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BRS 6 Year Repack Requirement ?


NC Bill

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From the CTLS AOI... Here is a PDF copy of the Minimum and Recommended list. I do not believe the 59 page CTSW AOI has a minimum and recommended list (at least I was unable to find one).

 

I do not believe that either of these is a true "Minimum Equipment List" as defined by the FAA.

 

But I do see the root of the confusion. POH's often specify "required" or "minimum" equipment under "Limitations". This has the force of law, but is very different from a true FAA authorized "Minimum Equipment List" issued for a specific aircraft.

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I do not believe that either of these is a true "Minimum Equipment List" as defined by the FAA.

 

But I do see the root of the confusion. POH's often specify "required" or "minimum" equipment under "Limitations". This has the force of law, but is very different from a true FAA authorized "Minimum Equipment List" issued for a specific aircraft.

 

It is 'irregular' to say the least and no doubt the FAA would not approve of such a perfunctory list if they were to closely scrutinize and approve the AOIs (they don't) . The manufacturer is only required by the CFRs to spell out the operating instructions and any oplims in the AOI. But they have chosen to use a term reserved by the FAA which carries specific meaning. So it is legally correct to refer to the FAA regs to interpret the intent of what FD refers to as an MEL; in the same way that FD is not permitted to change the meaning of terms like service directive, service bulletin, service alert, airworthiness directive.

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Hi Kurt,

 

I found them at different times over the last couple of years. Who knows there may have been others that no one has said anything about or that someone hasn't found yet.

Everyone can spare a minute to look at their chutes. FD published an SB a little while ago for people to look at bridle routing, but that should have been a wake up call to inspect the whole system. Anyone could have done that in about 15 minutes.

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In July 2007, a 2006 SW crashed short of Spruce Creek, FL. The pilot said that he pulled the chute and nothing happen. At the time, it was said that he didn't pull hard enough. MAYBE, he did and it wasn't installed properly?

 

This is the event that proceeded the safety directive that required disconnecting the cable to do the inspection. I am with Roger on this. I think that some were disconnected for the inspection and didn't get hooked back up correctly. Tom

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Here are the minimum equipment list that FD uses for the SW and the LS. It says if you make a change to update the list. They are in the maint. manuals section. 1.

Since there have been several types of panels then each aircraft has its own specific list which you were given at time of purchase and should be in your paperwork. Since the plane was issued with the list and it was given its airworthy cert. here in the US with it then that would be your list.

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Understood, and it does have force of law.

 

But my understanding is that you could take that list, whatever they call it, and strike off certain items - those not necessary for safe flight.

 

You would then present it to the FAA, who's could approve it (or not). They would issue a new document giving an operator more flexibility on what is really necessary for flight. THAT is what is meant by a Minimum Equipment List.

 

Without one, EVERY item on an aircraft's equipment list is required for flight. That's been covered by manufacturers by listing things in the Limitations section of the POH listing what's required for different flight conditions, but that's not a Minimum Equipment List.

 

Just trying to kep the terminology straight - it clearly can get confusing.

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It would be a form 337 that would need to be FAA approved since it would qualify as a Major Alteration to take something off the equipment list. These are not trivial to do. The list is not properly formatted, so you could likely argue about silly things like Rotax warranty, but anything like the BRS would be tricky. They would likely bounce the request and tell you to get an LOA from FD. Incidentlly, in the category of major things FAA will not approve on a 337 besides structural integrity stuff, things that change the aerodynamics and such, they never approve changes to fuel or oil lines or fittings. They consider that also too risky a change. Adds some context to all the CT's that have almost crashed (like mine) due to hose debris.

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Does 337 apply to Light Sport? My understanding is that it is only the LS mfg and (in rare situations) the ASTM group that can make any major changes. A manufacturer has the power to approve things via LOA and the FAA is not involved.

Wasn't that the whole point of LS - creating a category that doesn't need so much involvement and oversight from the FAA?

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Well, we are sort of in violent agreement. The FAA certainly could approve a form 337 for LS (it is still GA so part 91 rules apply) but is very unlikely to. The point was that is the only way you could remove something substantial from the equipment list without an LOA and cooperation from FD. FAA does not make equipment lists, minimum or otherwise. They can apporve an MEL if the manufacturer submits one for certified GA. FD could do one as an AOI supplement and probably not even need to get it FAA approved. The end user has no other legal way to remove something on the list.

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FAA may not make a minimum equipment list, but your plane has it's own list when it came into the country and got airworthied

 

This dead horse is pretty well beaten by now, but just so everyone can settle on proper terminology...

 

1) In the Cirrus, that list is called the "Kinds of Operation Equipment List":

 

8348706175_9081e90760.jpg

 

2) In my Sky Arrow, its just called "Equipment List":

 

8349767824_c948f19713.jpg

 

3) The pdf's that Roger provided are also just "Equipment Lists"

 

4) Adam provided a List of Minimum Equipment

 

That last is clearly the most confusing, but let me reiterate that NONE of these remotely qualify for what is meant by a Minimum Equipment List. They may, in fact, be lists of required equipment, but that's a whole 'nother thing.

 

Google can lead you to many sites describing what an MEL actually is. Probably not important for most of us, unless you're studying for your Commercial or ATP rating, in which case you'd better understand the terminology.

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FWIW sent my chute out on 12/18 and got it back on 1/7 Do not know how long Roger is waiting.

MEL on my CTSW requires me. Have not seen anything else. With GPS, if compass is inop, could you still fly a CT ?

No, the compass is required equipment and must be functional per 91.205 along with airspeed and altimeter for any flight. No exceptions.

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