FAA letter: Confirming that changing a gear floor light by owner is legal

[willerjim273]

Hola,

1980 M20K

I have a letter from the FAA re: an "occurance" recently at KBJC. I had no floor light, so I had the tower confirm the gear was down. I landed and left the plane tied down for about a week due to absurd winds we had.

 

Once back at home base, panel removed to replace the bulb. Noticed that the bulb was intermitent when wiring moved. Replaced the bulb, reconnected. Should be good to go. 

 

I figured it was a pretty standard "occurance" (word used in FAA letter). The letter asked me to call FSDO. I did. He asked a lot of questions. Now he wants copies of liscense, medical and log entry. No problem.

 

Like to get opinions on whether he may be setting me up some how. I understand bulbs are an owner item.

 

What say this group? 

 

Thanks

 

Paranoid Jim

 

[Shadrach]

I would talk to AOPA legal. This smells like a fishing expedition. I don’t say this out of paranoia, I say it out of experience. A pilot very close to me was absolutely mistreated by an FAA investigator for briefly losing comms with ATC while on a IFR flight plan. 
 

The long and short of it is that he was flying along in IMC fat dumb and happy when it occurred to him that he probably should’ve been handed off to the next controller. He calls Jacksonville on the last assigned freq. No answer. He finds a new freq and reestablishes communication. Several days later he gets a call from a FSDO down south. No charges were ever filed but they were threatened.  Tone was intimidating initially but softened after a lawyer began handling communication. Investigation was closed shortly there after. Investigator was a first class prick. He used terms like negligence, endangerment and intentionally. None of them came close to applying to what actually took place.

Edited May 4, 2022 by Shadrach

[Mooneymite]

1 hour ago, willerjim273 said:

I have a letter from the FAA re: an "occurance" recently at KBJC. I had no floor light, so I had the tower confirm the gear was down. I landed and left the plane tied down for about a week due to absurd winds we had.

Once back at home base, panel removed to replace the bulb. Noticed that the bulb was intermitent when wiring moved. Replaced the bulb, reconnected. Should be good to go. 

I figured it was a pretty standard "occurance" (word used in FAA letter). The letter asked me to call FSDO. I did. He asked a lot of questions. Now he wants copies of liscense, medical and log entry. No problem.

Like to get opinions...

 

I'm just guessing the issue may be how you got access to the bulb rather than the bulb replacement itself....

Does the owner pilot have carte blanche to disassemble/reassemble his plane in getting to a bulb?  Access to the floor light involves removing and replacing at least one belly skin.

That question may be at the heart of the matter.  

Edited May 4, 2022 by Mooneymite

[N201MKTurbo]

I wouldn't mention the bulb. I would just reply with the facts of the occurrence. You don't owe them any more.

Your replacing the bulb happened after the occurrence, so it has no bearing on it.

 

[McMooney]

is the issue you contacted tower regarding your gear status or that you changed a lightbulb?

My guess it's about contact with ATC.  

Answers for Pilots: Preventive Maintenance - AOPA

there are also a number of letters where an FAA rep has stated they cannot give an exhaustive list of owner maintenance. 

[mooniac15u]

Is there going to be a potential issue with flying home with the landing gear light inop?

Before the typical Mooneyspace pile-on starts, I'm not saying it's dangerous or should be a problem but once the FAA is involved could they see it that way.

[N201MKTurbo]

I believe you are required to respond to these letters. The response can be:

"Thank you for you interest in this occurrence. I appreciate your dedication to air safety."

End of response......  

[willerjim273]

Thanks everyone,

He is asking for copies of certificate, medical, and logbook entry for the light bulb replacement. I have read part 14 CFR Part 43, Maintenance, Preventive Maintenance, Rebuilding, and Alteration enought, I think, to know that I can make log entry and sign off. Any suggested language? 

 

I just renewed my AOPA, will call them as well. 

 

Thanks

 

[mooniac15u]

5 minutes ago, willerjim273 said:

Thanks everyone,

He is asking for copies of certificate, medical, and logbook entry for the light bulb replacement. I have read part 14 CFR Part 43, Maintenance, Preventive Maintenance, Rebuilding, and Alteration enought, I think, to know that I can make log entry and sign off. Any suggested language? 

 

I just renewed my AOPA, will call them as well. 

 

Thanks

 

Have you already signed the logbook entry?  Do you have an A&P who would be willing to sign off your work?  I realize that might not be necessary but it wouldn't leave the FAA with anything to complain about.

[Shadrach]

With the floor indicator have been readable had you had a flashlight? 

[A64Pilot]

1 hour ago, Mooneymite said:

I'm just guessing the issue may be how you got access to the bulb rather than the bulb replacement itself....

Does the owner pilot have carte blanche to disassemble/reassemble his plane in getting to a bulb?  Access to the floor light involves removing and replacing at least one belly skin.

That question may be at the heart of the matter.  

I was an A&P prior to being a civilian pilot so I never figured out all the rules, but I’m pretty sure that a pilot is allowed to remove inspection panels, and that’s all the belly skin is, it’s not structural.

You have to remove the cowling to change oil, what’s the difference?

I wouldn’t do anything until I contacted AOPA legal

I’ve never seen the FAA do anything over something so trivial, it was always really about something else.

In this case I think it’s that you flew a broken airplane without a ferry permit 

Edited May 4, 2022 by A64Pilot

[A64Pilot]

53 minutes ago, mooniac15u said:

Have you already signed the logbook entry?  Do you have an A&P who would be willing to sign off your work?  I realize that might not be necessary but it wouldn't leave the FAA with anything to complain about.

Except they go after him for falsifying the records, which is a pretty big deal.

If you do this make darn sure he knows about the FAA part, no way I would

Pretty sure AOPA legal is your best bet, don’t do anything until you talk to them.

On edit I’m pretty sure the inspector is under the impression that the only way you know the gear is down is the light, but that’s not our lights function, it merely makes the indicator more visible. If it’s not too late I’d say I flew the second time with a flashlight so that I could see the indicator.

Edited May 4, 2022 by A64Pilot

[cferr59]

 

1 hour ago, mooniac15u said:

Is there going to be a potential issue with flying home with the landing gear light inop?

Before the typical Mooneyspace pile-on starts, I'm not saying it's dangerous or should be a problem but once the FAA is involved could they see it that way.

That is the only thing I see as a potential issue here. I don't think the airplane is technically airworthy with the gear light inop.

If it is an issue for the FAA, I recommend having an attorney clarify that the bulb was working again for the flight home and that he checked the bulb out of an abundance of caution discovering the intermittent bulb issue.

[kortopates]

9 minutes ago, A64Pilot said:

On edit I’m pretty sure the inspector is under the impression that the only way you know the gear is down is the light, but that’s not our lights function, it merely makes the indicator more visible. If it’s not too late I’d say I flew the second time with a flashlight so that I could see the indicator.

I beg to differ, the light isn't just to illuminate  the window, it's to show you have the required pre-load on the gear to hold it down based on gear extension to the point the down limit switch has closed. If you hand cranked it down without either the light in the panel or the light on the floorboard to indicate this, you wouldn't really know when it was down enough and risk undershooting where it could fold on you (such as while turning to exit runway), or over shooting where you could bend a retract tube. If I was in that situation, I would make by best guess for how far to go with the manual extension by remembering the "normal" position, then after landing,  stop on the runway and call for aid to very gently tow it off after visually inspection the gear and bungee springs for compression rather than risk the gear folding and a prop strike - which will total a great many Mooney's. Call me paranoid if you like but no need to risk it IMO.

[A64Pilot]

We are talking about the floor light aren’t we? But either way I wouldn’t go through that with the FAA as it reinforces it shouldn’t have been flown prior to being repaired.

‘But so far as limit switch, it turns off the actuator, so if something stopped the gear prior or the switch is bad a CB is popping soon.

 

Edited May 4, 2022 by A64Pilot

[kortopates]

1 hour ago, cferr59 said:

I don't think the airplane is technically airworthy with the gear light inop

Definitely not, both position indicator lights are required and listed in the KOEL of the more modern Mooney POH for any operation. 

Plus even for older Mooney's there is a Mooney SB or SL to add a one page insert into POH to say the Floor indication is Primary, not the panel. 

Edited May 4, 2022 by kortopates

[kortopates]

5 minutes ago, A64Pilot said:

We are talking about the floor light aren’t we? But either way I wouldn’t go through that with the FAA as it reinforces it shouldn’t have been flown prior to being repaired

I think the cat is out of the bag given the inspector is requesting the log book entry for replacing the gear indicator light bulb.

I wouldn't necessarily jump to the conclusion that the inspector is out to get the pilot yet. Its the responsibility for any inspector to verify the issue (light bulb) has been properly corrected and logged; as others have said before further flight without a ferry permit. Since its obvious that didn't happen I wouldn't volunteer a lot of unnecessary info but perhaps plead you still had the other light bulb (even though it isn't legal) and express what you learned from the experience if pushed. But agreed AOPA Legal is your best source of advice.

[Rjfanjet]

I have a friend with an Arrow. He had an issue with the gear bulb and had the trucks roll out when he landed. The FAA just wanted to see a corrective action in the logbook for fixing the light.

[PT20J]

For my M20J, the POH Kinds of Operation Equipment List only lists the “landing gear position indicator” as being required. It doesn’t mention the light bulb illuminating the indicator or the annunciator panel (which is described as part of the gear warning system).

[willerjim273]

OK,

 

I think Turbo hit it pretty well. Just keep it to the gear fly-by. As I was taxing to the FBO, the CRASH crew and ground were talking. I am guessing they need certain answers once CRASH is alerted. They were on the ramp ready to go rescue me. So tower told them the gear looked good, but get ready just in case-basically. 

 

There has been no mention of the flight home yet.

 

I am waiting for a call from AOPA lawyer. 

 

IF they make a deal out of the flight home, the K model I have has the annunciator gear down light as well. So - 2 lights. All I told him on the phone was that 1-  I put in a new bulb, 2-  that moving wires going to the bulb assembly DID cause intermitency, 3- and it works fine now. Nothing else discussed.  

 

Tks,  Best Regards,

paranoid 

 

 

[Fly Boomer]

1 hour ago, A64Pilot said:

I wouldn’t do anything until I contacted AOPA legal

This is the best advice you will get.

[Aerodon]

I am told that all 'mechanical' diversions are reported to the FAA and that someone looks over the list and decides whether to follow up or not.  I would imagine that all emergencies are too, or anything that generates an incident report.  So I work on the assumption that it is going to happen.

So, with any incident, it is reasonable to enquire about the airplane and its recent maintenance history.   Even the pilot, was he qualified to fly, insurance etc.  No different to a traffic stop, rules might be different in different states.

And then was the problem properly fixed before the next flight.  In Canada it is well defined, a pilot is allowed to perform the following elementary work.

(17) removal and replacement of fuses, light bulbs and reflectors;
(21) opening and closing of non-structural access panels;

This would allow me to remove the one piece belly panel and replace a bulb.  Then sign the journey log and I am done.

But jiggling the wire to get it working again is not covered, and I am not qualified as a pilot to do that repair.  And the bulb needs to be purchased through an approved supplier.

On the M20K the floor bulb and annunciator light are in parallel.  The POH shows that the gear position indicator is required for VFR flight.  I would argue that the position indicator was working and at least 1 of the two lights was working.  I would also argue that a flashlight could be used to check the position indicator.

I do not know the FAA rules as well.  But I suspect 'jiggling the wire' is not an approved repair, and if you did no logbook entry and flew, you have created an issue for yourself.  Fessing up on the internet has created a paper trail, make no mistake the FAA reads through these blogs.

I suspect and hope that it all turns out well for you.

Personally, I think a tower fly by is a dumb thing to do.  Know your airplane, listen to the gear going down, feel the clunk etc.  Know your systems, if you have a second annunciator and it is working, there was no need to say anything to the tower.

And if you 'alert the tower', don't be surprised if they escalate to a full emergency whether you declare or not.  They don't need much of an excuse, and there's no upside on waiting until you do a wheels up or worse before calling the equipment.

And the lesson to all of us, if you've opened the can of worms, make sure you do everything right afterwards.  More than one plane has crashed after the owner has done some enroute repairs.  And more than one jet has crashed because of landing light bulbs not working.

 

Aerodon

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

[toto]

59 minutes ago, PT20J said:

For my M20J, the POH Kinds of Operation Equipment List only lists the “landing gear position indicator” as being required. It doesn’t mention the light bulb illuminating the indicator or the annunciator panel (which is described as part of the gear warning system).

I had no idea that there *was* a light bulb in the floor indicator until more than a year after I bought my J.  The mechanical indicator is easy to see in the daytime, and at night it's easy to see with a flashlight.  When the burned-out bulb was caught during the second annual, I was surprised that the light bulb existed - who knows how long it was out.  If this is an airworthiness item, I definitely want an LED.  Or two or three.

In any case, I have always read the flight manual as requiring the mechanical floor indicator, not requiring the light bulb.

[Guest]

It sounds to me that this FSDO may have an over staffing issue if they have time to investigate things like this.

Clarence

[A64Pilot]

2 hours ago, kortopates said:

Definitely not, both position indicator lights are required and listed in the KOEL of the more modern Mooney POH for any operation. 

Plus even for older Mooney's there is a Mooney SB or SL to add a one page insert into POH to say the Floor indication is Primary, not the panel. 

This often happens. Neither the SB or SL is mandatory, but the moment you put it in the POH as it IS mandatory, the SB in effect just became mandatory.

FAA determined on an Audit that way back in the day BD Maule didn’t properly load test the baggage compt and Maule didn’t have the money to retest and as there had never been any problems allowed Maule to issue a “mandatory SB” Maule sent it to all owners, it had a page to replace the one in the POH and a placard to replace the one in the baggage compt. If you complied with the SB you significantly decreased the usefulness of the airplane as both the POH and Placards are mandatory, so I threw it in the trash.

But if the limit switch drives both lights, what’s the logic of requiring both lights? What drives the Caution light?

Edited May 4, 2022 by A64Pilot