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Your new RV just got way more expensive to maintain

gasman

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Unless Paul posted this year's April Fools joke in the May issue of Kitplanes, owning a new RV will come with some expensive maintenance that was not even required on your old PA -28 that you were glad to leave behind for your new RV.

Take a look at page 3 of the May issue, Editor's Log Fine print......

"For instance, the latest ops lims have a paragraph that requires all life and overhaul time limits recommended by manufacturers to be observed. In simple terms, that means that if you have a Lyocming engine with a TBO of 2000 hours or 12 years (whichever comes first), you MUST have it overhauled when you reach the first of those limits."

That would be 166 hours per year. Think about the value of your RV, 12 years from now when the prop and motor is required to be overhauled. I sure hope the EAA will step in and correct this issue.

Or am I the only one that Paul caught with this April fool...........:confused:
 
Perhaps someone could post a link to the latest operating limitations.
 
This is a misunderstanding of the op limits. TBO is not and never has been a "life limit". TBO is a "recommendation".
 
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An overhaul at TBO is not required even for type certificated aircraft operated under part 91 (non-commercial.)

Edit- I looked up this article on Kitplanes website and Paul even points this out in the same paragraph. This sounds like a job for the EAA government advocacy folks to work on, and I'd be surprised if they weren't already.

Here'e the link, but you must be a Kitplanes subscriber to read the on-line version.

http://www.kitplanes.com/issues/36_5/exploring/Editors-Log-Fine-Print_22363-1.html
 
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Since the subject has been brought up and I am in search of a new RV what are the feelings about the 12 year TBO on overhauls. Quite a few of the aircraft I am looking at exceed that limit. Sellers seem to dismiss it and claim no one pays any attention and hours are the only thing that matters. If a engine is well maintained with proper soft parts replacement should it be a factor in a purchase decision. One aircraft has a 19 year since the overhaul on the motor that was stored for 6 years before installation and now has 850 hours.
George
 
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The article does appear to say what the OP states regarding new operating limitations.

If your operating limitations make such a statement, aren't you required to comply (assuming you wish to fly with a valid airworthiness certificate)?
 
The article does appear to say what the OP states regarding new operating limitations.
If your operating limitations make such a statement, aren't you required to comply (assuming you wish to fly with a valid airworthiness certificate)?

You are correct on both counts. Current op lims do not mention "recommended limits".

If your op lims DO contain such language, you must comply. OTOH, if your op lims contain this language, you should contact you local FSDO or DAR and have them corrected to the current language.

For what it's worth, the paragraph in question should not be in our op lims anyway as it does not apply to amateur-built aircraft. I have fought to have it removed since the new order first came out. I am still working on it and still have hope.
 
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Unless Paul posted this year's April Fools joke in the May issue of Kitplanes, owning a new RV will come with some expensive maintenance that was not even required on your old PA -28 that you were glad to leave behind for your new RV.

Take a look at page 3 of the May issue, Editor's Log Fine print......

"For instance, the latest ops lims have a paragraph that requires all life and overhaul time limits recommended by manufacturers to be observed. In simple terms, that means that if you have a Lyocming engine with a TBO of 2000 hours or 12 years (whichever comes first), you MUST have it overhauled when you reach the first of those limits."

That would be 166 hours per year. Think about the value of your RV, 12 years from now when the prop and motor is required to be overhauled. I sure hope the EAA will step in and correct this issue.

Or am I the only one that Paul caught with this April fool...........:confused:

Disclaimer: I am not a DAR or DER.

Need more context. What's the wording of the limitation?

Order 8130.2J is the latest document specifying operating limitations for homebuilts. There's no such limit requiring you to overhaul your engine there.

Now, 8130.2J does show limitation (2) in Table D-1 as follows:
The aircraft may not be operated unless the replacement for life-limited articles specified in the applicable technical publications pertaining to the aircraft and its articles are complied with in one of the following manners:
(a) Type-Certificated Products: Replacement of life-limited parts required by ? 91.409(e) applies to experimental aircraft when the required replacement times are specified in the U.S. aircraft specifications or type certificate data sheets.
(b) Non-Type-Certificated Products: All articles installed in non-type-certificated products operated under an airworthiness certificate issued for an experimental purpose, in which the manufacturer has specified limits, must include in their program an equivalent level of safety for those articles. These limits must be evaluated for their current operating environment and addressed in the approved inspection program. All articles installed in non-type-certificated products in which the manufacturer has specified limits, must include in their program an equivalent level of safety for those articles. The article must be inspected to ensure the equivalent level of safety still renders the product in a serviceable condition for safe operation. (20)
As Mel notes, recommendations =/= life limits. Life limits have very specific legal definitions and they are very clearly spelled out in somewhere like a TCDS (Type Certificate Data Sheet) or in an applicable approved maintenance document (e.g. the "Time Limits" and "Airworthiness Limitations" sections in Chapter 5 of a large jet's maintenance manual). Even if we install certified Lycoming engines, they do not come with a life limit specified in on the TCDS or in the applicable Operator's Manual (O-360 manual as an example). And finally, all of the guidance from Lycoming regarding TBO is explicitly worded as "recommendation".

By contrast, if you were use one of the Centurion diesels--e.g. a Centurion 4.0 BE-250 (TCDS E00079EN), note 6 specifically says "Centurion 4.0 engine is Life-Limited. The core engine must be removed from service in accordance with the Airworthiness Limitations Section, Chapter 5 of the Operation & Maintenance manual OM-03-01 (US-Version)." By my read of this operating limitation, installing this engine would place a hard life limit on your engine.

I do not know what the legal effect of obtaining such an engine, tearing it apart and rebuilding it, and calling it an experimental "Kitbuilder 250" engine (or whatever) would be.


Edit: Upon further reflection I think some of this is mean to apply to, say, S-SLA aircraft. Those aircraft don't have a TCDS but the manufacturer can require time limits. And if your S-SLA uses a certified engine with a time limit, you would be required to abide by that. Again, I'm no DAR but I'd agree with Mel that I wouldn't expect that this should apply to E-AB.

Edit 2: This limitation refers to "articles" which is a term with a specific definition in Part 21 (which concerns "certification procedures for products and articles"). My read would be that references to "articles" in the operating limitations means "articles approved under Part 21 procedures". If your particular component isn't approved via TC, PMO, TSO, etc. then even if the manufacturer does specify some kind of life limit, I don't see how it could be legally binding.

Edit of edit 1: Mel has pointed out below that S-SLA aren't included here. Unfortunately we lack a strikethrough format command.


This also makes me wonder what the applicability would be to the reuse of life-limited parts (e.g. landing gear) salvaged from a certified aircraft.
 
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Welllll
Maybe
This is talking about life limited "BRS" and the like.
It may not be directed to the engine at all.
 
Edit: Upon further reflection I think some of this is mean to apply to, say, S-LSA aircraft. Those aircraft don't have a TCDS but the manufacturer can require time limits. And if your S-SLA uses a certified engine with a time limit, you would be required to abide by that. Again, I'm no DAR but I'd agree with Mel that I wouldn't expect that this should apply to E-AB.

Your entire post is very well stated. As a point, S-LSA are certificated under 21.190 which does not include the paragraph in question.
 
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I called EAA Government Relations and Paul Dye is correct. This limitation has been on the books for years and was meant to apply to heavy jet warbirds and the like. For some reason some FSDOs have been issuing this to regular homebuilts. If applied universally it would kill homebuilding. They are aware of this and hope to have it fixed before Oshkosh.
 
You are correct on both counts. Current op lims do not mention "recommended limits".

If your op lims DO contain such language, you must comply. OTOH, if your op lims contain this language, you should contact you local FSDO or DAR and have them corrected to the current language.

For what it's worth, the paragraph in question should not be in our op lims anyway as it does not apply to amateur-built aircraft. I have fought to have it removed since the new order first came out. I am still working on it and still have hope.

Great news. I have an appointment with the North Dallas FSDO in 2 weeks to get my new AW certificate due to a N change. I've had the worst experience with one of the inspectors, seems he has no clue how to do anything. If my Ops Limits contain this wording I'll ask to have them removed but if I get the same guy I know it's going to be another fight !

On that note, what about if the limitations say no aerobatics for an RV-8, can that also be removed when I go get the new AW certificate and limitations?
 
I’m glad that this has generated discussion - that was the intended purpose!

I have gotten numerous letters on the topic, on both sides of the possible interpretation, both from builders/owners and from DAR’s/FAA guys. As a former long-time civil servant myself, I like to say that if the rule can be honestly interpreted in different ways, then re-wording is probably appropriate - and that is the point of bringing it up.

BTW, I really don’t think this is a problem regarding engines - hardly anyone has a “Lycoming Certified” motor on their machine. And it isn’t hard to overhaul them yourself if you are of the mind to do so. I am more concerned with the seven year limit on our Hartzells! You have to go to a prop shop for those.....

As others have noted, this has gotten the attention of EAA government affairs (and others), so we’ll see how it goes.

Paul
 
On that note, what about if the limitations say no aerobatics for an RV-8, can that also be removed when I go get the new AW certificate and limitations?

The latest op lims do not differentiate between aerobatic and non aerobatic, so you will be OK with the new limitations.
 
. I am more concerned with the seven year limit on our Hartzells! You have to go to a prop shop for those.....

What limitation?

The C2YR-1BFP/F7497 blended airfoil metal props supplied through Van's are on TCDS P-920. The TCDS specifies that airworthiness limitations are specified in the manuals.

Manual 115N specifies some blade life limits of 8700 or 10,000 hours that may be applicable to some engines used on RVs. There are other limits that (I don't think, anyway) apply to any engine/prop combinations used on an RV.

Note 12(b) does say "Refer to Hartzell Service Letter HC-SL-61-61( ) for overhaul periods." If you read the latest rev of that service letter it does seem to use very forceful language ("must" etc.). However, FAA Notice 8900.410 clearly states:

FAA legal interpretations state TCDS notes containing overhaul limits are not mandatory under our regulations. TCDS notes define the design of the aircraft and how that design meets the certification basis it is certificated under, not to define how it is maintained. Some manufacturers have attempted to put information into a TCDS that defines requirements for continuing maintenance of their aircraft; however, such information is not regulatory and is outside the purpose of the TCDS notes. Information not specifically referencing the design and configuration of an aircraft, such as ongoing maintenance requirements, is inappropriate and not binding on the owner/operator in a regulatory sense.

In very clear language, TBO limits are not binding even if they are mentioned in a TCDS. The operating limitation does specify that certified articles "must be inspected", but the scope of inspection is defined in another operating limitation ("scope and detail of part 43, appendix D; or manufacturer?s inspection procedures") and as the manufacturer we get to decide what the inspection procedures are if that wording is chosen. Plus, see below regarding "inspection" vs "maintenance".

Back to N8900.410:
While the concept of part 91 operators not having to comply with manufacturer?s TBO limits is well known, the reasons behind it have not been very well documented, although, Advisory Circular (AC) 20-105, Reciprocating Engine Power-Loss Accident Prevention and Trend Monitoring, has provided guidance since 1998. The regulations require that part 91 operators have an ?inspection program? of some sort. The program could be a 100-hour, annual, manufacturer?s recommended inspection program, or one of the operator?s own design, depending on aircraft type. However, part 135 (nine or fewer) operators must have a ?maintenance and inspection program.? It is this extra mention of a ?maintenance? program that makes TBOs required in part 135 (and some other operational rules), but not for part 91. Recall the definition of maintenance, ?Maintenance means inspection, overhaul, repair, preservation, and the replacement of parts, but excludes preventive maintenance.? In the definition, ?overhaul? and ?inspection? are separate items, showing overhauls cannot be inspections, rather they are both unique forms of maintenance. Remember, overhauls are a maintenance process, not an inspection process.

So my take on this (again, IANAL and IANADAR) even though Hartzell attempts to use strong language in their service letter and lists it in the TCDS, those limits are still not binding. Hartzell itself even reluctantly agrees:
Hartzell Technical Representative Kevin Ryan says it?s a slippery slope. ?Depending on how you?re operating,? Ryan says, ?your typical private pilot operates under Federal Aviation Regulation Part 91. A pilot that?s operating under Part 91 is not required by the Federal Aviation Regulation to comply with a manufacturer?s service document. So, if we say there?s an overhaul period and it?s this long, do I really have to do it? Well, we want you to do it. But you will not run afoul of the law if you decide not to do it.?
 
Turbine Aircraft

Lots of discussion in this thread.

I stopped being a DAR after I retired from Boeing and moved out of my FAA MIDO area.

Going back 6+ years, I remember that Turbine powered aircraft were required to have an approved maintenance plan from the FSDO before they could get a Special Airworthiness Certificate.

IF memory serves me correctly, the turbine engine will have life limited parts and be required to have parts replaced and maintenance done according to the manufacturer of the turbine. It is possible that this thread deals more with Turbine powered experimental homebuilt aircraft more than it does to most RV homebuilt aircraft.
 
It is possible that this thread deals more with Turbine powered experimental homebuilt aircraft more than it does to most RV homebuilt aircraft.

I think that was sort of the intent.

Now, I'm not really convinced that all of the "turbines need special rules" regs should really apply once you get into the really small stuff--the gliders with RC-scale turbojets, turboprops in the 150-300hp range, and so on--especially when they're non-TCed engines.


Also, a disclaimer to my previous post... I haven't researched all of the props offered through Van's. You're on your own to look it up.
 
Relax. We have been working on them with this since last year. We have our Winter Summit meeting with the FAA in May and it is on the docket.

Vic
 
Relax. We have been working on them with this since last year. We have our Winter Summit meeting with the FAA in May and it is on the docket.

Vic

It's only been one year? I'll relax when you've been at it for at least 3 years since it seems that's how long it takes for the FAA to move on things :D:):D:mad:
 
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