First Taylorcraft annual

[N96337]

Re: First Taylorcraft annual

Hank, I think the point most of us IA's are trying to get across is a person can't simply look at all that is required to be looked at, and in the detail it should be looked at in the amount of time that you are allowing for the inspection. Especially if you are trying to do several airplanes in one day. If you are doing it in less time you likely are not covering all that legally needs to be covered.

The one thing that sticks in my mind is the FAA inspector that administered my IA exam emphasizing to me that you "cannot supervise an inspection". I don't care how many have looked at it before me, I'm the one that's going to have to sign my livelihood on the line at the end of the inspection.
The other thing that pops in my mind is that when I'm doing an inspection, I don't look at just one thing and focus on it...I look at that one thing and how anything else can relate to it's operation or well being, or how it can affect something else....the whole story. So if there's 6 planes lined up for me, I'm not just going to go look at the "trim crank" of all 6 in a row...that to me isn't much of an inspection.... I'd want to do a full "flowing" annual inspection on each one, one at a time. So from where I stand, this wouldn't save me any time. I also tend to want to not have anyone else around, and no distractions while I'm doing your inspection....to the point that I may lock the door, and do it at night if I can't get the time in the day. To me, an annual inspection is a pretty serious thing...your life could depend on it, not to mention my livelihood. I send the owner home, do the inspection, and bring him/her back later and we go through it together if they want. Most of the "learning" is done while we are taking it apart and putting it back together, or going over any descrepancies I find.
That being said, I do like to have "owner assisted" annuals done on these aircraft. I think it makes a safer owner and pilot, if they understand more about their plane, but we both take the plane apart. I try to involve them as much as possible, however if you look at the very first paragraph of FAR43 Appendix D, it states
"43xD.a

Each person performing an annual or 100 hour inspection shall, before that inspection, remove or open all necessary inspection plates, access doors, fairing, and cowling. He shall thoroughly clean the aircraft and aircraft engine". (there's one that can hang alot of inspectors....cleaning the aircraft and engine before they inspect)

I remember what that inspector drilled into me about "supervising an inspection"...this relates, as far as I'm concerned, as well as I feel it's a big part of the inspection to be there to see everything AS it comes apart .
FAR43 Appendix D is the bare minimum that HAS to be completed for a legal inspection. You can (and should) do more, but everything listed in that appendix MUST be completed as stated.
I'm also a firm believer in a "second set of eyes" looking over the plane occasionally.... in fact I recommend that my customers take their plane to another IA every few years....different eyes see things differently.... but I want qualified eyes doing the looking.
Personally, I wouldn't feel comfortable signing off annuals that are done in a "group style" setup....but that's me. I know IA's that wouldn't bat an eye at it. I do agree that the "group style" has some advantages, and is an educational tool for the owner, but for this IA, I'll just stick to one at a time.
John

[Guest]

Re: First Taylorcraft annual

Here are the regs on I/A privileges regarding annual inspections and mechanic privileges,

§65.95 Inspection authorization: Privileges and limitations.

(a) The holder of an inspection authorization may—

(1) Inspect and approve for return to service any aircraft or related part or appliance (except any aircraft maintained in accordance with a continuous airworthiness program under part 121 of this chapter) after a major repair or major alteration to it in accordance with part 43 [New] of this chapter, if the work was done in accordance with technical data approved by the Administrator; and

(2) Perform an annual, or perform or supervise a progressive inspection according to §§43.13 and 43.15 of this chapt

Notice that as John said annuals must be preformed NOT supervised.

Mechanic's can use the "supervise" option as mentioned below;

§65.85 Airframe rating; additional privileges.

(a) Except as provided in paragraph (b) of this section, a certificated mechanic with an airframe rating may approve and return to service an airframe, or any related part or appliance, after he has performed, supervised, or inspected its maintenance or alteration (excluding major repairs and major alterations).


§65.87 Powerplant rating; additional privileges.

(a) Except as provided in paragraph (b) of this section, a certificated mechanic with a powerplant rating may approve and return to service a powerplant or propeller or any related part or appliance, after he has performed, supervised, or inspected its maintenance or alteration (excluding major repairs and major alterations). In addition, he may perform the 100-hour inspection required by part 91 of this chapter on a powerplant or propeller, or any part thereof, and approve and return it to service.


I skipped the part b paragraphs as they talk to light sport category

Dave

[Hank Jarrett]

Re: First Taylorcraft annual

It will be interesting. As I said, this time it is ONLY my plane and he took the paperwork home with him today. I can see a lot of good advice and discussion from this. There are some ideas that may fly, and some that won't. He did say he really liked the way I had broken down all the relevant information for the inspection. I had a folder for the different requirements and included copies of all AD,s, STC's, 337's, TSO's etc. along with several of our "home made" handbooks" and the TC. I also built a list of the original equipment and what page of the logs showed every mod. If it wasn't in the logs as having been added, I took it off. LOTS of junk added with no entries over the years. Lots of incorrect parts put on that I took back to original.

I had the Auto Fuel STC and I seem to remember he said there should be a 337 along with that. Is that right? I may have heard wrong, but it is the only STC on my plane and I don't remember a 337 being put in when I got it.

Hank

PS
The multiple inspection is the PLANE only, not the paperwork! He is thinking about that one and says there is NO WAY he could ever do 6 planes (not the paper at all) in a day. Three would be difficult. He also would NOT go from plane to plane doing one thing over and over. I have never looked at the FARs concerning an owner assist meaning that an owner couldn't take off all the panels. Every IA I have ever used allowed that and we DID NOT detail clean the plane before he looked at it the first time. You do NOT want to be cleaning up any stains or leaks prior to the IA looking! If the owner is going to clean it, the IA should see it first before you "remove evidence", CERTAINLY in the engine compartment! Of course MY engine compartment could be eaten from ANY day. ;-)

[Guest]

Re: First Taylorcraft annual

It will be interesting. As I said, this time it is ONLY my plane and he took the paperwork home with him today. I can see a lot of good advice and discussion from this. There are some ideas that may fly, and some that won't. He did say he really liked the way I had broken down all the relevant information for the inspection. I had a folder for the different requirements and included copies of all AD,s, STC's, 337's, TSO's etc. along with several of our "home made" handbooks" and the TC. I also built a list of the original equipment and what page of the logs showed every mod. If it wasn't in the logs as having been added, I took it off. LOTS of junk added with no entries over the years. Lots of incorrect parts put on that I took back to original.

I had the Auto Fuel STC and I seem to remember he said there should be a 337 along with that. Is that right? I may have heard wrong, but it is the only STC on my plane and I don't remember a 337 being put in when I got it.

Hank

PS
The multiple inspection is the PLANE only, not the paperwork! He is thinking about that one and says there is NO WAY he could ever do 6 planes (not the paper at all) in a day. Three would be difficult. He also would NOT go from plane to plane doing one thing over and over. I have never looked at the FARs concerning an owner assist meaning that an owner couldn't take off all the panels. Every IA I have ever used allowed that and we DID NOT detail clean the plane before he looked at it the first time. You do NOT want to be cleaning up any stains or leaks prior to the IA looking! If the owner is going to clean it, the IA should see it first before you "remove evidence", CERTAINLY in the engine compartment! Of course MY engine compartment could be eaten from ANY day. ;-)

Hi Hank,

That is correct you need an 337.

An STC is a major alteration and requires a 337 so you should have one additionally an STC requires that you have permission to install it.

See below.

Dave

§91.403 General.

(a) The owner or operator of an aircraft is primarily responsible for maintaining that aircraft in an airworthy condition, including compliance with part 39 of this chapter.

(b) No person may perform maintenance, preventive maintenance, or alterations on an aircraft other than as prescribed in this subpart and other applicable regulations, including part 43 of this chapter.

(c) No person may operate an aircraft for which a manufacturer's maintenance manual or instructions for continued airworthiness has been issued that contains an airworthiness limitations section unless the mandatory replacement times, inspection intervals, and related procedures specified in that section or alternative inspection intervals and related procedures set forth in an operations specification approved by the Administrator under part 121 or 135 of this chapter or in accordance with an inspection program approved under §91.409(e) have been complied with.

(d) A person must not alter an aircraft based on a supplemental type certificate unless the owner or operator of the aircraft is the holder of the supplemental type certificate, or has written permission from the holder.

[Hank Jarrett]

Re: First Taylorcraft annual

I bought the STC and have the permission. Problem was no one ever said you had to do a 337 along with it. Funny that EAA would send the STC and not remind you to do that. Where do the regs say to do a 337 in addition to the STC and permission letter? It never hit me that this was an "alteration" since nothing was changed on the plane, just the fuel going into it.

Hank

[Guest]

Re: First Taylorcraft annual

Hi Hank,

Let me try to walk thru this.

1) at the IA meeting they say that an STC is a major alteration.

2) It's a major change. Fuel octane is specified in the TCDS.

Appendix A to Part 43—Major Alterations, Major Repairs, and Preventive Maintenance

(a) Major alterations—(1) Airframe major alterations. Alterations of the following parts and alterations of the following types, when not listed in the aircraft specifications issued by the FAA, are airframe major alterations:

(i) Wings.

(ii) Tail surfaces.

(iii) Fuselage.

(iv) Engine mounts.

(v) Control system.

(vi) Landing gear.

(vii) Hull or floats.

(viii) Elements of an airframe including spars, ribs, fittings, shock absorbers, bracing, cowling, fairings, and balance weights.

(ix) Hydraulic and electrical actuating system of components.

(x) Rotor blades.

(xi) Changes to the empty weight or empty balance which result in an increase in the maximum certificated weight or center of gravity limits of the aircraft.

(xii) Changes to the basic design of the fuel, oil, cooling, heating, cabin pressurization, electrical, hydraulic, de-icing, or exhaust systems.

(xiii) Changes to the wing or to fixed or movable control surfaces which affect flutter and vibration characteristics.

(2) Powerplant major alterations. The following alterations of a powerplant when not listed in the engine specifications issued by the FAA, are powerplant major alterations.

(i) Conversion of an aircraft engine from one approved model to another, involving any changes in compression ratio, propeller reduction gear, impeller gear ratios or the substitution of major engine parts which requires extensive rework and testing of the engine.

(ii) Changes to the engine by replacing aircraft engine structural parts with parts not supplied by the original manufacturer or parts not specifically approved by the Administrator.

(iii) Installation of an accessory which is not approved for the engine.

(iv) Removal of accessories that are listed as required equipment on the aircraft or engine specification.

(v) Installation of structural parts other than the type of parts approved for the installation.

(vi) Conversions of any sort for the purpose of using fuel of a rating or grade other than that listed in the engine specifications.

3) example of a TCDS

AIRCRAFT SPECIFICATION NO. A-696
Type Certificate Holder Taylorcraft 2000, LLC
Dba Aircraft Taylorcraft Co., LLC
2100 Les Mauldin Rd.
Brownsville, TX 78521
Type Certificate Ownership Record Taylorcraft Corporation transferred ownership to Syncron, Inc. on October 19, 1994.
Syncrom, Inc. transferred ownership to Airborne Marketing, Inc. on January 8, 1997.
Airborne Marketing, Inc. transferred ownership to Lee F. Booth on April 26, 1999.
Lee F. Booth, dba Taylorcraft Aerospace, transferred ownership to Harvey & Vera
Patrick Foundation, Inc. on May 10, 2000.
Harvey & Vera Patrick Foundation, Inc. transferred ownership to Taylorcraft 2000, LLC
on August 8, 2000
Taylorcraft 2000 LLC transferred ownership to Taylorcraft Aviation LLC on
March 5, 2003
Taylorcraft Aviation LLC, 2124 N. Central Ave., Brownsville, TX 78521 transferred
ownership to Taylorcraft 2000 LLC on May 21, 2008
Taylorcraft 2000 LLC transferred to Taylorcraft 2000 LLC Dba Aircraft Taylorcraft Co.,
LLC on October 7, 2009.
I - Model BC, 2 PCLM, Approved August 24, 1938; Model BCS, 2 PCSM, Approved April 5, 1939
Engine Continental A-50-1 (see item 114(a) for optional engines)
Fuel 73 min. grade aviation gasoline
Engine Limits For all operations, 1900 r.p.m. (50 hp.)


TYPE CERTIFICATE DATA SHEET NO. E-205
Engines of models described herein conforming with this data sheet (which is a part of type certificate No. E-205) and other
approved data on file with the Federal Aviation Administration, meet the minimum standards for use in certificated aircraft in
accordance with pertinent aircraft data sheets and applicable portions of the Civil Air Regulations provided they are installed,
operated and maintained as prescribed by the approved manufacturer's manuals and other approved instructions.
Type Certificate Holder Continental Motors
2000 9th Street
Mobile, Alabama 36615
Type Certificate Holder Record Teledyne Continental Motors
Ownership & name change as of April 19, 2011 (Continental Motors, Inc.)
Model A-65 -1 -3, -6 -7 -8, -9 -12 -14
Fuel (minimum grade aviation
gasoline)
See NOTE 9 - - - - - - - - - -
.
.
.
NOTE 9. All models using Stromberg NA-S3A1 or NA-83B carburetors eligible for use of 73 octane grade fuel except
A-65-14 model which is limited to use of 80/87 octane fuel.
All models using Marvel-Schebler MA-3PA carburetor are limited to use of 80/87 octane fuel.


4) It is a change to the type design (that makes is a major alteration (change)). Let me try to say this a better way; the fact that it is an STC means that it has been determined by the FAA to be a major change (added on 10/20/14)


§21.113 Requirement for supplemental type certificate.

(a) If a person holds the TC for a product and alters that product by introducing a major change in type design that does not require an application for a new TC under §21.19, that person must either apply to the appropriate aircraft certification office for an STC or apply to amend the original type certificate under subpart D of this part.

(b) If a person does not hold the TC for a product and alters that product by introducing a major change in type design that does not require an application for a new TC under §21.19, that person must apply to the appropriate aircraft certification office for an STC.

(c) The application for an STC must be made in the form and manner prescribed by the FAA.


§21.19 Changes requiring a new type certificate.

Each person who proposes to change a product must apply for a new type certificate if the FAA finds that the proposed change in design, power, thrust, or weight is so extensive that a substantially complete investigation of compliance with the applicable regulations is required.


I never noticed the octane difference mentioned in note 9 for Marvel versus Stromberg before.

Dave

[Garry Crookham]

Re: First Taylorcraft annual

I bought the STC and have the permission. Problem was no one ever said you had to do a 337 along with it. Funny that EAA would send the STC and not remind you to do that. Where do the regs say to do a 337 in addition to the STC and permission letter? It never hit me that this was an "alteration" since nothing was changed on the plane, just the fuel going into it.

Hank

I don't understand why the EAA needs to remind you to file a 337. This is basic aircraft certification/A&P/IA skills. An STC is a change to the type certificate and as so is a major alteration. Installing the auto fuel STC requires the involvement of an A&P/IA. Even though the only change involved is installing placards on the fuel tanks the installing A&P is required to complete the paperwork including a form 337 and have it approved by an IA.
I think this explains why this thread has become such a long discussion. Maintaining an airplane in accordance with the applicable FARs, even a simple Taylorcraft, is a much more involved process than most aircraft owners are willing to understand.

[Hank Jarrett]

Re: First Taylorcraft annual

I think I see why no one changed it with a 337 before. The fuel SYSTEM was never changed, only the fuel type. The Auto fuel IS within the octane range required by my engine specifications and in fact, after an argument with the airport management where I used to be hangared, I contacted Continental engineers who recommended NOT to use 100 LL because of the low compression design of the 65 hp engines. The admin person at the airport didn't like the STC holders bringing fuel to the airport and not buying theirs. SHE said it was OK to use 100LL and the engineers were full of it. She should know, she had a high school diploma and took typing! My engine specifications require only 73 octane which the regular (auto) gas here meets but Continental said the engine does NOT do well with any alcohol (which is NOT present since the airport gets the fuel directly from the local fuel terminal before it is added).

The AIRFRAME is never modified, nor is the aircraft's fuel system. No modifications what-so-ever are made to the engine. Based on that I can understand why the prior IA's never did the 337. The IA I am using NOW agrees with you and I have no problem with getting the 337 done, but I don't see anything in what you quoted that requires it except your line 4, which is from you and not the regs. I don't see where it is a change to the "type design" and haven't seen where it is called out that an STC is automatically a major change or where the FAA determined that this is one of them. What I am missing is where the FAA says the source of the fuel constitutes a change to the product (and that "product" isn't even a part of the airplane).

Like I said before, my IA is the one wanting to do it and I agree it "couldn't hoit", but I like to learn and there are MANY interpretations of the FAR's! Most of them wrong (we have an IA here who is FAMOUS for those! I am amazed he still has his certifications with as many times as he has been called on the carpet). When in doubt, take the safest route, which in this case means get the 337, which we are. I just want to understand the FAR's better, which I am starting to think may be impossible.

Hank

Wasn't the old saying that if you understood the FAR's, the FAA had to change them. Fully understanding them IS NOT ALLOWED! ;-)

[Guest]

Re: First Taylorcraft annual

I give up.

This is a hopeless discussion.

Dave

[M Towsley]

Re: First Taylorcraft annual

I am curious, if, let us say the new UL fuel is a new octane, (which it will be), do you need to get a 337 for a change in fuel?

Was there a 337 completed when all these old aircraft started burning 100LL?

If it works one way for an auto fuel STC will it work the other when 100LL is no longer available?

[Garry Crookham]

Re: First Taylorcraft annual

I give up.

This is a hopeless discussion.

Dave

Me too. STC=Supplemental Type Certificate=major alteration even if no physical airframe or engine changes. I'm out of this.

[Hank Jarrett]

Re: First Taylorcraft annual

BINGO! Found the written requirement. It was at the bottom of the second page of the letter from the issuer of the STC. It states that not only are you required to put in a 337 for the plane, but the engine as well! Clearly says TWO 337 forms to the FAA by the IA. The cover letter is NOT a regulation, and I can see how some of the mechanics could miss that. I don't think the cover letter is a good place to put the requirement, but at least it is clearly in writing SOMEWHERE.

Dave and Gary, please don't think we are challenging your wisdom or the wisdom of a 337, we are just trying to understand the FAR's better. It seems like a hopeless task sometimes with all the convoluted and poor language. When I get two IAs saying two different things in interpretation I usually do the one that requires the MOST or is the safest. I do NOT use "my IA said I didn't need to" in order to avoid doing something. It amazes me that my last IA didn't catch this as he is about the safest and most thorough I have ever met. I will want to sit down with him and talk about it.

DON'T GIVE UP on us. The discussions are FAR from hopeless to us. We are just trying to learn, and sometimes that means challenging what people say. It does NOT mean we don't respect what you say, nor does it mean we aren't going to do it.

Hank

Yea, I drove my instructor nuts with my "WHY?" questions too. I would never accept "because I said so". You do what he says, but you ask questions when you don't understand why.

[VanDy]

Re: First Taylorcraft annual

Hank, check out ADlog, I believe its in the neighborhood of $100 a year per plane, but man is it sweet. THe first time set up takes everybit of a full day (for a 172) But when you are done, you have EVERY serial number and part number in the record with all the AD's in a very user friendly format.

The longest and hardest part is still the logs and checking the paper but I am working on that now to try and set up a standardized system. I want a notebook with copies of all the Major repairs and alterations showing the dates and pages in the logs, all AD's, STC's, 337's, and TSO and PMA parts since last annual. With everyone using the same book layout with all the paperwork in order and a checklist for the planes you can save a LOT of time. To me the best thing is you have multiple OWNERS looking at ALL of the planes.
Hank

[VanDy]

Re: First Taylorcraft annual

Hi Hank,

Let me try to walk thru this.

/snip/
Dave[/B]

I am saving that, thank you. It is hard to get through to some people that a 337 is required for an STC, even as simple as a Rosin sunvisor...

[astjp2]

Re: First Taylorcraft annual

The auto gas stc is 2 337's, one for the airframe and the other is for the modification to the engine.
Technically you can legally get an gas stc from Peterson for either the engine or the airframe and EAA for the other...that is technically legal as long as you meet the requirements of both. Tim

oh and cleaning is to identify smoking rivets, look for cracks and condition AS YOU CLEAN...Tim

It will be interesting. As I said, this time it is ONLY my plane and he took the paperwork home with him today. I can see a lot of good advice and discussion from this. There are some ideas that may fly, and some that won't. He did say he really liked the way I had broken down all the relevant information for the inspection. I had a folder for the different requirements and included copies of all AD,s, STC's, 337's, TSO's etc. along with several of our "home made" handbooks" and the TC. I also built a list of the original equipment and what page of the logs showed every mod. If it wasn't in the logs as having been added, I took it off. LOTS of junk added with no entries over the years. Lots of incorrect parts put on that I took back to original.

I had the Auto Fuel STC and I seem to remember he said there should be a 337 along with that. Is that right? I may have heard wrong, but it is the only STC on my plane and I don't remember a 337 being put in when I got it.

Hank

PS
The multiple inspection is the PLANE only, not the paperwork! He is thinking about that one and says there is NO WAY he could ever do 6 planes (not the paper at all) in a day. Three would be difficult. He also would NOT go from plane to plane doing one thing over and over. I have never looked at the FARs concerning an owner assist meaning that an owner couldn't take off all the panels. Every IA I have ever used allowed that and we DID NOT detail clean the plane before he looked at it the first time. You do NOT want to be cleaning up any stains or leaks prior to the IA looking! If the owner is going to clean it, the IA should see it first before you "remove evidence", CERTAINLY in the engine compartment! Of course MY engine compartment could be eaten from ANY day. ;-)