I got ramp checked!

[Big Ed]

A while back, on one of the threads in this forum, I expressed my skepticism that ramp checks were a realistic concern. Well, the universe has a sense of humor.

Last Friday I flew from Tampa up to Laurinberg, NC (KMEB) to pick up a friend. We then flew to Jacksonville, NC (KOAJ) for a short event, and returned to Laurinberg that evening. I started getting sporadic low voltage messages from my AHI. By the time I finished the last leg, I was getting low power messages on my radio and my landing light didn't work. It be was late, so I got a hotel room and decided to sort out out the next day.

The next morning, Saturday at 9am, I went to the airfield with my friend. He brought a battery booster cart and a generator. My plan was to charge up the battery for an hour and fly back to Tampa. First, we decide to look at the charging system to see if there are any obvious issues, so we pull the cowl off.

We are standing by the plane on the ramp. Nobody else is at the airport, and everything is closed. A guy walks up and introduces himself. He is an FAA maintenance inspector and was passing by. He asks if one of us is an A&P. I explain what we are doing, and he helps us take a look. Eventually we determine the alternator is inop. Then we start discussing what to do.

I say that I don't need an electrical system to fly in day VFR in class E below 10K. He says that he does not think it is legal or safe for me to fly. He takes a picture of my registration and pilot certificate, then leaves. So now I am in a bad position. If I fly, and he follows up to ask for documentation of what repairs I did, I have no defense. But I am in the middle of nowhere, with no access to parts or an A&P on the weekend.

Eventually I decided to get a hotel room and have the repairs done. I find a local A&P who travels, and order a voltage regulator and alternator from aircraft spruce on Monday. I pay $250 for next day air shipping so it will arrive by Tuesday noon. Thanks to a big snowstorm in PA, it does not arrive until yesterday at 4pm. We install the parts last night, troubleshoot this morning, and I fly home.

The guys who run the airport said that the FAA has not visited in the 30 years they have been there. What are the odds? Thanks to that friendly visit, I spent 5 nights away from home in rural NC, and spent about $1000 on hotels and shipping cost.

 

[Bob Turner]

Wow!

Technically he was correct - you cannot fly with known inoperative equipment. A good guy would have just not asked or followed up. Might have been a younger guy - sometimes it takes a while for reasonableness to sink in.

We had a situation (statute of limitations is up) where we had a non-stanfard exhaust pipe failure, and had to remove the alternator to get the new ($1000) stack on. Flew it home that way with the fan belt zip-tied. A fed would have put us in jail. Perfectly safe operation.

 

[Bob Turner]

Oh - the odds? Suppose your ADS-B started giving an error message? And remember, there are half as many of us and five times as many of them.

 

[Big Ed]

Don't get me wrong, he was a nice guy, and he doesn't make the rules. He spent about an hour helping us look at the plane, and made some calls to link me up with an A&P. He did not explicitly say I could fly or not fly. I think he probably was in a bad position too. If he said to fly, and I had a mishap or violation, he's responsible. He was an older guy, but had spent most of his career in the Coast Guard working on C-130s and helos. A 2 seat tube and fabric airplane in day VFR is just out of his comfort zone.

My complaint is with the arcane and inflexible nature of the regs. It took a great deal of research to get a confident answer on the legality of flying in that condition. And there is no room for pilot or mechanic discretion. I get that you don't want field guys making engineering decisions on airliners or complex IFR aircraft. But it should not take a week and cost thousands of dollars to get home in a Decathlon with a charging issue.

 

[Bob Turner]

I agree - once in a while rules are bent. The big deal is not an FAA letter in your file; it is your insurer, and what happens to coverage.
Here in Calif, whatever is judged non-airworthy has to be a proximate cause, or the insurer cannot deny coverage. But then, we have a "different" outlook.

 

[Tangogawd]

Review 91.213(d)

I this case, pull Alternator circuit breaker, and make a "Inop" label on a piece of tape.

If Friendly Fed doesn't agree, kindly ask to show you where in 91.205, the type cert, or an AD that says the Alternator is required. Because my interpretation of .213 says I can.

Remember, just like us, the inspectors opinions dont mean anything, they have to prove in writing, acceptable to the administrator, what they say is right.

Sorry this cost you valuable time and money, I guess that is the ultimate goal of the inspectors, prevent people from committing aviation.

 

[Big Ed]

If Friendly Fed doesn't agree, kindly ask to show you where in 91.205, the type cert, or an AD that says the Alternator is required. Because my interpretation of .213 says I can.

FAR 91.213(d) excerpt:

(d) Except for operations conducted in accordance with paragraph (a) or (c) of this section, a person may takeoff an aircraft in operations conducted under this part with inoperative instruments and equipment without an approved Minimum Equipment List provided -
...
(2) The inoperative instruments and equipment are not -
...
(ii) Indicated as required on the aircraft's equipment list, or on the Kinds of Operations Equipment List for the kind of flight operation being conducted;

I have an equipment list in my FAA-approved Aircraft Flight Manual. The alternator is listed as required for certification.

 

[Tangogawd]

I have an equipment list in my FAA-approved Aircraft Flight Manual. The alternator is listed as required for certification.

And that may be so. A lot of older aircraft have no such list, or the equipment list has only 91.205 items as required. its worth knowing

 

[Bob Turner]

So, question: if your alternator is on the MEL (not likely, of course) can a pilot disable and placard, or is that not one of those things listed as ok for pilots to do and log?

 

[aftCG]

While the flight could have been conducted safely, I think placarding it and pulling the circuit breaker wouldn't pass the sniff test of 91.213.

However, it could have been your lucky day because that FAA dude was the one guy who could have signed a Special Flight (aka "ferry") Permit mentioned in 91.213(e), and let you fly it home all legal like.

 

[Tangogawd]

So, question: if your alternator is on the MEL (not likely, of course) can a pilot disable and placard, or is that not one of those things listed as ok for pilots to do and log?

The MEL, which actually is a list of things that CAN be broken, will specify what action to take (pull circuit breaker) and who can do it (mechanic or pilot).

So, my interpretation,

91.213
(d) i go here because I don't have a MEL, a person may takeoff under this part (91-not for $$) with broke things provided,

(1) flight is conducted in a​

(i) non-turbine-airplane where no MEL was developed, (my 7GCBC)​

(ii) or SMALL non-turbine-airplane with an MEL (7gcbc is small, but no MEL)​

and​

(2) the broken things are not​

(i) part of the type cert of the aircraft required for VFR-day (nope)​

(ii) on the aircraft equipment list as required (don't have one)​

(iii) required on 91.205 (not this broke thing)​

(iv) required by AD (nor this)​

and then

(3) broke thing is , either
(i) removed (probably might need A&P), cockpit control labeled and maintenance recorded (this can be a piece of scrape paper in my shirt pocket) Part 43 doesn't say where, just what)

or

(ii) deactivated (pull breaker) (hasn't it already self-deactivated?) and placarded. IF, again, IF deactivation involves maintenance (pulling a breaker is a pilot preventative task, thus acceptable to the administrator), record it. (some would argue that pulling a breaker is not maintenance, but if one disagrees, write it down and put it in your pocket)

(4) and finally, if a pilot (me) says its safe, we fly.

so at least with my plane, I say I can fly with a broke alternator. Now the type cert does say I need a mixture control, I could safety the mixture full open, like an old stromburg carb, but I would need a ferry permit 91.213(e)

Your mileage and interpretation may vary

 

[Bartman]

alternatively, if, after the FAA Inspector left, you reset the CB for the alternator, ran the engine and found the battery was being charged, if it failed enroute you'd be free to complete the flight. or if you did any simple adjustment (pulled and reseated the battery cables, for example) and found it worked, you could start the flight legally.

 

[Big Ed]

alternatively, if, after the FAA Inspector left, you reset the CB for the alternator, ran the engine and found the battery was being charged, if it failed enroute you'd be free to complete the flight. or if you did any simple adjustment (pulled and reseated the battery cables, for example) and found it worked, you could start the flight legally.

Considered that, but the clock was ticking. By the time the FAA left the airfield it was after noon. The flight takes 4 hours and 30 minutes, and it gets dark at 6:30. So I had at most 2 hours to research the regs, make a decision, and launch. Really less than that, as arriving in Tampa as twilight with a weak electrical system would not be smart. Lots of traffic and inside the mode C veil. Not the time to rush a decision.

That was Saturday. That night, IFR weather moved in and lasted thru Monday. I ordered the parts on Monday with the intent of getting them Tuesday by noon, installing that afternoon, and returning home that evening with a functioning electrical system. Spent another day waiting on shipping delays. Installed everything by Weds dinnertime, but couldn't get it to work properly until Thursday morning. Everything just kind of piled up on me.

But I did get to hang with the Golden Knights pilots and watch several hundred military training jumps. One of the GK pilots caught the bug checking out my plane.

 

[Big Ed]

Twin Otter jump bird

 

[Big Ed]

LOL, I got ramp checked AGAIN!

Stopped at a rural airport in Nowhere, Georgia for gas. Nothing but a shack and a pump. There was a medevac helo there and am ambulance doing a patient transfer. A small crowd of 6-8 people were watching, most of them presumably family members.

One guy comes over and starts complimenting me on the plane. He asks if he can get a closer look and I say of course. He sticks his head in the cockpit for a while, then says thanks, and oh by the way do I have my pilot certificate on me. At that moment I noticed the FAA badge and lanyard around his neck.

All uneventful and harmless, but I highly recommend not hanging out on ramps with me. I am a Fed magnet.

 

[aftCG]

Too funny. You would think that would be the last place to get ramped.

Not quite two weeks ago I was supposed to ferry the '49 Yak 18 I mentioned elsewhere. Well I got there and it was a real museum piece of an airplane, but the paperwork wasn't clean. Annual (condition inspection) wasn't signed off and then the airworthiness cert (experimental exhibition) with the letter of authorization and FAA registration were lost. The latter two items surfaced by the time I got there but still no annual. And oh by the way I never saw a W&B.

"Airworthiness" is a definition debated almost as much as engine oil and there seem to be two camps. One thinks a plane is airworthy if it is in good mechanical condition, all the stuff works, controls free and correct, runs well, no significant corrosion or damage, etc. The other camp thinks the plane is airworthy if it has an airworthiness certificate and a current annual inspection. I guess because those two things should result in the plane matching the first description.

I've flown some seriously derelict s*** that had good paperwork. This plane seemed mechanically flawless. I'm not going to say I was pressured into flying the plane without the sign off but it was offered as a possibility - which I declined. Any type of incident or ramp check and it would all lay on my shoulders.
The discussion meandered towards getting a ferry permit but I used the clear wording in the sales agreement that stated the annual would be complete to get back on an ERJ and go home.

Another story from last year. I had a student seeking his tail wheel endorsement and I was providing him dual in my Citabria. He mastered his 3 point landings and we were working on wheel landings when he bought a Kitfox IV. I didn't have enough Kitfox time to get on his insurance and that was the last I heard of him for a while.

Fast forward a couple months and I was chatting up one of my airport neighbors/fellow Kitfox builder. We were walking towards my hangar and saw an older Kitfox in front of the restaurant, so we decided to look it over. Just our luck, the owner was preflighting and had his back turned to us.

I couldn't avoid an opportunity so as we got close I said "Hey, is this your first ramp check?". Dude was white as a sheet when he turned around, and it was my former student. I'm guessing he hadn't gotten around to finishing his training.

 

[Bob Turner]

The FAA can swat your fingers. What you do not want to do is step in an expensive aircraft without insurance. Some policies state that it must be airworthy for coverage.
Be careful on ferries - get it in writing.

 

[Hiperbiper]

Some people just LOOK guilty...ya know?

Chris