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Thread: Skis & Floats: "Major Change" FAA CFR 21.93??

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    Member gderamel's Avatar
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    Default Skis & Floats: "Major Change" FAA CFR 21.93??

    I'm considering putting my CCEX CCK-1865 on floats (Clamar 2180 amphibs) and/or skis. Anyone know if this requires getting back into Phase I? My Special Operating Limitations (in part) state:

    “14. After incorporating a major change as described in § 21.93, the aircraft owner is required to reestablish compliance with § 9l.3l9(b) and notify the geographically responsible FSDO of the location of the proposed test area."

    Reading paragraph (b)(3) of CFR 21.93, if I understand it correctly, seems to exempt Propeller Land aircrafts reconfigured with floats or skis. Correct?

    14 CFR § 21.93
    (a) In addition to changes in type design specified in paragraph (b) of this section, changes in type design are classified as minor and major. A “minor change” is one that has no appreciable effect on the weight, balance, structural strength, reliability, operational characteristics, or other characteristics affecting the airworthiness of the product. All other changes are “major changes” (except as provided in paragraph (b) of this section).


    (b) For the purpose of complying with Part 36 of this chapter, and except as provided in paragraphs (b)(2), (b)(3), and (b)(4) of this section, any voluntary change in the type design of an aircraft that may increase the noise levels of that aircraft is an “acoustical change” (in addition to being a minor or major change as classified in paragraph (a) of this section) for the following aircraft:

    (3) Propeller driven commuter category and small airplanes in the primary, normal, utility, acrobatic, transport, and restricted categories, except for airplanes that are:


    (i) Designated for “agricultural aircraft operations” (as defined in § 137.3 of this chapter, effective January 1, 1966) to which § 36.1583 of this chapter does not apply, or


    (ii) Designated for dispensing fire fighting materials to which § 36.1583 of this chapter does not apply, or


    (iii) U.S. registered, and that had flight time prior to January 1, 1955 or


    (iv) Land configured aircraft reconfigured with floats or skis. This reconfiguration does not permit further exception from the requirements of this section upon any acoustical change not enumerated in § 21.93(b).

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    Default Re: Skis & Floats: "Major Change" FAA CFR 21.93??

    The key is in the first sentence. Paragraph (b), and all the subsections thereof, are only applicable "For the purpose of complying with Part 36 of this chapter..." meaning noise standards. for other purposes, you're still in paragraph (a).

    Floats, and especially amphibious floats, are a major change (they change the operational characteristics of the aircraft). You could probably argue that fixed penetration skis are not a major change, but certainly hydraulic wheel skis would be for the same reason.

    When we install floats or hydraulic retractable wheel skis here at the factory on a E-LSA or EAB, it's back to Phase 1 for 5 hours.
    Last edited by Brad Damm; 12-13-2016 at 08:57 PM.
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    Member gderamel's Avatar
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    Default Re: Skis & Floats: "Major Change" FAA CFR 21.93??

    Quote Originally Posted by Brad Damm View Post
    The key is in the first sentence. Paragraph (b), and all the subsections thereof, are only applicable "For the purpose of complying with Part 36 of this chapter..." meaning noise standards. for other purposes, you're still in paragraph (a).

    Floats, and especially amphibious floats, are a major change (they change the operational characteristics of the aircraft. You could probably argue that fixed penetration skis are not a major change, but certainly hydraulic wheel skis would be for the same reason.

    When we install floats or hydraulic retractable wheel skis here at the factory on a E-LSA or EAB, it's back to Phase 1 for 5 hours.

    Thanks, Brad!

    Follow up question: Once you've made the initial float installation and re-completed your Phase I, does one need to repeat the Phase I EACH time/season the floats are installed and/or removed? Or, just that first time and thereafter just simple logbook entries noting the installation?

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    Senior Member Dan L's Avatar
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    Default Re: Skis & Floats: "Major Change" FAA CFR 21.93??

    I asked this question to the Helena FSDO when I first put wheel penetration skis on my EX. I was told it did not have to go back into Phase One.
    Flying Carbon Cub EX #11 since 2011

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    Senior Member Springloaded's Avatar
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    Default Re: Skis & Floats: "Major Change" FAA CFR 21.93??

    We have put a couple of CC on floats down here in FL. Seems FSDO don't all seem to be on same page. We installed a set of Aerocets on a CC FX Down here in Florida and I ended up in a conference call with owner and 2 people from Miami FSDO which told me I didn't and don't need to put back in phase 1 for float installation. We still do though with every install per CCI recommendation.
    Last edited by Springloaded; 12-14-2016 at 11:58 AM.
    Chuck Kinberger
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