As regular readers of Club Connector will know, every edition has the thread of a theme that stiches together the articles into a cohesive whole. This month, the theme is based around the notion of “back to school”, where we look at collegiate and high school flying clubs. Stretching the theme just a bit more, we come to the related idea of “get out the books” as we challenge club members to get to know more about the aircraft they fly.
Such regular readers will also know that we changed the Club Connector Safety section some months ago, and we now provide topical material for safety officers to use during their club’s regular meetings. Steve and Drew are safety officers for their respective clubs and are also FAASTeam Safety Representatives. They present modified versions of the WINGS Topic of the Month (ToM) material at their club’s safety meetings and, for good outreach and education, extend invitations to all local pilots. These ToM presentations are then made available to all flying clubs in the new Club Connector Safety section and we highly encourage all safety officers to include this topical material in their club’s regular meetings.
As a related aside, we also developed WINGS for Clubs, where we encourage all flying clubs to follow the FAASTeam WINGS pilot proficiency program. The reasons are simple, proven and provide tangible value:
More information on WINGS for Clubs is available at the end of this article.
The September 2021 FAASTeam Topic of the Month is: Service Bulletins and the Aircraft Owner. This got us thinking…just how much do members really know about their club aircraft?
Perhaps we all know of a self-professed plane whisperer—the club member who, to the bemusement of other members, openly states that they “are as one with the plane”. Okay, if you fly a plane enough, you get to appreciate its idiosyncrasies and quirks, but can you really ever get to know the soul of the machine?
In this month’s QoM, we look at some less-known ways to get better acquainted with the details of your club aircraft, and so be better equipped to recognize, and handle, unusual or emergent situations.
Get Out the Books
The obvious starting point to get to know your plane is the Pilots Operating Handbook (we’ll use the term POH to refer to all ways that an aircraft manufacturer provides operational information to pilots).
Very early on in our training we are taught that there is a POH specific to every N number, and that it must, by regulation (FAR 91.9) be available to the pilot in the airplane. Actually, the regulation (the “O” in ARROW) is broader than the oft misinterpreted “Operators Handbook” as it is more specifically “Operating Limitations”. These limitations certainly include the everything in the POH, but also cover markings, placards, and, importantly, documentation particular to everything that has been added to the plane using Supplementary Type Certificates (STC).
The point here is that the POH you bought online and use at home, even if it happens to be for the correct model and applies to your airplane’s serial number, may not include vital information and limitations about the actual club plane.
Work with your club’s maintenance officer to get the actual plane POH scanned and available to all members. Make sure to include all supplements and STCs. Then work with your safety officer to create a new checkout quiz to include some plane specific questions and introduce it to all existing club members at a fun quiz-night social event. We guarantee that it will get the hangar talkers engaged!
Include things like:
Given that placards and markings are a regulatory requirement (and unreadable/obscured/missing examples may negate airworthiness), trawl through the POH to see what placards and marking are required…and compare with what actually exists. Common ones to go missing or fade beyond readability are those by each fuel filler cap. These should indicate the type of fuel and the capacity of the tank. Things like this should be picked-up at the annual (or 100-hour) inspection, but you can get ahead of any downtime by knowing what to look for and ordering the correct placards. Of course, as placards are a regulatory requirement, make sure the appropriate logbook entries are made when they are changed.
Do you have a personal copy of the airplane’s Type Data Certificate for your standard category aircraft, or Operating Limitations for a special category aircraft, like S-LSA, E-LSA and E-AB?
Probably not…at least not readily available. These make really interesting reading and cover a lot of ground (for example, required placards, CG limits, control surface adjustments…and much more), so take the time to get and study them.
All standard category aircraft (white airworthiness certificate) have a Type Data Certificates (TDC) that can be searched and downloaded, here. Enter the model (for example A152 for a Cessna Aerobat) and see what you get. Many TDC’s cover different models and serial numbers, so pay close attention to the various sections in the document. For example, the TDC for Steve’s Aerobat is number 3A19, which states: “This data sheet which is a part of type certificate No. 3A19, prescribes conditions and limitations under which the product for which the type certificate was issued meets the airworthiness requirements of the Federal Aviation Regulations.” Gosh…now we know!
All special category aircraft (pink airworthiness certificate) have Operating Limitations. Experimental aircraft will have these as part of the per-airplane approval process and so are somewhat at the mercy of the approving Designated Airworthiness Inspector. This allows for differences, in that not all E-AB or E-LSA aircraft of the same make/model will necessarily have the same Operating Limitations. The moral is clear…know your specific aircraft and read the Operating Limitations, as this defines airplane-specific airworthiness conditions.
S-LSAs also have operating limitations as part of the factory build/delivery process. For example, factory-built Van’s RV-12 S-LSAs come with a Pilot’s Operating Handbook that contain Section 2, “Operating Limitations”. This clearly states, for example, that “Flight in IFR/IMC Conditions is Prohibited”. So, even if equipped with a Garmin G3X and autopilot, Van’s is limiting operations to VFR only, even when flown by an instrument-rated (and current) pilot. Section 2 also very clearly states which placards are required to be compliant with the issued airworthiness certificate but be careful as there are separate pages for E-LSA and S-LSA versions of the same model!
There is so much more that could be written about understanding airworthiness limitations for each specific aircraft…but for now, let’s change gears and look at regulatory (or not) service information from the FAA and manufacturers.
Do you, or the club’s maintenance officer, or your A&P, or anyone else for that matter keep an up-to-date library of all airworthiness directives (AD), service bulletins (SB), safety alerts (SA), notifications and letters?
What should aircraft owners (including flying club members), know about these communications from the FAA and manufacturers?
Well, we’re glad you asked, as this is the very topic of the FAASTeam September 2021 Topic of the Month. A copy of the ToM slides that Steve presented to his club are available in this month’s Club Connector Safety section.
Let’s dig into this a bit more.
Firstly, we all should know that the FAA (not manufacturers) issue ADs, and they are mandatory. You’ll need to read the AD itself to determine the timeframe for compliance and if inspections, or work, is required on a regular cadence. Perhaps the most well-known repeating AD is that for Cessna seat rails. This AD stipulates the models affected, what needs to the checked and how, and that it is repeated every 100-hours of operation or every 12-months, whichever occurs first. This is important for flying clubs, since in a correctly operating club, FAR 91.409, the regulation regarding 100-hour inspections, may not be triggered, yet the AD will most definitely have to be complied with, and logged, every 100-hours’ time in service.
You can search for the ADs that affect your aircraft by going the FAA Airworthiness Directives web site. Don’t use the first search area, but rather scroll down to All Current ADs by Make/Model. Many of you will search for Cessna information, so remember that this is now listed under Textron Aviation, Inc.
We suggest that you print out all applicable ADs and keep them in a binder in the hangar, or in a digital binder on your club’s online management tool. If you use such a tool (Steve’s and Drew’s clubs use Flight Circle), ensure that all ADs are added to the maintenance reminders/notifications section, so that members reserving and dispatching aircraft can quickly see if any have expired. There are also more specific tools available to help with maintenance tracking. We haven’t used any of these, but colleagues mention Pilot Partner, Adlog, and WhenYouFly.
Remember, airworthiness is a responsibility of the pilot in command and an AD is most definitely a matter of airworthiness. Trust, but verify!
Service bulletins are issued by manufacturers—aircraft, engines, fuel pumps, avionics, and so on. They are one way that manufacturers (try to) communicate with us about their products defects, modifications, changes, improvements, obsolescence, etc. SBs contain vital information, so don’t get caught in the Part 91 trap, that “SBs don’t apply to me”.
It is true that SBs are not generally mandatory for Part 91 operations, unless accompanied by an AD—SBs called Alert Service Bulletins usually quickly result in an AD, and most likely the AD will state the mandatory force of the AD, but will reference the SB for work, methods, etc. For commercial operations, like those under Part 121 and 135, applicable SBs are very likely to be mandatory. This is another of those all-to-strange situations in aviation…the same SB may be mandatory for one sector and not for another, even though the impacts and risks of non-compliance are the same. It is somehow okay to give Part 91 operations a choice, but not Part 121/135…interesting indeed!
So, the message is clear: Don’t Ignore SBs. In fact, treat them as a learning experience. Something, somewhere happened that persuaded the manufacturer to issue the bulletin, and whilst for sure there will be some liability mitigation (CYA) involved, it is fair to say that they wouldn’t draw attention to a product problem unless there was some clear risk involved. Again, we suggest that you printout all applicable SBs, keep them in a binder…and read them!
Once you have read and understood an SBs, then you can decide if it: a) Applies to your plane; b) Is something you want to do and c) When you intend to do it (immediately, at the next annual, etc.).
Make this an active decision, rather than passively letting it slip from your consciousness. In the case of a club, the maintenance team should be involved in the decision. If the bulletin is complied with, enter the work into the appropriate logbook as “In Accordance With (IAW) Service Bulletin Number 1234”. If you decide not to comply, at least monitor the situation related to the SB during routine maintenance and inspections.
Warning: Non-compliance to an SB may well be cited in an accident report as a contributing factor. Now, given that SBs are not mandatory, perhaps this is more to cast doubt on decision making and judgement rather than suggesting that lack of compliance was a root cause, but the impact to the owner will probably be the same, particularly as it may give an insurance lawyer some ammunition.
There are various “types” of manufacturers communications and again, we advise that you at least read and understand them. You can find SBs on manufacture’s websites. Many type clubs have links to the manufacture’s sites and/or directly list the SBs themselves. Manufacturers will also send information about new SBs to the aircraft’s registered owner. Here is another trap for flying clubs. Is the registered address up to date? If not, you may not be getting information about important SBs, so double check using the FAA N-number search website.
The Case of LSAs
The requirement to comply with SBs is quite different in the case of aircraft with airworthiness certificates in the Light Sport category—that is, S-LSA and E-LSA.
LSA manufacturers conform to ASTN consensus standards which includes the obligation to provide continued airworthiness support, in order for owners to comply with FAR 91.327. Unless there are exceptional circumstances, the FAA does not get involved with this. That is, the FAA does not issue ADs. Nevertheless, the “power” of LSA manufactures is great indeed and so manufactures can—and do—issue mandatory communications, which must be complied with in order maintain airworthiness status.
FAR 91.327 details the need for inspections (annual and possibly 100-hour), who may perform maintenance and inspections, and so on. Indeed, it is this regulation (FAR 91.327(d)) that tells us we must only operate the aircraft in accordance with the aircraft’s operating instructions. FAR 91.327 (b)(4) is also very clear:
(b) No person may operate an aircraft that has a special airworthiness certificate in the light sport category, unless—
(4) The owner or operator complies with each safety directive applicable to the aircraft that corrects an existing unsafe condition.
So, we must treat SBs issued by manufactures relating to S-LSAs, as mandatory. Now, different manufacturers use slightly different terminology when issuing such communications. We know of Safety Alerts (SA), Service Bulletins (SBs), Service Letters, Notifications, and more. Nevertheless, treat them all as not only important, but compulsory. This obviously makes sense from covering all the regulatory bases, but when you consider just how much cheaper LSA parts are, then there’s a sound cost-of-safety argument. A little later, we’ll also suggest a way to reduce the cost of labor for your club’s LSAs.
One good thing about this is that all manufacturers involved in S-LSAs must make their service information readily available. Indeed, top-tier S-LSA and engine manufacturers have everything on their websites. This includes maintenance manuals, service manuals, flight training manuals, operating handbooks, and search areas where you can quickly get a list of all SAs, SBs, etc. As with the case of ADs, we strongly advise you to print out the details of all applicable safety and service information. Do this regularly to keep it up-to-date, and most definitely do it before very annual condition and 100-hour inspection. Your A&P or repairman should of course do this as part of an inspection, but having read them yourself will open up the opportunity for a good discussion with your mechanic.
Steve recently attended a 15-day Light Sport Repairman-Maintenance course at Rainbow Aviation. This excellent 15-day full immersion course consisted of in-depth lectures and fantastic hands-on practical work. Carol and Brian Carpenter are exceptional presenters and hosts, and their new facility in Kingsville, MO, is outstanding. There is so much to say about the course and what was learnt, but here are just three takeaways in the context of this article:
Costs of Compliance
We cannot leave this topic without considering the cost of compliance. For ADs, it is simple as you have to comply, so somehow, you’ll find the funds, even if the club has to imposes a special assessment on all members. This of course affects safety and, importantly the value of the aircraft. Examples in point are the current set of wing spar ADs on various airframes. To be legal, you have to comply with the AD, which also means the plane’s value should be (at least) what it was before the AD. It is rare (but not unheard) that compliance to a particular AD may actually increase the value of an airplane, but it is crystal clear than non-compliance will drastically reduce the value, as the plane is not airworthy. This could be a huge negotiating lever for a buyer, if you try to sell a plane with “open” ADs.
On the other hand, the buyer could be you, and with a good mechanic in the loop, you may be able to pick-up “a bargain” if you are willing to do the work to get the airplane airworthy. Interestingly, in these days of short supply and high demand, this may be the only way for a club to get its next plane, without being tenth in the potential purchaser queue!
Drew’s club did this very thing with the purchase of a gorgeous 1975 Cessna Cardinal, which was subject to Cessna Service Letter SEL-51-09, that concerns wing spar inspections. The interesting thing here is Cessna (Textron) issued a Service Letter and it was marked as MANDATORY. At about the same time, the FAA issued a Notice of Proposed Rulemaking (NPRM) to add Cardinal models to an existing AD regarding carry-though wing spars. As the club had been searching for its next plane for several months, and as they really liked the Cardinal, they wisely chose to work with the seller and a local maintenance shop to get the inspections done ahead of the new AD. They now know more about their plane, and even better, the seller paid for the work!
We suggest that you think the same way about SBs for your club planes, whatever their regulatory weight. Yes, you may not “have to” comply, but without doubt, compliance will reduce any future liability, result in a safer aircraft and, by virtue of a club’s costs sharing advantage, will be “good value”. We usually think of the “club advantage” as sharing the fixed costs of ownership across all members—but the same advantage comes into play for unanticipated costs associated with compliance to SBs, etc., so the decision to comply should be a lot easier. We anyway recommend that clubs add a few dollars to the monthly dues to allow a “just-in-case” reserve to accumulate, but even if you don’t have the funds to cover a $10,000 SB fix, then for a club of ten members, it is only $1,000 per members for safety and peace of mind.
There is another angle when considering the cost of compliance—that of safety. The September 2021 FAASTeam Topic of the Month, “Service Bulletins and the Aircraft Owner”, refers to an accident in 2017, in which a Cessna Skymaster crashed into trees. The NTSB determined that the aircraft had run out of fuel. It is really easy to jump to conclusions here and blame the pilot for fuel mismanagement, and whilst that is true, the story gets a bit more involved.
The NTSB report states (in abstract) that the probable causes of this accident were: The pilots' inadequate preflight inspection, during which they failed to adequately verify the quantity of fuel, which resulted in fuel exhaustion, a subsequent total loss of power to both engines, and a forced landing into trees. Contributing to the accident were the erroneous fuel quantity displayed by the fuel quantity indicating system fuel sender units and the operator's failure to comply with a mandatory service bulletin addressing inaccuracies in the fuel quantity indicating system.
Ah-ha. Digging deeper will reveal that Cessna had issued a (mandatory) service bulletin on the fuel quantity indication system some 18-years prior to the accident. The SB required an initial inspection, and then recurring inspections every 12-months. The review of the logbooks revealed no evidence of compliance with the SB. In other words, the failure of the (then) owner/operator to comply with an SB, caught up with a pilot 18-years later. Now, it is true to say that a good pre-flight involving dipping the tanks should have revealed the difference between actual fuel and that indicated, and we are always told to never actually believe fuel gauges, but this shows that the impact of non-compliance to SBs can be long-term.
The conclusion from this case is clear. If you are buying an aircraft, you should include SBs along with ADs when reviewing the logbooks and never assume that any non-compliance was based on informed decision making. If you find SBs that that were not followed and logged, you must now decide what to do. We’d even apply this to a pilot about to fly a new-to-them airplane, perhaps as a new member of the club. Trust, verify and question!
In the spirit of FAR 91.103 (know everything there is to know about a flight), we challenge you to know all there is to know about your aircraft. At the very least join a type club and trawl though their articles and archives.
So, there it is…some not-so-obvious ways for you to know more about your aircraft. As always, if you find additional gems that you’d like to share with other clubs, please send an email to: [email protected]
As promised earlier, here are some links to learn more about WINGS for Clubs:
Fly lots and fly safely!