Engine upgrade

[barnstmr]

Re: Engine upgrade

These orders are written as a guide that FSDO inspectors are to follow. The wording is interesting. If it does not say STC, then it can be up for debate.

"Case-by-case" really means it depends on the capabilities of the FSDO inspector. Hopefully you can find a FSDO inspector who is experienced and knowledgeable about these kinds of airplanes.

"Other than STC" means

1) Field approval - Submit 337 with no approved data and ask FSDO to approve it. This is getting more and more rare.

2) 337 with DER approved data, the IA signs off block 7 of the 337, attaches a DER's approval (FAA form 8110-3, and then the 337 goes straight to OK City (bypasses FSDO regional office).

3) 337 with other approved data such as factory drawings etc. Usually the "approved data" is hard to come by and then it has to be proven as "approved".

Not a lot of folks understand #2 very well. But it can be the best way to go on projects that do not require an STC. DERs have a set of rules they must work within, but a lot of major changes can be supported by DER's. Sometimes the change is complex enough that more than one DER is necessary. For example, right now I am working with an L-2 owner to add two 5 gallon fuel cells as an expansion of the wing tanks. This involves a Powerplant (fuel system) DER and a structures DER. But with an 8110-3 approval from each, this project can be approved without an STC and without involvement from the Aircraft Certification Branch of FAA. We have contacted the FSDO inspector. Once he heard that we will have 2 DERs involved, he said this will take him 5 minutes to approve once it comes across his desk. I think he is planning to go take a look at the installation just to satisfy that the workmanship is proper. But in this case, we are working within an area that the FSDO inspector is comfortable. Utimately, the IA's who have the best luck are the ones who have earned the trust of their FSDO inspectors.

The only problem with #2 though is the data must be developed to the DERs satisfaction and this can be expensive. Mainly in the time involved in getting the data in a form that is acdeptable for showing compliance with the regulations. In my case, I enjoy these old airplanes and am willing to horse-trade sometimes to keep the applicant's expense down. I have been known to trade my services for airplane parts. Still, I cannot afford to do it for free. And most DERs are not so affordable. I recommend that if you have something in mind you want to do, Shoot me an email and we can discuss the best way to skin the cat.

[crispy critter]

Re: Engine upgrade

Guys,
Sorry for my incorrect input. I was basing that on second hand info from an old time IA who has been gone for sometime now. I will be more careful about what I say unless I know it to be correct.

[barnstmr]

Re: Engine upgrade

Kevin,
Actually, your IA was correct just a few short yrs ago, this wording in the Order did not exist. And many engine upgrades were done by field approval.
We are being bureaucracy'd to death.

[Guest]

Re: Engine upgrade

Guys,
Sorry for my incorrect input. I was basing that on second hand info from an old time IA who has been gone for sometime now. I will be more careful about what I say unless I know it to be correct.

Not a problem Kevin. No apology required. This is a forum, a place to discuss, speculate, debate, theorize, its open discussion that's good for us all.

No one is always correct, or the absolute authority or always wrong, its a great American tradition. And we get to do it from the comfort of home instead of a public square!

There is always something to learn.

Thanks, Dave.

[crispy critter]

Re: Engine upgrade

Thanks guys. So I quess I really wasn't wrong,just behind the times,lol.

[Ed O'Brien]

Re: Engine upgrade

Any good ideas would be appreciated. One year ago I put a
C85-12/w Don's Dream Machine in my rebuilt from the ground-up L2. I have flown it this past year. It flies great. The problem is...
#1. Dave Wiebe in El Dorado, KS, who has done plenty of these engine changes and was confident of a 337 sign-off. BUT, was stalled once he filled out the paperwork and sent it into the Wichita FSDO. No one told either of us... these 337s were "on-hold." This has been a series of surprises and after saying they'd approve engine-- the FAA is now non-communicative... neither approving nor kicking out the paperwork and telling us to wait on #2.
#2. Terry Bowden's STC's approval is running late. Although it seems like it's 6 weeks away at the this point... at least when he and I spoke last week.

So here's the problem. What can one do? I can't get a new annual sign-off. March was my last month to fly legally. Everything on the plane is up to date, ready to go, rebuilt over the last few years and sure does look pretty. So... what does the tribe think? I'm not sure that this a complaint. I think everybody is doing their best. I think the FAA is goofy about first not telling people that they weren't doing 337s, then doing them slowly, and now not doing them at all...
So? What should one do at this time?
With regards;
ED OBRIEN

[barnstmr]

Re: Engine upgrade

Ed,
You can have a DAR issue an experimental airworthiness certificate for a temporary time period under the "research and development" option. They can hold your standard airworthiness certificate until such time that you have your approved paperwork.

[Larry Lyons]

Re: Engine upgrade

So? What should one do at this time?
With regards;
ED OBRIEN


Ed in all honesty I think you should just give it away; give it to someone (me) that would be glad to spend the next few months or even a year getting everything approved again! As my T is at least 5 years from flying I would even give it back to you after I get mine up and going!
Larry (with tongue firmly in cheek!) Lyons

[Ed O'Brien]

Re: Engine upgrade

Larry;
I think your logic on this giving my plane to you is absulutely impeccable. You sir deserve this airplane. Please come pick it up promptly... but... remember... today is April Fools day. Terry thanks for the idea... now I have to figure... are you going to be done with the STC before this exam and paperwork get through the FAA. I love experimentals... but I usually don't fly them... just look at them.
With regards;
ED OBRIEN

[Guest]

Re: Engine upgrade

Any good ideas would be appreciated. One year ago I put a
C85-12/w Don's Dream Machine in my rebuilt from the ground-up L2. I have flown it this past year. It flies great. The problem is...
#1. Dave Wiebe in El Dorado, KS, who has done plenty of these engine changes and was confident of a 337 sign-off. BUT, was stalled once he filled out the paperwork and sent it into the Wichita FSDO. No one told either of us... these 337s were "on-hold." This has been a series of surprises and after saying they'd approve engine-- the FAA is now non-communicative... neither approving nor kicking out the paperwork and telling us to wait on #2.
#2. Terry Bowden's STC's approval is running late. Although it seems like it's 6 weeks away at the this point... at least when he and I spoke last week.

So here's the problem. What can one do? I can't get a new annual sign-off. March was my last month to fly legally. Everything on the plane is up to date, ready to go, rebuilt over the last few years and sure does look pretty. So... what does the tribe think? I'm not sure that this a complaint. I think everybody is doing their best. I think the FAA is goofy about first not telling people that they weren't doing 337s, then doing them slowly, and now not doing them at all...
So? What should one do at this time?
With regards;
ED OBRIEN

Ed,

It all sounds odd to me but I am probably missing some facts.

What does this mean "was confident of a 337 sign-off"?

I don't send 337's to the FSDO for sign off I send them in already signed off.

Is this man an IA? If so, why doesn't he sign his own? FSDO's don't sign off 337 unless its a feild approval and in that case they sign before the work is done.

About a year ago the FAA started processing 337's on a pass thru basis, that is they send them direct Okla. City without any approval process. In some places IA's themselves send them to Okla. City direct, there was a notice about that last spring. In my region they want them sent in to our FSDO first so each FSDO is different regarding that.

Perhaps I misundertstand and you did a feild approval but did the work first and then sent in the paperwork, is that what happened?

Can you fill in some of the blanks?

Dave

[Ed O'Brien]

Re: Engine upgrade

Dave; I can't give you details on the process from either the FAA side or from Dave Wiebe's side. Dave had done many engine change-overs and upgrades, I had pre-cleared this upgrade with him about 2 months before I brought him the plane... meaning he was to have all things set-up with the FAA as well as purchased all needed material and have on hand... but still no finished paperwork as of today. So you and I are both confused about this matter.
With regards;
ED OBRIEN

[Guest]

Re: Engine upgrade

Hi Ed,

Sorry to be less than encouraging but sounds to me like somebody is not telling you the entire story. I guess that's not news though.

Here are some thoughts.

Did you get a copy of the 337 for the work when you got the plane back with an IA's approval signature on it? That is required, you should have gotten one.

Was there a log book entry made? Does it refer to a 337.

Did you get an ICA (instructions for continued airworthiness)?

All 3 things above should have been done to return the a/c to service if you did not get these then you should not have been flying the plane.

In other words the a/c was either returned to service or not after the alteration, you should have not flown it unless it had been returned to service.

If I assume you did NOT get these 3 things then you can't turn him in he did nothing wrong (he never returned it to service) and you will turn yourself in by complaining.

If you can't get an annual done because of this alteration not being approved then you have been illegal all year. Again it was returned to service or not.

If I assume you DID get those 3 items then it was returned to service it has to be eligible for an annual inspection. Somebody is denying it for no good reason.

Dave

[barnstmr]

Re: Engine upgrade

I know Dave Weibe and he's a good guy, excellent restorer, and has been doing a lot of good for general aviation over the past couple of decades. But I won't try to defend his credibility with Ed on this paperwork issue.

But I must say, I believe this is happening more and more lately as the older/experienced FAA FSDO guru's retire and leave the less experienced ones behind. The FAA is losing its common sense approach and having to adopt a more strict by-the-book approach. And, they are having to revise the "book" to account for the things that many previously handled with common sense.

I believe Dave had a surprize education of this fact on Ed's project. The field-approval method for engine changes is a thing of the past. In its place are STCs now, which shifts the review authority to a totally different FAA branch. No longer FSDO, but now ACO. And if you look at the experience base of the ACO engineers, you find some very capable engineers for today's high-tech aerospace industry, and only a few that have actually worked on simple birds like we fly. The result is, most have to learn how to get back to a more simplistic level or they over-complicate these old airplanes. It is my quest to help them stay at the simplistic level and keep common sense in their view of the aging technology that built their industry.

[birdlegs]

Re: Engine upgrade

My field approval for installation of C-85-f cont. with a 337 was done in july of 1955. The only change made was the fuel injector had some rust so a carb. replaced it. Just a bolt on change to N96861 a 1946 BC12D.

It has been flying ever since with no fuel problems from the two wing tanks draining into the header nose tank. No mods to the struts or spars or fuel system. I did have the prop repitched from 74-43 to 74-42 for better mountain flying. The same prop I had on the 65 hp. I operated for a while out of dirt strips above 8000 feet elevation in the mornings and evenings during the summer. Many flights above the 10,000-12,000 foot altitude to clear the mountains. RBA in central Idaho

Rich, this sounds very much like the S.T.C. that is in my logs the original was a C-85 8FJ (fuel injected) issued 1960.Its a bolt on one time to the sn# STC no change to the airframe,been in license since 1960.

[Guest]

Re: Engine upgrade

Originally Posted by Rich. Anderson
My field approval for installation of C-85-f cont. with a 337 was done in july of 1955. The only change made was the fuel injector had some rust so a carb. replaced it. Just a bolt on change to N96861 a 1946 BC12D.

It has been flying ever since with no fuel problems from the two wing tanks draining into the header nose tank. No mods to the struts or spars or fuel system. I did have the prop repitched from 74-43 to 74-42 for better mountain flying. The same prop I had on the 65 hp. I operated for a while out of dirt strips above 8000 feet elevation in the mornings and evenings during the summer. Many flights above the 10,000-12,000 foot altitude to clear the mountains. RBA in central Idaho.

Well this is pure gold.

Rich Andersons 337 was completed prior to the magic date of October 1, 1955 and is therefore approved data.

It can be used to make the same alteration. This is not true of 337s after that date.

No STC, no DER (sorry Terry) required, do a feild approval and use that 337 as the approved data, just plan to do the same mod, refer to the 337 data, send in for feild apporval.

Start selling copies Rich!

Dave