NetHeads,  

A few weeks ago we had a discussion (maybe more of a debate) on what paperwork 
was required after putting a new engine in an experimental plane, like I did 
last weekend.  I'm not sure that we ever answered it definitively.  This week I 
called the FSDO and asked them, and although it took him a while to come up 
with an answer (he had to call me back), he told me to abide by my operational 
limitations provided at the time my airworthiness certificate was awarded.  
Since they are all the same (at least in Alabama), he read it to me over the 
phone and offered his clarification.  Here's what paragraph19 says:

"After incorporating a major change as described in FAR 21.93, the aircraft 
owner is required to re-establish compliance with FAR 91.319(b) and notify the 
geographically responsible FSDO of the location of the proposed test area.  The 
aircraft owner must obtain concurrence from the FSDO as to the suitability of 
the proposed test area.  If the major change includes installing a different 
make and model of engine or propeller, the aircraft owner must fill out a 
revised Form 8130--6 to update the aircraft's file in the FAA Aircraft 
Registry.  All operations must be conducted under day VFR conditions in a 
sparsely populated area.  The aircraft must remain in flight test for a minimum 
of 5 hours or for the time the FSDO assigns. [I would assume that it would be 
prudent to call the FSDO and verify that they concur with 5 hours].  Persons 
non-essential to the flight must not be carried.  The aircraft owner must make 
a detailed logbook entry  describing the change before the test flight.  
Following satisfactory completion of the required number of flight hours in the 
flight test area, the pilot must certify in the records that the aircraft has 
shown to comply with FAR 91.319(b).  Compliance with 91.319(b) must be recorded 
in the aircraft records with the following or similarly worded statement: "I 
certify that the prescribed flight test hours have been completed and the 
aircraft is controllable throughout its normal range of speeds and throughout 
all maneuvers to be executed, has no hazardous characteristics or design 
features, and is safe for operation.  The following aircraft operating data has 
been demonstrated during the flight testing:  speeds Vso___, Vx____, and 
Vy____, and the weight____ and CG____ location at which they were obtained."

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He made it clear that unless I was changing the engine make or model, I was not 
making a "major change", and that I would not have to file any paperwork, just 
make the two logbook endorsements mentioned above.  This is what I did last 
time around as well.  It's good to know that I haven't voided my airworthiness 
certificate along the way.

Just for kicks I called my DAR for his take on it (and the FSDO recommended 
that he was really the "expert" on the subject anyway).  He said the newest 
version of operating limitations call a major change "conversion from piston to 
turbine engine", and doesn't even mention make, model, or propeller.  He also 
said all I needed to do was note the change in my log book and go flying, 
although it would be smart to stay within gliding distance of an airport for a 
little while.  He also said a prop swap is only a logbook entry, not involving 
a test area.

This form may be different for different FSDO's but it would be interesting how 
it compares with the operating limitations that others were given.  My guess is 
that they are all the same, but the FSDO's and DAR's interpretations may vary 
widely, so check with them if there's any question...

Mark Langford, Huntsville, Alabama
see KR2S project N56ML at http://home.hiwaay.net/~langford
email to N56ML "at" hiwaay.net
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