New Operating Limitations?

[Johnnybgoode]

General question regarding re-issue of Operating Limitations.
Just removed a Pacesetter 200 propeller from my RV-4 and replaced it with a Catto 2-blade. I'm being told I need to be issued a new set of operating limitations and reapply for a new airworthiness certificate. Seem right to you guys? Saying it has to be done any time a plane is put back in Phase I testing - a requirement if installing a new and different propeller. Just seems like alot of paperwork for a prop change...
Thanks for any help.
JB

[WingsOnWheels]

Originally Posted by Johnnybgoode

General question regarding re-issue of Operating Limitations.
Just removed a Pacesetter 200 propeller from my RV-4 and replaced it with a Catto 2-blade. I'm being told I need to be issued a new set of operating limitations and reapply for a new airworthiness certificate. Seem right to you guys? Saying it has to be done any time a plane is put back in Phase I testing - a requirement if installing a new and different propeller. Just seems like alot of paperwork for a prop change...
Thanks for any help.
JB

I'll let one of the experts answer for sure, but as far as I know that is BS. To go back into Phase 1 you just need the FSDO to assign a test area and then make the appropriate logbook entry.

[bkilby]

Pay attention to the replies from Mel..
http://www.vansairforce.com/communit...ighlight=phase

[Johnnybgoode]

I was hoping he'd chime in...

[ccsmith51]

I worked with Mel to get my Op-Lims updated to the current wording. It was painless and he was a pleasure to deal with. I highly recommend him.

[DanBaier]

Your op limitation letter is what governs. You need to follow that exactly. What the guidance for such letters is now is not really relevant.

What I'd expect to find is that you need to notify the FSDO, agree on a Phase I time period and test area, make an entry to put it into Phase I following the change and then another entry to put it back into Phase II following the test period.

YMMV based on when the letter was issued and who signed off.

Dan

[Johnnybgoode]

Thanks guys.
Dan, I would expect that to be the case but my change statement, included below, makes it seem like a letter and a return letter would suffice, as well as a log entry when flyoff complete. Apparently not.
Mine say:
"The cognizant FAA office must be notified and their response received in writing prior to flying this aircraft after incorporating a major change as defined by FAR section 21.93."
JB

[DanBaier]

I still think your letter is what governs (I think it's actually incorporated as part of your airworthiness certificate). Your letter is different that mine. In your case, your letter says to notify them and receive a written response. Having done exactly that, I think you'd be good to go. What would the FAA response be? Hard to tell. Although your letter does not seem to have this text, the text of order 8130.2(g) (I believe the present guidance) might give some insight - it says (pages 4-67, 4-68):

(19) 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.?

Dan

[rvbuilder2002]

Originally Posted by DanBaier

What would the FAA response be? Hard to tell.

Usually it is a statement that acknowledges the change, and specifies specific requirements for flight testing (if any) such as test area and how long.

I deal with this all the time with RV's I maintain (because of the type of experimental certificate they have, I have to notify them of any major change).

In the notification letter I usually tell them the test area and time period I intend to use, and since I know what they typically expect, I usually just get back a reply saying approved as requested.

This is all done via e-mail. I then print a copy and put in the aircraft paperwork file.

[LifeofReiley]

will probably chime in here... he is the best of the best!