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J-3 with wood spars and 0200 engine

bob turner said:
dga may be correct - if an STC requires metal spars, you cannot later decide to install wood, without a field approval. Univair cannot do field approvals. If there is an FAA stamp in block 3 of the O-200 337, then you are home free. If not, then get Dave to do his magic.

oops - sorry - you do have metal spars. You need the stamp in block 3 of the clip wing 337. Either that, or a metal spar clip wing STC.
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Bob, the funny thing is, doing a Reed Clip wing (per the drawings, wood spars and A75) is a minor alteration since it is on the TC. Can be done with just log book entry. All that said, I would do a 337, but by the letter of the law it is a minor!


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I recovered a Clipped Wing J3 with O-200 and aluminum spars with all the approvals. Previously owned by Patty Wagstaf now owned by Todd Peterson of King Katmi 182 fame.
 
Used to be easy to get approvals. I have no doubt that this one has been approved, but I would not license it without at least looking at the 337. As Dave said before, a metal spar clipwing is not in the type certificate, and would need a field approval.
 
There is no 337, one is not required. The Reed modification was done IAW the TC as dgapilot stated can be done. Then after that, the Univair STC was used to install the 0-200 which specifies metal spars. Two separate modifications, two different but acceptable authorizations. Again, one IAW the original type certificate (Reed clip wing) the other IAW the supplemental type certificate ( 0-200 )
 
If by letter of the law it is a minor, WE SHOUD FOLLOW THE LAW!! Just saying!!
DENNY
 
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You know, I had these same questions when I was buying the airplane so I called the folks at Univair and I had no trouble understanding their explanation of how they did it. And when I called my FSDO to make sure, the inspector had no trouble understanding it. So I’m not sure what the problem with you guys is. Look, I don’t know who or what DGA is, all that know is the FAA says it’s legal, and so has every IA that’s signed the annual for the last 43 years, so if you guys want to poke holes in everything and try to say my airplane isn’t legal then go ahead, I don’t care, I’ll sell it to someone who isn’t so obtuse. Have a nice life.
 
Smonroe said:
You know, I had these same questions when I was buying the airplane so I called the folks at Univair and I had no trouble understanding their explanation of how they did it. And when I called my FSDO to make sure, the inspector had no trouble understanding it. So I’m not sure what the problem with you guys is. Look, I don’t know who or what DGA is, all that know is the FAA says it’s legal, and so has every IA that’s signed the annual for the last 43 years, so if you guys want to poke holes in everything and try to say my airplane isn’t legal then go ahead, I don’t care, I’ll sell it to someone who isn’t so obtuse. Have a nice life.
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Smonroe, I see you are a new member here, welcome aboard. It takes a while to understand where the other members are coming from, who is serious about what he is addressing and who is the BSer. We have folks here from all walks of life with experience levels from the very green behind the ears newby to some of the most qualified in their respective industry. We as a group have a tendency to dig deep in "the weeds" on most any discussion at hand. It so happens DGA is a DER (Designated Engineering Representative). He is our resident authority on the FAR's and possesses the FAA's blessings to approve aircraft alterations such as yours.

The discussion with which you have taken offense, has only been to ensure your airplane has been legally modified. It has been intended to help you in preventing some sort of problems in the selling of your Cub and to educate the rest of us. Sometimes the words get twisted in an unintentional manner which gets misunderstood. I can assure you that all of the "talk" about your situation has been with an effort to help you.

Univair has a long time good reputation. I'm sure they have done the right thing with your Cub. It's just in the explanation which has been presented here, there were some detail questions raised which needed to be understood. We get deep into details, all with good intentions.

I hope you have now had a good night's sleep and a tasty refreshing morning cup of coffee. Stick around, this is a fun place. You will find many new true friends.
 
75-35 on an 0-200 will outperform a 90 with a 76 ak40-2 but the 90 with 75-35 outperforms everything just not approved.
 
I find your statement that you have the only legal Clipped Wing Cub with O-200 and metal spars a bit arrogant.
 
Smonroe said:
You know, I had these same questions when I was buying the airplane so I called the folks at Univair and I had no trouble understanding their explanation of how they did it. And when I called my FSDO to make sure, the inspector had no trouble understanding it. So I’m not sure what the problem with you guys is. Look, I don’t know who or what DGA is, all that know is the FAA says it’s legal, and so has every IA that’s signed the annual for the last 43 years, so if you guys want to poke holes in everything and try to say my airplane isn’t legal then go ahead, I don’t care, I’ll sell it to someone who isn’t so obtuse. Have a nice life.
Click to expand...

Just because it’s been done that way for 43 years doesn’t make it right.

Heck, if you ask 3 different FSDO’s a question you’ll get 5 different answers


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RaisedByWolves said:
Just because it’s been done that way for 43 years doesn’t make it right.


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Click to expand...

And conversely, what the FAA suddenly says isn't legal even tho it's been done ( with the FAA's blessing) for 60 years doesn't make them right !!

The J3F conversion to J3C is a perfect example of that !!
 
That’s why having access to a DER or a DAR with field approval authority is so important in today’s world. Yeah, FAA used to do it for free, but that ship has sailed.


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dgapilot said:
That’s why having access to a DER or a DAR with field approval authority is so important in today’s world. Yeah, FAA used to do it for free, but that ship has sailed.


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Click to expand...

Side note, I tried to become a DAR after paying one to convert to E-LSA. I mentioned I'd like to become one and he begged me to talk to my fsdo, they need dar's bad. My FSDO said "You don't have the experience and even if i did I don't have the time to baby sit you".
 
It took something like 4 years for me to get DART finally in 2004 and another 10 years to get DARF. Been an A&P since 1977, IA since 1980. Assisted in aircraft certification on about 15 airplanes (both import and export) and hundreds of Field Approvals before getting the DART. Had to apply to FAA Headquarters to get a deviation for home builds. The process is not easy. It is all dependent on need and FAA ability to manage.


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dgapilot said:
...a minor alteration since it is on the TC. Can be done with just log book entry. All that said, I would do a 337, but by the letter of the law it is a minor!
Click to expand...

I'm curious as to why you take this position?
I've seen a lot of discussions where someone gets chewed put for filing a 337
for a mod that (others claim) is a "minor alteration" needing a logbook entry only.
Odyssey battery is a good example.
 
Yes, but don't you find this interesting? Univair and the FAA have decided that their O-200 STC is approved data to convert a Reed conversion to metal spars, and all you need to do is cite the Univair STC.

Funny how folks get upset when they try to use a forum to sell stuff and get comments. Forums are designed for comments and opinions. You get good opinions, bad opinions, facts, nonsense . . . That's what forums are.
 
Nobody gets chewed out anymore for filing a 337. Nobody looks at them until an event happens. That's why we are starting to see so many major alterations without approved data.

All of my recent field approvals are to fix 40 year old 337s that cite nothing other than an IA signature - two of them for fuel systems! Four were on an Oshkosh winner! Nobody caught them.

But I agree. The FAA is supposed to reject 337s for minor work, including stuff authorized by the type certificate, like the Reed conversion for wood spar Cubs.
 
This was 40 plus years ago. Today you would need data to prove that the modifications to the Reed Clipped wing modification would cross over to metal spars. This guy is trying to sell an airplane. I am sure there is more data than a logbook entry and an STC. If so it wouldn't hold mustard today.
 
hotrod180 said:
I'm curious as to why you take this position?
I've seen a lot of discussions where someone gets chewed put for filing a 337
for a mod that (others claim) is a "minor alteration" needing a logbook entry only.
Odyssey battery is a good example.
Click to expand...

Using 14 CFR 1.1, the definition of Major Alteration includes “not listed on the aircraft specification ( the specification was the precursor to the current TCDS). The definition of minor alteration is anything that isn’t major. So if something is listed on the TCDS, the installation of that is a minor alteration. The Reed Clip Wing is listed on TCDS 691, item 625, so that makes it a minor alteration for a J3C series airplane.


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bob turner said:
Yes, but don't you find this interesting? Univair and the FAA have decided that their O-200 STC is approved data to convert a Reed conversion to metal spars, and all you need to do is cite the Univair STC.

Funny how folks get upset when they try to use a forum to sell stuff and get comments. Forums are designed for comments and opinions. You get good opinions, bad opinions, facts, nonsense . . . That's what forums are.
Click to expand...

I’ve never considered that. If you read the limitations on STC SA107RM, it gives the typical don’t extend this modification bless it’s determined no adverse effects . . . Nowhere in that a STC does it say how to shorten a metal spar wing, and the Reed drawing don’t include metal spar wings. I don’t see how anyone can make the jump that STCSA 107RM would allow installing metal spar wings on a Reed Clip Wing. The couple I’ve seen use the Reed drawings as acceptable data, create their own drawings for shortening metal spar wings, and got Field Approvals for the installation.


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DGA
If the clip wing install specifically calls out wood spars and the O-200 STC specifically calls out metal spars, wouldn't that make the two incompatible? It seems to me that to make the O-200 STC legal, the wings would have to be built up without the clip wing kit and have the metal spar installed at the same time. Am I missing something? If I wanted to get a field approval for the clip wing AND the O-200, how would I generate 'approved data'?

Teach me!

Web
 
wireweinie said:
DGA
If the clip wing install specifically calls out wood spars and the O-200 STC specifically calls out metal spars, wouldn't that make the two incompatible? It seems to me that to make the O-200 STC legal, the wings would have to be built up without the clip wing kit and have the metal spar installed at the same time. Am I missing something? If I wanted to get a field approval for the clip wing AND the O-200, how would I generate 'approved data'?

Teach me!

Web
Click to expand...

Web, you are correct, without additional “approved data” the two alterations aren’t compatible. I’ve seen Field Approvals for metal spar clip wing Cubs, but they would not be Reed Clip Wings. I’ve done a couple DER approvals for O-200 installations in wood spar airplanes. I use the Univair STC as acceptable data, and an old memo from NY ACO recommending the O-200 as a reasonable replacement for A-65 and other engines with an RPM limitation to 80 HP if no additional fuel, or 90 HP if there is additional fuel tanks installed.


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Teach you? Either an ASI or a DER with proper authorization can "generate" approved data. In the case of an ASI, all that is needed is a signature and stamp in block 3.

In this case, the back - block 8 - could simply state "Metal spar wings clipped in accordance with Reed drawings, with allowance for slight differences in compression strut and drag wire attach."

Then, to be sure, add: "O-200 engine installation accomplished using original mount and accessories, and instrument markings derating to 90 hp."

Of course, some might say that engineering calculations or test flights should back all this up - but once you get that stamp in block 3, you are home free. There is a small matter of ICA, but my ASIs have been letting that slide.

God, I hate acronyms and abbreviations - ICA = Instructions for Continued Airworthiness. ASI = that FAA guy who comes to your hangar with a stamp. Be sure to have coffee and donuts ready.
 
bob turner said:
Teach you? Either an ASI or a DER with proper authorization can "generate" approved data. In the case of an ASI, all that is needed is a signature and stamp in block 3.

In this case, the back - block 8 - could simply state "Metal spar wings clipped in accordance with Reed drawings, with allowance for slight differences in compression strut and drag wire attach."

Then, to be sure, add: "O-200 engine installation accomplished using original mount and accessories, and instrument markings derating to 90 hp."

Of course, some might say that engineering calculations or test flights should back all this up - but once you get that stamp in block 3, you are home free. There is a small matter of ICA, but my ASIs have been letting that slide.

God, I hate acronyms and abbreviations - ICA = Instructions for Continued Airworthiness. ASI = that FAA guy who comes to your hangar with a stamp. Be sure to have coffee and donuts ready.
Click to expand...

Bob, you are correct, once an FAA Inspector or a DAR signs block 3 with a statement to the effect that the data in block 8 is considered “approved” for this airplane (and this airplane ONLY), no further approval is necessary. Everything in Block 8 becomes Approved Data. If done by a DER, you will get either a report, or drawings or both along with an 8110-3. You cite the 8110-3 and report or drawings as your approved data. In this case only those things specified on the 8110-3 are approved! If there are other things listed in block 8 then they need their own approved data. If everything in block 8 has approved data there is no need for a field approval.


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Watching the guy with metal spars stomp off because of our discussion, I found this by a poster called "pinkeye" on the "emptywheel" site, referring to GlennGreenwald:

This is a golden age for watching grown-ass men throw tantrums and pick up their toys and stomp away, and the reason is the same as always: It’s entertaining.
 
dgapilot said:
.... once an FAA Inspector or a DAR signs block 3 with a statement to the effect that the data in block 8 is considered “approved” for this airplane (and this airplane ONLY), no further approval is necessary. Everything in Block 8 becomes Approved Data. If done by a DER, you will get either a report, or drawings or both along with an 8110-3. You cite the 8110-3 and report or drawings as your approved data. In this case only those things specified on the 8110-3 are approved! If there are other things listed in block 8 then they need their own approved data. If everything in block 8 has approved data there is no need for a field approval.
Click to expand...

So an 8110-3 is only "approved data" for that particular airplane?
I have seen mods documented by a 337 that cited an 8110-3 (signed by a DER) for another (same make/model) airplane, signed off by an IA.
But nothing in block 3-- in other words, not a field approval.
Is that 8110-3 of no use for anything on another airplane?
 
No use at all. As far as I can tell, not even acceptable data. They are more like "work product" and belong to the originator and the owner who paid.

Being an IA is a bit like being a highly specialized lawyer. We get recurrent; we should probably have malpractice insurance.
 
Each 8110-3 is good ONLY for the one aircraft identified on the form. Now, I have used the same report or drawings for multiple aircraft, but each has a separate 8110-3. Most times, I also state that the report is only applicable to the aircraft identified in the 8110-3. Block 8 of the form is the Purpose of the form. In that block it should state “to support major alteration on N#, make, model, serial number. That statement means it only applies to the aircraft identified.


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