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Hypothetical

S2D

S2D

MEMBER
Montana
Suppose you just found your perfect Supercub. 1959 model with low time since completely gone thru airframe and engine. The owner is an old time IA and just can't fly anymore so he has to get rid of his pride and joy and its really reasonable. You send him a deposit, order the CD from faa and drag your IA along to get it. One look at the paperwork and our IA says no way, this is originally a 90 hp Supercub and there is no paperwork for the modifications other than a weight and balance and flight manual for the 150 model. Its not legal


Is he right?
 
Must be cold and Crappy weather in Montana today. Get Tunge's book and look at cool pictures and read about South Dakota. ;)

I agree with the above statement and add that you will need the flight manual.
 
Steve Pierce said:
Must be cold and Crappy weather in Montana today.
Click to expand...

Actually its beautiful out. but just enough spotty snow to go with the tall grass to make it not worth going out. Trying to keep from wasting gas !!

Just trying to see if I'm missing anything. I'm sure someone can some up with something.
Would no log book entries change anything ??
 
skywagon8a said:
If the price is right and you have an IA in your back pocket, NO.
Click to expand...
:lol:

Only talking legal as is. I'm an IA so I have one in my pants.:p

Plus if Steve and PA are correct, I'd only need an A&P at the most.
 
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I got in a pissing match with a FSDO inspector over a similar matter. CAR 8 aircraft left the factory with a 1340, later a 985 was hung with only a logbook entry. He blew a gasket, I said the engine was on the TCDS so I understood it as only needing a logbook entry. He seemed satisfied with that answer, haven’t heard anything else about it since then.
 
The real question is what “model” does the data plate have? If it only has PA-18, then that is the model you have and is limited to the eligible engine. That said, looking at the TCDS, changing to a 105 Special, 125, or 135 would be pretty easy. Changing to a 150 would require a little more work since it’s listed separately. I had the same issue a few years back converting a PA-22-150 to a PA-22-160.

In any case, it really doesn’t sound like fixing the paper is a big deal, some $$$ and some time to push paper. It all depends on what it’s worth to you.


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Being pragmatic- if you need the IA signature, in the end his opinion is all that matters.

Now, if you can convince him he is wrong and will sign off the annual, great. If not is it worth having to find a new mechanic?

Yes, I have had to find a different mechanic because they did not do a good job; ones that do a good job need to be listened to!
 
dgapilot said:
The real question is what “model” does the data plate have? If it only has PA-18, then that is the model you have and is limited to the eligible engine.
Click to expand...

Don't have time tonight to go completely thru my take on it and what I would use to support my decision, but I will respectfully disagree with this statement.
Some of the early PA-18-150s came out with PA-18-135 Data plates from the factory and have been legal to fly all this time.

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Just to expound on the data plate a little. Years ago i was looking at an early PA-18-150. It had a PA-18-135 data plate on it. Also had the correct serial number and all the original records. Can't remember the exact wording, but the first entry in the logbook went something like removed 135 and installed 150 hp engine. It would really be interesting to know what happened , but it probably went something like this.
When Piper finally got the approval for the 150, they still had X number of 135s still in inventory. Rather than sell them as 135s, they included the on the ac specs s/n eligible list and just swapped engines and included new paperwork. They never changed the data plate tho.

When I looked at the plane, my first thought was, man I'd hate to lose the original logbook. Someday nobody would believe it.

Don't know how many they did this way, but this wasn't even close to the first s/n on the list.

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S2D said:
Suppose you just found your perfect Supercub. 1959 model with low time since completely gone thru airframe and engine. The owner is an old time IA and just can't fly anymore so he has to get rid of his pride and joy and its really reasonable. You send him a deposit, order the CD from faa and drag your IA along to get it. One look at the paperwork and our IA says no way, this is originally a 90 hp Supercub and there is no paperwork for the modifications other than a weight and balance and flight manual for the 150 model. Its not legal Is he right?
Click to expand...

I'm not an IA, but I met one once--
I'd say it needs at least a logbook entry documenting the engine installation (and any other changes).

FWIW I just read the PA-18 TCDS
http://rgl.faa.gov/Regulatory_and_Guidance_Library/rgMakeModel.nsf/0/ab203ab0e89895af862572090071f7cd/$FILE/1A2.pdf
It indicates the (original) PA-18 was equipped with the C90-8 & C90-12 engines.
It also seems to indicate that TCDS items 101, 106, & 108 (Lyc O235C & C1, 290D, & 290D2) are approved as "alternate engines"--
no mention there of the 320.
Maybe the airplane has to be converted to a later model to that.
 
hotrod180 said:
I'm not an IA, but I met one once--
I'd say it needs at least a logbook entry documenting the engine installation (and any other changes).

FWIW I just read the PA-18 TCDS
http://rgl.faa.gov/Regulatory_and_Guidance_Library/rgMakeModel.nsf/0/ab203ab0e89895af862572090071f7cd/$FILE/1A2.pdf
It indicates the (original) PA-18 was equipped with the C90-8 & C90-12 engines.
It also seems to indicate that TCDS items 101, 106, & 108 (Lyc O235C & C1, 290D, & 290D2) are approved as "alternate engines"--
no mention there of the 320.
Maybe the airplane has to be converted to a later model to that.
Click to expand...

That was kind of how I read the TCDS as well. That said, we all have our acceptable level of”risk” when it comes to putting signatures in log books. I prefer to simply read what something says and act accordingly rather than interpret what I think or want it to say. Finding approved data to justify a major alteration isn’t that hard. All it takes is $$$$$.


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Also not an IA, just looking at this from my layman’s mind:

The PA-18-150 is on the same TCDS, 1A2, as the PA-18-105, 125, 135 etc. On page 4 of the TCDS it states: Models PA-18 "150" and PA-18A "150" same as corresponding models PA-18 "135" and PA-18A "135" except for the engine, wings, and revisions to the fuselage, fuel system and landing gear.

Seems like you should be able to hang the 320 on a 105 airframe, and write in the logs it was installed and the airframe modified in accordance with factory drawings.
 
CenterHillAg said:
Also not an IA, just looking at this from my layman’s mind:

The PA-18-150 is on the same TCDS, 1A2, as the PA-18-105, 125, 135 etc. On page 4 of the TCDS it states: Models PA-18 "150" and PA-18A "150" same as corresponding models PA-18 "135" and PA-18A "135" except for the engine, wings, and revisions to the fuselage, fuel system and landing gear.

Seems like you should be able to hang the 320 on a 105 airframe, and write in the logs it was installed and the airframe modified in accordance with factory drawings.
Click to expand...

If only it was that easy!


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If I had such a plane show up in my shop for inspection, this is what I would do.

First I would look under TC 1A2.
and would find this:

Serial Numbers Eligible 18-3771; 18-3781 through 18-9015; 18-7309016 through 18-8309025; and 1809001 through

1809113.

since its a 59 model, it would fall in this number sequence.

Then I would go here:

(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:

So no 337 is needed as they are listed in the TCDS

Then I would go here:


Sec. 91.417

Maintenance records.

(a) Except for work performed in accordance with Secs. 91.411 and 91.413, each registered owner or operator shall keep the following records for the periods specified in paragraph (b) of this section:
(1) Records of the maintenance, preventive maintenance, and alteration and records of the 100-hour, annual, progressive, and other required or approved inspections, as appropriate, for each aircraft (including the airframe) and each engine, propeller, rotor, and appliance of an aircraft. The records must include--


(b) The owner or operator shall retain the following records for the periods prescribed:
(1) The records specified in paragraph (a)(1) of this section shall be retained until the work is repeated or superseded by other work or for 1 year after the work is performed.

since the modifications were done according to the TC they would be considered minor alterations and the records only need to be kept for a year.
We all know what happens when a Supercub goes to Canada. Those knuckleheads throw the US logbooks away. Or they could have got lost or burned up , or stolen, but they aren't required.

So as far as I'm concerned, up to this point everything is OK.
Now we get into a couple gray areas.

1. The Data Plate.
Does it have to say PA-18-150 ? I cited earlier a case where they weren't changed and this was done by Piper, so we have precedence. Also, If you have a AR-7 certified cub and have a standard AW cert, you are operating under a completely different TCDS than the AC was certified under and still have the AR-7 data plate. So why would this one be illegal. Also, suppose it had a -150 stamped on it by persons unknown, does this make it an illegal alteration of the Data Plate? Why?

2. The Airworthiness Certificate. Does it have to say -150? if so why ?

I would document all the above info and use it to justify sending the airplane on its merry way as long as everything was airworthy.

 
skywagon8a said:
TC 1A2 is specific as to serial numbers which are applicable.
Click to expand...

( maybe your response was to others) Don't think other models would be as simple because of that !!

As I stated:

First I would look under TC 1A2.
and would find this:

Serial Numbers Eligible 18-3771; 18-3781 through 18-9015; 18-7309016 through 18-8309025; and 1809001 through

1809113.

since its a 59 model, it would fall in this number sequence.

 
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I recovered that airplane about 5 years ago and it’s back where we first seen it Brian. Pretty sure we were the last ones to fly it back then until it was all redone.
 
ag-pilot said:
I recovered that airplane about 5 years ago and it’s back where we first seen it Brian. Pretty sure we were the last ones to fly it back then until it was all redone.
Click to expand...

I've kept tabs on it and saw they still owned it.
Did you take picture of the dataplate and logbook ??
 
S2D said:
( maybe your response was to others) Don't think other models would be as simple because of that !!

As I stated:

First I would look under TC 1A2.
and would find this:

Serial Numbers Eligible 18-3771; 18-3781 through 18-9015; 18-7309016 through 18-8309025; and 1809001 through

1809113.

since its a 59 model, it would fall in this number sequence.
Click to expand...
Since I don't know the serial number, unless it is within this number sequence 18-3781 through 18-9015 it would seem that it was not eligible to have the 90 hp engine in the first place. If that is where it is then it would be a log book entry only.
 
CenterHillAg said:
….except for the engine, wings, and revisions to the fuselage, fuel system and landing gear. Seems like you should be able to hang the 320 on a 105 airframe, and write in the logs it was installed and the airframe modified in accordance with factory drawings.
Click to expand...

Different wings, plus (possibly extensive) fuselage, fuel system, and landing gear revisions. Nothing to it!! :roll:
Seems like at least some of all that should have had logbook entries made.
So sounds to me like the OP's hypothetical airplane might possibly be un-airworthy as is.
But like I said, I'm no IA.
 
hotrod180 said:
Different wings, plus (possibly extensive) fuselage, fuel system, and landing gear revisions. Nothing to it!! :roll:
Seems like at least some of all that should have had logbook entries made.
So sounds to me like the OP's hypothetical airplane might possibly be un-airworthy as is.
But like I said, I'm no IA.
Click to expand...

(1) The records specified in paragraph (a)(1) of this section shall be retained until the work is repeated or superseded by other work or for 1 year after the work is performed.
 
This discussion reminds me of an issue in which I have discussed with several FSDO Inspectors over the years. That issue is a "model change". If one could change the model of the hypothetical aircraft to PA-18-150 no further discussion would be necessary. Does anyone have any knowledge of any Piper aircraft with an FAA approved model change? I believe the FAA's current position is no model changes unless specifically allowed by the manufacturer or other approved data specifically addressing the model change.

Also, S2D, you stated you saw a PA-18-150 with a PA-18-135 data tag (I would suggest you saw a PA-18-135 with a 150 engine as I would suspect the Airworthiness Certificate for that aircraft indicates model as PA-18-135 thus, officially (in the eyes of the FAA) it's a PA-18-135.) with a log book entry of the engine change. I assume that entry was made by Piper, is that correct?

A question for those who know pertaining to the TCDS's eligible serial numbers. As the serial numbers listed for the PA-18-135 appear to overlap those of the PA-18-150, and it's my understanding (which could be wrong) Piper used PA-18-150 parts on these later PA-18-135, wouldn't the TCDS be wrong (for the later 135's) when listing the differences between the 135 and the 150?
 
bubb2 said:
Does anyone have any knowledge of any Piper aircraft with an FAA approved model change?
Click to expand...

Yes, I know of a PA-11 that was changed to a PA-18-135. Legally. Has lots of engineering data etc. Listed as PA-18-135 but has s/n 11-XXX.
I do agree with you. FAA isn't approving shpit . But that doesn't mean ones that were done previously aren't legal.



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I have posted the except of AC 45.2E that I have used to try to convince FSDO Airworthiness Inspectors the PA-18-135 in front of you is identical to a PA-18-150, and it can be easily proven, with 100% certainty, using FAA approved and accepted data, primarily TC1A2 and the PA-18 Parts Manual, without success.

Changing Identification Plate Information
You may change the identification data required by § 45.13(a) only when such change comply with specific FAA-approved or -accepted data (for example, design data,maintenance procedures, and rebuilding or alteration procedures contained in manufacturers’ manuals, letters, bulletins).

Note: When an aircraft has been modified to conform to another model of the same make, a new identification plate is required to be attached as close as physically possible to the original identification plate. The original identification plate is not to be removed or altered in any manner.
 
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bubb2 said:
This discussion reminds me of an issue in which I have discussed with several FSDO Inspectors over the years. That issue is a "model change". If one could change the model of the hypothetical aircraft to PA-18-150 no further discussion would be necessary. Does anyone have any knowledge of any Piper aircraft with an FAA approved model change? I believe the FAA's current position is no model changes unless specifically allowed by the manufacturer or other approved data specifically addressing the model change.

Also, S2D, you stated you saw a PA-18-150 with a PA-18-135 data tag (I would suggest you saw a PA-18-135 with a 150 engine as I would suspect the Airworthiness Certificate for that aircraft indicates model as PA-18-135 thus, officially (in the eyes of the FAA) it's a PA-18-135.) with a log book entry of the engine change. I assume that entry was made by Piper, is that correct?

A question for those who know pertaining to the TCDS's eligible serial numbers. As the serial numbers listed for the PA-18-135 appear to overlap those of the PA-18-150, and it's my understanding (which could be wrong) Piper used PA-18-150 parts on these later PA-18-135, wouldn't the TCDS be wrong (for the later 135's) when listing the differences between the 135 and the 150?
Click to expand...

Bob, I just did a model change from a J3F-65 to a J3C-65. That one also involves a change in TC. All it requires is change firewall forward, instrument markings, and supplemental data plate indicating the change. It also requires an application for a new (by new , any 8100- 2) airworthiness certificate since the new airworthiness certificates have the model listed.


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dgapilot said:
Bob, I just did a model change from a J3F-65 to a J3C-65.
Click to expand...

Nice to know they are allowing that again
Went round and round with some on the J-3 forum about whether that was legal or not since some in the FAA were telling them it wasn't !!



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No I didn’t have the log books just parts in need of fabric. I did have the data plate that I transferred to the new floorboard. Your right the very first entry in the aircraft log was “removed 0290 and installed 0320” then the flight test. It had to be one of if not the first 150hp cub and it had and still has 13 rib wings.
 
ag-pilot said:
No I didn’t have the log books just parts in need of fabric. I did have the data plate that I transferred to the new floorboard. Your right the very first entry in the aircraft log was “removed 0290 and installed 0320” then the flight test. It had to be one of if not the first 150hp cub and it had and still has 13 rib wings.
Click to expand...
Do you happen to know if the Vne and max gross weight were increased to 153 mph and 1750 lbs on that airplane? I'm wondering if the 13 rib wings restricted it to the lower speed and weight of 138 mph and 1500 lbs.
 
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