Working on amateur built aircraft???

Vance

Gyroplane CFI
Staff member
Joined
Oct 30, 2003
Messages
18,377
Location
Santa Maria, California
Aircraft
Givens Predator
Total Flight Time
2600+ in rotorcraft
I would appreciate some help with the FARs.

Where in the FARs does it allow people without a repairman’s certificate to work on an amateur built experimental aircraft?

43.3 seems to prohibit anything but minor maintenance work on an amateur built experimental aircraft by anyone but the builder with the repairman's certificate without the supervision of the holder of a mechanic certificate, repairman’s certificate or an inspection authorization.

I am often confused by the FARs.

I would be grateful for help in understanding the limitations and privileges related to working on amateur built aircraft. .

Thank you, Vance
 
Vance,

I highlighted the appropriate section below:
=================================================================

§ 43.1 Applicability.

(a) Except as provided in paragraphs (b) and (d) of this section, this part prescribes rules governing the maintenance, preventive maintenance, rebuilding, and alteration of any—

(1) Aircraft having a U.S. airworthiness certificate;

(2) Foreign-registered civil aircraft used in common carriage or carriage of mail under the provisions of Part 121 or 135 of this chapter; and

(3) Airframe, aircraft engines, propellers, appliances, and component parts of such aircraft.

(b) This part does not apply to—

(1) 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; or


(2) Any aircraft for which the FAA has issued an experimental certificate under the provisions of §21.191 (i)(3) of this chapter, and the aircraft was previously issued a special airworthiness certificate in the light-sport category under the provisions of §21.190 of this chapter.
 
Exactly what I was looking for!

Exactly what I was looking for!

Thank you Mike.

Somehow I missed it.

What part does apply?

Thank you, Vance
 
None of Part 43 applies as far as I know Vance.
Your Operating Limitations however, probably specify that your aircraft should have an annual 'Condition Inspection' according to the scope and detail of Part 43 Appendix D.

I don't have my O.L.'s handy, but I'm sure it's in there.

Here's a good article on this subject by the EAA:
http://www.eaa.org/experimenter/articles/2011-04_darside.asp
 
Who can do maint

Who can do maint

Here is the relevant qoute from the EAA article posted above

'Now what about the maintenance? Maintenance requirements are called out in Part 43 of the FAA regulations. Right at the start of Part 43 there’s a paragraph regarding applicability. This paragraph contains the following verbiage:

“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;”
This specifically states that Part 43 doesn’t apply to an aircraft that holds an experimental airworthiness certificate except in those cases where a different type of certificate was previously held. Because our amateur-built aircraft have always held an experimental airworthiness certificate since their original certification, this statement applies. This is why there’s no requirement to hold an FAA certificate of any type when doing maintenance, repair, or modification on an amateur-built aircraft. You don’t have to be the builder or the owner or hold any FAA authorization of any kind when performing these functions.'
 
Thank you for help with my homework!

Thank you for help with my homework!

Thank you Mike,

The requirement for an annual condition inspection is in my operating limitations.

I have spent the last week with at least four A&P mechanics trying to find reasons The Predator is not airworthy. On Friday another IA that works there printed out part 43 and explained that I could only do maintenance on my experimental.

I succumbed to the pressure and became dysfunctional. I frantically looked for and was not able to find where it said that I could do anything I wanted on my Experimental as long as I went through a process with major modifications. My homework was to find where in the FARs it said that I could do more than maintenance on my experimental aircraft without the supervision of at least someone with a mechanic’s certificate. Thank you for helping me with that Mike.

I imagined I could because two people from the Van Nuys FSDO came out to inspect my major modification and issue new operating limitations and a new phase 1. I made it clear to them I was not the builder and did not know much about aviation.

This has been a good exercise and they did find several items that I feel are important.

I hope to write about it once it is over.

Phil was using it as a training exercise for his mechanics and I believe it was a useful exercise.

He feels I am a particularly difficult and persuasive customer and he wanted them to learn to stand their ground.

It reminded them to go to the book and gave them tools to work around missing paperwork. It reinforced the concept that something is either airworthy or it is not. That probably won’t fail for a while is simply not good enough.

The engine was the biggest challenge for the lead mechanic because there are several applicable airworthiness directives that apply to that particular engine and that particular fuel injection. They know the person who built the engine and the person who did the fuel injection and they both have very good reputations and all the work was done after the ADs were issued. It was sold as an experimental engine because it has two experimental cylinders and an experimental crankshaft so the both the rebuilder of the engine and the shop that supplied the fuel injection feel they do not need to supply the paperwork. This issue is still not resolved.

The conundrum is exacerbated because I have already taken one of them flying with plans to take two more up. None of them want to be responsible for getting a friend of the boss hurt or killed.

Thank you, Vance
 
Thank you Jason.

Thank you Jason.

Thank you Jason,

I concur with your opinion.

I was just hoping that there was something about what I could do rather than just I don’t need to pay attention to the rules because it is an experimental.

The FAR seems to be so fond of spelling things out that I thought it might be buried somewhere in there.

I continue to use it as a sleep aid.

Thank you, Vance
 
Bob Mace a retired FAA inspector that retired as the head of the Nashville FSDO once told me that the FAR'S are written in blood. That is to say that each regulation came about because of someone's death. With that that thought in mind , if the regulations do not say that you can not do it then you probably can. The caveat is there are a lot of regulations and no one knows them all.

AMATEUR-BUILT MAINTENANCE
By Earl Lawrence, EAA Government Programs Office

The EAA Government Programs office has recently received many questions about who can do maintenance and what maintenance is required on an experimental amateur-built aircraft. So I thought this would be a good time to review the regulations.

FAR Part 43.1 (b) specifically excludes experimental aircraft. It states, "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." I stress the word aircraft so that it is not interpreted to include an engine.

What about major repairs and alterations? First, you never have to fill out a form 337 for an experimental aircraft. Repairs, major or minor, can be done by anyone ( remember Part 43.1 (b). However, alterations are different. If you alter the aircraft with a different propeller or engine, for example, then it is not the airplane for which you received an airworthiness certificate. This would also apply to changing pistons or magnetos. It is a new and untested airplane. If you change propellers, you must notify the FAA (not by a 337) of your change.

Your aircraft's operating limitations should have a statement such as the following in regard to major changes: "The FAA cognizant Flight Standards Office must be notified, and their response received in writing, prior to flying this aircraft after incorporating a major change as defined by FAR 21.93."

If you do not have such a statement on your operating limitations, then you can claim you do not have to notify the FAA. However, EAA suggests that you do so even if you do not have this limitation.

The FAA inspector will make a determination as to whether he needs to come out and inspect the change and/or assign a new test-flight period. If the inspector gives you an OK by letter (which is often done), you should note the date, time, name, and change in your aircraft log book. If the inspector wants to inspect the aircraft, it is the same as when you first received your airworthiness certificate. You start all over. It is a new airplane. This information is covered in the FAA ORDER 8130.2C paragraph 142 "Issuance Of Experimental Operating Limitations." Every FAA inspector has a copy of this ORDER.

If the aircraft received its original airworthiness certificate based on the fact that the engine was certified and you alter it in any manner that would render it no longer within certification requirements, then you must notify the FAA of your change and receive an approval.

Look at it this way, you may use any combination of parts you wish to build your aircraft. However, once you receive your airworthiness certificate you cannot alter it without getting the FAA to reinspect the "new" aircraft.

ADs apply to all aircraft, aircraft assemblies and parts the AD is written against, no matter what type of aircraft they are installed in. The key to this statement is, "that the AD is written against." For example, if an AD is written against a particular make, model and serial number propeller, it only applies to that particular make model and serial number. It applies to that particular make model and serial number propeller no matter what aircraft it is installed on. Now this is where I complicate things. You, as an amateur builder, remove the data plate of that propeller, send it to the FAA, the FAA notifies the manufacturer, and you make it a Ross propeller model R1, serial number 001. Now the propeller is no longer the propeller listed in the AD, so it does not apply. The FAA may, however, issue a new AD against the Ross propeller model R1 serial number 001. To date the FAA has never done this, but they can.

If you install an electronic ignition system on a Lycomming engine, you are still responsible for ADs on other accessories on the engine and the engine itself if you have the component listed on the AD on your engine. And, of course, if you haven't changed its designation to the Ross model R1 serial number 001. In general, you can say if your AC received its airworthiness certificate based on the fact it had a certified engine, then the ADs apply. If you received an airworthiness certificate based on the fact that your engine was not certified, then the ADs don't apply.

Isn't this fun?!

Now about who can do work on amateur-built aircraft. Anyone can normally work on an experimental aircraft and sign off the work, including your two-year-old son. Some FAA field inspectors do not believe this. Remember FAR Part 43.1(b) "This part does not apply to any aircraft for which an experimental airworthiness certificate has been issued." The operating limitations that each experimental aircraft must have are what replaces Part 43. Each set of operating limitations is different. However, an FAA inspector has the power to place a requirement in the operating limitations that all work must be done by an FAA certified A&P. So far to EAA's knowledge, this has never happened on an amateur built aircraft. Most operating limitations contain a statement that says an annual "condition" inspection must be performed per the scope and detail of FAR Part 43 Appendix D. It also states that an FAA certificated A&P or repairman must perform this inspection. Note it says, "A&P or Repairman." It does not require an IA.

Let me clarify this. Anyone can work on an experimental aircraft and sign off the work. However, the annual "condition" inspection must be completed by an A&P or a Repairman.

I hope this clarifies some of the confusion that is out there.

THE END

http://www.wanttaja.com/avlinks/MAINT.HTM
 
Unrelenting Ambiguity

Unrelenting Ambiguity

Thank you Jeff,

As is so often the case you are the man with the answers.

I have printed that out along with the relevent FAR and will show it to the concerned parties at Costal Valley Aviation on Monday

It does bring up another challenge; it says the ADs apply to the engine if the aircraft received its original airworthiness certificate based on it being a certified engine.

The original airworthiness certificate was issued with a Lycoming O-290G and a Prince Propeller. This is not a certified engine.

The new operating limitations are for a Lycoming IO-320B1A and a Cato Propeller.

I told the FSDO that it was an experimental engine because of the two experimental cylinders and the experimental crankshaft. There is nothing in the operating limitations that suggest it is a certified engine but nothing that says it is not.

The engine still has the data plate on it and the head mechanic at Coastal Valley Aviation feels that means it needs to have proof of compliance with the ADs.

The shop that built the engine and sold it to me is a repair station and they don’t agree with that assessment and they do not want to issue proof of compliance with the ADs. The engine did not come with an engine log because it was going in an experimental and it was built from parts, some experimental.

It seems to me that this letter from Earl Lawrence is a little ambiguous relating to my aircraft on this point because the airworthiness certificate was not based on the engine being a certified engine either time but the engine still has the data plate on it and it has not been surrendered to the FSDO and renamed.

What would you do Jeff?

I love my Clocks, thank you again.

Thank you, Vance
 
The short answer would that a repair station is required to maintain work orders for three years. As such they should be able to supply you with a copy of the work order and it should list the work performed on this engine. The down side to repair station entries they will list in the logbook something similar to this aircraft was repaired in accordance with the manufactures manuals. Detail are on file under work order #?. Once the repair station purges the records the actual work performed is no longer available.

If they are adamant about not supplying the work order then you will need to make a list of all the components on the engine that were FAA approved, by make, model and serial number. This would include the engine, the magnetos, the fuel servo unit, alternator, starter, etc.

With this information we can construct a listing of any AD's that may be applicable to your engine and accessories. Many of the AD's will probably not be applicable by serial number. As we eliminate different AD's you will be left with some that we can not substantiate that they have been complied with. In this case each AD would be complied with and entered into the logbooks along with the AD's that are not applicable.

Listing of AD's applicable to the IO-320-B1A

IO-320-B1A

2010-07-08 04/19/2010 Turbochargers
2009-26-12 02/04/2010 Cylinder assemblies
2009-02-03 02/09/2009 Fuel injection servos
2008-14-07 08/14/2008 Externally mounted fuel
injector fuel lines
2008-08-14 04/29/2008 Fuel injection servo plugs
2007-04-19R1 05/07/2007 SAP cylinder assemblies
2004-10-14 06/25/2004 Crankshaft gear
2003-14-03 08/14/2003 Rotary fuel pumps
98-17-11 10/19/1998 Crankshafts
98-02-08 03/30/1998 Crankshaft
96-23-03 12/17/1996 High pressure fuel pumps
96-09-10 07/15/1996 Oil pump
95-26-02 01/24/1996 Aviation Gasoline
87-10-06 R1 09/01/1989 Rocker Arm Assembly
75-09-15 04/30/1975 Fuel Starvation To The Engine
75-08-09 08/18/1977 Oil Pump Drive Shaft
73-23-01 01/13/1977 Piston Pin Assembly
67-22-06 08/09/1967 Fuel Injectors
66-20-04 08/27/1966 Oil Filter Adapter Gasket
65-03-03 08/05/1967 Crankshaft Flange
64-16-05 07/10/1964 AC Pumps
 
Vance, you may have under-thought this when changing the engine, and may be over-thinking it now. It is not your responsibility to track down a FAR reference beyond the one that clearly states that 43 does not apply to you. At that point, it's up to the mechanic or inspector to show you why you're required to employ his services. If the FAA tried to replace this blanket exemption with specific exemptions for every one-of-a-kind experimental aircraft, the FAR would be years behind, and experimental aircraft would cease to exist.

I don't believe an engine on an experimental is required to have a data plate at all. It seems common practice to simply remove the data plates from formerly-certified engine cases during the build. (Jeff? Thoughts?)

At this point, you could probably do a paper conversion (removing the data plate) of your IO-320 to make it a "Breese Model 1 engine," completely an experimental, notify your FSDO of a major alteration, accept whatever new Phase I test is assigned (which may be as little as five hours, especially if they're aware you haven't actually changed the engine,) and never have to think about it again.

The level of maintenance diligence you exhibit far exceeds that of the typical owner of an old IO-320 in a standard category aircraft getting an occasional annual inspection. If you're not directly receiving ADs at this point anyway, there would seem to be little advantage in keeping the dataplate. You'll theoretically lose some resale value compared to a certified engine, but I suspect that's already gone as a result of changes made.
 
It will work itself out in a way not yet revealed.

It will work itself out in a way not yet revealed.

Thank you Paul,

I often under think things.

I was so excited about the engine that I did not consider the ramifications of the data plate.

I did not realize that the data plate is what made it a certified engine.

This is the engine I am going to use in Mariah Gale.

The engine is not assembled with certified parts so it probably should not have the data plate on it. I don’t begin to understand the complexities of an STC application but I will learn more soon.

There are only two ADs that apply to this particular engine and two on the fuel injection.

They have already verified the fuel injection line hold downs as part of the inspection. The oil pump on the engine and a part on the flow divider are fairly easy to verify, the wristpins are a little more involved.

Monday I am going to try to resolve it with paperwork from the sellers.

Phil has a good relationship with both sellers and is confident he can resolve it. Part of this attention to detail is to teach his mechanics a stronger sense of airworthy or not airworthy. I have certainly learned a lot through this process.

If I am not able to resolve the matter that way I will call the Van Nuys FSDO and make them aware of the conundrum. They have always been very helpful.

I feel fortunate to have friends that are looking out for me and Ed.

I have to be careful that I don’t get someone in trouble because I under thought it. The regulations for a repair station are quite complex.

I don’t want to compromise the application for the STC on the cylinders and crankshaft because that is part of why the engine was reasonably priced.

The engine has 321 hours in the Predator and seems to run better all the time. She does leak and I go through a quart of oil every 7 or eight hours, burning most of it. We have found no metal when we cut the oil filter apart. She always starts well and is very easy on the plugs. I have no baffles and the cylinder heads run cool and the experimental cylinders looked particularly good with the bore scope and the compression is good.

Other than our muffler cracking and the alternator bracket breaking I have no issues at all.

The question I started the thread about is nicely resolved and I am grateful for the help of my friends here on the forum.

The Predator has over 960 hours on her and she is holding up well with very little maintenance.

Mark did a very nice job building her and I have learned a lot about the aviation way from working on her.

Mariah Gale is basically a copy of her with some minor changes.

This annual condition inspection has been particularly instructive.

I don't ever want to look in the childrens eyes and tell them I have killed their mother so this is all very inportant to me.

Thank you, Vance
 
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I applaud and admire your due diligence Vance. I am delighted that my time with FAR's, and when I was obliged to know them far better that I ever will again, is over. They made for extremely soporific reading material.

I hesitate to say it, but if you were on the machine that their mother was killed on, then it is quite likely that you would have arrived on the scene of the accident slightly ahead of her, and probably be holding her hand and looking into her eyes as you wandered up to the Pearly gates togetherm rather than theirs. And may that event never happen.
 
I hesitate to say it, but if you were on the machine that their mother was killed on, then it is quite likely that you would have arrived on the scene of the accident slightly ahead of her, and probably be holding her hand and looking into her eyes as you wandered up to the Pearly gates togetherm rather than theirs. And may that event never happen.

Hello Leigh,

I once told a mother of the death of her son in Korea and it was a very difficult experience for me.

I often think of the life I have in my hands when I fly a passenger and take that responsibility very seriously.

I have survived at least four accidents that should have been fatal.

Ed will be sitting on 38 gallons of gas in Mariah Gale.

I am every mindful of the pain the survivors go through. Ed was extremely upset when they pronounced me dead after the streamliner accident.

Ed’s children love her on a level I have not seen before and I will go to great lengths to avoid having to bring them that tragic news.

I can’t imagine what a pilot goes through for the rest of their life when they lose a passenger and survive. I suspect it haunts them every day of their lives.

I suspect I would find my life diminished if I killed the love of my life.

We want to grow old together.

I am learning how to be safer in an aircraft every day and in my opinion inspection and preventative maintenance are an integral part of the package.

Thank you, Vance
 
They make it clear as mud so no matter what you do you're wrong.
 
Vance as to removing the dataplate; reference 45.13 Identification data.

(8) Any other information the FAA finds appropriate.

(b) Except as provided in paragraph (d)(1) of this section, no person may remove, change, or place identification information required by paragraph (a) of this section, on any aircraft, aircraft engine, propeller, propeller blade, or propeller hub, without the approval of the FAA.

(c) Except as provided in paragraph (d)(2) of this section, no person may remove or install any identification plate required by §45.11, without the approval of the FAA.

(d) Persons performing work under the provisions of Part 43 of this chapter may, in accordance with methods, techniques, and practices acceptable to the FAA—

(1) Remove, change, or place the identification information required by paragraph (a) of this section on any aircraft, aircraft engine, propeller, propeller blade, or propeller hub; or

(2) Remove an identification plate required by §45.11 when necessary during maintenance operations.

(e) No person may install an identification plate removed in accordance with paragraph (d)(2) of this section on any aircraft, aircraft engine, propeller, propeller blade, or propeller hub other than the one from which it was removed.

Remember the dataplate does make the item certified. It only shows that the item has met the requirements specified in the FAR 20 series.

In your case you were worried that the engine might be illegal as it has non certified parts installed. If it were to be installed on Twin Comanche then it would be a concern. However, as this particular engine was on the aircraft when the FAA issued the new phase flight time after its installation,then I would consider it approved. Note that the early Rotax engines used by the Diamond Aircraft Corporation were approved as a part of the DV20-A1 and the DA20-A1 certification as a complete unit. It was later that Rotax completed the paperwork for certification of the engine.

Airworthiness Directives are a very important part of aviation. They help keep people alive and safe. That is not to say the FAA has never issued an AD that they have rescinded because of error or is no longer applicable, they do. Even if you were able to claim the engine is no longer certified you still have parts and components which have known wear issues or other more urgent defects.

Assuming you still have a dual action high pressure fuel pump there are potentially AD's on it.

The Bendix magneto's have a long list of AD's against the coils, points, capacitors, impulse couplings and distributor.

The engine has a crankshaft with potentially high cost of replacement. One issued in 1998 that requires visual inspections of the inside diameter (ID) of the crankshaft for corrosion pits, and if corrosion pits are found during this inspection, prior to further flight, performing a magnetic particle inspection (MPI) or fluorescent penetrant inspection (FPI) of the ID for cracks.

Personally, based on the year the engine was assembled, almost all of the AD's would have been complied with at the time of assembly, particularly as it was assembled by and signed off by a Certificated Repair Station.

The only recent AD that will probably be applicable would be the RSA-5 and RSA-10 series fuel injection servos plug.

SUMMARY: The FAA is superseding an existing airworthiness directive (AD) for Lycoming Engines IO, (L)IO, TIO, (L)TIO, AEIO, AIO, IGO, IVO, and HIO series reciprocating engines, TCM TSIO-360-RB reciprocating engines, and Superior Air Parts, Inc. IO-360 series reciprocating engines with certain Precision Airmotive LLC RSA-5 and RSA-10 series fuel injection servos. That AD currently requires inspecting servo plugs for looseness and damage on fuel injection servos that have a servo plug gasket, part number (P/N) 365533, installed, and if loose, inspecting the servo regulator cover threads for damage, inspecting the gasket for damage, reinstalling acceptable parts, and torquing the servo plug to a new, higher torque to maintain the proper clamp-up force between the plug and cover. This AD requires the same inspections, except if the plug is found loose, servo plug gasket, P/N 365533, must be replaced with a new, improved gasket, P/N 2577258. This AD also requires replacement by December 31, 2009, of servo plug gaskets, P/N 365533, manufactured and made available on or after August 22, 2006, as mandatory terminating action to the repetitive inspections required by this AD. This AD also prohibits the installation of any servo plug gasket, P/N 365533. This AD also clarifies the TCM engine model applicability, and adds Bendix RSA-5 and RSA-10 series fuel injection servos to the applicability. This AD results from Precision Airmotive LLC introducing the installation of a new improved servo plug gasket, P/N 2577258, to the affected Precision Airmotive LLC RSA-5 and RSA-10 series, and Bendix RSA-5 and RSA-10 series, fuel injection servos. We are issuing this AD to prevent a lean running engine, which could result in a substantial loss of engine power and subsequent loss of control of the airplane.
The AD list a method to verify the that the AD has been complied with by marking the servo plug, by scribing or stamping the letter G on the servo plug.

I know this is a lot to take in, and others will benefit from the information. It will take a little time to complete the paperwork this time, but it will be easier in the future. If you are fortunate to receive a parts listing of all the part numbers that was installed at the time of assembly treat it with the respect given to gold and make copies for future reference.
 
Part 39—airworthiness directives

Part 39—airworthiness directives

From FAR part 39

§ 39.1 Purpose of this regulation.
top

The regulations in this part provide a legal framework for FAA's system of Airworthiness Directives.

§ 39.3 Definition of airworthiness directives.

FAA's airworthiness directives are legally enforceable rules that apply to the following products: aircraft, aircraft engines, propellers, and appliances.​

§ 39.5 When does FAA issue airworthiness directives?

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.
§ 39.7 What is the legal effect of failing to comply with an airworthiness directive?​

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

§ 39.9 What if I operate an aircraft or use a product that does not meet the requirements of an airworthiness directive?

If the requirements of an airworthiness directive have not been met, you violate §39.7 each time you operate the aircraft or use the product.​

§ 39.11 What actions do airworthiness directives require?

Airworthiness directives specify inspections you must carry out, conditions and limitations you must comply with, and any actions you must take to resolve an unsafe condition.​

§ 39.13 Are airworthiness directives part of the Code of Federal Regulations?

Yes, airworthiness directives are part of the Code of Federal Regulations, but they are not codified in the annual edition. FAA publishes airworthiness directives in full in the Federal Register as amendments to §39.13.​

Editorial Note: For a complete list of citations to airworthiness directives published in the Federal Register,consult the following publications: For airworthiness directives published in the Federal Register since 2001, see the entries for 14 CFR 39.13 in the List of CFR Sections Affected, which appears in the “Finding Aids” section of the printed volume and at www.fdsys.gov. For citations to prior amendments, see the entries for 14 CFR 39.13 in the separate publications “List of CFR Sections Affected, 1973–1985,” “List of CFR Sections Affected, 1964–1972,” and “List of CFR Sections Affected, 1986–2000,” and the entries for 14 CFR 507.10 in the “List of Sections Affected, 1949–1963.” See also the annual editions of the Federal Register Index for subject matter references and citations to FAA airworthiness directives.

§ 39.15 Does an airworthiness directive apply if the product has been changed?

Yes, an airworthiness directive applies to each product identified in the airworthiness directive, even if an individual product has been changed by modifying, altering, or repairing it in the area addressed by the airworthiness directive.​

§ 39.17 What must I do if a change in a product affects my ability to accomplish the actions required in an airworthiness directive?

If a change in a product affects your ability to accomplish the actions required by the airworthiness directive in any way, you must request FAA approval of an alternative method of compliance. Unless you can show the change eliminated the unsafe condition, your request should include the specific actions that you propose to address the unsafe condition. Submit your request in the manner described in §39.19.​

§ 39.19 May I address the unsafe condition in a way other than that set out in the airworthiness directive?

Yes, anyone may propose to FAA an alternative method of compliance or a change in the compliance time, if the proposal provides an acceptable level of safety. Unless FAA authorizes otherwise, send your proposal to your principal inspector. Include the specific actions you are proposing to address the unsafe condition. The principal inspector may add comments and will send your request to the manager of the office identified in the airworthiness directive (manager). You may send a copy to the manager at the same time you send it to the principal inspector. If you do not have a principal inspector send your proposal directly to the manager. You may use the alternative you propose only if the manager approves it.​

§ 39.21 Where can I get information about FAA-approved alternative methods of compliance?

Each airworthiness directive identifies the office responsible for approving alternative methods of compliance. That office can provide information about alternatives it has already approved.​

§ 39.23 May I fly my aircraft to a repair facility to do the work required by an airworthiness directive?

Yes, the operations specifications giving some operators authority to operate include a provision that allow them to fly their aircraft to a repair facility to do the work required by an airworthiness directive. If you do not have this authority, the local Flight Standards District Office of FAA may issue you a special flight permit unless the airworthiness directive states otherwise. To ensure aviation safety, FAA may add special requirements for operating your aircraft to a place where the repairs or modifications can be accomplished. FAA may also decline to issue a special flight permit in particular cases if we determine you cannot move the aircraft safely.​

§ 39.25 How do I get a special flight permit?

Apply to FAA for a special flight permit following the procedures in 14 CFR 21.199.​

§ 39.27 What do I do if the airworthiness directive conflicts with the service document on which it is based?

In some cases an airworthiness directive incorporates by reference a manufacturer's service document. In these cases, the service document becomes part of the airworthiness directive. In some cases the directions in the service document may be modified by the airworthiness directive. If there is a conflict between the service document and the airworthiness directive, you must follow the requirements of the airworthiness directive.​
 
Jeff- Your posts add so much weight to this forum. When you say something, it can be assumed it is factual and coorrect. Thanks for your relentless efforts to help us all understand a lot of this stuff. Stanj
 
Help from tolerant friends!

Help from tolerant friends!

They make it clear as mud so no matter what you do you're wrong.

It certainly feels the way Gary.

Phil has weekly tests for his mechanics that are open book and they can ask each other.

If they all get the questions right then the split a nice pecuniary bonus.

I hear them talking and debating about the meaning of the rules so them can get the questions right and split the bonus. This is just what Phil wants. Maybe someday the question of who can work on an experimental aircraft and what is covered will be on the test.

Most of them seem to have better debating skills than I do and being outnumbered doesn’t help.

It has been a great learning experience for me and the forum has helped me a lot in how they fit together and where the answers might be.

Because of my brain injury I am in the 17th percentile for unrelated short term memory so the entire FAR/AIM is particularly challenging for me. Anything I can do to make it relate to my personal experiences helps me remember it.

I don’t think I could do a better job of writing the regulations and I feel in my heart they are written to save pilots lives.

I am grateful to people like Jeff, Phil, Paul, Jim and Terry who seem to understand them much better than I do and seem willing to help assuage my ignorance.

Thank you, Vance
 
Thank you for your patience with my ignorance!

Thank you for your patience with my ignorance!

Thank you Jeff,

I concur with Stan, it is great gift you give this forum and I suspect you invest considerable time and effort into this gift. I feel that it allows all of us to become confused on a higher level about the nuances of aviation.

Your ongoing efforts to help me understand aviation has brought me to the opinion that the best way to resolve this conundrum results from getting the engine builder to supply a parts list.

He assembled the engine to run on a test stand rather than fly. After many hours of testing his boss decided to sell the engine to me against his consul for a very low price and on time payments. I can understand why that would make him a little temperamental. The fuel injection was also sold for a very low price at the request of the builder so providing the paperwork will escalate the cost of the favor to the builder. I suspect that somewhere deep inside he feels that I don’t trust him. This is not the case and he has a very good reputation in the industry. It is actually much more complicated than this rough outline but suffice it to say I feel his reluctance is justified.

I don’t want to make enemies and burn bridges so I will have to find a way to sweeten the astringent experience of dealing with my pedantic temperament.

Thank you, Vance
 
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