Possible aircraft purchase with no data plates

T

tintin6680

Filing Flight Plan
Joined
Aug 25, 2023
Messages
8
Display Name
Display name:
Tyler
Hello all, I am going to keep this as anonymous as I can to protect the involved parties. Looking at purchasing a post war tube and fabric plane that is in decent shape but needs a lot of overall work. It was last registered for flight 4 decades ago and was de assigned due to expiration in 2013 but I recently checked with aircraft registration branch and it is not marked as scrapped/ destroyed and I was told there shouldn't be any issues when it comes time to register. The paperwork is as follows - It has an A/W certificate in it from 1957 and it has a chain of custody for ownership. The serial number on the fuselage matches the factory N-number (only one it's ever had) and all other documents that it should that we have possession of. For reasons that we have some info about but won't ever fully know, ALL the logbooks and data plates are gone. I know that the aircraft in its entirety was not ever wrecked or stolen. They have never been assigned to another aircraft. I am well aware of how the FAA can get in situations like these and this case is complicated by the fact that the TC holder has not been reachable for over a decade and will not be able to vouch for or supply a replacement plate. The engine will just be replaced and used for good parts unfortunately.

My question is this: Has anyone seen a situation like this where the FAA did eventually grant authorization for a new data plate? And what all documentation would be required for that? I would like to see this plane fly again because it is a rare bird but I am inclined to think this is a 'not-a-snowballs-chance' kind of situation.
 
Last edited:
tintin6680 said:
Has anyone seen a situation like this where the FAA did eventually grant authorization for a new data plate? And what all documentation would be required for that?
Click to expand...
Without the model of aircraft I can't offer much detail. Regardless, you state the TC holder has been "regulated to the pages of history." But do you mean the airframe TC has been surrendered back to the FAA? This is important. The logbooks on the other hand are immaterial at this point.
 
Before 1987, there was no requirement for an external data plate. Metal planes frequently tended to have them, but tube and fabric did not. To comply with the inane DEA-pushed legislation, you had to retrofit your plane if it didn't have one.
 
flyingron said:
Before 1987, there was no requirement for an external data plate. Metal planes frequently tended to have them, but tube and fabric did not. To comply with the inane DEA-pushed legislation, you had to retrofit your plane if it didn't have one.
Click to expand...
I believe the OP is referring to the permanent data plate required by regulation since day one per the CARs. The external data plate you reference was a secondary requirement decades later. If you would like a reference be happy to provide it along with the rule about removing those original data plates.;)
 
Bell206 said:
Without the model of aircraft I can't offer much detail. Regardless, you state the TC holder has been "regulated to the pages of history." But do you mean the airframe TC has been surrendered back to the FAA? This is important. The logbooks on the other hand are immaterial at this point.
Click to expand...
Believe this is pertinent. I know of only one TC holder truly 'regulated to the pages of history' and that is WACO. When they went out of business post WWII, they simply shut down. All WACO documentation went public domain and no one owns the WACO Type Certificates, not even the new WACO Classic.

Just about every other manufacturer was bought by someone else. I think Piper bought up much of Stinson when they closed, but the 108 TC specifically belongs to Univair.

I know it can be done, but depending on who owns the information may dictate which hoops you have to jump through.

My WACO did not have an original data plate and many warbirds do not have original data plates.

14 CFR 45.13 provides guidance for data plates. There are companies that will make reproduction data plates, but 45.13 (b) and (c) pretty much say you need FAA approval to place a data plate on an aircraft.

Bottom line, I suspect you will need to contact the FSDO and explain the situation and ask what they need to approve placing a new data plate on the aircraft.
 
But he is replacing a data plate. I do not think B or C is a limiting factor here.

We come across components often that are missing data plates. They get re-made and replaced. In our case we have good records to positively identify the installed part.
 
Bacho said:
We come across components often that are missing data plates. They get re-made and replaced.
Click to expand...
There are different Part 45 ID rules for products (aircraft, engines, props) and articles (components, all other parts). Even items defined as articles if they are listed in an Airworthiness Limitations Section they too must follow a stricter path when it comes to data plates and markings. In the OPs case while there are specific rules dealing with the removal of data plates on products for maintenance, if he does not have the original data plate to reinstall on that aircraft and engine then the FAA ACO must be involved. Plus its not a slam dunk he can get a replacement but definitely doable in with the right circumstances. And if by chance someone does hold the TC for this aircraft he will also need a LOA from that holder if he wishes to maintain his Standard AWC. Plenty of guidance on this even going back to the CARs.
 
Last edited:
If the aircraft still has a valid AWC the FAA's only involvement is to renew the registration, they won't be inspecting it. The missing logs and data plate are between you and the IA who will be doing the first annual. You can start new logs, I presume the plane and engine are getting a full rebuild anyway, and make a new data plate that looks old.
 
Dana said:
If the aircraft still has a valid AWC the FAA's only involvement is to renew the registration, they won't be inspecting it.
Click to expand...
The AWC becomes invalid if there is no Part 45 data plate on the aircraft as it is a condition to issue an AWC. And if the TC has been surrendered or abandoned one's chances to get a new data plate and Standard AWC become difficult if not impossible depending on the scenario.

1693061438741.png
 
That's why many restorers will just quietly make and install a new data plate and not mention it. Not that I'm suggesting that anybody break the law... :rolleyes:
 
Dana said:
That's why many restorers will just quietly make and install a new data plate and not mention it.
Click to expand...
Interesting. But thats not my experience as all the "restorers" I know or dealt with over the years go the legit route to get replacement data plates. And on the few aircraft where there is no option they simply go the Special AWC and EE. It can be rather easy to find bogus data plates and once found will open a pandoras box for the person(s) who did it. But it does happen unfortunately.
 
Appreciate all the responses so far. We are talking about the original airframe data plate not that stupid DEA tag. I edited this in the first post but to clarify, the TC is held by an LLC but they have no physical footprint anymore and even people who had connections and were in contact with them in the past haven't been able to reach them for over a decade so they are effectively zero help. The aircraft would be getting a full restoration so AD compliance and the like aren't a concern for me. There are no time limited parts issues. From what I've heard, not having the logbooks only causes an issue in helping to positively identify the aircraft as being the one I claim it is to the FAA.
 
tintin6680 said:
From what I've heard, not having the logbooks only causes an issue in helping to positively identify the aircraft as being the one I claim it is to the FAA.
Click to expand...
The original AWC, chain of ownership, and the other documents you do have are worth a lot more than the logbooks for this in my experience. Most of the aircraft I dealt with didn't have any paper. The only issue may be checking the aircraft conformity but there are methods to perform that as well. And if the engine and prop were mfg'd by a legacy company (P&W, Continental, McCauley, etc) you may want to address those plates/markings/records separately.

But since it appears the airframe TC is still active though not directly supportive, your only option is via the FAA. However, they may want to see that you personally contacted the holder vs just hearing about their lack of support. Below are a couple guidance docs on getting a replacement AWC through the FAA. There's a 3rd doc but since the FAA RGL was dumped into the DRS I have lost a number of links. Since you plan to restore the entire aircraft I'd sit down with your mechanic who will sign the next annual and come up with a plan then contact the FSDO before you start work to see were you're at. Worst case is you'll have to get a Special AWC under Experimental Exhibition to fly. Good luck.

1693082410787.png
Hofmann-Vexa LOI

AC 45-2
Revision E paragraph is 6.8 vs 6(i)(3) as mentioned in the LOI.
 
Some FSDO's require data plates to be surrendered when an aircraft is scrapped.
 
tintin6680 said:
From what I've heard, not having the logbooks only causes an issue in helping to positively identify the aircraft as being the one I claim it is to the FAA.
Click to expand...
There are other ways proving to the FAA that it is the same airplane. Some manufacturers like WACO stamped the serial number into the frame. Other methods that work is go through the FAA 337 records for the airplane and like comparing dental records to identify remains, you can use evidence of documented repairs to validate it is the same airplane.

Logbooks are important for proving AD compliance or documenting certain life limited parts. Outside of that , lack of logbooks is just something to haggle over when selling the airplane.
 
Fearless Tower said:
There are other ways proving to the FAA that it is the same airplane. Some manufacturers like WACO stamped the serial number into the frame.
Click to expand...
anybody can stamp a number on a steel tube.
 
Fearless Tower said:
To replicate how it was done in the 20s and 30s would be extremely difficult.
Click to expand...
not really. Nobody in the FAA is qualified to do forensics on a number stamp anyway. The point is it can be faked. Data plates can be faked as well. The FAA mentions it in an AC.
 
tintin6680 said:
Appreciate all the responses so far. We are talking about the original airframe data plate not that stupid DEA tag. I edited this in the first post but to clarify, the TC is held by an LLC but they have no physical footprint anymore and even people who had connections and were in contact with them in the past haven't been able to reach them for over a decade so they are effectively zero help. The aircraft would be getting a full restoration so AD compliance and the like aren't a concern for me. There are no time limited parts issues. From what I've heard, not having the logbooks only causes an issue in helping to positively identify the aircraft as being the one I claim it is to the FAA.
Click to expand...
Sounds like a PA-12 or -14? FS2003? With data tag and logs missing? They may have been sold to “legitimize” another airplane. Like one of the questionable imports from the TC holder.
 
martym said:
not really. Nobody in the FAA is qualified to do forensics on a number stamp anyway. The point is it can be faked. Data plates can be faked as well. The FAA mentions it in an AC.
Click to expand...
No forensics needed. If you know what you're looking for it can be very obvious when dealing with bogus parts and situations. Its been an issue for many years. Unfortunately not everyone knows what to look for or fully understands how the system works. Most people I've found who have been hit are owners who buy an aircraft and the bogus issues aren't found till its 1st annual. Plus there are many holes in the process that can allow a situation to go through several annual inspection cycles before it is found. It's one of the reasons when I look an aircraft for the time, I check the data plate, AWC, and registration first. If those three items fail to meet my expectations then I dont look at anything else until those issues are resolved. And in a number of cases I walked without further research just from what I saw on those 3 items.
 
martym said:
not really. Nobody in the FAA is qualified to do forensics on a number stamp anyway. The point is it can be faked. Data plates can be faked as well. The FAA mentions it in an AC.
Click to expand...

Knock yourself out.
 
martym said:
not really. Nobody in the FAA is qualified to do forensics on a number stamp anyway. The point is it can be faked. Data plates can be faked as well. The FAA mentions it in an AC.
Click to expand...

Swap a data plate, or fake one, and the FAA is the least of your worries. And the OIG can get the people that are forensic experts to assist them in their case.

Owner of Tennessee Aircraft Repair Station Sentenced for Attempted Aircraft Parts Fraud | DOT OIG

On September 15, 2020, the U.S. District Court for the Eastern District of Tennessee sentenced Richard Paul Harper, a citizen of the United Kingdom, to time served amounting to nearly 8 months in prison, followed by 3 years of supervised release and a $100 special assessment. In addition, he...
www.oig.dot.gov www.oig.dot.gov

On September 15, 2020, the U.S. District Court for the Eastern District of Tennessee sentenced Richard Paul Harper, a citizen of the United Kingdom, to time served amounting to nearly 8 months in prison, followed by 3 years of supervised release and a $100 special assessment. In addition, he must surrender to an immigration official for deportation. Harper is the former owner and operator of Apple International, Inc., an aircraft repair station based in Bristol, Tennessee, and the United Kingdom.

On June 16, 2020, Harper admitted in court that he obtained a helicopter with significant damage to its underbelly. Rather than make the necessary and costly repairs, a large portion of the helicopter’s fuselage was switched with the fuselage of another helicopter that had crashed in New Jersey, and the original data plates were affixed to the fuselage of the combination helicopter. The data plate switch concealed the true history of the helicopters’ damage and repairs. With intent to defraud, Harper actively marketed and tried to sell the resulting helicopter with switched data plates to an aircraft broker and other unsuspecting purchasers.

DOT-OIG led this joint investigation with the U.S. Department of Homeland Security–Homeland Security Investigations, with substantial assistance from FAA.
 
Fearless Tower said:
There are other ways proving to the FAA that it is the same airplane. Some manufacturers like WACO stamped the serial number into the frame. Other methods that work is go through the FAA 337 records for the airplane and like comparing dental records to identify remains, you can use evidence of documented repairs to validate it is the same airplane.

Logbooks are important for proving AD compliance or documenting certain life limited parts. Outside of that , lack of logbooks is just something to haggle over when selling the airplane.
Click to expand...
This aircraft has the actual serial number stamped on the frame. It also had a landing gear repair many years ago documented on (2) 337s so that could be useful as you described.
Stewartb said:
Sounds like a PA-12 or -14? FS2003? With data tag and logs missing? They may have been sold to “legitimize” another airplane. Like one of the questionable imports from the TC holder.
Click to expand...
It's a strange backstory and I know different pieces of it but as far as I can take my research I cannot find any evidence of those logs or plates being used on another ship. Engines are of course harder to track but same thing there.
 
I’ve read that Clyde Smith Jr (https://www.cubdoctor.com/) has access to old Piper production records and may be able to validate original airframe-aircraft production numbers. It’d be worth asking. You aren’t the only one whose been it this position. He may offer some advice.
 
Stewartb said:
I’ve read that Clyde Smith Jr (https://www.cubdoctor.com/) has access to old Piper production records and may be able to validate original airframe-aircraft production numbers. It’d be worth asking. You aren’t the only one whose been it this position. He may offer some advice.
Click to expand...
Unfortunately that won’t help. I’m dealing with a Taylorcraft. Meant to throw that in the last reply.
 
tintin6680 said:
My question is this: Has anyone seen a situation like this where the FAA did eventually grant authorization for a new data plate?
Click to expand...
At the end of the day, the manufacturer has to issue a new data plate so what the FAA says has little value. If the manufacturer is out of business, you're SOL. I've been through the process with an owner to have Cessna issue a new dataplate. Never again. They can make it impossible to comply.
 
martym said:
At the end of the day, the manufacturer has to issue a new data plate so what the FAA says has little value. If the manufacturer is out of business, you're SOL. I've been through the process with an owner to have Cessna issue a new dataplate. Never again. They can make it impossible to comply.
Click to expand...
I've mostly heard that the FAA needs to grant their blessing for a replacement plate, and that authorization could be taken to any number of businesses that can make a new one. I have also read the horror stories about the FAA arguing that actually legitimate, original data plates were bogus so it's anyones guess how much fun THIS is going to be!
 
tintin6680 said:
I've mostly heard that the FAA needs to grant their blessing for a replacement plate, and that authorization could be taken to any number of businesses that can make a new one. I have also read the horror stories about the FAA arguing that actually legitimate, original data plates were bogus so it's anyones guess how much fun THIS is going to be!
Click to expand...
You definitley need permission from the FAA to remove or attach a dataplate. It's in the regs. The rest of that is pretty sketchy.
The process could take months or years. Why be a slave to bureaucracies when you could buy another plane and be flying.
 
What I take away from this is that you need the FAA's approval to replace the data plate and you need to buy it from an approved source. I presume the source will be part of the approval.

Asking the FAA for permission feels like a "do I feel lucky" moment.
 
tintin6680 said:
so it's anyones guess how much fun THIS is going to be!
Click to expand...
Each attempt is very unique to the aircraft and how prepared you are when you present your request. The remainder boils down to the experience of the FAA person you talk to. On the data plate approvals we were successful with, 3 were an OEM/FAA process and 2 were just an FAA process. Only one was done at the FSDO level with the others at the MIDO/ACO levels for the approval. If your intent is simply to rebuild this T-Craft for personal enjoyment vs flip it for a profit there are other "certification" avenues to follow in order to fly and enjoy your completed project. I've known several Stearmans that couldn't get replacement data plates for a Standard AWC issuance but still received an AWC and flew on a regular basis. So while it is definitely not a walk in the park, if you perform your due diligence you have a decent shot at this. If you find yourself unsure of the process then another option is to find an experienced consultant or aviation attorney in which to guide you through the process or simply provide guidance. Good luck.
 
Bell206 said:
Each attempt is very unique to the aircraft and how prepared you are when you present your request. The remainder boils down to the experience of the FAA person you talk to. On the data plate approvals we were successful with, 3 were an OEM/FAA process and 2 were just an FAA process. Only one was done at the FSDO level with the others at the MIDO/ACO levels for the approval. If your intent is simply to rebuild this T-Craft for personal enjoyment vs flip it for a profit there are other "certification" avenues to follow in order to fly and enjoy your completed project. I've known several Stearmans that couldn't get replacement data plates for a Standard AWC issuance but still received an AWC and flew on a regular basis. So while it is definitely not a walk in the park, if you perform your due diligence you have a decent shot at this. If you find yourself unsure of the process then another option is to find an experienced consultant or aviation attorney in which to guide you through the process or simply provide guidance. Good luck.
Click to expand...
I will be keeping the T-Craft as my personal plane for quite a while. Of the data plate approvals you pursued and had success with, how many more, as a ratio, didn't work out? Your words do offer some encouragement to my situation so I will keep grinding ahead on this. Many thanks!
 

I have two airplanes, one damaged, one in good shape but not all there. Both have logs and data plates. I'm restoring the damaged one using the parts from the good one. One major part is the fuselage frame. I plan to use the logs and data plate from the restored damaged one. Then once that is completed, I'll restore the other one using the damaged fuselage, after repairs have been made.
 
As to the serial number being stamped on the frame; Taylorcraft did that as well, It's stamped on the flange that holds the engine controls (throttle etc) in the cockpit. It is stamped on the firewall side, usually to the right of the throttle somewhere. That number is the serial number of the fuselage frame, and will differ from the aircraft serial number. There is also a plate afixed to the wing spars with a number on it. I don't know if it's a serial number, or a part number, I haven't gotten that far with my research.

To TinTin6680: there's a Taylorcraft group on FB, and also the Taylorcraft Foundation website, Same folks, but the FB group is more active, and there is lots of good info on the foundation website open to the public.
 
bluerooster said:
I have two airplanes, one damaged, one in good shape but not all there. Both have logs and data plates. I'm restoring the damaged one using the parts from the good one. One major part is the fuselage frame. I plan to use the logs and data plate from the restored damaged one. Then once that is completed, I'll restore the other one using the damaged fuselage, after repairs have been made.
Click to expand...
 
Update to bring this thread to a close - I had someone much smarter than me come look at the airplane and they found the trim panel with the data plate on it buried under junk in the baggage compartment so that major issue has been resolved. I never expected this as an outcome because I was told upside and down that it didn't exist anymore but I am elated that we were able to find it.
 
tintin6680 said:
Update to bring this thread to a close - I had someone much smarter than me come look at the airplane and they found the trim panel with the data plate on it buried under junk in the baggage compartment so that major issue has been resolved. I never expected this as an outcome because I was told upside and down that it didn't exist anymore but I am elated that we were able to find it.
Click to expand...
So did you buy it?
 
You must log in or register to reply here.
Back
Top