cracked prop repair

[Sonerai13]

Help me out here, how does the FAA know which prop my plane is supposed to have?

The propeller is listed on the Application for Airworthiness Certificate (FAA Form 8130-6, block 1, items 9 and 10). I went through a bunch of back and forth with the FAA a few years ago concerning airplanes that were being raced at Reno. The racers are always looking for the "edge" and change props frequently. But many of them didn't have the proper records to record the changes. This is not something that would be caught on a "ramp check" necessarily, but if the FAA ever decided to look at your airplane in detail, it's one more thing they can try to find that's not right. So if you change props without following the proper procedure, you do so at your own peril.

FAA at the HQ level told me that any propeller change other than a direct replacement of the exact same make/model is considered a "major change". FSDO inspectors in the field don't always see it that way. So if your FSDO tells you it's not, get that response in writing so you can prove that you checked.

[kevinh]

Help me out here, how does the FAA know which prop my plane is supposed to have? ... How does one specify it if they built the prop themselves?

The FAA doesn't know this. However, if you ever had some sort of incident you or others might make statements on past maintenance etc... It is possibly a major change (see this http://www.vansairforce.com/community/showthread.php?t=81212). So even if the FAA doesn't 'know' about some change you may still be required to tell them (at least to get the email that says 'no problem').

Putting a plane back into phase 1 and then signing it off again after the test period isn't really that painful.

[fastj22]

Help me out here, how does the FAA know which prop my plane is supposed to have?

The propeller is listed on the Application for Airworthiness Certificate (FAA Form 8130-6, block 1, items 9 and 10). I went through a bunch of back and forth with the FAA a few years ago concerning airplanes that were being raced at Reno. The racers are always looking for the "edge" and change props frequently. But many of them didn't have the proper records to record the changes. This is not something that would be caught on a "ramp check" necessarily, but if the FAA ever decided to look at your airplane in detail, it's one more thing they can try to find that's not right. So if you change props without following the proper procedure, you do so at your own peril.

FAA at the HQ level told me that any propeller change other than a direct replacement of the exact same make/model is considered a "major change". FSDO inspectors in the field don't always see it that way. So if your FSDO tells you it's not, get that response in writing so you can prove that you checked.

Thanks, interesting.
When I converted from nose to tail dragger, I called the FSDO and they told me to put it back in Phase 1 for 5 hours. Makes sense, however I didn't get written confirmation. Just complied in my logs. There is no entry on the form for that configuration. But changing from a Sensenich to a Prince might get you violated if you don't have a paper trail? That's insane. Oh well, it is what it is.

[Johns]

Hi guys, just got off the phone with the fsdo and he told me the prop change had to be done by A+P seeing I don't have a repairman certificate. I didn't think this was the case. Thought I could do it myself. what do you think?
John

[MichaelFarley56]

To the best of my knowledge, modifications and alterations on an Experimental can be performed by anyone. The only time you need a Repairman's Certificate (or an A&P) is when you're signing off the yearly Condition Inspection.

You should be able to switch props, engines, etc. all you want (of course making sure you follow your Operating Limitations about a major change).

Sounds like your FSDO isn't sure about the rules governing Experimentals!

[GordonTurner]

I don't have time to go look this up right now, hopefully somebody will step in with reference to the actual rule, but I'm pretty sure the rule is any person can basically do anything to an EAB aircraft, possibly requiring a return to Phase 1 (I think this does, but there's room for interpretation). Only the repairman or an AP can sign off the annual condition inspection.

Gordon, another aviator with an opinion...

[Johns]

Found this,


I am going to buy a used homebuilt, what work can I perform myself?
FAR Part 43 specifically states that the rules of that part do not apply to experimental, amateur-built aircraft. Therefore, any work (not just maintenance) on an experimental aircraft can be performed virtually by anyone regardless of credentials. (This does not apply to the condition inspection). Let common sense be your guide as to what maintenance you conduct yourself.

Maybe I should talk to someone else at the FSDO.
John

[radfordc]

Once again you've shown that possibly the worst thing you can do is ask the FAA for "guidance". If they don't know the answer they will gladly make one up for you.

[Sonerai13]

Hi guys, just got off the phone with the fsdo and he told me the prop change had to be done by A+P seeing I don't have a repairman certificate. I didn't think this was the case. Thought I could do it myself. what do you think?

This is absolutely INCORRECT! There is NO requirement for an A&P to do ANYTHING on an experimental airplane except the condition inspection (if the builder does not hold the repairman certificate). The reference for this is found right at the beginning of FAR Part 43. Part 43 contains the maintenance, repair, and alteration regulations, and the first paragraph, 43.1, addresses applicability. It states (in pertinent part):

(b) This part does not apply to—

(1) Any aircraft for which the FAA has issued an experimental certificate, unless the FAA has previously issued a different kind of airworthiness certificate for that aircraft

Since an amateur-built aircraft has never held other than an experimental certificate, this regulation states that Part 43 does not apply. Thus, ANY requirement for a certificated mechanic to perform maintenance, repair, or alteration does not apply to the amateur-built aircraft. The requirement that the person performing the condition inspection hold a repairman or A&P certificate is found in the aircraft's operating limitations, not the regulations themselves.

Your FSDO people need some education. I suggest that you talk to the maintenance department supervisor, or the FSDO manager and get this cleared up so that you (and other homebuilt aircraft owners) don't have problems in the future. If you get resistance at the management level of the FSDO, contact the EAA Government Relations department and get them on it to get this straightened up.