Modifying Your S-LSA

[Doug Hereford]

WmInce,

Actually, a phone approval would cover it, but try proving that to anyone. The rules do not define a specific approval process or documentation requirements for that approval. My recommendation is that before you alter an SLSA, (or allow yours to be altered) put yourself in a position to prove to any interested party, that you have received prior approval to alter. This could be something written on a bar napkin, or written on the wing of the plane. The term "letter of authorization" is not defined in the FAR's. As far as I know, it is something that was cooked up in the field. Approval in writing does seem to make the most practical sense however.

 

The Standard Airworthiness parallel to this requires approved data (FAA approved) from specific sources (STC, field approval, TC, etc). Then the actual performance of the alteration on a specific aircraft must be documented in a very specific way (FAA form 337). Then this document must be dispositioned in a very specific way (copy to owner, and copy to FAA archive). All of these requirements are spelled out in 14 CFR part 43 and 65.

I say this to illustrate that these concepts are not complex. The FAA could, and should force manufacturers to comply with a similar system.  This debate would probably be much less stimulating if they (FAA) did this. More importantly, we in the field would be less hung-out-to-dry if the FAA, and the SLSA mfg's (hope you guys are listening) would start doing their jobs!

 

Doug Hereford

[Doug G.]

Wasn't that, in part, the reason for the FAA investigation of overseas LSA manufacturers a couple of years ago? I think they were all down to be lacking in compliance, but FD was one of the better ones.

[Doug Hereford]

To all:

An additional thought on documentation of alteration approval and performance. Retain forever, the evidence of approval, and the record of performance of ANY alteration to your SLSA. Transfer such record with the aircraft when sold.

 

Doug G.

I don't know about that, but I seem to remember hearing something along those lines. In my limited experience, FD is one of the least non-compliant SLSA mfg's.

 

 

Doug Hereford

[Roger Lee]

When you figure how to be 100% compliant in the SLSA arena let me know because it isn't possible to be 100% , 100% of the time. You can't even talk to some MFG's. You can nickle and dime or nit pick every item on the plane, mechanic and owner until you can always find something. There isn't a plane that has come into my shop that has been 100% compliant. I could go into anyone's shop or plane and find something, but is it worth the bother, most times not. It just depends on what each person feels comfortable with, what he has been told by FD and what he really cares about. You could nit pick probably every aircraft owner or mechanic and eventually find something. FD isn't compliant themselves nor is any other SLSA MFG. Technically you can't change tires because it isn't in the maint. manual and needs special approval from FD. Anything not in the manual is considered a special procedure because there is technically no procedure from FD to change tires. So who cares, not anyone I know. If a procedure isn't in the manual for your plane technically you need approval.

 

We'll have to settle with myself and others using springs and tubes with FD's blessing and curing our temp issues while others who don't like our solution will continue to keep there problem because they will never be able to make any change.

Now that begs the question what will you do if you can't get an LOA? If you can't get an LOA do you ground yourself forever, sell the plane and stay away from LSA or go ELSA. If you try and dot every "I" and cross every "T" with an LOA what will you do when you can't get one for a minor issue? I think this is a good question for a realistic answer.

So you have to ask yourself how far do you want to run this horse into the ground?

 

If someone that has a problem that doesn't want to use FD's accepted method then they'll have to climb that mountain to try to get an LOA and that may never happen and you wouldn't be able to force a German company to comply. I know first hand that if they don't want to address something or don't like it it's a dead issue. FD is actually pretty good. You should try dealing with other SLSA MFG's.

 

The spring is too much a minor issue to make it a major deal killer. I can leave the dot off the "I" this time.

[Jim Meade]

Changing a tire is a process that one can find explained or inferred in many FAA approved publications and it seems a stretch to me that the FAA would come after someone for performing a routine task. Saying it is not explained in detail in an SLSA manual doesn't convince me that the FAA will violate you for it if one follows generally accepted industry procedures.

 

Changing or modifying a part is an entirely different matter. One doesn't justify changing a part to the FAA by comparing it to repairing a tire.

 

If FD chooses to modify their manuals or approve non-standard parts or procedures by providing verbal guidance in a telephone call, how does one refer to that modification if questioned by the FAA? It would seem to me that one can't, but at the least one should write a memorandum for record of the call and preferably send a copy to FD as well as keeping a copy on file. Short of that, it's a "he said, she said" day in court if challenged.

 

I'm comfortable in guessing that FD would not say that refusal or failure to issue an LOA is an excuse for us to pretend one is not needed. I'm willing to bet that FD would say, if pushed, that the LOA is necessary.

 

Applying a process from one application to another can be a risky proposition both for safe operation and for legal operation. Claiming that OK to use springs in a water line means it's OK to use springs in an oil line is utter sophistry. (the use of reasoning or arguments that sound correct but are actually false).

[Roger Lee]

In the SLSA world you have to have a procedure for it in the maint. manual or you are not allowed to do it. These aren't certified aircraft so all FAR's don't apply. You can't infer these things with LSA. The rules say the procedure must be in the MFG maint. manual or you need approval to do that procedure with written instructions.

 

"Changing a tire is a process that one can find explained or inferred in many FAA approved publications". 

This is okay for certified aircraft. You can't mix and match FAR's to fit both certified and SLSA. If an SLSA needs a procedure done and it isn't in the MFG manual you need permission. Was it a missed section that should have been in the manual, sure, but it still isn't there.

No inferring allowed because I could infer that if two springs are allowed then 3 is okay.

 

"If FD chooses to modify their manuals or approve non-standard parts or procedures by providing verbal guidance in a telephone call, how does one refer to that modification if questioned by the FAA?"

 

Welcome to the SLSA world. As much as some want to believe the SLSA world is not 100% clear nor does it have all the paperwork you want to make it clear. It's the same way in the certified world in some cases. There will be extremist on both sides of the coin in every thing in life and neither side will ever agree.

 

I work on around 30 aircraft a year and from several MFG's. They are all different, some ASTM compliant some not. Some will issue an LOA some won't, you can take to someone of authority from the dealer side and sometimes not.

 

I will state this right up front. No one is 100% compliant whether it is the owner, mechanic or MFG. No one.

 

So my questions still stands and it must be answered to proceed with this conversation or there is no conclusion.

It will be one side against the other side forever. (Like some of our debates)

 

What will you do when you can't get an LOA?  What will you do when someone points out you are not 100% compliant?

 

I can answer this for Jim. You didn't like the LOA side of SLSA or the MFG's not being so forth coming so you changed the game and went ELSA. 

Why did you do that if it was so easy to get things done on the SLSA side?

 

For most of the mods done in the field they get changed and then you ask for an LOA. Even FDUSA may agree with a mod, but FD Germany won't and they have to sign it off. So you do the mod which may have cost an number of $$$ with ones okay and a submission of an LOA approval, but then FD Germany declines.  Oops.

 

Welcome to the SLSA world.

 

We'll still have to agree to disagree. It isn't clear cut and there are too many items that can't be addressed because MFG's won't and the guidelines are to unclear.

 

You make the best decision with the best information you have and for the benefit and safety of the owner and aircraft. Sometimes there is no clear path to follow.

If I waited for LOA's all these years on all my research you wouldn't have half the LOA's in the approval section.

 

Do you have Matco brakes? Where and how do you think those came about. Do you have an Odyssey battery? How about a drip tray mod to keep them from cracking? How about header wrap or wheel pant modifications? These are just a few that no LOA existed until it was done and tested.

 

It isn't as clear cut as some want it to be.

[Tom Baker]

Doug H, I don't plan to put any springs in any hoses that do not have them already, until I hear that it is approved. When you ask about springs in fuel hoses I simply stated that Flight Design does put springs in fuel hoses. The fact that they do not show the spring in the parts manual really has no bearing on it. In fact removing the spring based on it not being listed in the parts manual would be an illegal alteration, and a safety issue.

[FlyingMonkey]

 

Now that begs the question what will you do if you can't get an LOA? If you can't get an LOA do you ground yourself forever, sell the plane and stay away from LSA or go ELSA. If you try and dot every "I" and cross every "T" with an LOA what will you do when you can't get one for a minor issue? I think this is a good question for a realistic answer.

 

 

That was precisely my question.

[Doug Hereford]

Tom,

I think I agree with everything you said. I mentioned the lack of call-out on the spring in the fuel line because it is interesting to me that this particular spring appears to be installed "sometimes". I would make the assumption that this fuel line is critical to the safe operation of the aircraft. I also make the assumption that it has an inherent tendency to kink due to poor routing and securing. The reason I say "poor routing and securing" is because, as I mentioned before, the DIN standard for this hose does not call for internal springs. Therefore I also assume that the spring has been added by someone (FD or other person) to keep it from kinking and thus restricting flow. If this hose were instead properly routed and secured as required by its design DIN 73379, there would be no need to add an additional feature to the hose. The other option might be to use a different standard of hose that is actually designed to resist kinking in this particular application. Any of this would of course require approval.

 

If this spring is really a safety of flight issue, there should be something to tell everyone this. An unknowing mechanic might order the correct P/N and replace this hose without ever realizing that there is supposed to be a spring installed.

 

Mr Morden, Roger,

If the manufacturer will not issue an alteration approval, and you believe that by not doing so, there is a safety issue, GO TO THE FAA.

 

Roger,

Did you get a copy of the FD approval to install those springs yet?

 

 

Doug Hereford

[Jim Meade]

The reason I went ELSA is because I could then perform my own condition inspection with the Inspector rating. That I can make reasonable modifications to my airplane is an added bonus, but not the main reason.

 

I'm done with this discussion. I started it and the thread develops the subject very clearly and forcefully.

[Roger Lee]

Did you get a copy of the FD approval to install those springs yet?

 

It'll never happen. Just like everyone here breaks traffic laws whether on purpose or by ignorance of the law. They will continue to do it and we all do it and we find justification doing it even at the risk of the fines. So you're picking and choosing which laws and rules you want to break or bend.

 

It's hard to break laws and rules and criticize the other guy because he can justify his end and you can't.

It's all the same just a different camp.

[WmInce]

. . . "The reason I went ELSA is because I could then perform my own condition inspection with the Inspector rating. That I can make reasonable modifications to my airplane is an added bonus, but not the main reason." . . .

 

This thread makes a very good case for taking the airplane to ELSA.

Is the proposal to limit passengers, if going SLSA to ELSA, off the table?  That limitation would be a big drawback.

Thanks for getting the discussion started.

[Roger Lee]

No fighting on my part, just clean fun debate and perspective.

[Jim Meade]

This thread makes a very good case for taking the airplane to ELSA.

Is the proposal to limit passengers, if going SLSA to ELSA, off the table?  That limitation would be a big drawback.

Thanks for getting the discussion started.

Bill,

I'm not aware of the passenger limitation proposal you mention.

AS far as where you can and can't fly, Van's RV folks are mostly Experimental and we don't hear them complaining of being limited in where one can fly. I've never been, but of course I've not tried to fly everywhere so I can't state unequivocally that it won't happen, but I've not heard of it.

[FlyingMonkey]

Bill,

I'm not aware of the passenger limitation proposal you mention.

AS far as where you can and can't fly, Van's RV folks are mostly Experimental and we don't hear them complaining of being limited in where one can fly. I've never been, but of course I've not tried to fly everywhere so I can't state unequivocally that it won't happen, but I've not heard of it.

 

There was a proposed rule change a while back that slipped in a provision that E-LSA could not carry passengers.  The FAA ran away from it when they got caught and EAA and a lot of pilots called BS.

 

The rules for experimentals are that you must fly over congested areas in a manner such that "the failure of a power unit (engine) will not pose undue hazard to persons or property on the ground."  That's pretty milquetoast language, and basically just says you have to operate in such a way that if you have to put it down you can do everything possible to minimize collateral damage.  Which you should basically do in ANY aircraft.  Stick to the 1000ft vertical above whatever is within 2000ft laterally per the FARs, and I think you can claim that you are not presenting "undue" hazard.  After all, the FAA is not going to argue that its own rules are hazardous.

[Ed Cesnalis]

There was a proposed rule change a while back that slipped in a provision that E-LSA could not carry passengers.  The FAA ran away from it when they got caught and EAA and a lot of pilots called BS.

 

The rules for experimentals are that you must fly over congested areas in a manner such that "the failure of a power unit (engine) will not pose undue hazard to persons or property on the ground."  That's pretty milquetoast language, and basically just says you have to operate in such a way that if you have to put it down you can do everything possible to minimize collateral damage.  Which you should basically do in ANY aircraft.  Stick to the 1000ft vertical above whatever is within 2000ft laterally per the FARs, and I think you can claim that you are not presenting "undue" hazard.  After all, the FAA is not going to argue that its own rules are hazardous.

 

It is not the FAA that has tried to prohibit experimentals but municipalities.   

[FlyingMonkey]

It is not the FAA that has tried to prohibit experimentals but municipalities.   

 

The proposed rule in question was a change to experimental definitions and limitations in the FARs, and applied only to E-LSA, not E-AB or Exhibition aircraft.

[Ed Cesnalis]

I was responding to this part "After all, the FAA is not going to argue that its own rules are hazardous."  My point being that changing to experimental does run the risk of being prohibited even if the FAA isn't the threat.  North Las Vegas tried to enact such a prohibition twice.  http://generalaviationnews.com/2009/11/09/vjt-pilots-thwart-ban-on-experimentals/

 

The attempt to limit experimental aircraft at the airport came after the crash of a Velocity on Aug. 22, 2008. According to the National Transportation Safety Board, the homebuilt, which had about five hours on the airframe, was on a flight to test the aircraft’s performance with an engine boost from a non-certified, belt driver supercharger normally used in cars. The Velocity failed to gain altitude above 300 feet and within 30 seconds of departure crashed into a home located in a densely populated area one mile from the airport. Two people in the home and the pilot were killed. Media reports about the crash played up experimental aircraft as inherently dangerous. Critics of the airport called for banning all experimental aircraft and the removal of so-called “high-risk activities,” such as flight training and student solos.

 

 

[WmInce]

. . . "There was a proposed rule change a while back that slipped in a provision that E-LSA could not carry passengers.  The FAA ran away from it when they got caught and EAA and a lot of pilots called BS." . . .

 

Andy,

 

It was my understanding, that the proposed rule (passenger limit) was to apply to S-LSA's being converted over to E-LSA.

So in regards to that, it would apply to S-LSA owners, like you and I.  The proposed rule would not have applied to those already flying registered E-LSA aircraft (which doesn't make much sense).

 

I agree with the opposition, it was a bunch of BS.

Have not heard much of that proposal lately.  I hope the FAA took it off the table permanently.

That withstanding, I am seriously considering going E-LSA for the same reasons that Jim Meade so eloquently stated.

[FlyingMonkey]

I was responding to this part "After all, the FAA is not going to argue that its own rules are hazardous."  My point being that changing to experimental does run the risk of being prohibited even if the FAA isn't the threat.  North Las Vegas tried to enact such a prohibition twice.  http://generalaviationnews.com/2009/11/09/vjt-pilots-thwart-ban-on-experimentals/

 

The attempt to limit experimental aircraft at the airport came after the crash of a Velocity on Aug. 22, 2008. According to the National Transportation Safety Board, the homebuilt, which had about five hours on the airframe, was on a flight to test the aircraft’s performance with an engine boost from a non-certified, belt driver supercharger normally used in cars. The Velocity failed to gain altitude above 300 feet and within 30 seconds of departure crashed into a home located in a densely populated area one mile from the airport. Two people in the home and the pilot were killed. Media reports about the crash played up experimental aircraft as inherently dangerous. Critics of the airport called for banning all experimental aircraft and the removal of so-called “high-risk activities,” such as flight training and student solos.

 

Ah, I see what you are saying.  I thought that the FAA put the hammer down on such attempts and said that it is the sole arbiter of what is legal in the national airspace, and would not allow every town to have its own hair-brained rules.

[FlyingMonkey]

Andy,

 

It was my understanding, that the proposed rule (passenger limit) was to apply to S-LSA's being converted over to E-LSA.

So in regards to that, it would apply to S-LSA owners, like you and I.  The proposed rule would not have applied to those already flying registered E-LSA aircraft (which doesn't make much sense).

 

I agree with the opposition, it was a bunch of BS.

Have not heard much of that proposal lately.  I hope the FAA took it off the table permanently.

That withstanding, I am seriously considering going E-LSA for the same reasons that Jim Meade so eloquently stated.

 

Yeah, you are correct, I forgot it only applied to conversions and not original E-LSAs.  Even dumber!  

[Doug Hereford]

Jim Meade,

I think your initial observation about the forum's general position on SLSA rules has been largely confirmed with this discussion.

 

In briefings I have had with air crews over the years, one statement from a pilot sticks with me. While broken on the road, he was asking me what he should do (whether or not he should dispatch) with whatever it was (I don't remember now) inoperative. My immediate answer was: What does the MEL say? He sharply replied to me that this was a $50K charter, and that we will worry about safety when we have more time. Don't go clouding the issue with a bunch of rules................................................................................................................................................................................He was joking.

 

Doug Hereford