Tcds a-696

[PA1195]

Re: Tcds a-696

Gary,

Very good idea to look at the original equipment list.

Mine does not have item 101 or 102, no main wheels and no tail skid.

But it does have the 302e tail wheel.

It also has 304 which is the brake assembly that weighs 4 lbs. so that is brake only not wheels.

Obviously it had to have wheels but too Garry's question it seems like these items numbers were used with some liberty.

Dave

I show this for Item 304 in my Franklin engined TCDS A-699: 304. 6.00-6 wheel (Firestone 6C4HB) with brakes +6 lb. (+1) The 6.00-6 tires and tubes are listed as Item 317.

However, my original paperwork shows Item 304 as this: 6.00-6 wheels (Shinn 6C4HB) w/tires +27 lb. (+1). Must mean wheel-brake-tire assembly.

And this for original Item 304 (now Item 207 via Note 19) in the current TCDS A-696: 19/ 207. Two main wheel-brake assemblies, 6.00-6, Type III Firestone Model 6C3HB +4 lb. (+2) Tires are listed as 22/ 210 (formerly Item 317).

Hey...it was the '40's!!! The same inspector signed off both our Airworthiness documents so it must be right.

My A/W Cert was later changed to a Continental by the FAA. Yes I know some feel that's not correct, but paper beats opinions most days.

Gary

[Garry Crookham]

Re: Tcds a-696

Gary--PA1195
Thanks for the reference to A-699. I think there is a letter in tech resources from Dorothy Ferris stating all of the BF, BL, and BC series airframes are basically identical so one would expect the TCDS to be the same.

Dave
At this time I don't have an explanation or answer to your question.

Marty
It is probably hard for you to understand my "stirring the pot" as you describe it. I'm an A&P/IA, have been for years and in my job I have a lot of interaction with the FAA. Today, almost all of the FAA people have no knowledge of general aviation, especially the antique/classics. They rely strictly on their documentation to perform their jobs. At some point there will be an incident/accident, etc where A-696 will be examined and someone will end up in trouble. If trying to correct what I think is an error in A-696 is "stirring the pot" so be it.

Joe Cooper
I'll ignore your insult. I've been flying for 52 years. My first 600 hours were in my father's BC12-D and I've owned my Taylorcraft for 35 years. I don't consider myself a Taylorcraft expert but have some knowledge of them.

Still looking for A-696 revisions earlier than revision 14.

Garry

[Guest]

Re: Tcds a-696

Gary,

I have put in two requests for interpretation, both this year.

I retracted one after a phone call with the FAA counsel that it was assigned to told me about an existing Federal Register entry that explained my issue.

The other one will be released in the next couple of weeks according to what the counsel told me.

They are very good to work with and have no axe to grind. Like other good lawyers that I have dealt they say things that are true and I don't like. But that's how answers are some times.

Personally I believe that the things that I mentioned so far give latitude to install a tail wheel and remove a skid but I also would not be afraid to ask for an interpretation.

I expect that my "success" rate so far is 50% that is half went my way and half did not.

Dave

[PA1195]

Re: Tcds a-696

Here's my interpretation as a non-A&P owner and a question. The TCDS lists basic needs for installed equipment and calls them "Required"...prop, engine, main wheels, something at the tail as a support to prevent ground contact, carb heater, and control wheel in A-699/BF for example. There may be more for other TCDS or models (like in A-696/BC or A-700/BL).

From TCDS A-696, A-699, and A-700 under "Model Specs, Equipment": ..."Approval for the installation of all items of equipment listed herein has been obtained by the aircraft manufacturer except those items preceded by an asterisk (*)"...

A-699 and A-700 doesn't list tailwheels (Item 302) as required equipment. Yet mine had a tailwheel installed at the factory and approved by the Gov't inspector assigned to Taylorcraft under A-699. A-696 only lists tailwheels as required for the 85hp ships (Item 206), yet many were likely installed at the factory for earlier models (check your records).

So, if the manufacturer has approved the optional installation of the tailwheels listed in the TCDS, and in some cases, if not most, installed them, why would we need anything besides an I/A signoff on a Minor 337 and a revision to the W&B and Equipment list to approve an installation? This also includes the tail spring (OEM or the FAA/PMA'd P/N UB-562SET) which I believe by the installed total weight listed is part of the "tail wheel assembly" item identified in the Taylorcraft TCDS through 1A9.

And yes, Ms. Ferris' letter 6/7/85 states the airframes (BL, BF, and BC) are identical except for firewall forward. It's under "Misc. Info" in the Foundation page (http://www.taylorcraft.org/resources.html).

Gary

[NC36061]

Re: Tcds a-696

Most likely if you ever find an original copy of the TCDS it will be written just like the revisions, specifying a tail skid. The very early B models no doubt used them, and that's probably how the original TCDS was written. Its far more likely that no one ever bothered to amend the item than it is that someone changed tail wheel to tail skid during a revision of the document at some point in history.

Have you tried to contact Forrest? This is exactly the sort of thing the "foundation" should be involved in sorting out. If an original version exists, most likely that's where you would find it. Good luck in your quest.

[Garry Crookham]

Re: Tcds a-696

Thanks to all for the comments. It would be helpful if the "foundation" were involved in such, but my belief is the "foundation" exists in name only. After reviewing A-696, A-699 and A-700 it appears that that item was probably never amended and without factory support probably will not change.

Garry

[Bernard]

Re: Tcds a-696

at a mechanics meeting with the Seattle FSDO The subject came up on optional equipment . The inspectors take was that if the item was listed on the TCDS it could be installed as a minor with a log book entry. but if it was not on the TCDS the it was a major and required a 337. I was installing new wheels and brakes on a Cessna 152. The old wheels and breaks are now longer made but the new wheels were listed as optional equipment, but not on the TCDS. What saved me was Cessna came out with service buliton that was FAA approved Data for installing the wheels and breakes . So it just took a log book entry and weight & balance up date.

[M Towsley]

Re: Tcds a-696

Gary,

Here are two tailwheel related incidents I quickly found on the NTSB website, I did not search further. One has a probable cause the other, occurring this last May, does not. In the first, in 2009, I did not note any comments concerning the failure of the tailwheel equipped airplane from the FAA inspector, or NTSB investigator, regarding your concerns. The one in May has no probable cause as of yet.

I am glad you are trying to educate the local FAA to the intricacies of our antiques and classics. Unfortunately, the people at my FSDO probably really wouldn't care. I applaud you in your endeavours, but trying to change something like this may be an effort in futility.

I am not sure why further investigation was not taken by the NTSB or FAA in the 2009 incident, or perhaps they didn't care or know they should have.

http://www.ntsb.gov/GILS/_layouts/ntsb.aviation/brief.aspx?ev_id=20090611X52616&key=1

http://www.ntsb.gov/_layouts/ntsb.aviation/brief.aspx?ev_id=20150519X55027&key=1

Perhaps these may help with your investigation.

[PA1195]

Re: Tcds a-696

I hope this is resolved, especially for those that currently have tail wheel assemblies not listed on their TCDS without paperwork.

As far as tail shimmy, assuring the assembly is lubricated, properly tightened, and not given to excessive rotational free play is essential, especially as tail loading increases.

The angle of the tailwheel to ground influences it's behavior, as does the tension of attaching springs and chain (http://www.airframesalaska.com/v/vsp...stallation.pdf). For the rudder horn and fasteners I like to use cotter keys on all fasteners and clevis pins. I also safety wire spring connectors to prevent loss of contact if they go slack during operation.

Gary

[Guest]

Re: Tcds a-696

at a mechanics meeting with the Seattle FSDO The subject came up on optional equipment . The inspectors take was that if the item was listed on the TCDS it could be installed as a minor with a log book entry. but if it was not on the TCDS the it was a major and required a 337. I was installing new wheels and brakes on a Cessna 152. The old wheels and breaks are now longer made but the new wheels were listed as optional equipment, but not on the TCDS. What saved me was Cessna came out with service buliton that was FAA approved Data for installing the wheels and breakes . So it just took a log book entry and weight & balance up date.

Hi Bernard,

Just slight nuance here but important, it is certain that an alteration that is listed in the TCDS specs is not a major alteration see the definition in part 1 or 43 appendix A.

It's not for certain that an item not in the TCDS specs is a major alteration though. Some items may not be listed but are also not living up to the definition of a major alteration in part 1 and part 43 appendix A.

Also an alteration could be a major one even with the existence of approved data, we have to look at the definition of a major alteration in part 1 and part 43 appendix A to make the determination. For example some Aeronca service letters are approved data but they are also major alterations.

BTW I am not commenting on your specific alteration but rather on the general process.

Garry's quest as I perceive is one that IA's probably care about more than others. When the annual is done the aircraft needs to be checked that it conforms to its type data and that required equipment list could be interpreted as it must have a skid which of course most do not. Some legal eagle with no common sense might pursue that but in my opinion would not get far since a tail wheel is an obvious replacement and tail wheels are listed in the TCDS.

Dave

[Edwin Otha]

Re: Tcds a-696

The tailwheel is not a regulated item per CAR04. I don't get too worked up by the type installed as long as it works. I've seen too many people struggle with crappy tailwheels and ultimately losing the plane because of it.
Just because it's on the TCDS doesn't convey blanket installation approval. This document is provided, by the manufacturer, to the FAA for for obtaining a Production Certificate.

04.442 Wheels. Main landing gear wheels shall be of a type or
model certificated by the Secretary in accordance with the provisions
of Part 15 and shall not be subjected to static loads in excess of those
for which they are certificated. Tail wheels may be of any type or
model and are not certificated. Nose wheels are subject to special
rulings to be made by the Secretary.

[Mark Bowden]

Re: Tcds a-696

Hi Garry, historically I think this is interesting. I might offer a view looking at it from my Wichita days on the manufacturing side and discussing with one of the internal certification guys I worked with, don’t see a basis for an issue. As Dave and Gary stated there is context for coverage. If you look at the sum of remaining and available documentation, the 696 equipment list, the equipment list notes, as well as the existing drawings for tailwheel installations and service items listed in the manuals that there is coverage and intent for tailwheels. The ultimate key is each airplane has coverage through its original: equipment list, inspection and conformity documents at the time of manufacture.

While it would be great if we could have each revision of 696, it just doesn't matter. My guess would be that a skid requirement was likely added to 696 when a tail wheel became an option. There is no error to be found. If you look at the required equipment for each model in 696 over time it is just the minimum part required or unique things that make one model different from the earlier ones, it is an MEL if you will. The document functions by listing the required equipment that is the cheapest or most basic option when more than one piece of equipment can be selected by the Taylorcraft under their CAA Production Certificate and building to their approved Type Certificate design data.

696 clearly states 'approval for … all items of equipment listed herein has been obtained', approval coming from the CAA. Thus by default, as-built substitutions are allowed unless noted for some reason in the list like props.

The most basic choice to keep the rudder horns out of the dirt is a skid. But listed as approved equipment are multiple tailwheels from different vendor sources with no asterisk. It is just like saying a 2 ply tire is required. Delivered with a 4 ply, the aircraft is still ok but the equipment list would not have the required 210a item, 210b would be listed.

The tailwheel design exists in drawings and 696 lists vendor options. This means that the manufacturer designed and approved the installation. The skid has no weight/moment notes. Thus the skid is standard for W&B, tailwheel is an option and the difference must be noted in inspection and conformity as equipped.

Other supporting info. There are drawings to support the tailwheel installation, the title block says, "Alighting Gear", which also covers the wheel stream lines, I have a copy in my service manual.

The rudder has spring horns for the tailwheel which means that the empennage is designed for steerable tailwheel use. The service manual lubrication section states to lube the tailwheel axle.

The paper trail and key to what makes it ok is my Inspection report and the Conformity Statement form. The authorized Chief Inspector filed the paperwork with the CAA that Taylorcraft, under their issued Production Certificate #9, built 39911 in July of 1945, equipment list shows 302e, tailwheel and he verified it conforms to the Type Certificate, 696-2 and the changes in work for the BC12-D design application.

She then sat as a whitetail until sold in the fall and they put the AW certificate on her 5 days after the model BC12-D was an approved design on November 23, 1945 per 696 date. All still on file with FAA. It’s funny that the exact same process occurs today with new aircraft development in every category.

You can't deliver until TC award. If you don’t have your PC then the FAA has to inspect the aircraft prior to delivery, when you get your PC, you then are authorized to do so. Your production certificate means you can build things to the approved Type Design identified by the TC#. And you have the processes in place to do it correctly and are authorized to inspect it back to the design and also properly document the process thru delivery with an AW cert.

The factory had the option to configure to the items listed in 696. As built, a tailwheel is NOT an alteration it is just like a 4 ply tire, an acceptable substitute for the minimum required items. History plays a role too in absence of full documentation, physical evidence shows nearly everything had tailwheels. I’m not an IA but would state we are covered for the as delivered configuration through the sum of our inspection docs, equipment list and AW certificate. Change it after delivery, different story, different process and documentation required.

Mark

[Guest]

Re: Tcds a-696

Hi Garry, historically I think this is interesting. I might offer a view looking at it from my Wichita days on the manufacturing side and discussing with one of the internal certification guys I worked with, don’t see a basis for an issue. As Dave and Gary stated there is context for coverage. If you look at the sum of remaining and available documentation, the 696 equipment list, the equipment list notes, as well as the existing drawings for tailwheel installations and service items listed in the manuals that there is coverage and intent for tailwheels. The ultimate key is each airplane has coverage through its original: equipment list, inspection and conformity documents at the time of manufacture.

While it would be great if we could have each revision of 696, it just doesn't matter. My guess would be that a skid requirement was likely added to 696 when a tail wheel became an option. There is no error to be found. If you look at the required equipment for each model in 696 over time it is just the minimum part required or unique things that make one model different from the earlier ones, it is an MEL if you will. The document functions by listing the required equipment that is the cheapest or most basic option when more than one piece of equipment can be selected by the Taylorcraft under their CAA Production Certificate and building to their approved Type Certificate design data.

696 clearly states 'approval for … all items of equipment listed herein has been obtained', approval coming from the CAA. Thus by default, as-built substitutions are allowed unless noted for some reason in the list like props.

The most basic choice to keep the rudder horns out of the dirt is a skid. But listed as approved equipment are multiple tailwheels from different vendor sources with no asterisk. It is just like saying a 2 ply tire is required. Delivered with a 4 ply, the aircraft is still ok but the equipment list would not have the required 210a item, 210b would be listed.

The tailwheel design exists in drawings and 696 lists vendor options. This means that the manufacturer designed and approved the installation. The skid has no weight/moment notes. Thus the skid is standard for W&B, tailwheel is an option and the difference must be noted in inspection and conformity as equipped.

Other supporting info. There are drawings to support the tailwheel installation, the title block says, "Alighting Gear", which also covers the wheel stream lines, I have a copy in my service manual.

The rudder has spring horns for the tailwheel which means that the empennage is designed for steerable tailwheel use. The service manual lubrication section states to lube the tailwheel axle.

The paper trail and key to what makes it ok is my Inspection report and the Conformity Statement form. The authorized Chief Inspector filed the paperwork with the CAA that Taylorcraft, under their issued Production Certificate #9, built 39911 in July of 1945, equipment list shows 302e, tailwheel and he verified it conforms to the Type Certificate, 696-2 and the changes in work for the BC12-D design application.

She then sat as a whitetail until sold in the fall and they put the AW certificate on her 5 days after the model BC12-D was an approved design on November 23, 1945 per 696 date. All still on file with FAA. It’s funny that the exact same process occurs today with new aircraft development in every category.

You can't deliver until TC award. If you don’t have your PC then the FAA has to inspect the aircraft prior to delivery, when you get your PC, you then are authorized to do so. Your production certificate means you can build things to the approved Type Design identified by the TC#. And you have the processes in place to do it correctly and are authorized to inspect it back to the design and also properly document the process thru delivery with an AW cert.

The factory had the option to configure to the items listed in 696. As built, a tailwheel is NOT an alteration it is just like a 4 ply tire, an acceptable substitute for the minimum required items. History plays a role too in absence of full documentation, physical evidence shows nearly everything had tailwheels. I’m not an IA but would state we are covered for the as delivered configuration through the sum of our inspection docs, equipment list and AW certificate. Change it after delivery, different story, different process and documentation required.

Mark

Hi Mark,

I have to disagree, a tailwheel or any item in the TCDS item list is an alteration. Check out the definition of a major alteration in part 1 and it says that alterations not listed in the TCDS are major alterations thereby ones that are listed are merely alterations.

Certainly they are not alterations from and engineering point of view but from a maintenance point of view I think that you can see that they are an alteration. But the definition I mentioned is the final arbiter that defines it.

Dave

[astjp2]

Re: Tcds a-696

Well Dave, per the FAA, if the tailwheel is an option in the TCDS, then its a minor and just requires a Log book entry if it originally did not come with it from the factory. IE a Scott 3-24b, Lang, etc. If you want to put a 3200, Maule Bushwheel, on then it could be considered a Major, if there is no PMA, I know that the Maule had a PMA for the BC series and I think the Scott 3200 does as well. The pain gets when you have a BC12-65 and the PMA says BC-12D, then its a Major unless you have some other approval. Its just like my argument about the 4 ply vs. 6 ply tires. The TCDS specifically calls out a 4 ply and a 6 ply would then be a Major and requires a 337. People have been violated for it...and a lot of others will have an opinion that they can not back up with paperwork. This information has been put out in previous IA seminars so I know it has not changed since then. Tim

[astjp2]

Re: Tcds a-696

Here's my interpretation as a non-A&P owner and a question. The TCDS lists basic needs for installed equipment and calls them "Required"...prop, engine, main wheels, something at the tail as a support to prevent ground contact, carb heater, and control wheel in A-699/BF for example. There may be more for other TCDS or models (like in A-696/BC or A-700/BL).

From TCDS A-696, A-699, and A-700 under "Model Specs, Equipment": ..."Approval for the installation of all items of equipment listed herein has been obtained by the aircraft manufacturer except those items preceded by an asterisk (*)"...

A-699 and A-700 doesn't list tailwheels (Item 302) as required equipment. Yet mine had a tailwheel installed at the factory and approved by the Gov't inspector assigned to Taylorcraft under A-699. A-696 only lists tailwheels as required for the 85hp ships (Item 206), yet many were likely installed at the factory for earlier models (check your records).

So, if the manufacturer has approved the optional installation of the tailwheels listed in the TCDS, and in some cases, if not most, installed them, why would we need anything besides an I/A signoff on a Minor 337 and a revision to the W&B and Equipment list to approve an installation? This also includes the tail spring (OEM or the FAA/PMA'd P/N UB-562SET) which I believe by the installed total weight listed is part of the "tail wheel assembly" item identified in the Taylorcraft TCDS through 1A9.

And yes, Ms. Ferris' letter 6/7/85 states the airframes (BL, BF, and BC) are identical except for firewall forward. It's under "Misc. Info" in the Foundation page (http://www.taylorcraft.org/resources.html).

Gary

No such thing as a minor 337, if its minor, log book only