Jump to content

Modifying Your S-LSA


Jim Meade

Recommended Posts

I followed with interest and a certain amount of disbelief the thread about oil temperature in the climb. The forum consensus seems to be to add springs to the oil hose. Other options such as changing fittings were recommended.

 

A question as to the legality of using what is not a manufacturer installed part was brushed aside.

 

There have been discussions about different batteries, tires and lights yielding suggestions to choose parts not installed by the maker. In some cases the discussion as to the legality has been more tortuous than Jesuits and Pharisees debating how many angels can dance on the head of a pin.

 

My sense is that this forum is changing it's collective mind about what constitutes an S-LSA and what is an acceptable modification. I conclude that the general membership does not believe in and does not adhere to a strict reading of the provisions of S-LSA.

 

No harm, no foul, right?

 

I'm not so sure. One reason I took my FD CTSW to E-LSA was so I could make sensible modifications and feel comfortable about the legality.

Link to comment
Share on other sites

  • Replies 71
  • Created
  • Last Reply

I agree Jim, but have gotten tired of the battle. I just pulled my wings for the first time under the guidance and supervision of an A&P in accordance with the regs. (I thank Roger for giving me help with tips on the procedure.)

It seems to have gone from "you need an LOA for that" to "do it first, then get an LOA" to "it's gotta be major to bother with an LOA." On occasion it has even been don't worry about the FAA they don't really mean it. (External cameras.)

Link to comment
Share on other sites

Here's the simple and straight facts:

 

In the official camp, we're supposed to follow the regs to the letter.

 

In the unofficial camp, there's something called "spirit of the law". Sometimes the writing of the law doesn't line up with the spirit of the law (springs in oil hoses, done properly, actually makes the plane SAFER).

 

If you have an accident, guess which camp you will face? Therefore, if you are going to do a modification, keep your mouth shut and make sure you know exactly what you are doing, or more preferred, do it right and get approval.

 

By the way, changing fittings is a minor change. You can do that on S-LSA as long as it is in accordance with acceptable methods and practices. Adding springs to hoses might be a little more hairy, but FD already does that as well.

Link to comment
Share on other sites

On the LOA question, I have been told by FD to apply for an LOA, then go ahead and have the work done while the LOA process moves forward with FD Germany...this was for something that was very unlikely to be denied.  So what is an owner supposed to do when that is the factory guidance?  It's not like we are all out there being cowboys with maintenance and repairs.

Link to comment
Share on other sites

I will say that sometimes things DO seem a little "loosey goosey" out there.

 

A respected shop installed a new Powersonic battery in my Sky Arrow - not the specified Italian FIAMM.

 

No LOA that was ever delivered or communicated to me. The factory was NOT forthcoming with one for another owner wanting to do the same thing, so I doubt one was available.

 

I, too, went E-LSA largely to avoid any and all potential legal problems with parts substitutions.

 

Like Rhett Butler, I frankly don't give a damn what anyone else does. But if there's ever an accident in an S-LSA attributed to a non-authorized part, or even unrelated to the accident, someone may end up with some legal 'splainin' to do.

Link to comment
Share on other sites

I followed with interest and a certain amount of disbelief the thread about oil temperature in the climb. The forum consensus seems to be to add springs to the oil hose. Other options such as changing fittings were recommended.

 

A question as to the legality of using what is not a manufacturer installed part was brushed aside.

 

There have been discussions about different batteries, tires and lights yielding suggestions to choose parts not installed by the maker. In some cases the discussion as to the legality has been more tortuous than Jesuits and Pharisees debating how many angels can dance on the head of a pin.

 

My sense is that this forum is changing it's collective mind about what constitutes an S-LSA and what is an acceptable modification. I conclude that the general membership does not believe in and does not adhere to a strict reading of the provisions of S-LSA.

 

No harm, no foul, right?

 

I'm not so sure. One reason I took my FD CTSW to E-LSA was so I could make sensible modifications and feel comfortable about the legality.

Jim,

Can you review the process for converting to an E-LSA for me, I'm considering that as an option for my RV12 for the same reasons.  As long as your not using or planning on someone else using the airplane for hire I fail to see a downside but I'm sure I'm missing a lot.

Thanks in advance.

Lee

Link to comment
Share on other sites

Aren't there limits on flying an experimental over populated areas?

Well, it depends on the Operating Limitations, but in reality, not much different from certified.

 

I'll look up and post what mine says.

 

Ok...

 

I can't copy and paste (I have it as a jpg), but mine says effectively no flying over congested areas, unless directed by ATC or at an altitude permitting a safe landing without undue hazard to persons or property on the surface should the engine fail. As such, it's effectively the same as specified in "Minimum Safe Altitudes" in Part 91, for "anywhere".

Link to comment
Share on other sites

There are only two choices on the hose and spring, do the mod , or take your chance on the safety of the aircraft. I can assume that when Flight Design see's the inherent liability of this design induced defect they will do something, the ball will be in their court. Over many years as an IA my primary job was to see that the aircraft is safe. There are a lot of issues that are in the grey area and this requires experience to guide you to make a good decision. The FAA knows this and it has been discussed off the record many times. These minor changes require the mechanic to do his homework on the issue. Also I have been told by senior FAA inspectors that recording to work in the logbook shows no intent to hide anything and in the worst case if they have a problem with it they will ask you to change it. No matter what you do if there is an accident you as a mechanic will be at fault.The FARs are written for the lawyers not for the pilots or mechanics, and that quote comes from the very person who writes the FARs in Washington.

Link to comment
Share on other sites

Jim,

Can you review the process for converting to an E-LSA for me, I'm considering that as an option for my RV12 for the same reasons.  As long as your not using or planning on someone else using the airplane for hire I fail to see a downside but I'm sure I'm missing a lot.

Thanks in advance.

Lee

I think there have been several discussion about converting to E-LSA. I used Brian Carpenter of Rainbow Aviation while he was teaching an LSRM course at Oshkosh a couple of years ago. I used my plane as one of the demo planes.

 

Brian wrote up the Operating Limitations and issued a new airworthiness certificate. I had to put EXPERIMENTAL on the side in lieu of LIGHT SPORT and had to put a passenger warning inside.

 

Your FSDO can do it, as well. The problem is some FSDOs don't know anything about it and some do. I think it's a good idea to deal with someone (like Brian Carpenter or a knowledgeable FSDO). You have to research a little to find that person.

 

Several of us on this forum have E-LSA and could send you a copy of our operating limitations.

Link to comment
Share on other sites

To all,

The rules are clear. One cannot operate an altered SLSA when the alteration does not have manufacturer approval. They give no relief with regard to major vs minor. They give no relief when the person performing the alteration thinks that it makes the plane safer.

I believe that this requirement exists in large part because the manufacturer is charged with the continued airworthiness (Condition for Safe Operation is a better position) of their product. If the manufacturer is unaware of the configuration of their product (because it has been altered without their approval), they cannot adequately assess for and cause to be corrected, "unsafe conditions".  By law, they must do this through the Safety Directive system. While in my opinion, this system is grossly inadequate, unapproved alterations make it that much worse.

 

If a person becomes aware of an unsafe condition, they should report it to the manufacturer, and when appropriate, recommend corrective action. Do not alter the aircraft without approval to do so. To take the position that we are all smarter than the system is no good.

 

Doug Hereford

Link to comment
Share on other sites

To all,

 

One additional thought:

 

Remove any unapproved springs from  hoses and replace the subject hoses with approved hoses. Route and secure these hoses in accordance with accepted maintenance procedures.............................BEFORE FURTHER FLIGHT!

 

Doug Hereford

Link to comment
Share on other sites

To all,

 

One additional thought:

 

Remove any unapproved springs from  hoses and replace the subject hoses with approved hoses. Route and secure these hoses in accordance with accepted maintenance procedures.............................BEFORE FURTHER FLIGHT!

 

Doug Hereford

 

So, if your airplane has inadequate oil cooling for safe operation with the factory setup, do you recommend grounding the airplane and trying to get a MRA for the spring install?

 

Not attacking your position, just curious how far you'd take this.  If the factory setup is unsafe and there is no approved alternative, do you park the airplane?  What if the factory refuses to approve any modification or alternative?  Do you (try) to sell the plane, since you cannot safely operate it?  Do you disclose to a buyer that the airplane is not airworthy and never can be?   

Link to comment
Share on other sites

In type certified aircraft we have options for making changes, stc's, field approvals, designated engineering representatives, and FAA engineering. I have done all of these, some of them major mods. A large number of them in a few days. In light sport we are bound to the manufacturer who may not have any interest in making things easy. Unfortunately many decisions are now being made by lawyers

and not by common sense, both in S-LSA and certified aircraft.

Link to comment
Share on other sites

To all,

 

One additional thought:

 

Remove any unapproved springs from  hoses and replace the subject hoses with approved hoses. Route and secure these hoses in accordance with accepted maintenance procedures.............................BEFORE FURTHER FLIGHT!

 

Doug Hereford

 

Doug,

 

When you provide clarity for the repair / maintenance shops working on our SLSAs I applaud you. There is a big need for further education.  The wing inspections are a great example.

 

When you advise the owners to ground their planes for a gray area where no solution is provided, then not so much.  I am on my 4th set of approved hoses and as of right now my CT can't even climb to pattern altitude.  If I begin taking steps backwards then my plane has no value, this is a 6 year old problem now that only gets worse.

 

The existing system has flaws.

 

On a brighter note my CT goes back together today with new hoses, springs, overhauled oil-cooler, optimized cooler angle and enlarged cowl openings. 

Link to comment
Share on other sites

Just talked to Flight Design about the springs. They have used numerous methods on hoses including springs and aluminum tubes to keep the hose open. They have not defined a specific method to be used and currently use springs in the cooling system, so there is not a regulatory issue on this as this is an accepted method.

Link to comment
Share on other sites

Charlie,

I am sorry, but I see no gray area here. If someone inserts a foreign object into a fluid carrying line on an SLSA aircraft, and does so without approval, and then subsequently operates the aircraft, they are breaking the law. As a practical matter, I cannot get my mind around how anyone would think it was ok to insert something into a critical fluid carrying line without some form of approval.

If these aircraft have an inherent overheating problem, or hose kinking problem, then the manufacturer needs to correct it. If this condition rises to the level of an unsafe condition, than a Safety Directive must be issued. That is the solution (also see "Before Further Flight" comment above). Before I did anything else however, I would inspect the entire system to make sure that it meets all of the applicable design criteria: Proper type and size of hose, proper routing, securing and connections. Who knows, it may be discovered that someone before had made an unauthorized alteration that is causing the current condition(s).

 

One other avenue that I would not hesitate to pursue if the manufacturer remains silent, is to contact the FAA. Be prepared to have specific details, and regulatory back-up to support your position however. Also, I do not think it would be a good idea to mention (to the FAA) anything about springs in hoses, or grinding out through-holes (even if deemed to be non-structural).

I am not trying to say that this solution is the best one, or the quickest, but if this system is not adhered to, and corrected in the proper way, it may become a house of cards. At some point, if allowed to progress, political pressure might lead to drastic measures to correct it. Imagine a world 20 or so years from now with skies full of SLSA aircraft flying around with un approved alteration after alteration applied to them by well meaning mechanics/owners. These aircraft will have morphed into a hodgepodge that is undefinable by anyone.

Maybe the spring idea is a good one (although I can't think of any aircraft where springs are used inside of fuel, oil, or hydraulic system fluid lines). Let the manufacturer bare the liability of determining this, since this is their job.

 

 

Mr. Morden,

I guess my direct answer is.................absolutely yes. If the aircraft truly has inadequate cooling for its intended operating parameters, then what choice would you have but to ground it until it is fixed. If as you say, the factory set-up is faulty, why would you not demand that the manufacturer correct this condition?

 

Doug Hereford

Link to comment
Share on other sites

All that seems a little overblown to me.  Hasn't the possibility of overheating during a hard climb been around forever?  For all aircraft?  Long before I was a pilot I heard the term "stairstep climbing" having to do with a technique to limit overheating.  Didn't Jabiru have some cooling issues, which resulted in a warning to not operate when temperature is over XX degrees?  Who says a plane is guaranteed to be able to climb for extended times at Vx or Vy on a hot day?  Isn't it the pilot's duty to monitor those things and adjust accordingly, to be safe?  Isn't this passage true for all planes?:

"Just remember to not to prolong the climb at the maximum angle of climb speed as this speed is relatively low, engine cooling is poor and overheating and detonation could be the result. Lower the nose and increase the airspeed as soon as possible after clearing the obstacles to enhance cooling and forward view. Maintain airspeed at cruise climb speeds."

This is not new or unique.  Google "cessna overheating climb"- 379,000 hits.  "cirrus overheating climb" 617,000 hits.

 

Wasn't this topic settled a few posts back (#12) when FDUSA said it is an accepted method of insuring better flow?

Link to comment
Share on other sites

Archived

This topic is now archived and is closed to further replies.


×
×
  • Create New...