Ed,

You miss four additional points that cannot be refuted:

1. I also offered " incontrovertible evidence" that the "Manufacturer's
Required Equipment List" which is, by definition, all equipment on an
aircraft when CAA/FAA Certification was received is further specific
physical description and definition of one individual aircraft by serial
and registration number "as certificated".  ERCO put the spinner on that
list in the great majority, if not all, cases. The presence or absence of
said spinner (or its production replacement) directly relates to the
airworthiness of that airframe.

2.  What Kevin and Bill Biggs "say" or "expect" is irrelevant.
IF the drawings are part of the ATC, as interpreted by the FAA, the very
absence of documentation in aircraft records of any change to the original
spinner makes an Ercoupe unairworthy.

3.  I'm glad you asked about instances of the FAA "pounding on
someone" for something not specifically identified on the ATC
or TCDS downloadable form the FAA site.  It concerns another
subject that has previously been "thrashed to death" here...
that of a mixture control rendered inoperative.  Here's the link:

http://groups.yahoo.com/group/ercoupe-tech/files/

Look for "NTSB" - pdf

4.  Those Tech members voting the final "poll" option should consider
departing the Tech list for the Fly-In list. They contribute NOTHING to Tech
and are unlikely to in the future.

Regards,

WRB

--

On Sep 3, 2009, at 18:32, Ed Burkhead wrote:


Please, let me summarize what I see of the discussion:

1a. Bill has incontrovertible evidence that there are words that seem to indicate the original drawings are a critical part of the aircraft's type
certificate and any deviation from that without permission means the
aircraft is unworthy.

1b. John Cooper, a working A&P/AI, agreed that the skull cap spinner is not permitted without an approved form 337 for that aircraft but he didn't cite
his documentary source.

2. Kevin and Bill Biggs, working A&P/AIs, say that what they are expected to go by is the Aircraft Specification or Type Certificate Data Sheet for
that aircraft (though I've heard it called, incorrectly, the "type
certificate").  For us, that means Aircraft Specification A-718 for the
415-C and 415-CD and Type Certificate Data Sheet A-787 for all the later
models.  Both documents are linked to from my Coupe page:
http://edburkhead.com/Ercoupe/index.htm
As Bill Briggs and Kevin say, there's no spinner listed in either A-718 or
A-787.

Are there ANY instances of the FAA pounding on someone, "violating" them
with a reference back to the factory drawings?

Ed

Ed Burkhead
(nasty and abusive forum dictator)
http://edburkhead.com/Ercoupe/index.htm
ed -at- edbur???khead.XXX change -at- to @, remove ??? and change XXX
to com

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