12 year mandatory overhaul

[Roger Lee]

And the A&P must be present all the time on an owner assist. . The owner can not work on an aircraft if the A&P isn't present. I confirmed that with the FAA. They said he isn't supervised if the A&P isn't there. How many times have you seen an owner by themself. A bunch.

[Doug Hereford]

Roger,

I am Literally laughing out loud.

Your "self rescue" video has the owner working by himself.............................in a field.

Hard to stomach again. 

[Runtoeat]

I have never totally understood "what is legal and what is not" when it comes to a non-certified person attempting to do maintenance.  In particular the "supervision" part of this.  The replies provided have really helped me, and I believe will help others, understand this topic a lot better.

 

[Doug Hereford]

Runtoeat,

FAR part 43 app A gives a list of items of preventive maintenance. 43.3(g) is the regulation that allows pilots and sport pilots to actually PERFORM any of those listed items on their aircraft (in the field or road or podunk airport). 43.7(f/h) lets that same pilot/sport pilot approve that SLSA aircraft for return to service. Then he/she can legally (and safely) fly back home. So contrary to what Roger said above, an owner can work on the aircraft when an A&P is not present........................under certain specific circumstances.

I don't know what certification you hold, but unless you are a student or recreational pilot, you can perform and approve for return to service, items of preventive maintenance on your own without any supervision. Just remember to make that maintenance record entry in the aircraft records before you are "wheels up".

Roger,

Disassembling a carburetor is still not on the list of preventive maintenance items in 43 app. A. Therefore, the many times aforementioned "self rescue" techniques of debris removal from the carburetor in an SLSA is reserved for supervised pilots, or pilots who also hold appropriate mechanic or repairmen certification. I am still laughing at your last post and looking for that Prilosec.

Don't forget to up date the forum with the FAA's opinion on the "self rescue" video.

Mr. Morden,

I don't know what certifications you hold either. If you have not read 43 app A, you may want to. I think you would be pleasantly surprised at how many mechanical type things that you are allowed to do as just a pilot (I realize that you might be a mechanic and consequently do not care). In my opinion, we are actually not that heavily regulated in this country when it comes to "Joe Blow" general aviation.

[Anticept]

Keep in mind, appendix A does not apply to S-LSA. The maintenance tasks and who may perform them are on the manufacturer to provide, hence why the manuals come with provisions stating the certification required as part of ASTM compliance.

[Roger Lee]

You don't want more regulation to hold people back, but you're using them now to hinder people and their education that may save them from being stranded.

I guess you have never been stranded with no help available.  You're still forgetting the thousands of experimentals that can do what they want and others worldwide and no one is twisting anyone's arm. Do or don't do.

Knowledge is king when the chips are down and you're by yourself.

These people here are smart and want knowlegde and I know none that would be afraid to help themselves.

Why do you want to hinder them?

You can sit on the sideline and cry and complain or stand up and act. The choice is yours when things go wrong.

If I worried about regulations and rules I probably shouldn't drive a car or do anything else since I tend to break rules everyday..

I'm sure you break rules too in some form. People break rules every day.

 I'm not sure why you chose to single this one out and try and berate me.

 

If this video is so upsetting why aren't you one the Rotax Owner forum. They have a bunch of how to videos and so does the EAA.

 

 

[Runtoeat]

Doug, I went into App A and found this under "(C) Preventative Maintenance" (paragraph 23):

"Cleaning or replacing fuel and oil strainers or filter elements"

I really didn't want to go into CFR rules because I totally don't understand them and the way the rules are structured, with all of the clauses that rule out other clauses, makes it difficult to understand what the damn FAA is saying.  You are certified in many areas and I am not certified nor do I understand the CFR rules.  I am not being argumentative but just trying to learn. My interpretation of the above paragraph is this allows a non-certified person to perform certain types of maintenance to a fuel system.  Does this rule allow a non-certified person to take apart the gascolator which requires removing the bowl and the filter screen and then reassemble this which, on my CT, includes safety wiring?  If so, wouldn't this procedure also allow the removal of a carb bowl since this task requires the same proficiency and caution to carry out as is the case with a gascolator?  If this doesn't allow cleaning the gascolator, my logic doesn't hold water (pun intended). 

[Doug Hereford]

Runtoeat,

Your are correct about the gascolator. Cleaning it is preventive maintenance, and can be done by an owner/operator sport pilot. The carburetor bowl would not be a part of that. When you remove a carburetor bowl, your disassembling the carburetor.

Replacing safety wire is also preventive maintenance.

Corey,

43 App. A list of preventive maintenance items absolutely apply to SLSA. The manufacturers have no authority to say WHO can perform maintenance/preventive maintenance with the possible exception of a Safety Directive.

Roger,

I do not mean to ever berate anyone. I apologize if you think that I am doing that.

As far as I know, I am still on the Rotax forum, and have been for years.

 

[WmInce]

13 hours ago, Doug Hereford said:

Roger,

I am Literally laughing out loud.

Your "self rescue" video has the owner working by himself.............................in a field.

Hard to stomach again. 

The joke is on you.

The only complaint I have about Roger's videos is . . . he doesn't post enough of them!

Take care of that stomach.

 

[Runtoeat]

Doug, still not convinced about the differences between gascolator and carb.  The gascolator has a bowl and screen which collects sediment and has a bail wire which is pressed aside to allow removal of the bowl.  Isn't removing the gascolator bowl effectively disassembling the gascolator?   The carb has a bowl intended to allow sediment to settle out and also to provide reserve amount of fuel to keep full flow of fuel to engine when needed.  Isn't the bail wire on the carb intended to allow easy removal of the bowl to check for sediment and for removal of the sediment?  Seems to me that the intent for both the gascolator bowl and the carb bowl is to allow for simple maintenance that is not highly technical.

[Doug Hereford]

Runtoeat,

I agree that taking the bowl off of this type of carburetor is pretty basic. The preventive maintenance tasks make no assumptions about specific brands/designs of products, just that they not involve complex assembly operations. When you remove the bowl, there is more going on than first impressions might see. A carburetor bowl does much more than collect sediment. In fact, I think that Bing would say there really shouldn't be sediment in the bowl at all, and if there is, its source should be found and corrected.........................unlike a gascolator who's purpose is actually to trap sediment and water and stuff.

There is a lot of individual interpretation needed with 43 app. A I will admit.

When Roger hears back from the FAA we can all know for sure.

 

WmInce

As I said before, I have no problem with the video content, just the context. That is why I was laughing. On one hand, as Roger eluded to,  we don't want owners working by themselves unauthorized and unsupervised, and yet the video promotes just that. Furthermore, it has one working in a very non-standard situation.

[Anticept]

I don't think 43 appendix A applies to S-LSA. I'm pretty sure I saw this in one of the FAA's docs stating that the manufacturer decides who can do what kind of maintenance (in compliance with ASTM standards). That said, "preventive maintenance" is also in 43.3 so I am not sure what to believe.

[Tom Baker]

Dick, if the Bing carb had a screen or filter inside the float bowl, then it would fall under preventive maintenance. Since it does not it becomes a maintenance task that does not fall under preventive maintenance. In many applications removing the float bowl is not just a simple task of flipping the bail and removing. For example on the CTSW the carb must first be removed from the socket. I have had the balance change from doing this, because of removing and reinstalling back in the socket. That being said, over the years the list in appendix A has changed to keep up with the times. Especially to keep up with modern avionics. Maybe it is time, due to the large numbers of Rotax engines for it to change again. You could petition the FAA to revise appendix A to allow for removal of the float bowl on a Rotax engine with Bing carburetors.

[WmInce]

56 minutes ago, Doug Hereford said:

WmInce

As I said before, I have no problem with the video content, just the context.

I could care less about the 'context' or the perceived audience Roger is targeting.

All I know is I'm learning something.

Isn't that the whole point?

[Doug Hereford]

Corey,

Read the original rule preamble. It confirms the intent to include 43 app A as preventive maintenance tasks for SLSA.

 

Runtoeat,

Another thing about preventive maintenance is it generally done as its name implies...................to prevent an unsafe condition. Sediment in a carburetor would most likely always be an unsafe condition. 

 

WmInce,

You may not care, but I do. Like I said earlier, I wouldn't have known about the video if one of my customers had not mentioned it to me. See he thought he would be doing me a favor if the part 141 flight school's airplane lost power while he was renting it. I happen to perform maintenance on that plane. My name is all over the records. The last thing anyone needs is unauthorized, undocumented maintenance taking place behind a required inspection or other work. I explained all that to him and he agreed with me. 

I think if you ask any inspector they will tell you the same thing.

[WmInce]

4 minutes ago, Doug Hereford said:

WmInce,

You may not care, but I do. Like I said earlier, I wouldn't have known about the video if one of my customers had not mentioned it to me. See he thought he would be doing me a favor if the part 141 flight school's airplane lost power while he was renting it. I happen to perform maintenance on that plane. My name is all over the records. The last thing anyone needs is unauthorized, undocumented maintenance taking place behind a required inspection or other work. I explained all that to him and he agreed with me. 

I think if you ask any inspector they will tell you the same thing.

Okay, but let's not throw the baby out with the bath water.

If I am armed with the information provided by that video, I can refer the A&P to it and/or provide advice to him/her on a proven method of troubleshooting. At least that's a start . . . 

On the other hand, I don't think any inspector would object to us viewing that video. YMMV.

Your customer was wrong in his thinking. Glad you pointed that out to him.

[Doug Hereford]

WmInce,

Sound fair to me. Hopefully Roger's FAA guy will give his opinion on it. Obviously his opinion will carry much more weight than mine does. Maybe we will have an expert opinion on Monday.Until that time, I stand firmly on everything that I have said.

If the joke is on me, then it is on me.

[Tom Baker]

4 hours ago, Doug Hereford said:

WmInce,

Sound fair to me. Hopefully Roger's FAA guy will give his opinion on it. Obviously his opinion will carry much more weight than mine does. Maybe we will have an expert opinion on Monday.Until that time, I stand firmly on everything that I have said.

If the joke is on me, then it is on me.

The FAA' guy's opinion is no different than yours, and carries no more weight. It only becomes a real opinion when the answer comes from FAA legal. 

[Doug Hereford]

Tom,

Yes. What I should have said is that his opinion will likely be more respected and likely seen as more credible. I realize that I find myself in unpopular positions on this forum. I don't mind it though.

Even though I have never had any kind of enforcement or disciplinary action from the FAA, I have been in numerous heated discussions with them when their opinion and mine did not match. Fortunately I have always managed to come out on the right side of things. No guarantee for future events though. 

If I have legal questions, I do put them to the chief counsel, never the FSDO.

[Runtoeat]

Good discussion and a good learning thread.  Like Corey, it was my understanding that preventative maintenance was different for SLSA than GA.  I will read the preamble but only due to my curiosity since Doug seems to know the FAA rules.  To have confidence I could remove and install the float bowl, should the need arise, I did this at my last conditional inspection while my mechanic stood by.  He then removed and re-installed it to insure it was correctly installed.  I do understand this isn't a simple procedure due to the possibility of "tweaking" the float needle armature and/or not positioning the bowl gasket properly.  I have also done this on many small engines and motorcycles.  I am confident I could do this correctly if it turns out that i am allowed to do so.

[FredG]

Dick, go Experimental.  It will set you free.

[Doug Hereford]

https://www.google.com/url?sa=t&source=web&rct=j&url=https://www.aopa.org/-/media/files/aopa/home/news/all-news/2004/aopa-online-members-only-aopa-epilot-flight-training-edition-vol-4-issue-30/sport_rule.pdf%3Fla%3Den&ved=0ahUKEwiC4tCHjM3XAhVSx2MKHW0hDR4QFggoMAA&usg=AOvVaw3lb_8xsPJ6IFgxImP1mq6B

I am not very good at the link copy thing, but here is a link the the Light Sport original rule preamble stuff.

It is a large doc. Part 43 details are about half way through when you scroll along.

sport_rule.pdf

[Runtoeat]

Hi Fred.  This carb bowl situation is a perfect example of a good reason for going experimental.  IMHO, anyone with experience fixing mechanical things is capable of doing this safely without certified mechanic supervision.  The other option would be for me to get the LSRM to be certified for working on SLSA.  Currently, I am able to work on my CT while being supervised by my mechanic.  This is a safe, convenient and low cost situation and has worked well, so far. 

Doug, you realize you're going to just confuse me by showing me this FAA stuff?  Just kidding.  I'll try to understand this but nothing guaranteed.  Thanks for posting. 

[Doug Hereford]

Runtoeat,

Actually the document contains a bunch of input from the field from regular "joes" like you and me.

 

Back on that carb bowl situation, whether ELSA or SLSA or Standard Airworthiness, if you are self rescuing  and find carb bowl debris, my advice would be to ask yourself why it is there...................and be able to actually answer that same question before further flight.

[Ed Cesnalis]

6 minutes ago, Doug Hereford said:

Runtoeat,

Actually the document contains a bunch of input from the field from regular "joes" like you and me.

 

Back on that carb bowl situation, whether ELSA or SLSA or Standard Airworthiness, if you are self rescuing  and find carb bowl debris, my advice would be to ask yourself why it is there...................and be able to actually answer that same question before further flight.

After the 5 year rubber hose change the answer is: its there from the barbed fittings damaging the new fuel lines.  You have to assume there could be more than what is currently in the bowls but probably far less than the first event.