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-----Original Message----- From: William R. Bayne [mailto:[EMAIL PROTECTED] Sent: Saturday, April 23, 2005 8:24 PM To: Ed Burkhead Subject: Required Reading: Current FAA NRPM - Orphaned STCs & Aircraft RLYFLYIN (WRB via Ed Burkhead's computer-I can't post directly) Please send responses directly to the list or to me, Bill Bayne @ <[EMAIL PROTECTED]> Hi All (WRB forwarding), In the following, substitute "Er" for "Mono" - The FAA Bottleneck & Orphaned Aircraft ...and, oh yes, the time for response ended on 4/18 unless the FAA extends it (as a number of people have requested). As recent past President of the Monocoupe Club and a restorer of wrecked, damaged and nearly destroyed Monocoupes, I am alarmed by the destructive nature of some hidden language in FAA 2003-14825. As brought to my attention by the Antique Airplane Association, the wording of sections of this document can severely affect the survival of rare and historically important aircraft such as the Monocoupe, which is of primary interest to myself and members of our Aircraft Type Club. Please allow me to comment, taking just two trains of thought on a very complex issue. First will be the "orphaned aircraft type certificate" issue. Second will be the very positive procedures in effect now which work extremely well to ensure high standards in antique aircraft restoration. Both will be expressed from my personal involvement over the past 17 years as a Monocupe owner and restorer. First, the "orphaned ATC" issue. I am currently restoring two 1929 Monocoupe Model 113s. One belongs to Old Rhinebeck Aerodrome, Rhinebeck, NY. The second is a Model 113 Special wreck I own. In my efforts to comply with strict historical and FAA maintenance practices, I spent over 2 years working with very dedicated FAA Staffers to locate all existing FAA files on the Monocoupe Model 113 ATC. After shuffling through many FAA Regional Offices with my Freedom of Information Request, I settled with the archival office, which took nearly two years to search for the ATC Records. In the end, I received a small packet of copies of letters between the Company owners and the CAA, but not a single drawing, diagram or blueprint, despite the fact that all concerned knew how desparately I was searching for engineering drawings! On questioning the poor results of this 2 year search, I was told that a number of drawings did in fact exist, that the ATC was considered abandoned or orphaned, and that the FAA had determined that I COULD NOT purchase copies of the existing drawings! This shocked me, as I was in on the beginning of the initial FAA discussions regarding Abandoned and orphaned ATC's. I felt that the FAA offices concerned were VERY committed to assisting owners and maintainers of these rare aviation treasurers. It appeared to me after the wasted 2 year FOI search, that possibly, this same enthusiasm and commitment did not extend to all levels of the FAA. Leadership was on board but not the troops. Failing research and engineering documentation support for these restorations, I resorted to what proved to be the most rewarding collaboration I have been involved with. I am using the old CAM-18, the 43-13, several very experienced A&P, IA's and an retired FAA Inspector in private practice as a DAR. The technical guidelines and quality assurance provided by these documents and extremely qualified individuals have assured me that I am tracking straight and true to the original Monocoupe Corporation factory design. We are all assisted by the fact that this aircraft, like most of its contemporaries, is of very straightforward steel tube and wood construction. Restoring even a badly damaged Monocoupe of this era does not require rocket science. It DOES demand quality craftsmanship. That, I have found, is quaranteed by the demanding standards of my IA's and DAR, all the products of FAA training programs and years of hands-on experience. So, in my view, the structure is in place for the FIELD work on orphaned aircraft to be completed to standards exceeding original 1920's CAA mandates. It is not broke - don't fix it! What DOES require fixing is the communications down the FAA chain of authority. Taking my own fruitless 2 year slog through the FAA papermill as an example, I would venture to guess there are countless other similar episodes of thwarted, legally correct, searches for the holy grail. Somewhere within the FAA Staff are employees who do not understand that abandoned and orphaned ATC aircraft owners require their support, not their obfuscation. IF the FAA were truly intent on supporting abandoned and orphaned ATCs, the owners and restorers would have internet access via the FAA website to listings of all documents held on FAA file, with the ability to purchase copies at cost to support restorations and repairs. I my case, I was advised that drawings did exist on record, but that I could not purchase copies. This part of the FAA is the broken part of this entire equation. Restoring and rebuilding broken antique aircraft is not the problem. The second issue I would address has been mentioned above, regarding the "human element" in place to guarantee the safety and quality of restored antique airplanes. I would like to point out that I have been inundated with stories related by restorers of troubles, rejections and horrors inflicted by FAA field inspectors who knew nothing of antique aircraft and their construction techinques, but exercised their authority to ground or halt projects. Hangar flying is rife with these "us versus them" crises. What I have personally encountered is a bit different, but I suspect standard, given the way things are. When I find a very senior FAA Inspector, I am on common ground in discussing the repair and restoration of my Monocoupes. Unfortunately, these Gentlemen are a dying breed. When I encounter a newly minted FAA Inspector, I find them very good at interpersonal and documentary skills but lacking in any real knowledge or interest in the specifics of the construction techniques used in antique airplanes. It is not their fault, it is just how they were trained. Because they may not know what is going on, some are hesitant to sign off a restorer's workmanship, or approve a field STC on an antique airplane. In the old days, we would appeal to a higher order, a supervisor would wandeer in from his holding pen, and things would move forward to everyone's satisfaction. Today, it takes ages to get an FAA field inspection, and a rejection is only overturned by submitting mountains of paperwork and testing documentation, which is prohibitively costly, considering the overall value of the aircraft. Several years ago, the FAA must have realized that their system was broken, as they allowed restorers and repairmen to work with DARs and DERs. These independents are costly, but very knowledgeable and most importantly, accessible. They are sanctioned by the FAA to do for a fee that which the FAA is supposed to do by law. I personally do not mind, because I am able to work with the DAR whom I choose. My choice is based upon the DAR's credentials and experience in the repair and restoration of antique airplanes. Their standards of quality and levels on knowledge far exceed that of the 25-35 year olds in FAA employee. Nothing against the new breed at the FAA, it is just the way it is. So, what is broken is the FAA inspection program for old, orphaned and abandoned ATC airplanes. Some wise soul in the FAA realized there was a diminishing corps of inspectors who understood wood, steel tube, wire and fabric airplanes with engines called Warner, Kinner, LeBlond and Velie. The correct decision was to farm out approval for repair and modification of these airplanes to DAR and DER contractors, those who had proven to the FAA that they DID know what the FAA DID NOT. In my personal experience, this is a perfect solution. It is not broke, don't fix it. What could be fixed in the inspection and repair process is a more streamlined, efficient methodology. As a restorer, I need, from the FAA, a set of procedures which address the different hurdles I must jump to successfully return a badly damaged antique airplane to the air. A simple booklet which: a. identifies DARs and DERs in practice, listed by their specialties. b. provides STANDARDIZED guidelines on the correct paperwork trail required to return antique aircraft to airworthiness. This would include different levels of repair, from simple field repairs to engine and system STC's and the total reconstruction of a destroyed antique. Note, I am referring to paperwork guidelines here. More than adequate instruction and guidance on the physical work involved in restorations and repair. c. states what resources are and are not available through the FAA to assist in accurate and safe maintenance on orphaned ATC aircraft. d. allows unlimited access to records and drawings held by the FAA pertaining to orphaned aircraft. In conclusion, please accept this critique of FAA 2003-14825 in the spirit in which it is sent. I feel there is a system in place and the resources available for antique airplane owners and restorers to keep these treasurers flying for another 100 years. The FAA is a bottleneck in our access to abandoned and orphaned ATC records on file in FAA archives. The FAA is a bottleneck in field inspections due mainly to the fact that there are so few inspectors who know what they see concerning antique aircraft, and are thus unwilling to "risk" their signature on approvals. To solve just these two issues, I suggest (1.)opening access to all records available, at cost, via the already significant FAA website, and (2.)standardizing and publishing procedures to enhance the already successful DAR and DER inspector program. Regards, Bob Coolbaugh ========================================================================== ==== To leave this forum go to: http://ercoupers.com/lists.htm Search the archives on http://escribe.com/aviation/coupers/
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