Vern

Vern

Well Known Member
Anyone had a chance to read thru it yet? For newbies, this is the order regarding certification of our aircraft
 
I haven’t had a chance to read it yet, but knew that the drop was imminent.

There must be some level of changes with operating limitations because us DAR’s have been notified that the AWC system is not yet set up for properly populating and issuing operating limitations, so we will have a bit of extra work for a while in putting them all manually.
 
rvbuilder2002 said:
I haven’t had a chance to read it yet, but knew that the drop was imminent.

There must be some level of changes with operating limitations because us DAR’s have been notified that the AWC system is not yet set up for properly populating and issuing operating limitations, so we will have a bit of extra work for a while in putting them all manually.
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I made a first cut through the Ops Lims table and while there are definitely some wording changes, I didn’t see anything that is truly a significant operational change….but I have yet to get my magnifying glass out!

And yea - releasing “K” wile AWC is not updated is (as Louise, another former Fed said) “a major fail”…..
 
The only takeaway that I care about is that it clearly says slanted and shadowed N numbers are okee-dokee. That's gonna eliminate a whole category of argument over on the airplanes and coffee FB group.
 
Ironflight said:
I made a first cut through the Ops Lims table and while there are definitely some wording changes, I didn’t see anything that is truly a significant operational change….but I have yet to get my magnifying glass out!

And yea - releasing “K” wile AWC is not updated is (as Louise, another former Fed said) “a major fail”…..
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The FAA is broken up into so many different sub parts, way beyond what most people would imagine, and each one of those does things in their own way, and at their own pace. I imagine one group decided they just weren’t going to wait for another group any longer.
 
Desert Rat said:
The only takeaway that I care about is that it clearly says slanted and shadowed N numbers are okee-dokee. That's gonna eliminate a whole category of argument over on the airplanes and coffee FB group.
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Not likely.
The order is rules and guidance for compliance with the FAR‘s
It is the FAR‘s and to some degree advisory circulars that define what the actual rules and requirements are.
My personal take is that there is already information to imply that slanted and drop shadowed N numbers are acceptable. There is specific terminology, stating that any drop shadow can’t be counted in meeting the minimum requirement size for the end number so that in itself seems to imply that it is acceptable.
 
rvbuilder2002 said:
Not likely.
The order is rules and guidance for compliance with the FAR‘s
It is the FAR‘s and to some degree advisory circulars that define what the actual rules and requirements are.
My personal take is that there is already information to imply that slanted and drop shadowed N numbers are acceptable. There is specific terminology, stating that any drop shadow can’t be counted in meeting the minimum requirement size for the end number so that in itself seems to imply that it is acceptable.
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Yeah, I know that's in the FARs but it's now spelled out very clearly in this order on page 2-6. Was it always in there? At any rate, it seems like that argument comes up every few days in some builder group or another. It's nice to have something to point to that spells it out when people ask
 
Desert Rat said:
Yeah, I know that's in the FARs but it's now spelled out very clearly in this order on page 2-6. Was it always in there? At any rate, it seems like that argument comes up every few days in some builder group or another. It's nice to have something to point to that spells it out when people ask
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Sorry, I misinterpreted your post to mean you were hoping they added those details… not that they had.
Good to know (and I guess I should have read it first before commenting 🙄)
 
Desert Rat said:
Yeah, I know that's in the FARs but it's now spelled out very clearly in this order on page 2-6. Was it always in there? At any rate, it seems like that argument comes up every few days in some builder group or another. It's nice to have something to point to that spells it out when people ask
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Well….page 2-6 also says that the N-Number must readable from 500 feet away….and I woudl be surprised if most people can read a 2” number from that distance! This just points out the problem of having one document that covers the process for both Standard and Special Airworthiness Certificates - and I am guessing someone wasn’t paying attention to the exceptions for N-Number size in the Special AWC….. so once again, we DAR’s are somewhat on our own out there for interpreting the Regs (not the guidance). But yeah - slants seem to be OK! 😉
 
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Desert Rat said:
The only takeaway that I care about is that it clearly says slanted and shadowed N numbers are okee-dokee. That's gonna eliminate a whole category of argument over on the airplanes and coffee FB group.
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What about having N-numbers on the fuselage under the horizontal tail? Do the Airplanes and Coffee FB folks argue about that? I see LOTS of airplanes that should not have been able to complete DAR inspections and issuance of CA's because of that. Even a P-51!!!.
 
scsmith said:
What about having N-numbers on the fuselage under the horizontal tail? Do the Airplanes and Coffee FB folks argue about that? I see LOTS of airplanes that should not have been able to complete DAR inspections and issuance of CA's because of that. Even a P-51!!!.
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As has been said many times before. We usually sign off an aircraft before paint. After we sign it off, we have no more control. That's why I always take pictures showing that it "was in compliance" at certification.
 
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rvbuilder2002 said:
Sorry, I misinterpreted your post to mean you were hoping they added those details… not that they had.
Good to know (and I guess I should have read it first before commenting 🙄)
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No worries. In that same section it also spells out that the "experimental" placard can be on the inside or outside of the airplane, which is a question that you guys have answered here in the past based on a common sense interpretation. Now it's specifically stated.

Nice to get rid of at least a couple of gray areas.
 
😬

Previous wording
No person may operate this aircraft for other than the purpose of meeting the requirements of § 91.319(b).
The pilot in command must comply with § 91.305 at all times.
This aircraft is to be operated under VMC, day only.
This aircraft must be operated for at least _____ hours with at least_____ takeoffs and landings in this geographical area: [ The area must be described by radius, coordinates, navigational aids, and/or landmarks. The size of the area and airports must be that required to safely conduct the anticipated maneuvers and tests.]
This aircraft may only operate from [identify name of airport(s)]. (42)
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New wording:
When operating in Phase I, no person may operate this aircraft for other than the purpose of meeting the requirements of § 91.319(b). The pilot in command must comply with § 91.305 at all times. This aircraft is to be operated under VMC, day only. Phase I flight testing must be conducted either (1) in accordance with the task-based flight test program described in FAA AC 90-89C, or (2) must be operated for at least _____ hours with at least_____ takeoffs and landings.
For major modifications (ref § 21.93), prolonged inactivity, or substantial re-assembly, this aircraft must be operated for at least _____ hours with at least takeoffs and landings. [For amateur-built flight test hours, reference 15-4(e). For ELSA flight test hours, reference 17-3(f)]. These flights must take place in the geographical area described as follows: [Refer to paragraph D-4.h for instructions. The size of the area must not exceed that required to safely conduct the anticipated maneuvers and tests.] This aircraft may only operate from ______. [Identify name of airfield. A second airfield may be listed with valid justification of a specific flight test or safety requirement.] (39)
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Sounds like they're really trying to clamp it down to one, maybe two airports.
 
Does this FAA order have any direct applicability to airplanes that already have an airworthiness certificate and are out of Phase 1?
 
MacCool said:
Does this FAA order have any direct applicability to airplanes that already have an airworthiness certificate and are out of Phase 1?
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No
The operating limitations issued for your aircraft at the time of certification are the ones you are to follow.
There are numerous differences depending on when any given aircraft was certified.
 
rmartingt said:
😬

Previous wording


New wording:


Sounds like they're really trying to clamp it down to one, maybe two airports.
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Yikes - the restriction to a SINGLE airport (well you can get an additional one more with justification….) is a significant change! I sent a note to the guys at EAA who follow stuff with the FAA, and he was surprised by this and is looking in to it. I can easily justify one additional airport - like if someone crashes on your primary runway wile you’re in the air - and can think of good reasons to have several listed - so this is a significant change!

We’ll see what we hear back from the EAA….
 
Ironflight said:
Yikes - the restriction to a SINGLE airport (well you can get an additional one more with justification….) is a significant change! I sent a note to the guys at EAA who follow stuff with the FAA, and he was surprised by this and is looking in to it. I can easily justify one additional airport - like if someone crashes on your primary runway wile you’re in the air - and can think of good reasons to have several listed - so this is a significant change!

We’ll see what we hear back from the EAA….
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I know trying to answer "Why does the FAA....?" is an exercise in wasted breath, but I really wonder what's driving them to clamp down on this. Has there been a rash of folks who were still supposedly in Phase I getting caught at local fly-ins or something? Or is this just a case of the Good Idea Fairy paying someone a visit and we wind up with a Solution in search of a non-existent Problem?

I'm especially not pleased given as I am hoping to fly in the next few months...
 
Ironflight said:
Yikes - the restriction to a SINGLE airport (well you can get an additional one more with justification….) is a significant change! I sent a note to the guys at EAA who follow stuff with the FAA, and he was surprised by this and is looking in to it. I can easily justify one additional airport - like if someone crashes on your primary runway wile you’re in the air - and can think of good reasons to have several listed - so this is a significant change!

We’ll see what we hear back from the EAA….
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How about my small home airport with no services but 11 miles away is a Class D with part time tower and on airport fire services. Where do I want to land if I find a significant flight safety problem during phase 1 testing? Does this fall under the PIC decision, safety first, regulation second?
 
I had to divert on my inauguration flight because of unforecast x-winds. The diversion airport was 5 miles away from the primary. I had a choice of 5 airports within 25 miles.

To me the biggest change that needs to be made is eliminating the 40 hr requirement and go to a task based test cards like the ELSA RV12. Min of 5 hrs or whatever it takes to complete all the test flight task cards. 25 hours for "type certificated" was a terrible compromise. Brand new Lycoming Thunderbolt 540 after a 4 year wait? Nope you ain't in a type certificated 25 hour qualification. Keep flying the 40 hours like the VW and LS1 and subaroo folk.
 
docjjrmd said:
How about my small home airport with no services but 11 miles away is a Class D with part time tower and on airport fire services. Where do I want to land if I find a significant flight safety problem during phase 1 testing? Does this fall under the PIC decision, safety first, regulation second?
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I'm thinking of less dramatic but still safety-relevant things...
- Takeoff/landing testing needing different runway surfaces and directions
- Testing that would be disruptive to "normal" airport traffic
- Weather or biological diversions
- Fuel availability at home base

I really don't see what was wrong with the old approach of "any airport in the test area"... or even a list of several... if we're looking at Phase I areas on the order of 75-100 miles across. Especially if one's area is "lopsided" thanks to airspace or geography and your home base is at one end...
 
cactusman said:
I had to divert on my inauguration flight because of unforecast x-winds. The diversion airport was 5 miles away from the primary. I had a choice of 5 airports within 25 miles.

To me the biggest change that needs to be made is eliminating the 40 hr requirement and go to a task based test cards like the ELSA RV12. Min of 5 hrs or whatever it takes to complete all the test flight task cards. 25 hours for "type certificated" was a terrible compromise. Brand new Lycoming Thunderbolt 540 after a 4 year wait? Nope you ain't in a type certificated 25 hour qualification. Keep flying the 40 hours like the VW and LS1 and subaroo folk.
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This is done -- task based phase 1 is an option that is being included on all new E-AB operating limitations. AC 90-89C provides details on the program.
 
rmartingt said:
I'm thinking of less dramatic but still safety-relevant things...
- Takeoff/landing testing needing different runway surfaces and directions
- Testing that would be disruptive to "normal" airport traffic
- Weather or biological diversions
- Fuel availability at home base

I really don't see what was wrong with the old approach of "any airport in the test area"... or even a list of several... if we're looking at Phase I areas on the order of 75-100 miles across. Especially if one's area is "lopsided" thanks to airspace or geography and your home base is at one end...
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The solution here is to "center" you radius some distance from your home base.
As long as your home is within the area, you're good-to-go.
 
For those just about to have a certification inspection, the FAA just revised the effective date of 8130.2K to October 27th so any certification done before then will still be done under the 8130.2J requirements.
 
rmartingt said:
😬

Previous wording


New wording:


Sounds like they're really trying to clamp it down to one, maybe two airports.
Click to expand...
This aircraft may only operate from [identify name of airport(s)]. (42)

My previous operating limitation gave a radius of 75 miles and stated "This aircraft may only operate from (2 airports in my flyable) radius was listed. I asked about this and was told that I could land and take off at any airport to include refueling. Was that correct?
 
dmattmul said:
This aircraft may only operate from [identify name of airport(s)]. (42)

My previous operating limitation gave a radius of 75 miles and stated "This aircraft may only operate from (2 airports in my flyable) radius was listed. I asked about this and was told that I could land and take off at any airport to include refueling. Was that correct?
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Who'd you ask? And isn't a take-off or a landing an "operation"?
 
dmattmul said:
This aircraft may only operate from [identify name of airport(s)]. (42)

My previous operating limitation gave a radius of 75 miles and stated "This aircraft may only operate from (2 airports in my flyable) radius was listed. I asked about this and was told that I could land and take off at any airport to include refueling. Was that correct?
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That was not correct.
Whatever airports are listed as approved for operations, are the only airports that you can operate from (as in, make a takeoff or landing).
 
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