Doug Hereford Posted November 20, 2017 Report Share Posted November 20, 2017 Ed, That has been my point back to the hose change portion of this discussion. I think we can agree though that there are other things that could cause contamination of the float bowls too. I actually looked up the Rotax procedure for inspecting the float bowls, and it very explicitly requires a determination of cause and subsequent corrective action for ANY contamination in float bowls. The procedure also calls out for idle speed adjustment. Roger, Anything from the FAA yet? Link to comment Share on other sites More sharing options...
Roger Lee Posted November 20, 2017 Report Share Posted November 20, 2017 Hi Doug, I just did hear back. They quoted out of 43.1a and checked the video. They said this is NOT a complex task and it is covered under the sediment / filter ruling under preventive maint. Their example was a Schebler Carb where to do the same bowl removal entailed removing a number of screws and some disassembly and then calibrating the carb. That is considered a complex task. The Rotax carb bowl is just a sediment basin to collect debris and water before entering the carb like the gascolator which has a bale to remove it. Part 43.1a allows for a sediment filter or filters to be serviced by an owner as preventive maint. This bale removal is not considered disassembly nor complex. You can't take what the Rotax manual says for it's literal interpretation at times. This is why going to Rotax schools on a continuing basis (every two years) helps remedy things like this. There are changes to manuals that don't get published on a daily basis. Most probably don't even know there are new March 2017 manuals out. "The procedure also calls out for idle speed adjustment." My way needs to adjustments. It becomes a mute point. Rotax believes in this statement that you disassembled the carb flushing out all orifices. All we're doing here is checking the sediment bowl. So does this move me to the top of your X-Mas list? Link to comment Share on other sites More sharing options...
Doug Hereford Posted November 20, 2017 Report Share Posted November 20, 2017 Roger, You have always been at the top of my Christmas list. Now we all know. Thanks. Link to comment Share on other sites More sharing options...
Runtoeat Posted November 20, 2017 Report Share Posted November 20, 2017 Guess my logic was good with the comparison made between the gascolator bowl and Bing float bowl but I really didn't think the FAA would be this logical. Chalk it up to something else I've learned from this thread. Thanks for taking the time and effort contacting the FAA Roger. Suggestion: Perhaps the Forum management might want to "pin" this thread for future reference?. Link to comment Share on other sites More sharing options...
Doug Hereford Posted November 20, 2017 Report Share Posted November 20, 2017 Runtoeat, Come on now. Everybody is entitled to be wrong now and then. Ha ha. Good idea on the "pin". Link to comment Share on other sites More sharing options...
Doug Hereford Posted November 20, 2017 Report Share Posted November 20, 2017 Roger, I don't mean to belabor this point, but in the spirit of total thoroughness, would you mind giving me the name of your FAA contact so that I might contact them and confirm exactly what you said and what he said? I have re-read your post, and some of the details are a bit confusing to me. Apparently I have been misunderstanding some things for a while. I want to set straight some mis-information that I may have spread, but feel like I need to be able to quote the FAA directly. I am glad to give you my personal contact info if needed. Link to comment Share on other sites More sharing options...
Doug Hereford Posted November 20, 2017 Report Share Posted November 20, 2017 Runtoeat, Who knows.....................It depends on what you think constitutes a win for LSA pilots. If the opinion from Roger's FAA contact is actually the opinion of the collective FAA, than my personal opinion is that it is not a win for aviation in general, but a degradation in our safety standards for some unseen reason. As I think Tom Baker aptly pointed out, representatives from the FAA can give their opinions just like you or I can. They put their pants on one leg at a time too. When their legal counsel weighs in though, it carries a little more weight as their opinions represent what they (collective FAA) are likely willing to litigate. That is why I have asked Roger for his contact. If I can follow up on this, I will do so by email, and copy this forum in on exactly what is said between both of us. As I have said earlier in this conversation, I don't mind arguing with the FAA when I feel that safety or my ability to properly do business is at stake. I am not interested in being right for the sake of being right. According to the FAA, the CT has two gascolators (actually three) I guess. I will say that I am very surprised that they did not have a huge problem with the "self rescue" situation in general. Link to comment Share on other sites More sharing options...
Doug Hereford Posted November 20, 2017 Report Share Posted November 20, 2017 I would add that while I have not asked any aviatiors their opinion on this topic, I have asked several non-aviation, non-mechanical people about it. Their unanimous first question to me was...............where did the debris come from? I was not leading in my questions, nor did I have them watch the video. They also all told me that if I ever have that happen while flying one of their kids around, to call an Uber for them (the passenger) before I self rescue from the field. Link to comment Share on other sites More sharing options...
Tom Baker Posted November 20, 2017 Report Share Posted November 20, 2017 I can see removing the bail and dropping the bowl as a simple operation that could be allowed under appendix A. The thing is that is not all that is going on. You are not just flipping the bail and dropping the bowl. On the CTSW you have to remove the carburetor from the socket to remove the bowl. Others you have to remove the drip tray. Again these things are not hard to do, but they can lead to other issues. I have had the balance change significantly after simply popping the carb off to check the float bowl during a condition inspection. I have had the floats not seat on the levers right causing the float valve not to seal properly causing flooding. I have seen the bowl gaskets shift and get pinched causing a fuel leak right over a hot exhaust pipe. I have seen un certified people who could do this with no issues. I have seen certified people who shouldn't be doing this. The worse case will be un certified people who shouldn't be doing this doing it because of regulations saying it is OK for them to do. Link to comment Share on other sites More sharing options...
Doug Hereford Posted November 21, 2017 Report Share Posted November 21, 2017 Appendix A would allow them to do it if they were just removing an arbitrary bail on some on some arbitrary fuel sediment bowl. A carburetor "float bowl" is NOT a sediment bowl. Find me one carburetor assembly that refers to this reservoir as a "sediment" bowl or filter or gascolator. Roger, In your video..........what are those small little black things that you nonchalantly take out to remove "sediment? Floats..................... what are they riding up and down on? Why did the engine lose power to begin with? The ease of removing the fuel reservoir "bail" has nothing to do with the critical nature of maintenance on a carburetor. I would echo that certifications are not the issues here. Safety is. There will always be people that are qualified on a legal basis that "should not" on a practical basis.............and conversely so. However, I will emphatically say that the FAA is very wrong here if they think taking a carburetor bowl off and dumping out "sediment" falls under the heading of preventive maintenance. Roger, Get me your FAA contact info so that I can have an argument with them.............I promise to publish it verbatim on this forum for all to be entertained by. Runtoeat, where did your post go? Link to comment Share on other sites More sharing options...
Ed Cesnalis Posted November 21, 2017 Report Share Posted November 21, 2017 @Doug Hereford Speaking for those of us that got our start in 2-stroke home-built machines the idea of leaving our slightly more complex plane in a field over an issue we have handled is a tough sell. even if your right Link to comment Share on other sites More sharing options...
Doug Hereford Posted November 21, 2017 Report Share Posted November 21, 2017 Not if........................for example you are the parent of a kid taking a ride with you when you landed that plane in the field due to power loss. Easy sell. See, not everyone who watches maintenance videos, or who flys airplanes is someone who does so in a Lone Ranger nothing can hurt me kinda way. The rules account for this. By the way, I have no problem with a Lone Ranger approach when it is appropriate. I would also not want to leave my machine in a field, but I would if necessary. And I don't mean to imply that you would do differently. Link to comment Share on other sites More sharing options...
Doug Hereford Posted November 21, 2017 Report Share Posted November 21, 2017 Roger, I am going to need that contact info. If you don't want to give it, I understand. I sent you a private message as well. If you don't let me know who you talked to, I will e-mail Edsel Ford as a starting point. I will save and copy my emails as I go. Link to comment Share on other sites More sharing options...
Anticept Posted November 21, 2017 Report Share Posted November 21, 2017 Remember that these regulations are not there as an end all be all solution to a problem, and that problem being maintenance induced failures. Rather, they are intended to raise the bar and qualifications in an attempt to reduce such failures. It's a statistics game. I'm sure there's a study somewhere about this. Link to comment Share on other sites More sharing options...
Roger Lee Posted November 21, 2017 Report Share Posted November 21, 2017 The question was answered. No reason to turn this into a 20 page what if scenario. To answer the second half of those what ifs: If your problem didn't get solved by simply dumping the bowl which you should have actually seen debris then further carb tear down is necessary then you need a certificated person to perform that. The only hose that can give you debris in the carbs is the short 14" hose off the bottom of the pump that goes to the carb crossover fuel distribution assembly. Why? Because the fuel pump has its own internal filter and anything before this will get stopped there. Most engine either have the stainless steel carb feed tubes or the Teflon and neither presents a problem. Planes like the Sport Cruiser that uses rubber hose all the way to the carbs have a bigger concern. The key comment here is that you should be able to see any debris. Link to comment Share on other sites More sharing options...
Doug Hereford Posted November 21, 2017 Report Share Posted November 21, 2017 Roger, Are you going to tell me who at the FAA you talked to? Link to comment Share on other sites More sharing options...
Roger Lee Posted November 21, 2017 Report Share Posted November 21, 2017 I already got you the answer. I'm headed out the door as we speak to Tombstone, AZ for the week to ride the hills and explore the mines. Link to comment Share on other sites More sharing options...
Doug Hereford Posted November 21, 2017 Report Share Posted November 21, 2017 Ok, I guess I will assume that you spoke to Edsel Ford. I plan to email him so that I can get a clarification. I will post any communications on this thread. Have a great trip! Link to comment Share on other sites More sharing options...
Runtoeat Posted November 22, 2017 Report Share Posted November 22, 2017 Geeze, this is like watching The Curse of Oak Island! Link to comment Share on other sites More sharing options...
Doug Hereford Posted November 28, 2017 Report Share Posted November 28, 2017 On 11/20/2017 at 11:21 AM, Roger Lee said: So here is what I got back from the FAA on the rescue video and preventive maintenance activity. The emails are out of order. My question is below and the response is in blue. Van.Stumpner (Van.Stumpner@faa.gov)To:you Details Slideshow Van.Stumpner Van.Stumpner@faa.govHide To whitefaced whitefaced@aol.com Cc Bcc Slideshow Greetings Doug, I hope that you had a great Thanksgiving and are doing well. With regard to your email, I completely concur with the advice that you gave the operator of the SLSA. According to Part 43 Appendix A that deals with preventative maintenance (c) (23) only allows for the cleaning of or the replacement of fuel strainers or filters. I would have thought that Rotax inspection requirements would cover fuel system maintenance pretty thoroughly with regard to contamination. If this is a common occurrence perhaps a better solution would be to address the problem via a manufacturer safety directive. Like you, I can envision all sorts of bad things happening when an unauthorized person is performing maintenance on a fuel system in less than ideal circumstances. For SLSA aircraft, such maintenance would have to be accomplished by an A+P mechanic or an LSA repairman with a maintenance rating and would require a maintenance record entry. Draining the carburetor bowl to check for contamination is covered on most of inspection checklists for GA aircraft that I’ve dealt with. I was in KC to go through the TWA museum (ex-employee) and we walked through your hangar to see the MD 80 and I saw the guys working on the LSA and figured one of them was you. I still look forward to meeting you soon. Take care Van From: Doug Hereford [mailto:whitefaced@aol.com]Sent: Wednesday, November 22, 2017 11:51 AMTo: Stumpner, Van (FAA) <Van.Stumpner@faa.gov>Subject: SLSA maintenance Hi Van, It is Doug Hereford in KC. I have had a couple of things come up in recent past, and was hoping that maybe you could give a clarification, or point me to someone who could. I had a customer ask me about whether he could pull the float bowl off of his SLSA Rotax powered Sky Arrow and clear debris from the carburetor, in the event that he lost power and had to make an off airport landing. He referred to a you tube video as his source for this procedure to "self rescue". https://www.youtube.com/watch?v=XBT-yQ_X3N8 I was a bit taken back by the question, but after some more looking into it, I am not sure that I am correct with what I told him. I told him that he should absolutely not do this. In my opinion, removing the carburetor(s) float bowls is not a preventive maintenance activity, and under an off airport set of circumstances, it would be ill-advised anyway. Anyway, I just wanted to check and see if there were any special light sport opinions out there with regard to preventive maintenance and or this specific task in general. I will say that these Rotax carburetor bowls are pretty simple to remove on the 912 engines, but the float do come out with the bowl assy., and the carburetor itself is above the exhaust. Hope things are going good for you. My guys told me that you were up in KC and in the hangar a while back. Sorry that I missed you. All is good in KCK. Regards, Doug Hereford Here is a quote from what you said the FAA told you Roger: Hi Doug, I just did hear back. They quoted out of 43.1a and checked the video. They said this is NOT a complex task and it is covered under the sediment / filter ruling under preventive maint. Their example was a Schebler Carb where to do the same bowl removal entailed removing a number of screws and some disassembly and then calibrating the carb. That is considered a complex task. The Rotax carb bowl is just a sediment basin to collect debris and water before entering the carb like the gascolator which has a bale to remove it. Part 43.1a allows for a sediment filter or filters to be serviced by an owner as preventive maint. This bale removal is not considered disassembly nor complex. You can't take what the Rotax manual says for it's literal interpretation at times. This is why going to Rotax schools on a continuing basis (every two years) helps remedy things like this. There are changes to manuals that don't get published on a daily basis. Most probably don't even know there are new March 2017 manuals out. "The procedure also calls out for idle speed adjustment." My way needs to adjustments. It becomes a mute point. Rotax believes in this statement that you disassembled the carb flushing out all orifices. All we're doing here is checking the sediment bowl. So does this move me to the top of your X-Mas list? He Link to comment Share on other sites More sharing options...
Doug Hereford Posted November 28, 2017 Report Share Posted November 28, 2017 Pretty glaring inconsistencies Link to comment Share on other sites More sharing options...
Runtoeat Posted November 28, 2017 Report Share Posted November 28, 2017 Doug, it appears that you somehow have been successful in getting a written reply from an FAA administrator involved with LSA policy. I know from my personal attempt at this that this is not an easy thing to do. Mr. Stumpner's comments leave no doubt that he does not consider removal of the float bowl to be a preventative maintenance item. I will comply. Link to comment Share on other sites More sharing options...
Roger Lee Posted November 28, 2017 Report Share Posted November 28, 2017 Only because Van doesn't know about the differences. I will call him. All things may not be a blanket policy. You have to give them ALL the facts and paint a complete picture and not a partial picture. This is why emails are a poor median for fact finding decisions. and interpretations. Link to comment Share on other sites More sharing options...
Ed Cesnalis Posted November 28, 2017 Report Share Posted November 28, 2017 9 hours ago, Runtoeat said: Doug, it appears that you somehow have been successful in getting a written reply from an FAA administrator involved with LSA policy. I know from my personal attempt at this that this is not an easy thing to do. Mr. Stumpner's comments leave no doubt that he does not consider removal of the float bowl to be a preventative maintenance item. I will comply. 6 minutes ago, Roger Lee said: Only because Van doesn't know about the differences. I will call him. All things may not be a blanket policy. You have to give them ALL the facts and paint a complete picture and not a partial picture. This is why emails are a poor median for fact finding decisions. and interpretations. Getting comments from FAA officials accomplishes little or nothing. Their favorable comments might not be determination in an enforcement action. Getting an official written legal opinion does accomplish something though not perhaps the opinion you were seeking. Link to comment Share on other sites More sharing options...
Doug Hereford Posted November 28, 2017 Report Share Posted November 28, 2017 Ed, I completely agree that the opinion is not very binding one way or another. Take it for what it is worth. I will say that Van's reference to a safety directive is actually the main point I was driving at from the beginning (thread started with mandatory vs not mandatory). Kind of got off into the weeds a little. Link to comment Share on other sites More sharing options...
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