Tom wrote:
> Is it possible to prepare and submit 337's for work past
> completed, AND is there an STC that covers the work
> that was done to my plane?
Tom,
I'm not an A&P or AI and just have a pilot's level knowledge of this
subject. Nevertheless, let me take a swing at answering your question.
A standard STC is researched, engineered and approved by the FAA. It's
a market commodity the use of which can be sold. There is no STC for
removing the header tank on an Ercoupe that I know of.
Not to worry too much.
Yes, you can document and get approval for a previously performed
modification - subject to the information below.
The form 337 is often called a one-time-STC. It is a supplement
covering changes to the type certificate for one plane - approved by the
FAA. It is possible to use another pilot's form 337 as justification
for a change to your airplane. Form 337s signed off before a certain
date are considered "approved data" because all the FAA people back then
who did such sign-offs were engineers. Form 337s signed off since that
time may be accepted as "approved data" or maybe not. It'll depend on
how much the current FAA wienie feels that approving your change might
threaten his/her career.
In the last few years, the FAA has been reluctant to approve major
changes to aircraft without some "approved data." "Approved data" lets
the blame fall on the person who created the "approved data" rather than
on the FAA wienie who signs off on your form 337.
In the absence of "approved data" in the form of an old form 337, an
approved STC, the FAA staffer may require an engineering analysis from a
Designated Engineering Representative (DER) who is a non-FAA person
authorized to make such analysis and charge money for the service. With
a favorable analysis from a DER, some pretty major changes can be made.
Many people have bought planes and found changes for which there is no
documentation on file with the FAA. (See that document CD.) If it is a
"major" change, then the plane is not legally airworthy until a form 337
is submitted and approved. You may be required to include an
engineering analysis from a DER.
For your fuel tank removal and fuel system restructuring, you may well
need to have "approved data" to use as a reference. Perhaps one of the
members here can fax or scan/e-mail you a copy of prior approval for
removal of the header tank.
Your fuel system restructuring is similar to that needed for the 30
gallon wing tank installation and the STC for that modification may
constitute adequate approved data for your plane's change. I'd urge you
to talk to Skyport ( http://ercoupeparts.com ) and/or watch for a
response from John Cooper here on the forum.
If your current mechanic is unwilling to do the paperwork and get
approval for the mods to your plane, you need to find a mechanic who
will. I can't blame this guy /too/ much. He's presented with a plane
that has a strangely modified fuel system AND which is having fuel
problems sever enough to cause a forced landing. A mechanic with plenty
of other work to do may well decline to dive into this. But in doing so
to me, he would forfeit any further business from me if I could possibly
help it.
Unfortunately, I think you have some work to do and will need to pay for
some professional paperwork. In addition, some physical work will
probably need to be done to solve your current fuel delivery problems.
Me, I liked to do cross country trips and like having the extra fuel
reserve in the header tank as well as the excellent hard-to-mismanage
fuel system. If it were mine, I'd seriously consider buying a
refurbished fuel tank and modifying the instruments as needed, putting
the plane back to the original design.
Sorry,
Ed
Ed Burkhead
http://edburkhead.com/Ercoupe/index.htm
ed -at- edburk???head. com change -at- to @ and
remove question marks and extra space
