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160 HP Paperwork problem - Help!

B

bob turner

Registered User
This Cub is a converted PA-18 105 special, and is in fact one of the nicest Cubs anywhere. The engine is in the overhaul shop, and now it turns out that the paperwork is questionable.

We have log entries and a 337 dated 1993 that explain that the pistons etc. were changed, and the designation changed from an O-320-E2D to an O-320-D2A.

Problem is, the 337 has no FAA stamp, and the data plate on the sump was not modified.

Question is, what is the most cost-effective way to correct this little oversight? Are there readily available STCs for this particular combination? We assume the D part is Dynafocal, which is the mount on this aircraft.
 
Paperwork

Bob,

The E2D and D2A Stand for the following the E & D for the power section and rating, The 2 stands for the nose section, and the D & A stand for the accessory section. I don't have a manual in front of me but I believe the E series are 150Hp and the D series are 160HP. I don't know of any STC's out there. Hope this helps some.

Si
 
I have never seen an STC for a dynafocal mount except for the O-360. Should be a 337 for the engine since none of those models are on the TCDS.
 
I also have an early Super Cub that came from the factory as a 105 in 1950 but not a 105 Special. I took an early narrow deck 0-320-no suffix, 150 hp engine and built it into a -B2B 160 hp. There are two issues potentially:

1. Approval for installing a 160 hp 0-320 engine on a Super Cub airframe.
Since the Super Cub Aircraft Specification No. 1A2 does not list a 160hp engine in the specification, installing a 160hp engine is a Major alteration to the airframe. A 337 is required to install the B2B or just about any other 160 hp engine in the Super Cub. STC SA00522SE (installation of a 160hp engine in a Super Cub) is available for purchas from Cub Crafters and the change must be reported for approval on a 337.

2. Rebuilding a 150 hp 0-320 into a 160 hp engine. This does not require an STC or a 337 ( as long as all internal & external parts exactly match the new suffix bill of material), just the stamping of the engine data plate with a "C" as spelled out in a Lycoming Service Instruction SI-1304J available on line, just Google it. Then with a log book entry explain why the "C" was added to the data plate. Below, I reference going from an A2A to a B2B but any 150 to 160 hp change would follow the same logic.

Since most people would believe that a 337 is required, here is the logic string that proves the point.

A. FAR 1.1, General Definitions, states: Major Alternation means an alternation not listed in the aircraft, aircraft engine, or propeller specification. The key point – if the alteration is listed in the engine specification then it is not considered to be a major alteration.

B. FAR 43, Appendix A - Major Alterations, Major Repairs, and Preventive Maintenance, states: (2) Powerplant Major Alterations. The following alterations of a powerplant when not listed in the engine specifications issued by the FAA are powerplant major alterations. The FAR goes on to list examples of major alteration including a compression change but the point once again is that the list of major alterations is applicable only if the change is not included in the engine specification.

C. Type Certificate Data Sheet No. E-274 is the FAA certification document for the 0-320 engine. All engine models listed in the document lie within 0-320 engine specifications. In the TC block on each engine data plate “274” appears for all 0-320 engines listed in the E-274 document. Revision 15 to E-274 dated February 19, 1998, lists 59 engine models that fall within this engine specification including 0-320-A2A and 0-320-B2B. Therefore converting an –A2A to a –B2B is a change within the engine specification and qualifies as a minor change.

I hope this helps, Darrel
 
Wow, Darrell, I will print that one out and post it on several hangar walls! Thank you.

So we are breaking new ground with the Dynafocal? I suppose we can handle that one on a one-time basis.
 
>the pistons etc. were changed, and the designation changed from an O-320-E2D to an O-320-D2A. <

An E2D can't be modified to be similar to a D2A and can't be marked as such -- they have a different front main bearing setup, with the E2D having the same front main bearings as the O-235.
JimC
 
To elaborate on the differences between the E2D and the D2A,

The O-320-E2D uses eight bearings p/n 68763 that are secured in the crankcase by locktangs and a dowel in the main bearing saddle.

The O-320-D2A by contrast uses a full length front main bearing (LW-13884) and depending on generation, either a thick shell center and rear bearing p/n LW-11021 that is secured by a tang and dowel OR, the latest generation which uses a thin-shell, high-crush bearing with locktangs and no bearing dowel in the crankcase main saddle.

JimC
 
Bob, don't panic yet. I believe there is an STC for converting an E2D to 160 hp (it remains an E2D). I don't remember who owns the STC, but will see if I can dig it up.
JimC
 
Ram Aircraft and Lycon both have an E2D 160 hp STC.

Will send Lycon info in a later post.

The info for the Ram conversion is:

-------------------------

www.ramaircraft.com

(this is for a Cessna) -- note that it requires a cylinder and carb change

Applicable engine: Lycoming O-320-E2D

The most practical time to apply these STCs is during a normal TBO overhaul. STCs were originally engineered to allow these models of O-320 engines to burn 100 octane fuel. These STCs are not offered to suggest a significant performance increase.
STC - Engine Horsepower Increase Authorization:
Allows increasing from 150 hp to 160 hp using the existing 150 hp Lycoming O-320 engine. Involves cylinder change/substitution, different carburetor, and re-pitch the propeller - all of which must be purchased separately. Requires purchase of second STC below which allows for installation of the same engine once the 160 hp changes have been implemented.
STC Fee per engine serial number: $295
 
Bob, Lycon's website says 150 to 160 STC's are available, but doesn't give any details or engine model numbers. Their phone number is 559-651-1070
 
In the "Customer Documents" for Cub Crafters STC #SA00522SE, they list the 10320-D2A as covered by the STC. Cub Crafters also sells a dynafocal mount, Pt # 101950, and an installation drawing, #101910.

This STC though does require a number of upgrades to the airframe including:
1. Flaps & balanced elevators
2. Dual groove trim system
3. Later model torque tube (13735-00) with pivot point change
4. Cleveland wheels & brakes
5. Scott tail wheel
6. Modifications to bring gross wt up to 1750 lb
7. Some boot cowl and possibly windshield changes to bring configurtion up to 150 hp config.
8. Hydrasorbs
9. Later cabane "V", pt # 30602-07
10. MA4-SPA carb with a "Straight Riser Sump"
11. Bendix S4LN20 &21 or Slick Mags
12. Oil pres line from engine to gauge pt # 71061-00 with flow restrictor
13. Prop flange bushings for use with 3/8" prop bolts
14. Original starter or B&C or Sky-Tec
15. Most props are allowed
I think this covers the big stuff but this is a 10 page document that should be studied if you plan to go this direction. Making all these changes was not a big deal for me as my plane was an incomplete project when I bought it but this may be a major issue for you. The double groove trim system , for instance, would not be a fun thing to change in a flyable Super Cub.
Regards, Darrel
 
Thanks Darrel. Been on their site 100s of times and never saw that one. Did you find any advantages or disadvantages to the dynafocal mount engine?
 
I have been impressed before with the knowledge accumulated around here, but this time I am blowed away! Thanks for all the good help!
 
I already had an engine core with a conical mount so I used it. Also, this was several years ago, I talked to Jim Richmond at Cub Crafters about this issue. He said the isolation from the Dynafocal mount was superior to the conical mount but that the improvement in vibration levels was not great. The downside of the Dynafocal mount was that it allowed the engine to move around more so it became difficult to install the cowling so that the engine or accessories would not rub on it. Of course, since then Cub Crafters has designed their own cowling so Jim's opinion may be different now.
By the way, the theory behind the Dynafocal mount is major league better than the conical mount. Not only does this design use larger mounts that can be softer but the big advantage is that the line-of-action of the mounts all meet at the engine center of gravity. This is a universally known sound design practice for isolating a piece of machinery.
Darrel
 
I had a suction and pressure filter full of metal last year in my 150hp E3D, Sent the engine to the overhaul shop, overhauled it and STC (Lycon) 150 to 160hp, already had an old FAA 337 for the engine fit along with Wag Aero STC SA388EA, 337 was for the Dynafocal mount. (this was done in 1988)
For the 160 hp install and it covered the dynafocal mount I used Svenn Aviation STC SA04121CH.
Jim
 
Darrel Starr said:
I also have an early Super Cub that came from the factory as a 105 in 1950 but not a 105 Special. I took an early narrow deck 0-320-no suffix, 150 hp engine and built it into a -B2B 160 hp. There are two issues potentially:

1. Approval for installing a 160 hp 0-320 engine on a Super Cub airframe.
Since the Super Cub Aircraft Specification No. 1A2 does not list a 160hp engine in the specification, installing a 160hp engine is a Major alteration to the airframe. A 337 is required to install the B2B or just about any other 160 hp engine in the Super Cub. STC SA00522SE (installation of a 160hp engine in a Super Cub) is available for purchas from Cub Crafters and the change must be reported for approval on a 337.

2. Rebuilding a 150 hp 0-320 into a 160 hp engine. This does not require an STC or a 337 ( as long as all internal & external parts exactly match the new suffix bill of material), just the stamping of the engine data plate with a "C" as spelled out in a Lycoming Service Instruction SI-1304J available on line, just Google it. Then with a log book entry explain why the "C" was added to the data plate. Below, I reference going from an A2A to a B2B but any 150 to 160 hp change would follow the same logic.

Since most people would believe that a 337 is required, here is the logic string that proves the point.

A. FAR 1.1, General Definitions, states: Major Alternation means an alternation not listed in the aircraft, aircraft engine, or propeller specification. The key point – if the alteration is listed in the engine specification then it is not considered to be a major alteration.

B. FAR 43, Appendix A - Major Alterations, Major Repairs, and Preventive Maintenance, states: (2) Powerplant Major Alterations. The following alterations of a powerplant when not listed in the engine specifications issued by the FAA are powerplant major alterations. The FAR goes on to list examples of major alteration including a compression change but the point once again is that the list of major alterations is applicable only if the change is not included in the engine specification.

C. Type Certificate Data Sheet No. E-274 is the FAA certification document for the 0-320 engine. All engine models listed in the document lie within 0-320 engine specifications. In the TC block on each engine data plate “274” appears for all 0-320 engines listed in the E-274 document. Revision 15 to E-274 dated February 19, 1998, lists 59 engine models that fall within this engine specification including 0-320-A2A and 0-320-B2B. Therefore converting an –A2A to a –B2B is a change within the engine specification and qualifies as a minor change.

I hope this helps, Darrel
Click to expand...

I have to respectfully disagree with this analysis. While TC 1A12 covers the O320 series, each specific model is a separate certification. Switching from one model to another would be a Major Alteration and require approved data. The Lycoming SI doesn’t authorize alterations to their engines, it simply states that if you do alter the engine, you need to enter a C at the end of the serial number indicating that it was altered. There are several STCs out there to modify various Lycoming engines, and most require a supplemental data plate to be consistent with FAA Order 8130.2.


Sent from my iPhone using Tapatalk
 
For a hypothetical example, Part A (bolt) goes in Model x, while Part B (same bolt application) goes in Model y. All other parts are the same between Models x and y.

In a similar situation, wouldn't the parts manual be approved data?
 
Gordon Misch said:
For a hypothetical example, Part A (bolt) goes in Model x, while Part B (same bolt application) goes in Model y. All other parts are the same between Models x and y.

In a similar situation, wouldn't the parts manual be approved data?
Click to expand...

Parts catalogs have never been considered approved data.

You may also want to consider reading 45.13, you can’t change data on a data plate without approved data from FAA.

You might also look at 21.93, I would think a change in HP counts as a change in operational characteristics which would fit the major change in type design category.


Sent from my iPad using Tapatalk
 
Continental is different. They published a service bulletin that clearly states that it has all been approved by the FAA.But in general, I lean in the same direction as Dave - the PA-11 is on the J-3 type certificate, but I get field approvals to use 11 struts and wings on a J-3. Makes me more comfortable.
 
dgapilot said:
I have to respectfully disagree with this analysis. While TC 1A12 covers the O320 series, each specific model is a separate certification. Switching from one model to another would be a Major Alteration and require approved data. The Lycoming SI doesn’t authorize alterations to their engines, it simply states that if you do alter the engine, you need to enter a C at the end of the serial number indicating that it was altered. There are several STCs out there to modify various Lycoming engines, and most require a supplemental data plate to be consistent with FAA Order 8130.2.


Sent from my iPhone using Tapatalk
Click to expand...

After talking with my FAA PMI, Lycoming, Ly-Con and Cub Crafters I am in agreement. My plan is to buy the STC from Ly-Con to convert my O320-A2B into 160 HP ($275). Installation of a 160 HP engine as previously mentioned is from Cub Crafters ($500)
337 required for each STC. ( I typically don't combine 337's)
 
I did the same, except I used the Crosswinds STC for installation in my -12. Charly is always helpful.
 
I’m curious on how this worked out

bob turner said:
This Cub is a converted PA-18 105 special, and is in fact one of the nicest Cubs anywhere. The engine is in the overhaul shop, and now it turns out that the paperwork is questionable.

We have log entries and a 337 dated 1993 that explain that the pistons etc. were changed, and the designation changed from an O-320-E2D to an O-320-D2A.

Problem is, the 337 has no FAA stamp, and the data plate on the sump was not modified.

Question is, what is the most cost-effective way to correct this little oversight? Are there readily available STCs for this particular combination? We assume the D part is Dynafocal, which is the mount on this aircraft.
Click to expand...

I'm having a similar situation with a pa28-140. In 1977 a O-320-E2d was installed on my Cherokee from a 172. No 337 was filed and just realized this during overhaul. Now I have an overhauled engine that’s not legal for my airplane. The prop bushings and carburetor were changed. Can anyone shed some light on this and how it can be made legal?
 
Look at the Lycoming O-320 Type Certificate Data Sheet and see what the difference in the engine model you have and the one certified on your airplane. A lot of time it is a simple to change the model number like different prop bushings, carburetor or magnetos.
 
dgapilot said:
Parts catalogs have never been considered approved data.

You may also want to consider reading 45.13, you can’t change data on a data plate without approved data from FAA.

You might also look at 21.93, I would think a change in HP counts as a change in operational characteristics which would fit the major change in type design category.


Sent from my iPad using Tapatalk
Click to expand...
There are some parts manuals that are now approved, but it’s not the normal.
 
JamesB1 said:
I'm having a similar situation with a pa28-140. In 1977 a O-320-E2d was installed on my Cherokee from a 172. No 337 was filed and just realized this during overhaul. Now I have an overhauled engine that’s not legal for my airplane. The prop bushings and carburetor were changed. Can anyone shed some light on this and how it can be made legal?
Click to expand...
337 with the wording “previously installed by unknown persons” will go a long ways towards an approval.
 
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