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Documentation for "On Condition" 912 ULS


Isham

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My engine has less than 400 TT.  It is 13-years old.  I plan to go on-condition when it reaches 15-years and keep the airplane in SLSA.  No commercial use of this airplane.

My question is:  What documentation is needed and does it need to be approved by any FAA office, local GADO prior to the 15-year limit?

My plan is this:

1.  Based on research on here and the Rotax Owner site I developed a document containing the ROAN general guidelines for going "on condition" and added reference material (4/22/2011 FAA Legal letter on the Beech Baron question, the ROAN guidelines and reference from the flight manual to the rotax-owner.com site for useful airworthiness info) to become part of my log book package. 

2.  I plan to start documenting the condition on a form I developed at my next oil change or condition/annual inspection and continue this past the 15-years for as long as the engine meets a safe condition.  This provides a baseline for the next 2-years before I reach the 15-year mark.

I want to make sure I do this legally. 

Thank you for you input.

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There is nothing special for this that you shouldn't be doing every annual. Below is the FAA stance on TBO. Places like Lockwood now refuse to work on your plane if it is timed out in hours or years. Of course because that's $14K+ in their pocket. I have attached two letters from the FAA and if you even read down to the last sentences in the FAR's on TBO it says it's acceptable because Rotax of an aircraft company can not dictate rules or regs over what the FAA has in place. Some would like to think they do though.

A little soapbox here too. :) 

Start printing out the Rotax check list from the Line maint. manual and the checklist from the FD maint. manual. Fill out the front page. Sign off everything as you go and annotate anything you touch, tweak, torque or change as you go in the margins. Include the 100 hr and annual together and say so. Collect an oil sample and send it in. Keep all of these in a 3 ring binder. You only need the oil sample at annual and not every single oil change. When you do a logbook label strive to be a cut above average and do a good job. Too many people are happy with average.  For me a normal annual logbook entry is typed in #9 font and a full page long and on a hose change and other items to fix could be two pages. Same thing in the logbook entry. If you touch, tweak, torque or change some thing log it. If you inspect all the hoses write that you did it. Write what the gearbox friction torque was, that you changed oil and the filter (what filter who's oil, did you inspect the mag plug, did you safety wire it and the oil tank plug). There is nothing magical about logbook labels. It should be just like a doctor writes in a patient chart. The courts say if you didn't write it you didn't do it and I've seen many a Dr, nurse, fireman, police officer or medic burned to the ground for crappy documentation. Of course the people that have never spent anytime in court tend to argue this.

Be better than average or what just barely meets legal. Does it take a little longer to write it up over the mechanic that puts a three liner in the book, yes, but it is worth it. More money when you sell, easier to sell, less chance of the FAA or Insurance company taking you down and even if your buddy says he won't sue you if he gets hurt his wife or relatives don't care. Going to court for 30 years taught me well and I never got burned because I listened the first 3 weeks of med school to the three lawyers that came in.

Never ever be lazy in documentation. It's your only savior. expect nothing less from any mechanic. Your paying good money for the work. Get it done the way you want it.

Every single person that has come through my shop since day one gets a discrepancy list, a Rotax checklist and fuselage checklist and a good solid detailed logbook label.

Damn fell off my soapbox and hurt my ankle. LOL

 

FAA and the TBO.pdf TBO....willette-dodgecenteraviation - (2013) legal interpretation.pdf

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Thanks Roger!  Great write up and I particularly like the Willette/Dodge letter from FAA.  It is very CLEAR and answers my concern.

I agree on inspection records and log entries.  That is exactly the way I did my Piper inspections and it did help with the pre-buy mechanic when he inspected it for the buyer.  He knew the airplane was well maintained. 

Since this is my first LSA I am on a learning curve.  Unfortunately, the prior owners mechanics were mostly three liners and it took me about a week to sort through all of the log entries and match up the complied with SB's, receipts and other paperwork.  It is now very organized and includes an SB section with a spreadsheet. 

I will probably include a copy of the referenced letter in my logs just in case anyone would ever question the engine age. 

Appreciate your time and input to my post.  There are many posts out there on this site and the Rotax site (including several of yours) and your input above is a great and easy to understand answer that I think a lot of owners will find useful.

 

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I totally agree with Roger here.  The only entity that can set maintenance procedures and intervals for an S-LSA airplane is the airplane manufacturer, not individual component manufacturers.  An engine is a component just like a voltage regulator, an intercom, or a bolt.  If a bolt manufacturer said that every bolt on an airplane should be replaced every 12 years, that would not be legally enforceable unless the *airplane* manufacturer stated such.  Likewise Rotax cannot mandate an engine replacement or overhaul for an S-LSA, only the airplane manufacturer can do that.

The only way you might run into a problem would be if the airplane manufacturer had a statement in their maintenance procedure that all Rotax maintenance and replacement intervals must be adhered to strictly.  As far as I know and have read, nothing like that exists for FD.

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Agree.  After reading Roger's write up and the referenced FAA Legal letters the only way the manufacturer could make it mandatory is list it in their "Airworthiness Limitations" (which they do not have) or for the FAA to issue an AD.

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I found this FAA Clarification of Inspection and Overhaul which is quite interesting.  Basically says Part 91 airplanes are not required to do an overhaul at TBO, or SB's.  File is attached.  It supports the FAA legal positions on this subject.  I highlighted much of what I considered applicable here. 

In my opinion, owners that place their airplane in Experimental because they think it saves them an Overhaul or SB avoidance are mis informed.  No reason to put the airplane in Experimental.

n_8900.410.pdf

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8900.1 - Volume 3 Chapter 15 Section 1.pdf

8900.1 - Volume 3 Chapter 15 Section 2.pdf

  

18 minutes ago, WmInce said:

Since it has a cancellation date of 3/31/18, I would like to see the replacement document.

 

These two files are from the FAA's 8900 (AKA their operating Bible).  Good stuff in there.  Almost anything an FAA inspector has to deal with will be somewhere in FAA 8900.1.

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