Unless Paul posted this year's April Fools joke in the May issue of Kitplanes, owning a new RV will come with some expensive maintenance that was not even required on your old PA -28 that you were glad to leave behind for your new RV.
Take a look at page 3 of the May issue, Editor's Log Fine print......
"For instance, the latest ops lims have a paragraph that requires all life and overhaul time limits recommended by manufacturers to be observed. In simple terms, that means that if you have a Lyocming engine with a TBO of 2000 hours or 12 years (whichever comes first), you MUST have it overhauled when you reach the first of those limits."
That would be 166 hours per year. Think about the value of your RV, 12 years from now when the prop and motor is required to be overhauled. I sure hope the EAA will step in and correct this issue.
Or am I the only one that Paul caught with this April fool...........
Disclaimer: I am not a DAR or DER.
Need more context. What's the wording of the limitation?
Order 8130.2J is the latest document specifying operating limitations for homebuilts. There's no such limit requiring you to overhaul your engine there.
Now, 8130.2J does show limitation (2) in Table D-1 as follows:
The aircraft may not be operated unless the replacement for life-limited articles specified in the applicable technical publications pertaining to the aircraft and its articles are complied with in one of the following manners:
(a) Type-Certificated Products: Replacement of life-limited parts required by ? 91.409(e) applies to experimental aircraft when the required replacement times are specified in the U.S. aircraft specifications or type certificate data sheets.
(b) Non-Type-Certificated Products: All articles installed in non-type-certificated products operated under an airworthiness certificate issued for an experimental purpose, in which the manufacturer has specified limits, must include in their program an equivalent level of safety for those articles. These limits must be evaluated for their current operating environment and addressed in the approved inspection program. All articles installed in non-type-certificated products in which the manufacturer has specified limits, must include in their program an equivalent level of safety for those articles. The article must be inspected to ensure the equivalent level of safety still renders the product in a serviceable condition for safe operation. (20)
As Mel notes,
recommendations =/= life limits. Life limits have very specific legal definitions and they are very clearly spelled out in somewhere like a TCDS (Type Certificate Data Sheet) or in an applicable approved maintenance document (e.g. the "Time Limits" and "Airworthiness Limitations" sections in Chapter 5 of a large jet's maintenance manual). Even if we install certified Lycoming engines, they do not come with a life limit specified in on the TCDS or in the applicable Operator's Manual (O-360 manual as an example). And finally, all of the guidance from Lycoming regarding TBO is explicitly worded as "recommendation".
By contrast, if you were use one of the Centurion diesels--e.g. a Centurion 4.0 BE-250 (
TCDS E00079EN), note 6 specifically says "Centurion 4.0 engine is Life-Limited. The core engine must be removed from service in accordance with the Airworthiness Limitations Section, Chapter 5 of the Operation & Maintenance manual OM-03-01 (US-Version)." By my read of this operating limitation, installing this engine would place a hard life limit on your engine.
I do not know what the legal effect of obtaining such an engine, tearing it apart and rebuilding it, and calling it an experimental "Kitbuilder 250" engine (or whatever) would be.
Edit:
Upon further reflection I think some of this is mean to apply to, say, S-SLA aircraft. Those aircraft don't have a TCDS but the manufacturer can require time limits. And if your S-SLA uses a certified engine with a time limit, you would be required to abide by that. Again, I'm no DAR but I'd agree with Mel that I wouldn't expect that this should apply to E-AB.
Edit 2: This limitation refers to "articles" which is a term with a specific definition in Part 21 (which concerns "certification procedures for products and articles"). My read would be that references to "articles" in the operating limitations means "articles approved under Part 21 procedures". If your particular component isn't approved via TC, PMO, TSO, etc. then even if the manufacturer does specify some kind of life limit, I don't see how it could be legally binding.
Edit of edit 1: Mel has pointed out below that S-SLA aren't included here. Unfortunately we lack a strikethrough format command.
This also makes me wonder what the applicability would be to the reuse of life-limited parts (e.g. landing gear) salvaged from a certified aircraft.