Owner maintenance on a Non-type certified aircraft

[Etienne]

Hi

I would like to find out about doing maintenance work on my own aircraft, once it is registered in Canada.

The aircraft started off as a wreck after being flown into a tree after a stall just after take-off. There was virtually nothing left but a bent fuselage and very badly damaged wings.

The whole airframe was stripped down, pulled straight (and patched where necessary), powder-coated, recovered, and a reconditioned engine attached.

The wings were rebuilt, using fresh ribs replacing the damaged ones, and recovered in Seconite, with rib-stitching.

There were 3 of us who did the work, my dad, uncle and I.

My dad has since passed away, and my uncle will stay behind here in South Africa, so it will just be me, and it has been like this for the last 5 years.

Until the end of last year, I was allowed to do any work on the aircraft, as long as after any major modifications it was inspected by a person authorised to do inspections by our Civil Aviation Authority (an AP). Since 1st Jan, a new set of laws have come into effect which has change this quite a bit... Now I am only allowed to do maintenance under direct supervision from an AP or AME.

Also, what are the laws regarding the operation of a timex engine ( more than 12 years, but less than 300hrs SMOH)?

Thanks
Etienne

[Hedley]

1) I would try very very hard to import this aircraft
into Canada as a homebuilt. Sounds like you made
51% of it. It doesn't sound like it would be easy to
import it as a certified aircraft (then move it to owner
maintenance). I have no clue if you could import
it directly to Owner Maintenance - if you could, it
sounds like an interesting option, except that you
can't fly Owner Maintenance south of the border
(ie no trip to OSH). Homebuilt has less restriction
because of reciprocity agreement with FAA.

2) engine TBO does not apply to private piston
aircraft engines as per CAR 625 app C. Feel free
to run it to 10,000 hours in the next 100
years without officially overhauling it:

http://www.tc.gc.ca/CivilAviation/Regse ... /a625c.htm

Information Note:
No hard time, including calendar time, between overhauls need be observed in the case of small aircraft reciprocating engines in non-commercial private operation.

[Etienne]

Definitely sounds like homebuilt is the way! Seeing as 3 of us did the work, yet I'm the only one who's currently looking after it, does it still fall into the 51% category? (Seeing as I could only have built a maximum of 33% personally!)

It was definitely not 49% factory built, so I guess so... It's all about the semantics, isn't it.

[Hedley]

It's a homebuilt. Start reading here:

http://www.tc.gc.ca/OntarioRegion/civil ... mateur.htm

and esp this:

http://www.tc.gc.ca/OntarioRegion/civil ... cklist.doc

[Jungle Jim]

You should check on that before you bring it to Canada. I believe that just recently TC put a stop on rebuilding a type certificated aircraft and registering it in the amateur built catogory. They even went to the point of not allowing any planes with certified wings or major components to be used in an amateur built plane. Gary Wolfe of the RAA recently sent out a message about this. If the letter of intent has been filed it will be allowed but no new ones will be allowed.

Jim

[l_reason]

You should check on that before you bring it to Canada. I believe that just recently TC put a stop on rebuilding a type certificated aircraft and registering it in the amateur built catogory. They even went to the point of not allowing any planes with certified wings or major components to be used in an amateur built plane. Gary Wolfe of the RAA recently sent out a message about this. If the letter of intent has been filed it will be allowed but no new ones will be allowed.

Jim

I wouldn't be so sure about that, I know of a C-182 thats was just (in December) moved over to armature built. This 182 is going to be re engined (Chev Z-07, V8) and fresh glass dash, and some canard mod. TC wants to make sure the aircraft meets the 51% rule and is stopping the guys that are only doing a couple minor mods that don't ad up to 51%.

[Etienne]

Thankyou... Hedley, are you an aviation lawyer or something? You know these laws backwards!

What's a fuel-flow report? Just a table of fuel flows under different power settings?

Seems fairly straight forward. Just forms and fees...

[Hedley]

Hedley, are you an aviation lawyer or something?

Er, no, I'm just an airshow pilot that's banned for life by
Transport from ever performing at another airshow in
Canada, so now I just fly airshows in other countries.

There aren't many airshow pilots in Canada - less than 10 -
and part of the overhead of being a Canadian airshow pilot
seems to be that you're going to have to spend an awful
lot of time at Tribunal, Tribunal Review, Federal Court and
Federal Court of Appeals, all of which I have represented
myself in.

It has been made painfully clear to me that as a pilot, you
are responsible with complying with every letter of every
word of every sentence of every paragraph of every one
of all of the thousands and thousands of regulations at every
moment, or you will be crucified.

So, you had better know the regulations better than the regulator,
or you're going to run into serious and very expensive legal
trouble sooner or later.

I know that when I stop flying shiny airplanes the attacks
will stop, but until I run out of energy to respond to the
attacks, I will continue to fly.

[Etienne]

My word...

[Bulawrench]

Hey guys,

"Feel free to run it to 10,000 hours in the next 100"

This has got to be one of my biggest pet peeves. There is a reason manufactures' recommend overhaul periods.
In my opinion, running piston engines "on condition" is irresponsible of anyone. Why not just drink a gallon of tequila and go for a drive on the freeway. I have had numerous customers over the past 10 years falling into this trap. Once the engine has gone for overhaul the engine shop was amazed it didn't explode. One customer was even taking children with Cancer up for flights. All to save the might coin. There are many recommendations from manufactures that aren't being done on private and commercial. Owner maintenance is just as much a joke.

[Hedley]

running piston engines "on condition" is irresponsible

Take a deep breath. It's going to be ok. Really.

TBO is a statistical value. My favorite statistic is that a man with
his head in the freezer, and his feet in the stove is on average
comfortable

TBO is not just hours, it's calendar time. A privately operated
aircraft might have only 500 hours on it's engine by the time
the calendar TBO expired.

On the other hand, a frequently-flown engine can often greatly
exceed TBO and still be in very good condition. I once flew a
T-34 in Atlanta, GA that had it's TCM IO-550 run out to 2600
hours. Getting nervous they pulled it for overhaul, and found
that EVERY PART of the engine was within SERVICE LIMITS. Not
new limits, but service limits which is as good as most of us
are going to get at an overhaul anyways. Note that this
engine was not "babied" the way many people like to - it
was run wide open, all the time.

One can either get excited about nonsense, or make a data-
driven decision. The fact is that catastrophic engine mechanical
failure is not a significant cause of aircraft accidents for
privately-flown aircraft.

Most of the time, it's pilot error. If you're truly concerned with
reducing private aircraft accidents, spend your money on what's
broken, IMHO.

[Etienne]

Running it past 10,000 hours would be irresponsible. Not doing boroscopes would be irresponsible. Not doing blow-by's would be irresponsible. But you really think that an engine that has only run 500 hours in 12 years (without long periods of inactivity) needs to be completely overhauled, if all the tests say it's fine?

[Hedley]

I once flew a small, somewhat elderly piston twin that
had one engine with 5500 SMOH. A jug went south,
they changed it. An accessory went bad, they changed
it.

This aircraft flew a LOT, so there were no corrosion
issues from disuse. It was down south, so there
were no cold starts, either, which can really hurt
an engine.

That engine ran a lot better than the engine on the
other side, which had a lot less time SMOH.

[Etienne]

Let me qualify my statement: Running an engine past 10,000hrs without doing boroscope, blow-bys and the like is irresponsible

I don't know...
I'm sure the liability insurance that covers Lycoming comes in to it... Hypothetical: They run an engine and it fails after 40,000hrs. They run another one and it fails at 30,000hrs. A third one fails at 35,000hrs. 100 other engines fail around the 35,000hr mark.

A statistical curve-fitting process shows that the mean life is 35k, and less than 3% fail below 30k, or above 40k.

So to reduce the premiums that they have to pay to their insurers, they say that the expected life is 10,000hrs. Way to the left of the curve, so that the chances of an engine failing within the "expected life time" is minimal.

That's what I'd do anyway if I were Lycoming. It means that they can charge less than their competitors, whilst off-loading the risk of a liability claim at the expense of the owner (remember that when one buys a new engine, 10k hrs sounds like a very long time away, so a MOH isn't considered as part of the expense)... If you're running it past 10k, you're probably still in safe territory, but the chance of a failure are higher, and if it goes it's your problem, so best keep an eye on the blow-bys etc...

[Hornblower]

There is a reason manufactures' recommend overhaul periods.

He's quite right, ... except he doesn't appear to know what the reason is!
Ha ha ha.

[Bulawrench]

Keep em flyin'

[Hornblower]

edited