Dual brakes - paperwork?

[mhorowit]

I'll be getting my fuselage home next week to begin welding. This is the time to install the dual brakes. I've collected material on the subject over the years but have lost POC information.

If anyone on the forum has put in dual brakes, would you please contact me?
Second - I'll weld these in place; do I need to submit any paperwork and it would be helpful to understand why.

Thanks in advance - Mike

[Guest]

Re: Dual brakes - paperwork?

Yes paperwork must be done/submitted because;

1) the a/c has been altered so it needs an entry in the aircraft records for that and even if it was within its TC it would need the aircraft records entry ie. paperwork.

2) the a/c has been altered beyond its type certificate (TC) so one needs to determine if this is a major alteration. See part 42 appendix D para. (a) (1). It does not look like a major alt to me.

If it is a major alteration a 377 has to be made out and an entry in the aircraft records. If it is not major then just an entry in the aircraft records is needed. This all that I think that you need.

3) debate may ensue regarding welding (see part 42 appendix D para. (b) (1). That applies to welding repair of primary structural members, I don't think you are doing that. btw the brake coversion kits were clamp on rather than weld on.

Maybe that helps.

Dave

[Guest]

Re: Dual brakes - paperwork?

oh yeah I forgot, I added dual brakes to mine. May have pics, not sure

[Hank Jarrett]

Re: Dual brakes - paperwork?

My 45 is "nekid" right now and it has original welded in dual brakes. There are a LOT of funkey things that were tried at the factory on my plane to see if they wanted to do them in production. Welded RH brakes didn't make the cut. It was much cheaper and easier to do the bolt ins. If you want pictures of how the factory did it right after the war, just yell and I will take some. My plane was built in 1945 but kept at the factory till late spring, early summer of 46. It had the welded tube doors (really nice and light, but also didn't make the cut for production) and a REALLY neat skylight that I have all of the original wood for ( VERY complex and also didn't make the production cut).
Hank

[N96337]

Re: Dual brakes - paperwork?

I would definately consider that a Major Alteration. You're doing something that's not on the TC, something that requires welding to the structure, and also something that if not done properly, could definately affect safety... but I could be wrong. Some great advice that my PMI gave me a long time ago... nobody ever got busted for submitting a 337 that wasn't needed on something, but lots of guys get busted for just doing a log entry when it really should have a 337.
Just my 2 cents.
JH

[mhorowit]

Re: Dual brakes - paperwork?

My 45 is "nekid" right now and it has original welded in dual brakes. There are a LOT of funkey things that were tried at the factory on my plane to see if they wanted to do them in production. Welded RH brakes didn't make the cut. It was much cheaper and easier to do the bolt ins. If you want pictures of how the factory did it right after the war, just yell and I will take some. My plane was built in 1945 but kept at the factory till late spring, early summer of 46. It had the welded tube doors (really nice and light, but also didn't make the cut for production) and a REALLY neat skylight that I have all of the original wood for ( VERY complex and also didn't make the production cut).
Hank

Hank - can you think of any downside to welding them in place? the hard part would be making the bend in the long tube, otherwise it looks no more difficult than welding a simple cluster. Economics perhaps? - Mike

[mhorowit]

Re: Dual brakes - paperwork?

Yes paperwork must be done/submitted because;

1) the a/c has been altered so it needs an entry in the aircraft records for that and even if it was within its TC it would need the aircraft records entry ie. paperwork.

2) the a/c has been altered beyond its type certificate (TC) so one needs to determine if this is a major alteration. See part 42 appendix D para. (a) (1). It does not look like a major alt to me.

If it is a major alteration a 377 has to be made out and an entry in the aircraft records. If it is not major then just an entry in the aircraft records is needed. This all that I think that you need.

3) debate may ensue regarding welding (see part 42 appendix D para. (b) (1). That applies to welding repair of primary structural members, I don't think you are doing that. btw the brake coversion kits were clamp on rather than weld on.

Maybe that helps.

Dave

Thanks Dave - I gotta memorize that. Do you think my IA would raise any objection if I suggested a 337 might be appropriate? There seems to be a reluctance among the older IA's to submitt them, ;prefering to see things as a repair. For example, I'm going to replace the tailpost and redo that nasty cluster and I suspect he'll say "make a logbook entry" - Mike

[jCandlish]

Re: Dual brakes - paperwork?

Major vs Minor is a can of worms. How a 'bout side windows? Check out Forrest's comment to this thread: http://vb.taylorcraft.org/showthread.php?t=3322

... MINOR alteration which that photographed one may indeed be one too!

Being a more than thousand miles from the nearest FSDO I'd really like to hear the opinions on what the difference between a major and minor alteration is? Is it "installed windows" or "repaired fabric with equivalent plexiglas/lexan patch"?

Anyways, here's a pic of my dual brake installation;

[mhorowit]

Re: Dual brakes - paperwork?

Major vs Minor is a can of worms. How a 'bout side windows? Check out Forrest's comment to this thread: http://vb.taylorcraft.org/showthread.php?t=3322



Being a more than thousand miles from the nearest FSDO I'd really like to hear the opinions on what the difference between a major and minor alteration is? Is it "installed windows" or "repaired fabric with equivalent plexiglas/lexan patch"?

Anyways, here's a pic of my dual brake installation;

is that a sheathing you have covering the brake cables? did you do away with pulleys? - Mike

[jCandlish]

Re: Dual brakes - paperwork?

There never were pulleys. Those are tubular fairleads. Very much simpler. More pics here: http://www.candlish.net/taylorcraft/...s/2008_Annual/

[mhorowit]

Re: Dual brakes - paperwork?

There never were pulleys. Those are tubular fairleads. Very much simpler. More pics here: http://www.candlish.net/taylorcraft/...s/2008_Annual/

WOW!
Can I do that in the US?
Did I miss the memo?
Obviously Shinn breaks; have to have something to anchor the sheath at either end. Did you install?- Mike

[N96337]

Re: Dual brakes - paperwork?

Guys and girls, this aint rocket science...... there's regs that tell you what is and what isn't a major repair and major alteration.
FAR 1.1 states:
"Major alteration means an alteration not listed in the aircraft, aircraft engine, or propeller specifications—

(1) That might appreciably affect weight, balance, structural strength, performance, powerplant operation, flight characteristics, or other qualities affecting airworthiness; or

(2) That is not done according to accepted practices or cannot be done by elementary operations.

Major repair means a repair:

(1) That, if improperly done, might appreciably affect weight, balance, structural strength, performance, powerplant operation, flight characteristics, or other qualities affecting airworthiness; or

(2) That is not done according to accepted practices or cannot be done by elementary operations.

Mike, the tailpost is definately a major repair...MUST have a 337 appropriately filled out and submitted.
JC...the windows were an option on that plane (weren't they?) so if done according to the way the factory did them, it's a logbook entry. (minor alteration).
We are told each year at our IA renewal seminar, that any time you start welding, it's automatically a MAJOR.
Back to FAR 1.1:
Minor alteration means an alteration other than a major alteration.

Minor repair means a repair other than a major repair.

Don't confuse the 337 submitted for a repair/alteration with a 337 submitted for a field approval.... two totally different, although sometimes overlapping issues here.Now...let's look at FAR 43 appendix A: (I took the liberty of deleting some of the content in the middle...)(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.


(b) Major repairs —(1) Airframe major repairs. Repairs to the following parts of an airframe and repairs of the following types, involving the strengthening, reinforcing, splicing, and manufacturing of primary structural members or their replacement, when replacement is by fabrication such as riveting or welding, are airframe major repairs.

(i) Box beams.

(ii) Monocoque or semimonocoque wings or control surfaces.

(iii) Wing stringers or chord members.

(iv) Spars.

(v) Spar flanges.

(vi) Members of truss-type beams.

(vii) Thin sheet webs of beams.

(viii) Keel and chine members of boat hulls or floats.

(ix) Corrugated sheet compression members which act as flange material of wings or tail surfaces.

(x) Wing main ribs and compression members.

(xi) Wing or tail surface brace struts.

(xii) Engine mounts.

(xiii) Fuselage longerons.

(xiv) Members of the side truss, horizontal truss, or bulkheads.

(xv) Main seat support braces and brackets.

(xvi) Landing gear brace struts.

(xvii) Axles.

(xviii) Wheels.

(xix) Skis, and ski pedestals.

(xx) Parts of the control system such as control columns, pedals, shafts, brackets, or horns.

(xxi) Repairs involving the substitution of material.

(xxii) The repair of damaged areas in metal or plywood stressed covering exceeding six inches in any direction.

(xxiii) The repair of portions of skin sheets by making additional seams.

(xxiv) The splicing of skin sheets.

(xxv) The repair of three or more adjacent wing or control surface ribs or the leading edge of wings and control surfaces, between such adjacent ribs.

(xxvi) Repair of fabric covering involving an area greater than that required to repair two adjacent ribs.

(xxvii) Replacement of fabric on fabric covered parts such as wings, fuselages, stabilizers, and control surfaces.

(3) Propeller major repairs. Repairs of the following types to a propeller are propeller major repairs:

(i) Any repairs to, or straightening of steel blades.

(ii) Repairing or machining of steel hubs.

(iii) Shortening of blades.

(iv) Retipping of wood propellers.

(v) Replacement of outer laminations on fixed pitch wood propellers.

(vi) Repairing elongated bolt holes in the hub of fixed pitch wood propellers.

(vii) Inlay work on wood blades.

(viii) Repairs to composition blades.

(ix) Replacement of tip fabric.

(x) Replacement of plastic covering.

(xi) Repair of propeller governors.

(xii) Overhaul of controllable pitch propellers.

(xiii) Repairs to deep dents, cuts, scars, nicks, etc., and straightening of aluminum blades.

(xiv) The repair or replacement of internal elements of blades.

(4) Appliance major repairs. Repairs of the following types to appliances are appliance major repairs:

(i) Calibration and repair of instruments.

(ii) Calibration of radio equipment.

(iii) Rewinding the field coil of an electrical accessory.

(iv) Complete disassembly of complex hydraulic power valves.

(v) Overhaul of pressure type carburetors, and pressure type fuel, oil and hydraulic pumps.

(c) Preventive maintenance. Preventive maintenance is limited to the following work, provided it does not involve complex assembly operations:

(1) Removal, installation, and repair of landing gear tires.

(2) Replacing elastic shock absorber cords on landing gear.

(3) Servicing landing gear shock struts by adding oil, air, or both.

(4) Servicing landing gear wheel bearings, such as cleaning and greasing.

(5) Replacing defective safety wiring or cotter keys.

(6) Lubrication not requiring disassembly other than removal of nonstructural items such as cover plates, cowlings, and fairings.

(7) Making simple fabric patches not requiring rib stitching or the removal of structural parts or control surfaces. In the case of balloons, the making of small fabric repairs to envelopes (as defined in, and in accordance with, the balloon manufacturers' instructions) not requiring load tape repair or replacement.

(8) Replenishing hydraulic fluid in the hydraulic reservoir.

(9) Refinishing decorative coating of fuselage, balloon baskets, wings tail group surfaces (excluding balanced control surfaces), fairings, cowlings, landing gear, cabin, or cockpit interior when removal or disassembly of any primary structure or operating system is not required.

(10) Applying preservative or protective material to components where no disassembly of any primary structure or operating system is involved and where such coating is not prohibited or is not contrary to good practices.

(11) Repairing upholstery and decorative furnishings of the cabin, cockpit, or balloon basket interior when the repairing does not require disassembly of any primary structure or operating system or interfere with an operating system or affect the primary structure of the aircraft.

(12) Making small simple repairs to fairings, nonstructural cover plates, cowlings, and small patches and reinforcements not changing the contour so as to interfere with proper air flow.

(13) Replacing side windows where that work does not interfere with the structure or any operating system such as controls, electrical equipment, etc.

(14) Replacing safety belts.

(15) Replacing seats or seat parts with replacement parts approved for the aircraft, not involving disassembly of any primary structure or operating system.

(16) Trouble shooting and repairing broken circuits in landing light wiring circuits.

(17) Replacing bulbs, reflectors, and lenses of position and landing lights.

(18) Replacing wheels and skis where no weight and balance computation is involved.

(19) Replacing any cowling not requiring removal of the propeller or disconnection of flight controls.

(20) Replacing or cleaning spark plugs and setting of spark plug gap clearance.

(21) Replacing any hose connection except hydraulic connections.

(22) Replacing prefabricated fuel lines.

(23) Cleaning or replacing fuel and oil strainers or filter elements.

(24) Replacing and servicing batteries.

(25) Cleaning of balloon burner pilot and main nozzles in accordance with the balloon manufacturer's instructions.

(26) Replacement or adjustment of nonstructural standard fasteners incidental to operations.

(27) The interchange of balloon baskets and burners on envelopes when the basket or burner is designated as interchangeable in the balloon type certificate data and the baskets and burners are specifically designed for quick removal and installation.

(28) The installations of anti-misfueling devices to reduce the diameter of fuel tank filler openings provided the specific device has been made a part of the aircraft type certificiate data by the aircraft manufacturer, the aircraft manufacturer has provided FAA-approved instructions for installation of the specific device, and installation does not involve the disassembly of the existing tank filler opening.

(29) Removing, checking, and replacing magnetic chip detectors.

(30) The inspection and maintenance tasks prescribed and specifically identified as preventive maintenance in a primary category aircraft type certificate or supplemental type certificate holder's approved special inspection and preventive maintenance program when accomplished on a primary category aircraft provided:

(i) They are performed by the holder of at least a private pilot certificate issued under part 61 who is the registered owner (including co-owners) of the affected aircraft and who holds a certificate of competency for the affected aircraft (1) issued by a school approved under §147.21(e) of this chapter; (2) issued by the holder of the production certificate for that primary category aircraft that has a special training program approved under §21.24 of this subchapter; or (3) issued by another entity that has a course approved by the Administrator; and

(ii) The inspections and maintenance tasks are performed in accordance with instructions contained by the special inspection and preventive maintenance program approved as part of the aircraft's type design or supplemental type design.

(31) Removing and replacing self-contained, front instrument panel-mounted navigation and communication devices that employ tray-mounted connectors that connect the unit when the unit is installed into the instrument panel, (excluding automatic flight control systems, transponders, and microwave frequency distance measuring equipment (DME)). The approved unit must be designed to be readily and repeatedly removed and replaced, and pertinent instructions must be provided. Prior to the unit's intended use, and operational check must be performed in accordance with the applicable sections of part 91 of this chapter.

(32) Updating self-contained, front instrument panel-mounted Air Traffic Control (ATC) navigational software data bases (excluding those of automatic flight control systems, transponders, and microwave frequency distance measuring equipment (DME)) provided no disassembly of the unit is required and pertinent instructions are provided. Prior to the unit's intended use, an operational check must be performed in accordance with applicable sections of part 91 of this chapter.

Spend a little time reading these....they're not that difficult to understand and it will help you know what you need to do, documentation-wise on your project. It's all available online for FREE! (we used to have to pay for paper copies of this stuff, and spent hours updating every 2 weeks!!) http://ecfr.gpoaccess.gov/cgi/t/text...14cfrv1_02.tpl

JH

[Hank Jarrett]

Re: Dual brakes - paperwork?

Hank - can you think of any downside to welding them in place? the hard part would be making the bend in the long tube, otherwise it looks no more difficult than welding a simple cluster. Economics perhaps? - Mike

The bend in the long tube is a non-problem. Actually I need to look at the tube, it may be cut and welded, but either way it shouldn't be hard to make for someone who has done a landing gear and a fin post.
The only downside to welding in the parts (from a safety/structural standpoint) is the problem with your brakes being available to someone in the right seat who doesn't know how to use them.
The REAL problem is a paper one with the FAA. Make sure whoever is in authority agrees welding them is OK before you put a touch to metal. If you can't get that, just clamp them in like the kits Taylorcraft sold.
Hank

[Guest]

Re: Dual brakes - paperwork?

Thanks Dave - I gotta memorize that. Do you think my IA would raise any objection if I suggested a 337 might be appropriate? There seems to be a reluctance among the older IA's to submitt them, ;prefering to see things as a repair. For example, I'm going to replace the tailpost and redo that nasty cluster and I suspect he'll say "make a logbook entry" - Mike

Hi Mike,

Like John said there is never a problem when you put in a 337 when it may not be required. I think the alteration is not major but there is wisdom in going beyond the minimum requirement so doing a 337 makes sense from that view too.

Your tailpost repair is a major repair and needs a 337 for sure as John also said earlier.

If it is true that your IA would avoid a 337 for a cluster repair then you should be concerned. It could mean that he/she is not skilled or knowledgeble about such things and that may mean that other items are not being adequately addressed as well.

John and I may not see eye to eye on the alteration (which happens normally) but there is no disagreement at all about that cluster repair being major and needing a 337.

I think that you are speculating about what your IA might say. But if it turns out to be as you speculate I am concerned.

Dave

[mhorowit]

Re: Dual brakes - paperwork?

Yes paperwork must be done/submitted because;

1) the a/c has been altered so it needs an entry in the aircraft records for that and even if it was within its TC it would need the aircraft records entry ie. paperwork.

2) the a/c has been altered beyond its type certificate (TC) so one needs to determine if this is a major alteration. See part 42 appendix D para. (a) (1). It does not look like a major alt to me.

If it is a major alteration a 377 has to be made out and an entry in the aircraft records. If it is not major then just an entry in the aircraft records is needed. This all that I think that you need.

3) debate may ensue regarding welding (see part 42 appendix D para. (b) (1). That applies to welding repair of primary structural members, I don't think you are doing that. btw the brake coversion kits were clamp on rather than weld on.

Maybe that helps.

Dave

Dave - Are you sure of the reference? I'm looking in my 2002 FAR and there is no Part 42. There is a part 43, and Appendix A - Major Alterations, Major Repairs and Preventative Maintenance. Based on my reading, replacing that "landing gear brace strut" is a major repair. When they mention Fuselage longeron, are they including replacing a piece of the longeron? And finally, replacing the tailpost doesn't seem to be listed as a major repair! But, covering does. Can all the items be reported in one 337 once the a/c is ready to fly? - Mike