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FAA Rule changes 8130.2j certification

I want to share my current experience with the Fsdo. The issue I have encountered can affect all jet owners. First, there does not appear to be a written policy for handling either (a) relocating your jet from one fsdo to another or (b) a sale of the aircraft that would involve a relocation to another fsdo jurisdiction. The Operating Limitations clearly list a home base airport and a need to amend the Operating Limitations to support any change of operation base involving a different fsdo. Each fsdo seems to handle this differently. In my current experience, the fsdo basically wants to recertify the aircraft as a result Only of a location change. In my case the jet has been certified since 2004. Only a location change is happening. This takes me to the main point of this open letter. As a part of the process of transferring to a new fsdo they want to update the Operating Limitations to comply with the latest Certification guideline. Currently that is 8130.2j. The rewrite of the guideline in 2017 apparently added NEW language that requires the fsdo to determine whether to place the jet into a "High Risk" category. The Appendix D item F lists five criteria. The item 2 is new and a real problem. It states that any aircraft manual that requires a bailout or ejection for any failure including a fire should be classified as high risk. Every warbird emergency check list I have ever seen would Fall into this category based upon the FAA loose arbitrary interpretation. Ive appealed this and lost with no faa explanation. The wording of this f.2 needs to be expanded and clarified or removed all together. As this slowly becomes enforced fsdo to fsdo,everyone can become a victim. High Risk means no passengers, no night, no ifr and more. This organization needs to make a stand on this issue.

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2 Comments

  1. Karl Hutter

    Aug. 28, 2020

    Hello everyone. I'm new to the organization and looking forward to joining the community. Obviously, the post that Alex CJAA made is a concerning one for all of us. However, as I reviewed the text of 8130.2J Appendix D (which I have pasted below) it appears that it states that the "very high risk" scenario applies if a bailout or ejection is required if an engine or other system fails. While some aircraft, particularly single engine aircraft with hydraulic controls, certainly fall into this, the level of threat of having this applied is unclear. That in and of itself is troubling... Indeed, we need to get some attention on this and hopefully a resolution that is on the better side, not the worse. Stay safe, Karl Hutter (hopeful future T-38 driver) 8130.2J Citation f. Aircraft with very high risk factors or safety of flight issues must have those factors properly mitigated. Restrict operations to a specified geographical area, and prohibit the carriage of passengers, flight over densely populated areas, and night or instrument flight rules (unless restricted to visual meteorological conditions (VMC)) operations for any of the following conditions: (1) Aircraft for which the applicant has surrendered a special LSA airworthiness certificate (§ 21.190) and is applying for an experimental airworthiness certificate (§ 21.191) for the first time, and is not in compliance with § 91.327(b)(3) or (4); (2) Aircraft for which the manufacturer’s or country of origin’s emergency checklist requires bailout or ejection in the event of an engine or other system failure; (3) Any aircraft in which a single system failure will render the aircraft uncontrollable, such as an airplane with a hydraulic flight control system with only one hydraulic pump; (4) Aircraft unable to comply with § 91.117(a) in normal cruise configuration; and (5) Rocket-powered aircraft

  2. John Totty

    Jul. 12, 2020

    This seems like a very important issue for all of us, and yet I see zero replies. Anyone from CJAA leadership care to respond?