where is the line in the sand ?

[ghostflyer]

a number of us cringe when we talk about swapping data plates on air craft . I know of a 170a, [in the USA] that had a ground loop and the whole main cabin has been distorted . A donor aircraft was used and that cabin was attached just behind the line where the cargo door is. A jig was used and the job was first class. as the jig was being removed it was noted that the tail wheel hung down too much . It was one of those things that were missed . The interior bulkhead was cracked and wrinkled . the outside skin was only slightly wrinkled or better slightly distorted . [it was very hard to see] That bulkhead was not available any where NOS. A wrecking yard in Texas had a 170b tail end for sale . This was graffered on to a 170a.
Job done . It looked strange ,forward cabin cream,center section white and tail area dark green. Data plate removed from twisted center section and attached to new donor center section. My question at that time is “ where is the part that has to be there as part of the original aircraft . Cessna engineering wouldn’t answer the question.
PS. The original wings and tail feathers were reused in the rebuild and engine and frame was also reused. the insurance company paid the bill.

[voorheesh]

https://www.faa.gov/documentLibrary/med ... 100.19.pdf

https://www.ecfr.gov/current/title-14/c ... tion-45.13

These may help.

[brian.olson]

https://en.wikipedia.org/wiki/Ship_of_Theseus

[Bruce Fenstermacher]

Reality is the absolute minimum line is the data tag. All else can be repaired or replaced. Dig as hard as you want and you won't find a FAR that will stop this.

Reality is this is a lot harder to do with construction like a 170 and not nearly as hard with tube and fabric construction. I know of no one making PMA 170 fuselages so salvage is the likely source but every part to build a Cub is readily available with a PMA.

A new data tag is extremely hard to get. Nearly impossible in the most honest of situations of a data tag gone missing. Originals are out there if you are looking. Original plates with logs being the most valuable. I've seen or more likely heard of them for sale. Not usually listed in Trade-A-Plane.

I've seen first hand, situations I wish a data tag could talk so we could find out how it really got there.

[falco]

So if the serial number follows the paperwork rather than some specific part of an airframe, does there need to be a line in the sand?

As long as the records are complete, the data tag on an airplane is the thing that tells you which records are attached to that airplane.

As long as the records are kept, honestly and completely, a serial number attached to a unique 'set of records' rather than the serial number being attached to a particular set of parts still has real value.

The documents tell you what you have (if complete and honest) You have what began in Wichita as 1954 C170B SN XYZ. It's well enough documented what that was. If the maintenance and repair and additions and removals are kept up, the documentation of what you have should still be current and tell the complete history of that airplane.

OK, so you had to replace the tail end of the fuselage. That can be done correctly with parts from a different airplane. So you do that, log it and move the data tag with the serial number over. You could replace a wing which has no data tag. Is that different? Why would the data tag matter? The records still match the airplane, which is the point. The records for C170B SN XYZ match the airframe with that data tag. Your record for that airplane still tells you what is attached to the data tag.

If you are having trouble with this, you kind of have to twist your mind into the thinking of a bureaucrat rather than an engineer, which I find painful.

Cheers,
Pete

[c170b53]

Its a fun game, guessing how many planes are in a picture of a plane for sale. My best is 4 , from a pic taken from twenty feet away. Plane sold to new owner and seems to be ok.

[voorheesh]

In the scenario posed by the OP, the removal and reinstallation of that airplane’s data plate appears proper and allowable by 45.13 because it occurred during a repair to the original airframe I/A/W Part 43. (See 45.13 d) Something like this should be noted in the maintenance records and the 337. Whomever was responsible for the repair might be smart in consulting his PMI about removal and replacement of the plate to hear a second opinion, but it seems straight forward to me. It might also be a good idea to check with Cessna concerning compatibility of a Cessna 170B fuselage sections with a 170A fuselage. It sounds like they are compatible, but how do you provide “approved data” if fuselages (or sections thereof) lack PMA numbers? (Maybe they are identical?)

[n2582d]

https://www.faa.gov/documentLibrary/media/Order/FAA_Order_8100.19.pdf

https://www.ecfr.gov/current/title-14/c ... tion-45.13

These may help.

Harlow,
That first link was very helpful. I think the following section from that link is germane to this discussion:

3. Repairable versus Destroyed Aircraft.
a. An aircraft that was rendered unserviceable through in-service wear and tear, damage, or corrosion may be approved for return to service after completion of a repair. A repair is performed to return the aircraft to its original (or properly altered) condition that conforms to its type design.
b. For an aircraft to be considered eligible for repair, it must have at least one primary structure around which a repair can be performed; otherwise, the action would constitute a replacement of the aircraft. The FAA considers an aircraft’s primary structure to be the structure that carries flight, ground, or pressurization loads, and whose failure would reduce the structural integrity of the aircraft.
c. The FAA does not consider an aircraft to be repairable if all primary structures of the aircraft must be replaced. Replacement of some major components of an aircraft would be considered a repair, but replacement of all of the primary structures of the aircraft is not a repair but a replacement of an aircraft. If the identification plate from the original aircraft were placed on the aircraft this action would be prohibited by 14 CFR § 45.13(e) which states that “No person may install an identification plate removed in accordance with paragraph (d)(2) of this section on any aircraft, aircraft engine, propeller, propeller blade, or propeller hub other than the one from which it was removed.”
d. The primary structure must be identifiable and traceable to the particular aircraft. For example, maintenance personnel can repaiir a heavily damaged aircraft by performing many major repairs on its fuselage and replacing all other primary structures that may be destroyed such as the wings and the empennage. In this case, the aircraft would not be considered destroyed because the fuselage is repairable. However, if the fuselage of that aircraft also needed to be replaced, then the aircraft would no longer be considered repairable as all of its primary structures were beyond repair and hence destroyed.
e. The following examples can be used as guidelines to determine if an aircraft is destroyed:
(1) All primary structures of an airplane or glider, including the fuselage, all wings, and empennage are beyond repair.
(2) The fuselage and tail boom of a rotorcraft are beyond repair.
(3) Only the aircraft identification plate is reusable.

So, clearly a data plate transfer is not a repair.

[voorheesh]

Thanks for highlighting. Then, Ghostflyer’s example would not be considered a repair because the damaged center fuselage section (primary structure) containing the data plate needed replacement? I guess these “repairs” do happen with some frequency out of financial necessity, or in some cases ingenuity. I doubt the FAA has the resources to enforce these regulations with any regularity, unless they happen to stumble on one. Thankfully, we don’t hear of them failing too often.

[falco]

Thanks for highlighting. Then, Ghostflyer’s example would not be considered a repair because the damaged center fuselage section (primary structure) containing the data plate needed replacement? I guess these “repairs” do happen with some frequency out of financial necessity, or in some cases ingenuity. I doubt the FAA has the resources to enforce these regulations with any regularity, unless they happen to stumble on one. Thankfully, we don’t hear of them failing too often.

I disagree. This is a repair because some, NOT all, of the primary structure was replaced. Wings and more were not "beyond repair" and retained from the original aircraft, thus the aircraft has not been "destroyed"

from above:

e. The following examples can be used as guidelines to determine if an aircraft is destroyed:
(1) All primary structures of an airplane or glider, including the fuselage, all wings, and empennage are beyond repair. (emphasis added)
(2) The fuselage and tail boom of a rotorcraft are beyond repair.
(3) Only the aircraft identification plate is reusable.

[ghostflyer]

i have removed my post on the request of one of my British friends . Why?? I didn’t use any names or places . he felt it was not appropriate to air our dirty laundry.

[voorheesh]

Years ago I dealt with British Aerospace on a regular basis and we had an issue with a Jetstream that landed at the wrong airport in Pasco, WA resulting in the right main landing gear and right engine being torn off. No data plate problems, but what to do? British Aerospace was technically the aircraft owner but our regional airline had it along with 100 others on a long term lease. The Brits wanted to load it on a truck and take it back to Mena, AR for repairs, but we got ahold of Renown Aviation in Santa Maria and had the engine and gear back on via boilerplate in less than 5 days. FAA approved a gear down ferry flight to Santa Maria and that airplane came back better than new in less than 2 months. But BAE engineering and ultimately their powers that be were furious with us (me in particular) and wouldn’t let it go. They wanted heads to roll for “endangering” their airplane. Their head honcho got in a screaming argument with our head honcho on some dinner cruise months later and the two actually had to be separated in a minor brawl over an issue already resolved. The British are extremely cautious and careful and really like to be in charge. Good airplanes though, that Jetstream survived a wreck that would have destroyed many other airplanes of similar capacity.

[GAHorn]

In my view…. Reference a Cessna 170…..replacing the aft fuselage/empennage is a “repair”. Replacing the cabin section … where Cessna riveted that dataplate during original mfr….. means the cabin section should keep it’s original dataplate and identity… I.E. it received new fuselge, empennage, wings, and gear, etc. Pulling the dataplate off that cabin structure and riveting the dataplate from the damaged cabin section onto the replacement cabin …was an illegal activity.

I suspect that illegal activity was done because the “donor” cabin didn’t have complete records or had an ownership issue (perhaps an old unresolved Lien on it, etc.)….and the owner of the damaged airplane wanted to keep the identity of his airplane that now has a “donated” cabin. If so, THAT is EVIDENCE a fraudulent action has occurred.

This also can explain why I once had the opportunity to own an Ercoupe which was complete…except it’s dataplate was not installed in its’ baggage compartment bulkhead (like all Ercoupes)… but instead had a “loose” dataplate in the glove-box. I suspected the dataplate did NOT originate with that airframe. I declined to own it (despite its’ very attractive purchase price.)

On a completely different airplane, an HS-125 which was from Sacramento and passing thru Austin on its way to a new owner in Ireland…. (I was hired to deliver it to Dublin)… The export C of A inspector noticed there was no dataplate on the cockpit vestibule (where British Aerospace nee’ Hawker-Siddeley always riveted them). The “aeroplane” had undergone a recent new interior refurbishment and when they installed new wood panelling where that dataplate normally lived… it had apparently been removed and lost. I contacted the interior shop and they’d scrapped all the old removed interior inlcuding that dataplate.
The company (BAe) field-rep was a very nice man (former Royal Marine who had been engineer on Mosquitos after WW2, named Maurice Helmore) who looked at me and said he could not approve the export of the aeroplane until that dataplate problem was resolved.

I went to a local jeweler and had them create a stainless steel dataplate about 3” X 4” and engrave upon it HS-125-400A, the serial, and the mfr’rs name “Hawker-Siddeley Aviation LTD.” ….and VOILA! …. we riveted it onto the vestbule bulkhead and I ferried that aeroplane to Dublin via Cleveland, Gander and the NAT….where the new owner looked it over, and then had me take it over to Bournemouth England for a new interior to HIS liking.

The British promptly cancelled that aeroplanes’ airworthiness….not for the dataplate….but for the fact it had a Solar APU installed under a U.S. STC… which the British did not like. BAe only approved of AirResearch APUs. The new owner had to shell-out another 100-Grand to convert the APU installation.

In THAT case, the mfr’s representative met the rule by authorizing a new dataplate which did NOT change the airframes’ identity….it merely met all the U.S. rules for export. (As long as it was on a U.S. registry that STC’d APU was “legal”….but when it changed registration to its’ new home in Ireland…it had to meet U.K. airworthiness which only approved the other APU.)

[voorheesh]

I need to add a thought to my “Brit” story that may have a bearing on the larger issues of this discussion. Yes, I made a decision over 30 years ago that fortunately had a good outcome. I had no expertise in temporary repairs or responsibility for the engineering, but our director of maintenance was like a brother to me and between us we made it work. We both completely believed we were doing the right thing. He made the airplane sound and I was able to work with one of our Jetstream check airmen to plan and complete a safe flight. I was a VP Ops at time and had responsibility for both our operations and the technical aspects of our aircraft lease. We got the FAA involved. But what I’m not proud of was that we did this behind British Aerospace’s back, thus betraying an important trust that I later came to learn is, or should be at the foundation of our aviation endeavors. I learned it’s all too easy to read a safety regulation or a lease in a way that favors your own point of view and then become the proverbial Bull in the China shop. My boss got over his beef with their VP and the airplane resumed flying (I now recall it took more than 5 days to prepare it for ferry and the repair was probably more like 6 months). But I had a better choice and didn’t see it at the time. Since then, I’ve learned and this has helped overcome the regrets.

[ghostflyer]

Well it’s good to know “Voorheesh” that i am not the only one that’s issue with the British including BAE. Our Premier [similar to your governor] wanted a Jet to cruise around in.
So in a dodgy deal he [the state did] purchased a Hs125 and 3 Jetstreams 31 . But our company had to have the Jetstreams to operate on a internal state RPT. No consultation by the state government or BAE as to suitability . They were a TOTAL disaster . The jetstreams had to land 50% of the time on rough gravel strips . Wheel assemblies , undercarriage legs ,props were being changed on a very regular basis . Then BAE imposed very restrictive load limits and major disassembly and inspections every 100hrs. We had a report of massive brake shuddering on the LH gear on landing . the whole aircraft shook. The whole LH leg and wheel assembly including brake pak was changed . so i decided to test it in a operational sense . So 2 am I was going to do a high speed rejected take off roll. Initial testing was good up to 30 knots . Then i tried to brake very heavy at 80 knots . The right hand brake system failed completely [both systems] and massive vibration was now occurring on the Rh leg . I am now in a ground loop heading for the weeds . Full reverse was selected . It was found the anti-skid was part of the problem. I was really scared that night.

PS. our premier has now recently purchased 5 Beechcraft King airs 350 and a Gulfstream G650 to fly around our state .