting learning experience.

We are going to build rudder cables on Wednesday and manage the details on the engine and then I think Phil is going to sign her off.

I took care of 25 squawk items Sunday and today. I will probably go flying tomorrow.

Thank you all for your help, Vance
 
I ran across this letter from the FAA, Legal Interpretations & Chief Counsel's Opinions, to a person who had questions related to maintenance of the aircraft. The aircraft are ex-military and I would presume they are registered experimental but I am unsure on this point. However the letter does address Airworthiness Directives (AD) and there applicability relating to aircraft that have an airworthiness certificate.

http://www.faa.gov/about/office_org/headquarters_offices/agc/pol_adjudication/agc200/interpretations/data/interps/2009/Gillick.pdf

U.S.Department of Transportation
Federal Aviation Administration
Office of the Chief Counsel 800 Independence Ave., SW.
Washington, D.C. 20591

JUL 6 2009
John E. Gillick

Zuckert Scoutt & Rasenberger, L.L.P.
888 Seventeenth Street, NW
Washington, DC 20006-3309

Dear Mr. Gillick:

Thank you for your letter of February 10, 2009 on behalf of the Army Aviation Heritage Foundation (AAHF) seeking clarification of the applicability of Airworthiness Directives (ADs) to AAHF aircraft. The AAHF fleet includes the Bell Helicopter UH-I and AHI G/PIF aircraft that were acquired from the United States Army (Army).

Your letter indicated that your client received conflicting interpretations of AD applicability from FAA Counsel in 2007 from the Western-Pacific Region and in 2008 from the Southern Region. In 2007, the AAHF was told that because the aircraft in question were never given civilian type certificates, it was "unlikely that the FAA would ever issue an AD that would apply."

In 2008, the AAHF received an interpretation that concentrated on its maintenance program. The opinion indicated that the program does not exempt the AAHF aircraft from compliance with ADs, and that the intent of the program was to comply with ADs. We presume that the statement on intent means that the FAA considered compliance with ADs to be one of the
reasons it approved the AAHF's maintenance program. The later interpretation also cites FAA AdvisoryCircular (AC) 39-7C for its statement that having an experimental airworthiness certificate for an aircraft does not qualify for exemption from AD compliance.

Your request for clarification of the FAA's position regarding the applicability of part 39 to your aircraft states that there is no type design in use by the FAA to which the AAHF aircraft conform, and that the AAHF aircraft were not produced according to a type design for which a type certificate was ever issued. While you note that "in some cases, type certificates have been issued for civilian versions of these particular aircraft," you conclude
that since the military versions were manufactured either before or contemporaneously with the civilian versions, the type design basis was different, and therefore, the aircraft could not have a type design to which ADs would attach. Under your analysis, there could never be a type design for a surplus military aircraft since there is no civilian record of the 'drawings
and specifications' for the exact airplanes produced for the military, and regardless of the identicality of parts or production or the FAA's knowledge of an unsafe condition, no AD could ever be applicable to an aircraft originally produced for the military. This analysis assumes too much.

The relevant issue is not the basis under which the FAA issued an airworthiness certificate, but whether there is a type design applicable to the product. Neither of the previous interpretations addressed the question that is at the heart of your request, and that is the meaning of the term "type design" as used in 14 CFR Part 39. The regulation at the base of
this discussion is §39.5:


FAA issues an airworthiness directive addressing a product when we find that:
(a) An unsafe condition exists in the product; and
(b) The condition is likely to exist or develop in other products of the same type design.​

As you are aware, there is no definition in 14 CFR Part 1 for "type design," nor is there one in Part 39. Part 21, §21.31 describes "type design" and what it consists of for certification purposes under Part 21. In short, it indicates that the type design consists of the "drawings and specifications ... necessary to define the configuration and the design features of the product" shown to comply with the applicable regulatory part as is appropriate for the aircraft in question.

The FAA finds that your analysis of when part 39 applies is based on an overly restrictive reading of the term type design. Nothing in Part 39 suggests that its use of type design is a limited, tightly constrained concept. In fact, most ADs include in the applicability provision the phrase "certificated in any category" to ensure that the AD covers the aircraft affected by the unsafe condition, regardless of the kind of type certificate issued.

The mission of the FAA, beginning with its statutory authority, is aviation safety. Part 39 is the means used by the agency to correct known safety defects. It would be contrary to the intent of that authority to exclude aircraft based on a restricted reading of the term type design, when we have evidence that the aircraft or a part installed on it may have a safety
problem.

Your letter included tangential discussions of numerous other issues, including your understanding of the terms "airworthy," "product," "make" and "model" and their relationship to ADs, and instances of the term type design used in guidance material unrelated to Part 39. We did not find these other discussions applicable to the limited issue of the term type design as it is used in §39.5.

However, your letter also included reference to language in the AAHF's own maintenance program approved by the FAA. As you note, that program discusses methods of compliance with ADs; this would appear to presume their applicability to AAHF's aircraft. Thus, AAHF is required to comply with all ADs referenced by the maintenance program, even if not otherwise subject to an AD under part 39. The fact that AAHF does not conduct its
maintenance under part 43 (but under its FAA-approved program) does not alter the applicability of an AD issued under Part 39.

We trust that this explanation responds to your inquiry. If you have any questions, please contact my staff at 202-267-3073. This response was prepared by Karen Petronis, Senior Attorney for Regulations in the Office of the Chief Counsel with input from other agency attorneys. It was coordinated with the Aircraft Engineering Division of the Aircraft
Certification Service and the Aircraft Maintenance Division of the Flight Standards Service.

Sincerely,

Rebecca B. MacPherson
Assistant Chief Counsel for Regulations, AGC-200
 
Still Ambiguous

Still Ambiguous

Thank you Jeff,

I appreciate your inexorable efforts to illuminate the FARs so I can maneuver toward the luminosity you have bestowed upon us.

You are a true friend of mine, this forum and aviation.

In my opinion this epistle is applicable but still vague as to what an AD applies to.

The example used says “certificated in any category” and in my opinion experimental are not certificated in and category.

Part of the challenge I run into is I am not able to prove I installed the correct condenser when I rebuilt the magneto in spite of having a receipt for the magneto kits that includes condensers. I am not a licensed mechanic so even though I am authorized to work on the aircraft Phil, as an IA cannot take my word for it that I installed the correct condenser.

Fortunately this particular AD is relatively easy to check.

It is not hard to imagine an AD that is not easy to check.

Now that I have the paperwork on the engine and know I can get more of it this should not be a problem in future annual condition inspection.

This brings to my mind the question; when I am the builder/repairman for Mariah Gale, will I be able to state that all ADs have been complied with in her annual condition inspection?

This seems a small challenge because I intend to continue to have Phil do the annual condition inspection. Coastal Valley Aviation found several items I had missed and insisted that I improve some things that I felt were adequate.

I feel that having six trained pairs of eyes looking at her augments my one eyed inspection.

I feel there is no substitute for a trained professional mechanic.

I feel that Ed and I are safer because of this process.

Interacting with these A&Ps and IAs helps me to continue to enhance my discernment of the aviation approach to mitigating the risk of mechanical failure.

I have been working on writing an annual condition inspection procedure for Mariah Gale as part of the Pilots Operating Handbook and we will probably make some small design changes because of the process. I like to have a well defined position to expand from.

Thank you, Vance
 
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The certification categories fall into two groups, Standard and Special.

What is a standard airworthiness certificate?
A standard airworthiness certificate (FAA form 8100-2 displayed in the aircraft) is the FAA's official authorization allowing for the operation of type certificated aircraft in the following categories:

Normal
Utility
Acrobatic
Commuter
Transport
Manned free balloons
Special classes​

A standard airworthiness certificate remains valid as long as the aircraft meets its approved type design, is in a condition for safe operation and maintenance, preventative maintenance, and alterations are performed in accordance with 14 CFR parts 21, 43, and 91.

Is the existing standard airworthiness certificate transferable when I buy a used aircraft, or must I apply for re-issue of a new standard airworthiness certificate?

The existing standard airworthiness certificate is transferable to you (14 CFR section 21.179). As the owner you must first register the aircraft, and the aircraft must still conform to its approved type design, and be in a condition for safe operation.

http://www.faa.gov/aircraft/air_cert/airworthiness_certification/std_awcert/

Special Airworthiness Certificate

Primary
Aircraft flown for pleasure and personal use​

Restricted
Aircraft with a "restricted" category type certificate, including:​

Agricultural
Forest and wildlife conservation
Aerial surveying
Patrolling (pipelines, power lines)
Weather control
Aerial advertising
Other operations specified by the Administrator​

Multiple
Multiple airworthiness certificates​

Limited
Aircraft with a "limited" category type certificate​

Light-Sport
Operate a light-sport aircraft, other than a gyroplane, kit-built, or transitioning ultralight like vehicle​
Experimental

Research and development
Showing compliance with regulations
Crew training
Exhibition
Air racing
Market surveys
Operating amateur-built aircraft
Operating kit-built aircraft
Operating light-sport aircraft
Unmanned Aircraft Systems​
(UAS)

Special Flight Permit
Special-purpose flight of an aircraft that is capable of safe flight​

Provisional
Aircraft with a "provisional" category type certificate for special operations and operating limitations​

http://www.faa.gov/aircraft/air_cert/airworthiness_certification/sp_awcert/[/QUOTE]
 
43.3 Persons authorized to perform maintenance, preventive maintenance, rebuilding, and alterations.

(a) Except as provided in this section and §43.17, no person may maintain, rebuild, alter, or perform preventive maintenance on an aircraft, airframe, aircraft engine, propeller, appliance, or component part to which this part applies. Those items, the performance of which is a major alteration, a major repair, or preventive maintenance, are listed in appendix A.

(b) The holder of a mechanic certificate may perform maintenance, preventive maintenance, and alterations as provided in Part 65 of this chapter.

(c) The holder of a repairman certificate may perform maintenance, preventive maintenance, and alterations as provided in part 65 of this chapter.

(d) A person working under the supervision of a holder of a mechanic or repairman certificate may perform the maintenance, preventive maintenance, and alterations that his supervisor is authorized to perform, if the supervisor personally observes the work being done to the extent necessary to ensure that it is being done properly and if the supervisor is readily available, in person, for consultation. However, this paragraph does not authorize the performance of any inspection required by Part 91 or Part 125 of this chapter or any inspection performed after a major repair or alteration.

(e) The holder of a repair station certificate may perform maintenance, preventive maintenance, and alterations as provided in Part 145 of this chapter.

(f) The holder of an air carrier operating certificate or an operating certificate issued under Part 121 or 135, may perform maintenance, preventive maintenance, and alterations as provided in Part 121 or 135.

(g) Except for holders of a sport pilot certificate, the holder of a pilot certificate issued under part 61 may perform preventive maintenance on any aircraft owned or operated by that pilot which is not used under part 121, 129, or 135 of this chapter. The holder of a sport pilot certificate may perform preventive maintenance on an aircraft owned or operated by that pilot and issued a special airworthiness certificate in the light-sport category.

(h) Notwithstanding the provisions of paragraph (g) of this section, the Administrator may approve a certificate holder under Part 135 of this chapter, operating rotorcraft in a remote area, to allow a pilot to perform specific preventive maintenance items provided—

(1) The items of preventive maintenance are a result of a known or suspected mechanical difficulty or malfunction that occurred en route to or in a remote area;

(2) The pilot has satisfactorily completed an approved training program and is authorized in writing by the certificate holder for each item of preventive maintenance that the pilot is authorized to perform;

(3) There is no certificated mechanic available to perform preventive maintenance;

(4) The certificate holder has procedures to evaluate the accomplishment of a preventive maintenance item that requires a decision concerning the airworthiness of the rotorcraft; and

(5) The items of preventive maintenance authorized by this section are those listed in paragraph (c) of appendix A of this part.​

(i) Notwithstanding the provisions of paragraph (g) of this section, in accordance with an approval issued to the holder of a certificate issued under part 135 of this chapter, a pilot of an aircraft type-certificated for 9 or fewer passenger seats, excluding any pilot seat, may perform the removal and reinstallation of approved aircraft cabin seats, approved cabin-mounted stretchers, and when no tools are required, approved cabin-mounted medical oxygen bottles, provided—

(1) The pilot has satisfactorily completed an approved training program and is authorized in writing by the certificate holder to perform each task; and

(2) The certificate holder has written procedures available to the pilot to evaluate the accomplishment of the task.​

(j) A manufacturer may—

(1) Rebuild or alter any aircraft, aircraft engine, propeller, or appliance manufactured by him under a type or production certificate;

(2) Rebuild or alter any appliance or part of aircraft, aircraft engines, propellers, or appliances manufactured by him under a Technical Standard Order Authorization, an FAA-Parts Manufacturer Approval, or Product and Process Specification issued by the Administrator; and

(3) Perform any inspection required by part 91 or part 125 of this chapter on aircraft it manufactured under a type certificate, or currently manufactures under a production certificate.​

http://ecfr.gpoaccess.gov/cgi/t/text/text-idx?c=ecfr&sid=cecb734fa2687664797ed83aca26f759&rgn=div5&view=text&node=14:1.0.1.3.21&idno=14#14:1.0.1.3.21.0.363.3

§ 65.104 Repairman certificate—experimental aircraft builder—Eligibility, privileges and limitations.
top

(a) To be eligible for a repairman certificate (experimental aircraft builder), an individual must—

(1) Be at least 18 years of age;

(2) Be the primary builder of the aircraft to which the privileges of the certificate are applicable;

(3) Show to the satisfaction of the Administrator that the individual has the requisite skill to determine whether the aircraft is in a condition for safe operations; and

(4) Be a citizen of the United States or an individual citizen of a foreign country who has lawfully been admitted for permanent residence in the United States.​

(b) The holder of a repairman certificate (experimental aircraft builder) may perform condition inspections on the aircraft constructed by the holder in accordance with the operating limitations of that aircraft.

(c) Section 65.103 does not apply to the holder of a repairman certificate (experimental aircraft builder) while performing under that certificate.

§ 65.81 General privileges and limitations.
top

(a) A certificated mechanic may perform or supervise the maintenance, preventive maintenance or alteration of an aircraft or appliance, or a part thereof, for which he is rated (but excluding major repairs to, and major alterations of, propellers, and any repair to, or alteration of, instruments), and may perform additional duties in accordance with §§65.85, 65.87, and 65.95. However, he may not supervise the maintenance, preventive maintenance, or alteration of, or approve and return to service, any aircraft or appliance, or part thereof, for which he is rated unless he has satisfactorily performed the work concerned at an earlier date. If he has not so performed that work at an earlier date, he 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.

(b) A certificated mechanic may not exercise the privileges of his certificate and rating unless he understands the current instructions of the manufacturer, and the maintenance manuals, for the specific operation concerned.

With all of the above you can see quite a quagmire in answering this one.

In one part the holder of a repairman certificate may perform maintenance, preventive maintenance, and alterations as provided in part 65 of this chapter.

In another part the holder of a repairman certificate (experimental aircraft builder) may perform condition inspections on the aircraft constructed by the holder in accordance with the operating limitations of that aircraft.

My initial thoughts would be that you could you could do the AD's applicable to your aircraft, that you built, and have the Repairman certificate for.

Some caveats would be the wording in the operating limitations may exclude the Repairman from complying with the AD compliance.

Some AD' may require a person with a special rating to perform the inspection; magnaflux, ultrasound or X-ray, etc.

For the purpose of the above a Certificated Mechanic is not the same as a Repairman Certificated.

Perhaps Tom Milton will weigh in on this one, but I will see if I can find something better!
 
The example used says “certificated in any category” and in my opinion experimental are not certificated in and category.

If it has an airworthiness "certificate", then it is by definition "certificated" in some category. Doesn't matter which one.

People too often use "certificated" in a sloppy sense when they really mean to say "certificated in a standard airworthiness category", and that leads to confusion if the context isn't really, really clear.
 
I have an assurance that this will soon be finished.

I have an assurance that this will soon be finished.

Thank you all for your help.

Thank you for all your help Jeff, I feel confused on a higher level now although I still feel devoid of a resolution.

Thank you J.R. I am sloppy with my English. I intended to communicate that the sentence that allows me to work on an amateur built experimental also suggests the entire section doesn’t apply to an amateur built aircraft. I found many of the FARs to have a recursive structure and circular in their conundrum.

I have read multiple ADs now and I feel that how they are written has a lot to do with who can sign them off.

The one on the wristpins is a good example.

If a cylinder kit was sold during a time period it might have a wristpin that is marked with a particular number. It does not say who can say that it does not have those wristpins only that they can break and if you don’t know you need to check. The whole thing seems very fuzzy to me.

The fuel servo I have was made after the fuel servo AD was issued even though my engine was manufactured before and there is a way to tell. I called up some very nice experts and they asked me some questions about the brass plug and the serial number. Mine was built after the AD so unless someone has put in the parts I am ok. I could not find a source for how to tell other than this very nice fellow.

I have a receipt for the condensers that I installed in my magnetos. I still had to remove them and check the numbers. I can’t say that I feel safer knowing that my condensers are not part of the bad batch. I feel if it is a condenser and it is exposed to heat and vibration it will eventually fail.

My engine log book and engine file now have the current ADs managed.

I have the STC for the cylinders and that is probably not common for an experimental.

The Predator will be signed off tomorrow so I will be good till the end of next July. Hopefully Mariah Gale will be flying by then.

It is remarkable to me that Phil wants to live with the pressure of having to make sense out of something I find so incomprehensible. I am grateful for his patience and fortitude.

It was a learning experience and I feel I am better for it.

My medical is coming up in November.

Thank you, Vance
 
We in the industry feel the same confusing as you. And sometimes the answers are not hard to find.

However; your question on whether an Certificated Repairman can sign of on AD's is one that I have not found a good answer as to whether they can or can not. The few publications that I have looked at have not really given any clear answer. If all else fails i think I might send a letter to the FAA Legal Interpretations and see what kind of answer they give back.
 
Please...NOOOOOO

Please...NOOOOOO

...i think I might send a letter to the FAA Legal Interpretations and see what kind of answer they give back.

Please don't take this route. One person chose to do this pertaining to wheither dual, given by a subpart K CFI, could be counted toward the dual aeronautical experience required for higher ratings.

The result.... Sport Pilot CFI's are useless. No student will use one because the MONEY spent on their dual is thrown away.
 
Please, would more knowledgeable folks correct the following if I am wrong.

* An Experimental aircraft can use ANY powerplant.
* The aircraft engine/prop in it must be as it was when it received its' airworthiness certificate or it has to be reinspected per Major Modification Rules.
* A certified engine CAN be installed in an Experimental.
* A certified engine in an experimental comes with some perks, such as larger flight test area or less hours of testing required.
* If you want to enjoy the perks, you must keep the engine dataplate on the engine and keep it in compliance with all AD's and other maintenance rules for engines that meet the OEM Type Certificate. An A&P or above must make all logbook entries, and an A.I. or above has to sign off the annual.
* If you don't care about the perks, remove the data plate and call the engine a M1A1 Heat Pump and maintain it by anyone and by any method you see fit. AD's do not even apply. Any warm body can turn wrenches and make engine logbook entries. An A&P or above, or that aircraft's repairman can sign off the engine's annual Condition Inspection.
 
Bryan I do remember the sport pilot CFI question and the out come of that decision, and I hope that one day that their judgement will be changed.

With that in mind, I am not ready to go that route yet as there are still many references to look up yet. Ran across the following article on another web site hosted by Aircraft Spruce. I have not found the reference on the EAA web site but posted from the Aircraft Spruce site instead.

It is an interesting read and goes against some of what has been discussed here and especially by me.

EAA Position on Experimentals and AD Compliance.
[ Follow Ups ] [ Post Followup ] [ Starduster Bulletin Board ] [ FAQ ]

Posted by Jim Rice (169.198.254.6) on November 07, 2005 at 14:46:48:

Found this on EAA website and thought it was worth passing along since the AD discussion is going on. If you are an EAA member you can log on at listed link below.

Here is article pasted, in its entirity.

Airworthiness Directives & Amateur Built Aircraft
The applicability of Airworthiness Directives (AD's) to experimental amateur-built aircraft is an intensely contested subject. Regardless of what position one takes on this subject, many will take a personal affront to your position. It would be difficult to sum this topic up in a sentence. That said EAA does take the general position that:

Airworthiness Directives do not apply to experimental amateur-built aircraft or to any previously type certificated parts being operated on an experimental amateur-built aircraft.

That statement made, there are several things that need to be added. EAA is not saying AD's that directly relate to any component on your aircraft, need not be addressed. The owner of an experimental amateur-built aircraft should comply with, to the best of his or her ability, any AD that relates to a component installed on his or her aircraft. EAA is saying; there is no legal basis to apply an AD to an aircraft or component that is not required to be operated in compliance with a Type Certificate, or Type Design. There are some references in older outdated FAA guidance materials (e.g. Advisory Circulars) that indicate that AD's apply to experimental aircraft, and the FAA has held the position that AD's on type certificated parts, installed on experimental aircraft, should be complied with. However, despite what certain FAA field personnel have indicated in the past, the FAA Certification Office (AIR) has never produced a written position that states AD's are applicable to non-type certificated products. Further, there is no Federal Aviation Regulation (FAR) requirement for AD's on experimental amateur-built aircraft.

Because of the lack of written policy from FAA headquarters, EAA formally asked for the certification offices written position on AD's, as they relate to experimental amateur-built aircraft. After much debate within the FAA, a written position is still not available at this time. However, in 1998 a FAA headquarters Aircraft Certification Management Team1 studying the issue of AD's, stated the following in a written report of their findings:

"1. FAA has authority to issue an AD against any aircraft operating in U.S. airspace except under Part 129. FAA's ability to issue AD's is limited by practical considerations. The FAR do not support AD's for non-TC'ed aircraft. If FAA issues an AD against a non-TC'ed aircraft, it could be challenged strongly in court for violating its own rules. AGC (FAA Legal Council) is adamant in this. FAA refrains from AD's for experimental amateur-builts and foreign manufactured non-TC'ed aircraft."

Further, the FAA specifically stated that, FAR 39.1 Applicability, does not include experimental aircraft because it requires that the aircraft, engine, propeller or appliances referred to, must have a "type design." No experimental amateur-built aircraft has a "type design" therefore no AD's can apply to them. The FAA said, "the wording of the rules shows clearly, that in writing the rules, FAA had no intention of issuing AD's for non-TC'ed aircraft. 39.1 requires that the aircraft have a type design as defined in 21.312." Experimental amateur-built aircraft do not have a TC.

The problem with applying an AD to an experimental amateur-built aircraft is:

The aircraft has no type design, nor do any of the design standards in the FAR's apply (e.g. Part 23)
FAR Part 43 Maintenance, Preventive Maintenance, Rebuilding and Alteration does not apply.3
FAR 39 Airworthiness Directives, does not apply.4
The airworthiness standard for experimental aircraft is "safe to fly" not "Conformity to a type design5."
Does this mean you can ignore AD's?


No! There is an airworthiness standard for experimental amateur-built aircraft: "The aircraft must be in a condition for safe operation6."

It is reasonable to make the judgment, if the owner of an experimental aircraft did not address an AD issued against a component installed on his aircraft, it could be considered unairworthy. A pilot who operated such an aircraft could be considered in violation of FAR's 91.13(a)7 and 91.319(b)8. Notice that the term "address" was used, not "complied with" when referring to an AD on a component used on an experimental amateur-built aircraft. As was stated previously, there is no type design to comply with on an experimental amateur-built aircraft, therefore one cannot "comply" with the type design.


How should one "address" the requirements of an AD?

To ensure that your experimental amateur-built aircraft is "safe to fly," the owner of the aircraft should, at a minimum, study for any AD's that have been issued to similar type certificated components that are installed on their aircraft. The owner and the person performing the annual condition inspection should evaluate any such AD's and make a determination as to what action, if any, should be taken to ensure the aircraft is safe to fly. EAA suggests that the owner of the aircraft make a logbook entry indicating how any ADs that applies to components installed on his or her aircraft have been addressed.


Example 1: The magnetos installed have an AD against them. The solution may be to replace one with an experimental electronic ignition system, thereby insuring a back up ignition system if the magneto in question fails. This insures that the aircraft is "safe to fly."


Example 2: Particular batches of accessory case gears have been found to be failing in engines, which resulted in loss of vacuum pump drive. The AD's background information states that the failures have been taking place on gears with 500 to 1000 hours of operation. The AD requires replacement at the next annual inspection, or 500 hours, whichever occurs first; the engine installed in a homebuilt has 300 hours on it and the particular gear was installed at the last overhaul; the builder could determine that his aircraft was currently safe to fly with a note in the logbook, indicating that the gear in question should be replaced within the next 200 hours of operation, or if not replaced, no IFR flight should be attempted until the gear was replaced.


What about a type certificated engine installed on an experimental amateur-built aircraft?

Again legally, the AD will not apply for several reasons. One reason is that for the engine to comply with its type certificate it must be operated on an approved, type certificated aircraft. Since by definition no engines have been type certificated to operate on an experimental aircraft the engine is no longer in compliance with its type certificate once it is installed on an experimental aircraft. Further, the builder of an experimental aircraft may make any modification they wish to that "type certificated" engine. Once any change has been made to the engine, it is no longer a type-certificated engine. For example, if an AD is issued on a Bendix magneto the owner may remove the magneto and install an experimental electronic ignition system. The owner has still not complied with the AD, nor should he be required to. Further, the owner could simply remove the data plate from the magneto and replace it with one that says "no name magneto S/N 1". Because of this ability to modify any component on an experimental amateur-built aircraft, the fact that no certificated mechanic is required to approve maintenance or alterations (FAR 43.1(b)), and there is no "type design" for the aircraft, it is neither practical nor legal to require compliance with FAR 39 Airworthiness Directives.


This may lead you to the question, what does one have to do to install an engine previously used on a homebuilt on a type certificated aircraft?

The engine must have a conformity inspection performed were a certificated mechanic verifies that every component on the engine is one authorized on the TC for that particular make and model of engine and that all AD's have been complied with. Then the mechanic or repair station would make a log book entry attesting to the fact that the engine is in compliance with its TC. In many cases this would require the complete disassembly of the engine to verify the correct internal parts are in compliance with the TC for that engine. Disassembly could be avoided if the engine records confirm that the engine was in compliance when installed, e.g. factory new, no changes to the engine have been made and that a certificated mechanic performed all the maintenance since installation.


What about insurance?

While EAA cannot speak to every insurance policy issued, we can speak to the EAA Aircraft Insurance Plan by Falcon Insurance. This policy assumes that all components on an experimental amateur-built aircraft are experimental, and therefore compliance with an AD is not expected.

Non-compliance with an AD would not void the Falcon policy.


If AD's are not required, why do they have to be complied with to get a 25-hour instead of a 40-hour test period?

The FAA may impose any restriction they wish to protect the people and property on the ground from your "experiment". The 25-hour test period is given as a "reward" for showing that your engine and propeller combination meet a higher standard of safety than just "safe to fly." You are not required to comply with AD's to get your special airworthiness certificate. You must show the engine and propeller have complied with any applicable AD to qualify for the reduced test period9.


Can the FAA require AD's or the aircraft to be signed off by an A&P as a condition of certification?

No. Only the person who is applying for the certificate makes the determination of airworthiness and the FAA cannot require any other signatures or approvals in determining the airworthiness of a new experimental amateur-built aircraft.12


What about FAR 91.403 requirement to comply with Part 39?
FAR 91.403(a)11 requires the owner or operator of an aircraft to be responsible for compliance with FAR Part 39. As was explained earlier, FAA's legal office has stated that FAR Part 39 is not applicable to experimental amateur-built aircraft because they have no type design. Since FAR 39 is not applicable to experimental amateur-built aircraft - then the owner is always in compliance with the part 39 referred to in FAR 91.403(a).

FOOTNOTES

Report To The Aircraft Certification Management Team, Airworthiness Directive Application Team, April 28030, 1998 Washington, D.C. Team Membership included representatives from FAA offices AIR-200, AFS-610, AIR-200, AFS-300, ACE-100, ANE-100, ANM-100, ASW-100, and AGC-210.
Page 2, Summary of Conclusions.
Report To The Aircraft Certification Management Team, Airworthiness Directive Application Team, April 28030, 1998 Washington, D.C. Team Membership included representatives from FAA offices AIR-200, AFS-610, AIR-200, AFS-300, ACE-100, ANE-100, ANM-100, ASW-100, and AGC-210.
Appendix 1 Page 8, Aircraft with no U.S. TC.
FAR Part 43.1(b) "This part does not apply to any aircraft for which an experimental airworthiness certificate has been issued, unless a different kind of airworthiness certificate had previously been issued for that aircraft."
Report To The Aircraft Certification Management Team, Airworthiness Directive Application Team, April 28030, 1998 Washington, D.C. Team Membership included representatives from FAA offices AIR-200, AFS-610, AIR-200, AFS-300, ACE-100, ANE-100, ANM-100, ASW-100, and AGC-210.
Appendix 1 Page 8, Aircraft with no U.S. TC.
FAR Part 91.319(b) "No person may operate an aircraft that has an experimental certificate outside of an area assigned by the administrator until it is shown that- (1) The aircraft is controllable throughout its normal range of speeds and throughout all the maneuvers to be executed; and (2) The aircraft has no hazardous operating characteristics or design features."
FAA Order 8130.2D, Chapter 1, page 4, paragraph 9 Interpretation of the Term Airworthy for U.S. Certificated Aircraft. For non-TC'ed aircraft paragraph 9(b) the airworthiness requirement as "The aircraft must be in a condition for safe operation. This refers to the condition of the aircraft relative to wear and deterioration, e.g. skin corrosion, window delamination/crazing, fluid leaks, tire wear, etc."
FAR Part 91.319(b) "No person may operate an aircraft that has an experimental certificate outside of an area assigned by the administrator until it is shown that- (1) The aircraft is controllable throughout its normal range of speeds and throughout all the maneuvers to be executed; and (2) The aircraft has no hazardous operating characteristics or design features."
FAA Order 8130.2D, Chapter 1, page 4, paragraph 9 Interpretation of the Term Airworthy for U.S. Certificated Aircraft. For non-TC'ed aircraft paragraph 9(b) the airworthiness requirement as "The aircraft must be in a condition for safe operation. This refers to the condition of the aircraft relative to wear and deterioration, e.g. skin corrosion, window delamination/crazing, fluid leaks, tire wear, etc."
FAR Part 91.319(b) "No person may operate an aircraft that has an experimental certificate outside of an area assigned by the administrator until it is shown that- (1) The aircraft is controllable throughout its normal range of speeds and throughout all the maneuvers to be executed; and (2) The aircraft has no hazardous operating characteristics or design features."
FAA Order 8130.2D, Chapter 1, page 4, paragraph 9 Interpretation of the Term Airworthy for U.S. Certificated Aircraft. For non-TC'ed aircraft paragraph 9(b) the airworthiness requirement as "The aircraft must be in a condition for safe operation. This refers to the condition of the aircraft relative to wear and deterioration, e.g. skin corrosion, window delamination/crazing, fluid leaks, tire wear, etc."
FAR 91.13(a) "Aircraft operations for the purpose of air navigation. No person may operate an aircraft in a careless or reckless manner so as to endanger the life or property of another."
FAR Part 91.319(b) "No person may operate an aircraft that has an experimental certificate outside of an area assigned by the administrator until it is shown that- (1) The aircraft is controllable throughout its normal range of speeds and throughout all the maneuvers to be executed; and (2) The aircraft has no hazardous operating characteristics or design features."
AMATEUR-BUILT AIRCRAFT CERTIFICATION INSPECTION GUIDE C\INSPGIDE.DOC:7/10/97 AIR220:GMCNEILL:78152 File Number: 8100-1A: Page 2. I. "Was the engine and propeller originally type designed for operation in a type certificated (TC) aircraft? Is the installed engine/prop a compatible combination? (This would be validated by the engine/prop combination being listed on a type certificate data sheet for a certificated aircraft). This information will dictate whether the Phase I test flight time is 25 or 40 hours. To be eligible for the 25 hours, the certificated engine and propeller combination when installed, must be "airworthy." This means, the engine and propeller must meet its type design and be in a condition for safe operation. All applicable Airworthiness Directives must be complied with at this time. If these conditions are not met, the aircraft limitations will mandate the 40 hour Phase I test-flight time requirement."
FAR 91.403(a) "The owner or operator of an aircraft is primarily responsible for maintaining that aircraft in an airworthy condition, including compliance with part 39 of this chapter."
FAA Order 8130.2D Airworthiness Certification Of Aircraft and Related Products, Chapter 4, Section 7 Experimental Amateur-built Airworthiness Certifications, Paragraph 128(b)(7) Note: "There is NO requirement for Airframe and Powerplant mechanics to sign off amateur-built airworthiness inspection. The Aircraft builder's signature on Form 8130-6 Block III attest to the airworthiness of the amateur-built aircraft."

EAA Website for Experimental Compliance with ADs


Follow Ups:

Re: EAA Position on Experimentals and AD Compliance. Denny Pollard 19:12:29 11/08/05 (0)
Re: EAA Position on Experimentals and AD Compliance. Jim Rice 06:31:32 11/08/05 (0)
Re: EAA Position on Experimentals and AD Compliance. John 05:53:00 11/08/05 (1)
Re: EAA Position on Experimentals and AD Compliance. RT 16:59:26 11/07/05 (0)

http://starduster.aircraftspruce.com/wwwboard/messages/25960.html
 
Another interesting read.

AD COMPLIANCE FOR EXPERIMENTAL AIRCRAFT
By
RICHARD “Mongoose” HESS
Cannon Aviation Insurance, Inc.
It came to my attention, through the office of Cannon Aviation Insurance, that some of our clients had questions about the need to comply with airworthiness directives. I see this question having three sub-parts: FAR compliance (FARs are part of the Code of Federal Regulations (CFR), Title 14), insurance contractual compliance, and civil legal liability.

I’m not a lawyer although I did attend law school for a time. I didn’t even sleep at a Holiday Inn Express last night.

However, I do own, fly and teach in experimental aircraft, both jet and prop. I’m also a licensed aviation insurance agent. These are just my own thoughts, but let’s look at the facts pertaining to each part in turn.

FAR COMPLIANCE

Herb Baker of Herb & Ditto Airshows recently forwarded a response from Tony Ritzman at Aero Trader about AD applicability for the T-28 prop. Here it is in part:
“My FSDO PMI says that FAR Part 43 is not applicable to Experimental certificated aircraft (43.1b) and, by extension, Part 39 (Airworthiness Directives) is not LEGALLY applicable either, nor would it be supported by an NTSB judge in a violation enforcement. However, if your operating limitations, attached to your aircraft, state that Part 43 or Airworthiness Directives apply to your aircraft, you are bound to comply. Since all ADs are issued because of a safety of flight condition, I would think that a prudent operator or pilot would want to be sure that they are accomplished for peace of mind. After performing this inspection on about 30 hydromatic props over the years, I would HIGHLY recommend this inspection be included in the budget every five years. I suggest everyone dig out their aircraft Operating Limitations and review the maintenance requirements…”

In fact, there is further support for this argument with certain caveats.
Part 43.1(b) “This part does not apply to any aircraft for which the FAA has issued an experimental certificate, unless the FAA has previously issued a different kind of airworthiness certificate for that aircraft.”

I fly many foreign military aircraft so the likelihood of previous FAA certification is remote. But might US equipment have been certified otherwise?

I called my FSDO in ATL and asked their opinion on this subject. After being put on hold for quite a while, they finally agreed that if your aircraft’s Operating Limitations letter does NOT specifically say that Part 43 or AD compliance is required, then you are not bound by the FAA to comply with ADs. However, they strongly urge you to comply for
safety reasons.

With that being said, let me quote from some FARs that an inspector might just use to violate you if you had an accident or incident.
Part 91.7(a) “No person may operate a civil aircraft unless it is in an airworthy condition.”

Part 91.7 (b) “The pilot in command of a civil aircraft is responsible for determining whether that aircraft is in condition for safe flight. The pilot in command shall discontinue the flight when un-airworthy mechanical, electrical, or structural conditions occur.”

Part 91.13 "no person...may operate an aircraft in a careless or reckless manner so as to endanger the life or property of another."

Part 91.319 (b) (2) "No person may operate an aircraft that has an experimental certificate outside of an area assigned by the Administrator until it is shown that...The aircraft has no hazardous operating characteristics or design features."

Part 91.403 (c) "No person may operate an aircraft for which a manufacturer's maintenance manual or instructions for continued airworthiness has been issued that contains an airworthiness limitations section unless the mandatory replacement times, inspection intervals, and related procedures specified in that section or alternative inspection
intervals and related procedures set forth in an operations specification approved by the Administrator under part 121 or 135 of this chapter or in accordance with an inspection program approved under §91.409(e) have been complied with.”​

The last FARs I want to draw your attention to are in Part 39 which defines airworthiness directives and the requirement for compliance.

Part 39.3 “FAA’s airworthiness directives are legally enforceable rules that apply to the following products: aircraft, aircraft engines, propellers, and appliances.”

Part 39.5 “FAA issues an airworthiness directive addressing a product when we find that:
(a) An unsafe condition exists in the product; and
(b) The condition is likely to exist or develop in other products of the same type design.”​

Part 39.7 “Anyone who operates a product that does not meet the requirements of an applicable airworthiness directive is in violation of this section.”

You can see how the FARs contain enough variance of information to make for a good argument either way. My concern would be if an accident occurred due to the failure of a product which had an applicable AD and the owner had not complied. Do you think some of the Parts mentioned above might apply?

INSURANCE CONTRACTUAL COMPLIANCE

The very first page of your insurance policy states that “This policy is a legal contract between you and the Company, therefore, IT IS IMPORTANT THAT YOU READ YOUR POLICY CAREFULLY.” The Coverage Identification Page,
Items 9 and 10 list the requirements for the named pilots and use of the aircraft as defined under General Provisions and Conditions. Here’s what mine say.
Item 9 “The Pilot Flying the Aircraft: The aircraft must be operated in flight only by a person shown below, who must have a current and proper (1) medical certificate and (2) pilot certificate with necessary ratings as required by the FAA for each flight. There is no coverage under the policy if the pilot does not meet these requirements.”

Item 10 “The Use of the Aircraft: The aircraft will be used for your pleasure and business related purposes where no charge is made for such use and also will be used for the following purposes: YOUR STATIC DISPLAY AND
AIRSHOW FLY-BYS, INCLUDING FORMATION FLY-BYS.”​

My General Provisions and Conditions also state:

“You must make certain that the aircraft is used for the purposes stated in Item 10 of the Coverage Identification Page. There is no coverage under the policy if the aircraft:
a. Is used for any purpose not stated in Item 10 of the Coverage Identification Page;
b. Is used for any unlawful purpose;
c. Use requires a special permit or waiver from the FAA.
d. Airworthiness certificate is not in full force and effect or…”​

What I hope you get out of this mundane legal language is that an insurance policy is a legal contract between two parties, you and the underwriter. Each party has to perform or else that party is held in breach of the contract. The
underwriter agrees to provide coverage in case of loss to you under very specific conditions. You agree to pay the premium, be properly qualified, only use the aircraft for the stated purposes, and keep the aircraft airworthy.

Might a claim arising out of an accident, caused by non-compliance with an AD (causal factor), be justification to deny the claim even if you weren’t violated?

Just to show my experience in this regard, I had a prop strike about four years ago. The first thing the underwriter’s investigator wanted me to do was provide him copies of the following: license, medical, logbook, biennial flight review, and aircraft log entries. Thankfully, I had fully performed as per the contract.

CIVIL LEGAL LIABILITY

Tony Ritzman mentioned the word “prudent” in his response to the AD question. Here are some definitions of that word from various legal sources:
  • 1. Showing wisdom and caution in practical matters; sensible.
  • 2. Careful or wise in planning for the future; provident.
  • 3. Aware of the probable consequences of one’s actions; mindful.

Some of the synonyms of prudent are safe, judicious, cautious and wary.
In a court of law, the burden of proof, and questions to be asked, in a case of liability are, “Did the individual act in a prudent manner? Did he act, and take precautions, as would be expected of a reasonable person?” If the answers are yes, then you’re likely to win the case. If the answers are no, then watch the rats abandon the sinking ship as fast as they can.

Airlines crews have an even higher burden of responsibility. They are expected to take “great care” to protect the safety of the aircraft, cargo and passengers. That means you must do EVERYTHING in your power to avoid an accident. Crews have been, and will be, held liable for not taking every action and precaution to protect life and property.

A lawyer friend of mine mentioned that “strict liability” may apply in the case of an accident caused by noncompliance with an AD. Typically, strict liability is applied to product liability cases where a manufacturer sells a product in a
“defective condition” that is unreasonably dangerous to the ordinary user. The manufacturer would be held liable for any ensuing property damage or physical injuries.

Normally the liability arises out of a product’s defective design, manufacturing, packaging, instructions or warnings.

However, I believe a case could be argued for this principle to apply to a product [a propeller perhaps] that an owner knew had a safety issue, but chose to ignore. Remember, advisory circulars deal with recommended, but not safety related issues. ADs specifically deal with issues that have been identified as impacting SAFETY OF FLIGHT.

Would you really want to bet the farm on a COURT that has been presented information that you KNEW a safety issue existed, but you CHOSE to ignore it? In a civil suit, a court is not bound by a ruling of an NTSB judge. Even if
not found in violation of the FARs, the court could find against the owner/operator for damages (re: money).

I hope this article helps to give you some insight into the issue of AD compliance for experimental aircraft. It is complicated and layered. However, I believe if you do what is “prudent”, you will be holding up your end of the
bargain. Fly safe, and ALWAYS remember to check six!

Mongoose

[Author’s notes – After completing this article, someone graciously sent me a copy of Advisory Circular 39-7C dated 11/16/95. It can be read at the following web address:
http://www.airweb.faa.gov/Regulator...visoryCircular.nsf/0/ea051001b2ce246e862569b5
00508099/$FILE/AC39-7C.pdf

Of particular note is paragraph # 8 on page 2 which states, “…Some aircraft owners and operators mistakenly assume that ADs do not apply to aircraft with other than standard airworthiness certificates, i.e., special airworthiness certificates in the restricted, limited or experimental category.

Unless specifically stated, ADs apply to the make and model set forth in the applicability statement regardless of the classification or category of the airworthiness certificate issued for the aircraft…”

The circular is current and is an easy six pages to read. It has numerous explanations and examples. If anything, it leaves us with a clear picture of who is responsible for compliance and why. I hope this helps.]
 
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