Primary Category

[Ragsf15e]

I for one, bought a certified airplane because it was built and maintained to certain standards.  I agree there are many experimental airplanes that probably have higher standards, however there are many builders / owners that have lower or no standards.  I guess my point is, I have some expectation as to what I have in a certified airplane.  That’s what the draconian FAA regulations buy me.  They have been through a certification process and maintained in accordance with it.

The airframes in experimental aircraft, the electronics and the maintenance have been through a less thorough process which allows them to be much more nimble with technology.  And cheaper due to the reduced certification requirements.

In my opinion, thats why the experimental segment has a significantly higher accident rate than the certified general aviation segment. 
 

If you did this to your airplane, who am I to complain?  But it would definitely make me think twice before purchasing it.

[steingar]

6 hours ago, gsxrpilot said:

This has been going on for many years in the Experimental world and hasn't be a problem. 

Baloney.  There're two big bars to these guys.  One is they have to cobble together the ship, so they have something on the ball.  The second is even if they buy it from the builder, it has to be inspected once a year.  And even then, experimental is way more dangerous than certificated, and lots more of those accidents are from build/maintenance errors.  Like I said, this will end in blood and tears.  

[gsxrpilot]

Just now, steingar said:

Baloney.  There're two big bars to these guys.  One is they have to cobble together the ship, so they have something on the ball.  The second is even if they buy it from the builder, it has to be inspected once a year.  And even then, experimental is way more dangerous than certificated, and lots more of those accidents are from build/maintenance errors.  Like I said, this will end in blood and tears.  

Evidently Primary Category aircraft still have to be inspected by an IA as well. And so I just don't believe the data backs up your claims. There are hundreds of RV's out there that are now on their third or fourth owner. Everything except an annual inspection can be done by the owner. And most importantly they can use any electronics, avionics, instruments, they like and hold it all together with hardware from HomeDepot. And while Experimental accident rates are higher than Certificated, if you limit the stats to well supported kit makers such as the Vans RV's, Kitfoxes, Glasair, etc. the rates really aren't any different.

Unfortunately my 252 is too big, heavy and turbocharged, so it's not eligible. But if it were, I wouldn't hesitate.

[Parker_Woodruff]

34 minutes ago, gsxrpilot said:

 

Unfortunately my 252 is too big, heavy and turbocharged, so it's not eligible. But if it were, I wouldn't hesitate.

I would hesitate for resale purposes.

[gsxrpilot]

Just now, Parker_Woodruff said:

I would hesitate for resale purposes.

LOL... the first thing I learned from you is to never sell the 252. 

[Parker_Woodruff]

4 minutes ago, gsxrpilot said:

LOL... the first thing I learned from you is to never sell the 252. 

reminds me...I need to send you an email...

[Yetti]

4 hours ago, Ragsf15e said:

I for one, bought a certified airplane because it was built and maintained to certain standards.  I agree there are many experimental airplanes that probably have higher standards, however there are many builders / owners that have lower or no standards.  I guess my point is, I have some expectation as to what I have in a certified airplane.  That’s what the draconian FAA regulations buy me.  They have been through a certification process and maintained in accordance with it.

The airframes in experimental aircraft, the electronics and the maintenance have been through a less thorough process which allows them to be much more nimble with technology.  And cheaper due to the reduced certification requirements.

In my opinion, thats why the experimental segment has a significantly higher accident rate than the certified general aviation segment. 
 

If you did this to your airplane, who am I to complain?  But it would definitely make me think twice before purchasing it.

Here lies the fallacy of your line of reasoning.   Just because your 50 year old plane was built in a certified factory and maintained by certified mechanics over 50 years that does not make it airworthy.  But you are still responsible as an owner.   Unless you have a maintenance background and have been through your plane, you do not know.  You just don't.  And I would bet a dollar there is something not done properly on your plane.   I mean shoot we even had an electrical shop on the west coast that did not know how to do airworthy work.

[RobertGary1]

The FAA doesn't allow you to change the certification type on a whim. You need to show its for the purpose of product development, etc and then afterwards how you'll either scrap the airframe or return it to its original category.  There are checks and balances at the FAA to prevent people from changing the certification without a specific purpose.

 

-robert

[Ragsf15e]

24 minutes ago, Yetti said:

Here lies the fallacy of your line of reasoning.   Just because your 50 year old plane was built in a certified factory and maintained by certified mechanics over 50 years that does not make it airworthy.  But you are still responsible as an owner.   Unless you have a maintenance background and have been through your plane, you do not know.  You just don't.  And I would bet a dollar there is something not done properly on your plane.   I mean shoot we even had an electrical shop on the west coast that did not know how to do airworthy work.

Oh yeah, I totally agree with that and that my certified mechanic makes mistakes.  Multiply that by 50 years.

But I have a starting point and certification standards and regulations to work within to fix those things the right way as I find them.

 I have no misconception that my airplane is perfect because it’s certified.

[afward]

I'm really not seeing a huge problem with the Primary category, so long as the plane is properly maintained (much like experimentals).  I wouldn't buy one without giving it a good looking over, especially where it differs from Normal category choices, but hey, I did a pre-buy on my Normal category plane, so there's not a lot of difference there.

Two questions I'm not quite getting the answer to (here or elsewhere):

1. I get that primary category seems to allow experimental avionics (with the right magical incantations in the conversion paperwork), but what about airframe and engine mods?  For example, a custom cowling?  Or maybe SDS EFII on the engine?
2. What operational limitations are applied to the new cert?  Obviously no commercial use, but anything else?  "No passengers for 40 hours after a major change"?

I'm not planning to do any of this myself; just trying to understand it a little better and my Google-fu is weak today...

[cliffy]

5 hours ago, Hank said:

My whoel problem with the Primary category is that it still requires me to either go to A&P school or log a couple thousand hours working under supervision before I can do anything beyond the current owner-approved maintenance. That's a burden that few owners with jobs will ever be able to meet . . . .

Not true. If you want to go Primary the requirement is 24 hrs of professional training in doing the items YOU want expanded beyond the current Preventive Maintenance ones. The entire airplane is still recertified every year by a licensed IA doing an Annual Inspection by regulation!

 

"The FAA doesn't allow you to change the certification type on a whim. You need to show its for the purpose of product development, etc and then afterwards how you'll either scrap the airframe or return it to its original category.  There are checks and balances at the FAA to prevent people from changing the certification without a specific purpose."

Again not true. By reading the actual A/C you will see that in this instance we are changing from Normal category to a NEW category called 

"PRIMARY" into which you can change with the blessings of the FAA via the STC process.  They do however caution in the A/C that to go back to Normal category will be a struggle. 

So we are back to the same maybe misconceptions of the process.

If it holds true that we can change to this new category, do more of our own maintenance, IF WE WANT TO, as nothing says we have to expand the owner allowed maintenance-it can stay as it was, and then work into non TSO'd avionics, then that is a step forward for a lot of old airplanes. The airframe stays maintained as it was, by certified A&Ps without any owner maintenance (if this is the way the owner wants it) ,  Then the owner can avail himself of all the nice electronics that the Experimental field of aviation has been using for years without trouble. 

How much blood has been spilled by using the "experimental" non TSO'd  electronics? 

SO, as I mentioned years ago right here, in the above scenario we have an airframe being maintained as it was by certified mechanics and using currently available electronics, just not meeting the strenuous requirements of any TSOs. Show me the higher risk factor. Even the non TSO'd electronics have proven to be far more reliable than any 50 year old technology now in use - FOR THE VAST MAJORITY OF PRIVATE PILOTS TODAY WHO OWN LEGACY AIRPLANES AND THE WAY THEY FLY THEM.

Comparable safety does not have to come in the form of a TSO 

 

 

 

[Yetti]

I give you brake pads.   Probably one of the simpler things that can be changed out on the airplane.   A little more complex on the car because the fart heads at Ford used a not in any set metric allen head bolt.    You have to take the brakes off to do owner allowed change the tires, but woe is me if you pop out and reseat a couple of rivets with an $11 tool.

 

[cliffy]

Every engineer should have to be required to change any part they design.

Only then will we get easy to repair airplanes.

Cessna started that process a long way back on Citations  

[tmo]

On 3/2/2020 at 7:43 PM, Ragsf15e said:

That’s what the draconian FAA regulations buy me.

Say again?

How about a mandatory 6 year propeller overhaul, just because Her Majesty's subjects running the UK CAA said so?  How about mandatory overhaul at TBO, regardless if calendar or hours flown, just because some ex-military fellow running the local CAA thought it was a safe idea?  How about no GPS substitution for VOR / DME / NBD?  How about mandatory CAMO (Continuous Airworthiness Management Organization), usually with a sister company doing the maintenance, just because you aren't able to look up ADs on your own?  How about mandatory SBs?  Yes, for private operations.  Owner produced what?!

Don't get me wrong, I'd love to see price parity of identical devices between certified, experimental and ultralight.  I'd love to see all the cool stuff from E/AB and ultralight available for our planes.

But do not call the FAA Part 91 rules draconian.  That is simply not true.  They really did get it right, and are trying to continue down that road, with NORSEE, the Part 23 rewrite, just to name a few.  Yes, some ideas are stillborn, like LSA, but nobody is forcing anyone down that path.  And don't get me wrong, I think EASA (European Air Safety Agency) is moving the right direction, albeit starting from years of overly restrictive, disproportionate regulation, and still has ways to go, both in terms of the letter of the law and, more importantly, the mental attitude towards private flight.

And let's not talk about training, my BP is elevated enough already.

[Ragsf15e]

27 minutes ago, tmo said:

Say again?

How about a mandatory 6 year propeller overhaul, just because Her Majesty's subjects running the UK CAA said so?  How about mandatory overhaul at TBO, regardless if calendar or hours flown, just because some ex-military fellow running the local CAA thought it was a safe idea?  How about no GPS substitution for VOR / DME / NBD?  How about mandatory CAMO (Continuous Airworthiness Management Organization), usually with a sister company doing the maintenance, just because you aren't able to look up ADs on your own?  How about mandatory SBs?  Yes, for private operations.  Owner produced what?!

Don't get me wrong, I'd love to see price parity of identical devices between certified, experimental and ultralight.  I'd love to see all the cool stuff from E/AB and ultralight available for our planes.

But do not call the FAA Part 91 rules draconian.  That is simply not true.  They really did get it right, and are trying to continue down that road, with NORSEE, the Part 23 rewrite, just to name a few.  Yes, some ideas are stillborn, like LSA, but nobody is forcing anyone down that path.  And don't get me wrong, I think EASA (European Air Safety Agency) is moving the right direction, albeit starting from years of overly restrictive, disproportionate regulation, and still has ways to go, both in terms of the letter of the law and, more importantly, the mental attitude towards private flight.

And let's not talk about training, my BP is elevated enough already.

Well sheesh, I guess I should have put “draconian” in quotes because I was quoting a previous poster while disagreeing with him.  No, I don’t think the FAA is draconian.  I don’t think they’re perfect, but I think it’s about right.

[0TreeLemur]

On 3/2/2020 at 10:58 AM, cliffy said:

how do I change my oil",  how do I get the sump screen out". "how do I jack my airplane", "I want to pull out my landing gear and disassemble it and paint it",  "how do I change my vacuum pump"

FAQs

[Flybeech21]

Sorry I have been absent to the post.  You guys have been busy!  

Progress report.  The ACO has received my letter and has notified an AMI in the FSDO that the process is happening.  I now have a decision making "fork in the road."  I have a friend that is almost complete with his M20C transition to Primary category.  He has agreed to allow me to use his freshly minted STC to use as a basis for approval for my M20E transition to Primary category.  So I either wait for him to complete his process and then have a streamlined avenue OR I proceed with my process from scratch.  I think I am going to wait for my friend to complete his process.  He is extremely knowledgable in the process as he has completed the process once before.  

As far as some of the posts I have been reading, I respect everyones opinion on this thread.  Primary category does not mean the airplane is now dangerous.  Anyone that thinks that is just wrong.  I purchased my M20E with a standard category airworthiness certificate and a "fresh annual" and it was one of the most unairworthy airplanes I have ever seen.  Category does not determine airworthiness.  

Going to primary category is a decision for the aircraft owner to make.  The standard of airworthiness does not change with primary category.  The aircraft must still conform to it's type design and be in a condition that is safe for flight.  PERIOD.  If you don't understand that then you shouldn't own an aircraft - Standard, Primary, Experimental, or otherwise.

For me this decision is an easy one.  I am going to primary category for the purpose of accessing more economical avionics.  My draft STC states that I will continue to maintain my aircraft IAW the Mooney maintenance manual and will conduct 100HR and Annual Inspections.

Resale value is a consideration for sure.  I don't ever plan to sell this Mooney but, I will cross that bridge if I have to.  Selling an airplane subjects you to all kinds of buyer scrutiny.  They gripe about about Tempest filters vs. Champion, Multi-Grade vs. straight weight, ECI vs. factory cylinders, so on and so on.  My airplane being primary category will undoubtably cause some scrutiny.  However, I am an A&P/IA and I take care of my aircraft.  This airplane will be no different.  I believe that the airplane will speak for itself if the unfortunate time comes that I must sell it.

I will keep you guys up to date as to my progress.  Sorry for being absent on the forum.

 

Edited March 17, 2020 by Flybeech21

[carusoam]

Chapter two...

Nice to see the first chapter get completed...

We can get past all the other issues brought up in chapter one... that’s all water under the bridge now... 

Good luck with the next steps... keep us in the loop...

Best regards,

-a-

[Jeph357]

Very interesting thread. Looking forward to hearing about it as the process continues.

[chriscalandro]

Watching

[cliffy]

Have you got any idea what avionics you will be looking at and they rough dollar savings you expect to see in the completed  project?

I'm following your quest with much interest. 

 

[Flybeech21]

3 minutes ago, cliffy said:

Have you got any idea what avionics you will be looking at and they rough dollar savings you expect to see in the completed  project?

I'm following your quest with much interest. 

 

I am looking at Dynon.  They have a great reputation with customer support and have certified equipment as well as experimental.  In my opinion, that means they have good quality control and are innovators.  

Edited March 17, 2020 by Flybeech21

[chriscalandro]

I too am planning on going Dynon when the economy rebounds. Pricing is basically the same plus the STC which I think is $2500. 
 

I can do most of it and get a signature. I’m not sure this is worth the 2500 savings. 

[Flybeech21]

1 minute ago, chriscalandro said:

I too am planning on going Dynon when the economy rebounds. Pricing is basically the same plus the STC which I think is $2500. 
 

I can do most of it and get a signature. I’m not sure this is worth the 2500 savings. 

Good point.  There are some other caveats.  If you want higher compression pistons, EFII system, non-tso'd engine motoring systems.  All kinds of engine modifications are available to you as well.  

[cliffy]

A license to "hotrod" the airplane :-)