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Sorry in advance for the rant! I'm pissed!
After jumping through a dozen hoops and being led to believe that they were imminently going to approve my Field Approval for the no-weld skylight, the FSDO informed me today that their office will not be processing my 337, and to have my IA submit it through another FSDO.
This is after they had me make several changes to the paperwork, several changes to the physical installation, and two FAA inspector visits.
The incident on the last visit, when I truly expected his blue stamp to come out and walk away with an approved 337, was the kicker. I was honest on all my paperwork, and called out the 5 Minute Epoxy glue by name which I used to glue a dozen little 1x2 wood blocks in place. I knew the epoxy was 100 times stronger than it needed to be for that application.
After his having seen that material called out since day 1 on my paperwork, he brought it into question at the last visit, saying that it was not an approved glue. I told him it was quite a little better than the HORSE HOOF glue (Casein) that was approved. He agreed that the epoxy was better physically, but that he would have a tough time in front of an NTSB judge explaining why the FAA signed off model airplane glue on a certified airplane.
So we talked for a while and he finally backed off enough to give me the option of showing that this glue was indeed an approved glue or met the standards for an approved glue. Then, he said, he would keep working with me toward the approval of this installation... fair enough.
So I spent the entire weekend researching the old Mil-Specs for several aircraft glues, the AC 43.13, the CAM 18, the CAR4 certifications, the ASTM test certifications, etc. etc. etc. After a brief struggle with the computer and the telephone, I found exactly what I was looking for: three different trails of information showing that 5 Minute epoxy met ( and greatly exceeded) the minimum Mil-Spec strengths for FAA approved Resorcinol, Formaldehyde glues, and the ASTM D 1002 tests which the DoD uses to replace the retired and obsolete epoxy Mil-Spec testing.
So I quoted the new 43.13 which says clearly that any airplane glue that meets a Mil-Spec or Aerospace Mat'l Standard for airplane wood glue is acceptable to the Administrator. I furnished the FAA with the minimum shear strength set forth in the Mil-Specs for Resorcinol and Formaldehyde glues (less than 500 psi lap shear), and the ASTM test results of 5 Minute Epoxy at 1900 psi lap shear. A similar Mil-Spec set forth a minimum shear strength of 1500 psi for epoxy.
Of course the epoxy has greater strength than the FAA approved wood itself, so an epoxy bond greater than 900 psi (ANC-18 shear strength of Sitka Spruce wood) is academic from a flight safety standpoint. Of interest is the old ANC-18 Army aircraft wood spec says that a glue joint must meet 1/2 or less of the wood material shear strength, meaning 450 psi for Sitka. This is acceptable to the FAA... 450 psi... and good old 5 Minute epoxy is 4 times stronger.
I submitted irrefutable and valid documentation that showed this epoxy would meet or exceed the requirements set forth in 43.13. I e-mailed him all the info, mil-spec and other related internet resources to verify at his discretion, etc.
Today I get a call from the FAA inspector saying that they just don't want to deal with it, more or less, hanging their hat on the idea that my IA is based in Las Vegas so the local FSDO won't accept it... except for the fact that this geographical issue had been solved early on, with specific approval my my IA's local FSDO to run this through the local FSDO here because the plane was here.
So i will have to resubmit the paperwork all over again through another FSDO, running the risk that they too will find an excuse to not deal with this.
Did I mention that there are NO changes to the primary structure in this 337, and the "form fit and function" of my skiylight corresponds almost exactly to the Taylorcrat F-21B series skylight which was a factory option?
You know, I was just starting to get a good feeling from the FAA, that maybe there are still some people in the organization that care about helping aviation! The FSDO inspector had flown Taylorcrafts, agreed 100% that the skylight was a worthwhile mod, and agreed 100% that my installation was well thought out, clean and safe in his opinion.
More than one person at my local airport has told me that this is a sleazy tactic the FAA uses on purpose, to sucker you in and create the illusion they are trying to actually help the little guy, when their real intention is to eventually squash the project or bury it in busy work so they don't have to sign anything off. I would have doubted this, except for the fact that one of my hangar neighbors had exactly the same experience... the same "bait and switich" right down to the details and the "I'm going to try and help you because I think this is a worthwhile mod"... from another FAA inspector on a PA24 Comanche instrument panel mod he was doing.
I'm completely disgusted with this episode and damn well pissed off at not being able to finish my annual and start flying. The EAA and AOPA have said there are good people in the FAA who really do care and they are working with those organizations to make it easier... but my personal experience with the FAA on this skylight project has been a nightmare and a wrongful nightmare at that. If there was ANYTHING unsafe or inappropriate on my installation, then that's one thing. But trying to discourage me, and then bury me in busy work until I got tired of fighting, then slamming the door in my face when I jumped through the last hoop, has cost the FAA my respect until further notice.
It is with great sadness and disappointment that I lose faith in the FAA's small airplane division, and must return to the old-school view of "it's us versus them".
Bill Berle
After jumping through a dozen hoops and being led to believe that they were imminently going to approve my Field Approval for the no-weld skylight, the FSDO informed me today that their office will not be processing my 337, and to have my IA submit it through another FSDO.
This is after they had me make several changes to the paperwork, several changes to the physical installation, and two FAA inspector visits.
The incident on the last visit, when I truly expected his blue stamp to come out and walk away with an approved 337, was the kicker. I was honest on all my paperwork, and called out the 5 Minute Epoxy glue by name which I used to glue a dozen little 1x2 wood blocks in place. I knew the epoxy was 100 times stronger than it needed to be for that application.
After his having seen that material called out since day 1 on my paperwork, he brought it into question at the last visit, saying that it was not an approved glue. I told him it was quite a little better than the HORSE HOOF glue (Casein) that was approved. He agreed that the epoxy was better physically, but that he would have a tough time in front of an NTSB judge explaining why the FAA signed off model airplane glue on a certified airplane.
So we talked for a while and he finally backed off enough to give me the option of showing that this glue was indeed an approved glue or met the standards for an approved glue. Then, he said, he would keep working with me toward the approval of this installation... fair enough.
So I spent the entire weekend researching the old Mil-Specs for several aircraft glues, the AC 43.13, the CAM 18, the CAR4 certifications, the ASTM test certifications, etc. etc. etc. After a brief struggle with the computer and the telephone, I found exactly what I was looking for: three different trails of information showing that 5 Minute epoxy met ( and greatly exceeded) the minimum Mil-Spec strengths for FAA approved Resorcinol, Formaldehyde glues, and the ASTM D 1002 tests which the DoD uses to replace the retired and obsolete epoxy Mil-Spec testing.
So I quoted the new 43.13 which says clearly that any airplane glue that meets a Mil-Spec or Aerospace Mat'l Standard for airplane wood glue is acceptable to the Administrator. I furnished the FAA with the minimum shear strength set forth in the Mil-Specs for Resorcinol and Formaldehyde glues (less than 500 psi lap shear), and the ASTM test results of 5 Minute Epoxy at 1900 psi lap shear. A similar Mil-Spec set forth a minimum shear strength of 1500 psi for epoxy.
Of course the epoxy has greater strength than the FAA approved wood itself, so an epoxy bond greater than 900 psi (ANC-18 shear strength of Sitka Spruce wood) is academic from a flight safety standpoint. Of interest is the old ANC-18 Army aircraft wood spec says that a glue joint must meet 1/2 or less of the wood material shear strength, meaning 450 psi for Sitka. This is acceptable to the FAA... 450 psi... and good old 5 Minute epoxy is 4 times stronger.
I submitted irrefutable and valid documentation that showed this epoxy would meet or exceed the requirements set forth in 43.13. I e-mailed him all the info, mil-spec and other related internet resources to verify at his discretion, etc.
Today I get a call from the FAA inspector saying that they just don't want to deal with it, more or less, hanging their hat on the idea that my IA is based in Las Vegas so the local FSDO won't accept it... except for the fact that this geographical issue had been solved early on, with specific approval my my IA's local FSDO to run this through the local FSDO here because the plane was here.
So i will have to resubmit the paperwork all over again through another FSDO, running the risk that they too will find an excuse to not deal with this.
Did I mention that there are NO changes to the primary structure in this 337, and the "form fit and function" of my skiylight corresponds almost exactly to the Taylorcrat F-21B series skylight which was a factory option?
You know, I was just starting to get a good feeling from the FAA, that maybe there are still some people in the organization that care about helping aviation! The FSDO inspector had flown Taylorcrafts, agreed 100% that the skylight was a worthwhile mod, and agreed 100% that my installation was well thought out, clean and safe in his opinion.
More than one person at my local airport has told me that this is a sleazy tactic the FAA uses on purpose, to sucker you in and create the illusion they are trying to actually help the little guy, when their real intention is to eventually squash the project or bury it in busy work so they don't have to sign anything off. I would have doubted this, except for the fact that one of my hangar neighbors had exactly the same experience... the same "bait and switich" right down to the details and the "I'm going to try and help you because I think this is a worthwhile mod"... from another FAA inspector on a PA24 Comanche instrument panel mod he was doing.
I'm completely disgusted with this episode and damn well pissed off at not being able to finish my annual and start flying. The EAA and AOPA have said there are good people in the FAA who really do care and they are working with those organizations to make it easier... but my personal experience with the FAA on this skylight project has been a nightmare and a wrongful nightmare at that. If there was ANYTHING unsafe or inappropriate on my installation, then that's one thing. But trying to discourage me, and then bury me in busy work until I got tired of fighting, then slamming the door in my face when I jumped through the last hoop, has cost the FAA my respect until further notice.
It is with great sadness and disappointment that I lose faith in the FAA's small airplane division, and must return to the old-school view of "it's us versus them".
Bill Berle
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