Experimental category, maintenance, parts, and continuedairworthiness requirements

As the owner of a "new" 1985 DG-400, registered Experimental Exhibition/Racing, I'm trying to get a handle on what the FARs require. I have a mercifully short, ten-point set of Operating Limitations issued in 1989. Paragraph 4 states "The cognizant FAA Flight Standards District Office must be notified prior to flying this aircraft after incorporating a major change as defined by FAR 21.93." Paragraph 6 requires an annual condition inspection in accordance with Appendix D, Part 43; Paragraph 7 requires that an A&P or official repair station perform the annual; and 9 requires that the condition inspections be recorded in the aircraft maintenance records. The other paragraphs relate to general operating rules of FAR 91; placards and markings required by 91.31; acrobatics; no glider towing; day VFR only; and no flight over densely populated areas other than for takeoffs and landings.

There is no language requiring that maintenance and repairs be done in accordance with the approved maintenance manual or official requirements for continued airworthiness. There is no reference at all to the POH, aircraft manual, or maintenance manual.

Questions a

Can I do work beyond preventive maintenance specified in 43.3, without having this work supervised by an A&P?

Major changes require notification of the FSDO, so this means that the glider will remain essentially as it was delivered to the US. But, it does not have to conform to the German type certificate, as it would if it had a Standard AW certification?

If that is true, must the glider conform to DG's requirements for continued airworthiness? For example, those requirements state that the Rotax 505 must be totally overhauled at 300 hours, and that the seatbelt webbing must be replaced every 12 years. Is this legally required? (Leaving aside the question of whether these sorts of things are advisable.)

May parts be substituted - for instance, may I use a fuel filter other than the official DG part, if, as the person doing the maintenance, I determine that this substitution constitutes a minor change?

Thanks in advance for sharing your collective experience with these issues.

You can do more work on the glider than what is listed as "owner approved preventive maintenance", review what part 43 refers to as "major modification". Just remember that what ever you do needs to be acceptible to the A&P that is going to sign off the next condition inspection. He is certifying that the glider is still in conformance with the TCDS as it was imported. I would suggest you use DG parts as much as possible, if you feel a different filter is better, does not restrict flow you can say it is a suitable replacement. But be sure your A&P agrees. Be sure any work you do is in accordance with accepted practices in Part 43. Get the maintenance manuals, referring to them is more acceptable to the A&P and the FAA. Use aircraft approved hardware, if a bolt needs to be replaced, use an aircraft bolt, not an Ace Hardware special. Use approved aircraft wiring, not lamp cord.

Make good friends with an A&P knowledgable in gliders and Rotax engines, make sure he knows what you do, see advice. The glider will maintain value, shoddy work or obvious non approved parts will make the entire glider suspect at resale and decrease its value.

BT

Paul,

Read CFR part 43.1 (b) (1).

If your DG-400 has never been issued an Airworthiness Certificate other than Experimental then Part 43 does not apply. Some early production DG-400 were imported before the Type Certificate was issued and were therefore issued an Experimental Airworthiness Certificate.

If however your glider was issued a Standard Airworthiness certificate, or any other kind of Airworthiness Certificate, and someone later got an Experimental certificate issued then Part 43 does apply to your glider.

Robert Mudd
A&P I.A.
Composite Aircraft Repair
Moriarty, New Mexico

On Friday, April 4, 2014 5:08:49 PM UTC-7, Paul Villinski wrote:
As the owner of a "new" 1985 DG-400, registered Experimental Exhibition/Racing, I'm trying to get a handle on what the FARs require. I have a mercifully short, ten-point set of Operating Limitations issued in 1989. Paragraph 4 states "The cognizant FAA Flight Standards District Office must be notified prior to flying this aircraft after incorporating a major change as defined by FAR 21.93." Paragraph 6 requires an annual condition inspection in accordance with Appendix D, Part 43; Paragraph 7 requires that an A&P or official repair station perform the annual; and 9 requires that the condition inspections be recorded in the aircraft maintenance records. The other paragraphs relate to general operating rules of FAR 91; placards and markings required by 91.31; acrobatics; no glider towing; day VFR only; and no flight over densely populated areas other than for takeoffs and landings.



There is no language requiring that maintenance and repairs be done in accordance with the approved maintenance manual or official requirements for continued airworthiness. There is no reference at all to the POH, aircraft manual, or maintenance manual.



Questions a



Can I do work beyond preventive maintenance specified in 43.3, without having this work supervised by an A&P?



Major changes require notification of the FSDO, so this means that the glider will remain essentially as it was delivered to the US. But, it does not have to conform to the German type certificate, as it would if it had a Standard AW certification?



If that is true, must the glider conform to DG's requirements for continued airworthiness? For example, those requirements state that the Rotax 505 must be totally overhauled at 300 hours, and that the seatbelt webbing must be replaced every 12 years. Is this legally required? (Leaving aside the question of whether these sorts of things are advisable.)



May parts be substituted - for instance, may I use a fuel filter other than the official DG part, if, as the person doing the maintenance, I determine that this substitution constitutes a minor change?



Thanks in advance for sharing your collective experience with these issues.

Paul,
Looks like you were issued the old operating limitations. Today they would state "Aircraft will be operated in accordance with the flight manual and maintained in accordance with the maintenance manual".

Deviate from these manuals at your own risk.
JJ

Thanks for helping to clarify this. My glider was imported prior to the issuance of the German TC. CFR part 43.1 (b) (1) is certainly very clear. I guess the operating limitations become the primary document concerning these issues.... JJ, I actually currently have another glider registered Experimental, with a recent set of operating limitations, and they do state that the glider must be operated and maintained in accordance with the manuals. Let me reassure you that I would never deviate from operating in accordance with the POH. My question really centered around whether I could legally undertake work on the engine myself, and whether I could make what I deem to be intelligent minor parts substitions, i.e., changing to iridium spark plugs, for instance. I also see that requirements in the maintenance manual such as changing seat belt webbing every twelve years has not been complied with, so wondered whether this rendered the glider non-airworthy from a legal perspective. I'm a bit of a gear-head and DIYer, so I'm happy to learn that I won't be breaking the law if I replace my own carburetor diaphrams....

On Thursday, April 10, 2014 9:36:15 AM UTC-6, Paul Villinski wrote:
Let me tell you a funny seat belt story. I owned an 78 model ASW20 and the webbing looked like it was due so I took it to a Master Rigger buddy of mine who is Certificated by the FAA to make repairs to seat belts. He let me pick the color and strength rating (Which ended up being twice the original for the same weight) and we reused the hardware. When it was all done he signed the log book and I had a very nice set of belts that matched the interior of my ship. Then it hit the fan! I told some people what I did and posted my experience on an owners group (Plus the fact that this cost only 90 bucks) and you would would have thought I was a major criminal by the negative response I received. The big issue most pilots had was that there is no TSO tag. One local wiener got up in my face on the grid about this but he could not explain why my belts are illegal. So I called the FAA and worked my way up the ladder till I got THE person who is responsible for compliance of imported aircraft for the NW Region. I was assured in no uncertain terms (The rep sounded like she was tired of answering this question) that any experimental regardless of exhibition & racing, amateur built, etc, does NOT need to use approved parts.
I think part of the problem is that these gliders at Certificated to JAR or EASA standards but they are maintained to Part 43 standards. Two different standards with room for grey areas.