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DAR advice on EAB

jim miller

Well Known Member
If someone builds a EAB aircraft (Not RV-12) without an electrical system then after getting C of A and flying for a year or two decides to add full electrical with running lights what would be required to keep aircraft legal?
Would just a new W&B and logbook entry be all or would it require a new C of A or other paperwork from FAA. I apologize for the off topic question but a lot of DAR's look at the RV-12 threads.

Thanks
Jim Miller
 
My opinion would be that adding an electrical system should not be a major modification that would affect the flight characteristics of the airplane. Modifications affecting flight characteristics are what drive the need for a new set of limitations and/or test period sign off. What you might need to make sure of is that you can meet your limitations. If the original ones refer to no electrical, you might want to discuss with your local FSDO, who is repsonsible for issuing new limitations.

Vic
 
According to the regulations (specifically FAR 21.93), A ?minor change? is one that has no appreciable effect on the weight, balance, structural strength, reliability, operational characteristics, or other characteristics affecting the airworthiness of the product.

Now, the FAA does not specifically define "appreciable", so you need to do a good job of deciding whether the change you're making is "appreciably" affecting any of the factors mentioned above. The way I always explain this is, if you feel you can stand in front of an FAA administrative law judge and be confident that you can convince him/her that your change is minor (as defined above) then it's minor. If you would not be comfortable defending your position in front of the FAA judge, then it's probably a major change and should be handled in accordance with the major change provisions found in your aircraft's operating limitations.

Cheers!

Joe
 
Oh that's a good gray area! This is a rather typical issue with older warbird or antique airplanes (like old Stearmans and stuff) that originally came without electrical systems. Some are flying in standard category, some are experimental, some are exhibition, etc..

Depending on the certification status of the plane and the FSDO it can be a really big pain in the rear, or be no big deal at all. I've been involved in a number of these exact issues, and some have been literally no issue at all, where others have been a big problem. Major and Minor changes can be much more odd things or more complex than you would think. Most all of us in my shop are A&P's and or IA's and I don't think we'd be able to accurately predict the outcome of this question.

I wouldn't want to opine on what your exact FSDO says in relation to your exact plane, but a quick phone call would fix that!

My 2 cents as usual.

Cheers,
Stein
 
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