Recurrent Airworthiness Certificate

[Clarkie]

Was reading "Ask the DAR" today in Kitplanes and it has me a little concerned about the upgrade we are doing to our -6 and if a re-certification is required.

Here's the scenario. We are doing a complete panel redo. Replacing a D10A (moving it to back up status), adding two new AFS units, GTN-650, Trig TX, and ADS-B in/out capability. The airplane currently has a Digiflight II VS autopilot and we are swapping it for the AF Pilot.

Will we be requiring a new inspection, certification and test period of 40 hours?

What have you guys had to do after redoing your panels? I'm thinking it would be a major pain in the you know what if we have to go through a re-certification and 40 hours of Phase 1 flying.

[Vern]

You will not need another Airworthiness inspection nor another 40 hour flyoff.

You need to read and comply with your Operating Limitations which most likely will tell you that 'after a major change you need to contact the FSDO' and re-enter your bird into Phase 1 and do a minimum 5 hour test phase 1, and if all checks out, put the plane back into Phase 2. That is about all you will need to do. If you no longer live in the area where the Ops Lims were issued, you will have to ask the FSDO for a new test area.

[Clarkie]

Thanks Vern. I believe the original test area was out in PHX. Airplane has changed hands twice and is now based near CLT. The airplane is being upgraded near Atlanta. Will we be able to fly it back home and then make the request with the local FSDO? We are partners in the airplane. Can we both fly the 5 hours off or do we have to designate one pilot only?

[Vern]

Again, read your Operating Limitations. They will answer some of your questions. They will speak to who may fly the plane during Phase 1. If they are older Ops Lims, the FSDO where the plane is can re-issue more modern Ops Lims. By the way, they are a part of your 'Pink slip' 8130-7 Airworthiness Certificate and must be in the plane when flown.

There are no 'airplane police' looking for you so compliance is mostly a matter of your honor and if you think it might affect your later resale of the plane. If you read the Ops Lims and decide they require back into phase 1 and test flying, you would in this case have to do the test flying in the ATL FSDO area and get their direction.

I suspect most folks would not bother and would just fly home and forget it.

[N941WR]

Tom, you shouldn't have to get the FSDO involved at all. Again, it all depends on what your Operating Limitations say. The original test area or FSDO has nothing to do with your change.

Again, the idea is what constitutes a major change.

Check out this PowerPoint slide deck. Take a look at slide 15. Based on that definition, changing the panel is not a "Major" change.

[Mel]

If you need to change your flight test area, that can be done by simply having your operating limitations amended.
Any local FSDO inspector or a DAR with function codes 46 & 33 can do this.

Updating the panel should not constitute a major change unless you have added something to the control system, such as adding an auto pilot, or unless there is a significant change to the weight & balance.

Feel free to give me a call for discussion if you like. 972-784-7544

[Jesse]

I have just dealt with this on 3 different planes. 2 were changes from Subaru to Lycoming engines, and they required a return to Phase 1 for 5 hours. The 3rd was the addition of floats to a plane. It also had to return to Phase 1. The first 2 required a new airworthiness certificate because they required new Operating Limitations, because the date of issuance of the Operating Limitations was on the airworthiness certificate. The 3rd did not because the original Phase 1 area was unchanged. That is how my FSDO handled it, and the 1st 2 required an inspection because the back of the airworthiness certificate said something about the issuer having inspected the plane.

As for being a major change, that change would certainly have required a 337 form in the certified world, which means it would be considered a major repair or alteration. Again, that's in the certified world.

However, as was already stated, it's really an honor system.