Phase I 25 verses 40 hours

Bill.Peyton · #1 07-31-2011, 02:07 PM

I am trying to understand the actual written requirement differentiating the requirement to fly an additional 15 hours during Phase I. As far as I can tell, the following is the requirement "The owner / builder must show and the FAA must find that the engine and prop meet their Type Certificate and all ADs are complied with. (Please include a copy of the compliance list to show compliance with Type Certificate.)".

Lycoming will sell you an "experimental" version of the IO-540 D4A5, or a certified version of the same. The Lycoming rep at OSH stated that both engines contain the exact same parts and are put together on the exact same assembly line and that the only difference is the "X" designation in the serial number. I would assume that all ADs are complied with at the time of delivery.

Using either version of the Lycoming engine coupled with the certified Hartzell C2YR-1BFP/F8068D prop. appears to meet the intent of the above.

Am I missing something or is my interpretation incorrect?

Mel · #2 07-31-2011, 02:21 PM

The difference is that the "X" engine does not come with a "Type Certificate".
That's why Lycoming can sell it cheaper. It's a paper traceability thing.

guccidude1 · #3 07-31-2011, 06:17 PM

Mel is correct, you have a non-certified engine with a certified prop. Since both the engine and the prop must be certified to qualify for the 25 vs 40 hr phase I. I had the opposite problem, a certified engine and a non-certified Sensenich prop. Hope this clears things up. Dan

aerhed · #4 07-31-2011, 06:38 PM

Quote:

Since both the engine and the prop must be certified to qualify

Yes, and engine/prop must be cert together. The prop either has to be listed on the engine TC or carry an STC for that engine. So, an XO or a YIO for instance, is a 40hr bonk. Even accessory changes can get you if they were on the TC to begin with.

Bill.Peyton · #5 07-31-2011, 07:24 PM

I guess I still fail to see the reasoning. If all of the parts are the same that are used in both the type certified and x engine. If the engines are physically identical with the exception of the part number or serial number designation, then why are they different? It sounds like it is strictly a manufacturers documentation issue. If the builder could show that the x engine is physically the same as the certified it really boils down to the data plate?

I assume that if a person bought a core that came out of a certified aircraft and had it rebuilt by an authorized shop it would still be a type certified engine simply because that was it's original pedigree.

Phlyan Pan · #6 07-31-2011, 08:54 PM

So....let's say you have a certified engine and prop that you salvaged from a plane. But you really want to run the Wang Chung Super X Hypersonic Experimental prop.

Can you fly off the 25 hours on your certified gear and then swap props and be good to go after a simple test flight?

gasman · #7 08-01-2011, 12:48 AM

Quote:

Originally Posted by Phlyan Pan

So....let's say you have a certified engine and prop that you salvaged from a plane. But you really want to run the Wang Chung Super X Hypersonic Experimental prop.

Can you fly off the 25 hours on your certified gear and then swap props and be good to go after a simple test flight?

Yes, but would require going back into phase I for 5 hours for a prop change. This is the rule on my plane.

RV6_flyer · #8 08-01-2011, 02:37 AM

Quote:

Originally Posted by gasman

Yes, but would require going back into phase I for 5 hours for a prop change. This is the rule on my plane.

Maybe more than 5-hours. 5-hours is a minimum that the FSDO could require.

See FAA Order 8130.2G. (or the latest)
The current operating limitations being issued says:

After incorporating a major change as described in 14 CFR ? 21.93, the aircraft owner is required to reestablish compliance with 14 CFR ? 91.319(b) and notify the geographically responsible FSDO of the location of the proposed test area. The aircraft owner must obtain concurrence from the FSDO as to the suitability of the proposed test area. If the major change includes installing a different type of engine (reciprocating to turbine) or a change of a fixed-pitch from or to a controllable propeller, the aircraft owner must fill out a revised FAA Form 8130-6 to update the aircraft?s file in the FAA Aircraft Registration Branch. All operations must be conducted under day VFR conditions in a sparsely populated area. The aircraft must remain in flight test for a minimum of 5 hours. The FSDO may require additional time (more than 5 hours) depending on the extent of the modification. Persons nonessential to the flight must not be carried. The aircraft owner must make a detailed aircraft logbook and maintenance records entry describing the change before the test flight. Following satisfactory completion of the required number of flight hours in the flight test area, the pilot must certify in the records that the aircraft has been shown to comply with 14 CFR ? 91.319(b). Compliance with 14 CFR ? 91.319(b) must be recorded in the aircraft records with the following, or a
similarly worded, statement: ?I certify that the prescribed flight test hours have been completed and the aircraft is controllable throughout its normal range of speeds and throughout all maneuvers to be executed, has no hazardous characteristics or design features, and is safe for operation. The following aircraft operating data has been demonstrated during the flight testing: speeds Vso ______, Vx ______, and Vy ______, and the weight ______, and CG location ______ at which they were obtained.?

If you only have 25 hours on the airplane when you do this, the FAA may see what you are trying to do and could require 40-hours on top of the 25-hours that you already flew. Most of the people that work for the FAA are smart.

RV6_flyer · #9 08-01-2011, 02:53 AM

Quote:

Originally Posted by Bill.Peyton

I guess I still fail to see the reasoning. If all of the parts are the same that are used in both the type certified and x engine. If the engines are physically identical with the exception of the part number or serial number designation, then why are they different? It sounds like it is strictly a manufacturers documentation issue. If the builder could show that the x engine is physically the same as the certified it really boils down to the data plate?

I assume that if a person bought a core that came out of a certified aircraft and had it rebuilt by an authorized shop it would still be a type certified engine simply because that was it's original pedigree.

As Mel said: "It's a paper traceability thing."

It is NOT a CERTIFICATED engine built to the Type Certificate. Yes it may be identical parts but it does not have the paper traceability. It must have the paper traceability and be built in accordance with the FAA Approved procedures, parts, facility, workers, and paper. Any one of those is missing, then it is not a certificated engine.

Yes a rebuilt core with a certificated dataplate rebuilt / overhauled by a licensed A&P that has all ADs complied with and NO changes to it (ignition / fuel system) that is identical to the Type Certificate would get 25-hours with a certificated prop.

Remember that "the Applicant must show and the FAA must find that the product meets the requirements" so you must prove everything to the FAA. If it was not built on the approved line with all the paperwork that goes along with it, it is not a certificated engine. If it is a certificated engine and you cannot prove that it is, expect 40-hours.

A wise man once said "there is no such thing as a free lunch."

RVbySDI · #10 08-01-2011, 03:28 PM

Ok, I don't have any words of wisdom for the legal requirements of Phase I. However, I have an opinion on the 25 vs 40 hour issue.

Don't worry too much about it!

25 hours is barely enough time to get used to how your plane lands. Let alone time enough to figure out all of the little nuances of the panel, engine noises/vibrations, power settings for the various flight parameters you will be flying, best cruise settings, climb out settings, landing configurations. There are oil temps, pressures, fuel burn issues, CHT, EGT settings, trim issues, flap settings, control issues to test. The list is almost endless.

I am not sure why builders concern themselves so often about those 40 hours. I have experienced it twice now and really never felt like I was wasting time by flying 40 hours off before taking up a passenger or being able to leave a predefined area of flight. Trust me, you will have all kinds of opportunities to take up passengers. As for the predefined area of flight, if you talk with the FAA inspector or the DAR you can work out a large enough area to fly off your Phase I time. In my situation I discussed the speed of the RV and the distance traveled while flying an RV. When my inspector presented me with the Phase I area he had given me a 100 mile radius from my home airport. In my case that was about 80% of the entire state I live in. Flying within the predefined space became a non-issue. I had a great deal of real estate to fly over.

In my opinion, I would not use the Phase I fly-off time as an important factor in determining which engine/prop combination I was going to use. There are many more important issues to take into consideration than this.

Trust me, when the time comes for Phase I, those 40 hours will fly by so fast you wont know where they went. Chances are you will continue to learn new things about your new airplane for many many more hours beyond the 40 hours allotted for your Phase I.

Live Long and Prosper!