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ELSA's, Airworthiness Directives, and Form 8130-6

Tacco

Well Known Member
I learned something today...ok, its a low bar.

While working with my DAR (Gary Brown) filling out the 8130-6 correctly, he had me insert the number of the biweekly series of the AD Supplement (found on the FAA website) in the Airworthiness Directives block In section III. The block says to "Check if all applicable ADs are complied with and give the number of the last AD SUPPLEMENT...". I had entered "None" thinking - experimental category, non certified engine, AD's don't really apply. Not so fast!

Taking a second look, I thought I'd read through the list on the bi-weekly one more time thinking maybe there are certified/TSO'd components Van's has used that might be subject to an AD. Didn't find any but...I did find this:

Listed under "Various Aircraft" was AD 2018-03-05. It concerns ROTAX push-rod assemblies on their certified engines. That AD sources to ROTAX Service Bulletin 912-070 R1...which has a companion SB 912-070UL... Continued...
 
?for their non-certified engines.

Fortunately, Van?s is looking out for us and covered this in their SB 17-10-14. And if you?re registered with ROTAX, you get their bulletins as well. And for my engine, which was affected, ROTAX had made the repair before they shipped it to me and noted it in the log book.

Lesson learned: Don?t assume you?re not subject, in a practical sense, to an AD. Yes, the non-certified 912 ULS was not listed in the AD?but the problem existed in the ULS never the less.

For what its worth?
 
It is a complicated world with the FAA.....

FAA legal has gone on record to say that AD's do not apply to "Experimental" aircraft, but there are different divisions of the FAA that still have requirements that are totally contrary to that.

In the end, it is best to do whatever is being requested (within reason), and move on with a further reinforced understanding that "It is a complicated world with the FAA....."
 
No one told me to comply with the AD. I think my point was that without Van's and Rotax supporting their products, I would have never known there was a safety issue affecting my aircraft documented in an AD. I have no issue with complying with FAA AD's. I would have not considered my aircraft airworthy without complying with this AD even though it did not formally list my aircraft or engine.

Further, only the Rotax SB was MANDATORY. That doesn't necessarily mean compliance is required unless accompanied by the AD...which, again, did not mention the 912 ULS.

I'm not advocating the position that AD's apply to EAB/ELSA'a. I'm saying that in a self policing community such as ours, you have to be diligent. Hope that makes sense.

Safety shouldn't be complicated.
 
I'm not advocating the position that AD's apply to EAB/ELSA'a. Safety shouldn't be complicated.

And I wasn't meaning to imply that people shouldn't comply with AD's just because their airplane is experimental. I think it is a good idea to do so.

I was just commenting on the double standard....
That to get an airworthiness certificate, you are required to that you have complied with something that you aren't required to comply with...........
 
I'm not advocating the position that AD's apply to EAB/ELSA'a. I'm saying that in a self policing community such as ours, you have to be diligent.

I was just commenting on the double standard....
That to get an airworthiness certificate, you are required to that you have complied with something that you aren't required to comply with...........

There is an overlying requirement that many (most?) people fail to connect with this discussion. That is, you are required to assure that the aircraft is in a "condition for safe operation". This is the airworthiness standard for aircraft operating under a special airworthiness certificate.

So, while you are not legally required to strictly comply with an AD (even when making initial application for an airworthiness certificate), you ARE required to show that the aircraft is in a condition for safe operation. If there is an AD that may apply to a component installed in or on your aircraft, and you do not strictly comply with that AD, then you must show some alternate means of addressing the known safety issue that the AD points out. You can use whatever method you wish to address the safety issue, but you must show some method of addressing it.

So there really isn't a "double standard". The standard is that the aircraft must be in a condition for safe operation. This is required by the aircraft's operating limitations, and thus required by regulation. You can assure this condition by either complying with any applicable ADs, or you can do so by addressing these known safety issues in a manner that you find appropriate. Just be ready to defend your choice in front of an FAA administrative law judge if you ever have an accident or incident that may involve the known safety issue.

Now, if you are looking for a 25 hour flight test period for your amateur-built aircraft, because you have installed an engine/prop combination that is found on a type certificate, you MUST comply with ADs on the engine and/or prop in order to get the 25 hours. If you don't, your flight test period will be 40 hours.

Hope this helps!
 
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