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  #1  
Old 07-16-2019, 02:25 PM
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Ed_Wischmeyer Ed_Wischmeyer is offline
 
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Default ADs that Homebuilt Must Comply With

When I was getting the new operating limitations for the RV-9A (constant speed prop = major modification = new operating limitations), one of the things I had to do was to check for AD compliance. What?

Chapter and verse is AC 39-7D, dated 3/2/12, Section 9 (b) (2) gives this example text: " “This AD applies to Lycoming Engines Models AEIO-360-A1A and IO-360-A1A. This AD applies to any aircraft with the listed engine models installed.” This statement makes the AD applicable to the listed engine models installed on TC’d and non-TC’d aircraft. "

If an AD is issued, it's probably for good reason, and it makes sense to comply, even if not required. However, just because it's an experimental doesn't give you a free ride from all ADs. Some may apply.

Kudos to Mark Fayerman of the Atlanta FSDO for helping me through the process, and the friendly inspector who actually looked at the plane was Mike Denaro. The airplane inspection itself was the data plate, making sure I had the passenger warning installed, and a general walkaround.

The new Airworthiness and Operating Limitations are printed together on two sheets of very stiff paper, front and back.
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  #2  
Old 07-16-2019, 03:31 PM
rvbuilder2002 rvbuilder2002 is offline
 
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All depends on who you are talking too.

There is letter that was published (after EAA pushed for an official response some years ago) by the FAA legal department stating specifically that AD's do not apply to an aircraft with an experimental airworthiness certificate.

If that has changed, it is not being universally followed.
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  #3  
Old 07-16-2019, 07:05 PM
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bhester bhester is offline
 
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Default Where is the letter?

Sure would be nice to see this letter. Anybody have a link to it?
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  #4  
Old 07-16-2019, 07:57 PM
jacoby jacoby is offline
 
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Quote:
Originally Posted by bhester View Post
Sure would be nice to see this letter. Anybody have a link to it?
I found this link that includes the text: http://starduster.aircraftspruce.com...ges/25960.html

However the links are dead and I cannot find anything on EAA's site.

From my 5 min of research, the FAA AC 39-7D appears to be the current interpretation of the situation, specifically this passage:

Quote:
b. Non-TC’d Aircraft and Products Installed Thereon. Non-TC’d aircraft
(e.g., amateur-built aircraft, experimental exhibition) are aircraft for which the FAA has not issued a TC under part 21. The AD applicability statement will identify if the AD applies to non-TC’d aircraft or engines, propellers, and appliances installed thereon. The following are examples of applicability statements for ADs related to non-TC’d aircraft:
So, in the prior quoted example, if you have an "AEIO-360-A1A" from Lycoming you are required to comply with the AD.
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  #5  
Old 07-16-2019, 08:44 PM
PilotjohnS PilotjohnS is offline
 
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Quote:
Originally Posted by jacoby View Post

From my 5 min of research, the FAA AC 39-7D appears to be the current interpretation of the situation, specifically this passage:



So, in the prior quoted example, if you have an "AEIO-360-A1A" from Lycoming you are required to comply with the AD.
So if I have a XIO-320-xxx it doesnt apply to me. Cant anybody rename there engine as a SOGO 22?
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  #6  
Old 07-16-2019, 08:57 PM
NewbRVator NewbRVator is offline
 
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Good question. An AD applicable to an engine (say an O-360 A1A) if installed in an “Experimental” would likely ring the bell of an A & P but if the builder is doing the CI’s does the AD need to be satisfied to follow the letter of the law?

Thanks
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  #7  
Old 07-16-2019, 09:32 PM
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GalinHdz GalinHdz is offline
 
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Quote:
Originally Posted by rvbuilder2002 View Post
There is letter that was published (after EAA pushed for an official response some years ago) by the FAA legal department stating specifically that AD's do not apply to an aircraft with an experimental airworthiness certificate.
This statement is 100% correct, "AD's do not apply to an AIRCRAFT with an experimental airworthiness certificate." BUT if the AD is issued to a piece of equipment, not an aircraft, then the AD applies to the piece of equipment regardless of what aircraft it is installed in. Don't confuse aircraft AD's with equipment AD's they are apples and oranges.
Quote:
Originally Posted by PilotjohnS View Post
Can't anybody rename there engine as a SOGO 22?
As long as the engine identification data plate indicates a "SOGO 22" then you are good to go. But if you keep it as a Lycoming O360-A1A then you must comply with any AD issued for the Lycoming O360-A1A no matter what airframe it is installed.

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Last edited by GalinHdz : 07-16-2019 at 09:56 PM.
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  #8  
Old 07-16-2019, 11:18 PM
rvbuilder2002 rvbuilder2002 is offline
 
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Quote:
Originally Posted by GalinHdz View Post
This statement is 100% correct, "AD's do not apply to an AIRCRAFT with an experimental airworthiness certificate." BUT if the AD is issued to a piece of equipment, not an aircraft, then the AD applies to the piece of equipment regardless of what aircraft it is installed in. Don't confuse aircraft AD's with equipment AD's they are apples and oranges.

As long as the engine identification data plate indicates a "SOGO 22" then you are good to go. But if you keep it as a Lycoming O360-A1A then you must comply with any AD issued for the Lycoming O360-A1A no matter what airframe it is installed.

Ok, I shouldn't have spoken in generalities (by saying aircraft).

The point is still valid. The wording in AC 39-7D covers it. They only apply if within the AD it specifically states that it is applicable to a non-TC'ed component. (BTW this is the verbiage that the EAA campaigned for for quite a while and finally made happen).
I don't remember ever seeing that specified in any AD issued against engines or components that we commonly use in RV's.

BTW, I am in no way advocating NOT complying with AD's on experimental aircraft (my position is that in most cases they should be).... just that there is no regulatory requirement to do so.
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Last edited by rvbuilder2002 : 07-16-2019 at 11:21 PM.
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  #9  
Old 07-16-2019, 11:35 PM
SHIPCHIEF SHIPCHIEF is offline
 
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Just for fun, let me throw in a twist:
When I changed to a Lycoming engine in my RV-8, I got an IVO-360A1A from a Brantley Helicopter. I had to change it to a horizontal engine, so I altered the data to an XIVO-360A1A and kept the same logbook.
How to fit this into the discussion???
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  #10  
Old 07-17-2019, 05:46 AM
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GalinHdz GalinHdz is offline
 
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Quote:
Originally Posted by SHIPCHIEF View Post
Just for fun, let me throw in a twist:
When I changed to a Lycoming engine in my RV-8, I got an IVO-360A1A from a Brantley Helicopter. I had to change it to a horizontal engine, so I altered the data to an XIVO-360A1A and kept the same logbook.
How to fit this into the discussion???
Logbook is irrelevant. What does the data plate say? If it says LYCOMING IVO-360A1A then AD's for the LYCOMING IVO-360A1A apply. If the data plate says XIVO-360A1A (or whatever) then it is no longer a LYCOMING IVO-360A1A and those AD's don't apply. FWIW I would make sure both the logbook and data plate reflect the new XIVO-360A1A designation.

If the FAA ever put out an AD for the XIVO-360A1A engine, you would have to comply with it. But the LYCOMING IVO-360A1A is a different engine so compliance not required since they are two different engines. BTW I have never heard anything like that happening but you never know.

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Last edited by GalinHdz : 07-17-2019 at 05:52 AM.
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