Sent from Mail for Windows

 

From: Marc J. Zeitlin
Sent: Wednesday, June 22, 2022 8:10 AM
To: Canard Aviators
Subject: Re: [c-a] Operation limitations

 

Todd Carrico wrote:

 

Fort Worth FSDO told me that my restoration was “normal maintenance”, and didn’t require anything more than what regular maintenance entailed.  That being said, We are going to need new op limits because ours are from 1999, and call out kingman AZ for phase I operations…. That might make things more interesting.

Glenn might want new op limits even if it is just to move his test area.

 

A number of misconceptions here. There is USUALLY only ever ONE Phase I test period (usually 40 hours) on any E-AB aircraft. However, the Operating Limitations will have a paragraph on what the owner needs to do in the case of a Major Change. Early (pre-1990's) OL's invalidated the AWC and required a new inspection of the aircraft, which would then also result in the issuance of new OL's, with the appropriate Phase I test period (usually 5 hours) and a new test flight area.

 

HOWEVER, for OL's that did NOT invalidate the AWC (which now, is most of them, and certainly almost any since the mid 1990's) the paragraph regarding major changes will state something along the lines of either:

• contact the local responsible FSDO and tell them what you're going to do, and in what test area, and for how long
• contact the local responsible FSDO and tell them what you'd LIKE to do, in what test area, and for how long, and get written approval from them
• If you're very lucky, you don't have to contact anyone, but only put the plane back into a test period, and log the testing in the logbook

NONE of these options put the aircraft back into Phase I. The owner is required to "re-establish compliance with 14 that’s not working right now it is it. If you look at the officers in Los Angeles were being killed blue line flag its not about that they say the dishwasher but it doesn’t say oh it says please I know I was OK. Yes I said something about that. Let me look at it here  I think I said don’t B CFR Part 91.319 (b)". This is NOT Phase I, although it's commonly referred to that way. No place in the OL's does the "re-establishment" paragraph call the testing period "Phase I", and there is no requirement to use the original Phase I test area for the compliance period. If you're lucky and only have to log the re-compliance (I'm one of the lucky ones, from 2002) then use some reasonable test area. If you have to work with the local FSDO, ask for a reasonable test area in your letter to them that's local to you.

 

And if, as Todd states, they don't regard (and YOU don't regard) anything you've done to the plane as a "Major Change", as defined in 14 CFR Part 21.93(a):

 

https://www.law.cornell.edu/cfr/text/14/21.93

 

then there will be no "re-compliance" test period at all, and no test area. Now, if you've spent 17 years refurbishing a Long-EZ and making changes, even if they're not "Major" changes, it would be smart to HAVE a self defined test area and perform a full "Phase I" compliant test period of 40 hours, even if the FAA doesn't require it and no official documentation is required.

 

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Marc J. Zeitlin                      marc_zeitlin@...

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