FAA inspection objection recommendations

If anyone has time, I would like to know how you'd approach objecting to an FAA inspectors demand to have a wet compass installed in my RV. After reading all the forum posts I could find about compasses, I see where folks have pointed out that 91.205 does not apply to exp. amateur built aircraft in so much as the phase one letter says that if you wish to operate outside day-VFR one would of course need to meet the additional equipment requirements as listed for those operations.

After citing 91.205 my inspector said that his main justification was "in case my electrical system died." Opinion at best, good or bad.

I happen to have a dual screen Grand Rapids setup with dual magnetometers and a backup battery which I thought fulfilled the magnetic direction indicator requirement. I may be confusing compass and magnetic direction indicator but I've talked to a few friends and they have all said that I shouldn't have to comply but we all know that I'm dealing with the "bear." I was going to buy a wet compass for my slider roll bar brace but had to pose the question. Other then dueling over regs. does anyone have a kinder, gentler way..?

Additionally he told me that I had to label my fuel tanks with the fuel type, quantity, and paint my caps red. This seems familiar with Cessna's but RV's?

Thanks for your suggestions,
Andrew

If it was just install a compass, then I would just do it.............. But paint the caps red.................


NO WAY IN H***!!!

You need a type & quantity placard, but you sure don't need red caps. Who is this guy?

Buy an el-cheapo whisky compass and stick it to your glareshield with double-stick tape. And make sure that it has a correction card. Then, after he's gone, take it off and put it back it the box and put it away on a high shelf where you'll never find it again.

When I had my RV7, I simply used tie wraps to attach a cheap compass to the roll bar brace. Although I ended up never removing it, and of course never using it since I also had a dual GRT Horizon, the option makes it very easy to once you have satisfied the inspector.

Is this being required because of the FSDO's opinion or just this one inspector who is obviously very misinformed?

I try never to poke "the bear" until I am sure I am safe. Walmart has really cheap compasses with suction cups. A cheap labeler makes fuel tank placards very quickly. Water based paints come in red.

Once you have your pink slip, file a complaint against the guy with his boss and the FAA IG, citing the fact that he is enforcing regulations that don't exist. And hope that you never have to deal with that FSDO until after he retires.....

Paul

why wouldn't you want a compass installed? reminds me of those guys who remove the interiors from their car to go faster, makes no sense to me

I was very impressed with how thorough my FSDO inspector was. Mine didn't like my battery powered compass and also wanted my fuel tanks placarded with 100LL and capacity. I quickly grabbed a paint brush and labeled the fuel tanks and a compass was overnighted in from Wicks. After eight years of building and untold number of dollars... I wasn't going to make the inspector mad at this point. Like Paul and Van say "don't poke the bear"; buy a compass and paint your gas caps. Change it to what ever you want after you have the pink slip in hand. Just make sure whatever you end up with will pass a ramp check

Can you confirm that this guy is an actual FAA-employed inspector, rather than a DAR? I don't think standard-airworthiness certificated airplanes are even required to have red fuel caps. This just sounds weird.

I did have an inspector from the Milwaukee FSDO and he did a great job. Came out quickly, did a thorough inspection, and didn't require any outlandish changes. Unlike a DAR he also did not charge for the inspection. Since then I've made a couple of changes that needed FSDO approval and he's been very helpful.

Back in 2003, my DAR gave me a list of 12 items he wanted corrected. Stuff like, where is the certification data on the altimeter? (it was still in the box from Van's, the altimeter is not certified but the data was all he wanted to see)

The list was accomplished in 2 days and he was happy. So was I.

Like is so true in aviation where someone is always watching, it is one of those situations where one has to recognize who is in the drivers seat and the appropriate response is, yes sir, no sir, which hoop do I jump through next. It is quicker and easier than going to a war you can not win.

I would still tell him to pound sand on the red fuel caps. Show me the reg on that.

Go buy a small spool of red electrical tape and tape your cap red.

Then, if you change your mind later, peel off the elect tape and voila...

I also have wondered about color coding caps.
Years ago, my mechanic had me not only paint
the gas caps red, but also paint the oil cap
yellow. I don't remember his reason for requesting
it. This was on a Luscombe.
I am guessing someone, somewhere, put a fluid in
the wrong place and caused a problem.
Tom

Red caps on a nice white RV................. that's like riding a pink scooter......

So if you painted the A/C red, what color do you paint the caps?

If it's to make sure that we use the right fuel, then they should be painted blue.

Looking at over 25 A/C on the ramp just now........ and I did not find any red caps.......

I've worked with (and against) FAA guys since before they were "kinder and gentler". If you don't take them to task they just get worse. SLC was known for years as the worst FSDO in the US to deal with (you guys know who you are). We told them to stuff it and got our own FSFO attached to Denver. They don't scare me, they work FOR me. Pull out the regs and make them read out loud, then explain. They're not deities, they're bureaucrats. Some great guys for sure, but once an orfice gets in the door they're hard to get rid of. Make 'em horizontal the bad ones until you don't see them anymore. I worked for a racecar driver who got ramp grounded for peeled paint on a bonanza ruddervator (balance issue) in S. Carolina. Everyone has heard about the P-tip twin that was grounded because his tips were "bent". That's a real story and that inspector is still buried in the office in Chicago.
If this guy doesn't show you chapter/verse along with the "red cap" ****, get on the phone and tell them you want someone else. Otherwise the next guy just gets his shorts twisted too, and the beat goes on.

Thanks for your responses

I'll keep things anonymous to protect the innocent and say that they were very nice and looked over my plane far more then I expected. -To the tune of a couple of hours, checking most everything. And no, my plane isn't full of holes or dents. In fact, my aforementioned items were all they wish changed. Complying is easiest but perhaps I'll kindly point out some of the finer points I've learned from VAF once I am in the clear. Looks like I'm going to Walmart. You all have a good weekend.
Andrew

abrandt said:

If anyone has time, I would like to know how you'd approach objecting to an FAA inspectors demand to have a wet compass installed in my RV.

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Andrew.

There have been many opinions posted regarding whether or not you should "fight or switch" and I have an opinion too, but that's beside the point. What I want to do here is actually answer your specific question on what to do if you do decide to proceed with a challenge. Assuming that you decide to "poke the bear" at this point, here are my thoughts on how/where to poke.

Your first step would be to politely ask the inspector to show you in the written regulations or policy where it requires you to have a "wet compass" or red fuel caps.

For the compass he/she will point to 14 CFR 91.205. You should first point out that this regulation specifically applies to "standard aircraft", which yours is not. The inspector may then point out that your operating limitations will require you to meet this regulation if you wish to fly at night or under IFR. You should then point out that the regulation says exactly nothing about a compass. It requires a "magnetic direction indicator" and goes no further in describing what type. There is no specific definition and no specific prohibition on any type of magnetic direction finder, so something that happens to be powered by the aircraft's electrical system will meet the regulation so long as it is indeed a "magnetic direction indicator" (meaning it will find north on its own using the earth's magnetic field).

For the red fuel cap again ask the inspector to show you a written regulation or policy that requires this. A search of 14 CFR part 23 reveals no such requirement even for standard category aircraft.

Assuming you come to loggerheads on either or both issues, what's next. This depends on who the inspector is. If it's a DAR, ask to speak with his FAA advisor. Now, it's possible and even likely that these requirements came to the DAR from said advisor, so this might not gain you much ground, but it's a step you need to take.

If the inspector is an FAA employee, you should speak to his/her supervisor or manager. Again this might not gain you much ground, but it is a necessary step in the process.

If you get to this point and you still do not have a satisfactory resolution, you can file a Customer Service Initiative if the inspector works for a FSDO. If the inspector works for a MIDO I would suggest at this point you call Randy Hansen at EAA HQ. He's the person in EAA's Government Relations department who works these types of issues.

The bottom line is, ultimately you will probably win the argument, but you will not create any goodwill between yourself and the local FAA office(s). Each builder/applicant needs to make a choice as to how strongly you wish to argue your point, even when you are 100% sure you're right.

Good luck with your certification!

abrandt said:

... Looks like I'm going to Walmart. You all have a good weekend.
Andrew

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Umm ... make sure you buy that compass in the AVIATION department of Wal-Mart.

gimp2x said:

why wouldn't you want a compass installed?

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Because you have GPS. It really doesn't matter where your airplane is pointed, what matters is where it is going, and GPS provides that answer. For backup, the typical EFIS installation usually includes a magnetometer and more than one GPS.

A whiskey compass is an anachronism.

Joe Norris just showed us all the real value of VAF and, frankly, some other social networking sites too (including Oshkosh 365). No emotion, no telling 'em where to get off, just good, solid facts and guidance.

Well done, sir. Well done.

The bottom line is, ultimately you will probably win the argument, but you will not create any goodwill between yourself and the local FAA office(s). Each builder/applicant needs to make a choice as to how strongly you wish to argue your point, even when you are 100% sure you're right.

Good luck with your certification!
__________________
Cheers!

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Yep you have a choice.

Your plane is just skosh inches from getting it's pink airworthiness certificate and you can do as Paul Dye suggests.. a cheapo whiskey compass, a cheap labelmaker, and some cheap red water based paint and you will get your certificate. Operative word "will".

Or as Joe points out you are 100% correct and will ultimately prevail if you wish to take this guy to task , probably months from now you will get your certificate. The operative word here is probably.

While I think the inspector is just plain wrong, he is the guy who has to put his name on your documentation so I would be inclined to give him a bit of leeway in his interpretation of requirements.

We all respect Mel and he would probably never require this kind of trivia but he will not sign an aircraft off it the hoses do not have firesleeve. Something I agree with but is nowhere required in the regs.

Pick your battles wisely as every course of action has consequences.

I have a whisky compass

I bought it second hand..never did install it, even though I fly IFR.

So you can either borrow it (cost of shipping) or buy it for what i paid ($80 I think)..Send me a PM if interested.

Frank

N395V said:

We all respect Mel and he would probably never require this kind of trivia but he will not sign an aircraft off it the hoses do not have firesleeve. Something I agree with but is nowhere required in the regs.
Pick your battles wisely as every course of action has consequences.

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Yes, an inspector may require things that aren't in the regs.
Anything I require that may not be in the regs involve what I consider to be "safety of flight" issues. When we sign off the aircraft, we are essentially saying that "the aircraft is in a condition for safe operation."
Just the same as you would when you sign off a condition inspection.

Do as Paul D says

...and move on.

My FSDO wanted "experimental" inside and on both wings. I had it on the inside and on the right wing, but not the left. I made him drag out his reg and then we discussed syntax and grammar. Since this was the ONLY thing he found, I said, "Okay, I'll go to work on the sticker, you do the airworthiness paperwork". He agreed. I grabbed a roll of electrical tape and started cutting and sticking letters. I so wish I had taken a picture of it. Barely legible. But, at days end I had an airplane and the bear went back to his cave. And, yes, I peeled the tape off off before I went home.

Now that it is painted, I have put the required word on both flaps.