Van's Air Force
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FAA issues new Order 8130.2K effective 8/28/24
- Thread starter Vern
- Start date
Do you have the link?
Section 1.7 and 1.8 give the synopsis of the changes. Page 1-2 of the document here:
Xkuzme1
Well Known Member
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.
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.
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”…..
Desert Rat
Well Known Member
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.
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.
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.
Desert Rat
Well Known Member
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
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
)
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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scsmith
Well Known Member
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!!!.
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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Desert Rat
Well Known Member
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.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
Nice to get rid of at least a couple of gray areas.
No! Your current Operating Limitations are your "Bible".
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.
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!
Previous wording
New wording:
Sounds like they're really trying to clamp it down to one, maybe two airports.
We’ll see what we hear back from the EAA….
rmartingt
Well Known Member
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...
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.
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.
rmartingt
Well Known Member
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...
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.
Draker
Well Known Member
I remember specifically asking VAF's opinion about this, whether any kind of "home base" airport was implied by (2022 vintage) operating limitations. Looks like this is an area of the rules that is under active FAA scrutiny/review!
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.
dmattmul
Well Known Member
This aircraft may only operate from [identify name of airport(s)]. (42)
Previous wording
New wording:
Sounds like they're really trying to clamp it down to one, maybe two airports.
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?
Who'd you ask? And isn't a take-off or a landing an "operation"?
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).
Vern
Well Known Member
An email was sent out previously about the FAA Order 8130.2K being released and available on the Dynamic Regulatory System (DRS). This email is to inform you that the FAA Order 8130.2K now has an effective date of October 27, 2024, and is still available on the DRS with new effective date.
Just got this. Vern
Just got this. Vern
In addition, I had some discussions yesterday wit te EAA Government Liason folks, and they are working the issue on number of airports during Phase 1 with FAA HQ. I was told that if a DAR asks their Managing Specialist for a deviation (asking for more airports - but not and unreasonable amount) in the Phase 1 test area, it will be instantly approved by HQ. Yeah, that takes some extra work in the field, but at least it indicates that the HQ folks know the “one airport” thing is draconian.
Maybe the delay in implementation can get that fixed!
dmattmul
Well Known Member
It appears that the FAA has been using the name your operating airport(s) since Apr. 2023. Have the DARs and FSDO been following this guideline (recommendation) for the last 18 months? I'm pretty sure my 2016 and 2020 OL's do not have this, just a center airport and radius.
"This aircraft may only operate from [identify name of airport(s)]."
Thanks
Mon, Apr 24, 2023
Upon an applicant aircraft’s completion of the newly-specified tasks, the FAA will approve creation of a unique Aircraft Operating Handbook (AOH*). The applicant aircraft, thereafter, is considered to have completed the Phase I flight-testing period.
The program prescribes a series of 17 discrete flight-test tasks, and recommends the tests be flown per test cards carried in the aircraft. The program further requires the creation of an Aircraft Operating Handbook (AOH)* from the test results. Such a document benefits the builder and any subsequent owners of the vetted aircraft. Test plans—provided they accomplish the FAA-prescribed tasks—may be written by anyone, including kit manufacturers and type clubs. Users of the EAA’s Flight-Test Manual will note similarities in the requirements of the EAA and FAA protocols.
In order to utilize the task-based flight-testing program, an applicant aircraft must have an operating limitation allowing said program’s use. Operating limitations are issued along with airworthiness certificates by the FAA or Designated Airworthiness Representatives (DAR) as part of an aircraft’s airworthiness certification process.
As the traditional time-based Phase I program remains unchanged, aircraft builders are free to utilize such.
On 21 April, the FAA released a formal policy memorandum fully enabling the use of the task-based methodology.
The new operating limitation reads (blank fields to be filled in by the appropriate inspector or DAR:
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. Unless operating in accordance with the task-based flight test program described in Advisory Circular (AC) 90-89C, Amateur-Built Aircraft and Ultralight Flight Testing Handbook, chapter 2, section 1, during Phase I flight testing, 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)].
"This aircraft may only operate from [identify name of airport(s)]."
Thanks
Mon, Apr 24, 2023
FAA Releases Policy Memo on Task-Based Phase I
Better to Do, Than Wait
In early March 2023, the FAA published guidelines for an optional task-based Phase I flight-testing program, thereby establishing an alternative to the standard 25 or 40-hour flight-testing requirement for amateur-built aircraft and replacing the hours-based testing period with a list of comprehensive and concise tasks.
Upon an applicant aircraft’s completion of the newly-specified tasks, the FAA will approve creation of a unique Aircraft Operating Handbook (AOH*). The applicant aircraft, thereafter, is considered to have completed the Phase I flight-testing period.
The program prescribes a series of 17 discrete flight-test tasks, and recommends the tests be flown per test cards carried in the aircraft. The program further requires the creation of an Aircraft Operating Handbook (AOH)* from the test results. Such a document benefits the builder and any subsequent owners of the vetted aircraft. Test plans—provided they accomplish the FAA-prescribed tasks—may be written by anyone, including kit manufacturers and type clubs. Users of the EAA’s Flight-Test Manual will note similarities in the requirements of the EAA and FAA protocols.
In order to utilize the task-based flight-testing program, an applicant aircraft must have an operating limitation allowing said program’s use. Operating limitations are issued along with airworthiness certificates by the FAA or Designated Airworthiness Representatives (DAR) as part of an aircraft’s airworthiness certification process.
As the traditional time-based Phase I program remains unchanged, aircraft builders are free to utilize such.
On 21 April, the FAA released a formal policy memorandum fully enabling the use of the task-based methodology.
The new operating limitation reads (blank fields to be filled in by the appropriate inspector or DAR:
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. Unless operating in accordance with the task-based flight test program described in Advisory Circular (AC) 90-89C, Amateur-Built Aircraft and Ultralight Flight Testing Handbook, chapter 2, section 1, during Phase I flight testing, 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)].
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CJT
Active Member
I read through AC 90-89C. On page no.9 it mentions Task based testing is for conventionally designed, air cooled 4 stroke engine developing LESS THAN 200HP WITH FIXED PITCH PROPELLER
Does this make RV 10 an exclusion?
EAA has published this AC and printed test cards for each of these tasks, available at nominal cost of $20. The package also covers detailed instructions to apply for Airworthiness certificate
I think the thought behind this is to have more structured tests than just flying for X number of hours, which is commendable
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1001001
Well Known Member
In my case, my RV-10 will likely be based at an airport in Class D under Class B airspace, which makes restricting the test area to a radius around that airport very limiting. When I get to the point where oplims are to be issued, I will request an area around this airport, and a corridor to at least one other airport well outside the Class B area with an area defined around it for testing. I'd rather not have most of my test area be limited to a 4000 MSL ceiling. Additionally, the area around here is lousy with training flights, and with the speed of an RV, it just makes safety sense to be able to fly to a remote field and do testing around it.
The points about having emergency services around the test airfield are good ones, too, but can be exclusive of more remote fields.
gyoung
Well Known Member
I'm in the same situation, Class D under Houston Class B. In 2001 I got a big test area centered on a VOR well outside the Class B. Fast forward 20 years and tried the same for my new RV. No dice. They defined an area with airports defining the corners and carefully drawing around a couple other Class D. I've got a corridor to get to the test area. It's a bit of a PITA but at least there's no restriction about landing at any airport in the test area. I even got them to stretch the area a bit to pick up an airport I wanted. But that was a couple years ago. Sigh!
dmattmul
Well Known Member
"1.7 Request for Information. We have designed this AC as a reference document to help prepare a flight test plan for an amateur-built aircraft or ultralight vehicle. The suggestions and recommendations in Chapters 2 through 7 are for conventionally designed aircraft with an air-cooled, 4-cycle, reciprocating engine developing less than 200 horsepower (hp) and with a fixed-pitch propeller", page 1-2.
I'm hopeful by the wording "suggestions and recommendations" gives DARS and FSDO some wiggle room or else CS props might also be become an issue.
rmartingt
Well Known Member
My read is definitely not "this is the only aircraft type you can use task-based testing on". I interpreted that listing of an airplane type as just "here's a sample test plan for an airplane of this common configuration"--in other words they are providing their ground rules and assumptions because they had to have something to provide a sample off of. There's no way they could provide a comprehensive test plan applicable to all EAB aircraft and there's nothing in there that inherently limits it to fixed-pitch sub-200hp. It's still up to you to develop your actual test plan for your airplane.
Let's hope. Thanks to my location I'm "boxed in" on two sides by some restricted areas, Class C, busy MOAs and military fields, etc. and figured my Phase I area would be a rectangular box with my home base in the southeast corner. There are plenty of small rural airports in my theoretical box that are well away from dense populations that would be good for fuel, bathroom breaks, weather diversions (pop-up afternoon storms are common around here), etc. I can think of several I'd like to have just due to runway configurations and easy access if I need to divert and have someone come pick me up by car.
Not to worry -the Task Based program does not require a specific plan - you can develop any plan you want to defend (if anyone ever asks….which I can’t imagine they will unless you do something really dumb….). The AC is giving an example.-not a requirement. The most widely used plan is the EAA’s.
dmattmul
Well Known Member
With the EAA article out today "EAA Works to Correct Change in FAA Phase I Flight Test Policy" seems they are hopeful to get back to the wording that was recommended now for the last 18 months and that is naming specifically several airports in your phase 1 area you can land and take off from, and no others. I get we can use FAR 91.3 but I doubt landing to get cheaper gas meets that test. I'm surprised no one has raised a red flag on the forum or are DAR's not using the recommended language in ones OL? What has been the language being used in newer OL's?
As always appreciate the input
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You need to read this whole thread - several DAR’s (including me) have raised red flags on the issue - in fact, I was the one that brought it to the EAA’s attention the day that “K” came out and was supposed to be instantly effective. Bottom line is that there is a lot of behind the scenes work going on to get this fixed - including the very rapid change of effective date (be about two months) to make it happen.
The existing wording gives us the capability to provide multiple airports (no numerical limit is given) for pilots to use during Phase 1, and that is what is done by most of the DAR’s I know.
Paul
dmattmul
Well Known Member
And I have, thread started Sept 3, 2024. My point is the FAA issued guidance Mar 2023 to list all airports one can land and take off from in your phase I area. To date over the last 10 years 2 DARS and one FSDO for Phase 1documented I could land and take off from any area in Ohio that was in my designated area, now for my next experimental will have hopefully 3 or 4. (out of 20 or 30) My point is this seems like a major change that we have not been talking about since March 2023 or maybe I missed it ??
I think because it wasn’t that big of a deal and there wasn’t really a good argument against it (unless your primary flight test plan was to just cruise around and visit all of the airports in your region for 40 hrs).
The new rule of allowing only one airport is a big deal and likely a move backwards in the context of safety.
rmartingt
Well Known Member
There was some griping about it before (https://vansairforce.net/threads/phase-1-limited-airports-to-land.217879/ and https://vansairforce.net/threads/phase-1-limited-airports-to-land.210888/) but even then, the order still permitted several airports, which is pretty reasonable (though still begs the question of "why impose this new restriction after decades of not having it?").
The problem now is that the Order now basically says "only one airport, or maybe two if you give us a really good reason". There are lots of real-world problems with this.
Seems to me the people writing these rules are completely out of touch with both the real world and the DARs that apply the policies. Has there been significant turnover/change of leadership within the group that publishes these rules lately? Because this smells a lot like someone new coming in and deciding they want to "fix" what they see as a long-standing mistake and make some changes based solely off of "here's how it works in my head" without understanding why things are they way they are, or how they got that way in the first place.
To "center" your flight test area doesn't work if you're on the edge of class, B, C, or D airspace. Doesn't work if you're anywhere along the front range of the Rockies. Do you really want to go over those mountains in your "centered" airspace? Doesn't work if you're near any of our borders. Doesn't work if you're on the edge of any restricted airspace. Doesn't work if you're on the coast.
The point is, everyone's situation is different. There is no one size fits all. What if the FAA did what's safest for the particular situation?
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