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-----Original Message-----
From: William R. Bayne [mailto:[EMAIL PROTECTED] 
Sent: Friday, November 25, 2005 1:01 PM
To: Ed Burkhead
Subject: WRB Re: [COUPERS-TECH] 415D conversion


RLYTECH

Hi Hartmut, Jan

On Nov 25, 2005, at 11:55 AM, Hartmut Beil wrote:
>
> The 415 C/D is also having the sheet metal over the header tank.

        That is correct.
>
> In a way one could claim that the converted Cs aren't anything else 
> than what Erco did when the developed that D model and did not like 
> it.
> They went back to the C model by utilizing the Type certificate and 
> declaring it a C/D .

        This is not a "claim", but factual EXCEPT that only the CD Model HAS

the stainless steel over the header tank.  To "go back  to the C Model" 
would, in my humble opinion, require removal of the stainless (which no 
sane person should do).  The    Models C and CD are identical in rigging 
and flight characteristics.  Of course this discussion is with regard 
to the "real    world".
>
> As I understand  right, the 415-C/D could be flown under either type 
> certificate.
> Right ? Wrong ?
>
> Hartmut

        Again, with regard to the "real         world, this is right.
Rigged as 
either D or CD,  respective limitations insure safe flight.

        Unfortunately, in the fantasy world of FAA recognition and/or
approvals, each FSDO feifdom MAY recognize what is
        physically done, submitted to them for "official" records AND logged
by an appropriately certificated person.  On the other
        hand, they MAY NOT if no one ever "officially" requested (and
received) an "approved" change to information reflected in
        FAA ownership records, then one may only fly the bird under the
limitations of the model in what they deem to be
        "determinative" "official records".  There seems to be no
controlling requirement that the exercise of such "discretion" be
        applied to interpretation of the same regulations under the same
authority anywhere in the country, or even that the
        individual exercise of such authority be done in good faith.  In my
opinion, it is FAA abuses of such authority and the
        concurrent betrayal of the public trust implicit with each and every
incidence of such abuse that has resulted in their
        progressive loss of moral authority over those they purport to
regulate under applicable law(s).

        None of this has anything to do with safe operation(s).  It would be
my guess that if a plane had installation of the stainless, a
        changed data plate, and had been rerigged as a D Model, such changes
should certainly have been logged.  Even if never
        logged, if the FAA has anything in their records pertaining to these
changes, they would likely presume it had been flown at
        the higher weight which would disqualify it for their "Sport Pilot" 
category.  Good reason on such airframes for the current
        owner to order the cd so as to be able to reference all FAA records
of both ownership and repairs/mods/maintenance and
        thusly see where they stand "officially".

        Regards,

         William R. Bayne
        <____|-(o)-|____>
         (Copyright 2004)




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