Straight answer from FSDO

[MauleSkinner]

I'd like to ask them whether being deliberately obtuse and hypertechnical advance the discussion.

Hyper technical? I would disagree. Aviation is full of technical terminology that has very specific meaning. If you want a question about a specific thing answered, you need to use the correct terminology...using the wrong terminology can easily result in confusion, and in some cases (not normally cases pertaining to Internet opinions ) personal injury or death.

Obtuse? Well, Tom's been around a long time...he may not be as limber as he used to be, so it's entirely possible that he can't fold himself into an acute angle, which would probably then make him obtuse.

 

[Tom-D]

Hyper technical? I would disagree. Aviation is full of technical terminology that has very specific meaning. If you want a question about a specific thing answered, you need to use the correct terminology...using the wrong terminology can easily result in confusion, and in some cases (not normally cases pertaining to Internet opinions ) personal injury or death.

Obtuse? Well, Tom's been around a long time...he may not be as limber as he used to be, so it's entirely possible that he can't fold himself into an acute angle, which would probably then make him obtuse.

What did Brian ask in post 31?

Did I answer that question?

This is a case of RTFQ.

 

[Lindberg]

What did Brian ask in post 31?

Did I answer that question?

This is a case of RTFQ.

If I asked, "Can I legally remove the wings from my C150 and replace them with hang-glider wings?" Would you just say, "Yes"? Or would you say, "Yes, you can legally do it, but it wouldn't be airworthy"? Would you understand that I was asking for the later answer?

 

[midlifeflyer]

Nope. Let's not take things too literally. Admin law changes. It changes at the whim of an administrator, and is not backed up by a legislator(s). That was the only point I was trying to make. If you think they are being consistent, and you're ok with the process, I guess I'm ok with that.

Sorry if I read your observation that the Chief Counsel opinions are regularly reversed and are only good the day they are made too literally. Didn't realize you were making up stuff to support a point of view.

 

[midlifeflyer]

1) If you ask here, you will get different opinions, but what people here think doesn't matter

2) Different people at the FSDO will give you different answers, but what they think doesn't matter

3) You can ask the chief counsel and get an opinion, but that opinion doesn't matter.

What does matter is what some unknown FAA guy happens to think on whatever unknown day that person finds out what you are doing. And what happens as a result depends on how that person feels on that particular day. If they have a bee up their butt, even if it turns out what you did was OK, they will find something to nail you with.

So far, anyway, that hasn't been my experience Sure, there are cowboys out there, as in any other enforcement organization. And the agency sometimes uses their power to overreach when they shouldn't. What else is new? Might as well be USA Today talking about General Aviation.

The reason we continue to talk about the Bob Hoover case is precisely because the FAA overreaching it it WAS so exceptional.

 

[Capt. Geoffrey Thorpe]

No, it was may a licensed private pilot not a CFI let a unlicensed person (his kid) or anyone else fly the plane under his supervision.

Don't forget: and can he/she/it log the time?

 

[docmirror]

Sorry if I read your observation that the Chief Counsel opinions are regularly reversed and are only good the day they are made too literally. Didn't realize you were making up stuff to support a point of view.

No apology needed. The fact is, a reversal between the FSDO and the chief counsel office can be years, months, or even a day. When admin lais w made up as you go, there's no reason it can be reversed every hour if they want. Chief counsel <> judge. And to get a ruling reversed, I"m sure if I looked I could find one that went into the fed case law and find one if I was paid for the research.

 

[Tom-D]

If I asked, "Can I legally remove the wings from my C150 and replace them with hang-glider wings?" Would you just say, "Yes"? Or would you say, "Yes, you can legally do it, but it wouldn't be airworthy"? Would you understand that I was asking for the later answer?

I would have told ya, no, they won't fit.
Transponders are routinely removed and replaced by their owners or A&Ps then flown to a facility for testing.

Every body logs what they did.

But your question didn't ask "can I do it legally".

If your going to ask a question, ask the right question.

 

[brien23]

How do you verify
91.411

(3) Following installation or maintenance on the automatic pressure altitude reporting system of the ATC transponder where data correspondence error could be introduced, the integrated system has been tested, inspected, and found to comply with paragraph (c), appendix E, of part 43 of this chapter.



Appendix E Paragraph C


(c) Automatic Pressure Altitude Reporting Equipment and ATC Transponder System Integration Test. The test must be conducted by an appropriately rated person under the conditions specified in paragraph (a). Measure the automatic pressure altitude at the output of the installed ATC transponder when interrogated on Mode C at a sufficient number of test points to ensure that the altitude reporting equipment, altimeters, and ATC transponders perform their intended functions as installed in the aircraft. The difference between the automatic reporting output and the altitude displayed at the altimeter shall not exceed 125 feet.

What does that have to do with the transponder. From what you say "ATC transponder where data correspondence error could be introduced, " if you got into the static system that could affect altitude reporting equipment you would have to retest the encoder system all of it's range from the ground to operating altitude. And anytime you changed the altimeter, airspeed ind, or even washed the aircraft and ran a rag over the static port as something could have gotten in their. Get real nobody does that and you assumption that removing and replacing the transponder requires the same is just as bad.

 

[Everskyward]

What did Brian ask in post 31?

Did I answer that question?

This is a case of RTFQ.

You wrote "sign off what you did" which is pretty vague. What did you do?

 

[SkyDog58]

A bench check of an LRU does not guarantee that the entire installed system will function normally after the LRU is installed. That is the purpose of a post installation operational/functional test.

Of course any A&P knows that or at least should know that. By signing off the install only and not mentioning an ops check, an A&P is making no assertion as to its operational status unless the maintenance manual reference he uses for the signoff includes the ops check in the R&R instruction. In that case, it could be interpreted by anyone reading the log entry that the ops check was done and that the sign off qualifies as a return to service statement. It is advisable in that case for a log entry for an install only to include verbiage that the operational test especially FAR driven ones are still needed. Adding such verbiage to log entries is a fairly common practice.

In my opinion, making an install only type of sign off without any statement regarding the status of the ops check is inadvisable and possibly even negligent.

Yes, I know that the owner/operator is ultimately responsible for airworthiness of his aircraft and should be able to ascertain the status of the aircraft by reviewing log entries but I also believe that the A&P should do his best to make sure that those log entries make the status absolutely clear. We should not leave trap doors for pilots to fall into.

 

[midlifeflyer]

Don't forget: and can he/she/it log the time?

...speaking of long term consistency in Chief Counsel interpretations (more than 35 years so far).