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-----Original Message----- From: William R. Bayne [mailto:[EMAIL PROTECTED] Sent: Monday, October 31, 2005 12:09 PM To: Ed Burkhead Subject: Re: [COUPERS-TECH] Verify inlet/outlet on Fuel Pump RLYTECH Hi John, I'm not a mechanic. Neither am I a lawyer. So I'm going to tiptoe out on the slippery slope of "common sense". Ercoupes met the requirement of conforming to their type certificate by flight test after assembly. Whatever was on a given airframe met all applicable requirements when that airframe was signed off by a designated "representative of the administrator" (if we apply today's closest terminology), installed auto parts functioning as intended inclusive. Ercoupe production predates the concepts of TSO and PMA, therefore individual elements of the overall design are logically "grandfathered" except for SPECIFIC exceptions such as the "...approved anti-collision lighting system..." you mention in your "Strobed lights etc." message today as referenced to [91.205(c)(3)]. As you also stated therein, "Planes of Ercoupe era can get away with a system that meets earlier standards". Those earlier standards were automotive. If the original supplier no longer offers parts for pumps they made, or even the pumps themselves, a pilot/owner is entitled to MAKE parts or have them made to applicable standards. If I, as pilot/owner, choose to deem parts made in China functionally identical to the original manufacturer's automotive parts for these pumps, I believe existing regulations permit me to make that decision and hire an A&P or IA of my selection to install said parts to such extent as I may not legally install same as preventive maintenance. An original manufacturer's designation of an automotive quality fuel transfer pump should continue to apply to parts necessary to continue said pump in functional service or to replacement of such pumps with the "burden of proof" to change this reality entirely upon those who would argue in behalf of such change (i.e. the FAA and/or you). If there is one or more specific FARs that apply TSO and PMA standards retroactively to airframes designed and manufactured prior to origination, adoption and implementation of said concepts by the CAA/FAA, please give specifics. What such agencies may WISH to be true is not made so by mere assumption or liberal interpretation of general regulations. I simply do not believe parts and/or pumps from Tractor Supply" NEED to be approved for use on aircraft to be installed on an Ercoupe or other such early airframe design. Where is that written? Regards, William R. Bayne <____|-(o)-|____> (Copyright 2004) -- On Oct 31, 2005, at 10:54 AM, John Cooper wrote: > > At 10:06 AM 10/31/2005, WRB via Ed Burkhead wrote: >> "All fuel pump parts necessary for repair are available from >> the Continental >> Motors Corporation, AND AC AUTOMOTIVE SERVICE STATIONS". >> (WRB >> emphasis added) Perhaps this ERCO/Univair statement is >> clear enough >> as to the automotive origin and parts acceptable for use in >> the >> "Continental" pumps fitted to Ercoupes. > > > I don't think anyone is disputing the origin of the pumps. The > problem is that neither of these sources today supplies parts for the > pumps. It is not, in the eyes of the FAA, OK to source similar parts > from wherever one sees fit. At one time Delco had PMA approval for > those parts. No other automotive parts manufacturer can make that > claim. Thus, parts for those pumps from Tractor Supply are NOT > approved for use on aircraft. > > Incorporation of ESB 42 is required by AD 47-20-03 > > I could be mistaken, but the fittings in the photo appear to be > automotive, not aircraft fittings. > > > John Cooper > Skyport Services ============================================================================== To leave this forum go to: http://ercoupers.com/lists.htm Search the archives on http://escribe.com/aviation/coupers-tech/
