Rules? Repowering certified aircraft with experimental engine

[challenger_II]

More reference material:

experimental exhibition catagory (eaaforums.org)

 

[rv7charlie]

I wouldn't call that 'reference material'. It's random people posting on a forum, with as much (as little) authority as this one. And some of the posts are very much in error, both in understanding the purpose of some of the requirements and their effects on operation of the a/c.

 

[challenger_II]

Ah! But it keeps us from going down the same path!

 

[Turd Ferguson]

Would you contact first for permission to remove the data tag? Has anyone done this?

Removing and surrendering the dataplate is a relatively recent development. In the past, nobody cared. Years ago I was in a guys workshop where he had dozens of removed dataplates hanging on the wall. Pretty sure he didn't bother getting permission.
However, in 2018 as part of the registry clean up, the FAA wrote a new national policy for destroyed or scrapped aircraft. https://www.faa.gov/documentLibrary/media/Order/FAA_Order_8100.19.pdf Apparently, they are trying to prevent destroyed and scrapped aircraft from showing up on the registry in the future. One way to ensure that is by getting the dataplate out of circulation.

I seriously doubt anyone has gotten in trouble for removing a dataplate from a destroyed/scrapped aircraft without permission -- as long as it's not being removed and retained with the intent to sell or attach to a different aircraft.
Nonetheless, if an aircraft registered in my name was destroyed or scrapped, I would notify the FSDO that I am removing and surrendering the dataplate along with the other paperwork. If I found a dataplate in a pile or scrap parts I bought, I would just hang it on the wall in my shop.

 

[BBerson]

Nonetheless, if an aircraft registered in my name was destroyed or scrapped, I would notify the FSDO that I am removing and surrendering the dataplate along with the other paperwork.

But what if the aircraft you own wasn't destroyed or scrapped, can you start to do the modifications and turn in the data plate with the exhibition application when it is finished? Might take 10 years to modify.

 

[Fiberglassworker]

I think you can also license your aircraft as experimental flight research and development, then when you have the bugs worked out of it. look at putting it into the restricted category.

 

[skydawg]

A lot of wrong info on this thread. We put a lot of this info on Corsairpower.com
after literally hundreds of emails, calls and drop in visitors seeking same info. In the end assessment, the FAA has been trying to kill GA for a long time and they have restrictive policies (not regulations) that they use to make the conversion from cert to exp difficult and expensive. In a nut shell, unless you have a wide skill set, willing to spend more money than you would have spent keeping it certified, its not worth it. Buy an AB.

Corsair’s goal is to sell a kit with all the documents (approved/accepted manuals, engineering analysis, completed flight test, ect..same that would be required for standard cert) for exp conversion so that someone can just work with a DAR and not need to do all the complex and expensive stuff.….but FAA has been less than helpful, even though we solved the leaded gas issues and substantially lowered emissions while lowering hourly operating cost by more than 60%. Our team includes specialized engineers with graduate degrees, former DER, flight test pilot, ect…there’s a lot needed to do an auto conversion right and it’s not worth it for just a one off.

so, it was a great project with lots of challenges that was our initial drive, but I’d buy an AB before converting a certified aircraft. Good luck either way.

 

[PMD]

A lot of wrong info on this thread. We put a lot of this info on Corsairpower.com

so, it was a great project with lots of challenges that was our initial drive, but I’d buy an AB before converting a certified aircraft. Good luck either way.

I am sure you realize this, but I have to ask if you have had any sales into Canada - where we can put any certified airframe into the "owner maintenance" class and re-power as we see fit? I can see a wide bodied 182 being a really useful home for one of your engines/drives!

There was once a time when the world center and leader of genav was indeed the USofA. Sad to see it has become a backwater of bureaucrats, insurance scams, LLL (Legal Liability Lottery) ambulance chasers, etc. If you guys (and gals) don't fix this, I fear genav will simply go down the tube in USA and rise somewhere else on the planet.

(on edit) Just finished going through your website - see you are not quite at the sales end of the process yet. Of course, the big restriction for Canadians is once we are in OM, can not cross into USA as FAA does not recognize the classification.

 

[BJC]

Of course, the big restriction for Canadians is once we are in OM, can not cross into USA as FAA does not recognize the classification.

They probably wouldn’t recognize it if you did fly here in one.


BJC

 

[PMD]

They probably wouldn’t recognize it if you did fly here in one.

I have wondered about that, but not willing to poke that tiger in the balls any more than necessary.

 

[skydawg]

Canada’s OM is a great option for these older birds to continue flying. FAA is trying something similar with proposed LSA new rules but that’s likely 3-5 years away. as it would keep aircraft flying rather than scrapped or parted out to continue GA’s demise, I expect closer to 5. We get a lot of inquires from Canada and a Few shops wanting to install our kits, but none wanting to be first to commit to buying a minimum number to make it feasible. Can an OM aircraft be exported? We get a lot of international inquires about buying complete aircraft and may be a method to sell complete aircraft to developing nations and get around the liability issues we have in US.

we are still looking for right investor to fund STC that shares our vision, but the c172 kit is ready to go and c182 soon Thereafter. I think it would be a great solution under your OM category, especially for building time. FAA allows instruction and check rides in EXP here, what about OM?

 

[TFF]

In lots of countries, things like STCs don’t exist or are super expensive to implement. A friend flew for a contract company for the UN to find the Somali pirates. Lots of the European pilots ended up getting US licenses because they could update, with new equipment, a US registered with the 337 where as a European mod took a year while they thought about it; each time. They converted most of the fleet to US register planes. A complete flying airplane is usually importable. Most of the world thinks magic is released if you work in an airplane. The problem will still exist that it needs to be certified. Third world you might get away with lots, but Europe will still need it to be certified. Not exhibition.

Until you get the STC finished, it’s not going to happen.

 

[PMD]

We don't have the 337 option North of 49. Many used aircraft in Canada were imported from the US. WWWWAYYYYYY back when I was in the airplane fixing biz, we started out working on anything that came through the door. We found not one single private airplane that had been imported used that was actually legal. Many reasons, but the big one was that you had to "undo" 337 mods to make the a/c comply with the TC and any STCs in the log books.

The way I understand it: an OM a/c is not flying under its TC so to put it back you do an ITRAN that reverts all mods back to TC+STC. You could export it, but not sure what country would allow it in unless you could afford to bribe officials.

Not sure how the Transport Canada would look at instruction in an OM a/c - but suspect a no go. We have moved forward in some aviation sectors, but coming from a LONG way behind! That said: there was some kind of blind eye when "heavy ultralights" were used for instruction in the '80s before "advanced ultralight" (Canuck-speak for LSA) was clearly defined and enforced.

 

[Dan Thomas]

They probably wouldn’t recognize it if you did fly here in one.


BJC

It will have a big placard on it that identifies it as OM and flying without a Standard C of A.

CAR Standard 507.3(6):

(6) Special Certificate of Airworthiness - Owner-maintenance
(amended 2002/03/01)

1. (a) A Special C of A in the owner-maintenance classification is issued for recreational purposes only.
   (amended 2002/03/01)
2. Information Note:
   1. Aircraft eligible for a Special Certificate of Airworthiness - Owner-maintenance are listed in Appendix H of this Standard.
3. (b) Each aircraft in respect of which a Special C of A - Owner-maintenance is in effect, is marked on the side of the fuselage, in a position that is readily visible to persons entering the aircraft, in letters at least 10 mm (3/8 in.) high and of a colour contrasting with the background, with a placard containing the following statement:
   (amended 2002/03/01)
   1. WARNING
      SPECIAL CERTIFICATE OF AIRWORTHINESS - OWNER-MAINTENANCE
      THIS AIRCRAFT DOES NOT COMPLY WITH INTERNATIONALLY RECOGNIZED AIRWORTHINESS STANDARDS

 

[Dan Thomas]

I am sure you realize this, but I have to ask if you have had any sales into Canada - where we can put any certified airframe into the "owner maintenance" class and re-power as we see fit? I can see a wide bodied 182 being a really useful home for one of your engines/drives!

Might not get away with that. I have never seen any CARS or Standards that outline hard limits, but COPA has a guidebook on it that says something like "modifications within certain limits." Transport would want to know what you're doing with it and they'd want to see it. As it is, in applying for the OM you need an AME's inspection and signoff stating that the aircraft "meets its type design," so any mods at the time that have no STC will disqualify it.

A friend bought a Vagabond on OM that needed recover. Turns out that the previous owner had made some mods to the wings. TC yanked its C of A.

The OM category was intended to enable owners of simple, old, orphaned airplanes to do their own maintenance and to use non-specified parts to keep them going. A voltage regulator from NAPA. A generator from Bumper to Bumper. A lawn tractor battery, maybe. A spinner from another model of airplane. Automotive engine gauges. Stuff like that. Modifications that can be supported by STCs will likely be OK.

My idea of making a taildragging Navion and powering it with a Geschwender Ford would get those guys at TC all excited. Just the retractable gear disqualifies it, since the OM category is for fixed-gear, fixed-pitch prop, four seats or less airplanes, with a couple of exceptions that somehow were sneaked into Appendix H of Standard 507 early on. The Colonial Skimmer and the Bellanca 14-13 airplanes come to mind. Not simple airplanes at all.


My old Auster was an ex-military airplane and flew on a continuing flight permit, same as homebuilts in the 1970s. That category has been changed as well. It's gotten a lot tighter.

 

[PMD]

Might not get away with that. I have never seen any CARS or Standards that outline hard limits, but COPA has a guidebook on it that says something like "modifications within certain limits."

Thanks, Dan. Appreciate hearing/learning that.

 

[gtae07]

Canada’s OM is a great option for these older birds to continue flying. FAA is trying something similar with proposed LSA new rules but that’s likely 3-5 years away.

That was proposed 10 years ago in the Part 23 ARC's report. They called it "Primary Non-Commercial". As you note, it's supposedly in consideration as part of MOSAIC.

Given how broad the US E-AB rules are I'm sort of surprised the FAA is so rigid on the idea of letting people take standard-category aircraft and convert them (permanently or otherwise) to something broadly equivalent to homebuilts. Yes, the FAA does seem to be rather difficult to budge once it's made up its mind, but it almost seems like part of their objection is "but someone, somewhere, someday might want to use an airplane to make money, so we can't allow anyone to do that!"

In fact I think that sort of reasoning is behind much of the FAA's rules on cost-splitting, certification, and other rules--they just seem utterly convinced that everyone will eventually try to make money off airplanes and aviation, because they just can't imagine why someone would own/operate an aircraft without trying to recoup the cost. That, and the circular reasoning of "the rules say X, and we can't change them to say something other than X because the rules say X"

 

[Pilot-34]

You know it always seemed odd to me the front half of the airplane is usually considered to be the engine and from the firewall backward is usually considered to be the rest of the airport about half an half.
Now if I build the back half it’s A home built but if I build the front half that’s not considered to be doing anything at all.
It seems fair to me that if I can hang a certified engine on a home built fuselage and have whats considered a Homebuilt airplane that I should be able to hang a certified fuselage on a home built engine and have that considered to be a homebuilder airplane.

 

[Bill-Higdon]

You know it always seemed odd to me the front half of the airplane is usually considered to be the engine and from the firewall backward is usually considered to be the rest of the airport about half an half.
Now if I build the back half it’s A home built but if I build the front half that’s not considered to be doing anything at all.
It seems fair to me that if I can hang a certified engine on a home built fuselage and have whats considered a Homebuilt airplane that I should be able to hang a certified fuselage on a home built engine and have that considered to be a homebuilder airplane.

There you go again applying logic to a "illogical" organization.

 

[TFF]

Applying snowflake logic to rules that are written in stone. You don’t have to like them, that’s a personal choice. Changing them is not possible without difficulty and defacing. One little project is not the savior. Not the government’s problem one can’t complete the project when others have. Others have. Nothing wrong with dreaming big, but dreaming big is not getting over the finish line. You finish per the rules or you don’t. It’s a game of rules. There are plenty of rules that allow it not to be certified, so if it can’t find traction there where 80% of every engine thread wishes those wishes, you got a marketing problem.