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Lycoming Data Plate

 
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PGLong



Joined: 10 Jan 2006
Posts: 37

PostPosted: Fri Nov 10, 2006 9:09 am    Post subject: Lycoming Data Plate Reply with quote

I've been told that the data plate on my Lycoming 0-230 installed in my RV-4 is not in compliance with the FAR’s. The engine has some modifications on it, and I do not maintain an A.D. list, so the engine is experimental. Is it true that only a certified engine can retain its data plate? Who can remove a data plate? How would the FAA handle this situation?


Pat Long
PGLong(at)aol.com
N120PL
RV4
Bay City, Michigan
3CM


[quote][b]


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Pat Long
RV-4, N120PL
Bay City, MI
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jrccea(at)bellsouth.net
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PostPosted: Fri Nov 10, 2006 3:20 pm    Post subject: Lycoming Data Plate Reply with quote

The engine is not an O-230. It is either an O-235, or perhaps a typo for an O-320. Anyone can remove a data plate, but the engine cannot be returned to certified status afterward.
PGLong(at)aol.com wrote: [quote]

I've been told that the data plate on my Lycoming 0-230 installed in my RV-4 is not in compliance with the FARs. The engine has some modifications on it, and I do not maintain an A.D. list, so the engine is experimental. Is it true that only a certified engine can retain its data plate? Who can remove a data plate? How would the FAA handle this situation?

Pat Long
PGLong(at)aol.com
N120PL
RV4
Bay City, Michigan
3CM
[quote] [b]


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gyoung



Joined: 09 Jan 2006
Posts: 211
Location: Republic of Texas

PostPosted: Fri Nov 10, 2006 7:33 pm    Post subject: Lycoming Data Plate Reply with quote

You do not need to nor should you remove the data plate. It is just the identifier for a part. It is no different nor any more special than the data plates on your starter, fuel pump, radios, ELT or propeller. No one ever suggests removing the data plates or grinding off the part numbers for every component on our aircraft. Any component can be reused on a certified aircraft IF, big IF, the mechanic can satisfy himself with the service history and that the component conforms to it's original design and is airworthy. Lack of an AD list or non-AP signoffs or no log entries would be a red flag to most reputable mechanics leading to a tear-down for the conformity check. Parts with non-certified histories are returned to service all the time, including in the airlines. A US-built but foreign registered and maintained aircraft and all its components is just as "non-certified" as your RV. I participated in re-certifying a KLM 747, among others, for a US airline I worked for. It's just a matter of the level of inspection or repair $$$ required. Leave the data plate where it is.

Regards,
Greg Young - Houston (DWH)
RV-6 N6GY - project Phoenix
Navion N5221K - just an XXL RV-6A
[quote]




I've been told that the data plate on my Lycoming 0-230 installed in my RV-4 is not in compliance with the FAR’s. The engine has some modifications on it, and I do not maintain an A.D. list, so the engine is experimental. Is it true that only a certified engine can retain its data plate? Who can remove a data plate? How would the FAA handle this situation?


Pat Long
PGLong(at)aol.com
N120PL
RV4
Bay City, Michigan
3CM
Quote:
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jrccea(at)bellsouth.net
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PostPosted: Sat Nov 11, 2006 5:19 am    Post subject: Lycoming Data Plate Reply with quote

a url of interest:

http://www.rollanet.org/~mopilots/stlouis/jan2005nws.htm


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douglas.dodson(at)pobox.c
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PostPosted: Sat Nov 11, 2006 10:11 am    Post subject: Lycoming Data Plate Reply with quote

Based on the letter referenced in the URL, I would say that one should
ensure the engine and propeller are NOT type certificated at the time the
limitations and original airworthiness certificate are issued. This could
be done with any number of somewhat minor modifications I would think.
Removing the type certificate designation after the original issuance could
be done as well I would think, but the aircraft would revert to Phase I for
a time.

Douglas L. Dodson, Jr.
Glasair II-S FT
Flight Test Engineer, CFI-A,G

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mlas(at)cox.net
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PostPosted: Mon Nov 13, 2006 8:29 am    Post subject: Lycoming Data Plate Reply with quote

I would just like to add to what was written in the url below as it
pertains to AD's on experimental aircraft. One point that was missed,
if the part or assembly was originally certified there is no probation
regarding modification or change to said parts. Following any change to
the parts or assemblies the part would no longer conform to the original
part number and design and therfore not be subject to the AD provided
the logbook (legal document) entry showing the change and or
modification.

One other note: If you list the Lycoming O-320 as a Warp Space Jumper
#007 when certifying your airplane and enter it in your log book that
way, it is no longer a Lycoming O-320 as far a AD's go.

The point I am trying to illustrate above is that AD's are for certified
aircraft, engines, propellers, and accessories. Once modified or
changed they are no longer certified, and therefore not subject to AD's
because they are not listed on the AD (put forged pistons in said
Lycoming O-320(legal as an experimental), it is no longer a Lycoming
O-320 because forged pistons are not certified and therefore no longer
subject to the AD because the engine is no longer a Lycoming O-320). If
a part is unchanged in all respect as it relates to being certified then
the compliance to the AD is mandatory.

Mike Larkin

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PostPosted: Mon Nov 13, 2006 10:06 am    Post subject: Lycoming Data Plate Reply with quote

It does however note that if the experimental aircraft received its
operating limitations and certificate with a certified engine
installed, then it should get a modified operating limitations when
the engine is modified to make it no longer of approved type design.
It would be wise for the repaiman signing the condition inspection to
have reviewed ADs, so that you know if Lycoming has a crank problem in
same model engine, and you have that crank, that you are risking crank
failure if you don't heed the AD. As in use some common sense to
ensure your engine truly is airworthy.

On 11/13/06, Mike <mlas(at)cox.net> wrote:
[quote]

I would just like to add to what was written in the url below as it
pertains to AD's on experimental aircraft. One point that was missed,
if the part or assembly was originally certified there is no probation
regarding modification or change to said parts. Following any change to
the parts or assemblies the part would no longer conform to the original
part number and design and therfore not be subject to the AD provided
the logbook (legal document) entry showing the change and or
modification.

One other note: If you list the Lycoming O-320 as a Warp Space Jumper
#007 when certifying your airplane and enter it in your log book that
way, it is no longer a Lycoming O-320 as far a AD's go.

The point I am trying to illustrate above is that AD's are for certified
aircraft, engines, propellers, and accessories. Once modified or
changed they are no longer certified, and therefore not subject to AD's
because they are not listed on the AD (put forged pistons in said
Lycoming O-320(legal as an experimental), it is no longer a Lycoming
O-320 because forged pistons are not certified and therefore no longer
subject to the AD because the engine is no longer a Lycoming O-320). If
a part is unchanged in all respect as it relates to being certified then
the compliance to the AD is mandatory.

Mike Larkin

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s_korney(at)hotmail.com
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PostPosted: Mon Nov 13, 2006 10:15 am    Post subject: Lycoming Data Plate Reply with quote

Mike ...

With that said, all that is necessary is to remove the data plate, log it in
the engine log book, and the engine is no longer certified ... Is that
correct...?

Best... Steve

----Original Message Follows----
From: "Mike" <mlas(at)cox.net>
Reply-To: engines-list(at)matronics.com
To: <engines-list(at)matronics.com>
Subject: RE: Lycoming Data Plate
Date: Mon, 13 Nov 2006 09:28:54 -0700



I would just like to add to what was written in the url below as it
pertains to AD's on experimental aircraft. One point that was missed,
if the part or assembly was originally certified there is no probation
regarding modification or change to said parts. Following any change to
the parts or assemblies the part would no longer conform to the original
part number and design and therfore not be subject to the AD provided
the logbook (legal document) entry showing the change and or
modification.

One other note: If you list the Lycoming O-320 as a Warp Space Jumper
#007 when certifying your airplane and enter it in your log book that
way, it is no longer a Lycoming O-320 as far a AD's go.

The point I am trying to illustrate above is that AD's are for certified
aircraft, engines, propellers, and accessories. Once modified or
changed they are no longer certified, and therefore not subject to AD's
because they are not listed on the AD (put forged pistons in said
Lycoming O-320(legal as an experimental), it is no longer a Lycoming
O-320 because forged pistons are not certified and therefore no longer
subject to the AD because the engine is no longer a Lycoming O-320). If
a part is unchanged in all respect as it relates to being certified then
the compliance to the AD is mandatory.

Mike Larkin

--


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apilot2(at)gmail.com
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PostPosted: Mon Nov 13, 2006 11:13 am    Post subject: Lycoming Data Plate Reply with quote

Quote:
From the url cited earlier:
"The acting legal counsel also addressed the act of removing data

plates to avoid compliance with AD's. His Memorandum states that the
act of removing the data plate of a type-certificated product is
addressed in Part 45. Section 45.13 of that Part prohibits removing
data plates without the approval of the FAA. There are no exceptions
granted in that Part for engines or propellers installed in
amateur-built aircraft. Simply removing a data plate does not alter
the type design or nature of the engine or propeller. "
Don't blame me, the messenger, take it up with your FSDO.
On 11/13/06, steve korney <s_korney(at)hotmail.com> wrote:
[quote]

Mike ...

With that said, all that is necessary is to remove the data plate, log it in
the engine log book, and the engine is no longer certified ... Is that
correct...?

Best... Steve

----Original Message Follows----
From: "Mike" <mlas(at)cox.net>
Reply-To: engines-list(at)matronics.com
To: <engines-list(at)matronics.com>
Subject: RE: Lycoming Data Plate
Date: Mon, 13 Nov 2006 09:28:54 -0700



I would just like to add to what was written in the url below as it
pertains to AD's on experimental aircraft. One point that was missed,
if the part or assembly was originally certified there is no probation
regarding modification or change to said parts. Following any change to
the parts or assemblies the part would no longer conform to the original
part number and design and therfore not be subject to the AD provided
the logbook (legal document) entry showing the change and or
modification.

One other note: If you list the Lycoming O-320 as a Warp Space Jumper
#007 when certifying your airplane and enter it in your log book that
way, it is no longer a Lycoming O-320 as far a AD's go.

The point I am trying to illustrate above is that AD's are for certified
aircraft, engines, propellers, and accessories. Once modified or
changed they are no longer certified, and therefore not subject to AD's
because they are not listed on the AD (put forged pistons in said
Lycoming O-320(legal as an experimental), it is no longer a Lycoming
O-320 because forged pistons are not certified and therefore no longer
subject to the AD because the engine is no longer a Lycoming O-320). If
a part is unchanged in all respect as it relates to being certified then
the compliance to the AD is mandatory.

Mike Larkin

--


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ceengland(at)bellsouth.ne
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PostPosted: Mon Nov 13, 2006 2:26 pm    Post subject: Lycoming Data Plate Reply with quote

Kelly McMullen wrote:

Quote:


> From the url cited earlier:

"The acting legal counsel also addressed the act of removing data
plates to avoid compliance with AD's. His Memorandum states that the
act of removing the data plate of a type-certificated product is
addressed in Part 45. Section 45.13 of that Part prohibits removing
data plates without the approval of the FAA. There are no exceptions
granted in that Part for engines or propellers installed in
amateur-built aircraft. Simply removing a data plate does not alter
the type design or nature of the engine or propeller. "
Don't blame me, the messenger, take it up with your FSDO.
On 11/13/06, steve korney <s_korney(at)hotmail.com> wrote:

>
> <s_korney(at)hotmail.com>
>
> Mike ...
>
> With that said, all that is necessary is to remove the data plate,
> log it in
> the engine log book, and the engine is no longer certified ... Is that
> correct...?
>
> Best... Steve

>snipped>


Unless you have the misfortune to live in that particular FSDO area, the
document in question is nothing but an example of the thinly disguised
anarchy that serves as the FAA. (A good thing, in my opinion.)

The FSDO inspector here *took* the Lyc dataplate from my neighbor when
he did the inspection on a new homebuilt design. When my neighbor hung
the same engine on another new airframe (an RV-8, this time), the same
FSDO wanted to know where his dataplate was. (Answer: 'You took it.')

I'm sure that there is diversity of opinion among FSDO's on a
'certified' part keeping its status when hung on an experimental, but
over the 15+ years I've been involved with homebuilts the most common
position I've seen is that the part loses its certified status the
moment it becomes part of a non-certified system. Consider the
underlying logic: in the certified world, Lyc makes dozens of O-320's
but only a few are typically legal for a particular airframe because the
rest haven't been tested on that airframe. Similarly, only a handful of
propellers are certified for a particular engine on a particular
airframe. If you create an untested combination, you don't know if it's
safe until it's tested and 'the paperwork is done'. No 'paperwork' has
ever been done on any certified engine that's been hung on an RV, so how
can it be proven to the bureaucracy that it's *legally* safe?

The only perceivable logic in giving a shorter test period when using a
'certified' engine/prop combination on a homebuilt is that you are at
least starting with two parts that are known to work ok together (but
still a legal unknown on a homebuilt).

Charlie


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PostPosted: Tue Nov 14, 2006 6:23 am    Post subject: Lycoming Data Plate Reply with quote

The statement below muddies the waters regarding the question of AD
compliance on aircraft certified experimental homebuilt. IF you modify
a certified propeller, engine, airframe, or accessory you may be
required (based on the operation limitation issued during certification)
to return the airplane to Phase I for flight testing and then upon
successful completion of Phase I return the aircraft back to Phase II
and operate the aircraft in accordance to you operating limitations. So
if you have a certified MT propeller and you want to change the shape of
the blades (the following is subject to the limitations issued at
certification, older limitations require submission or notification to
your local FSDO of changes and/or modifications and later limitations
require returning the aircraft to Phase I before operating the airplane
outside of the test flight area) you may make the change fly off the
Phase I testing and return to Phase II upon successful testing. Now
with our newly changed prop, the FAA issues an AD on the original prop
model you are not required to comply. Not because it is exclusive
experimental, but because it is no longer the same prop buy part number
previously listed. Now common sense suggests that if an AD came out and
a potential safety hazard exists then it would make sense to consider
the AD. With homebuilt aircraft always remember that you are the
designer, engineer, and builder. It is up to you to decide what You
want and don't want in your airplane.

Mike Larkin
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PostPosted: Tue Nov 14, 2006 7:26 am    Post subject: Lycoming Data Plate Reply with quote

---

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PostPosted: Wed Nov 15, 2006 6:33 am    Post subject: Lycoming Data Plate Reply with quote

Yes, I agree Wayne.

MIke

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