J

Johnnybgoode

Well Known Member
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
 
Last edited:
Johnnybgoode said:
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
Click to expand...

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.
 
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.
 
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
 
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
 
Last edited:
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
 
DanBaier said:
What would the FAA response be? Hard to tell.
Click to expand...

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.
 
The same in Canada

I'm looking at changing props on my RV4 here in Canada. Are the rules the same up here in the Great White North?
 
Like others have said it all depends on what your operating limitation state. If the ones you currently have are different from the standard wording used in the most recent ones then simply get new ones. Easy as just contacting the FSDO. There is really no reason for them to deviate from the standard wording found in FAA Order 8130.2G found here http://www.faa.gov/documentLibrary/media/Order/8130.2G%20.pdf Page 4-75. When I changed my tail number which required new operating limitation I got the inspector at the Baltimore FSDO on the phone and he told me what he needed. I offered to bring down the basic documents he required since it is close to my office but he said to just scan and email them. I think it was simply a copy of my most recent condition inspection plus a copy of the registration change with the new tail number. A few days later he sent me the new ones over email and snail mailed me a signed hard copy. I think I hit the Staples Easy Button on that one.
 
Change of Engine or Prop

This seems to be the best place to bring this up with the previous posts.

I understand that when going from, say, a Subaru to a Lycoming engine, you have to fill out a new 8130-6 Airworthiness Application. Is it the same thing with changing a prop, like removing a Sensenich and installing a Catto?
 
Prop change/FSDO

I asked that same question to the agent from the GSO FSDO that did my certification, as I am looking to swap my Sterba out soon...he said to contact him, and he would give me a phase one time (very short) in which I would logbook entry back to phase one, fly off the time, and return back to phase two. he did not indicate he would have to visit or do any inspections. Sounded like a couple hours max just to verify no significant changes, ect. Seems simple enough to me...thats what I will be doing.
 
don't overthink the problem

I changed from an MT 3 blade CS to a Hartzell 2 blade CS. Did the Phase One time, and took the paperwork to Reno 2012, where scrutiny was at Warp Speed. The feds tore the paperwork up, and said thanks for effort.

In other words, return to Phase One NOT NEEDED. Memory kinda weak, but I recall this is what Mel said also.

2 blade FP to 2 blade FP, FP to FP, CS to CS? Record any CG change and carry on, per my experience. KISS.

Carry on!
Mark
 
You must log in or register to reply here.