AD's on Experimental A/C

[moby]

Maybe this topic has been brought up here before, But do
homebuilt/experimental aircraft have to comply with Airworthiness Directives
set forth by the FAA? specifically, I have a lycoming O-290G model engine in
my airplane and since that engine was not designed for aircraft use, I
wonder If I have to comply with AD's on it. Also, other accessories and/or
avionics in my plane are not TSO'd so therefore I guess there would not be
any AD's on those either.

Its all a little confusing to me. Maybe someone can provide a quick answer
that makes it clear.

Thanks.

[Ron Wanttaja]

On Wed, 31 Mar 2004 23:36:21 -0500, "moby" > wrote:

>Maybe this topic has been brought up here before, But do
>homebuilt/experimental aircraft have to comply with Airworthiness Directives
>set forth by the FAA? specifically, I have a lycoming O-290G model engine in
>my airplane and since that engine was not designed for aircraft use, I
>wonder If I have to comply with AD's on it. Also, other accessories and/or
>avionics in my plane are not TSO'd so therefore I guess there would not be
>any AD's on those either.
>
>Its all a little confusing to me. Maybe someone can provide a quick answer
>that makes it clear.

No certification, no ADs. Short and clear enough?

Ron Wanttaja

[jp]

The one caveat I can think of is if you use a certified engine to get the 25
hour fly off time vice 40 hour time I think you'd probably be held to the
AD.
John


Ron Wanttaja wrote:

> On Wed, 31 Mar 2004 23:36:21 -0500, "moby" > wrote:
>
>>Maybe this topic has been brought up here before, But do
>>homebuilt/experimental aircraft have to comply with Airworthiness
>>Directives set forth by the FAA? specifically, I have a lycoming O-290G
>>model engine in my airplane and since that engine was not designed for
>>aircraft use, I wonder If I have to comply with AD's on it. Also, other
>>accessories and/or avionics in my plane are not TSO'd so therefore I guess
>>there would not be any AD's on those either.
>>
>>Its all a little confusing to me. Maybe someone can provide a quick answer
>>that makes it clear.
>
> No certification, no ADs. Short and clear enough?
>
> Ron Wanttaja

[Richard Riley]

On Thu, 01 Apr 2004 07:44:33 +0000, jp > wrote:

:The one caveat I can think of is if you use a certified engine to get the 25
:hour fly off time vice 40 hour time I think you'd probably be held to the
:AD.
:John

I've heard the same thing (though the version I've heard was certified
engine *and prop*)

But I've gotten a 25 hour fly off with a non-certified, modified
Lycoming and non-certified composite/wood prop. It looks like it's
whatever your DAR is comfortable with.

I comply with all the engine AD's I can, or at least take them as
serious warnings. Not because they're required, just because they
might be good ideas.

[Dan Thomas]

Ron Wanttaja > wrote in message >...
> On Wed, 31 Mar 2004 23:36:21 -0500, "moby" > wrote:
>
> >Maybe this topic has been brought up here before, But do
> >homebuilt/experimental aircraft have to comply with Airworthiness Directives
> >set forth by the FAA? specifically, I have a lycoming O-290G model engine in
> >my airplane and since that engine was not designed for aircraft use, I
> >wonder If I have to comply with AD's on it. Also, other accessories and/or
> >avionics in my plane are not TSO'd so therefore I guess there would not be
> >any AD's on those either.
> >
> >Its all a little confusing to me. Maybe someone can provide a quick answer
> >that makes it clear.
>
> No certification, no ADs. Short and clear enough?
>
> Ron Wanttaja

I would think that ADs against transceivers would apply, especially
if the defect would put the transmission parameters outside legal
limits. Ditto for ELTs.
In Canada, there's an AD that forces ALL aircraft owners to
pressure-check the exhaust system yearly or every 150 hours, whichever
comes first, if the system is used for cabin heat. No exceptions.

Dan

[nauga]

Richard Riley wrote:

> I've heard the same thing (though the version I've heard was certified
> engine *and prop*)

Like you say, it's *supposed* to be 25 hours for a certified
engine *and* *prop*, but there seem to be a lot of cases
where a certified engine alone gets you 25 hours. I also
know of at least one case where a non-certified engine got
25 hours. Like everything else, it depends on the inspector.
Personaly, I can't imagine feeling done after 25 hours. I've
got at least 50 hours planned, and that would apply regardless
of what engine and prop I used...but I can see the utility of
being able to leave the flight test area with less. I've got
a certified engine (an O320-D2C, apparently THE O320-D2C)
and experimental prop (Aymar-Demuth). I'm also slow as
molasses and only have about 5 hours on the airplane so far.

> I comply with all the engine AD's I can, or at least take them as
> serious warnings. Not because they're required, just because they
> might be good ideas.

Same here on all counts.

Dave 'creeper' Hyde
RV-4 Builder, EAA Tech counselor

[JDupre5762]

>>Maybe this topic has been brought up here before, But do
>>homebuilt/experimental aircraft have to comply with Airworthiness Directives
>>set forth by the FAA?

snip

>No certification, no ADs. Short and clear enough?

True for an airframe or experimental engine. But if the aircraft uses any
component such as an appliance or propeller or engine etc. then the AD's
against that comoponent would apply even if the aircraft it experimental.
Appliance ADs most often use a phrase such as "..is applicable on any aircraft
certificated in any category... That would cover the experimental category.

John Dupre'

[ET]

(JDupre5762) wrote in
:

>>>Maybe this topic has been brought up here before, But do
>>>homebuilt/experimental aircraft have to comply with Airworthiness
>>>Directives set forth by the FAA?
>
> snip
>
>>No certification, no ADs. Short and clear enough?
>
> True for an airframe or experimental engine. But if the aircraft uses
> any component such as an appliance or propeller or engine etc. then
> the AD's against that comoponent would apply even if the aircraft it
> experimental. Appliance ADs most often use a phrase such as "..is
> applicable on any aircraft certificated in any category... That would
> cover the experimental category.
>
> John Dupre'
>
>

ah....., no


--
ET >:)


"A common mistake people make when trying to design something
completely foolproof is to underestimate the ingenuity of complete
fools."---- Douglas Adams

[Ron Webb]

>
> No certification, no ADs. Short and clear enough?
>
> Ron Wanttaja


Short enough. Clear enough. But WRONG - at least according to my local FSDO.

Background:

Last year I ground looped my experimental (looks like a piper pacer, but
it's an experimental). Attracting the attention of the local FSDO. Bad move.

They went over my paperwork, and cited me for not complying with the AD's on
my Slick Mag and lift struts.

I pointed out the little passage in part 43 that says - er...what you just
said...

Their reply was that even experimentals are required to be "Airworthy".
Since an "AD" is an "Airworthieness Directive", it is declaring the affected
part "non-airworthy". Therefore I gotta fix it!

You see their logic. I even agree with it. (I have replaced the struts). But
it still ****es me off!
Is there an appeals process?

[ET]

"Ron Webb" > wrote in
:

>>
>> No certification, no ADs. Short and clear enough?
>>
>> Ron Wanttaja
>
>
> Short enough. Clear enough. But WRONG - at least according to my local
> FSDO.
>
> Background:
>
> Last year I ground looped my experimental (looks like a piper pacer,
> but it's an experimental). Attracting the attention of the local FSDO.
> Bad move.
>
> They went over my paperwork, and cited me for not complying with the
> AD's on my Slick Mag and lift struts.
>
> I pointed out the little passage in part 43 that says - er...what you
> just said...
>
> Their reply was that even experimentals are required to be
> "Airworthy". Since an "AD" is an "Airworthieness Directive", it is
> declaring the affected part "non-airworthy". Therefore I gotta fix it!
>
> You see their logic. I even agree with it. (I have replaced the
> struts). But it still ****es me off!
> Is there an appeals process?
>
>
>
>
>
>

Very ridiculous, since if you had used struts off a 69 ford fairlane, you
would have had no problem.... If this indeed ends up to be true, I will
endevour to use ZERO certified parts on my experimental.

--
ET >:)


"A common mistake people make when trying to design something
completely foolproof is to underestimate the ingenuity of complete
fools."---- Douglas Adams

[Del Rawlins]

In > Ron Webb wrote:
>>
>> No certification, no ADs. Short and clear enough?
>>
>> Ron Wanttaja
>
>
> Short enough. Clear enough. But WRONG - at least according to my local
> FSDO.
>
> Background:
>
> Last year I ground looped my experimental (looks like a piper pacer,
> but it's an experimental). Attracting the attention of the local FSDO.
> Bad move.
>
> They went over my paperwork, and cited me for not complying with the
> AD's on my Slick Mag and lift struts.
<snip>
> You see their logic. I even agree with it. (I have replaced the struts).
> But it still ****es me off! Is there an appeals process?

You can remove the data plate from your slick magneto and stamp "Webb
magneto model 1, serial number 1" on it and the AD will no longer apply
to it. Then it is just a surplus mag you found (that happens to take
Slick parts). As for the strut, I'd like to see them prove that it came
off one of the piper models that the AD applies to. For all they can
tell you built them in your garage, unless there are part numbers
visible on them, which I highly doubt.

Furthermore, there are two parts to the FAA's own legal definition of
the word "airworthy." In addition to being in condition for safe flight,
it requires compliance with type design. Since your experimental has no
type design, it can never be considered to be airworthy by their
definition. It sounds like your FSDO has a case of cranial rectitis but
now that you are on their radar it is probably easier to just do as they
say.

----------------------------------------------------
Del Rawlins-
Remove _kills_spammers_ to reply via email.
Unofficial Bearhawk FAQ website:
http://www.rawlinsbrothers.org/bhfaq/

[Scott]

We had an FAA seminar at my local airport about a week ago and I asked
the FSDO guy the same thing. He basically told me that, for example
your magneto AD, the AD must be complied with if the engine is
certified. He said the easiest way to make it uncertified was to remove
the manufacturer's data plate (ie Lycoming, Continental, etc). As far
as your lift struts, how does he know that they are production made
struts? You can build your own from stock from Aircraft Spruce, etc. I
personally defy my FSDO guy to find the yellow tag (paper trail as they
like to call it) for my struts.

Scott


ET wrote:
> "Ron Webb" > wrote in
> :
>
>
>>>No certification, no ADs. Short and clear enough?
>>>
>>>Ron Wanttaja
>>
>>
>>Short enough. Clear enough. But WRONG - at least according to my local
>>FSDO.
>>
>>Background:
>>
>>Last year I ground looped my experimental (looks like a piper pacer,
>>but it's an experimental). Attracting the attention of the local FSDO.
>>Bad move.
>>
>>They went over my paperwork, and cited me for not complying with the
>>AD's on my Slick Mag and lift struts.
>>
>>I pointed out the little passage in part 43 that says - er...what you
>>just said...
>>
>>Their reply was that even experimentals are required to be
>>"Airworthy". Since an "AD" is an "Airworthieness Directive", it is
>>declaring the affected part "non-airworthy". Therefore I gotta fix it!
>>
>>You see their logic. I even agree with it. (I have replaced the
>>struts). But it still ****es me off!
>>Is there an appeals process?
>>
>>
>>
>>
>>
>>
>
>
> Very ridiculous, since if you had used struts off a 69 ford fairlane, you
> would have had no problem.... If this indeed ends up to be true, I will
> endevour to use ZERO certified parts on my experimental.
>

[Ron Webb]

>
> You can remove the data plate from your slick magneto and stamp "Webb
> magneto model 1, serial number 1" on it and the AD will no longer apply
> to it.

Yes. That's what they told me to do with the engine (a modified IO-360).
Can't just remove the data plate (I'd done that). Didn't know I'd have to do
that even to the Mags, but I guess so. I don't have trouble with the mag AD
anyway. That inspection I can do - and sign off - myself.

> As for the strut, I'd like to see them prove that it came
> off one of the piper models that the AD applies to. For all they can
> tell you built them in your garage, unless there are part numbers
> visible on them, which I highly doubt.
>

As for the struts, I could have just replaced the forks (they are
recognizable as the small sized forks that were notorious for cracking. Mine
were new, but who needs a cracked strut - it's NICE if the wings stay
attached like they're s'posed to. And once I'd decide to replace them, the
whole strut wasn't much more of a stretch.

> It sounds like your FSDO has a case of cranial rectitis

Cranial WHAT? How'd you know his name??

Naw - he was really a nice enough fella, but his word was LAW, and he knew
it! It seems I'm "guilty until proven innocent", and there is no practical
way to challenge their decrees short of a $Lawyer$.

> now that you are on their radar it is probably easier to just do as they
say.

Yep.