S-LSA downsides

Discussion in 'Rules and Regulations / Flight Safety / Better Pil' started by PTAirco, Jan 14, 2020.

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  1. Jan 21, 2020 #61

    Hot Wings

    Hot Wings

    Hot Wings

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    Or more likely the FAA will ask the F-37 committee to 'fix' the problem. That has happened in the past when a manufacturer created hazards by following the letter of the standard.
     
  2. Jan 21, 2020 #62

    Victor Bravo

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    The strange part is that IIRC we have it on fairly good authority from one source thaat I know personally (WW Hunter) that the owner(s) of ALA are good people, and then we have what appears to be bad faith behavior by them in the matter of actual repair of the aircraft.

    If they were just scumbag people, then it would be a straightforward play with the FAA to pressure them or shame them into reasonable behavior. But apparently they're not actually scumbags. So unfortunately there may be a good reason to do all of this with some amount of resatraint :)
     
  3. Jan 21, 2020 #63

    Hot Wings

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    Could very well be. Actually coming up with good repair procedures, other then the standard texts, and documenting those can be as much work as the original design and ASTM testing. Designing/engineering and repair do require different skills.
    I've discovered this myself with my rather simple plans redo project. Just creating an inspection list for pre-flight and condition inspection is going to be a project of it's own.
     
  4. Jan 21, 2020 #64

    BJC

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    It might relate to the terms of their insurance.


    BJC
     
  5. Jan 21, 2020 #65

    davidb

    davidb

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    No doubt but this aircraft is also available as a kit. If one wants to simply remove and replace a strut, the part and procedure already exists.
     
  6. Jan 23, 2020 #66

    PTAirco

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    My partner is flying out there in person to speak to them next week. IF they will even speak to him. I think it's a waste of time but I'll give them the benefit of the doubt for now.
    Since 90%+of customers want ElSA, I don't even see point but I would prefer a working relationship with the company.
     
  7. Jan 23, 2020 #67

    Victor Bravo

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    Maybe present them with a proposal that you can be the West Coast repair center. They get to work with someone credible and experienced, and they can tell the FAA they have changed their policy to provide a safer or more viable option. You agree to provide them with data and that their quality standards are being used in repair of their aircraft. Win-Win, and you get some extra gas for the Maule :)
     
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  8. Jan 24, 2020 #68

    PTAirco

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    I agree, engineering and repair are two different disciplines. ALA replied with this to my request for drawings:

    "Legend aircraft engineering, manufacturing processes and certification documentation is all proprietary. Please refer to our maintenance manual, page 68. “No structural repairs are approved” .

    If this was Spaceship 1 or something ,I get the "proprietary engineering and processes". I'd want some guidance and procedures for repairs. This is a Cub clone! It's mostly off the shelf parts from other vendors with a fuselage design that probably came from some homebuilt variant. Proprietary engineering, indeed. As if there was something about their tube and fabric design from the 30s that a typical A&P shouldn't be messing with.
     
  9. Jan 24, 2020 #69

    Victor Bravo

    Victor Bravo

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    There is also the delightful "Alternate Means of Compliance", which a group of us used to defeat the factory wing strut AD/robbery attempt at Taylorcraft about 15 years ago.

    You might look to see if an AMOC can be accepted by the feds. It doesn'treverse the factory's authority, it gives you another way to meet the FAA's intention to improve air safety.
     
  10. Jan 24, 2020 #70

    PTAirco

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    I'm sure we could come up with something similar if they are being obstinate. Personally, I'd rather go the ELSA route.

    I pity the people who bend their SLSA Cubs.
     
  11. Jan 24, 2020 #71

    Hot Wings

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    Per F2245:
    5.1.3.2 The structure must be able to support ultimate loads
    without failure for at least 3 s. However, when proof of
    strength is shown by dynamic tests simulating actual load
    conditions, the 3-s limit does not apply.
    5.1.4 Proof of Structure—Each design requirement must be
    verified by means of conservative analysis or test (static,
    component, or flight), or both.
    5.1.4.1 Compliance with the

    This combined with what i posted earlier may be enough to simply rebuild using common and accepted methods, and then go test fly to show compliance with this part of the ASTM standards?? The tests required are actually rather simple and could be done with just a few flights at various CG and loads.
     
  12. Jan 24, 2020 #72

    ToddK

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    Make a friend who is an A&P. Problem solved.
     
  13. Jan 24, 2020 #73

    TFF

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    Probably only the certificate holder can show testing as compliance. Is the ASTM aviation regulations available for viewing or does it require membership? This is not an A&P problem as they can’t legally fix it without rules being different. I wonder what has been fixed without repair documents, if insurance has not been invoked?
     
  14. Jan 24, 2020 #74

    Hot Wings

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    Unfortunately the ASTM standards are copyrighted....and rather expensive. :( I couldn't justify the cost but you get a "free" standard of your choosing with membership every year.

    From post #52
    9.2 The manufacturer or other entity that performs the
    evaluation of an alteration or repair shall provide.......

    I take that to mean that anyone can come up with a repair that maintains the certification provided the required testing is done and the paperwork generated.
     
  15. Jan 25, 2020 #75

    Mad MAC

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    "means of conservative analysis or test (static, component, or flight)" that's straight out of FAR 23, so analysis would be the typical approach.

    The wording I would take to mean that repairs need approved data (probably different name but much the same thing in practice) just like the TC'd aircraft, so a repair design approved by a DER (I guess that's what person acceptable to the FAA was aimed at). In this case a major mod to have AC13-43.1 approved as acceptable repair data (its a change to the airworthiness approval so I think its a mod not a repair).
     
  16. Jan 25, 2020 #76

    Hot Wings

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    Part 23 doesn't apply to LSA nor do DERs have anything to do with them.

    LSA was set up from the beginning to be in industry standard based self certification path to building airplanes. There is an old law on the books that mandates that federal agencies use industry standard groups for formulating regulations rather than making them internally whenever appropriate. I'd have to go look up the information again because I can't remember the name of the act but it's pretty old - like 2 decades.

    This is the same reason the the redo of part 23 has all been under ASTM F44. Much like the A.C.'s the ASTM process is only one way to show compliance. If one wanted to go directly to the FAA/DER process they would be free to do so, but there would probably have to be a pretty good reason?
     
  17. Jan 25, 2020 #77

    rv7charlie

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  18. Jan 25, 2020 #78

    BBerson

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    I think he is saying those words for the ASTM standards were copied straight from part 23.
    When I read the ASTM standard for engines and found it was copied straight from part 33, I decided to give up my ASTM membership. There isn't any 30 or 50hp ASTM engines because the standard is impossible for such small numbers.
    The Hirth distributor flat out told me they will not get any ASTM approvals. So Rotax has the market to themselves.
     
  19. Jan 25, 2020 #79

    BJC

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    Change that to Special Light Sport Aircraft and I will agree with you.

    For the new reader here, I would point out that many existing aircraft (Piper J-3, Aeronca 7-AC, Ercoupe, etc.) meet the criteria of LSA and may be flown as LSAs. Similarity, an E-AB that meets the criteria of LSA may be operated as a Light Sport Aircraft.

    BJC
     
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  20. Jan 25, 2020 #80

    Hot Wings

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    Should read my own signature line more often.:oops:o_O
     
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