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Re: Flap Handle Extension STC
I have kissed the panel twice, yea, I am a slow learner. Fractured jaw in 3 places and a nice scar on my cheek and chin to remind me daily. I now fly with shoulder harnesses in everything possible.
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Re: Flap Handle Extension STC
I had a landing gear failure causing the plane to nose in at about 50 mph. Glad I had shoulder harness. Bruised shoulders were better than face damage. I also havd a small CO monitor with a sound alarm.
"You can only tie the record for flying low."
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Re: Flap Handle Extension STC
Originally Posted by
tjlebaron
…/
/….While your at it, install a carbon monoxide detector that gives a flashing light where you can see it. Nearly every year there is a fatal accident from exhaust leaks. I get tired of seeing something so preventable cause so much pain for families.
A CO detector was the first thing I added when I got it home. It was an illuminating experience. With all the vents closed I saw CO readings in excess of 50 ppm on initial climb out. Not drastically so, but still over the 50 ppm limit the FAA borrowed from OSHA (who uses it was a maximum 8 hour exposure level. I was also seeing readings around 35 parts per million on descent from pattern altitude down to the landing. In cruise, levels varied from 0 to 9 ppm depending on airspeed.
Personally, I think 50 ppm might be fine as an OSHA standard for people working at sea level but 50 ppm, 35 ppm pr 9 ppm at sea level would will all get progressively as the altitude increases. Add in normal effects of reduced oxygen and the need for more O2 for decent night vision and the FAA’s adopted limit of 50 ppm was something I consider excessive.
My Pa-22/20-150 has ball vents added in the front portion of each front window and with at least one of the vents open CO levels quickly go to 0 in all phases of flight, so the short term solution was keeping a vent open.
I started trouble shooting. Cabin heat settings made no difference but I still took a look at carb heat effects. I noted a normal drop in rpm with carb heat application (about 50 rpm and not over 100 rpm - anything greater suggests an exhaust leak). I also pressure tested the exhaust system and found no leaks.
I replaced the weather strip on all three doors and it made no difference.
I suspected the culprit was CO entering between the belly panels around the landing gear and sealing those is problematic.
What did work and was fairly easy to do was extending the exhaust stack from 1 7/8” outside the cowling to 8” outside the cowling. It adds some drag, but the CO readings are now near zero in any phase of flight.
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Re: Flap Handle Extension STC
Originally Posted by
LarryV
A CO detector was the first thing I added when I got it home. It was an illuminating experience. With all the vents closed I saw CO readings in excess of 50 ppm on initial climb out. Not drastically so, but still over the 50 ppm limit the FAA borrowed from OSHA (who uses it was a maximum 8 hour exposure level. I was also seeing readings around 35 parts per million on descent from pattern altitude down to the landing. In cruise, levels varied from 0 to 9 ppm depending on airspeed.
Personally, I think 50 ppm might be fine as an OSHA standard for people working at sea level but 50 ppm, 35 ppm pr 9 ppm at sea level would will all get progressively as the altitude increases. Add in normal effects of reduced oxygen and the need for more O2 for decent night vision and the FAA’s adopted limit of 50 ppm was something I consider excessive.
My Pa-22/20-150 has ball vents added in the front portion of each front window and with at least one of the vents open CO levels quickly go to 0 in all phases of flight, so the short term solution was keeping a vent open.
I started trouble shooting. Cabin heat settings made no difference but I still took a look at carb heat effects. I noted a normal drop in rpm with carb heat application (about 50 rpm and not over 100 rpm - anything greater suggests an exhaust leak). I also pressure tested the exhaust system and found no leaks.
I replaced the weather strip on all three doors and it made no difference.
I suspected the culprit was CO entering between the belly panels around the landing gear and sealing those is problematic.
What did work and was fairly easy to do was extending the exhaust stack from 1 7/8” outside the cowling to 8” outside the cowling. It adds some drag, but the CO readings are now near zero in any phase of flight.
While I think extending the exhaust was a safety improvement, that is a major alteration requiring a 337 and approved data.
Sent from my iPhone using Tapatalk
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Re: Flap Handle Extension STC
Originally Posted by
dgapilot
I have to say, we now live in a world of people so risk averse it just amazes me! A CFI that refused to fly in an airplane without shoulder harnesses? You have got to be kidding me! I fly a lot of different airplanes, so with and some without harnesses. I've never really worried about it. If they are there, I use them, if they aren't, it's not a big deal. I flew my TriPacer for about 6 or 7 years towing banners with no shoulder harness. Early Pacers, all the Clippers, and Vagabonds (along with MANY other airplanes built in the 30s, 40, and early 50s only had a single belt that went across both occupants in both the front and back. Yes, crash protection is important. If you want to wrap yourself in bubble wrap, don't buy an old airplane, survivability wasn't built into them. For at least half my career, flying broken airplanes was a part of my job. I'm talking major structural damage from gear up landings, animal strikes, wind damage, you name it. First time I flew a Cirrus, about 3 feet of the leading edge was missing. Risk management is all part of the job. If you are worried about reaching the damn flap handle, plan on not using the flaps!
It was inconvenient and the install would have been neater if done at my home field, but I was able to fix what wasn’t done to my standards later.
As for the CFI it’s his face and his call.
I probably will not use him in the future but for different reasons. The plan was to fly home and do training on the way to get me Pacer proficient. It didn’t quite work that way as it ended up being a two day trip with a half day spent resolving fuel system issues - a leaking quick drain in the gascolator, a weeping fuel line in the engine compartment and a leaking fuel hose from the right wing tank due to a clamp being excessively tightened, all three of which appeared while remaining overnight at an airport leaving a fair sized damp spot on the ramp.
The training was then done at his home base a couple hours from mine the morning after we got back. We were both tired and it showed in my flying and in his instruction. At one point he wanted me to fly a longer final to have more time to set up and stabilize the descent. When I did that one the next pass he was concerned I was too far out to make the runway of the engine quit. There really was no happy medium for him. He also got upset at one point on a base to final turn where I had some opposite aileron to correct the over banking tendency. He was obviously concerned about a skid, but both my seat and the ball clearly showed the turn was coordinated. At that point I realized he was tired and not at the top of his game.
We got me proficient enough to fly home to my 1800’ grass strip. From there I worked out the ways of the Pacer on my own on a nearby uncharted 3000’ auxiliary spray strip we use for training. About 50 hours later I got some dual from a 35,000 hour former bush pilot with Pacer experience who showed me how to really get it to do what I needed it to do. To me, that illustrated that part of the problem was CFI number 1, despite being an experienced tail wheel instructor who knew how to teach a formula that worked in most tail wheel aircraft, just wasn’t all that experienced in a Pacer.
In general I also just didn’t click with his teaching style.
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Re: Flap Handle Extension STC
Originally Posted by
dgapilot
While I think extending the exhaust was a safety improvement, that is a major alteration requiring a 337 and approved data.
Sent from my iPhone using Tapatalk
Why yes, that’s how I and the AP/IA I used both saw it as well given the realities of over enforcement and micromanagement of APs and IAs by the FAA.
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I will add however that the fact that such an obvious safety improvement resolving something as serious as high CO levels is viewed as a “major alteration” requiring “approved data” and an odious 337 approval process is a sad commentary on the FAA and it’s devolution to narrow read of the law and bureaucratic butt covering as opposed to common sense field focused knowledge that actually improves flight safety.
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Administrator
Re: Flap Handle Extension STC
I sent my tail pipe to Dawley, told them to make it ..." longer and installed it. If someone can prove it made the airplane crash so be it.
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Re: Flap Handle Extension STC
Originally Posted by
Steve Pierce
I sent my tail pipe to Dawley, told them to make it ..." longer and installed it. If someone can prove it made the airplane crash so be it.
How many FAA folks do you know who would do ramp checks and even know how long the exhaust stack is supposed to be in the first place.
Not to beat up on or blame DGA by any means but APs and IAs have been bullied into using an over abundance of caution when interpreting the definition of “Major alteration”. The long standing legal principle (and I say this as a former fed who used to write, interpret and enforce regulations) is that any ambiguity goes against the author.
14 CFR 1.1 defines major and minor alteration:
“Major alteration means an alteration not listed in the aircraft, aircraft engine, or propeller specifications -
(1) That might appreciably affect weight, balance, structural strength, performance, powerplant operation, flight characteristics, or other qualities affecting airworthiness; or
(2) That is not done according to accepted practices or cannot be done by elementary operations.
Minor alteration means an alteration other than a major alteration.”
14 CFR 49.3(a)(4) also makes the point that it is the person performing the repair or major alteration who must decide whether it is major or minor. Unfortunately the FAA field staff have gotten in the habit of second guessing the APs and AIs and the over abundance of caution in calling it a major alteration and submitting a 337 with approved data has become common place.
Unfortunately at the same time submitting data that the FAA will consider photo be approvable has become substantially more difficult in some regions as staff in those regions pretty much reject any and all data out of an over abundance of caution and just keep asking for more and more data until the IA involved gives up.
One of the local mechanics in this are submitted a 337 that was repeatedly rejected - even though he had personally submitted and received approvals based on the same data no less than 6 times previously. He eventually asked one of the FSDO staff coming to host an event to show up 30 minutes early to go over the data. That person from the FSDO noted that same data had been approved six times in the past and in fact had been signed off by himself twice. He signed it on the spot. So it often just comes down to a) not giving up, and b) finding someone at the FSDO who is not excessively risk averse.
What the FAA folks involved in all this excessive risk aversion and over abundance of caution fail to realize is that when things like extending an exhaust stack on a Pacer come up to mitigate unsafe levels of CO that are essentially inherent in the original design, if the 337 isn’t approved, it’ll just get done anyway and just won’t be logged. As Steve notes who is going to know? Based on 12 years as a field oriented staff person working inside the beltway with risk averse attorneys in an dysfunctional agency I can confirm that over enforcement *always* leads to sub optimal outcomes and unintended consequences.
Looking at the definition again, a critically thinking AI could clearly interpret extending the exhaust stack as a logical and simple means to “restore” the aircraft to its original certified and safe condition (less than 50 ppm CO).
The questions then are:
- does adding the extra 6” of exhaust pipe appreciably changes the weight and balance. (It doesn’t take much math to demonstrate that it does not.);
- does the extra drag of that 6” of exhaust pipe appreciably affect performance. (Again it doesn’t take much thought to demonstrate that it doesn’t have an effect on an airframe as “clean” as a Pacer, especially a converted PA-22/20 that no longer has the weight and drag of the nose wheel, which also applies to the weight and balance question above.); and
- does the extra 6” of exhaust pipe appreciable affect engine operation. (Did the static RPM appreciably decrease when the pipe was added, and more importantly is the static rpm still within the limits stated in the type certificate?)
Given all the answers indicate it is not a major alteration, then it’s simply not a major alteration and no data needs to be submitted - based on the AP/IAs qualified status to make that determination based on very sound and logical principles and the information in the type certificate.
Yet here we are with a significant percentage of AP/IAs faced with what is clearly a minor alternation requiring nothing more than a log book entry fearing they’ll be second guessed and thus (at least attempting to) submit a 337 as a major alteration.
Ironically this FAA, the one leaning hard on general aviation and apparently working hard to make it unaffordable for all but the Uber rich and claiming it’s in the name of air safety, is the same FAA that basically let Boeing do it’s own 737 Max certification using a single point of failure for data going to the air data computer. Zero oversight. Frankly it was a mistake in the first place to let Boeing use a flight computer to manipulate the flight characteristics of a distinctly different aircraft with distinctly different systems so that Boeing could certify the plane in a manner that did not require a separate type rating, making it marginally more attractive and cost effective to existing 737 operators.
It’s why we can’t have nice things.
Last edited by LarryV; 08-06-2021 at 06:30 PM.
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Flap Handle Extension STC
Larry, I’m the first one to tell people to actually use the FAA guidance to make the major/minor determination, and believe that far to many things are classified as a major where if you actually use the guidance it will be a minor. In this case I disagree. 14 CFR 43 appendix A lists changes to the exhaust system design as a major. I would consider extending the tail pipe a change to the design since it no longer matches the Piper print. I also agree that this change is a safety improvement, and would still likely meet the CAR 3 requirements, so issuing a field approval or DER approval should be a no brainer. The issue at hand is also determining that the change doesn’t impact power output, or result in increased cylinder head temperatures due to higher pressure at the exhaust outlet resulting in increased back pressure. Everything you do to an airplane has trade offs, and you need to determine those interactions before you just jump in.
As for fearing the heavy hand of FAA, I’m usually the first to argue with them and on several occasions I’ve challenged them to issue me a letter of investigation and “I’ll see you in court!” I do however fear the potential litigation if things go south. I don’t carry any insurance, so my entire financial well being is on the line every time my name goes in a log book, on an airworthiness certificate, or on an 8110-3. I make it a point to be sure all my bases are covered, and even then there is no guarantee. So far, knock on wood, in 44 years since I got my A&P, I haven’t had a law suite or an FAA violation.
Just to put this in another perspective, filing a 337 for a minor repair or a minor alteration is the exact same violation of 43.9 as not filing a 337 for a major alteration or major repair. Use the resources FAA gives us to make your Major/Minor determinations. 14CFR 1.1 definitions, 14CFR 21.93 definition of major change in type design, 14 CFR 43 Appendix A, AC43-210A, FAA ORDER 8300.16A, and the AFS-300 Major Repair and Major Alteration job aid.
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Last edited by dgapilot; 08-07-2021 at 08:48 AM.
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