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Unapproved Parts Notification- Dan's Aircraft?

Steve Pierce

Steve Pierce

BENEFACTOR
Graham, TX
Have not heard anything about the FAA's Unapproved Parts Notification against Dan's Aircraft for using unapproved fabric in the covering of certified aircraft.

http://www.faa.gov/aircraft/safety/programs/sups/upn/media/2016/UPN_2016_20150609004.pdf

An owner caught up in this contacted me quite some time ago about this issue and recently I found out that even after his airplane was recovered the FAA revoked the airworthiness certificate supposedly because through the investigation they discovered that the airplane was built new around paperwork with all new parts.

If all is true I can't imagine someone using uncertified fabric, not that big a price difference and the uncertified fabric I have played with did not glue or shrink near as well as certified. I can't understand the FAA revoking airworthiness certificate either, I thought I could replace every part on a certified airplane if the part is approved. Seems there is way more to this story than meets the eye.
 
How does that actually work when they say around paperwork? Does that mean when a plane is built with all the proper registrations in hand from a prior owner, do you have to have the prior owner of the plane, when it was flying, sitting on a chair and watching the process to comply? Uncertified fabric is uncertified fabric, have no idea of the situation whatsoever but uncertified to me would mean uncertified. Has to be more to the parts part of it. If a plane was totaled and burned you would have to start somewhere?
 
Aircraft built around data plates faa should check out the Taperwing boys in MinnesotaI think rare aircraft has been doing it for years and I think if you have a few original pieces it's legal I could be wrong
 
Just reading that, (and giving Dan's the benefit of the doubt...) "Installed covering materials that are not consistent with STC#SA4503NM and airworthiness cannot be determined", could that be as simple as no pma stamp visible on the patch or maybe even Polyfiber fabric on a repair to Ceconite? To me, it sounds like he's got the wrong fed mad (again) and here comes the revenge! :nutz::nutz:
John
 
I believe the light fabric is not approved for certified aircraft. Perhaps the stamp was incorrect for the covering system. Maybe it is some FAA messup.
 
Big crankshaft contest. feds trying to prove theirs is bigger than ours. Even if they're wrong, lol.

I've heard from other operators up here that some feds are claiming that we cannot legally build up a 'totaled' aircraft. I guess we can just write it up as repaired by replacing all the damaged parts? I still cannot find anything in the FARs that would actually prohibit building a small aircraft around a data tag. If all the parts are quality built and legitimate for that aircraft and we use manufacturer's and STC holder's instructions we meet the requirements of the certification basis and the Type Certificate requirements. So that leaves safety concerns. And once again if we follow instructions we should have no issues.

Does anyone else know of an FAR that would prohibit the rebuild of a small aircraft?

Web
 
I saw that letter, but was reluctant to post. I met Dan, and was impressed with his work. It sounds like a vendetta.

Who among us, when rebuilding a Cub, will call the feds when we see something illegal that is being removed and replaced? Count me out of that.

I do not believe you can buy uncertified Dacron any more, but about two decades ago you had your choice. It was identical fabric, and the stuff without stamps was a quarter the price. It was for homebuilts, and as near as I know, homebuilts have not been falling out of the sky due to fabric failures. I believe it was used by Bellanca on their Citabria and Decathlon aircraft in the factory. It was very tempting. Then folks got a bit uptight, made the fabric suppliers put a big black stripe down the middle of cert. fabric, and Aircraft Spruce started demanding a verbal affidavit.

You cannot buy the stuff any more. Too bad for homebuilders.

Mostly opinion.
 
$0.02

Regarding "boot legging" aircraft covering..

Sailcloth, is presently heavily marketed with certain weights and weaves that are very "similar" to uncertified aircraft covering. Dacron cloth was first manufactered for marine use (at least in California)... There are about 20 types of Dacron cloths available that would be fine for covering if "certification" was no needed.

But, following the FAA guidance is pretty much un-negotiable. Just like others parts with same quality but no PMA.
 
Exactly - if you want to know who reported them (Dan's) ask the FAA... if anyone ever turned me in for anything (not that I'd ever do anything wrong) I'd want to know who did it.
 
I guess if you shave a coat or two, as Bill Ellis talks about in one cub video, you fall into this category. If you cheat on the sanding a little, you 'don't conform' to the STC.

Adding an extra coat might not be ok, and if I remember correctly, some glue processes do not 'conform' to repair stc instructions either.

That being said, there are mechanics out there that do a very poor job, to the point of endangering lives by signing off incorrect part installations. They need to go prior to folks getting killed.

Not saying that is the case here, seems if the fabric lived through the lifespan, that should be the testament there.

Seems WWI was fought with bed sheets on the wings...
 
Here at Anoka County (KANE) in Minnesota several of the SCs are all new planes built around purchased paperwork & usually with a rebuild cost of $200K +; one guy paid $5000 for the data plate, airworthiness certificate and clean bill of sale. All parts in the build were PMAd or part of an STC. Nothing illegal about that. There must be more to the story in the Dan's rebuild case.
 
The uncertified fabric Aircraft Spruce now sells is not the same as the old uncertified Dacron Griege they used to sell.

They are smart businessfolk. There was a guy selling brake pads for experimentals - they were something like a buck each. Not suited for certified aircraft, but they would stop a homebuilt Super Cub just fine. Aircraft Spruce bought him out, and no longer sells those parts.

Murtherfore - if some other shop turned Dan in, I would like to know who it was so I could avoid ever having maintenance done there.

Some certified FAA shop glued my carb drain plug in, because they stripped the threads. When I discovered that, I became extremely picky about who looks at my aircraft. So, no chance I will ever use the offending shop, whether or not he is published.
 
bob turner said:
...I do not believe you can buy uncertified Dacron any more, but about two decades ago you had your choice. It was identical fabric, and the stuff without stamps was a quarter the price. It was for homebuilts, and as near as I know, homebuilts have not been falling out of the sky due to fabric failures. I believe it was used by Bellanca on their Citabria and Decathlon aircraft in the factory. ...
Click to expand...
Bob,
This would be a legitimate use for "uncertified" fabric. Since Bellanca is the holder of the Type Certificate and holds a PMA for all of the component parts they can use the fabric. Bellanca's approval and inspection process certifies it as "airworthy". You can use the same fabric for repairs on your Bellanca airplane if you buy it from Bellanca since it is then an "approved part".
 
bob turner said:
Some certified FAA shop glued my carb drain plug in, because they stripped the threads. When I discovered that, I became extremely picky about who looks at my aircraft. So, no chance I will ever use the offending shop, whether or not he is published.
Click to expand...

And what happens to the next guy that has a problem like this but is not experienced, so does not catch it? He goes out and flies his grandkids and out comes the plug, plane goes down and hurts the grand children.

Sorry, but there is a reason that shoddy shops need to be made public.

In Dan's case, his work has always been well respected. The Alaska Airman's Ass. had some of their raffle cubs done by him. It is very possible that an inspector was in a shop when the crew was stripping a plane, and then saw the fabric did not have the stamp. Just because a guy works for the Feds does not mean he is clueless.

There seems to be much middle ground between all of the scenarios suggested here.

For me, seeing Dan's signature in a log book will give me confidence, not fear. There are a few others that is not so.
 
wireweinie said:
....I've heard from other operators up here that some feds are claiming that we cannot legally build up a 'totaled' aircraft. I guess we can just write it up as repaired by replacing all the damaged parts? I still cannot find anything in the FARs that would actually prohibit building a small aircraft around a data tag. If all the parts are quality built and legitimate for that aircraft and we use manufacturer's and STC holder's instructions we meet the requirements of the certification basis and the Type Certificate requirements. .......
Click to expand...

Back in 2001, I blew a connecting rod in my old C-170, the engine was overhauled and "crankcase replaced with used crankcase s/n xxxx". Still considered the same engine, even with a different crankcase-- they didn't even start a new engine logbook. This was done by a Certified Repair Station.

That same C170 had been severely ground-looped back around 1960. The description of the repair work on the 337 included "replaced damaged fuselage with used airworthy fuselage". The original data plate stayed with the airplane, in spite of it being riveted on a different fuselage.

If you can replace what I would consider the heart of the engine (crankcase) and the airframe (fuselage), I think you can replace anything. You just have to do it with proper documentation.
 
sooooooo.... on a metal airplane, is that raw sheet of aluminum you make the new skin from FAA-PMA???? hmmmmm

gotta be more to this story.....

anyone got the backstory of what got this ball rolling?
 
AC43-17 discusses data plates, transferring them to parts on which they were not origionally installed, and the FARs involved. But it is my understanding that you can build an airplane around a dataplate using new or used parts IF you ask/notify the FAA first and keep everything you do legal, documented, and above board. Otherwise to the Feds you are just a thief dealing in stolen airplanes and stolen parts and passing them off as legit for top dollar. jrh
 
N86250 said:
AC43-17 discusses data plates, transferring them to parts on which they were not origionally installed, and the FARs involved. But it is my understanding that you can build an airplane around a dataplate using new or used parts IF you ask/notify the FAA first and keep everything you do legal, documented, and above board. Otherwise to the Feds you are just a thief dealing in stolen airplanes and stolen parts and passing them off as legit for top dollar. jrh
Click to expand...

What FAR tells me I have to 'tell the feds'?

Web
 
This is section 5 from AC43-17:

5 GUIDELINES. Persons authorized to perform maintenance under theprovisions of FAR Part 43 are exempt from the requirement of having toobtain individual approval from the Administrator when it is necessary,during certain maintenance operations, to remove or change identificationinformation or to remove an ID plate. Removal of an ID plate would beconsidered necessary during certain maintenance operations such as causticcleaning, paint removal, or sandblasting. Remotil of an ID plate wouldalso be considered necessary when the structure to which the ID plate isfastened has to be repaired or replaced for maintenance purposes. The. changing of identification information would be considered necessary wheninstructed to do so in compliance with specific maintenance procedurescontained in manufacturers' manuals, letters, or bulletins. that areincorporated in and made a part of an airworthiness directive. An ID plateremoved during maintenance operations must be reinstalled in the originallocation from which it was removed prior to releasing the product toservice.

This, specifically allows me to remove/reinstall data plates for maintenance. If I install a new or different fuselage, as an example, I would transfer that data plate to the new one. I would also be responsible for insuring all maintenance and AD's are brought up to date as needed.

Web
 
mike mcs repair said:
sooooooo.... on a metal airplane, is that raw sheet of aluminum you make the new skin from FAA-PMA???? hmmmmm

gotta be more to this story.....

anyone got the backstory of what got this ball rolling?
Click to expand...

You're not riveting beer cans together to replace the fuse. You're using the same as what the factory used. If you're covering something and the stc says to use certified fabric, you don't go use bed sheets...
 
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