EAA Seeks Clarification on Operating Limitation

April 25, 2019 - EAA is seeking clarification on an operating limitation assigned to many homebuilts in the past several years concerning manufacturer-assigned life limitations on component parts. 

Around five years ago during a significant revision to Order 8130.2, the document that sets forth operating limitations for experimental aircraft, EAA worked with the FAA to create flexible inspection programs for large and/or turbine experimental aircraft. 

These aircraft make use of precisely manufactured equipment that often requires limitations on service life and careful inspection, and the new guidance allowed operators to develop inspection programs that allowed operators of jet warbirds and other high-performance experimental aircraft to extend the service life of certain components. In lieu of an alternative program, the FAA requires operators to respect these service limitations.

Unfortunately, the current draft of the order does not clearly specify that this limitation (Limitation 20) is intended to only apply to large and/or turbine aircraft, and many recently built homebuilts have this limitation. Under a strict interpretation, this means that affected aircraft are now bound by life limits such as manufacturers’ TBOs, even though most other personal GA aircraft are not.

The wording in the limitation makes multiple references to a “program,” which is likely the aforementioned required inspection program for certain rare experimentals. This is further evidenced by a repeat of this language elsewhere in Order 8130.2J in a section that explicitly discusses such programs. Most homebuilts do not have an inspection program requirement beyond the standard condition inspection (usually annually).

EAA is investigating to ensure this wording is a simple discrepancy that will not impact members, and is working to correct the wording in the next revision of the order.