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Modifying Your S-LSA


Jim Meade

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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

Thanks for the response, Doug, but you didn't respond to the critical second part of my question: what if the factory refuses to acknowledge there is a problem and provide a remedy? In the certified world an A&P can make it work using acceptable practices and sign it off...in the LSA realm we don't have that option, so now you are left with a busted airplane that CANNOT be fixed legally, and likely cannot be disposed of except at a great loss. So how slavishly do we want to stick to the regs, when an obvious $2 remedy is available?

 

I'm a law-abiding person (I used to be a Police Officer), but we have to be careful not to confuse the law with right and wrong. When rules stop serving their intended purpose of helping and protecting people, they are not really serving any function except obstruction. IMO, of course.

 

Again, I'm not arguing with you per se, just having the discussion and presenting a different angle.

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Doesn't it then become finding a method to change the law, not violating them. Assuming you wish to remain a law abiding citizen.

There were some ultra-lights that became non entities with the advent of LSA. If I remember correctly.

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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...

 

Doug Hereford

 

Doug,

 

I did not get the springs installed, Jeremy wouldn't do it because it would cause an impeded flow.

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Doesn't it then become finding a method to change the law, not violating them. Assuming you wish to remain a law abiding citizen.

There were some ultra-lights that became non entities with the advent of LSA. If I remember correctly.

So while you try to change the law for five years you just let the airplane sit and rot? I wish to remain a law abiding citizen, yet I have rolled through a stop sign on occasion.

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Can someone here tell me who the A&P mechanic that broke the FAA rules a few years back on purpose and then got violated just to challenge that ruling that caused others to get suspend? Why did this person get the ruling changed first?

 

This was before that moment in time before the FAA came out with a new ruling and this A&P broke the law.

 

 it isn't always straight forward and doesn't always happen in a logical  order and as far as FD is concerned it isn't breaking the law.

 

If we nit pick every single nut and bolt we do for our aircraft then we have to admonish ourselves fro speeding, running yellow lights, walking across the street against the light of Jay walking or maybe claiming something on taxes that might be questionable. To me how far do you want to point fingers and for how long. How about we look at each item that actually works, is safer and benefits us all.

 

Kind of like the A&P that broke the law a few years ago before it was changed. SLSA and even parts of certified aircraft rules can and does leave room for interpretation and mechanics and owners have since time began made some changes before the law was changed.

SLSA is not always clearly defined as this A&P has seen since he started working on SLSA and unfortunately SLSA MFG's are not always jolly on the spot to help because it takes time and money and some don't have enough of either.

 

If my only offence is placing a spring in my oil line to save my engine and the MFG is good with that then so am I.

 

p.s.

This isn't a design flaw and it isn't a fleet-wide engine killer. It's more of an annoyance and is easily fixed.

If you don't like springs in hose then you'll have to yank all the springs from the coolant hoses and or yank the aluminum tubes out of the CTLS radiator hose. 

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Hi Ed,

 

I don't believe Jeremy is correct. What testing did Jeremy use to come to this conclusion? The flow is impeded by the smallest fitting on that hose which would include the spring and each fitting ID. All fittings on each end are 1/2" OD just like the spring. The spring has the same ID as the end fittings. The other part of this is how much oil is actually flowing and how much oil do we need. We don't suffer a severe friction loss here because we aren't flowing enough. We flow 4 gpm. Pressure for our application is not affected by spring or fittings. Just by simple testing that has been done for a while now we can safely say from this experience and by the 20F+ drop in temps that flow is not impeded because a reduced radius caused the high temps. If the spring reduced the flow like the reduced radius then the temps would not have lowered and may have gone higher, but this didn't happen. Each individual that has placed a spring here has experienced lower oil temps which shoots down any concern about slowing the flow. The ID on the fittings and spring are more than sufficient to allow plenty of oil for our needs. We only need 4 gpm and that hose has the capacity to flow more.

 

You have to judge and put this in it's proper perspective for our needs.

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Just like many of our other highly debated topics. We will all have to agree at times to disagree and do what may need to be done to make things right with our aircraft and sometimes that may bend the rules and my just be an interpretation issues for each owner to deal with.

I have learned not to get to hung up over every nut and bolt issue or our planes may have been grounded since day one.

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Mr Morden,

I did answer your question. Go to the FAA if FD doesn't respond.

 

CT4ME,

I agree, that any aircraft may have heat issues in certain operating conditions. I believe that is probably more the case here than an actual unsafe condition. There are simply limits to what the machine can do. I to think tha the heating issue may be overblown a bit. My issue is not with overheating specifically, but with unauthorized alterations, especially ones that seem absolutely contrary to conventional wisdom.

 

Charlie Tango,

I agree with your mechanic. I would add some other concerns: What should this mysterious spring be made of? How long should it be? What keeps it from deteriorating inside the hose, and traveling to a place where it can block flow? What keeps it in place at all? What keeps it from causing damage to the interior of the hose and producing debris? Why is the hose kinked or collapsed in the first place? How does anyone other than the person installing the spring know that it is there? I don't have the answer to any of these questions. The manufacturer should though.

 

Roger,

You may be referring to me with regard to the mechanic that, as you say "broke the rules........................................". I'm sure that if you have talked to Carol, you have gotten some of that story. If it is me that you are referring to, you have most of the important details wrong.

1. I never broke any rules.

2. I was never violated. I also never initially went to the FAA. Carol sent them to me on her own (it seems a common practice in the SLSA world for people to ring up the FAA at the drop-of-a-hat). Carol was incorrect on almost all of her points starting with an article that she published in Mid West Flyer Magazine (I have saved all of our e-mail correspondences as proof of what was said between us). In Carol's defense, she seemed to be repeating all of the mis-information that the FAA fed her.

3. As far as I know, in spite of what I think you posted years ago claiming mechanics were suspended in Texas or something for not having Rotax training, no mechanics have ever been violated for this.

4. The FAA never changed the rules as you imply. Rotax training has never been required. This was misinformation spread throughout the field and within the FAA.

5. SLSA rules are clearly defined in 99% of the cases.

 

I make my living maintaining aircraft (Fire Department is stress relief), so when Carol’s MWF article came across one of my customer’s desks, and they (my custormers) started asking questions of me, I followed up with Carol informally to see if I was missing something. After a considerable amount of time e-mailing back and forth, unable to convince me that she was correct, she contacted the FAA, who then contacted me (Van Stumpner AFS-640 at the time). At some point, AFS-300 (Washington DC) got wind of all of this, and contacted my local FSDO (Kansas City). KC was told by DC that the training was required, and DC subsequently directed  my FSDO to tell me and my employees to stop working on the engines until we received the training.  My FSDO was very reluctant to do this, and assured me that absolutely no violation would be pursued against me or my mechanics for past work.

At that point, I am now losing money (so are my customers), and no one at the FAA will take up the fight. I have a very good relationship with the customers who’s SLSA’s we worked on at the time, so I asked them to file a formal complaint on me with the FAA in order to get them (FAA) to actually answer this issue in a timely manner (chief counsel opinions take 6 months to receive). The FAA’s attorney (Ed Avermann) promptly called me, and stated that Carol’s, AFS-640’s, and AFS-300’s interpretations were all incorrect, and that I was not in violation of any rules. In a conference call between Avermann, Murry Huling (Kaleb Glick’s Boss) AFS-300, and myself, I was informed that I could resume working on the engines as I had been before. Huling described the whole thing as a “misunderstanding.” Had my customer not filed the complaint (he actually never had a true complaint, I drafted it up for him to submit), This issue may have taken years to get resolved. In the course of all of this, there was also an operator in Joplin Mo. who was using SLSA for flight training as my customer did. This operator was also told to stop working. After my process with the FAA he was allowed to go back to work as well. Essentially what I did is attempt to "fall on my sword" so to speak although not really, because I knew that the eventual outcome would show that I was correct.

 

As you can see, mis-information spread by persons who front themselves as experts, or who are acting in an official capacity, can cost other people real money. I would take up this fight again in a heart-beat if necessary. As a business owner, if someone tells me that I have to spend mine or my customer's money, they better know what they are talking about.  End

 

Roger, you also know better than I do, that these engines will run just fine with a failed cooling hose. Springs are installed in cooling hoses by design. There is a reason you do not find springs inside of fuel supply, oil supply or hydraulic hoses. If these hoses fail, the aircraft does not run fine. These hoses are critical. Cooling hoses are not.

 

If FD is actually aware of what you are doing, and is truly ok with it, then I will reverse my position. I would need to see that approval in writing with the specific instructions on how, where, and when to install these engine saver springs (don’t forget fuel supply hose at “A” post). If it really only costs $2 dollars to make this safety enhancement, then I am sure FD will incorporate them into all future products.

 

Doug Hereford

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Mr Morden,

I did answer your question. Go to the FAA if FD doesn't respond.

 

 

My point is, what remedy would you ask for from the FAA?  It's clear from the regulations that the manufacturer is the final authority on an S-LSA, and I don't think the FAA is going to step in and force them to correct a non-structural issue, especially one that only affects a few airplanes.  So that leaves you with petitioning to change the regs, which is a process taking years, with little certainty of success.  All the while you have a useless airplane gathering dust and rodent poop, with all of its systems deteriorating from non-use.

 

From your responses so far I assume your answer is "tough luck, next time buy a certified airplane or experimental"?

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Hi Doug H,

 

I do know the whole story and who it was before it hit the web. If everything was so clearly defined and the Rotax training wasn't an issue then you wouldn't have had to do what you did and the FAA wouldn't have taken months to rule on it from legal. If rules on Rotax training were so clear then Carol and many others wouldn't and shouldn't have been so wrong.

Same with the springs we have here. It isn't clear so we have differing opinions and for me that's okay because that's how we learn, move forward, correct and benefit.

I have a good friend in the FAA SLSA section I talk too fairly regularly to keep up on upcoming or changing rules in our category.

 

Read Madhatter's post.:

"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. "

 

Like you said I already knew the outcome of this before I did it. FD has been using springs and aluminum tubing inside hoses since the early CT2K days and who knows it may go beyond that time. That was before my time with them.

 

This is a well accepted method to prevent hose collapse in the LSA industry because I have seen it in other LSA aircraft and in EAB too.

 

 

"I agree with your mechanic. I would add some other concerns: What should this mysterious spring be made of? How long should it be? What keeps it from deteriorating inside the hose, and traveling to a place where it can block flow? What keeps it in place at all? What keeps it from causing damage to the interior of the hose and producing debris? Why is the hose kinked or collapsed in the first place? How does anyone other than the person installing the spring know that it is there? I don't have the answer to any of these questions. The manufacturer should though.'

 

Some of these are just common sense and and easy to answer and If the nay sayers have tried and tested these like I have they would have all these answers. If someone has never tested and tried this how can they have an intelligent rebuttal.

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Mr. Morden,

I am not sure I understand your issue completely. If the plane truely has an unsafe condition due to a design defect or other circumstance that is likely to exist on other aircraft of the same model, then the manufacturer is legally required to address this. If they refuse to, then I recommend contacting the FAA. Have your ducks in a row first. Know, and be able to site the relevant regulations [ie. 14 CFR part 21.191©(5)], and fully explain the unsafe condition. Roger has a good friend in the FAA who can undoubtedly help with this. Another option would be to convert to Experimental and start experimenting.

 

Is your aircraft really unsafe? Is it really going to sit and gather dust and rodent poop? Or is it just an inconvenience that it gets hot under certain conditions? Is there possibly an underlying maintenance issue unrelated to the design that needs to be troubleshot and addressed as a part of the normal aircraft service.

 

I am not saying "tough luck". However the system for SLSA does have some encumbrances that the Standard and Experimental worlds do not. It seems like a "have your cake and eat it too" position. Everyone is more than happy to take advantage of the relief that SLSA offers, but some seem to want to bend or gray up the rules when it suits their purposes. To do this actually does alot of damage to the system as a whole in my opinion.

 

Roger,

Please post for everyone's benefit, a copy of the FD approval and installation procedures for installing springs in specific fuel and oil hoses (not referenced to cooling hoses). I expect also that this approval will be in compliance with the ASTM design standards for which the aircraft is certifcated.

 

What is EAB?

 

 

Doug Hereford

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Doug, Flight Design places a spring in the fuel line that comes from the wing to the fuselage on the CTLS to keep the line from kinking when it goes around the corner. I think some of the airplanes might have had a tube here instead of the spring early on.

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Hi Tom,

 

I agree. Matter of fact I have put springs in the wing fuel lines in the CTLS because of the 90 degree bend that tends to kink. It works like a charm. FD and others have been using springs and tubes for years and because some are just now hearing about it doesn't make it wrong.

 

"Please post for everyone's benefit, a copy of the FD approval and installation procedures for installing springs in specific fuel and oil hoses (not referenced to cooling hoses). I expect also that this approval will be in compliance with the ASTM design standards for which the aircraft is certifcated."

 

No such LOA and it isn't needed.

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Jim Meade,

I was really not trying to be disingenuous with my question. ;). I actually did not know what E-AB stood for. Interesting that the "E" stands for experimental though.

 

Tom, Roger,

I'm really not trying to be arguementative or stubborn.

 

As near as I can tell, the call out for the wing root fuel supply hose is P/N: C9993184A. This hose is a DIN 73379 hose. I don't find anything in that standard that mentions internal springs to be used as a part of the design. I'm not saying that FD hasn't put them there, I just see no call out in any tech data to indicate this. Also, Roger, if FD uses the springs, why have you had to add them yourself? Hopefully these springs are not piling up at the tee fitting down-stream. I also find no standard practice listed in any FD maintenance procedures that permit the use of springs in hoses at all.

 

At any rate, FD's use of a spring in this hose, is not a blanket approval to add springs where ever we want to. Does FD install springs into the oil hoses? FD also uses a fuel injected engine in some of their aircraft. Can we just install one in place of carbs with no further approval? 

 

I respecfully request again, a copy of the approval document from FD to install springs in hoses (same details included).

 

Doug Hereford

 

PS: I may be wrong on the fuel hose P/N. The parts listing confuses me a bit.

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Let's assume a manufacturer builds a specific model S-LSA with the early run of manufacture one way, say without springs in the fuel/oil lines. Later in the production cycle, they add springs in specific locations. There is no specific documentation saying to use or not use springs. A plane comes in for service that does not have springs. Can an appropriately qualified mechanic add springs to be consistent with the current products from the manufacture without an LOA?

 

Alternatively, a plane comes in for service that has springs. Since there is not specific documentation authorizing springs, do you need to remove them for continued airworthiness?

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S3flyer,

My first question is: Why were the springs added at all? We must assume that they were added for a good reason (safety?). If so, there should be something published to authorize (Service Bulletin) or require (Safety Direcive) alterations of in service aircraft. In the scenario you present, I would be on the phone to FD to request documentation to advise me one way or another. In this case, I think Roger is working on getting us that documentation.

 

The bottom line is that we cannot alter an SLSA without manufacturer approval.

 

Doug Hereford

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Springs and aluminum tubing have been used on and off since the early CT's and are still in use today. None of the springs any any hose is documented in any document. Other MFG's also use them with no documentation.

 

Welcome to the LSA world.

 

As they say sometimes:

 

It's better to ask forgiveness than to ask permission.  :o

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. . . "The bottom line is that we cannot alter an SLSA without manufacturer approval." . . .

 

So, in that context, what constitutes an "alteration"?

Are you implying that it is an "all or nothing" proposition, with no room for any discretion?

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Every time this issue comes up it gets confusing. There is an LOA for installing an Airgizmo on my GPS, but not one for putting springs in hoses? There are specific instructions for notching the wheel pants to get at the stem, but we wing it on springs in hoses?

Some say it doesn't matter because FD uses springs sometimes, or it is accepted practice in the standard certificated or experimental world. Yet others say don't tell anyone and you will be ok (wink, wink).

I believe one of the principles of S-LSA is that the manufacturer controls any modifications and takes responsibility for them as the alternative to the standard certification route.

So, when I am doing things to my plane that don't fit the FD manuals (incl. Rotax since they defer to Rotax on engine issues) I call their representatives at FDUSA to get approval. I would call both FD and Rotax on the spring issue - if I had the problem. In my experience they have been very accommodating.

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Roger,

Continue with that theory and watch SLSA unravel.

Please provide the approval for springs.

 

WmInce,

I am not implying anything with that specific statement. I am just repeating what the regs. require.

 

Doug G

You said it better than I have been able to.

 

Doug Hereford

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Springs and aluminum tubing have been used on and off since the early CT's and are still in use today. None of the springs any any hose is documented in any document. Other MFG's also use them with no documentation.

 

Welcome to the LSA world.

 

As they say sometimes:

 

It's better to ask forgiveness than to ask permission.  :o

Roger,

 

You provide the practical solution.

That may not fit everybody else's opinion of compliance though.

I think this issue on hose springs fall's into the "unwinable" column.

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Every time this issue comes up it gets confusing. There is an LOA for installing an Airgizmo on my GPS, but not one for putting springs in hoses? There are specific instructions for notching the wheel pants to get at the stem, but we wing it on springs in hoses?

Some say it doesn't matter because FD uses springs sometimes, or it is accepted practice in the standard certificated or experimental world. Yet others say don't tell anyone and you will be ok (wink, wink).

I believe one of the principles of S-LSA is that the manufacturer controls any modifications and takes responsibility for them as the alternative to the standard certification route.

So, when I am doing things to my plane that don't fit the FD manuals (incl. Rotax since they defer to Rotax on engine issues) I call their representatives at FDUSA to get approval. I would call both FD and Rotax on the spring issue - if I had the problem. In my experience they have been very accommodating.

So getting approval over the telephone from the FD Maintenance Director doesn't cut it?

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