Your Experimental Light Plane Annual Condition Inspection - The Benefits and the Process
By Carol Carpenter, EAA 678959
Carol Carpenter and student
One of the things we often forget is that the condition inspection is much more than just this regulatory process we have to go through. Over the years, when performing a condition inspection, we’ll consistently run across something that causes that “Oh, my God, it’s a good thing we caught this” response. Recently, for example, we had an aircraft flown in for an inspection directly from the paint shop. During the inspection we discovered the wing bolts were installed into the holes, but the nuts were barely turned and had never been tightened. Discovering a discrepancy like this is certainly enough to get your attention. So while the inspection is required, more importantly, it’s an opportunity to get in there and really look at the aircraft in depth—a process that may even save your life.
For this reason, from 1991 to 2004, when we were flying Quicksilver aircraft under Part 103 as legal ultralights, we still performed condition inspections on all of them, each year, just as we did with our type certificated aircraft, a practice that proved to be worthwhile. Today, under the light-sport rule, our experimental Quicksilver Sport II must be inspected each year or we can’t legally fly it. Our operating limitations, which are part of our airworthiness certificate, require the inspection. But more importantly this yearly condition inspection is our chance to really look at our aircraft, regardless of the legal requirement to do so.
The annual inspection is one of the experimental aircraft owner’s more important duties. Ultralights are no exception. A number of accidents have been traced back to poor inspection practices. The inspection should be a thorough and systematic means by which you verify that the aircraft and all of the components are in condition for safe operation.
The good news
It’s easy to obtain the authorization to perform the inspection yourself on your experimental amateur-built aircraft (as long as you’re the original builder) and even easier if you own an experimental light-sport aircraft (E-LSA). For an E-LSA, you don’t have to be the original builder—just the owner. If you have successfully completed the 16-hour repairman inspection course and your aircraft N number and serial number are listed on the back of your repairman certificate, then you are authorized. (Read about the art and science of aircraft dataplates)
Further, the 16-hour course will allow you to perform annual condition inspections on any E-LSA certified in the assigned “class” of the selected course (airplane, weight shift, powered parachute, glider, gyroplane, or lighter-than-air) which you own or purchase in the future. Additionally, there are no renewal requirements for your certificate once you earn it, and there are no limits on how many aircraft you may own in a particular class. Today, 30 percent of the participants in our repairman inspection course are, in fact, experimental amateur-built owners. These pilots are attending purely for the course content.
I have heard concerns that E-LSA owners may cheat on their inspections and simply sign off their annuals after a perfunctory inspection. This may be true for a few, but I find most pilots are much more conscientious when inspecting their own aircraft. As an aircraft owner, the pilot, and the mechanic, you certainly have a vested interest in the safety of the aircraft, and you don’t have to worry about making a profit on the inspection. So take your time and thoroughly inspect your machine. When you’re flying at 3,000 feet above the ground, the peace of mind will be well worth the extra time and attention—a stronger motivation than FAA fines and penalties associated with noncompliance or falsifying logbook records.
The condition inspection can’t be delegated to another person. You can’t supervise another person as they perform the inspection; you must complete it yourself. Before you begin the actual inspection, plan ahead and get organized. Remember, the use of a checklist is mandatory. You may use the checklist in 14 CFR part 43 (appendix D), or a checklist designed by the holder of a repairman certificate, that includes the scope and detail of the items listed in appendix D to check the condition of the entire aircraft. This list includes checks of the various systems listed in 14 CFR part 43, section 43.15. Developing your own checklist allows you to address items specific to your aircraft. Note that 14 CFR part 43 (appendix D) is a minimum. You’ll want to use this document as a starting point and expand your checklist to cover your specific engine, propeller, airframe and components. You may even want to add consumables to it, items you’ll need to have on hand, such as oil, fuel strainers, and the like.
Brian Carpenter using a checklist for the condition inspection as is required
Next, collect and review all of the required resources. First and foremost, the procedures and scope for annual inspections for your E-LSA aircraft are set forth in 14 CFR part 43, appendix D, and should be followed in detail. Second, you’ll need the engine, aircraft, and propeller manuals, as well as any manuals for avionics or components. There are additional requirements for annual inspections listed in 14 CFR part 43, section 43.15, so you should also read this section of the regulations.
Since you’re required to determine that the required placards and documents are available and current, this is a good place to begin the inspection. Missing, incorrect, or improperly located placards are regarded as unsafe items. Under the requirements of 14 CFR part 91, section 91.9, the aircraft may not be operated until they’re available. Required aircraft identification markings are discussed in 14 CFR part 45. It’s also the owner’s or operator’s responsibility to have the nationality and registration markings properly displayed on the aircraft (14 CFR part 91, section 91.9(c)).
It’s imperative that weight and balance (weight and loading for weight shift and powered parachute) checks and computations be made very carefully. Since practically every aircraft manufacturer uses a different method of weight and balance control, it would be impossible to provide a universally adaptable method. Generally, however, on small aircraft, it’s often convenient to post a placard in the aircraft indicating the empty weight, useful load, and empty center of gravity, along with example loadings or general instructions, to cover the most likely loading conditions. Refer to 14 CFR section 91.9(b)(2). AC 120-27, Aircraft Weight and Balance Control and FAA-H-8083-1, Aircraft Weight and Balance Handbook contain useful information.
The inspection itself is essentially a visual evaluation of the condition of the aircraft and its components and certain operational checks. The manufacturer may recommend certain services to be performed at various operating intervals. These can often be done conveniently during an annual inspection and in fact should be done, but they aren’t considered to be a part of the inspection itself. I highly recommend that you complete the entire inspection before addressing any discrepancy or service items. This will ensure a systematic inspection. As an owner/operator, you’re in an optimum position to take your time and do the inspection right—you can’t afford to do it otherwise.
Either before or after the visual inspection, you’ll need to research all service bulletins issued on the aircraft, engine, propeller, or components such as instruments. It’s very important that you be familiar with the manufacturer’s service manuals, bulletins, and letters for the product being inspected. Use these publications to avoid overlooking problem areas.
If your aircraft is equipped with an emergency locator transmitter (ELT), you should inspect it during your condition inspection. ELTs must be inspected every 12 months in accordance with 14 CFR part 91.207; it makes sense to do this during the yearly condition inspection. 14 CFR section 91.413 requires that before a transponder can be used under 14 CFR section 91.215(a), it shall be tested and inspected within the preceding 24 calendar months. Therefore, we recommend that if you have a transponder you verify the last date of inspection.
Fortunately, good penmanship isn’t a requirement for a valid entry in the maintenance or airframe log.
Finally, the inspection isn’t over until the holder of a repairman certificate records the inspection in accordance with the requirements of 14 CFR part 43, sections 43.9 and 43.11. Additionally, record entries are very important as they are the only evidence an aircraft owner has to show compliance with the inspection requirements of 14 CFR part 91, section 91.409. They will be essential if you’re involved in an accident or incident. For example, just recently a pilot was forced to land on a public road due to a minor engine problem. When this incident was reported by local law enforcement, the FAA followed up and asked to see the maintenance records. In another example, an E-LSA made a bad attempt at crosswind landing on a public airport, damaged the gear, and blocked the runway for a time. The pilot didn’t report it, but the airport authority did. It resulted in a visit and a check of the books. Anybody can have their maintenance records checked as a result of a relatively minor incident. It’s also true that clear and complete records will protect your aircraft’s value, track trends over time, and track standard maintenance performed on your aircraft, such as oil changes. Don’t forget to indicate the aircraft’s total time in service on that inspection logbook entry. Once the entries are made, you can begin enjoying the benefits.
And the benefits? Not only is your aircraft legal for another year, but you and your aircraft will be happier and safer.
About the Author
Carol Carpenter, coauthor of Sport Pilot Airplane: A Complete Guide and A Professional Approach to Ultralights, is a sport pilot instructor, an instructor for both the FAA Light-Sport Repairman-Inspection and maintenance courses, FAA ground instructor with an advance rating, FAA private pilot, and FAA Safety Team representative. She holds a California teaching credential. Contact Carol at www.RainbowAviation.com.