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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




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