Tech Forum

Sept. 25, 2008

Fuzzy regulations
I myself as an IA would not have gone to the extent of the first IA. I can understand that he would be concerned that this engine could be removed from the experimental and possibly sold and/or put on a certified aircraft. I myself would have entered a logbook entry stating that this engine was experimental and added experimental to the data plate. Most experimental aircraft that I come across that have certified engines or propellers that have been identified as such.

These engines, propellers or appliances must prior to installation on a certified aircraft, be overhauled by an A&P or by a FAA approved repair station.

Part 91 is clear that what is required is “Conditional Inspection” is just that condition for safe operation and permission is also given to an A&P, original builder, or repair station to perform this task and to follow Appendix D of Part 43. The IA also had shown that this aircraft was safe for flight by signing off the ferry permit.

I myself happened to own an experimental aircraft. Attached to my “special airworthiness certificate” is an “Operating Limitations For Experimental Amateur Built” and Item 8 says that the aircraft must have within the preceding 12 months a condition inspection performed in accordance with Appendix D of Part 43 and this shall be recorded with limitations Item 9 listed below. Item 8 says that Experimental builder (original builder), FAA certified A&P, and an appropriately rated repair stations I.A.W appendix D of Part 43. Item 9 states that Condition Inspection shall be recorded in aircraft maintenance records showing the following word statements. “I certify that this Aircraft/Powerplant has been inspected on (insert date) in accordance with the scope and detail of Appendix D of Part 43 and was found to be in a condition for safe operation.

This entry will include the aircraft total time in service, the name, signature, and certificate type and the number of the person performing the inspection.

I feel that is unfortunate that people sometimes go to an extreme. That IA could have called his local FSDO, local EAA chapter for their opinion or decided not to do the inspection at all. It’s not like this is the first time a certified component has been used in an experimental application.
— Paul Bessler

Fuzzy regulations
The problem is solved when the owners of Experimental A/C, that they did not build themselves, learn to use the network of A&Ps and EAA Tech Counselors that deal in Experimental A/C on a regular basis. Noncertificated engines are the norm, this owner should have simply removed the data tag, and then seen if the mechanic was ready to do the job he was hired to do, “determine if the engine condition was safe for flight. “
Enjoyed your input !!
— Thomas Wrobel, A&P/IA

Experimental engine article
Good article on experimental engine sign off, thanks. Can you expand in a future article what exactly constitutes the difference legally between an experimental engine and a certified engine. Many people have “certified engines” in their experimental, do not pay attention to ADs, consider it an experimental engine since it is installed in an experimental aircraft, and sign it off under the condition inspection criteria. Also, if the logbook does not mention experimental engine how can it be changed legally to an experimental engine, a logbook entry?
— Mick Harrison, A&P, former IA

Fuzzy regs
Let me say that I enjoy your articles. They help us get to thinking! Having endured this A&P/IA general aviation roller coaster for 37 years there are always different ways to look at and decode the FARs.
In reference to “Fuzzy Regulations” here’s what I’ve been told by my local FAA about ADs on certified aircraft engines (Lycoming, Continental, Franklin, etc.) installed on homebuilt aircraft. “AD’S must be done.” We also see the removal of the factory data plate on engines with the belief that you uncertify the engine and ADs are no longer required. Not the case with our local FAA.
So is the glass half full or half empty.
— Jim Kjeldgaard