Building a new aircraft

If Amelia Earhart's plane was ever found and the only salvageable part was the data plate, you can be sure you'd see a shining new Lockheed Model 10-E Electra with the original data plate doing a tour of all the air shows...just like Glacier Girl. It's up to the FAA as to what's allowable.
 
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Bell206 said:
"Was" is the key word here. After several OEMs went after data plate builders/swappers in the 80s, it has fallen out of favor and the Feds began enforcing the rules. At one time it was the only way to get certain aircraft like a Stearman. The only thing that has really changed is the FAA has finally defined what is a repairable aircraft and they require you to follow the rules that have always been there, i.e., you can't build an aircraft from only a data plate. Section 3 in Order 8100.19 further explains this. However, there are some CRSs that can push these types of repairs to the limit, but they operate under FAA approved processes which is a little different than this Cub.
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That is a matter of interpretation
The guy that tipped the scales on data tags was a Bonanza owner that he built and had no data tag, he was trying to force the FAA to issue one , they said no way, you must get a data tag from the OEM manufacturer.
But when you have a data tag, the whole picture changes. It is still legal to repair the aircraft.
(I just got off the phone)
In this case we have all the documentation. The AWC, N number, old logs, and the registration.
I believe doing it as a repair is the method we need to use.

next step for me is to establish If the administrator will allow the transfer of the data tag to a new fuselage. and how to make that request?
 
Tom-D said:
The guy that tipped the scales on data tags was a Bonanza owner that he built and had no data tag, he was trying to force the FAA to issue one ,
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The Bonanza guy was the latest episode about 4-5 years ago. I think it was the final straw behind Order 8100.19. The big push happened in the late 80s when Bell Helicopters went after a company who combined various wrecked airframes under one data plate. Problem was Bell had started an in-house "destroyed listing" and several of these "repaired" aircraft were traced back to the list via warranty claims if I remember correctly.
Tom-D said:
next step for me is to establish If the administrator will allow the transfer of the data tag to a new fuselage. and how to make that request
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If I recall the ACO has final approval but they use the local FSDO for all their legwork. Have seen it done with helicopters but it was through a CRS procedure and DAR. Maybe a "what if" call to the regional ACO office to see how your area handles the process?
 
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You can move the data tag to a new STC-PMA airframe or a salvaged airframe if you're talking Cubs. A Cessna would be harder to do.
 
Stewartb said:
You can move the data tag to a new STC-PMA airframe or a salvaged airframe if you're talking Cubs. A Cessna would be harder to do.
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Here is the FAR,
(b) Except as provided in paragraph (d)(1) of this section, no person may remove, change, or place identification information required by paragraph (a) of this section, on any aircraft, aircraft engine, propeller, propeller blade, or propeller hub, without the approval of the FAA.

(c) Except as provided in paragraph (d)(2) of this section, no person may remove or install any identification plate required by §45.11, without the approval of the FAA.

(d) Persons performing work under the provisions of Part 43 of this chapter may, in accordance with methods, techniques, and practices acceptable to the FAA—

(1) Remove, change, or place the identification information required by paragraph (a) of this section on any aircraft, aircraft engine, propeller, propeller blade, or propeller hub; or

(2) Remove an identification plate required by §45.11 when necessary during maintenance operations.

(e) No person may install an identification plate removed in accordance with paragraph (d)(2) of this section on any aircraft, aircraft engine, propeller, propeller blade, or propeller hub other than the one from which it was removed.

Here is the question.

If I remove the data tag from N1234, then replace the fuselage, then replace the data tag.
have I replaced the data tag on the one from which it was removed ?
 
That one again? How long has it been for sale and how many times do you need to be told that external load permits are not transferable?
 
Stewartb said:
That one again? How long has it been for sale and how many times do you need to be told that external load permits are not transferable?
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That's all with Cubcrafters
An A/C like that has a very narrow market.
 
I appreciate your depth of knowledge of the high performance Cub world. That’s something I’d like to learn more about someday. ;)
 
Tom-D said:
If I remove the data tag from N1234, then replace the fuselage, then replace the data tag. have I replaced the data tag on the one from which it was removed ?
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It depends. It's my experience there are separate takes depending on the aircraft construction: tubular frame vs monocoque. But its my understanding if you still have a piece of primary structure, as defined by the Feds, that is "attached" to the original data plate, you are still under the repair guidance of Part 43. For example, if you had an original wing then replacing the fuselage would be a repair. However, when you get to the level of changing every structure associated to a data plate....

You mentioned that Cub Crafters had previously done his paperwork, what did it look it? Also since he buys his parts from Univair, I'm sure they would have some tips/guidance as would Airframes Alaska. I can't see these vendors remaining in business if there is not a path to swapping the data plate at the A&P/IA level.

If you want to read about data plate swaps from the other side of the fence, here's several links I'm aware of. Read into them what you want.
https://www.ntsb.gov/legal/alj/OnODocuments/Aviation/4787.pdf
https://www.ntsb.gov/legal/alj/OnODocuments/Aviation/5722.PDF
https://www.ntsb.gov/legal/alj/OnODocuments/Aviation/3937.PDF
 
Bell206 said:
It depends. It's my experience there are separate takes depending on the aircraft construction: tubular frame vs monocoque. But its my understanding if you still have a piece of primary structure, as defined by the Feds, that is "attached" to the original data plate, you are still under the repair guidance of Part 43. For example, if you had an original wing then replacing the fuselage would be a repair. However, when you get to the level of changing every structure associated to a data plate....

You mentioned that Cub Crafters had previously done his paperwork, what did it look it? Also since he buys his parts from Univair, I'm sure they would have some tips/guidance as would Airframes Alaska. I can't see these vendors remaining in business if there is not a path to swapping the data plate at the A&P/IA level.

If you want to read about data plate swaps from the other side of the fence, here's several links I'm aware of. Read into them what you want.
https://www.ntsb.gov/legal/alj/OnODocuments/Aviation/4787.pdf
https://www.ntsb.gov/legal/alj/OnODocuments/Aviation/5722.PDF
https://www.ntsb.gov/legal/alj/OnODocuments/Aviation/3937.PDF
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Your examples are clear violations of the FAR, in as much you can not swap data tags from one N number to another.
We would not be doing that. we would be replacing an old part with a new one. not one from another aircraft. But I'm not certain that makes any difference.

The previous aircraft that he had CubCrafters do the return to service I was never involved with and their logs are not available to me. Cubcrafters is a 6 hour drive for me.
 
if you want the correct answer....call your PMI.

...and ask for a friend.... lol;)
 
Another what if by tom. This one is good. A lot of good answers from some very knowledgeable people also. As with most thing in the fars the answer is maybe. My take is the faa gets real upset when people ask for forgiveness after the fact. Like the bo dude. Working with your pmi before starting is the best line to take. The deciding question is how much, and what type of original structure is required to be called a repair? can it be done as one repair? Or will multiple repairs be in order? As in rebuild wings, reinstall, do 337's return to service. Next week replace fuse, do paperwork, return to service. Next week replace horizontal etc etc.
 
Checkout_my_Six said:
...and if it's all documented on 337's, what could go wrong? :D
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Give your reason for a 337 on rebuilding a wing, They have no serial numbers.

Log book entry :
Rebuilt and installed new wing with all new certified parts from Univair, covered with the Poly-Fiber system IAW the blue prints and STC instructions.
 
Checkout_my_Six said:
doesn't the STC require a 337?.....o_O
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Certainly, but not a simple wing rebuild..the STC would be just for the fabric system, not the parts to rebuild the wing.
and all airframe STCs can go on one 337.
Block 8 entry:
the following STCs were installed. In accordance with STC instructions
(then just list them)
 
Tom-D said:
Give your reason for a 337 on rebuilding a wing, They have no serial numbers.
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S/Ns not required. 43 Appx A (b)(1v), (x), (xxv). Repair is your only option, i.e., completing a 337. Otherwise it would be manufacturing a wing. Now if you want to test the system, you could have the owner provide all the parts and at his direction assemble (manufacture) the wing as an owner-produced part which would require its own P/N marking per Part 45. All legal without a 337 required.

So your logbook entry would read: Installed new owner-produced wing assembly, P/N Bubba-001, covered with the Poly-Fiber system IAW the blue prints and STC instructions.
 
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Tom-D said:
RTFQ.. then answer it. Bell did.
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Read the thread and maybe my response will make sense to you. I was answering the question two posts up about why not just register it as experimental or build a carbon cub. The world doesnt revolve around you and not every post people make in a thread is in direct response to your questions. I actually tend to just ignore most of what you post anyways as very little of it serves any purpose other than to try and stir things up on here. If answering other people in a thread you started bothers you that much feel free to just skip over my posts from now on.
 
The title for this thread is "Building A New Aircraft". Mechanics can't do that legally.

Then there is discussion about aircraft being "rebuilt". Again, mechanics in the field can't do that legally.

They can repair and overhaul. How much can they repair and overhaul? Depends. If the mindset from the start is to make a plane and then make the paperwork fit, that would be a stretch and the linked NTSB reports seem show that to be the case. If the mindset is to rebuild aircraft abc123 and to do that I need this part and that, etc, etc, then I would think that is acceptable. The difference may be subtle, but it is tangible. I have always thought that at least some major piece of the original had to be there for the rest of the repair parts to be hung on.
 
Tom-D said:
That is a matter of interpretation
next step for me is to establish If the administrator will allow the transfer of the data tag to a new fuselage. and how to make that request?
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are you required to ask? If not why ask? Getting the government involved in anything unless absolutely necessary is never a good idea...Government at all levels ultimately seeks only power...(I think I am paraphrasing a quote there)
 
To me to crux is whether you're repairing a plane and maintaining that plane's identity or swapping a data tag to transfer the original identity to a different airplane. I've done a ground up restoration that used a new PMAd airframe. I moved the data tag. The FAA took no exception.
 
tceq24443 said:
are you required to ask? If not why ask?
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How would you gain authorization if you didn't ask..There must be a way, otherwise why did the FAA put that phrase in the FAR.?
 
Bell206 said:
S/Ns not required. 43 Appx A (b)(1v), (x), (xxv). Repair is your only option
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Correct, but it would not be an alteration, So 43-A would not apply, just a simple repair signed of in the maintenance records. The only 337 that would be required is the one applying the Poly-fiber STC
 
Stewartb said:
To me to crux is whether you're repairing a plane and maintaining that plane's identity or swapping a data tag to transfer the original identity to a different airplane. I've done a ground up restoration that used a new PMAd airframe. I moved the data tag. The FAA took no exception.
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Can you tell me how the fuselage was returned to service? what verbiage was used.
 
Tom-D said:
but it would not be an alteration, So 43-A would not apply,
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Alteration? I believe I stated, 43 App A, (b) which is Major Repairs. And it would apply. You also forget the Part 1 definition of major repair. But if you want to replace all structural members of a wing as a minor repair, to each their own.

But then again you think touching up the paint on a prop is a major repair.;)
 
Bell206 said:
Alteration? I believe I stated, 43 App A, (b) which is Major Repairs.
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Repair of a wing by replacement of parts is not a major.
The wing was assembled with all new parts, When you replace the entire spar, the spar was not repaired. the wing was.
 
Tom-D said:
Repair of a wing by replacement of parts is not a major.
The wing was assembled with all new parts, When you replace the entire spar, the spar was not repaired. the wing was.
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It can be....what's the definition say?o_O
 
Tom-D said:
Repair of a wing by replacement of parts is not a major.
The wing was assembled with all new parts, When you replace the entire spar, the spar was not repaired. the wing was.
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Errrrrrrr, say again? o_O
 
Tom-D said:
Repair of a wing by replacement of parts is not a major.
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Curious. So your interpretation of the Part 1 definition of major repair is that if the repair is done improperly it will not affect the aircraft and that a repair of an entire wing falls under an "elementary operation"?

Tom-D said:
was assembled with all new parts,
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Then by extension, if you assemble an engine with all new parts would that be a minor repair also? And a minor repair on a propeller with all new parts?
 
Bell206 said:
Curious. So your interpretation of the Part 1 definition of major repair is that if the repair is done improperly it will not affect the aircraft and that a repair of an entire wing falls under an "elementary operation"?


Then by extension, if you assemble an engine with all new parts would that be a minor repair also? And a minor repair on a propeller with all new parts?
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Ask yourself, If this were a major repair, wouldn't you need approved data to make the repair? what approved data is required to assemble a wing from all new parts?

The engine question, the overhaul of an engine is not a major repair, no matter how many new parts are used, and that is what assembly with all new parts would be.

The propeller question, you must know we A&Ps are not allowed to do that scope of work on propellers. we are allowed to do minor maintenance only. plus, when you strip and paint a prop, when done wrong wouldn't that make it a major under your interpretation?
 
Bell's question about assembling an engine with all new parts brings to light the answer to my original question.
The data tag would require to be moved from the old case to the new one. That's done all the time when replacing cases with new, under the rules given in FAR 45.
What's the difference of moving the data tag from the old fuselage to a new one under the same rules. "to facilitate the maintenance"

(d) Persons performing work under the provisions of Part 43 of this chapter may, in accordance with methods, techniques, and practices acceptable to the FAA—
(1) Remove, change, or place the identification information required by paragraph (a) of this section on any aircraft, aircraft engine, propeller, propeller blade, or propeller hub; or

(2) Remove an identification plate required by §45.11 when necessary during maintenance operations.
 
Tom-D said:
what approved data is required to assemble a wing from all new parts?
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That would be manufacturing, not repairing.

Tom-D said:
engine is not a major repair, no matter how many new parts are used, and that is what assembly with all new parts would be.
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Overhaul is not major, correct. But again, assembly with all new parts would be considered manufacturing, not repair.

Tom-D said:
when you strip and paint a prop, when done wrong wouldn't that make it a major under your interpretation?
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Prop repair as above, I would not classify it as major, though the case for doing so could be made.
 
Just for supposition, I have an 11AC, that when uncovered it was found that all 4 wing spars were rotten, and need to be replaced. Ribs are corroded beyond use, so spars and ribs get replaced. Then it was found that the drag/antidrag wires, as associated fittings to be corroded beyond repair, so they got replaced, of course new leading edge was installed, and the tip bows were bent, so they got replaced, All the attach fittings were corroded, and bolt holes elongated, so they got replaced as well. The compression struts were all rusty, and had pinholes, so they got replaced. The aileron hinges were not there, so had to get new ones. The pulleys and associated mounting hardware, were shot, so they all got replaced. Pretty much every single part of the wings got replaced with new PMA parts. Essentially a pair of brand new wings. Is that a repair, or built new?
 
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