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Discussion in 'Rules and Regulations / Flight Safety / Better Pil' started by PTAirco, Jan 14, 2020.
I think it's four years now....... (from Dan Johnson, insider)
At what point does a "repair" become an "alteration"?
So for a "repair" (of any type) you need to follow "(7) The owner or operator complies with the requirements for the recording of major repairs and major alterations performed on type-certificated products in accordance with §43.9(d) of this chapter, and with the retention requirements in §91.417." This is data recording and keeping.
While an AC is not regulatory, it seems to state that for a major repair "The manufacturer MUST provide the technical data for such a repair or alteration and identify the training required, IF ANY, to perform that repair or alteration". This seems to be a requirement for the manufacturer. It would seem that if manufacturer does not provide the technical data it could be argued that the manufacturer is saying that none is required beyond that of standard practice. A certified letter to the manufacture stating this could get a response.
Major Alteration is defined in part 1.1.
Ric Peri, who does I.A. talks said over half the 337 forms that mechanics fill out are unneeded.
The words "might appreciably affect" weight, balance... are key.
Ric said that means only extreme changes, such as a gross weight increase. It's up to the owner to decipher the rules.
Intriguingly there doesn't look to be any exemption applications in the system for repairs to LSA aircraft unless we haven't found the right rule yet (even the denied ones contain interesting statements of FAA policy).
Finally got an email from the owner and the punchline is:
Strip the entire fuselage and all damaged parts and send it all to us to repair.
Buy a new airframe.
Gee. Sounds like a great plan.
ELSA it is. No brainer.
Curiously, Cub Crafters sells a lot of S-LSAs. But most of them get converted to ELSA before they ever leave the factory. At no charge. Because 90% of customers want ELSA but don't want to build the thing themselves. Seems very accommodating.
Hmmm... I'm thinking that if an owner converts to ELSA, then the manufacturer's liability could be substantially reduced, no? Maybe that's their intention.
Quite right. Win-win.
I think you will find that with some of the kit manufacturers as well... Parts are very expensive for what they are (mostly OTS stuff) and there is usually a pretty good wait time.
Some companies are better than others, but some really follow the car manufacturers policy of 300% mark up.
Good luck with the repair and fly safe,
It's a one way street. Just like Exhibition category switches. Sorry.
Glasair Aviation is an exception. A recent response for a price quotation on a replacement commercial component was “XX dollars, but it is a [manufacture] part number XXX available at most auto parts stores for [much less].
The cost for them to handle a few dozen parts a year increases the price that they must charge to the point where it is unreasonable.
YOWWWWZA ! Aviation is still a pretty small community, taildraggers even more so, and word about this kind of behavior spreads like wildfire. The owner of that business is making a mistake of Biblical Bede proportions.
If it were me (and it definitely isn't), and unless there is some really unique and draconian regulatory issue that prevents him from behaving well toward the customers, I would tell the owner of American Legend : "If you, as the Production Authorization and Design Approval holder, authorize me to use 43.13 acceptable methods on this repair, I promise to not incinerate your company's reputation on social media and the aviaiton forums so much that you may never sell another airplane again. Aviation, and antique style airplanes in particular, is a very small, tight community. I react very very very poorly to highway robbery, and I bet most other folks do as well... you will have nobody to blame but yourself."
That too is my opinion, but it will only stop me* from buying one. I probably would never be in the market for one anyway so it makes no difference to the business owner.
What might make a difference is when the insurance companies find out that what they are insuring is for all practical purposes, a disposable airplane.
*and maybe someone that might ask for my input before making such a purchase.
Insurance would rather scrap it. I know of a helicopter that the insurance company said scrap. Why? The never wanted to pay a claim on that aircraft again. They lost too much. They payed up and had the manufacture revoke its Serial Number. All very fixable. I know because my boss bought the low time engine and tail rotor, from it for us.
The FAA likes it because they are not on the hook to regulate repairs. The company is. The FAA would rather cut in on the company than find some small shop in trouble.
Hot Wings, you may have just gave us the way to solve PT Airco's issue. A letter signed by all of the owners of the Legend Cub, sent to the insurance company (and the FAA), saying that because of their stance on repairs, it is affecting everyone's interest in paying for insurance on that aircraft, AND it is significantly increasing the insurance company's cost of repair as part of a claim.
It is also creting a situation where (knowing this) owners are morelikely to overlook repairs or make hasty "backyard" repairs because it's less anguish. This creates a potential air safety hazard.
I think the insurance company would send it to their authorized repair center or the factory.
They don't deal with small repair shops. The whole system works against independent shops.
I know a small, privately owned repair shop that gets all the insurance work that it wants. They do outstanding fabric and paint work, wood work, etc. There was an article in Sport Aviation a few years back, about his M14 powered UPF 7.
The shop is the cleanest, most organized aircraft workshop that I have seen.
Yeah, some get all the insurance work. The insurance companies prefer a known company that has a proven track record for that type. Not always the lowest local bidder. They don't even ask for bids, from my experience.
The insurance angle is a good one. If the repair or replace cost becomes prohibitive, insurance companies might decline to insure them at a reasonable cost. No insurance, no financing, because the bank will want some protection. No financing, no sales.
I don't usually comment on any type of 'legaleze" crap. I will mention that I have been researhing and looking at several LSA type of the years and have personally met and talked in depth with Darin (owner of Legend). One of the easiest and most starighforward (honest?) manufactures I talked to. (Randy) of RANS is another. The factory built LSA aircraft are a whole different ball game compared to cerified aircraft. I found out a long time ago that any modification, repair.....most anything you want to do on the airplane has to be approved and factory letter to keep them legal. It is the main reason I did not want an SLSA. Most, if not all the LSA manufactures are willing to have a DER convert the plane to ELSA upon purchase which allows the owner to work on it.
The manufacture of these planes is done under ASTM Consensus Standards not type certification like a Cessna/Piper/Beechcraft. The info is there if you research it. I think the Legend is one of the nicest LSA on the market and a greater value vs. say the Carbon Cub. If I were to buy one, it would be immediately converted to ELSA before it left the factory.
I actually looked at a few LSA that have been damaged (including the Legends) and walked away due to the same reason the OP is having issues. I would buy them to part out, not to rebuild as the cost/value wouldn't be worth the spediture. JM2C
The second has nothing to do with the first. The repair situation described is strictly due to the manufacturers choice. It is not mandated due to the ASTM standards.
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