Wots all this then? Service, Replacement Times and Inspections - Airworthiness Limitation Section (ALS)

[JS]

Many of us will have just received something about HQ-16-14.
In trying to read the mumbo jumbo, I perceive the idea that in order to improve safety you can for example install an electrical system in a SGS 2-33.
But then it's all Greek to me.
Jim

http://rgl.faa.gov/Regulatory_and_Guidance_Library/rgSAIB.nsf/WebSearchDefault?SearchView&Query=HQ-16-14&SearchOrder=1&SearchMax=0&SearchWV=TRUE&SearchFuzzy=TRUE&Start=1&Count=100#

[cliff...@gmail.com]

I understood it to mean that if a manufacturer did not have a service time life limit imposed at the time your Aircraft was made,you are not required to follow their later imposed one. Unless they go through the FAA and do an official AD to address a specific issue to require one. It seems it came about because of a court battle with Cessna over the 210. From what I read FWIW

[Mark628CA]

Hmmm...I wonder if that means the life limit AD on the Pegase is invalid? I mean, the manufacturer did not have a life limit. The AD was pushed through by one doofus at FAA and they backed him up on it until Bob Carlton got an AMOC to extend the 3,000 hour life limit imposed by the AD to 4,500 hours.

I don't expect the FAA to do the right thing and rescind the AD, because that would be tantamount to admitting they made a mistake in the first place. Not very likely in the bureaucracy we deal with.

[Stephen Damon]

That's why some Twin Larks can fly?

[cliff...@gmail.com]

I guess that is true. A friend (Duane Sprague) in Aguila has a Lark Is28 B2 that he imported as Experimental and he says is not life limited. That's why he did it.

[C-FFKQ (42)]

In Canada, an aircraft may be put into "Owner Maintenance" category. The data plate is "X"-d out and warning stickers are put in the aircraft. This is a one-way exercise and must be conducted while the aircraft is still otherwise legal to fly. One downside is that it cannot be flown in the US.

I part-own a Twin Lark that was put into Owner Maintenance just before it hit the 35 year life expiry.

[ifee...@hotmail.com]

About the Pegase, the FAA Type Certificate includes this:

"Section 5 of the CENTRAIR Maintenance Manual, titled "Airworthiness Limitations", is FAA-approved and it specifies mandatory replacement times, structural inspection intervals, and related structural inspection procedures. These airworthiness limitations may not be changed without F.A.A. approval"

So... if the manufacturer followed the usual European procedure of first publishing the manual with a low airframe lifetime (e.g. my ASW-15 started out with a 3000 hour airframe life in the manual) and then extending it by stages with a revision to the manual those extensions don't override the original manual specified airframe life limits unless also accompanied by an A.D. requiring the manual be updated to the new higher limits. Presumably the TC holder never got the FAA to issue an AD increasing the life? It's a little different here in Canada as any AD issued by the authority under which original certification was obtained is automatically applied under Transport Canada too so for my glider the LBA AD's about increased service life were legally binding on my Canadian registered glider without needing any other action by Tranport Canada. That's why all our single seat Grobs got their spar pins replaced years before it was finally required in the U.S.

[Mark628CA]

ifee-

Well, no, that's not how the situation really is. The Pegase 101A (and the B, C and AP models) are certificated in Europe with no life limit, as long as the glider continues to pass the mandatory five year or 3,000 hour inspection as stated in the POH and Maintenance Manual. Section 5.1 of the Maintenance Manual has nine pages of inspection procedures to be performed AFTER 3,000 of airtime. The preceding page, 5.01, which only appears in the US version of the manual, states that "The structure life limits is 3,000 hr" (sic). It seems reasonable that, if on the very next page that the manufacturer begins to lay out a procedure for an inspection to be performed AFTER 3,000 hours that their intent was not to ground the aircraft at 3,000 hours.

We have tried to get any information about the questionable Page 5.01 and how it was included through a Freedom Of Information Act (FOIA) petition, but the results were 42 pages of redacted (blacked out) garbage. An appeal resulted in 14 pages of "released" information- none of which was even remotely associated with the original request, i.e. how the page appeared and who was responsible for its inclusion in ONLY the US Maintenance Manual. So much for "The most transparent Government," according to out current President's decree upon his election.

In Europe (and Canada), the manufacturer's original intent of a lifetime based on repeated 3,000 hour inspections is in force. There are Pegase gliders in France with over 8,000 hours of airtime, and over 200 out of a fleet of 400 with over 3,000 hours. It is only in the US that the FAA (actually one guy) decided that Page 5.01 meant that the manufacturer really didn't mean that the 3,000 hour inspection procedure meant anything. Thus AD 2005-24-01 told Pegase owners to cross out all reference to the 3,000 hour inspection and turn the aircraft into a lawn ornament or sell it overseas when it hit 3,000 hours.

After a long battle, the FAA issued an AMOC (Alternative Means Of Compliance) that instructs Pegase owners to ignore AD 2005-24-01 and perform the inspection.

So now I have two documents from the all-knowing, all-seeing OZ- I mean FAA, that contradict each other. At least I can continue to fly my glider, but this is a case of bureaucratic BS at it's worst. Well, maybe not the worst, but it's right up there with what we have come to expect from our "public servants" in the US.

Sorry about the rant, but this is still a thorn in my side. I hate being lied to and screwed over by a bunch of know-nothing bureaucrats that only protect their bad decisions instead of just saying, "Sorry. My bad. I'll fix it."

[Mark628CA]

For more information about the Pegase life limit AD 2005-24-01 and our efforts to combat it, see www.savethepegasus.org for the history of the AD. Since the AMOC was issued, the website has not been updated, but the preceding action and our research is well documented.