Fuel Valves, Wing Tips, And You

There has been much discussion about Home Depot fuel valves, homebrew
wingtips, and the like. There has been much discussion about what is and
what is not allowed by the regulations.

Finally, somebody at the highest echelons of the FAA in Washington is trying
to put some sense back in the regulations. Read the Notice Of Proposed
Rulemaking here http://makeashorterlink.com/?S1075282A as to what Mr.
O'Brien is trying to do.

Understand, what he is saying is that he wants to make ACCEPTABLE data
APPROVED data without going through the field approval process. Not
ACCEPTED data, ACCEPTABLE data. What remains to be seen (and I hope that
the installing mechanic may choose what is acceptable) is who defines
acceptable.

If you want to change how the maintenance game is played, now is your
chance. Either comment on this NPRM or forever hold your peace. This is
the most far-reaching maintenance change since 21.303(b)(2) came along as a
modification from the CAR to the FAR.

Jim

In article ,
RST Engineering wrote:
There has been much discussion about Home Depot fuel valves, homebrew
wingtips, and the like. There has been much discussion about what is and
what is not allowed by the regulations.

Finally, somebody at the highest echelons of the FAA in Washington is trying
to put some sense back in the regulations. Read the Notice Of Proposed
Rulemaking here http://makeashorterlink.com/?S1075282A as to what Mr.
O'Brien is trying to do.

Understand, what he is saying is that he wants to make ACCEPTABLE data
APPROVED data without going through the field approval process. Not
ACCEPTED data, ACCEPTABLE data. What remains to be seen (and I hope that
the installing mechanic may choose what is acceptable) is who defines
acceptable.

If you want to change how the maintenance game is played, now is your
chance. Either comment on this NPRM or forever hold your peace. This is
the most far-reaching maintenance change since 21.303(b)(2) came along as a
modification from the CAR to the FAR.

Jim,

I read the NPRM, and maybe I just can't see the forest for the trees,
but I don't understand what it's saying. Can you give us some
background on what "acceptable" vs. "accepted" data is all about and
why it matters?

I also notice that this only applies to fixed gear under 200 HP. This
seems like an odd distinction.

Federal Aviation Administration
Aircraft Maintenance Division
William O'Brien
Washington DC

Dear Mr. O'Brien

This comment is in reply to your referenced NPRM for aircraft maintenance
requirements. My general comment is that this is the best piece of proposed
regulation to come out of the FAA in my 45 years in the aircraft maintenance
field. It will result in an increased level of safety concomitant with a
reduced workload on local FAA FSDO personnel. This reduced workload will
allow them to concentrate on true safety of flight programs and eliminate
the paperwork blizzard generated by minor maintenance on light single engine
aircraft.

There are a couple of items that will make the proposal internally
consistent with itself. I repeat here the seminal paragraph of the entire
NPRM:

: "The FAA plans to include a new policy that would allow mechanics
: and repair stations to use acceptable data as approved data for major
: alterations to certain non-pressurized aircraft. The new policy would
: apply to a landplane, seaplane, or floatplane, fixed gear aircraft of
: 6,000 pounds or less maximum gross weight, of 4 seats or less, and with
: a reciprocating engine of 200 horsepower or less."

The proposed 6000 pound max gross limit is reasonable. This encompasses
virtually every nonpressurized single engine aircraft in the fleet.
However, restricting the engine to 200 horsepower eliminates a very large
segment of the fleet, including such popular models as the Beech 35/36
series, all Cessnas from the 182 through the 210, a large segment of the
Piper mark, and others. Instead of encompassing these aging aircraft and
allowing an increased level of proper maintenance on them, it forces them
into what I foresee as a heightened level of restriction on them.

As a less onerous provision, the restriction to 4 seats or less eliminates
such aircraft as the Cherokee 6, the 182-210 Cessnas with the permanently
mounted "kiddie seat", and other aircraft that have 5 or 6 seats.

Therefore, I propose that you eliminate the horsepower restriction (or at
least raise it to encompass the vast majority of the fleet) and raise the
restriction on seats to 6.

Again, my compliments on a particularly good proposed regulation.

Jim Weir
A&P, IA
CFI, CGI, Airplane and Glider






If you want to change how the maintenance game is played, now is your
chance. Either comment on this NPRM or forever hold your peace.

Thanks for the heads up. This is the year 2005... its about time some
sense it being injected into a few of these "maintenance" regs...

I'm all for required inspections and so forth, but people shouldn't
have to be scrounging around for parts like they do... or not replacing
older parts with otherwise "better" and modern parts because they haven't
been blessed by Pope Pious XII (and since he's long passed on there will be no
more blessings... etc. etc.)


RST Engineering wrote:
There has been much discussion about Home Depot fuel valves, homebrew
wingtips, and the like. There has been much discussion about what is and
what is not allowed by the regulations.

Finally, somebody at the highest echelons of the FAA in Washington is trying
to put some sense back in the regulations. Read the Notice Of Proposed
Rulemaking here http://makeashorterlink.com/?S1075282A as to what Mr.
O'Brien is trying to do.

Understand, what he is saying is that he wants to make ACCEPTABLE data
APPROVED data without going through the field approval process. Not
ACCEPTED data, ACCEPTABLE data. What remains to be seen (and I hope that
the installing mechanic may choose what is acceptable) is who defines
acceptable.

If you want to change how the maintenance game is played, now is your
chance. Either comment on this NPRM or forever hold your peace. This is
the most far-reaching maintenance change since 21.303(b)(2) came along as a
modification from the CAR to the FAR.

Jim

The King may propose to free the serfs, but the Dukes and Princes will
not take kindly to usurpation of their authority...

Expect to see the Dukes and Princes looking for a mechanic to hang who
had the temerity to claim that the data is acceptable to him... The
FSDO's will be circling the wagons and the local mechanics will not be
clamoring for a chance to charge the wagons, waving their repair
station license in the air... It will require real leadership from OK
City to force the inspectors to embrace this brave new reg..

Denny

Federal Aviation Administration
Aircraft Maintenance Division
William O'Brien
Washington DC

Dear Mr. O'Brien

This comment is in reply to your referenced NPRM for aircraft maintenance
requirements. I want to congratulate the FAA for recognizing the need to
simplify repairs and alterations on smaller GA aircraft, by acknowledging
the
responsibility and effort of we who hold an Inspection Authorization
certificate,
thus lightening the load on local FSDO's for approval of what could under
most
circumstances be considered "minor" repair and/or alterations as per AC
43.13, albeit
maintenance restricted to authorized and duly licensed persons (i.e. A&P's,
IA's).
With over 22 years of experience in General Aviation maintenance as an A&P,
and
more recently IA, I consider this NPRM a POSITIVE step in making G.A. safer
and easier to maintain, by helping eliminate illicit maintenance by those
who "sidestep"
the regulations due to perceived restrictive, costly, and time consuming
issues
relating to an aging General Aviation fleet.

There are a couple of items that will make the proposal internally
consistent with itself. I repeat here the seminal paragraph of the entire
NPRM:

: "The FAA plans to include a new policy that would allow mechanics
: and repair stations to use acceptable data as approved data for major
: alterations to certain non-pressurized aircraft. The new policy would
: apply to a landplane, seaplane, or floatplane, fixed gear aircraft of
: 6,000 pounds or less maximum gross weight, of 4 seats or less, and with
: a reciprocating engine of 200 horsepower or less."

I consider the restrictions to applicable aircraft very reasonable, however
the
power restriction of 200 HP should be reconsidered to 300 HP limit, as this
would include a very large number of aircraft essentially the same in
weight, size,
speed, and complexity as the sub 200 HP group, to benefit from this new rule
if put in effect. As a technitian who has many many thousands of hours
flying
and maintaining aircraft in bush flying operations, I'd really like to see
some bushplane
favorites included in this benefit, simply for reasons of field repairs in
remote areas,
since they see a heavy toll in wear due to the nature of their labour,
aircraft such as the
C182, C180, C185, C205, older C210, as well as several other models of Beech
and
Piper manufacture.

Again, my compliments on one of the best rule proposals in favour of GA
aircraft maintenance in
over 20 years.

Jerry D. Witt Jr.
A&P, IA since 1978
3,000 Hours + PPI, SEL Airplane