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has a Warp drive had CTsw US approval? or European approval.


johnr

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I am arranging a trip from Perth W Australia to the easten states & around the top end of Aus . Probably a 5000 mile trip. Most of the country aitstrips are gravel/ dirt.

I know the 2 blade Neuform is not up to the task. I have a Warp drive 3 blade with square tips & nickle leading edges that has already made the trip on my Jodel D11 powered by the Rotax 914.

I have been unable to find an approval for the Warp drive in Australia. I have been told that if there was an approval in the US or else where the authorities would accept that.

I have looked on this site & elswhere but have been unable to find it.

My question: has there ever been an approval granted for a 3 blade Warp drive for the CTsw? & if so where could I download a copy.

John

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Hi John,

 

Back in 2005 through 2007 the Warp 66" 3 blade was approved. I and several others had them. They will no longer approve the Warp. They think it a step backwards. I know, where do they get this stuff. The right tool for the right job in your case. I would not however use a Warp with a nickel edge. The inertia is too heavy. Rotax wants a 68" Warp or less and no nickle edges. I now have a Sensenich 68" 3 blade and I still have my Warp which I guess I should put up for sale. If you do use a warp for your trip take some super glue, baking soda and sandpaper. If you do get a nick you can fill it with the supper glue and backing soda , then sand it to conform.

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Hi Roger, How is the weather over there at this time of the year?.Thanks for the info . If Flight Design approved the Warp Drive in 2006 then that is the approval I am looking for.

If it has been approved & there is no instruction to remove the prop then all I need is a copy of that original approval. I will show that to the Australian authorities & they can make the descision.

The logical reasoning is that if there are still CTs flying with the Warp drive & they have not been grounded with the removal of a previous approval then it must still be approved.

To return to the bush strips in Australia, some have a lot of pea gravel which is extremly hard stone, it would not lose in the contact with any composite material. My experience from the previous trip

where I had no damage to the warp drive with stone chips & even though one of the strips had not been mowed & had tufts of long grass there was no visable damage to the blades.

It is most frustrating when legislation that is supposed to be there for safety is preventing you from keeping safe.

Another example, I have friends who would like to fit a fuel flow gauge on a Ctsw which has analogue instruments, they wanted to use the MGL unit but it has no approval, calls to Flight Design

indicate that the cost for approval may be as high as $2000. This will prevent the fitting of an item that would enhance safety.

John

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The Warp was an option back then. You would have to find an old website or an old brochure from back then. I still have my approval letter. I'll see if I can get it and send you a copy. FD will not give any more LOA's for Warp. I ran that issue into the ground and was "told" by FD no more Warp's. PERIOD

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Hi John,

 

Back in 2005 through 2007 the Warp 66" 3 blade was approved. I and several others had them. They will no longer approve the Warp. They think it a step backwards. I know, where do they get this stuff. The right tool for the right job in your case. I would not however use a Warp with a nickel edge. The inertia is too heavy. Rotax wants a 68" Warp or less and no nickle edges. I now have a Sensenich 68" 3 blade and I still have my Warp which I guess I should put up for sale. If you do use a warp for your trip take some super glue, baking soda and sandpaper. If you do get a nick you can fill it with the supper glue and backing soda , then sand it to conform.

 

Rog, I have the nickle warp, no problems. How are you liking your Sensenich 68" 3 blade & why?

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Do you need an LOA to install something that was a factory option at the time your aircraft was built? I'm not clear on that. Seems to me that as long as the installation is done in accordance with the maintenance manual and is signed off by the proper authority, it would not be a modification. Has FD actually rescinded approval of the Warp Drive or are they just not supporting it any more?

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Yes, you would need an LOA. Your particular plane did not get airworthied with it. So anything after that would need an LOA. FD will no longer support or issue any LOA for a Warp. They are out of the picture for new installs. Unless you just want to put it on there and fore go the regs. then you're out of luck to get an LOA.

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Roger, I think you're wrong. Here's the definition of major repair, alteration, or maintenance straight of of ASTM F2483.9919-1

 

3.1.10 major repair, alteration, or maintenance—any repair,

alteration, or maintenance for which instructions to

complete the task excluded from the maintenance manual(s)

supplied to the consumer are considered major.

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Do you need an LOA to install something that was a factory option at the time your aircraft was built? I'm not clear on that. Seems to me that as long as the installation is done in accordance with the maintenance manual and is signed off by the proper authority, it would not be a modification. Has FD actually rescinded approval of the Warp Drive or are they just not supporting it any more?

A propeller change is a major alteration IF the prop is not described in the AOI or maintenance manual that came with your plane (14 CFR 43 appendix A). I see even in my 2006 maintenence manual, the WARP is referred to. I have a pdf of the CTSW maintenence manual from 2008 and the warp is not mentioned. You only need an LOA for a major so legally it all comes down to whether or not the Warp is referenced in your manuals. FD has not issued a service directive to remove warps so no problem there. 14 CFR 91.327 b 5,6,7 governs alterations and such, but the description of manufacturer issued LOAs is in the ASTM standard F2483 (not online).

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Sorry guys,

 

Your plane was given its airworthy cert. with specific equipment to your plane. It can not be changed without an LOA. The prop is a major deal. Even FD has to put 50-100 hrs. on them with the same type of plane and engine combo that they will be used on to get a certification to use them ( i.e. a CTSW or CTLS). If they switched engines on a CTLS they would have to do the test all over. The parts manulas were made up for different configurations and only your configuration makes the difference. Just because a part is in the parts manual or any manual from FD does not mean you can swap them any time you want. If your plane wasn't given its original airworthy cert. with it then you MUST get and LOA if you want to be legal. As far as this prop issue goes I know without a doubt I'm correct that you would need an LOA which they are now refusing to give for the Warp.

 

You have three choices then:

Put the Warp on and forget about the reg.

Put a Sensenich on with a metal edge, but still a light composite

Change your planes category from SLSA to and ELSA and use the Warp.

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Roger, the ASTM standard I quoted is crystal clear. And if FD thinks the Warp Drive prop is unsafe they can easily issue a safety bulletin. And if they think it's a bad fit they can issue a service bulletin. I don't see either.

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Not suggesting this is in any way authoritative, but as I was googling for information to understand what you guys are talking about, I came across an article (p 27-31) in this online publication. In the last paragraph, she states that "[major repairs].....includes installation of new avionics or any propeller change." http://viewer.zmags.com/publication/6d3a4a62#/6d3a4a62/29

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Hi Paul,

 

That's a good article and gives good info for owners and mechanics. It says the manufacturer (FD Germany in this case) has to approve any mods. to a plane that has left their facility with an LOA.

They do not have to approve anything they don't want to and can take away any item for future use even though it came on previous models.

 

 

The reason I know about this is I fought this battle for months one year ago for a client. I went to FD USA 3 times and they went to FD Germany which sent them a VERY straight forward email saying this was done a deal and to leave it alone. I read the email. FDUSA was very helpful, but FD Germany wouldn't budge. I talked to the FAA and they backed up what FD said that a prop has to be approved and have an LOA to make a switch no matter what is in a manual because planes from one company may come in different configurations and the same plane type may have individual airworthy certs when they individual gets them with specific equipment. So swapping certain types of equipment needs an LOA approval. If FD has not tested this equipment then you may pay them to test it prior to the issue of an LOA. Props must be tested for at least 50 (maybe 100) hours on each plane / engine configuration before it can be approved and certified. When reading regs. remember to separate the GA writings from the LSA. Some times they are the same sometimes not and many confuse the two and additional research to find their separation may not be easily forthcoming.

 

For Example:

A CTLS or a CTSW would need to have those 50-100 hrs. flown off with each prop type that FD would like to allow to be used. So the Warp, Sensenich or Neuform (2 & 3 blade) would need to have all those hours flown off to be certified to be used on both types of aircraft.

 

So if you have a Warp on a CT and it gets damaged you can put the Warp back on. If you already have a Neuform a Warp (legally) is probably not in your future.

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The part I don't understand Roger, and can sympathize with, is if a part was originally offered against other choices, if I later decide i wanted the other choice, why shouldn't that be fine? For example, If I could have taken delivery of a plane with one of three prop choices (or autopilots, etc...) then clearly all three choices have been tested and ASTM "certified". Don't see why new testing (or an LOA) is needed in that case. I would understand however a requirement that requires a mechanic of certain experience or training to do the work, but not whether I can do the work at all.

 

Paul

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Hi Paul,

 

Here is an example. My plane a Dec. 2006 CTSW got its airworthy cert. with a 3 blade Neuform. 5 minutes after the DAR signed off the plane for its US airworthy cert. The prop was pulled and a Warp was installed. Then FD had to FAX over an LOA for that change for the DAR to sign it off again. I still have the LOA.

 

So what is blocking people's understanding here is when your plane hit the US with specific equipment your specific plane got its airworthy in that configuration. Once it got signed off no changes can be made to that specific aircraft without an LOA from FD Germany regardless of what options there maybe from FD in any manual. All changes are plane specific at that point. That specific plane needs an LOA to be changed because you are altering it from its original airworthy (equipment) certification. There are no implied fleet approvals unless FD comes out in writing and makes it a fleet LOA regardless of what parts are in a manual. If FD changes their mind along the way about what they will or will not allow then that's their prerogative. I don't always like it any more than the next guy, but I live within the system too.

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It seems difficult to discuss any of these regulatory issues without the discussion becoming heated. It is the main reason that I have a policy of always “quoting scripture”, meaning the specific regs, when I respond to any of these threads because

1) Going direct to the source is the only way to be sure I’m being accurate, not just repeating hearsay

2) The FARs are the only thing you can be legitimately violated for

3) Forewarned is forearmed. IOTW, knowing the rules well is the best defense to ward off a hypothetical illegitimate violation

 

I do not doubt that Roger had the experience he describes and that a DAR said he needed an LOA. I also know that my FAA examiner had to have me explain the regulations to him about how to convert S-LSA to E-LSA. And that the ROTAX A&P fiasco started with the FAA violating a mechanic for not having ROTAX training, a position they then reversed 180deg since that amounts to letting an OEM modify 14CFR 43.3 about qualifications. http://www.midwestflyer.com/?p=4654

So it is easy to get conflicting opinions, but you should realize that before the FAA can violate you, they HAVE TO figure out a specific section in 14 CFR and state exactly how you broke it. That is the fundamental basis of administrative law which covers all federal regulations. So for instance, any explicit failure to follow the FD AOI is a violation of 14cfr 91.327 d. Ignoring a safety directive violates 91.327 b4. Everything else FD has to say can be ignored with (legal) impunity. Major repair and alteration is well defined in part 43. Now I’ll quote from 91.327 “(5) Each alteration accomplished after the aircraft's date of manufacture meets the applicable and current consensus standard and has been authorized…” Well, the warp has been authorized as is easily proven if it is in your official manuals.

 

So someone from the FAA could stroll up and tell you how much trouble you are in for the new Warp and failing to repack your parachute or whatever but in my experience nothing disarms a bureaucrat or other authority figure like being able to calmly and nicely recite the relevant regulations better than they can, and clearly show they have no prima facie case. ( use that term for added effect)

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Hi Kurt,

 

See there is the problem. The Warp is not authorized any longer and you still need an LOA or you wouldn't need an LOA for any thing else. This was one of the reasons you went to ELSA. So you didn't have to worry about LOA's. Options and parts change with every MFG and they can add or remove items at will. The chute repack isn't in the same ball park, it's a whole different animal. Now talk about taking the chute out and it's a different story, then you would need another LOA to completely remove it. You need to separate ELSA from SLSA. Then you need to apply what your own plane was given its airworthy cert. as far as equipment. I think your interpretation is wrong and that's according to FAA legal. I told you I did all this research over a year ago with everyone involved.

 

"Each alteration accomplished after the aircraft's date of manufacture meets the applicable and current consensus standard and has been authorized." (before or after its airworthy cert day, ELSA, SLSA or GA) Your research quote is too short and doesn't explain how it works after the fact. It's authorized under the FAA rules and regs. so long as it has the LOA from the MFG.

 

 

Here's my challenge and a chance to prove me wrong: :)

Before you guys come back on this post take a couple of days and make some calls to FD, the FAA and or Carol Carpenter of Rainbow Aviation and talk to whom ever makes you comfortable and ask about adding a Warp to an SLSA plane that has a Neuform and what it would take to get this done and if you can just swap props without FD's LOA.

 

Make the calls. If I'm wrong I'll have to eat my words right here on the forum. If I'm right I'll bring the ketchup. :lol:

I did the research it's your turn. You guys are basing your commitment on your own interpretation of the regs. Take the research a few steps farther.

 

I'll bet you hit a brick wall trying to get this by anyone. Use this example with the Warp only. Nothing else really applies as this is what the post is about. There are lots of people who have sworn the FAA doesn't know what they are talking about and some times there have been a few of them, but they still write the citations and you still fork over the fines screaming all the way.

You may be reading the regs, but if you interpret them wrong, fail to go to sub paragraph or it doesn't apply to SLSA then it's a mistake.

 

It's time for more than reading and talk to the pros from more than one source. They all can't be wrong.

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It's time for more than reading and talk to the pros from more than one source. They all can't be wrong.

 

It seems to me that they have been in the past. As I've said before, nothing is certain until the FAA general council makes a determination.

 

Disclaimer - Nothing I have said should be interpreted as legal advice. See a lawyer for legal advice.

 

I'm done here. Again.

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My 2006 CTSW is registered as an ELSA. If at some point I wanted to change from the Neuform to a Warp, would this be considered a major alteration that required an FAA inspection or approval? Also, any opinions on how the Sensenich composite compares with the Warp?

 

Roger Kuhn

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