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Thread: Unapproved Parts Notification- Dan's Aircraft?

  1. #1
    Steve Pierce's Avatar
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    Unapproved Parts Notification- Dan's Aircraft?

    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/p...0150609004.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.
    Steve Pierce

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    180Marty's Avatar
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    Where do you get unapproved fabric----China?????

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    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?

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    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
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    Hardtailjohn's Avatar
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    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!
    John

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    Maybe this is similar to when the feds were chasing Hoover

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    Maybe using a heat gun to shrink fabric instead of an iron?
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    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.

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    Steve Pierce's Avatar
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    All I know from the shop that recovered it that there were no stamps.
    Steve Pierce

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    Will Rogers

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    wireweinie's Avatar
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    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?

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    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.

  12. #12
    8GCBC's Avatar
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    $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.

  13. #13
    DarrenLucke's Avatar
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    Quote Originally Posted by bob turner View Post

    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.
    4 words...... " Freedom of Information Act "

  14. #14
    Steve Pierce's Avatar
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    Look at Aircraft Spruce Bob. They sell uncertified fabric. It acts different to me.
    Steve Pierce

    Everybody is ignorant, only on different subjects.
    Will Rogers

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    Quote Originally Posted by DarrenLucke View Post
    4 words...... " Freedom of Information Act "
    I'm not sure what you're getting at, the FoIA is for obtaining information FROM a governmental agency not the other way around.
    Remember, These are the Good old Days!

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    DarrenLucke's Avatar
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    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.

  17. #17
    RaisedByWolves's Avatar
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    Unapproved Parts Notification- Dan's Aircraft?

    http://m.aircraftspruce.com/catalog/...clickkey=66562
    11.94/yd
    8.40/yd for un certified.

  18. #18
    aktango58's Avatar
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    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...
    I don't know where you've been me lad, but I see you won first Prize!

  19. #19
    aktango58's Avatar
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    Quote Originally Posted by 180Marty View Post
    Where do you get unapproved fabric----China?????
    Jenks OK
    I don't know where you've been me lad, but I see you won first Prize!

  20. #20
    wireweinie's Avatar
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    Quote Originally Posted by aktango58 View Post

    Seems WWI was fought with bed sheets on the wings...
    But were those 'approved' bed sheets?

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  21. #21
    Darrel Starr's Avatar
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    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.

  22. #22

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    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.

  23. #23
    8GCBC's Avatar
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    Quote Originally Posted by OLDCROWE View Post
    I'm not sure what you're getting at, the FoIA is for obtaining information FROM a governmental agency not the other way around.
    ...And...

    This is the reduction act of information the government can request:
    https://en.m.wikipedia.org/wiki/Paperwork_Reduction_Act

  24. #24
    skywagon8a's Avatar
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    Quote Originally Posted by bob turner View Post
    ...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. ...
    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".
    N1PA

  25. #25
    aktango58's Avatar
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    Quote Originally Posted by bob turner View Post

    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.
    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.
    I don't know where you've been me lad, but I see you won first Prize!

  26. #26
    hotrod180's Avatar
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    Quote Originally Posted by wireweinie View Post
    ....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. .......
    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.
    Cessna Skywagon-- accept no substitute!

  27. #27
    www.SkupTech.com mike mcs repair's Avatar
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    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?

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    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
    You can't get there from here. You have to go over yonder and start from there.

  29. #29
    wireweinie's Avatar
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    Quote Originally Posted by N86250 View Post
    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
    What FAR tells me I have to 'tell the feds'?

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  30. #30
    wireweinie's Avatar
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    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.

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  31. #31
    RaisedByWolves's Avatar
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    Quote Originally Posted by mike mcs repair View Post
    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?
    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...

  32. #32
    wireweinie's Avatar
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    The feds used a statement that they were using 'covering materials', that were 'inconsistent' with the STC. If they had been caught with rolls of un approved fabric, they would have just said 'unapproved parts'. The vague wording of their statement sounds like it could have been patches or reinforcing tapes that did not have visible stamps to prove the 'approval'.

    I've seen the work that comes out of this shop and my money is on Dan. Sounds more like a pissed off fed than unsafe airplanes.

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  33. #33
    aktango58's Avatar
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    Quote Originally Posted by wireweinie View Post
    The feds used a statement that they were using 'covering materials', that were 'inconsistent' with the STC. If they had been caught with rolls of un approved fabric, they would have just said 'unapproved parts'. The vague wording of their statement sounds like it could have been patches or reinforcing tapes that did not have visible stamps to prove the 'approval'.

    I've seen the work that comes out of this shop and my money is on Dan. Sounds more like a pissed off fed than unsafe airplanes.

    Web
    I get the same impression.
    I don't know where you've been me lad, but I see you won first Prize!

  34. #34
    algonquin's Avatar
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    I agree that Dan runs a first rate operation, also a guy that is very involved with the aviation community in Alaska. I don't believe Dan would ever do anything unsafe or illegal , I second the grudge as hard as that is to believe.

  35. #35

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    Interesting analogy - sheet aluminum and fabric. If we follow that logic, we can maybe use uncertified fabric on ACA products? Recovering them in Dacron with dope and an automotive top coat is part of the type certificate, and not a major alteration.

    Or does having the aluminum labeled 5606 or 6061 give it the imprimatur of the FAA?

    I never considered that before.

    One thing that does sort of bother me is the idea that an STC lives forever. It is like an infinite patent. It should become available after a couple decades, for the same reason that patents enter the market after 17 years. Never happen, right?

  36. #36

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    Quote Originally Posted by wireweinie View Post
    What FAR tells me I have to 'tell the feds'?

    Web
    Sec 45.13
    Identification data.
    (a) The identification required by § 45.11 (a) through (c) must include the following information:
    (1) Builder's name.
    (2) Model designation.
    (3) Builder's serial number.
    (4) Type certificate number, if any.
    (5) Production certificate number, if any.
    (6) For aircraft engines, the established rating.
    (7) On or after January 1, 1984, for aircraft engines specified in part 34 of this chapter, the date of manufacture as defined in § 34.1 of this chapter, and a designation, approved by the FAA, that indicates compliance with the applicable exhaust emission provisions of part 34 of this chapter and 40 CFR part 87. Approved designations include COMPLY, EXEMPT, and NON-US, as appropriate. After December 31, 2012, approved designations also include EXEMPT NEW, and EXCEPTED SPARE, as appropriate.
    (i) The designation COMPLY indicates that the engine is in compliance with all of the applicable exhaust emissions provisions of part 34. For any engine with a rated thrust in excess of 26.7 kilonewtons (6000 pounds) which is not used or intended for use in commercial operations and which is in compliance with the applicable provisions of part 34, but does not comply with the hydrocarbon emissions standard of § 34.21(d), the statement "May not be used as a commercial aircraft engine" must be noted in the permanent powerplant record that accompanies the engine at the time of manufacture of the engine.
    (ii) The designation EXEMPT indicates that the engine has been granted an exemption pursuant to the applicable provision of § 34.7 (a)(1), (a)(4), (b), (c), or (d), and an indication of the type of exemption and the reason for the grant must be noted in the permanent powerplant record that accompanies the engine from the time of manufacture of the engine.
    (iii) The designation NON-US indicates that the engine has been granted an exemption pursuant to § 34.7(a)(1), and the notation "This aircraft may not be operated within the United States", or an equivalent notation approved by the FAA, must be inserted in the aircraft logbook, or alternate equivalent document, at the time of installation of the engine.
    (iv) The designation EXEMPT NEW indicates that the engine has been granted an exemption pursuant to the applicable provision of § 34.7(h) of this chapter; the designation must be noted in the permanent powerplant record that accompanies the engine from the time of its manufacture.
    (v) The designation EXCEPTED SPARE indicates that the engine has been excepted pursuant to the applicable provision of § 34.9(b) of this chapter; the designation must be noted in the permanent powerplant record that accompanies the engine from the time of its manufacture.
    ( Any other information the FAA finds appropriate.
    (b) Except as provided in paragraph (d)(1) of this section, no person may remove, change, or place identification information required by paragraph (a) of this section, on any aircraft, aircraft engine, propeller, propeller blade, or propeller hub, without the approval of the FAA.
    (c) Except as provided in paragraph (d)(2) of this section, no person may remove or install any identification plate required by § 45.11, without the approval of the FAA.
    (d) Persons performing work under the provisions of Part 43 of this chapter may, in accordance with methods, techniques, and practices acceptable to the FAA—
    (1) Remove, change, or place the identification information required by paragraph (a) of this section on any aircraft, aircraft engine, propeller, propeller blade, or propeller hub; or
    (2) Remove an identification plate required by § 45.11 when necessary during maintenance operations.
    (e) No person may install an identification plate removed in accordance with paragraph (d)(2) of this section on any aircraft, aircraft engine, propeller, propeller blade, or propeller hub other than the one from which it was removed.
    -
    -
    I think (b), (c), and (e) pretty clear. Maybe it's how you interpret it. What I know is my ASI would expect to hear about a fuselage change whether new or used and he would want to know where I got the replacement and where was my original going. It has been a while ago but we discussed building an airplane from a dataplate and parts and it was not impossible if he knew about the project from the getgo but I was cautioned not to do that without contacting him. jrh
    You can't get there from here. You have to go over yonder and start from there.

  37. #37
    www.SkupTech.com mike mcs repair's Avatar
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    But it not a DIFFRENT AIRCRAFT. it's the same one. Just new parts.

  38. #38

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    Quote Originally Posted by mike mcs repair View Post
    But it not a DIFFRENT AIRCRAFT. it's the same one. Just new parts.
    I guess it's different FSDOs, different people. One of my ASIs does seem a little obsessed with stolen parts and parts from insurance write off wrecks. You feel you have approval to remove a dataplate and install it on a new or used part. I've had it said to me I better not do that unless they know about it first and 45.13 was put before me. He then said it was fine if the dataplate was removed and then put back right where it came from but if it was not going back on the same part in he same place he wanted to know about it. Maybe it's just me and I look like a crook. After all my maternal Grandma was an Okie and she was nutz, too. jrh
    You can't get there from here. You have to go over yonder and start from there.

  39. #39
    www.SkupTech.com mike mcs repair's Avatar
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    Quote Originally Posted by N86250 View Post
    I guess it's different FSDOs, different people. One of my ASIs does seem a little obsessed with stolen parts and parts from insurance write off wrecks. You feel you have approval to remove a dataplate and install it on a new or used part. I've had it said to me I better not do that unless they know about it first and 45.13 was put before me. He then said it was fine if the dataplate was removed and then put back right where it came from but if it was not going back on the same part in he same place he wanted to know about it. Maybe it's just me and I look like a crook. After all my maternal Grandma was an Okie and she was nutz, too. jrh
    EVERY SINGLE PLANE I(and everyone else) Build(s) has the data plate removed and put on a BRAND NEW DIFFERENT new floor board, and probably not in exact same location...

  40. #40
    www.SkupTech.com mike mcs repair's Avatar
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    Quote Originally Posted by N86250 View Post
    ...parts from insurance write off wrecks....
    jrh
    whats that have to do with anything?? insurance writes off stuff they don't think they can return to the pre-accident condition for less than ?70% insured value....

    but the owner can buy back the salvage and rebuilds it themselves because of "sentimental value"... multiple times kinda like a ruff marriage ....

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