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Hangar Flying / VGs & Major change
« on: February 22, 2006, 08:00:53 PM »
Drew,
Oh brother?
What stipulates that addition of VGs on a primary flight surface would be, or not be, a Major change? (Answer to this a bit later...)
My T/C advice to Dave was based on:
1. Older Ops Limitations
2. Definition of Major change
3. My 20 years as an engineer in the airplane biz (currently a Certification Engineer - yes, Part 25 is bigger and nastier, but Part 21 applies all around). I do airplane Certification & Major/Minor Determinations for a living these days.
The approach I suggested to Dave was conservative. Addition of VGs could easily be determined to be a Major change, as they can be shown to have an appreciable effect (Appreciable, meaning measurable, for simplicity's sake) on the performance and/or handling characteristics of the airplane. Dave's operating limitations were of the "older " variety (circa 1988), and thus required him to contact FSDO. A prudent thing to do, when in doubt, especially for those who did not build their airplane. The Bill Davenport incident should continue to be a reminder to all operators of experimental homebuilts regarding adherence to Ops Limitations. Sorry, but playing below the table (i.e. not following your Ops Limitations with respect to making changes to the airplane) is something that can only work against us. Knowing the the requirements of your airplane's operating limitations is paramount. To be ignorant of them, or worse, to dismiss them, is bad ju-ju.
Now then, as I counseled Dave, not all FSDOs are created equal. My put to him is that he needed to find out what his local FSDO would say, based on his situation. I also gave him some talking points to better poise him for dealing with the FSDO, regarding the VG installation. In the end, the FSDO called "Minor", and all is kosher. I certainly would not dare do battle with the FAA and tell them that I was still convinced the VGs constituted a "Major", after such a ruling (unless I got paid for it, like in my day job)... Other FSDOs could easily say otherwise (if only for an excuse to get some of the inspectors out of the office and looking at some real hardware).
"Shopping for FSDOs" is possible, but as things progess in the FAA, such a practice will become less and less possible. There are continuing efforts in the FAA regarding what is called "harmonization" - this, driven by the need to make the world's skies a more level playing field, with respect to the various regulatory agencies of the world, and their respective regulations. This will have a trickle-down effect within the FAA. I have already seen more standarization between two different Aircraft Certification Offices in the past year, for example. Fortunately for you FSDO shoppers, this is still a way's out.
Dave has a nice set of test flight parameters detailed by a competent EAA Flight Advisor, in order to test his VG installation in a safe manner.
Cheers,
-Joe Person
EAA Tech Counselor 4418
VariEze N79JN
Bothell, WA (KPAE)
Oh brother?

What stipulates that addition of VGs on a primary flight surface would be, or not be, a Major change? (Answer to this a bit later...)
My T/C advice to Dave was based on:
1. Older Ops Limitations
2. Definition of Major change
3. My 20 years as an engineer in the airplane biz (currently a Certification Engineer - yes, Part 25 is bigger and nastier, but Part 21 applies all around). I do airplane Certification & Major/Minor Determinations for a living these days.
The approach I suggested to Dave was conservative. Addition of VGs could easily be determined to be a Major change, as they can be shown to have an appreciable effect (Appreciable, meaning measurable, for simplicity's sake) on the performance and/or handling characteristics of the airplane. Dave's operating limitations were of the "older " variety (circa 1988), and thus required him to contact FSDO. A prudent thing to do, when in doubt, especially for those who did not build their airplane. The Bill Davenport incident should continue to be a reminder to all operators of experimental homebuilts regarding adherence to Ops Limitations. Sorry, but playing below the table (i.e. not following your Ops Limitations with respect to making changes to the airplane) is something that can only work against us. Knowing the the requirements of your airplane's operating limitations is paramount. To be ignorant of them, or worse, to dismiss them, is bad ju-ju.
Now then, as I counseled Dave, not all FSDOs are created equal. My put to him is that he needed to find out what his local FSDO would say, based on his situation. I also gave him some talking points to better poise him for dealing with the FSDO, regarding the VG installation. In the end, the FSDO called "Minor", and all is kosher. I certainly would not dare do battle with the FAA and tell them that I was still convinced the VGs constituted a "Major", after such a ruling (unless I got paid for it, like in my day job)... Other FSDOs could easily say otherwise (if only for an excuse to get some of the inspectors out of the office and looking at some real hardware).
"Shopping for FSDOs" is possible, but as things progess in the FAA, such a practice will become less and less possible. There are continuing efforts in the FAA regarding what is called "harmonization" - this, driven by the need to make the world's skies a more level playing field, with respect to the various regulatory agencies of the world, and their respective regulations. This will have a trickle-down effect within the FAA. I have already seen more standarization between two different Aircraft Certification Offices in the past year, for example. Fortunately for you FSDO shoppers, this is still a way's out.
Dave has a nice set of test flight parameters detailed by a competent EAA Flight Advisor, in order to test his VG installation in a safe manner.
Cheers,
-Joe Person
EAA Tech Counselor 4418
VariEze N79JN
Bothell, WA (KPAE)