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Owner pilot maintenance of an E-AB airplane without repairman's certificate?

Interestingly, I searched the entirety of Part 91 subpart E for the word "configuration".

"No matches found"...


Did you find anything that discussed “conformance with the Type Certificate”? (that’s FAA speak for “Configuration Management”)


...Safety is "incidental"? An interesting view of the regulations. Perhaps not incorrect, I guess...

Consider this - I know of someone who owns an antique, type certificated aircraft which is equipped with neither brakes nor a tail wheel (skid only). Application for a retrofit for both has hit a wall with the Feds because there is no such equipment listed on the TC, nor is there an STC. This is an extreme example of the need for the Fed to maintain "configuration" as paramount - even to safety. And there are many, many more examples of safety advances that we take for granted today that are simply not allowed on antique TC'd aircraft. Any type specific blog will be filled with examples.

In most cases though, maintaining the TC does “ensure” a safe aircraft, so yes, safety is incidental to the primary requirement.
 
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.....Consider this - I know of someone who owns an antique, type certificated aircraft which is equipped with neither brakes nor a tail wheel (skid only). Application for a retrofit for both has hit a wall with the Feds because there is no such equipment listed on the TC, nor is there an STC. This is an extreme example of the need for the Fed to maintain "configuration" as paramount - even to safety. And there are many, many more examples of safety advances that we take for granted today that are simply not allowed on antique TC'd aircraft. Any type specific blog will be filled with examples.

In most cases though, maintaining the TC does ?ensure? a safe aircraft, so yes, safety is incidental to the primary requirement.

The FAA does make allowances for antique aircraft to have configuration changes, either as a "minor change" or with a 337....

Link to AC 23-27

There must be more to this particular story....:)
 
Did you find anything that discussed ?conformance with the Type Certificate?? (that?s FAA speak for ?Configuration Management?)

I guess I should indicate more clearly when I'm being snarky.

And to answer your question...nope. Nary a word.
 
It strikes me how similar this debate is to the whole “AD’s are required on E-AB” we used to have. Even after EAA as an organization came out with a very clear statement that E-AB’s were exempt, people still couldn’t separate “THE process” from “an element within that process". I suppose there are still some out there that still want to believe, though even the Feds have conceded. It’s the same square peg/round hole situation we are discussing here.

Only this one is even LESS of a fit.

Yes, the regs state we need to “maintain records…”, but there is a lot more to maintaining records than simply ink in a logbook. Maintaining aircraft records is a process which includes proper validation, tracking and documentation of parts replaced, adherence to the manufacturer’s maintenance data, review of the TC to ensure continued compliance, and certification/approval (backed up by a certificate number) that the aircraft can return to service. The ink on the page is nothing more than the evidence that the process is complete. With a TC aircraft, the regs mesh perfectly with this process and it makes sense from beginning to end – round peg, round hole.

With an E-AB however, you are missing many critical elements of the process:

-Parts replaced are not serially nor configuration controlled (can’t verify their provenance);

-There are no manufacturers instructions to adhere to;

-The aircraft has no set standard/configuration to maintain:

-The mechanic may not be trained or hold a “certificate number” (a specific requirement of the reg, remember?) which ensure a minimum skill/competency.

The best we can do is the last step - scribble in a logbook. But without the process in place, that entry has about as much regulatory value as your 3 year old with a box of crayons. Round peg, square hole.

Now, I’ll admit that it is not above the Feds to require worthless “checking the box” or “going through the motions” effort, but it should be clear to everyone that with the exception of the crystal clear requirements for who and how to document a Condition Inspection and a few other very "E-AB specific" actions, the regs as they stand today are a very poor fit for routine E-AB maintenance. If anyone wants to gloss over the many significant discontinuities in the regs with: "...they just haven't fixed it yet..." and give them full benefit of the doubt, that’s fine by me. But it's going to have to be a more compelling argument than I've seen yet before I change my mind.
 
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Can someone please point to the source that will explain what maintenance an owner pilot of an E-AB airplane can perform who does not have the repairman's certificate for that airplane. I need to replace the electric fuel pump (Facet 40108) on my RV and would like to know if I am required to have an A&P do the work, or am I permitted to do it myself.

Thanx.

Victor

There's been a lot of info on the thread about this, and sounds like you got your answer for the maintenance part. Here's a link to some FAQ's and I pasted the EAA has to say about about it.

Q. I?ve seen some amateur-built aircraft with very detailed maintenance records, and some that are much less complete. Aren?t there regulations that govern recording of aircraft maintenance? What is required to be in the aircraft logs?

A. The regulations regarding aircraft maintenance and the recording of same are found in FAR Part 43. However, the first section of Part 43 talks about the applicability of the part. Taking a look at Part 43.1(b) we find 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.

An amateur-built aircraft receives an experimental airworthiness certificate at the very beginning, so this section tells us that the regulations found in Part 43 do not apply. That being the case, none of the record-keeping requirements of Part 43 are applicable. The only entries that are strictly required are those found in the aircraft?s operating limitations, issued by the FAA as a part of its airworthiness certificate. Mainly this would be condition inspections each year and the flight test sign-off, along with transponder tests (if a transponder is installed) and pitot/static tests if the aircraft is to be flown under instrument flight rules. There is no strict guidance on what to put (or what not to put) in an amateur-built aircraft logbook other than what is required by the aircraft?s operating limitations.

At the time of the airworthiness inspection by the FAA, the owner of the aircraft, whether or not he/she is the builder, will be required to record that a condition inspection has been completed on the aircraft prior to the FAA inspection. This initial condition inspection is recorded using the same language as later condition inspections, as follows:

I certify that this aircraft has been inspected on [insert date] in accordance with the scope and detail of Appendix D to Part 43, and was found to be in a condition for safe operation. [signature], Owner

The FAA also likes to see at least one hour of ground testing recorded in the aircraft records. This is not a strict regulatory requirement, but is very common among airworthiness inspectors.

The other requirement is for the flight testing to be properly recorded. The aircraft?s operating limitations will contain the appropriate language to use for closing out the flight-test period, as shown here:

I certify that the prescribed flight test hours have been completed and the aircraft is controllable throughout its normal range of speeds and throughout all maneuvers to be executed, has no hazardous operating characteristics or design features, and is safe for operation. The following aircraft operating data has been demonstrated during the flight testing: speeds VSO ______, VX ______, and VY ______, and the weight ______ and CG location ______ at which they were obtained. [Aircraft total time], [signature], [type of pilot certificate and certificate number]

Other than this, the annual condition inspections, and documentation of major changes as directed by the aircraft?s operating limitations, there isn?t any regulatory requirement to log anything! Of course EAA recommends a ?best practice? of proper logging of all maintenance in accordance with Part 43 even though it?s not strictly required. This not only promotes safety by having a record of what has been done to the aircraft, but also increases the value of the aircraft at the time of sale.
 
There's been a lot of info on the thread about this, and sounds like you got your answer for the maintenance part. Here's a link to some FAQ's and I pasted the EAA has to say about about it.

Interesting FAQ.... It would be nice to hear the authors opinion on 91.417....:)

His whole description of the ARROW document requirements quote Part 91 rules, not Part 43 which exempts Homebuilts. It seems like the FAQ is cherry picking the rules (and the FAR parts) they think you should follow.

I wonder if the answers were actually written by multiple authors?
 
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I'm sure it's written by several authors, perhaps decades apart even. But I believe this type of article is a compilation of EAA's "party line". I suspect that all EAA personnel will cite substantially the same answers when asked. Unlike the FAA, EAA has a much better track record of keeping their story straight. Of course, that's easier to do when your "story" is based upon logic rather than simply regurgitation of beurocratic nonsense as the FAA/FSDO personnel seem to do.
 
Interesting FAQ.... It would be nice to hear the authors opinion on 91.417....:)

His whole description of the ARROW document requirements quote Part 91 rules, not Part 43 which exempts Homebuilts. It seems like the FAQ is cherry picking the rules (and the FAR parts) they think you should follow.

I wonder if the answers were actually written by multiple authors?

I don't have my Ops Limits handy and don't recall if paragraph (9) is in there, but here's the EAA page on their interpretations of the "standard" Ops Limits for EABs:

http://members.eaa.org/home/govt/issues/samateur_built_operating.asp

"(9) Aircraft instruments and equipment installed and used under ? 91.205 must be inspected and maintained in accordance with the requirements of part 91. Any maintenance or inspection of this equipment must be recorded in the aircraft maintenance records.

EAA Position: This is speaks for it?s self ? record what you or your mechanics do to your aircraft."

So...I guess EAA itself has different opinions depending upon which page you read.
 
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