New threads

[PA1195]

Re: New threads

I think your airplane and the other one you mentioned were incorrectly done. They are not the only ones to have that happen to. There have been many others. My BL that I restored hab been converted to a Continental and the paperwork incorrectly changed. I had to get it changed back when I switched back to the Lycoming. Back before permanent airworthiness certificates it happed more often.

I agree but that snake next to the Data Plate has fangs. They filled out an Application for Airworthiness Certificate, did a conformity inspection, and signed the paperwork. Even mentions TCDS A-696 Rev. 16. Today not likely to happen.

Then STC SA1-210 was installed and the dual fuel tanks became part of the mod.

Gary

[3Dreaming]

Re: New threads

In the Resources portion (http://www.taylorcraft.org/resources.html) is a Field Approved 337 to convert a BL to a BC (see: BL to BC Page 1 Page 2) via engine change to Continental. They state on Page 2 TCDS A-696 now applies and factory wing tanks were installed per specifications. Might be handy supporting data at some point.

My BF12-65 was converted in 1982 to a BC12-65 and the FAA GADO issued a new Standard Airworthiness Certificate and signed the airframe logs to that effect. It's reflected in their online records as a BC12-65 today. There's another sleeping snake I'll not waken.

Gary

I think your airplane and the other one you mentioned were incorrectly done. They are not the only ones to have that happen to. There have been many others. My BL that I restored hab been converted to a Continental and the paperwork incorrectly changed. I had to get it changed back when I switched back to the Lycoming. Back before permanent airworthiness certificates it happed more often.

[PA1195]

Re: New threads

In the Resources portion (http://www.taylorcraft.org/resources.html) is a Field Approved 337 to convert a BL to a BC (see: BL to BC Page 1 Page 2) via engine change to Continental. They state on Page 2 TCDS A-696 now applies and factory wing tanks were installed per specifications. Might be handy supporting data at some point.

My BF12-65 was converted in 1982 to a BC12-65 and the FAA GADO issued a new Standard Airworthiness Certificate and signed the airframe logs to that effect. It's reflected in their online records as a BC12-65 today. There's another sleeping snake I'll not waken.

Gary

[3Dreaming]

Re: New threads

One thing NOT to loose sight of is the Ferris letter states that the planes are all the same from the firewall aft. That was true when Dorthy was building them. It is NOT TRUE for 45 and prior! There is also paper somewhere (sorry I don't have it, just have seen it) saying post war stamped ribs can be used in place of pre war stick ribs. I HAVE found the wing drawings and they DO say you can use post war ribs to build or repair a pre war wing. An argument could be made (I'm not making it) that if you have a pre war plane with post war 15 rib wings you could use that to allow two wing tanks just like a post war. From an ENGINEERING perspective I agree completely, but real engineers are far and few between at the FAA and I am betting it would be a tough sell to an FAA rep with a business degree.

All I am adding here is that this discussion is great, but you CAN NOT carry a lot of the arguments to the earlier planes.

This discussion was why I asked for this addition to the forum and I am learning a LOT while getting TERRIBLE headaches! When all agree I am hoping whoever does the first dual wing tank plane posts all of the documentation on a "Dual wing tank" thread for future owners. This is the thread for debate, a new thread will be for how to do the job. We need to settle the debate prior to creation of teh "How to" thread. Looks like we may need one for stamped ribs AND stick ribs (13 and 15 rib!)

Hank

Hank, I think there is an official letter from the FAA stating that the BC, BL, and BF airframes are the same firewall aft. If memory serves me I used it as the basis for a field approval for installing a Continental A-65 in a BL65 airframe. The letter originated from the New York ACO.

[3Dreaming]

Re: New threads

Sorry for the confusion Tom, I was trying to answer some of Gary's (PA1195). He stated that A-696 doesn't specify which wind the tank goes in. I think items IV and V show the tank in the right wing. I don't think the 337 originally mentioned showing cross referencing to A-696 is valid. My thinking is that a field approval or a DER approval is necessary to install the second wing tank. A data package could be put together using the letter from the factory and maybe a couple of 337's from previous installs (Mike Ragwing nut indicated he had obtained an approval for both tanks). With the letter and 337's from previous installs I would try the field approval route.

That is my take as well. I think I stated that earlier.

[Garry Crookham]

Re: New threads

FAA 8100.16 approved data

[Hank Jarrett]

Re: New threads

One thing NOT to loose sight of is the Ferris letter states that the planes are all the same from the firewall aft. That was true when Dorthy was building them. It is NOT TRUE for 45 and prior! There is also paper somewhere (sorry I don't have it, just have seen it) saying post war stamped ribs can be used in place of pre war stick ribs. I HAVE found the wing drawings and they DO say you can use post war ribs to build or repair a pre war wing. An argument could be made (I'm not making it) that if you have a pre war plane with post war 15 rib wings you could use that to allow two wing tanks just like a post war. From an ENGINEERING perspective I agree completely, but real engineers are far and few between at the FAA and I am betting it would be a tough sell to an FAA rep with a business degree.

All I am adding here is that this discussion is great, but you CAN NOT carry a lot of the arguments to the earlier planes.

This discussion was why I asked for this addition to the forum and I am learning a LOT while getting TERRIBLE headaches! When all agree I am hoping whoever does the first dual wing tank plane posts all of the documentation on a "Dual wing tank" thread for future owners. This is the thread for debate, a new thread will be for how to do the job. We need to settle the debate prior to creation of teh "How to" thread. Looks like we may need one for stamped ribs AND stick ribs (13 and 15 rib!)

Hank

[PA1195]

Re: New threads

Gary I don't think the FAA would consider the Ferris letter as approved data but it could be used as supporting data, meaning the FAA would still have to approve the install but it should make it easier. FAA Order 8300.16 lists sources of approved data. I'll try to post up the list when I have a bit more time.

Thanks Garry my goal is only to help discussion for folks with dual tanks not installed per the CAP STC and learn how this approval works. Your efforts to educate are appreciated. Any further info would be great reading.

Why not take the route of the STC SA1-210 with a request for deviation for fuel system only?

Gary

[Garry Crookham]

Re: New threads

Gary I don't think the FAA would consider the Ferris letter as approved data but it could be used as supporting data, meaning the FAA would still have to approve the install but it should make it easier. FAA Order 8300.16 lists sources of approved data. I'll try to post up the list when I have a bit more time.

[Garry Crookham]

Re: New threads

Sorry for the confusion Tom, I was trying to answer some of Gary's (PA1195). He stated that A-696 doesn't specify which wind the tank goes in. I think items IV and V show the tank in the right wing. I don't think the 337 originally mentioned showing cross referencing to A-696 is valid. My thinking is that a field approval or a DER approval is necessary to install the second wing tank. A data package could be put together using the letter from the factory and maybe a couple of 337's from previous installs (Mike Ragwing nut indicated he had obtained an approval for both tanks). With the letter and 337's from previous installs I would try the field approval route.

[PA1195]

Re: New threads

Good discussion and learning. I missed the Item 2 Garry notes. Now the question is whether or not Dorothy Ferris' letter noting firewall back airframe uniformity is approved data (I agree they're probably the same, but?). If the Owner's Manual isn't then what? Let's hear more.

Gary

[astjp2]

Re: New threads

Its real simple, do a 337 field approval using tcds 696 as basis for the approval and the letter from the Ferris's and state that you are doing the modification to an airplane certified by TCDS 700 which the modification is identical to the installation of a tank installed IAW TCDS 696. You can go further by documenting the line routing, valves you are going to use and the same placarding as directed in TCDS 696. Then just install the valves and plumbing just like the BC series aircraft. If you want to change the valve locations, just put a simple line drawing showing where you want to put it. You can then include the data for using a valve that meets spec. wwv-35c, which is an international standard and acceptable for this installation. So your IA has to do about 30 minutes of typing and you pay him the fee to get it to the FAA for the Field approval. I have used Piper and Cessna installations as acceptable data for use on a major alteration field approval on a Taylorcraft. Data is data...and similar or like data is acceptable.

I have info for using a valve in the wing root that uses an extended handle, just PM me and I can find you the part number from a commercial supplier that meets the spec and has had the seals tested in both avgas and mogas for the last 10 years.

[3Dreaming]

Re: New threads

Garry C,

I understand that the BC type certificate allows for installation of the left hand wing tank to go along with the right hand tank that is already there. The TC is approved data for installation on a BC12-65. I am not sure I understand your view for his installation.

Are you saying this would also be approved data for installing the left hand tank on a airplane built under type certificate A-700, or does he need further approval?

[Garry Crookham]

Re: New threads

Copied directly from A-696:


IV - Model BC12-D, 2 PCLM, Approved November 23, 1945;
Model BCS-12D, 2 PCSM, Approved February 19, 1946.
(Same as Model BC12-65 except for alternate tail surface,
revised aileron travel, alternate one piece windshield and
other miscellaneous structural and not-structural changes).
(Model BC12-D1 eligible as Model BC12-D when items 601 and
204 and **6 gal. right-hand wing tank are installed).**


V - Model BC12-D1, 2 PCL-SM, Approved September 10, 1946;
Model BCS12-D1, 2 PCL-SM, Approved September 10, 1946.
(Same as Model BC12-D except for elimination of left hand
door (item 601), parking brake (item 204) and 6 gal. R/H wing tank)
(Model BC12-D1 eligible as BC12-D when items 601 and 204 and
**6 gal. right-hand wing tank are installed)**




A-696 Note 2: Left hand wing tank eligible as 6 gal. auxiliary on all models except BCS-65 and BC12D-85.



“ The Taylorcraft Owner's Manual on page 4 indicates the single auxiliary tank was installed in the right wing for "B12" models.”
The Taylorcraft Owners Manual is not FAA approved and cannot be used for approved data.


FAA Advisory Circular 43-210A

Subject: Standardized Procedures for Obtaining Approval of Data Used in the Performance of Major Repairs and Major Alterations Date: 8/17/16 Initiated by: AFS-300 AC No: 43-210A

2.2.2 Approval Status.
2.2.2.1 Approved Data. Approved data is data approved by the FAA. The term “approved” is based on § 1.1, which states, “Approved, unless used with reference to another person, means approved by the FAA or any person to whom the FAA has delegated its authority in the matter concerned, or approved under the provisions of a bilateral agreement between the United States and a foreign country or jurisdiction.” For the FAA aviation safety inspector (ASI), “approved” or “approved by” means the item (e.g., data; methods, techniques, and practices; manual contents; tools; materials; equipment) is required to be and has been reviewed and formally approved by the FAA (or appropriate Civil Aviation Authority (CAA)). Approvals are granted only by letter, by a stamp of approval, by the issuance of operations specifications (OpSpecs), or by other official means. All data used to substantiate a major repair or major alteration, regardless of the source, must be approved before being used.

Re: New threads

You may find this legal interpretation useful.

https://www.faa.gov/about/office_org/headquarters_offices/agc/practice_areas/regulations/interpretations/?year=all&q=rude&bSubmit=Search

Dave R