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  2. 12 year mandatory overhaul

    I know nobody asked me, but I have an opinion on "mandatory" maintenance. I don't think ANY maintenance should be mandated on a light single engine airplane that is not used for commercial purposes. Encouraged strongly, yes. But mandated...no. Let people who choose to do so assume the risk. Just like people who defer maintenance on their cars. However, I am a libertarian and do recognize I'm in the minority on this.
  3. Today
  4. 12 year mandatory overhaul

    Roger, I am not sure if I am understanding you correctly. If you are asking a leading question about whether I have ever been violated by the FAA, you are seriously out driving your headlights. I see the FAA about once a month for normal surveillance and other oversight activities. This has been the norm for me for about 17 years due to the fact that I am DOM for two 135 charter certificates, operate a 145 repair station, perform and manage mx for the area's only 141 flight school, and perform/manage mx for numerous corporate flight departments and small part 91 operators in the area as an A&P IA. I also occasionally exercise my pilot privileges. The FAA knows just where to find me. I have NEVER been violated by the FAA……………………ever. I have never had any kind of enforcement activity initiated against me or my employees. I have never had so much as a verbal warning or written notice in my file. None of this makes me an expert at anything, and I would not even post it were it not for your offensive inference. I suspect that you are referring the ridiculous Rotax training issue that came up back in 2009. That whole thing was based on a bunch of misinformation put out by self-proclaimed experts in the field and some in the FAA. The only ones who conceded there were AFS 300 in Washington (not me). Discussion threads like this one on mandatory stuff are likely due in large part to that very type of misinformation. I haven’t seen a lot of retractions or corrections though over the years. Please report back to the forum about what the FAA thinks of the video on “self-rescue”. Had you asked my opinion ahead of time, I would have strongly advised you to take it down, and never go to the FAA about it, but looks like that ship may have sailed.
  5. 12 year mandatory overhaul

    This is such a sore subject matter to me because I see so much poor and wrong work done by supposedly "trained mechanics". They have all kinds of excuses. I don't know where to get manuals, what checklist, what SB's and I don't know where to find them, I don't usually see a Rotax or CT, if I don't write it in the logbook they can't get me if something goes wrong, why can't I do what I want, it takes too long to write all that in the logbook, and the list goes on. So you want to give these same people the authority to decide for someone that a hose is good or bad? No Thanks. The video is not meant to target just CT owners. That's thinking in the box. Experimental guys can do that without an issue. A lot more people have experimentals than SLSA. There are over 50K Rotax engines out there and most can do their own work. "I am also not an advocate for needless regulation." Needless regulation has usually been caused by mechanic and owner failures in history. So the government tries to protect those people and all the others that may fly in that plane unknowingly of what someone may not have doner correctly that may have put their life in danger. If you want to stop more regulations then help educate everyone and stop people from making bad decisions that cause the rest of us more regulation. Who decides if a hose is at an on condition state? The same people that can't get the other very basic things during an annual right. How do these people see under fire sleeve? How do these people see under clamps and inside the hose and under those clamps? How do you know the clamp wasn't applied too tight from the last guy and has been cutting into the inner liner? Most mechanics can't tell you if a hose is collapsing under the fire sleeve. happens a lot on a CTSW on the hose out of the cooler and back into the oil pump housing. Some one had to draw a line in the sand from past hose failures and past mechanic and owner failures to recognise a potential problem. So these people that caused these initial issues had this 5 year replacement decision made for the rest of us because of their failures so we all get regulated. Hose companies help make these decisions. They were made in a vacuum. Too many would like to make maintenance reactive and not proactive. If there are problems with the maint. it should be blamed on a 5 year replacement program, but directly on the mechanic for failing to do a good job and not just a mediocre job. The human factor is very unreliable because many let the wallet rule and fail to take preemptive safety precautions. An owner that can change oil, spark plugs and other FAA owner approved maint. and If that person has been shown the way to pull the carb and look for debris they can be more qualified than many mechanics that don't have a clue. I see that proof in the pudding every week from A&P's that know less than the owner. I just did a pre-buy on an SW and because of the A&P mechanic it needs about $900 worth of repairs. I trust A&P's less than most owners. An owner will seek the correct way because they don't know. A mechanic does it without a clue anyway because he's been doing maint. work for 20-30 years. Doug, Did you not violate the rules years ago? Following the rules can be different than following regulations. The Rotax 5 year rubber is a rule by Rotax and aircraft Mfg's. A regulation for the same is making it legally mandatory. On the carb debris issue I have a call into the FAA on their take on the procedure. I had to leave a message, it's Friday. I don't think bowl removal will be considered carb disassembly.
  6. BRS 1350HS Rocket Kit

    One other thing I would like to mention. Due to my extraordinary circumstances, BRS shipped my parachute back to me 2 days after they received it. They usually return a repack in less than 2 weeks. But for my special needs, they went above and beyond. I really appreciate that. Excellent service from BRS. Point of contact is: Derek Kuefler BRS Aerospace Inc. – www.brsaerospace.com 380 Airport Rd · South St. Paul, MN 55075 · USA Phone: 651-294-3275 / 651-457-7491
  7. 12 year mandatory overhaul

    Tom, That's fair enough. Do you think in your experience that rubber changes need to be made mandatory? Maybe I don't have my facts straight, but there seems to be a lot of discussion about how the 5 yr. rubber thing is vitally important to safety. It sounds to me like it might be. I have much more limited experience with Rotax, but I have changed hoses here and there do to inspection findings or pilot reports. I haven't seen chronic repeat issues on the engines that we have maintained through several thousand hours of operation. None of our aircraft have ever had a flight plan change due to hoses, but it seemed like this forum had a number of them in years past. Like I said, maybe I got my facts a little wrong. Roger, Just for the record, I don't think that pilots or owners are dumb, and I am not at all against training videos for maintenance tasks. My issue with the aforementioned video is the context for which it is presented. I stand firmly on that, and the very bad situations that I think could be created by pilots using it as a "self rescue". Disassembling a carburetor is not a preventive maintenance task. Even if it were, a maintenance record is required, and I would have serious doubts about the aircraft safety unless I found the root cause of the debris, which the video does not speak to. I gave the example above where a previously done condition inspection could be called into question by unauthorized and undocumented maintenance performed. To be fair, if the person using the video happens to be a mechanic or repairmen, they would be fine, so long as they document their work. I would still make the case for reporting to promote the continued airworthiness system of Safety Directives and/or Airworthiness Directives if the aircraft had an incident. I am also not an advocate for needless regulation. But I am an advocate for trying to properly follow existing regulations whenever possible.
  8. This did go through my mind but the shop is closed to the public due to insurance purposes. They want to round off my bolts in private!😳
  9. I’ve called several local major jet, turbine, large engine shops that don’t have a clue about Rotax but tell me to bring it in and they’ll do the hose job! 😳 They think working on the little weed eater would be elementary I guess! No thanks!
  10. Who has taken the 15 day LSRMR class and impression?

    I would probably pay the FBO and tell them you hope it can be a learning experience and within 3 years they could be doing them without your participation. Make videos of Rotax specific stuff. Get them what info and support they need to avoid an unfortunate result.
  11. 12 year mandatory overhaul

    Doug, I have performed several rubber replacements. I have one aircraft that I have done twice. I have had zero issues with carb debris on aircraft when I have performed the replacement. I did have one customer with an off field landing due to rubber debris, but I had not performed the rubber replacement. I have found some issues during rubber replacements that I had not found during condition inspections.
  12. 12 year mandatory overhaul

    The topic of overhaul requirement time limits are really a symptom of the bigger "required vs mandatory" discussion that has gone on and on. I mention Safety Directives in this thread because it directly pertains to the mandatory side of things. I mentioned the Piper AD that was referenced by Corey earlier because it is an example of how an otherwise non-mandatory maintenance event is correctly made mandatory in an effort to enhance aviation safety. As for the video, Roger you are DEAD WRONG here, but I will make this concession to placate you: Pilots, if you do perform this illegal maintenance on your aircraft to self rescue, please properly document your action in the maintenance records for your aircraft, and do so before you depart from the field or road. This is already required by regulation. I have to warn that you will be incriminating yourself by doing so, but it will save the poor inspector that performed your last condition inspection. See, his entry may very well be the last one in your records prior to the "self rescue" event. This way when the FAA and NTSB come to investigate, if there is anything left of the records, they will be able to discover why the carburetor bowl fell off, and not pin it on the poor inspector.
  13. BRS 1350HS Rocket Kit

    Thanks Bill. Based on comments I've read, I was under the assumption that the replacement of the rocket pucks was a simple procedure and could be done "in the field". It appears that there is more to the rebuild of the rocket than I thought. Consequently, I now understand why BRS must protect itself from liability and will not ship components but only the complete system. The expenses are reasonable when the complete rocket motor is involved and, like you, I don't see BRS taking this position to "make money".
  14. 12 year mandatory overhaul

    Roger, Doug is on our side. He doesn't think that the hose change should have a mandatory hard 5 year date, rather it should be on condition. The same for engine overhaul. When he said "it should be a safety directive", he meant if it is truly a safety of flight issue then it needs to be safety directive. He is not implying that it is a safety of flight issue.
  15. BRS 1350HS Rocket Kit

    Can we mount the old rocket under the wing for ground attack missions?
  16. 12 year mandatory overhaul

    Your read it wrong Roger Doug isn't advocating more regs. He said "if"
  17. 12 year mandatory overhaul

    I think we should regulate more mechanics while we're at it. They don't know what the correct plug gaps are, they rotate the prop to get more oil out after the system has been drained, they use the wrong type of clamps, they don't know how to check the gearbox for friction torque, they don't know what a magnetic plug is or when to check it, they have no clue where the fuel filters are, they rarely ever balance tires, they don't know how to set a prop pitch. They have no clue where to find SB's for the aircraft or engine and they have no clue where to find nor do most use a maint. manual or checklist so they miss half the items. And don't even get me started on the 2-3 liner garbage logbook labels. The FAA considers those the bottom 1%, but legal. How unfortunate for the owner. Most engine and aircraft issues are "MIFs". Mechanic induced failures. So we don't need to abandon and disregard good and best maint. practices. We need to educate mechanics and owners to proper procedures. Just had a CT in and looked at the logbooks. Looks like the last two annuals were nothing more than general maint. on just 3 items. You don't even know if it was the annual for sure. That mechanic is hanging in the wind. You can regulate everything and we should start with all the above with the mechanics.
  18. 12 year mandatory overhaul

    " it should be made a Safety Directive" So you're proposing more regulation to protect people from themselves. I don't see it that way. There are many "Best Maint. practice" items that aren't flight issues, but should be done. With this Safety Directive thinking why not make oil changes, plug changes, gearbox friction torque test, brake pads, ect.. mandatory at a specific hour. If left long enough they can cause engine issues and bring a plane down. Why change tires, why not wait until one goes flat. Smart and intelligent maint. practices should be common sense and not need more regulation that affects everyone else to make some sloppy owner or mechanic maintain their aircraft from hurting themselves and someone else. Why do helicopters have timed maint. Because some idiots would go until more fell out of the air and killed people. You shouldn't have to mandatorily regulate good maint. practices into someone's head. A few people will always cause the rest more aggravation from being over regulated because they just don't get it. Why do we have so many laws and regulations in everything we do with more coming everyday. The few cause the rest of us grief. "It is absolutely amazing to me that there is a video on the internet showing pilots how to perform maintenance" Then you should be really offended by all the Rotax owner videos. Have you EVER watched any video on maint. they you were to preform? " Any pilot who performs the procedures shown in this video on an SLSA that he/she just landed in a field due to power loss should take a serious gut check because it is highly unsafe, and correspondingly, completely illegal." With this thinking you think owners are too dumb to dump a bowl and not be left stranded? You're right you could just sit there and do nothing and or let another non educated mechanic that knows nothing about your Rotax try and figure it out. Your plane and you could sit at some oddball airstrip for days when 30 minutes of your time puts you back on your way. You can be proactive and educated or just another helpless victim. I know many of these pilots here and I fully believe all of them are smart enough and proactive enough to handle this minor situation. No Thanks. There have been many that have self rescued themselves on continued on home. Dumping a carb bowl isn't rocket science and not an invasive procedure. You do what you need to do when things aren't in a nice neat package sitting at your mechanic's shop.
  19. The local FBO told me he’d do my annual for $900. That would of either solved my problems or hatch a slew of new problems! I just couldn’t get the nerve up to take it in. Why? I could take it in and pay $900 for the annual indorsement only or if he did indeed work on it he’d probably screw the engine up! All those little pesky things like turning the prop the wrong way, over tightening the oil filter, wrong torque on spark plus, smearing heat transfer paste on the plug ends, getting air in the oil system etc etc. For me it’s either take the class or sell the plane and quit.
  20. It was a good foundation for me. I had experience with engines and electronics. I had none with the rules and regs of LS or some of the specifics of Rotax and airframe. Having said that I have spent a good deal of time talking with folks on this forum. And lots of calls to FD, Roger, and others with experience. The classes were great but I took more Rotax classes. Joining Rotax Owner was also very helpful. It ain’t easy and there have been times when I would have liked to let someone else do it. But, it is a part of the fun too. If I took it to a local A&P I would have to spend time and/or money getting them to know FD and Rotax. And even then I would wonder if I could trust them. (“I taught him all I know and he still don’t know nuthin’!”) 😎
  21. 12 year mandatory overhaul

    Anticept, My point was that the FD hose change requirement should be looked at in the same way as the engine overhaul requirement. If changing all the hoses on FD rotax aircraft arbitrarily every 5 years is really a safety of flight issue, it should be made a Safety Directive......................................in the same way that AD's very specifically require actions to correct very specific unsafe conditions. In the Piper oil cooler hose AD, there were 26 reported incident/accidents, and 24 SDRs submitted from field A&P and repair station mechanics, in an eight year period. It is quite possible that some of those incidents were off field landings. Had those gone unreported (self rescue maybe) or had diligent mechanics not submitted SDR's in the other non-operational cases, the AD may have not been issued and injuries could have resulted. It is well to note that once an owner has the proper TSO'd hoses installed correctly on their aircraft, the AD is no longer applicable (no further life-limitation to the oil cooler hoses at all). I ask again of all the guys who routinely perform this type of maintenance......................... How many off field landings or flight plan changes have occurred after arbitrary changing all the hoses and subsequent debris induced into the fuel system? How many off field landings or flight plan changes have happened due to NOT changing all of the hoses? And of these, how many were actually due to a problem with all of the hoses on the aircraft that could not have been detected with proper inspection techniques at the aircraft's required "condition inspection"? It is absolutely amazing to me that there is a video on the internet showing pilots how to perform "self rescue" maintenance on their aircraft after an off field landing due to debris in a carb bowl. That maintenance task is absolutely not within a pilot's privileges as an airmen operating an SLSA................................................................. which is the least worrisome fact in that scenario. I am left to assume that off field landings due to carb debris are common enough that someone thought that it was a good idea to create a video which clearly shows maintenance tasks being performed to correct what could possibly be a symptom of some unknown larger problem, and then to imply that anyone can do it to "self rescue". Any pilot who performs the procedures shown in this video on an SLSA that he/she just landed in a field due to power loss should take a serious gut check because it is highly unsafe, and correspondingly, completely illegal. What is next I wonder, a self rescue engine overhaul?
  22. BRS 1350HS Rocket Kit

    It is my recent understanding, BRS will not sell parts (BRS 1350) for a rocket which has timed out, at 12 years. The whole rocket, as Roger posted with the photo, must be replaced. The BRS tech, Derek, indicated that due to hardware improvements and incompatibility issues, that is the only way they will sell the kits. Another issue was liability. They would rather just have the entire rocket unit replaced, rather than piecing a unit together (bastardizing), as a serious BRS safety device. I do not believe there is a monetary motive for that position (YMMV). If the parachute repack is done concurrently with rocket replacement, the current combined cost is $1980 (excluding shipping). The parachute and rocket are shipped separately. For my particular situation, shipping for each was $150, one way. The rocket is shipped by ground only (as an explosive). I requested FedEx 2nd Day Air for shipping the parachute (at approx. 35 lbs.). If the parachute repack and rocket are not purchased at the same time, the combined cost is approximately $400 more. You get a price break for replacing both at the same time.
  23. BRS 1350HS Rocket Kit

    Arggghhhh! Can we go back to our previous discussion a few months ago about just replacing pucks instead of the whole assembly?!
  24. 12 year mandatory overhaul

    Doug: I know of one where an oil hose has to be a certain type with fire sleeving and I'm sure that's the one you're talking about. But I've also heard, admittedly only through others, of one on a piper aircraft where there are several hoses with those life limits. Having said that and realizing I've not actually read such an AD, I probably shouldn't have said anything about it. As for hoses: I've removed hoses on a Rotax on the 5 year where they were very stiff, and the end of the hose would crumble with a hard twist. The rubber used doesn't seem to hold up very well with age or exposure to elements.
  25. 12 year mandatory overhaul

    Doug, well said. I totally agree with your comments and thank you for your comments regarding Part 41. Those who are waiting for the FAA to issue the "Holy Grail" telling us the Rotax TBO is not "mandatory" are missing the point you make...which is...until the FAA issues an AD stating the TBO is mandatory........it is not.
  26. Yesterday
  27. 12 year mandatory overhaul

    I never really liked the Willette opinion letter. It focuses on part 43. That portion of the regs. imposes NOTHING on owners or operators. The topic of mandatory engine overhaul, or any other mandatory maintenance, are requirements of WHEN to perform maintenance, and they are found in other rules like part 91, 39, 135, etc........................Part 43 speaks to WHO can perform, and HOW maintenance must be performed. So for SLSA, 91.327 is the operational rule that puts maintenance burdens on operators. It doesn't speak to any kind of "maintenance program". It does speak to an "inspection program" for the aircraft.......................................... a "Condition Inspection". A condition inspection is just that..........................an inspection. That is the extent of legally required maintenance on SLSA aircraft. The other key language in 91.327 is the requirement for operators to have any maintenance performed on their SLSA be performed (by appropriately qualified personnel) in accordance with PROCEDURES. In the case of SLSA, these PROCEDURES must be those specified by the aircraft manufacturer. An overhaul requirement, or a hose change requirement, or a training requirement, are not PROCEDURES, and are therefore not part of required maintenance on SLSA regardless of what the maintenance manual or POH say. I agree with previous posts, that an SLSA aircraft manufacturer can make other types of maintenance legally mandatory with regard to WHEN, and HOW by way of the Safety Directive system. The FAA can also do so using the Airworthiness Directive system. I too think that the inspector in IOWA is 100% wrong in taking the position that the engine must be overhauled for the aircraft to be legal. He is well within his authority to say that he is not going to certify the aircraft as in a condition for safe operation, but his basis for saying it is fundamentally incorrect in this case. Same could be said for hose change, or lock nut change. Absent a Safety Directive or AD, those types of maintenance requirements come down to the judgment of the inspector after diligent application of the required inspection PROCEDURES. Just because something is replaced, or overhauled does not by itself correct an unsafe condition. I can replace a properly functioning used lock nut with a brand new defective one, and I have actually induced a potentially unsafe condition. Wouldn't it just make more sense to use proper maintenance PROCEDURES when installing/inspecting any fastener, and then safety can be assured. Basically what that means is......................if the nut is found to be bad as installed, REPLACE it. Used is not necessarily bad, new is not necessarily good...................Judgment prevails and the regulations support this. How many hose changes have resulted in off airport landings due to debris? How many off airport landings have been found to be a direct result of NOT replacing all hoses at and arbitrary 5 yr. mark? Anticept, The Piper hose AD is an apples to oranges comparison as I see it. The unsafe condition there is cause primarily by a routing proximity to the aircraft exhaust and not a blanket life limit for a hose. It is very specific, and as we have discussed previously, the AD only applies to aircraft with a specific type of hose design installed in the first place. Nevertheless, the safety issue was addressed in the correct way. If hose changes or engine overhauls, or locknut replacements are so critical to safety in the SLSA world, a Safety Directive must be issued.
  28. Thanks a bunch! When I graduate I’ll know everything I’m sure. 😱😂🤓😳
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