Piper Seneca iii Prop Deice INopt,airworthy or not? IA's and A/P's?

[Travis Schaefer]

Greetings to all!
I am in the first stages of setting up a prebuy on a Piper Seneca iii with full FIKI and I am wanting to know if the following is an issue...

The last annual had the prop heater breakers zipped tagged INopt and placard, "flight into known icing conditions prohibited " The fuel heater likewise... I am not planning on ever flying in known icing and hope I never end up there.

I am trying to find out if this aircraft is airworthy with the prop deice heater boots INopt. It was installed at the factory. Is the prop heat INopt legal to fly otherwise in normal conditions? I have been searching for data and info on this and have run aground. A few local IA's have been saying it is not legal, but this aircraft was signed off with it INopt in the logs from a decent size shop. If any IA's, A&P's, Prop Shops on here have any info on this, please throw it my way! If this is legal to fly, I'm good with this until I can get to replacing or fixing it.
Thank you!

 

[Caramon13]

What does the POH say? Is it on a MEL? Maybe you should read 91.213?

 

[Travis Schaefer]

I finally found it in the MEL! I overlooked it. Looks to be legal in other than known or forecasted icing conditions.

 

[MauleSkinner]

I finally found it in the MEL! I overlooked it. Looks to be legal in other than known or forecasted icing conditions.

As I’m sure you’re aware, the MMEL doesn’t apply unless you’ve been issued an LOA, so 91.213(d) would apply otherwise. I don’t think there would be any difference in application.

Technically I believe your IA will have to have a conversation with you every year if you don’t fix it. What’s actually wrong with it, and would you be better off to remove it than just defer it?

what’s a “fuel heater” in a Seneca?

 

[Bell206]

I am trying to find out if this aircraft is airworthy with the prop deice heater boots INopt.

To add to the above, so long as the INOP equipment is dealt with per 91.213(d) and reviewed every annual it can flown legally. And as mentioned, unless the FSDO has issued a MEL to your aircraft by S/N the MMEL you reference does not apply. Perhaps get an estimate to fix the items and negotiate that cost in the purchase price.

 

[Jim Carpenter]

A few things to note:
The MMEL is general guidance for listed items, but unless your aircraft is specifically authorized to operate with an MEL, (unlikely for Part 91 private aircraft), you're left with 91.213.
Either way, note that deice items in the MMEL are category C, to be repaired within 10 days.
Or, 91.405 requires repair or removal at 'next' inspection (annual, 100hr, etc.)
So, yes, OK to fly as long as you don't go into icing conditions, but you don't get to fly indefinitely with the placard/de-activation.
AC 91-67 provides detailed explanations, too. (But, I see that it's been 'cancelled' until further revision).

 

[Fracpilot]

As I’m sure you’re aware, the MMEL doesn’t apply unless you’ve been issued an LOA, so 91.213(d) would apply otherwise. I don’t think there would be any difference in application.

Technically I believe your IA will have to have a conversation with you every year if you don’t fix it. What’s actually wrong with it, and would you be better off to remove it than just defer it?

what’s a “fuel heater” in a Seneca?

I believe a simple visit to the FSDO with the MMEL in hand would generate the LOA to use the MMEL.


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[Bell206]

but you don't get to fly indefinitely with the placard/de-activation.

FYI: there has been a number of discussions on this and while the intent of 91.213(d) and 91.405(c) was not for an aircraft to fly "indefinitely" there is nothing in FARs to prevent provided the INOP item is "inspected" every scheduled inspection and 91.213(d) applied anew. There is one LOI, possibly 2 LOIs that state this.

 

[Bell206]

I believe a simple visit to the FSDO with the MMEL in hand would generate the LOA to use the MMEL.

It can be but usually there can't be any outstanding inoperative equipment issues prior to its issuance. But having an MMEL is not always the best route as it is much more restrictive than 91.21(d). For example, in this case while the prop deice system is listed, it is a Cat C item which requires the system to be fixed within 10 consecutive calendar days or 250 hours. If not then the aircraft is AOG.

 

[Travis Schaefer]

As I’m sure you’re aware, the MMEL doesn’t apply unless you’ve been issued an LOA, so 91.213(d) would apply otherwise. I don’t think there would be any difference in application.

Technically I believe your IA will have to have a conversation with you every year if you don’t fix it. What’s actually wrong with it, and would you be better off to remove it than just defer it?

what’s a “fuel heater” in a Seneca?

I would rather keep it and fix it than remove it. The annual involving this didn't specify the issue. The janitrol heater is what I was referring to as a fuel heater.

 

[MauleSkinner]

It can be but usually there can't be any outstanding inoperative equipment issues prior to its issuance. But having an MMEL is not always the best route as it is much more restrictive than 91.21(d). For example, in this case while the prop deice system is listed, it is a Cat C item which requires the system to be fixed within 10 consecutive calendar days or 250 hours. If not then the aircraft is AOG.

The deferral categories only apply to Air Carrier OP’s...part 121, 135, etc. when operating under Part 91, they don’t apply.

I would rather keep it and fix it than remove it. The annual involving this didn't specify the issue. The janitrol heater is what I was referring to as a fuel heater.

Ah, ok...I was kind of wondering if you were referring to the Janitrol heater.

 

[Bell206]

The deferral categories only apply to Air Carrier OP’s...part 121, 135, etc. when operating under Part 91, they don’t apply.

My bad. I was thinking of 91K and 91.213(c). Good catch.

 

[JAWS]

I'd almost be more concerned about the inop janitrol than the prop deice. Janitrols need constant attention, especially the jet fueled ones. That is why Chieftains often have two, when one quits the other will keep going until on approach!

Prop deice is relatively easy. Boots, brushes, timer.

 

[Travis Schaefer]

I'd almost be more concerned about the inop janitrol than the prop deice. Janitrols need constant attention, especially the jet fueled ones. That is why Chieftains often have two, when one quits the other will keep going until on approach!

Prop deice is relatively easy. Boots, brushes, timer.

Yeah, I've worked on Jani's before. The deice, on the other hand, 4 to 5k for boots for each prop if bad... The owner is going to test them to make sure they work. I did find out from the owner also, the shop that did the annual gave him the option to leave out the prop heat and the Jani heater to reduce the initial annual inspection cost as they said it was not a required item. Background checked the shop and it's no small shop... which is odd to me.

 

[JAWS]

Go read the A&P rates thread. Owners control the what and when. Mechanics the how. Can't afford to fix the toys on the plane? Then don't. But don't expect the mechanic or inspector to ignore it.

Those are some expensive boots, but welcome to the price to play in the ice. I've seen Senecas and Barons with "faux boots". AKA the leading edges painted black. I'd be looking at the wing boots closely if keeping the props maintained was an issue. I bet those bladders will have a story to tell!

 

[Travis Schaefer]

Go read the A&P rates thread. Owners control the what and when. Mechanics the how. Can't afford to fix the toys on the plane? Then don't. But don't expect the mechanic or inspector to ignore it.

Those are some expensive boots but welcome to the price to play in the ice. I've seen Senecas and Barons with "faux boots". AKA the leading edges painted black. I'd be looking at the wing boots closely if keeping the props maintained was an issue. I bet those bladders will have a story to tell!

Faux boots (boots with the fir) lol I don't plan on ice skating but I do plan on having them operational asap, it's all parts cost for me and the IA time for oversight... Will find out Monday when turning them on to see what's going on.

 

[Doc Holliday]

I believe a simple visit to the FSDO with the MMEL in hand would generate the LOA to use the MMEL.


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Doesn’t work that way.

The operator needs to follow the guidance in 8900.1, draft an MEL using the MMEL as the guide, then submit for approval.

Walking into a FSDO with an MMEL might make for a nice visit, but won’t get you any approvals.

 

[JAWS]

Faux boots (boots with the fir) lol I don't plan on ice skating but I do plan on having them operational asap, it's all parts cost for me and the IA time for oversight... Will find out Monday when turning them on to see what's going on.

Piper manuals are generally very detailed and give good information. I'd be checking the boots condition and resistance values against what they should be in the manual, same for the brush condition. Prop boots can be "massaged" to a certain degree to make them serviceable. Sitting outside in the elements is sure death to any deice boot. In the end, age will catch up to these items and they will eventually need to be replaced. Whether that time has come and gone or is in the future, remains to be seen.

Good luck.