Is airplane re-cover a 337 or a logbook entry?

[fearofpavement]

Re: Is airplane re-cover a 337 or a logbook entry?

What is approved data, approvable data and so forth is really not the issue the OP is facing here. The aircraft is lacking paperwork and will remain unairworthy until the paperwork is squared away. This is a classic example of airworthiness not being related to the plane's ability to fly safely but in the lack of documentation of repairs/maintenance that has already occurred.

This is not a fuzzy case of whether the plane can have six ply rated tires or just four. This is a clear cut situation that would only be interpreted in one way by the FAA. And the end result would not be good for the owner/operator or the IA that signed annuals subsequent to the recover job.

I feel the paperwork issue could be resolved but any potential purchaser should be aware that it "could" result in the aircraft needing to be recovered which would likely chop the value in half on a typical Taylorcraft.

[skyboltone]

Re: Is airplane re-cover a 337 or a logbook entry?

What is approved data, approvable data and so forth is really not the issue the OP is facing here. The aircraft is lacking paperwork and will remain unairworthy until the paperwork is squared away. This is a classic example of airworthiness not being related to the plane's ability to fly safely but in the lack of documentation of repairs/maintenance that has already occurred.

This is not a fuzzy case of whether the plane can have six ply rated tires or just four. This is a clear cut situation that would only be interpreted in one way by the FAA. And the end result would not be good for the owner/operator or the IA that signed annuals subsequent to the recover job.

I feel the paperwork issue could be resolved but any potential purchaser should be aware that it "could" result in the aircraft needing to be recovered which would likely chop the value in half on a typical Taylorcraft.

Yes sir Mr Fearofpavement. You couldn't have said it any better if you weighed a ton. I have not made my final contact with the fellow who has the airplane, but I have concluded that I won't even go for a look see until he has his paperwork in order. It's just not worth it. This one has a C-85-12 with the Don Swords mod. That STC in on the FAA disc. But the most recent 337 of ANY type was filed in 1968 and involved a repair to the right wing. The patch was "grade A fabric". If I lived closer, I might go take a look at what he does have. The reason being that I know of a Stinson 108 (1946 no suffix) that I am certain has the Bobcat 180 mod, said mod having been completed by Tom Buce himself. The basic registration data still shows the original 150 Franklin. To make a short story even longer, the feds don't necessarily always have their ducks lined up either. But, something is amiss for sure. If they got the engine STC at the time of the rebuild, why didn't they get the covering (and brakes, and God knows what else) done at the same time? It just doesn't make sense to file one STC but not the rest. The owner needs to present, or have his IA present, an acceptable set of paperwork for my mechanic (Forrest) to look at before I even fly out for a look. Meanwhile, Tom Buce (of Bobcat Stinson mod fame) has a beautiful yellow 41 deluxe that he's been doing the maintenance on for 40 years. With an A-65 and a 74-42. I'm a little bitty dude (150lbs wringing wet) and the 65 would meet my needs flying alone but I WANT more juice. For mountain flying. To take my wife camping. To race Luscombs in. We'll see. I have a pal with a pre-war BC12 and he doesn't worry about it. He says "just plan ahead Dan" But he also has a 180 horse PA-18 in the hangar. Easy for him to say.
Y'all have a Merry and Blessed Christmas.

[NY86]

Re: Is airplane re-cover a 337 or a logbook entry?

This one has a C-85-12 with the Don Swords mod. That STC in on the FAA disc. But the most recent 337 of ANY type was filed in 1968 and involved a repair to the right wing....The basic registration data still shows the original 150 Franklin.... It just doesn't make sense to file one STC but not the rest....

Sounds like at least some folks are still confused. Unless the Don Swords mod was performed prior to 1968, there should be a more recent 337 documenting that mod. To further confuse the issue, engine modifications may not be filed under an "N" number. Unless installation of the modified engine into the airframe also requires an STC, there may be no paper trail from the engine modification to the airframe.

Engine changes filed on 337's don't have any impact on registration data; the registration would have to be changed separately, and often isn't. (Also, see above.)

Lastly, STC's are not filed. STC's are approved data used to justify a modification, which modification is documented on a 337, which 337 is then filed. For every modification supported by an STC there must be a 337 on file; one 337 may be used for one or more modifications.

HTH

[fearofpavement]

Re: Is airplane re-cover a 337 or a logbook entry?

I am wondering if perhaps the 337's ARE filed and someone isn't recognizing them for what they are.

Recovering an aircraft is a pretty major event and it seems like those accomplishing or overseeing that task would be fully aware of the paperwork required. Not sure why it wouldn't have been accomplished other than perhaps non-payment, death, or some type of rift between the owner and the A&P or IA.

And just to make things a little less clear. The A&P fills out the forms, the IA signs them and then the A&P is responsible to get a copy to both the owner/operator and the FAA. (Although in real life the IA often does the paperwork)

So it is feasible that the paperwork was completed and somewhere along the line there was a failure to complete a submission or something. If the owner has a signed copy of the 337 (as he should) and the FAA does NOT have it on file, it could probably be submitted again.

If you like everything about the plane other than the paperwork, then perhaps it would be worth doing some investigation.

[Guest]

Re: Is airplane re-cover a 337 or a logbook entry?

well said John

[lawheelock]

Re: Is airplane re-cover a 337 or a logbook entry?

Part of an earlier post:
>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>
"see part 91.403(d)
(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."

This translates to one needs written persmission for the aircraft and it must be given by aircraft serial number.

Its more than an casual comment or reference is my only point.

Dave "

>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>

This probably is the reason my FSDO told me to quit sending them 337s along with a copy of the STC, but send both to OKC. Filing a copy of the STC is the only way the Feds know that it was assigned to that aircraft or engine.
I am not sure when 91.403(d) was added, but earlier STCs were not required to be assigned to a particular aircraft or engine, and many were installed on aircraft without a 337 just a log entry. Most of those had negligable weight and balance changes so might be interpreted to be minor mods. One time I did several minor mods along with an STC installation of a gps on a plane, sent all the paperwork, 337 and STC copy to the FSDO. Never heard back from them and the it never showed up on the OKC CD either after several years. The owner does have a signed copy of the 337 along with a log entry. This was at about the time the FSDOs decided to have IAs send 337s on STC mods sent directly to OKC.

I really doubt that there is an airplane flying (big or small)that a really careful nitpicker could not find some discrepency in the paper work. The system is that complicated and convoluted and every FSDO has their own little fifedom and every inspector has their own interpretation of the rules. Then when it gets to the DC FAA lawyers it all gets interpreted again, if it ever does get there.

We just have to do the best we can.

Larry Wheelock

[NY86]

Re: Is airplane re-cover a 337 or a logbook entry?

This probably is the reason my FSDO told me to quit sending them 337s along with a copy of the STC, but send both to OKC.

Actually, this is a result of two recent procedural changes. First, the local FSDO has been removed from the filing process. The paperwork is sent directly to OKC, rather than to the local FSDO, for them to turn around and forward to OKC. Second, in order to protect the STC holder, the FAA now requires proof that the rights to the STC have been obtained through proper channels. In fact, I stand behind my previous post: the STC is not filed. What you need to include with the 337 is the permission letter from the STC holder.

many were installed on aircraft without a 337 just a log entry. Most of those had negligable weight and balance changes so might be interpreted to be minor mods.

This is incorrect and never has been otherwise. By definition, an STC amends the Type Certificate or Aircraft Specification and again, by definition, any change to either is a major modification.

[skyboltone]

Re: Is airplane re-cover a 337 or a logbook entry?

Does anyone know Richard Baker A&P 2066947 IA? Or how to find him?

[skyboltone]

Re: Is airplane re-cover a 337 or a logbook entry?

Does anyone know Richard Baker A&P 2066947 IA? Or how to find him?

Never mind. I found him. I'll ask him what he knows. He's the IA so he should know. After all the vagaries and FSDO differences recounted here I suspect there is an explanation. Here's to hope!

[Ray36048]

Re: Is airplane re-cover a 337 or a logbook entry?

Do you think the story is someone owes him money??

[N96337]

Re: Is airplane re-cover a 337 or a logbook entry?

This is incorrect and never has been otherwise. By definition, an STC amends the Type Certificate or Aircraft Specification and again, by definition, any change to either is a major modification.

Exactly right John!

[magman]

Re: Is airplane re-cover a 337 or a logbook entry?

Never mind. I found him. I'll ask him what he knows. He's the IA so he should know. After all the vagaries and FSDO differences recounted here I suspect there is an explanation. Here's to hope!

When you contact him there are a few things you may want to be aware of:

1. YOU do not know what actually happened or there would be no need to call.

It is possible that "bad blood " exists between the parties.

2. Since it appears that the aircraft has been inspected & flown even though it is APPARENTLY Unairworthy

the folks involved may well understand this may be the poverbial "can of worms".

3. An IA, Repair Station & other agencies have an FAA requirement to keep a record of Major Repairs & Alterations.

In some cases an IA may submit this to the FSDO in the form of an "Activity Report".

However; they do NOT have to share this with you or any prospective buyer.

Many agencies charge a "Records Fee" when asked to forward data on activities.

Generally this is about $50 to $100 is what I've encountered.

It can be money well spent.

Paying someone $60 to send a copy of an Overhaul Record from 9 years ago is easier than

opening an engine up to determine compliance with an Oil Pump AD or similar.

[skyboltone]

Re: Is airplane re-cover a 337 or a logbook entry?

When you contact him there are a few things you may want to be aware of:

1. YOU do not know what actually happened or there would be no need to call.

It is possible that "bad blood " exists between the parties.

2. Since it appears that the aircraft has been inspected & flown even though it is APPARENTLY Unairworthy

the folks involved may well understand this may be the poverbial "can of worms".

3. An IA, Repair Station & other agencies have an FAA requirement to keep a record of Major Repairs & Alterations.

In some cases an IA may submit this to the FSDO in the form of an "Activity Report".

However; they do NOT have to share this with you or any prospective buyer.

Many agencies charge a "Records Fee" when asked to forward data on activities.

Generally this is about $50 to $100 is what I've encountered.

It can be money well spent.

Paying someone $60 to send a copy of an Overhaul Record from 9 years ago is easier than

opening an engine up to determine compliance with an Oil Pump AD or similar.

Very good points and advice Magman. I kinda still hope this is the one and my phone conversation did not give me any sort of "uh oh" feeling. I just have a sense that the fellow selling here is probably not top of form any longer. I don't know why there is no 337 for the covering. I went back carefully over the CD from FAA and I had made a mistake. The engine crank and rods + major are 337'd with the STC for supporting evidence. The engine change in the BC12D to make it a BC12D-85 has a 337 with the STC from Terry for supporting evidence. There is no mention of any recover in the FAA CD. The owner has assured me there is a log entry for it. I think this is an honest mistake. I'm treading lightly here and don't intend to be argumentative with anyone.

[fearofpavement]

You're getting closer...

Well, sounds like some of the questions have been resolved. With the "tread lightly" approach you are taking, you may be able to get to the end of the challenge. Doing your homework ahead of time is very wise. If you had plunked down money for the plane and you were now delving into this as the new owner it would be a stressful situation. You can pull the ejection lever at any time... and the owner has a vested interest in the process as well since even if you walk away, the next potential buyer may raise the same questions.

[Ray]

Re: Is airplane re-cover a 337 or a logbook entry?

I can tell you that a 337 is a major repair and like others commenting it must be signed off by an IA and submitted to the FAA. I'm currently completing my tcraft and he has come over and checked every stage of the process. I'm also having a 337 for the ELT install that is required if you go more than 50 miles from your home base. Also dont forget that a weight and balance must be done as well.