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Thread: Interesting article

  1. #1
    S2D's Avatar
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    Interesting article

    Just got my copy of Montana and the Sky today and found a very interesting article.



    INOPERATIVE EQUIPMENT
    WHAT DO I DO?
    You just bought a new airplane and you have gone to
    pick it up. On the way home, you were checking out
    all the equipment in the panel and you realized the
    Automatic Direction Finder (ADF) won’t tune to a local
    AM radio station and play your favorite music. You
    continue to your next fuel stop while thinking that you
    really would just like to remove this ADF, and
    everything else for that matter, and install a new glass
    cockpit after a few summers of flying it like it is.
    Safely on the ground at your fuel stop, you reviewed a
    few regulations and documents pertaining to required
    equipment and inoperative equipment such as FAR
    91.213(d). You’ve determined that this ADF is not
    required for the rest of your trip home, since you are
    flying under Part 91.
    Now that you know you can continue your trip home
    legally, and safely, you deactivate your ADF by pulling the circuit breaker, putting a collar on it and placarding the ADF
    “inoperative.” Once established in cruise on the second leg of your trip home you start to think about how long you can leave
    this ADF alone as placarded “inoperative.” You start to think, “Do I have to have this ADF repaired, replaced, removed at the
    next annual, or can I leave it alone until my panel upgrade?”
    You are not alone with these thoughts, especially considering the age of the average general aviation aircraft is more than 30
    years old. In fact, earlier in 2018 the FAA reviewed a letter of interpretation on this very subject a second time and changed
    positions on how this action is to be executed.FAR 91.405(c)
    says that inoperative equipment under 91.213(d)(2) must be “repaired, replaced, removed, or inspected at the
    next required inspection.” The first legal interpretation addressed whether an aircraft could continue to be flown “indefinitely”
    with inoperative equipment installed. “No!” In other words, it was not legal to reevaluate the inoperative equipment at the next
    inspection to confirm that it was still inoperative, safe and could continue on.
    Recently, the FAA revisited the rule and reviewed the legal interpretation a second time, and lucky for you and your ADF, they
    changed their answer. There was much debate over the interpretation of this regulation sparking the second review.
    In order to answer this question, the FAA went back to the original rulemaking relying on law making notes and the preamble
    from the late 1980s. The second interpretation states that if the inoperative equipment is not repaired, replaced, or removed at
    the next required inspection, (most often the annual inspection, in the case of light-general aviation aircraft) the inoperative item
    must be inspected again at that inspection in order to ensure that the discrepancy will not have an adverse effect on the safe
    operation of the aircraft.” It goes on to explain that operations with inoperative equipment could continue “indefinitely” if the
    reevaluation is appropriately conducted and logged in the aircraft’s permanent records each time the aircraft undergoes a
    required inspection.
    So, as long as the inoperative ADF remains appropriately placarded, reassessed at required inspections and documented in
    the logs, you can continue to fly legally and safely, albeit without listening to your favorite AM radio stations, until you
    finally pull the trigger on the panel upgrade.


    I may be wrong but that probably won't stop me from arguing about it.
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  2. #2
    S2D's Avatar
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    What's interesting to me, is not anything to do with instruments, but the FAA interpretation of regulations, and the question "who changed the interpretation in the first place ??

    How many times have we argued about a regulation and what the FAA now says it means and we take for granted they are always right and go on without ever questioning them.
    I'm glad they revisited this regulation cause obviously I've been doing it wrong since someone decided to reinterpret it.
    Now what about the Airport Surface Area issue and the 337 removal issue and so many others ??
    I may be wrong but that probably won't stop me from arguing about it.
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  3. #3
    mvivion's Avatar
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    Good find Brian. That regulation has been so differently interpreted by FAA types in past, maybe this’ll sort it out some......yeah, right.

    i was told “definitively” by a maintenance inspector that an inoperative radio had to be completely removed, and that pulling a breaker and collaring it wasn’t legal. Mechanic basically told him to bugger off.

    thats the real problem, though: every inspector has an opinion, and everyone else’s opinion is wrong.

    MTV
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  4. #4
    wireweinie's Avatar
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    Quote Originally Posted by mvivion View Post

    thats the real problem, though: every inspector has an opinion, and everyone else’s opinion is wrong.

    MTV
    That's what the FAR's are supposed to be about; removing the opinion and having a fixed answer on tap for inspectors/IA's/mechanics/owners to refer to. Amazing how many times over the years that we've heard 'Well, I think . . .' Sorry, but I don't really care what someone 'thinks', show me the reg. Contrary to what you might hear, most of these regs are pretty straight forward.

    Also, I think I like your mechanic, lol.

    Web
    Life's tough . . . wear a cup.
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  5. #5
    SJ's Avatar
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    I've been trying to buy a good ADF....

    But seriously, they used to INOP ADF's at a flight school I worked at just so they would have have to do ADF tracking or approaches on checkrides...

    sj
    "Often Mistaken, but Never in Doubt"
    ------------------------------------------

  6. #6
    Steve Pierce's Avatar
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    Pretty interesting accident report.
    https://www.ntsb.gov/_layouts/ntsb.a...15LA233&akey=1
    And pictures.
    https://dms.ntsb.gov/public/58500-58...692/591049.pdf
    Proper tool for the job, the T-118 timing pin bends if you turn the mag while it is installed. Still don't know why the engine would make enough power on one mag but I guess it had too much fuel at take off power for one mag to fire?
    Steve Pierce

    Everybody is ignorant, only on different subjects.
    Will Rogers
    Thanks STaylor2, RVBottomly thanked for this post

  7. #7
    skywagon8a's Avatar
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    Quote Originally Posted by Steve Pierce View Post
    Notice the extensive unnecessary damage done while removing the 206 from the ditch.
    N1PA

  8. #8
    Steve Pierce's Avatar
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    Quote Originally Posted by skywagon8a View Post
    Notice the extensive unnecessary damage done while removing the 206 from the ditch.
    Yep, seen that way too many times unfortunately.
    Steve Pierce

    Everybody is ignorant, only on different subjects.
    Will Rogers

  9. #9
    kcabpilot's Avatar
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    Quote Originally Posted by wireweinie View Post
    That's what the FAR's are supposed to be about; removing the opinion and having a fixed answer on tap for inspectors/IA's/mechanics/owners to refer to...
    ”supposed to be about” but everything written is subject to interpretation and the more complex the issue the more susceptible it is to varying interpretations. There are also overlaps and interconnections between specific regulations that may, despite all efforts, seem to be at odds with each other. The bottom line however is that there is a system and a hierarchy. An A&P is licensed and has the authority to make a decision and affix his signature to it. He or she can certainly go “up the chain” and ask for clarification and enough queries will probably produce a “clarification” statement which of course is still just another interpretation. In the end, if the book is signed, it’s really nobody’s business to come along afterwards and reinterpret the conclusions but unfortunately not everyone sees it that way and I don’t mean to imply that a mechanic can’t make a mistake but when it comes down to splitting hairs a lot of times egos get pushy.
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    n40ff's Avatar
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    If inop and you are not going to repair, why not remove it? Just extra weight.

    Jack

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    mvivion's Avatar
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    Quote Originally Posted by kcabpilot View Post
    ”supposed to be about” but everything written is subject to interpretation and the more complex the issue the more susceptible it is to varying interpretations. There are also overlaps and interconnections between specific regulations that may, despite all efforts, seem to be at odds with each other. The bottom line however is that there is a system and a hierarchy. An A&P is licensed and has the authority to make a decision and affix his signature to it. He or she can certainly go “up the chain” and ask for clarification and enough queries will probably produce a “clarification” statement which of course is still just another interpretation. In the end, if the book is signed, it’s really nobody’s business to come along afterwards and reinterpret the conclusions but unfortunately not everyone sees it that way and I don’t mean to imply that a mechanic can’t make a mistake but when it comes down to splitting hairs a lot of times egos get pushy.
    I concur with this. The exception (sorta) is an interpretation from the Chief Counsel's office. Once one of those is issued, it's a little harder to "interpret" different meanings.

    MTV

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    Quote Originally Posted by n40ff View Post
    If inop and you are not going to repair, why not remove it? Just extra weight.

    Jack
    Makes sense. Requires an updated W&B.


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    Quote Originally Posted by Troy Hamon View Post
    Makes sense. Requires an updated W&B.


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    Which requires a mechanic......

    MTV

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    Quote Originally Posted by mvivion View Post
    Which requires a mechanic......

    MTV
    Yep. Which I think is one of the reasons why people often avoid doing it, and just put a placard on for a decade or two...


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