Working on amateur built aircraft???

[StanFoster]

Vance- of course its a good thing. You went through a lot of trouble, but in the end you said you and Ed are safer for it, and it was 2 weeks well spent. That's why I said you turn everything into a positive. Stan

[bryancobb]

Originally Posted by Vance

Hello Brian,

I feel there are two important issues here.

First, the AD may address a real safety issue and in my opinion that may be a poor aviation decision to ignore it.

Second, many of the ADs are written for specific components, in my example the fuel injection and the magnetos. As I read the rules; if these components are installed on any aircraft then the ADs apply even if the engine in no longer a Lycoming.

I learned a lot by complying with the ADs, I am grateful for the experience.

I can understand why you would feel resentful of the ADs as it appears to me they have essentially turned your Brantley into a lawn ornament. Hopefully I am wrong or there will be some resolution there.

Thank you, Vance

I am in severe agreement with you that it is sensible, logical, and responsible to comply with ALL A.D's on components installed on ANY aircraft. My statements were pertaining to "WAS A.D. COMPLIANCE REQUIRED." The answer is NO.

I do not feel resentful toward A.D. issuance at all. I witnessed, first hand, the thoroughness that the FAA goes to, to consider all data BEFORE issuing an A.D. (Brantly Short T/R Driveshaft A.D.) If this A.D. is a typical model, A.D.'s are appropriate, thoroughly investigated, and needed.

The Rotor Blade problem has not been addressed by A.D. yet.

Pertaining to experimentals...
* Any warm body can work on them, including making log book entries and complying with A.D.'s
* Only an A&P, The Builder With a Repairman Certificate, or above, can sign off the Annual Condition Inspection
* An engine/prop combination can be either certificated or NOT certificated.
* IF it is CERTIFICATED, the Type Certificate for the combination MUST be adhered to TO-THE-LETTER, and a data plate must be present, even if it's sitting on a pallet on the ground. ALL A.D.'s MUST BE complied with before it goes into the air.
* If a previously certificated engine is installed on an experimental, the dataplate must be removed and a new dataplate installed that reflects that it is experimental and ties it to a serial number listed on the engine logbook. THEN A.D.'s do not apply but is still prudent to comply with them.

[gyroplanes]

Bryan, What you say about mandatory compliance (or lack thereof) is contrary to what the majority of FAA inspectors and officials contend.

As I have pointed out in the other maintenance thread, the FAA is awash in gray areas, but they seem pretty united on this one.

A certificated engine, it is argued by some, becomes experimental when installed in a non-certificated airframe.
It is generally acknowledged that a certificated engine becomes "experimental" when any accessory, not approved for that engine, is installed. (Warp Drive prop, electronic ignition, or any item that has not been maintained IAW manufacturer's instructions).

The FAA contends that if the AD reads "on any aircraft certified in any category" ADs apply.

It's a tangled web with a big venomous spider waiting.

[JEFF TIPTON]

EAA and experimental category aircraft owners waited a long time for this piece of good news, but it finally arrived on March 12, when the FAA published an updated Advisory Circular (AC 39-7D) on Airworthiness Directives (ADs). The circular formally set FAA policy that ADs are not applicable on non-type certificated aircraft, except when specifically noted. This is an issue that has been on EAA's "Top 10" list of advocacy issues and has been part of the agenda at the last three EAA/FAA Recreational Aviation Summits. The absence of FAA headquarters guidance had created a patchwork of regional policies that varied and at times conflicted with each other.

http://www.faa.gov/documentLibrary/m...AC%2039-7D.pdf

[Resasi]

Thank you Jeff for posting that and helping us keep up to speed with where we stand.

Compliance, certainly about safety and staying alive.

[All_In]

I love learning and this forum.

We are going to have the same problem.

Thank God my brother is an IA and we will have him do the inspection and sign off.

Thank you for posting and all the responses.

You guys ROCK!!

[gyroplanes]

Originally Posted by JEFF TIPTON

http://www.faa.gov/documentLibrary/m...AC%2039-7D.pdf

Thank you Jeff. This is fresh information, BUT, I have had battles with the FAA before regarding Advisory Circulars, the FAA says ACs are not regulatory, but "Advice". Probably enough to send an inspector scurrying for the books.

[JEFF TIPTON]

Battles with the FAA is inevitable. As long as information is printed in a manner that leads to interpretation, and the two parties envolved have opposing views, no one will win.

I quess the best one the mechanic has to deal with is when the FAA did away the CAM 18 which was considered to be approved data and replaced it with the AC 43.13 series which is considered acceptable data.

Excerpt from AC 43.13.1B

1. PURPOSE. This advisory circular (AC) contains methods, techniques, and practices acceptable to the Administrator for the inspection and repair of nonpressurized areas of civil aircraft, only when there are no manufacturer repair or maintenance instructions. This data generally pertains to minor repairs. The repairs identified in this AC may only be used as a basis for FAA approval for major repairs. The repair data may
also be used as approved data, and the AC chapter, page, and paragraph listed in block 8 of FAA form 337 when:

a. the user has determined that it is appropriate to the product being repaired;
b. it is directly applicable to the repair being made; and
c. it is not contrary to manufacturer’s data.

Sometimes it just does not seem any clearer!

[All_In]

Bummer, I guess this means we are going to have tear down and inspect Pra31's IO320 that we are installing on the two place Genesis we are building. It has no log books?

At least my brother will inspect it for free. We were going to only make sure the oil-pump AD applied and box it up and send it to Nicolas in Cypress so he could use it to re-design his two place to make it perfect CLT with the Lyc.

[JEFF TIPTON]

John is the engine a wide deck or a narrow deck?

For many Lycoming engines the same engine model may be a narrow deck or a wide deck. Each engine takes entirely different parts. How do you tell the difference. All wide deck engines have a engine serial number ending in A (except O-235 series engines). Lycoming serial numbers can be found on the engine data plate and also on the crankcase at the top parting surface.

Narrow deck engines also use internal hex style cylinder hold-down nuts and frequently use cylinder hold down plates. The cylinder flanges on wide deck engines are thicker and do not need cylinder hold-down plates.

[All_In]

Thank you Jeff I do not know and my brother is out of town, but I'll stop by the airport on the way to my daughters and look at the data-plate and hod-down plates.

PS:
AT least my brother will be happy we wanted us to tear it down inspect it and rebuild it....

I'm late and have to go I'll see you guys late tonight!