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Thread: Fairbanks FAA Seminar Concerning Destroyed Aircraft

  1. #81
    hotrod180's Avatar
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    The registration expires if not renewed every 3 years.
    FAA then "de-registers" the airplane.
    This seems to be the major cause of de-registered airplanes.
    Sometimes due to carelessness, sometimes due to the airplane being wrecked and then who cares.
    Tail number is then put on hold for 5 years,
    I assume to allow the owner to re-register it if he pulls his head out of you-know-where
    and realizes that he allowed registration to lapse.
    After that 5 years, the tail number is up for grabs.
    I never thought about the airworthiness aspect of this.
    My thought would be that the registration & the A/W certificate are two separate issues,
    but from the previous post I guess the FAA doesn't agree.
    Cessna Skywagon-- accept no substitute!

  2. #82

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    The problem many of us are finding is when the registration isnít renewed, or is otherwise canceled, FAA assumes the aircraft was scrapped or destroyed, and then it is a royal pain to get the registration back. In several cases Iíve been involved with, they want the TC holder to confirm that the dataplate is the original one issued, even if the current TC holder isnít the same organization that built the aircraft. This is just ridicules!


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  3. #83
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    Quote Originally Posted by Hardtailjohn View Post
    The way I see it, I have a Super Cub project that needs new fuselage and wings... 35+ years ago, this wasn't really worth rebuilding, so the registration and all was let expire. I've gone through all the steps and it now has current registration....but it's history says it was scrapped or lapsed in the past. Now it's well worth rebuilding, but it's going to have to go through an inspector, who chances are, has never seen a PA18 naked, and it's his/her choice to make a decision whether I get to rebuild MY airplane? At the least, this is going to cause me to build an inferior aircraft because it sounds like a huge PIA to replace both at the same time, like I had planned. We're allowed to replace ANY part with a PMA'd or STC'd part, but just not all at one time. What a crock!

    John
    So ...... replace fuselage, logbook shows aircraft returned to service. Two months later, wings damaged and replaced, returned to service. If IA is doing this it's legal, right? Does the FAA actually have to witness a flight when "returned to service"? Catch my drift? If a rebuild takes you a year, maybe you did it in three stages, returned to service for two months between each step. You just flew it at night and no one saw it in the air ..... guess it would work if airworthiness cert never expired.
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  4. #84
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    Well, it seems that the FAA has again moved the goal post. It is up to us as a group to find the loop hole with the work around. Collectively I'm sure that we can achieve the upper hand.
    N1PA

  5. #85

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    Experimental?

    Quote Originally Posted by Mark_Moyle View Post
    I didnít make it to the meeting. Did speak with a guy who did attend. He came away with the idea that the new regulations were designed to eliminate liability for the manufacturer of the aircraft and that it is to promote sales of new aircraft to replace older aircraft. His opinion was that the FAA is attempting to reduce risk of shoddy workmanship, saying that after rebuilding a totaled aircraft it canít be brought back to the same standard met by the manufacturer and that it canít be re-certified. That it can be moved into the experimental category. So...I asked. If I own a $25,000 certified aircraft and only insure the hull for $25k and it gets totaled by the insurance company because itíll cost more to repair due to the insured Hull value? That I canít rebuild it and keep it certified if the damage costs more than $25k? But if I insured that $25k aircraft for $50k and the repair cost is less than that it can be repaired as a certified aircraft.

    So after talking with him....I read the regulation... doesnít lead me to believe my restoration after the insurance company totaled is effected by this regulation. Didnít see anything about taking a certified aircraft into the experimental category.

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    What? What category, amateur built, exhibition, research?? I thought this was exactly what the FAA did not want to happen.

  6. #86

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    There are no new ďregulationsĒ, only policy in the form of Order 8100.19. The problem I see is that FAA is determining aircraft to be destroyed or scrapped where there was no accident, and no parts were sold as salvage, just that the owner didnít renew the registration. Registration should have nothing to do with airworthiness, other than being a prerequisite to legally operating an aircraft.


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  7. #87

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    Yes I'm finding this out with the Pacer project I posted about on the other site. Reg denied twice. First time because previous owner checked destroyed. It wasn't wrecked at all, just had a runout motor and 35 year old fabric. He sold it to a guy who wanted the wings for a different project. That guy got sick and passed so I bought the Pacer. FAA reg wanted pics of everything including logs to prove it was not destroyed, I sent them that, denied second time because aircraft was in pieces. Well yes the wings and tail are off, so I'm debating what now? Continue down this path and put it together and certainly face further denials and hassles? How much $$ should you put into a plane with no paper work?
    I think everyone can see they want these aircraft off the books for good and will make it increasingly difficult to legally repair/restore them.
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  8. #88

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    At some point it will take a class action suit against FAA to fix it. This all got started back in 2010 when registrations expired.


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  9. #89

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    Sometimes we create the problem. Case 1, C170 cartwheeled on takeoff. Owner Flubb sold the wreck to 170 Expert who took 4 years repairing the airframe and engine but ignored the paperwork. After 3 1/2 years Flubb happened to look up his old airplane on the web and found it still registered to him. Fearing something wonky was going on and he might get dragged into a lawsuit, he wrote the FAA a letter and deregistered the aircraft as destroyed. If Flubb would have filled out the back of the registration and mailed it in like he was supposed to when he sold the plane or if the Expert would have taken care of the registration when he bought it there wouldn't have been a problem. Case 2, Freezerburn sold his experimental to Gotrocks who kept it in his garage for two years and didn't register it. Why he would have had to pay a few dollars personal property tax to his home state if he registered it. And he lost the bill of sale. But the chance came to make a few dollars so he sold it to Cheapo who put it in his garage for two more years. He didn't want to pay Personal Property tax either. In the meantime Freezerburn passed away so there won't be another bill of sale unless it's forged in a dead man's name. Now Cheapo wants to drag this thing out, get a condition inspection, pay his taxes, and fly. Cheap bastard, I'm not gonna help fix this mess. I got better things to do.
    You can't get there from here. You have to go over yonder and start from there.

  10. #90

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    That's funny! I think I agree with you!

    Still, there ought to be some enlightenment back at 800 Independence. Those guys need to come fly Cubs and slow down a bit on the ACs and Orders.
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  11. #91

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    Quote Originally Posted by N86250 View Post
    Sometimes we create the problem. Case 1, C170 cartwheeled on takeoff. Owner Flubb sold the wreck to 170 Expert who took 4 years repairing the airframe and engine but ignored the paperwork. After 3 1/2 years Flubb happened to look up his old airplane on the web and found it still registered to him. Fearing something wonky was going on and he might get dragged into a lawsuit, he wrote the FAA a letter and deregistered the aircraft as destroyed. If Flubb would have filled out the back of the registration and mailed it in like he was supposed to when he sold the plane or if the Expert would have taken care of the registration when he bought it there wouldn't have been a problem. Case 2, Freezerburn sold his experimental to Gotrocks who kept it in his garage for two years and didn't register it. Why he would have had to pay a few dollars personal property tax to his home state if he registered it. And he lost the bill of sale. But the chance came to make a few dollars so he sold it to Cheapo who put it in his garage for two more years. He didn't want to pay Personal Property tax either. In the meantime Freezerburn passed away so there won't be another bill of sale unless it's forged in a dead man's name. Now Cheapo wants to drag this thing out, get a condition inspection, pay his taxes, and fly. Cheap bastard, I'm not gonna help fix this mess. I got better things to do.
    And that was the way aircraft transactions took place prior to 2010. Since the time limit on registrations was put in place, theyíve come up with all these new policies that donít make a lot of sense.


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  12. #92
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    Quote Originally Posted by dgapilot View Post
    At some point it will take a class action suit against FAA to fix it. This all got started back in 2010 when registrations expired.


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    How about a class action suite to force them to abide by the FAR's.

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  13. #93
    BC12D-4-85's Avatar
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    Note these earlier concerns from the FAA about destroyed aircraft and Data Plates.

    https://www.faa.gov/aircraft/air_cer...nt_seminar.pdf See page 21 on.

    Gary

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    Yeah, what about data plates? About half the J3s lose their baggage doors during restoration - dad dies, mama and the kids throw out the rotten wood and sell what is left.

    An engine case goes to a rebuilder, who blasts the data plate beyond recognition - or, Divco says case is no good; get another. Data plate in the trash; logs all the way back to Mobile.

    Twice in my short life I have gotten FSDO letters to reproduce data plates. I understand I have been very lucky; now no data plate means no aircraft.
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  15. #95
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    What a crock......

  16. #96
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    Quote Originally Posted by bob turner View Post
    Yeah, what about data plates? About half the J3s lose their baggage doors during restoration - dad dies, mama and the kids throw out the rotten wood and sell what is left.

    Twice in my short life I have gotten FSDO letters to reproduce data plates. I understand I have been very lucky; now no data plate means no aircraft.
    Mums the word!
    https://www.wagaero.com/data-placard...for-piper.html
    Click image for larger version. 

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    N1PA

  17. #97

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    That same tag can be had from Walmart for $19.95.

    Found a gorgeous brass Continental repro for $75. Noel Allard's Cub tags are $75, but you need a letter from the FSDO for even a blank.

    Interesting.

  18. #98

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    I wonder if the ACO office or DER will want engineering data with a repair plan? That could get really expensive.
    How about I submit>
    1) replace wing with serviceable wing.
    2) Sandblast and inspect airframe, replace any corroded tubes, prime/paint.
    3) Recover complete aircraft with ceconite process.
    4) Replace engine/prop with serviceable.
    5) weigh aircraft.
    6) inspect IAW annual inspection procedure.
    That's my plan.


    https://www.eaa.org/en/eaa/news-and-...ircraft-Policy

    Clarification on FAA Destroyed Aircraft Policy

    December 20, 2018 - EAA sought and received clarification on a recent FAA order that caused concern for some aviators, particularly in Alaska, that restorations of salvage airplanes and similar aircraft would be nearly impossible under the new agency policy.
    EAA government advocacy team members talked directly with the authors of Order 8100.19, Destroyed and Scrapped Aircraft, which was issued without a public comment period this fall. The order was written because of FAA findings that some restorations of salvaged or destroyed aircraft did not meet type certification specifications and, as such, could not be registered as type-certificated aircraft. This caused concern that certain restorations that involve significant rebuilding of the aircraft would be impossible.
    “True ‘data-plate restoration,’ where no part of the original aircraft is incorporated in a rebuilding project, has always run afoul of FAR 45.13, which states that a data plate may only be placed on the original aircraft, and FAR 47.41 states that registration is terminated when an aircraft is ‘completely destroyed,’” said Tom Charpentier, EAA government relations director. “However, the order’s authors do give a generous berth to the definition of completely destroyed, as any part of the primary structure — such as fuselage, wings, and tail — that is still salvageable can be defined as an aircraft that can be rebuilt. The intent is to prevent restoration only when there is truly nothing left of the original airframe other than the data plate.”
    The FAA order potentially adds paperwork to the restoration/repair process, but prevents only those restorations that were already against FAR 45.13.
    “We asked whether a restoration of a decades-old derelict aircraft, as is common in the vintage and warbird communities, would be allowed under the new order,” Charpentier said. “We were assured that these types of projects could be approved under this new policy, as long as some repairable parts of the previously airworthy structure survive.”
    While EAA expressed disappointment that the order was issued without a public comment period, FAA officials noted that an advisory circular as a companion to the order will be open for public comment in the coming months.

    EAA advocacy staff will continue to monitor this issue for any changes or necessary actions by EAA members.
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  19. #99

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    I wonder how one would prove that, say, the tailfeathers are actually from that specific aircraft? I bought a trio of fuselages with paperwork in the early 1970s, and two of those fuselages are close to flying under one data plate. I have no idea which paperwork the tail feathers belong to.

  20. #100

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    Six months later, still fighting with FAA registry on my PA-16! Previous owner fought with them for 2 years before selling me the project. Mind you it is a complete project with an original data plate that was never tampered with, still attached to the fuselage. Registration was canceled back in the 1970s when the previous owner didn't send in the tri-ennial report due to not providing a current address. Airplane was stored in a garage since the early 1960s. Some FAA Inspector that has never seen the airplane decided that he doesn't believe it is the original data plate and says Piper has to confirm that it is the true and correct data plate. Piper says they have no way to confirm said data plate, so I'm stuck in the middle. My local FSDO inspector believes it is the correct data plate. FAA Registry still says they need confirmation from Piper (a company that never built a Clipper) that it is the correct data plate. I'm so frustrated!!!! I've provided pictures, all the drawings that show where it is supposed to be located, the original build sheet from Clyde showing that the original frame number fuselage is there, that the original engine serial number is there, the only thing I haven't done is pull the fabric from the wings to find the pencil marks with the wing numbers.

    Talking with the Registry, their SOP is if a registration lapses, the aircraft is considered Scrapped or destroyed, and there is no appeal process. They won't give me a denial, only a "not recommended at this time", so still no appeal process. Nothing like being in legal limbo.
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  21. #101
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    Yeah well... grab one of the local inspectors (you don’t mention where you are at!). The local inspector can verify that all the parts are there in the correct order! Send the thing in with the inspectors verification. Tell the SOB that you want the name of his supervisor, if that isn’t good enough.
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  22. #102

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    Quote Originally Posted by nanook View Post
    Yeah well... grab one of the local inspectors (you don’t mention where you are at!). The local inspector can verify that all the parts are there in the correct order! Send the thing in with the inspectors verification. Tell the SOB that you want the name of his supervisor, if that isn’t good enough.
    I'm working with one of the local inspectors, and he is in full agreement with me that it is the correct data plate. Trying to get something in writing from the office is a little harder, but I think that will come. Once I have that, then the real battle begins as I'll have two different offices within FAA against one another. I've already tried to go to the manager of the registry and even though I know him, I've gotten the cold shoulder. I've also got my Senators and Congressmen involved (not sure if that was a good idea or not). Waiting for a reply from them, don't really expect much there. Working with AOPA as well. I really don't want to hire a lawyer as the value of the project isn't that much, just the principal of the thing. It's such BS! I know I can sell the parts for more than what I have in the project, but I hate to break up a good airplane!
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  23. #103
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    Quote Originally Posted by dgapilot View Post
    I'm working with one of the local inspectors, and he is in full agreement with me that it is the correct data plate. Trying to get something in writing from the office is a little harder, but I think that will come. Once I have that, then the real battle begins as I'll have two different offices within FAA against one another. I've already tried to go to the manager of the registry and even though I know him, I've gotten the cold shoulder. I've also got my Senators and Congressmen involved (not sure if that was a good idea or not). Waiting for a reply from them, don't really expect much there. Working with AOPA as well. I really don't want to hire a lawyer as the value of the project isn't that much, just the principal of the thing. It's such BS! I know I can sell the parts for more than what I have in the project, but I hate to break up a good airplane!
    Yes indeed, it becomes a responsibility, when you adopt one of these projects. Don’t give up and sell out!
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  24. #104

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    So these guys who deregister an aircraft to hide it from the wife they are divorcing are gonna shoot themselves in the foot.
    You can't get there from here. You have to go over yonder and start from there.
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  25. #105

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    Really? A triennial report was required in the 1970s? How come they never cancelled my registration - I never sent any reports to them. Some oufit is always trying to take a survey, but it says on the official looking form that it is voluntary.

    I think, before triennial re-registration started, you had to ask to get de-registered.
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  26. #106
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    Quote Originally Posted by dgapilot View Post
    Six months later, still fighting with FAA registry on my PA-16! Previous owner fought with them for 2 years before selling me the project.
    Quote Originally Posted by bob turner View Post
    Really? A triennial report was required in the 1970s? How come they never cancelled my registration - I never sent any reports to them. Some oufit is always trying to take a survey, but it says on the official looking form that it is voluntary.

    I think, before triennial re-registration started, you had to ask to get de-registered.
    Something is very fishy here. Granted my experience happened in the 80s but the airplane had been sunk in 1959. I bought it sight unseen from a second owner. There was a bill of sale from the person who sunk it. When I attempted to register it the FAA couldn't find the records claiming they had been sent to some vault somewhere (Texas I think). Eventually when the time period for the pink slip was expiring I sent them another letter and mysteriously two separate registrations arrived.

    Another time I was (storing) a special N number on a wrecked airplane by maintaining it's registration. When I sold that wreck, cancel and transferring the N number to my Cub, registering the Cub, transfer another number to the wreck in order to maintain it's title trail, I made the requests all in one letter in a sequence which would make it happen smoothly. The Oke City FAA separated the different actions, assigning them to different employees resulting in a cluster f***. I kept receiving letters from different people asking for information which had been in my original letter but apparently not given to that employee. Finally after some phone calls I got one person who saw what was happening and she fixed it.

    I think that dgapilot's paperwork ended up on the desk of the wrong person, who is unable to extricate itself from the hole it has dug. Sounds like the Registry of Motor Vehicles here in Mass. They have dug a hole so deep that they can't see the sunlight. If you have been following the news here, you will know of what I'm speaking.
    N1PA

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    Some how my aircraft became a target for the SEIT team. Special Enforcement Investigation Team! Back in the 1940ís, the CARs only required manufacturer, model, PC number, TC number and Serial number. Piper was still using the 85411 data plate that has a date Field. The date was a required item early in the Ď40s, but the requirement changed around 1945. The data plate is on a diagonal tube inside the tail of the fuselage on the Clipper, and was installed prior to covering and assembly of the aircraft, so the date of manufacture was unknown when installed and inaccessible to stamp the date when the aircraft is complete. Since the date field isnít filled in, and due to parallax error when pictures were taken, the SEIT Inspector doesnít believe that it is an original data plate, and says the current TC holder, Piper Aircraft Inc. in FL is the only entity that can confirm the authenticity of the data plate. Piper Aircraft Inc never made a PA-16, and isnít even authorized to build one under their PC! The aircraft was built by Piper Aircraft Corp in Lock Haven PA, a totally different organization! Piper Aircraft Inc. says they have no ability to authenticate the data plate yet this inspector insists they are the only ones that can. So here I sit in a Catch 22. Talked to a lawyer yesterday and he said figure $30k to take them to court. Iíve contacted my senators and congress critter, and they have made inquiries to FAA, waiting for their feedback but not very hopeful given previous contacts with them. My next step will likely be to demand that the FAA charge me with violating Title 18 USC given that if the data plate is false, I committed Fraud when filling out the registration application. Given the preponderance of evidence that the subject data plate is the one placed by Piper Aircraft Corp back 70 years ago, they could never be successful in prosecuting the case and then there would be legal precedent that it is the correct data plate. Itís just so frustrating that one guy in the FAA that has never even seen the airplane can screw up something so bad, and not be man enough to say he made a mistake.


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