Mailing List lml@lancaironline.net Message #26612
From: Marvin Kaye <marv@lancaironline.net>
Subject: flight testing
Date: Mon, 15 Nov 2004 03:26:14 -0500
To: <lml>



Posted for "Jim Auman" <jimauman@comcast.net>:

 I will go one step farther and point you all to the "Program Letter" ,
Reference 8130.2E Change 3 Section 6 Paragragh 122 Eligibility.
 
 Therein it states what the applicant "must" do.
 
 "The letter must be detailed enough to permit the FAA to prescribe the
conditions and limitations necessary to ensure safe operation of the aircraft.
 The letter should not describe everything in minute detail."
 
 Your operating limitations will be driven by what you state in your program
letter.  If you wish to flight test in Class A airspace on an IFR flight plan
then state it in your letter with proper reasons to support your contention.
 
 You are the applicant and test program applicant.  You don't ask for it, you
won't get it.  DAR's have  some latitude to assign you a nonstandard test
area.  You have to put forth a convincing defence of the necessity that fully
protects the public safety.
 
 That kind of high altitude flight should never be advised until later in the
test program anyway until all other flight modes have been thoroughly tested
and discrepencies remedied.
 
 Again, You are the applicant.  Prove what you want to do to the DAR.  We are
all assigned to a Principal Inspector that authorizes our visits to you.  We
have to prove to the Principal that your program meets or exceeds FSDO/MIDO
standards in the interest of the public safety.  Order 8310.2E Change 3 (now
old) and the recent 8130.2F are the standards that you will be judged against.
 On this subjesct, both are almost identicle.
 
 Draft a program letter that says exactly what you want to do and you may find
that those items will turn up in your limitations.  At least it will open a
dialogue that will lead to your limitaions.  We are not bad people here.
 
 Our job is to issue Special Airworthiness Certificates.  Your job is to
build, test, and operate aircraft safely.  You have to convince us, the DAR or
ASI, that you conform to those subjects that protect public safety.
 
 Jim Auman  (DAR)
 
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