200 hour inspection, labor cost 16 hr?

[gogogo888]

Hi,

I have gotten 2 quotes to do 200 hour inspection on my CTSW. 
 

1 said it can be done in 4 hours

Another said it can be done in 16 hours

How many hours does it normally take to do a 200 hour inspection?

[GrassStripFlyBoy]

This is a partial question you're asking, the 100 hour items would be covered here as well, and depending on what interval of the 200 hours the 600 hour items could be required as well.  Is an oil change due, or not, how's the tires and brakes look, if it's just the basic visual items, no PM items needed, maybe closer to that 4 hour mark.  If you're hitting the 600 hour trigger, and have not been keeping up on the PM stuff, then 16 hours could be real too.  Not a simple answer, all depends on what items are needing to be addressed.

[Tom Baker]

Are you talking about the 200 hour Rotax inspection? If so I would say around 8 hours. Besides the normal 100 hour stuff you should be removing and cleaning the oil tank, removing and inspecting the carbs, and replacing the spark plugs. 

For the airplane there really isn't a 200 hour inspection. The MM list a 100 hour inspection, and a annual inspection, but in reality the only inspection recognized by the FAA is a condition inspection. For the condition inspection I use the annual inspection checklist. If you are not using the airplane commercially then you are only required to do the inspection annually. That being said if you are flying as many hours as I suspect you are then the air frame would be worth a closer look than just annually. Add another 6-8 hours for the air frame inspection

[gogogo888]

Thank you gentlemen for all the tips.

I am pretty new to aviation, there is so much I dont know.

Yes, I'm talking about the 200 hour Rotax inspection, I change oil at 60 hours Hobbs and spark plug at 120 hours Hobbs and I fly about 50 hours a month. 

I will talk to both the mechanics and ask for more details on their quotes.

[GlennM]

50 hours a month!   Good for you!  It would be nice to be able to do that.

[gogogo888]

1 hour ago, GlennM said:

50 hours a month!   Good for you!  It would be nice to be able to do that.

I’m a full time student, so, 50 hr/month will still take me another 18 months to get to 1,500 hr.

There is a CFI in my airport done 100hr/month the last 12 months!

[GlennM]

You certainly start to feel comfortable in the plane and flying in general at that rate. I usually fly between 50 and 70 hours a year, which has more to do with work and other responsibilities.   I have started making a concerted effort to fly more often because I am not going to max out my TBO on my current engine before it will be replaced in two more years. (I am not going to go E-LSA and I only mention this as a reason for me, not to start another discussion on this.)  I do like going more often, for sure. 

[gogogo888]

8 hours ago, GlennM said:

You certainly start to feel comfortable in the plane and flying in general at that rate. I usually fly between 50 and 70 hours a year, which has more to do with work and other responsibilities.   I have started making a concerted effort to fly more often because I am not going to max out my TBO on my current engine before it will be replaced in two more years. (I am not going to go E-LSA and I only mention this as a reason for me, not to start another discussion on this.)  I do like going more often, for sure. 

TBO doesnt really mean anything, there is also no regulation regarding flying over TBO.

For example I know flight school that have CTs that are 500 to 1,000 hr over TBO.

As long as we do oil analysis, change oil at 50 hour tach and use AeroShell Sport +4 and Rotax filter., our Rotax engine can go 4000 hour without any problems.

Mike Bush has a really good video on TBO and buying used aircraft.

 

 

 

 

[GlennM]

I did not want to get into this because there are those who do not subscribe to this belief and there are those that converted to E-LSA for this reason.

The key aspect of Mike Busch's video you reference is certificated aircraft.  LSAs go by consensus standard.

Here is a link to Mike Busch's article on LSAs in particular:  https://www.aopa.org/news-and-media/all-news/2016/april/pilot/pe_savvy

Here is the Keller letter, which has been on this site since it was written:  https://www.faa.gov/about/office_org/headquarters_offices/agc/practice_areas/regulations/interpretations/data/interps/2015/keller - (2015) legal interpretation.pdf

Note, the last site is the FAA itself.  This has been discussed ad infinitum and my interpretation that started me flying more is that I will need to overhaul the Rotax at 15 years or 2000 hours because of the Keller letter.  You can interpret on your own or take someone else's advice at your own risk.

Once again, congratulations on your ability to fly as often as you do.

[Roger Lee]

"We have explained above that (1) overhaul and replacement times in a manufacturer's maintenance manuals are mandatory unless otherwise
authorized by the aircraft's manufacturer or by a person acceptable to the FAA"

 

The person that wrote this letter failed to post one of the last sentences of the FAR's o TBO that is referred to in other legal documents from the FAA. He just cited what the first part of the FAR addresses. The language this person also quoted says MAY be rendered ineffective. MAY is subjective language in the legal world and not imperative like the word WILL be ineffective. The FAA states that the plane's MFG and Rotax do not set the rules for the US. The FAA does. The Mfg's can not add or delete anything more than what is within the FARs.

If people would read down the FARs to the end of TBO section it states you also may use a method or program which is acceptable to the regulatory agency. When I did my extensive research project years ago on TBO the legal department said that this sentence means that an acceptable method was on condition and the regulatory agency was the FAA. Many things that people read and try to interpret is for certified aircraft and most people fail to read all the way through a certain FAR once they think they have their answer. Many times people in the FAA in OKlahoma have been wrong and when I point this out to them they get a little upset and wanted to know why I ask them if I already knew the answer and pointed it out in the FAR. It was to demonstrate all the inaccuracies of their advice and failure to understand LSA. Four different FSDO's may give you different answers.

FAA legal quote;

"":The FAA recognizes that some manufacturers have placed what they deem "mandatory"
replacement or overhaul times in their maintenance manuals for S-LSA and that these
provisions may be consistent with consensus standards accepted by the FAA. While
following the intervals set forth in the maintenance manuals is an acceptable means of                                                This paragraph says you are allowed to do it either way.
maintaining the aircraft under § 43.13(a), a maintenance provider may use another method
that is acceptable to the FAA. The intervals specified in maintenance manuals for S-LSA,
therefore, are not per se mandatory. Consequently, a maintenance provider may develop an
alternative that is acceptable to the FAA and maintain an S-LSA in accordance with those
provisions.
This interpretation was prepared by Paul Greer, an attorney in the Regulations Division of
the Office of the Chief Counsel, and was coordinated with the Aircraft Maintenance Division
(AFS-300) of the Flight Standards Service. If you have additional questions regarding this
matter, please contact us at your convenience at (202) 267-3073.

[GlennM]

I have seen all this before and I know you are a proponent of passing the TBO limit, on condition. I think the main point missing from all these arguments is that S-LSAs are given an airworthiness certificate based on their adherence to the consensus standards, they are not certified to the FARs.  In essence, this means you cannot change anything about your S-LSA because that would put it outside the standards.   The way to change things is by a change authorization from the manufacturer. The manufacturer is responsible for determining if the change you request will keep the aircraft within the consensus standard.  On an extreme end, you need authorization to place a different brand battery in the aircraft because without their authorization,  your aircraft is no longer the same as it was when its airworthiness was approved.  Flight Design says to follow Rotax limits, so you must comply to remain within the standard and S-LSA.   Mike Busch writes a better article than this response of mine, so read what he says in the link. He does mention coverting to E-LSA, which is the big out, as he describes it.  I choose to stay S-LSA, so I have to follow the manufacturer's directives.

Another point Mike Busch mentions is ADs and Service Bulletins.  I don't recall reading where anyone on this site said they were not going to perform a Service Bulletin on their aircraft. Most of what I read is related to compliance issues and questions about the Service  Bulletin. This is normal for S-LSA to stay within the  consensus standard.  Certificated aircraft do not need to follow manufacturer Service Bulletins, only ADs.  Somehow, we accept following Service Bulletins, but not the TBO limits.  You can't have it both ways.

[Tom Baker]

1 hour ago, GlennM said:

  Flight Design says to follow Rotax limits, so you must comply to remain within the standard and S-LSA.  

I have studied the manuals pretty closely, just exactly where does Flight Design say to follow Rotax limitations?  

[GlennM]

CTSW Maintenance and Inspection Manual:

5.2 Rotax 912ULS Engine 
For engine inspection and maintenance refer to the valid original Rotax manuals. Initial manuals are 
supplied with the aircraft: 
• Operator’s Manual for all versions of ROTAX 912; 
• Maintenance Manual (Line Maintenance ) for ROTAX Engine Type 912 Series; 
• Maintenance Manual II (Heavy-Maintenance) for ROTAX Engine Type 912 Series. 
Before performing any inspection or maintenance task on the aircraft check these manuals for available 
updates through ROTAX. 
Engine removal, installation & replacement can only be done of Flight Design USA authorized 
service center. 
Important: Rotax training may be required to perform maintenance on the engine

Then, ROTAX Line Maintenance Manual  05-10-00 page 2 item 2) Time limits for engine operation, specifies TBO based on engine type and serial number.

 

[Roger Lee]

But you have to remember that FD and Rotax can not make the rules or override the FAR's no matter what's in the manual.. They are legally required to operate within the FAR's and can not overreach. I've had a few LSA companies change their rules in their manuals because of this. MFG's are not all knowing or all powerful to make things up or leave them out. Spending $15K to $20K for no legal reason is just money out the window.

[Tom Baker]

1 hour ago, GlennM said:

CTSW Maintenance and Inspection Manual:

5.2 Rotax 912ULS Engine 
For engine inspection and maintenance refer to the valid original Rotax manuals. Initial manuals are 
supplied with the aircraft: 
• Operator’s Manual for all versions of ROTAX 912; 
• Maintenance Manual (Line Maintenance ) for ROTAX Engine Type 912 Series; 
• Maintenance Manual II (Heavy-Maintenance) for ROTAX Engine Type 912 Series. 
Before performing any inspection or maintenance task on the aircraft check these manuals for available 
updates through ROTAX. 
Engine removal, installation & replacement can only be done of Flight Design USA authorized 
service center. 
Important: Rotax training may be required to perform maintenance on the engine

Then, ROTAX Line Maintenance Manual  05-10-00 page 2 item 2) Time limits for engine operation, specifies TBO based on engine type and serial number.

When did limits become inspection or maintenance? Flight Design doesn't say defer to the Rotax manual for all things regarding the engine. They say to refer to the manual for inspection and maintenance. So my take is that I am required to use the Rotax manual for inspections of the engine, and also for any maintenance I perform. Beyond that Rotax has no say in the matter, since they are not the manufacturer od the airplane.

[Roger Lee]

Tom is right. Rotax has no legal say in the US and since FD installs the Rotax they take on full legal say so that must stay within the confines of the FARs.

[GlennM]

The FAA, in the Keller letter, has said FD and Rotax can make the rules when it comes to S-LSA and if you don't follow their specifications, then you would be subject to enforcement action.  

How did limits become inspections and maintenance?   I don't know:  Why did Rotax put their TBO limits in the maintenance manual? I don't know,  but they did and Flight Design referenced them in their manual, so we are obliged to follow them.

The easiest way out is E-LSA.  If you want to stay S-LSA and want to proceed on condition, you must petition the FAA with your plan on a case by case basis.  

I get the feeling that many CT owners out there figure they can just go on-condition by making a declaration and nice logbook entries and they are ok.  This is the FAA we are dealing with and you need paperwork and approvals from them to proceed.  Otherwise, you end up under the "homemade" alternative maintenance section of the Keller letter and are ripe for "enforcement action".  Likewise,  you need a signoff to go E-LSA, not just declare it. 

 

I know you will not be convinced by this, so I did not want to go so far, but I thought I would give you an alternative view.  One shared by Flight Design USA, Mike Busch, AOPA, and Phil Lockwood, among others.  Phil and Tom P. were on the ASTM subcommittee creating the consensus standards for the LSA category,  so they might know a thing or two about how it works.

[GlennM]

I said this before:  By your argument, you would not have to follow any Service Bulletins, either, because the FARs say you don't need to follow them in non-commercial use.   You only need to follow ADs.  

[Roger Lee]

There are no AD's in LSA. They are SD's. AD's are for certified.

"The FAA, in the Keller letter, has said FD and Rotax can make the rules when it comes to S-LSA and if you don't follow their specifications, then you would be subject to enforcement action."

They can make the rules if they are within the FAR's, but can not go beyond them. They can't overreach by making them more strict or by giving the farm away.  

 

Glenn you haven't once talked or quoted the FAA legal docs I posted about TBO. Why haven't you mentioned this post from the FAA? Part of the Keller report was in error which was confirmed in later legal docs from the FAA.

Let's talk about my legal doc post that states different from your Keeler interpretation.

"FAA legal quote;

"":The FAA recognizes that some manufacturers have placed what they deem "mandatory"
replacement or overhaul times in their maintenance manuals for S-LSA and that these
provisions may be consistent with consensus standards accepted by the FAA. While
following the intervals set forth in the maintenance manuals is an acceptable means of                                                This paragraph says you are allowed to do it either way.
maintaining the aircraft under § 43.13(a), a maintenance provider may use another method
that is acceptable to the FAA. The intervals specified in maintenance manuals for S-LSA,
therefore, are not per se mandatory. Consequently, a maintenance provider may develop an
alternative that is acceptable to the FAA and maintain an S-LSA in accordance with those
provisions.
This interpretation was prepared by Paul Greer, an attorney in the Regulations Division of
the Office of the Chief Counsel, and was coordinated with the Aircraft Maintenance Division
(AFS-300) of the Flight Standards Service. If you have additional questions regarding this
matter, please contact us at your convenience at (202) 267-3073."

[Roger Lee]

Read these from the FAA legal.

FAAandtheTBO.pdf TBO....willette-dodgecenteraviation-(2013)legalinterpretation.pdf

[GlennM]

I thought I did address those in my on-condition comments. The MacMillan letter is specific to FAR23, certified, aircraft, the Willette letter applies part 43 to S-LSA.

I am not disputing that you can go "on-condition", but you have to get a waiver from the FAA to do so. You can't just say you are going on-condition, you have to develop a plan and get the plan approved by the FAA for each specific aircraft. I have not seen that here.

 

[Roger Lee]

Hi Glenn,

Where does it say you need a waiver? 

[Tom Baker]

10 hours ago, GlennM said:

The FAA, in the Keller letter, has said FD and Rotax can make the rules when it comes to S-LSA and if you don't follow their specifications, then you would be subject to enforcement action.  

Take a close look at the Keller letter. They refer to the "manufacturer's" maintenance manual. The apostrophe indicates singular possession. For the purpose of the ruling Flight Design is the manufacture, Rotax is not. Flight Design does not have a TBO limit in their manual. The wording in the flight Design manual does not grant Rotax the right to establish limits. It simply says to refer to the Rotax manual for maintenance and inspection. Also notice it says refer, not follow the Rotax manual.

I will use the above to defend my position if I have to, but the FAA really needs to get this addressed soon in writing. These conflicting opinions from different councils really need to be sorted out, as we have so many aircraft approaching the Rotax calendar month limit.

[GlennM]

1 hour ago, Roger Lee said:

Hi Glenn,

Where does it say you need a waiver? 

You need your on-condition plan approved by the FAA for your aircraft. I assumed this was called a waiver in this case. Maybe wrong word.

Tom, if the manufacturer's maintenance manual references the Rotax maintenance manual to follow for inspection and maintenance items, they give you a copy of that manual, and it has the TBO listed in there, I find it hard to believe the FAA will accept that line of reasoning.   Good luck!

I think converting to E-LSA or getting the FAA to approve your on-condition plan is about the only way around this.  I think once one person gets their approval, their plan could be used as a template for additional approvals. 

Someday, they might start enforcing these rules and someone will get zapped by the FAA and we will all know what not to do.

[Tom Baker]

10 hours ago, Roger Lee said:

There are no AD's in LSA. They are SD's. AD's are for certified.

Roger, AD's can apply to SLSA. For example the AD on the Ameri King ELT that was installed in so many flight design aircraft. The FAA can also step in and issue a AD for a SLSA if they think the manufacture is not dealing with an issue as the should.