EAA Vintage Aircraft Proposal

[Ragwing nut]

Re: EAA Vintage Aircraft Proposal

I guess I will have to call Ed or Les up and see what is going on.

Mike

[rotaxflyer]

Re: EAA Vintage Aircraft Proposal

For those who are interested, I have attached the Canadian Owners and Pilots Association guide to the Owner Maintenance catagory. It talks about all the issues coming up here.

[barnstmr]

Re: EAA Vintage Aircraft Proposal

Please pardon this long-winded post.

I have been following this issue with great interest. As an FAA-DER and 2nd generation antique airplane owner/restorer, I sympathize with all who are suffering through FAA approvals of major alterations. In my opinion, the FAA has really made a mess of this issue. While I applaud the EAA’s effort to bring this issue to the forefront of discussion, I also believe the EAA proposal is short-sighted. Approval authority for certain changes belongs in the field, but not in the hands of the unprofessional public. Owner maintenance will inevitably lead to experimentation and compromised safety. What might start off with subtle deviations from proven design, will inevitably evolve into unknown and unproven designs. There is an appropriate place for such radical design experimentation and a separate “experimental” category for it. But, this way of aviation life has no place with standard category certified airplanes.

The problem is that DERs and other FAA engineers are currently strapped by the complexities created by the FAA bureaucracy. Aviation professionals have been stifled in their efforts to develop available data into an approval for major alterations. On one hand the FAA has delegated the authority for data approval to DERs, and on the other hand they have taken this authority away, by not allowing their own branches to accept this data, reserving it for review at the ACO (aircraft certification office) level. What was designed to relieve the over-taxed ACO offices has brought them even more burden. This has created undue complexity and unnecessary expense to maintaining the airworthiness of vintage airplanes which were originally certified to a more simplistic, yet safe set of requirements.

The problem is not availability of data. The EAA position is misleading. They state that type certification data is unavailable. This is not true. DATA IS AVAILABLE. The data may be difficult to obtain, but it is out there. And it is more available now than ever, due to the internet and activity of various type clubs who latch on to such information and make it available. I recognize that there are several so-called “orphan aircraft” that have no current type certificate support. But these airplanes were originally certified to a known standard. And aviation professionals who understand this standard can reasonably develop appropriate new data if the original type data is not readily accessible.

Prior to the release of FAA order 8130.10 Change 16 in 2003, the FAA’s own flight standards inspectors had the authority to make field approvals. Until this change, DERs routinely and efficiently assisted owners of vintage airplanes to achieve “field approval” and/or “337 with approved data” for major alterations that are now deemed ineligible for such approval means. While the field approval process is still allowed in some cases, it has been largely suppressed for many types of major alterations. By the implementation of change 16 the FAA has recognized that the engineering expertise base no longer exists in the majority of FSDO offices and admits that it is unwise to continue down the field approval path as it is currently defined. We must all face the reality that the FAA may never again hold the experience base among its direct employees to make such approval findings in the field. Along with this change in philosophy, the aviation industry must recognize that there is no lack of engineering expertise in the field. It exists in the private sector. In fact, the expertise flourishes among engineers who have grown their careers in the TC and STC industry.


Appropriate engineering assessment and approval of proposed design changes is an absolute must for ensuring continued operational safety of vintage airplanes. Professional implementation of approved data for returning airplanes to service is also of vital importance. DERs, DARs, and A&P/IAs in performing their roles are bound by the same FAA regulations, policy, and orders governing type certificate changes to which the FAA engineers and inspectors themselves must adhere. These professionals should be held accountable and therefore subject to enforcement of appropriate penalties for improper conduct. Through proper qualification, training, and oversight, experienced aviation professionals can continue the operational safety of vintage airplanes.

Experienced engineers and inspection professionals must continue to fill important roles in the type design change process for vintage airplanes. The vintage aviation industry must be returned to the pre-2003 days when the FAA allowed the professionals in the aviation field make appropriate findings of compliance within the regulations that were applied safely for vintage airplanes for more than 60 years.
1) I urge the FAA to re-define “vintage airplanes” as those originally certified under CAR 3 or CAR 4a.
2) I urge the FAA to re-define the term the “field approval” as it applies to vintage airplanes.
3) I urge the FAA to re-assign the authority for issuing field approvals for major alterations and/or major repairs to those with the expertise to do so.
4) I urge the FAA to accept the approvals made by its own designees.

[mulwyk]

Re: EAA Vintage Aircraft Proposal

Folks who live near Kansas City can attend the public meeting. It's at the Doubletree Overland Park, 10100 College Blvd. on March 22 and 23 starting at 8AM each day.

The meeting is NOT to discuss the EAA proposal, although the EAA will be there. The purpose is to discuss "continued airworthiness of older general aviation airplanes".

Anyone can make a statement at the meeting (request in advance), and anyone can submit a written statement. The FAA says written statements will be given equal consideration as statements at the meeting.

This would be a good time for anyone who wants to support the EAA proposal to make their opinion known. Written statements (or just a simple note) can be sent to:

Mr. Marvin Nuss
901 Locust, Room 301
Kansas City, Missouri 64106

I'd suggest a short, clear statement of how you feel owner maintenance will improve the airworthiness of vintage aircraft.

Bob Gustafson

[N96337]

Re: EAA Vintage Aircraft Proposal

Terry, that's the most sense anyone has ever made about the current state of affairs and the EAA proposal, as far as I'm concerned!!! You should be applauded for your views and experience, as well as ability to communicate it!!! I couldn't agree with you more!!! I hope this post gets posted on every aviation site!!!!
WELL DONE!!!!!!!
John H.

[barnstmr]

Re: EAA Vintage Aircraft Proposal

I realized I quoted the wrong order. it is 8300.10, change 16. See address below.

http://www.faa.gov/library/manuals/examiners_inspectors/8300/changes/

[flyguy]

Re: EAA Vintage Aircraft Proposal

Well written critique Terry. I have seen owners that knew so much about their aircraft that they could clue the professionals in on a lot of things, and I have see grossly dangerous maintenance and work done on aircraft by owners that were real yahoos and had no understanding of what they were doing.
My present Tcart was owned by an AI first, and then his son who was an AI. When I got it I cannot say there was anything grossly dangerous wrong with it, but almost everything on it showed real ham-fisted methods used to maintain and repair the aircraft. Nearly everything was done noticable wrong.
I have seen professionals do and say incredibly stupid things about aircraft over the years, and I suppose you can attribute that to being the general run of human aptitude.
I cannot help but think that without some sort of serious control and guidance that many owners, being normal average folks, will screw up like normal average folks, and really mess up what they do to their airplanes.
Darryl

[Ragwing nut]

Re: EAA Vintage Aircraft Proposal

I went to the first of those meetings several years ago. Lets just say it was interesting. Unfortunately I have not been able to get to another since.

Mike

[barnstmr]

Re: EAA Vintage Aircraft Proposal

Currently there are 3 ways to approve major alteration as listed below: Only problem is that most major alterations are not eligible for #2.

1) STC

2) Field approval by FSDO inspector - in this case the A&P submits a FAA form 337 without approved data. So there is no IA signature on the 337. Field approval is by FSDO inspector signature to approve the Data. Usually, this requires some drawings, sketches and/or photographs. The inspector will probably do a conformity inspection to ensure the mods meet the documentation (or that the documentation is sufficient).

3) DER approved data with IA approval of 337. - in this case the A&P and and IA signs off the 337 and attaches the DER approval form 8110-3. This is lesser utilized means of approval, but perfectly acceptable. The key to get this done is to contact FSDO at the begining of the mod project and let him know that you are going to use DER support and let him know what you are planning to modify. Then the DER will coordinate with the FSDO to get it done. Ultimately, it is up to the FSDO inspector if he will accept this or reject it. The FSDO cannot reject a DERs approval, but they can reject the return to service if he finds any aspects of the mod not in compliance. Usually they do not question this though.

[mhorowit]

Re: EAA Vintage Aircraft Proposal

I cannot help but think that without some sort of serious control and guidance that many owners, being normal average folks, will screw up like normal average folks, and really mess up what they do to their airplanes.
Darryl

Here, here. I know me. Several is the time I have proudly shown my A&P what I've done only to have him take it apart or round off the corners. I begin to feel confident and before long I'm using the wrong hardware. Probably no one else in the world has this problem, but I need the structure of at least A&P supervision and signoff. - Mike

[Dano"T"]

Re: EAA Vintage Aircraft Proposal

So....who went to this??? any news? Just curious how it was recieved.

[Dano"T"]

Re: EAA Vintage Aircraft Proposal

http://www.eaa.org/communications/ea...23_summit.html


I shoulda looked here first.

[barnstmr]

Re: EAA Vintage Aircraft Proposal

Attendance was good, approx 172 reported. Participation by type clubs was notably greater than expected. The EAA proposal was received with mixed views. While good for some folks, it is not for others. The aging aircraft issues are diverse with many airplane types among all sectors of general aviation.

A clear message that I think all came away with is that Type Clubs will play and increasingly vital role in the continued safety of aging airplanes. We should all do what we can to support the collection and storage of data within the Taylorcraft Foundation and make it available to all.

[cpirrmann]

Re: EAA Vintage Aircraft Proposal

I'll just throw in my 2 cents here. I too would put my plane in the vintage category as I trust my own judgement as I must each time I enter the cockpit. The FAA and others provide valuable information and rules to follow to make flying as safe as possible but it's up to me to use or follow them. The people it scares I understand. There are enough irresponsible people out there already, but do they really let FAA regs stop them? Were the pilots who fly drunk and kill their partying passengers following regs? Were the pilots who fly into known IMC following regs? Were the A&P's who used unapproved parts or short cutted the manual on elevator rigging following regs? The same argument is used for medicals also. The only time the FAA knows I'm acceptable medically is the 20 minutes I'm in the AME's office every two years. The rest of the time it's up to me. The only time the FAA knows my A/C is airworthy is the day it spends in my IA's shop each year. The rest of the time, it's up to me. Pilots fly without current annuals and medicals frequently. There are those who will enjoy this activity responsibly and those that won't. FAA regs won't stop them, but changing them or making them sensible can allow us responsible 'few' a little breathing room.

[mulwyk]

Re: EAA Vintage Aircraft Proposal

Well put,cpirrmann!