Ed,

Thanks for your response.  There is another mechanic who is very familiar with 
this airplane, in fact he replaced all the fuel lines three months ago.  I'm 
going to contact him.  The only thing is, I had to leave the plane quite aways 
from where he is located in another state.   But it sounds like getting the 
plane to him and/or him to the plane is the least of my worries.   Again, 
thanks for your thoughtful reply.

Regards,

Tom


From: Ed Burkhead 
Sent: Sunday, August 15, 2010 10:42 AM
To: [email protected] 
Subject: Re: [ercoupe-tech] Re: Fuel System Problems


  
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


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