sounds expensive - j3

No - shoulder harnesses installed in J3s need only be signed by an A&P. No STC or field approval required.

You bring up an interesting point - does a conformity inspection automatically approve alterations not previously approved?

I am going to guess “no” - I think you still need approved data for each alteration, which, I believe, is limited to type certificate, STC, or field approval. But I am also going to plead ignorance - I am just guessing.

I got six different field approvals in 2019. Not impossible.

There are so many Cubs out there with major alterations and 337s without approved data that I will guess you will be fine until you hit a knowledgeable IA. The airplanes I am finding with such defects have gone decades with no IA noticing - and at least one got several annuals done by a guy I highly respect. Most go through annuals with five or six different shops.

Did I tell you about the Mooney, annualled over a 20 year period by a Mooney-approved repair station, with major control and fuel tank ADs never addressed?

bob turner said:

You bring up an interesting point - does a conformity inspection automatically approve alterations not previously approved?

I am going to guess “no” - I think you still need approved data for each alteration, which, I believe, is limited to type certificate, STC, or field approval. But I am also going to plead ignorance - I am just guessing.

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When you import an aircraft from a foreign country or you lose your airworthiness certificate the aircraft gets a conformity inspection and is issued an airworthiness certificate. Anything installed at that time is waved with a magic wand and approved because the FAA says it conforms and they issue the certificate.

An old time retired FAA inspector who during the 60’s and 70’s in Alaska issued many field approvals that would in today’s world be impossible to obtain, once told me when I was asking his advice:
CHOOSE YOUR IA and YOUR DAR WISELY AND CAREFULLY.
Not only do FAA inspectors in different regions and different offices disagree, different inspectors in the same office often disagree. When we wave a flag I front of any of their faces we stir the pot and are likely to get stung.

We we would all be wise to measure what we advertise and what we say on this site, and elsewhere. Not only do you need to have confidence in your IA, he needs to have confidence in you.

Told you I was guessing. I have no experience with conformity inspections.

So there is a document that goes with the conformity inspection that explicitly approves all previous major alterations? Or is there some other way for the next IA to be comfortable with, say, J3 flaps? Like a regulation or technical order that says what Steve says about the magic wand?

I personally would try to get a stamp in block 3 for all major alterations not backed up with approved data. Again, I could be convinced otherwise by an FAA opinion letter or something similar.

Bob, Read what is printed in block 5.

bob turner said:

Told you I was guessing. I have no experience with conformity inspections.

So there is a document that goes with the conformity inspection that explicitly approves all previous major alterations? Or is there some other way for the next IA to be comfortable with, say, J3 flaps? Like a regulation or technical order that says what Steve says about the magic wand?

I personally would try to get a stamp in block 3 for all major alterations not backed up with approved data. Again, I could be convinced otherwise by an FAA opinion letter or something similar.

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When any DAR issues a “new” airworthiness certificate, the aircraft has to meet the definition of “Airworthy” (see 14cfr3.5). The aircraft has to meet the Type Design, and any alterations need to have been performed properly and with the appropriate data. For a “ new” certificate, the owner signs an application stating the airplane is “airworthy”, and for a Standard Certificate, a mechanic or repair station also signs the application stating it is airworthy.

The DAR takes those statements and looks at them as “accept but verify” if there are major alterations, they need to have been performed using FAA Approved data. The application will list ALL STCs installed. As a DAR, when I conform an aircraft, I’ll have the TCDS, and all those STCs (to include all the installation data called out on the STC ( and it is the applicant that provides them)).

If major alterations were performed while under foreign registry, they still need FAA approved data, so if a foreign STC was installed and there is no FAA STC, that installation either gets removed or the applicant gets an FAA STC for it. For items that don’t have STCs, but are still major alterations, the applicant will likely be finding a DER to approve them unless the Bilateral agreement allows us to accept that foreign CAAs method.

All in all, when a “new” certificate is issued, yes it is like a manic wand and all installations at that point in time are approved. There may not be 337s for all the STCs, but they will be listed on the application. The DAR uses FAA Form 8100-1 to document the inspection, but that form normally doesn’t go in the aircraft file.

Note, in the discussion above I referenced a “new” certificate. This would be a certificate that results from the applicant submitting an application. The date field on that certificate will have the date the certificate was issued. Contrast that to a “replacement” certificate. A “replacement” certificate has no application, only a letter requesting the replacement. The only requirement for issuing a replacement is that the aircraft only have a “current” inspection. The DAR is only required to verify the current inspection status and do a cursory inspection of the aircraft. For a replacement certificate, the date shown will be the date the original certificate was issued, preceded by an “R” indicating that it is a replacement. A replacement certificate is not the magic wand approving any prior installations noted above.

Hope this helps.


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bob turner said:

A metal spar wing covered through white is right at $15k from Dakota, outright. We opted to rebuild, because lead time was four months. Good thing - fooling with fuel tank area and landing light cost an additional ten hours.

By the by, since I don’t spray iso cyanates we opted for a shop to do the painting. First part was gear legs, shock struts, and cabana vee - all in white and scuff-sanded. Took me five hours to cover and spray through white. We gave the shop a quart of yellow, a quart of catalyst, and foolishly did not get an estimate! 16 hours labor! When quizzed they said they charge for drying time - at $105/hr. To my credit, not my first choice of paint shops. Closer, though. My shop of choice is half a day away at J3 speed.

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I guess they feel if it is taking up space in their booth they should be comensated. Curious how that works out for them.

Charlie Longley said:

Which episode?

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I don't remember, I have only seen parts of a few episodes.

Had an old timer DAR tell us the way to get all our proposed mods approved was to lose all the paperwork and get a new airworthiness certificate. We didn't do it that way. Also worked on a PA12 that had all kinds of mods that appeared to be per STC but no STC paperwork. Was done in Canada and had been imported an issued a new airworthiness certificate. The conclusion between myself and the IA doing the rebuild was that the mods had been blessed whenthe issued the new certificate. Luckily all I did were fuselage tubing repairs.

Still, an interesting topic. I probably will never encounter this exact situation, but if I did, it would be with dga’s approach. Certifying that an aircraft meets type certificate data and approved alterations presupposes that alterations have been approved prior to certification. Still just an opinion, now only backed by one VDER.

And yeah - while I did all the work, I have only the power to recommend a finish paint shop. I will not be recommending the shop that charges $110/hr for drying time.

bob turner said:

Still, an interesting topic. I probably will never encounter this exact situation, but if I did, it would be with dga’s approach. Certifying that an aircraft meets type certificate data and approved alterations presupposes that alterations have been approved prior to certification. Still just an opinion, now only backed by one VDER.

And yeah - while I did all the work, I have only the power to recommend a finish paint shop. I will not be recommending the shop that charges $110/hr for drying time.

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Bob, i’m also a DARt and DARf along with vDER. I issue lots a airworthiness certificates for both imports and airplanes “coming home” as well as exports. I also do conformity’s for STC projects, certify homebuilts and lots of other stuff, everything from light sport to 800,000 lbs.

David


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David- I barely know what a vDER does. But I am delighted to have my wild guess (based on nothing, really) corroborated by a professional with that many credentials.

Still, there appears to be little risk in flying around with major alteration data approved by IAs, or for that matter, with magic wand Airworthiness Certificates. These aircraft keep getting annuals done by competent folks, and insurance companies do not get in to that level of detail. Our discussion is academic.