Aircraft model change

[williamc]

The latest issue of the "Aeronca Aviator" has an interesting article by Bill Pancake called "Aeronca Maintenance". On page 9 there's a Question: Aircraft model change. The answer comes from FAA document 8130.2G,chapter 2, section 2, paragraph 217-Aircraft Model Change, Page 2-13, 31 August 2010. The main gist of the thing is this: When you change from a 7AC to a 7BCM, 7DC or whatever model, by using a Service letter or STC, the Aircraft registration, air worthiness certificate, and the aircraft ID plate must reflect the new model change. You must install a new ID plate next to the original plate. The original plate shall not be modified. This supercedes previous instructions to re-stamp the original. I thought everyone on the forum making model changes should know. Go to the FAA web site to read the full text.
Bill

[Paul Agaliotis]

Bill,
That's the funny thing about all of the FAA's documents. Go to Chapter 3 sect. 3 para. 327 & and 328 and they tell you to modify the ID plates.
Paul

[Dennis]

Bill,

What about when the STC specifically states that you "SHALL" restamp the data plate. The IA when submitting the 337 must state that the mod was done in accordance with the STC. Is this a catch 22?

Also, what about older mods. Do you go back and redo the data plate? I would not think so. So you end up with a mixed bag of applications.

On the other hand, why am I trying to make sense out of the regs.

Dennis

[williamc]

Paul, I really will have to hope that Bill Pancake will chime in and explain the ins and outs of that reg. I'm using the Lasher STC SA232SO to change my 7BCM from a C85-8 to a C85-12F and Bill told me I didn't have to re-stamp the ID plate as was stated in the STC. I guess it would take a Philidephia lawyer to figure out the regs. I hope pointing out the article will help someone rather than cloud the issue.
Bill

[Paul Agaliotis]

Bill,
I've come to the conclusion that if you can make a convincing argument for approval, you get it. The Feds seem to write these things with ambiguity in mind. I once asked Bill O'Brian why the FAA didn't make the FAR's easier to understand and follow. He gave a wry smile and told me " we don't write these regulations for people to understand, we write them so we can defend them in court".
Paul

[MikeB]

My L16 (7BCM) with the Wagner 0200 conversion has the original type plate with the original components (engine number, oil, fuel,etc. ) and also stamped "conv" per the STC instructions. I also had a new plate (same type) made up with the new serial number, oil, fuel, etc. located next to the original plate. Pretty hard to "unstamp something". Seems like a not to well thought out regulation to me.

Mike

[Paul Agaliotis]

Mike,
Most of this order applies to new stuff. I don't think there will be any problem with the current records or data plates. This is all part of the new Air-200 boon-doggle brought to you by the Aircraft Certification Service, whoever they are.
With the passing of the FAA funding bill, NextGen is here. Better put in an order for the GPS and ADS-B receiver you will need to fly in the "free world".
Paul

[rkittine]

My 7AC - Converted to a 7CCM also has the original plate with a "-CONV" stamped next to it and a new plate next to the original as well as the plate for U.S. Customs on the tail.

[rkittine]

Might be for TSA and not Customs.

[MikeB]

Well, we're probably beating a "dead horse to death" but it probably does make some sense to have a plate that reflects the current way the aircraft is configured (if that's the correct term) i.e. a C-90 in place of the original A65, extended fuel, oil capacity, etc.

Having said that, after spending 30 years working in community college system I know once someone is given authority to generate paper or records it becomes an endless cycle (called job justification ). I suspect the FAA is also the same over the long run.

MikeB

[jepropst]

Shortly after completing the Lasher conversion of my Champ with a C-85-12, the original nameplate was overstamped with “conv” as instructed by the STC. Following the conversion, which included about 15 field approvals, Bill Pancake and I began working with our FAA inspector to try to obtain a new and corrected aircraft airworthiness certificate. Over the years the indicated model on the airworthiness certificate had been incorrectly changed due to several questionable conversions. I wanted to get the airworthiness certificate updated to show the correct aircraft model. It should be noted that the FAA inspector that we were working with was extremely knowledgeable with both the regulations as well as with vintage aircraft and provided a lot of extremely useful guidance and suggestions in developing the various field approvals. As we discussed the correct model type that should be shown on the airworthiness certificate, we discussed the STC requirement for stamping the original nameplate. It was at this time that the FAA inspector advised us of the new and conflicting requirements of FAA Order 8130.2G which provides guidance for not modifying the original data plate and, instead adding a new second data plate. We were faced with both the situation that the STC was in conflict with the FAA Order, and also with the dilemma of needing to un-stamp the already stamped nameplate. Concerning the conflict, the FAA inspector suggested that if the conversion takes place after the date that Order 8130 was issued, then the Order would take precedent over the STC, but it would obviously not apply to conversions that took place before the issuance of the order. Concerning the dataplates, the FAA inspector issued me a letter permitting us to remanufacture a new “original” dataplate. We ordered two replacement dataplates from Don Jones. One was stamped with the original aircraft data while the second was stamped with the revised aircraft and engine data. The FAA inspector recommended that the original data plate be retained with the aircraft logs. While it would be desirable to have the STC holder for the Service Letters and the other various conversion STC’s revise their documents to comply with the FAA Order, it is highly unlike that this will ever happen. Therefore we are probably left with the fact that the Order is in conflict with a number of service letters and STC’s. While you most likely would not get caught with an incorrect data plate during a ramp check, if you are just going through an engine conversion, you might want to be aware of the FAA Order and comply with it or at least discuss it with your local FAA inspector.

[Dennis]

Let me throw this out. I have the Wagner STC and I installed an 0-200A engine in accordance with the STC. I submitted the 337 (verified correct) with the correct engine designation and serial number. So far, everything is good.

The other day, I checked my plane on the FAA web site and discovered that they had my engine listed as an 0-200D.

What gives? Should I leave contact the FAA about what appears to me to be an error or just let it go?

Dennis

[Paul Agaliotis]

This is where I believe the FAA has let General Aviation down. For something as simple as installation of the C85 in place of the A65 we end up with a confusing situation. With everybody doing their own thing for installations, who's to say what's correct.
It's been 50 years since people started making this engine change. Why don't we have a standard of some kind? This is such a simple change and yet, the only issue which I see as a problem, the fuel system, is not addressed. Not the delivery of the fuel, the quantity. The problem I have encountered is people running out of gas because the C85 burns more. But no flight supplement or added fuel requirement.
Now if you plan on installing a TSIO-541 in the Champ, there SHOULD be all of these hoops to jump through. I guess common sense isn't so common after all.
Paul

[jepropst]

It doesn't help that the service letter methodology for changing the aircraft model number is different than the methodology used with the Lasher and Wagner STC's. Service letter conversion model designation involves changing the model designation along with the addition of "Conv" whereas all the various conversions of Champs using the Lasher STC all end up having the original model designation plus the addition of the "conv" designation. The FAA Order 8130 does not change the model number but only changes how the aircraft data plate is handled.