Building a new aircraft

[Tom-D]

One of my customers builds new supercubs PA-18. He starts with a old data tag, the AWC, registration, then buys a new fuselage, and all new certified parts from Univair. Then he assembles a new cub.

These pictures are typical of the quality of his work.

Here is the question.
How would you document this?
Is assembling with all new parts a repair?

 

[Tom-D]

Example of one of his cubs

 

[AKBill]

Nice pictures Tom. Your customer/friend does nice work. So my question is does he buy an old Cub and restore it? What original parts does he use if any? Does he only use the data tag?

 

[3393RP]

Very nice looking aircraft.

I wonder who will be along first to criticize your post as argumentative or repetitive.

 

[Cap'n Jack]

Very nice looking aircraft.

I wonder who will be along first to criticize your post as argumentative or repetitive.

Me! Me!

They do this sort of thing a lot with old planes. Glacier Girl started as a bunch of crushed metal and the plane was essentially manufactured from scratch when they got done.

 

[timwinters]

Does he only use the data tag?

That's what he said. And if that's the case then I just can't imagine this is legal and, if it is, it shouldn't be.

 

[Juliet Hotel]

What does the FSDO say?

 

[DFH65]

Why not just build a carbon cub kit or just build it as an experimental cub. The whole needing a data plate thing is stoopit. If you built it from certified parts what is the need for a data plate other than to appease the king.

 

[Checkout_my_Six]

Here is the question.
How would you document this?
Is assembling with all new parts a repair?

with a ball point pen....blue, please.

 

[kmacht]

Carbon cubs and experimental cubs are limited to no commercial use. They make sense if you are just going to use the plane for personal use but if you want to make it part of a flight school or fly passengers or cargo for hire you can't. A certified cub or super cub is usually going to have a higher resale value than an experimental version equipped the same way just due to the additional limitations.

 

[overdrive148]

What does the FSDO say?

Ring-ding-ding-ding dinga dinga ding!

 

[Bell206]

customers builds new supercubs PA-18

While I'm sure there is more info to this post...

I think you are doing a dis-service to your customer by stating on a public forum he builds new Super Cubs. I think stating he repairs them to like-new condition would be more appropriate as only a manufacturer can build new. However, if what you say is true >>>>>

then buys a new fuselage, and all new certified parts from Univair. Then he assembles a new cub.

...and, he uses none of the original primary structure from the aircraft for which the "old data tag" is associated to, then that falls under "Aircraft Built from Spare or Surplus Parts" which invalidates the original data plate, AWC, and Reg. He can still do this legally, but he must now create a new data plate with his name as the manufacturer vs Piper (and just like E/AB) and apply for a new AWC. And best he can hope for would be a Restricted AWC.

However, as long as he uses a portion of of the original aircraft primary structure he can stay within the gray area of Part 43 concerning repairs and use replacement parts as a methods of repair. But without that original data plate aircraft primary structure he would lose the Part 43 gray area and the ability to use the same data plate per Part 45. There is various FAA guidance on this to include the FARs, Orders, ACs, and LOIs if you care to look for it.

How would you document this?

At a minimum, one 337 describing the repair to an original aircraft primary structure.

As a side note, he does very good work and you may tell him to look a Dakota Cub for his parts. I found them to be top-notch craftsmanship and cheaper than Univair. I believe a complete DC wing kit costs a third less than Univair.

 

[SkyDog58]

Why not just build a carbon cub kit or just build it as an experimental cub. The whole needing a data plate thing is stoopit. If you built it from certified parts what is the need for a data plate other than to appease the king.

Even if you build it as an experimental, you will still need a data plate.

 

[DFH65]

Even if you build it as an experimental, you will still need a data plate.

Well yeah but not a data plate from a certified airplane.

 

[SkyDog58]

While I'm sure there is more info to this post...

I think you are doing a dis-service to your customer by stating on a public forum he builds new Super Cubs. I think stating he repairs them to like-new condition would be more appropriate as only a manufacturer can build new. However, if what you say is true >>>>>

...and, he uses none of the original primary structure from the aircraft for which the "old data tag" is associated to, then that falls under "Aircraft Built from Spare or Surplus Parts" which invalidates the original data plate, AWC, and Reg. He can still do this legally, but he must now create a new data plate with his name as the manufacturer vs Piper (and just like E/AB) and apply for a new AWC. And best he can hope for would be a Restricted AWC.

However, as long as he uses a portion of of the original aircraft primary structure he can stay within the gray area of Part 43 concerning repairs and use replacement parts as a methods of repair. But without that original data plate aircraft primary structure he would lose the Part 43 gray area and the ability to use the same data plate per Part 45. There is various FAA guidance on this to include the FARs, Orders, ACs, and LOIs if you care to look for it.

Correct. Good to see that some folks do understand the regs. 45.13 is very clear on removing and reinstalling data plates and under what conditions it can be done. Also Order 8100.19 does an excellent job of explaining the issues at hand. And I believe there is at least on Chief Counsel opinion on the matter. But I guess we can just ditch all of that and play the SGOTI game instead.

 

[SkyDog58]

Well yeah but not a data plate from a certified airplane.

well, duh!

 

[Tom-D]

However, as long as he uses a portion of of the original aircraft primary structure he can stay within the gray area of Part 43 concerning repairs and use replacement parts as a methods of repair. But without that original data plate aircraft primary structure he would lose the Part 43 gray area and the ability to use the same data plate per Part 45. There is various FAA guidance on this to include the FARs, Orders, ACs, and LOIs if you care to look for it.

Thanks for that,, That is what I must find out.
I've never done the paper on one of his cubs, He's always used CubCrafters for that. So I don't know if they issued a new certificate or signed them off as a rebuild.

 

[Tom-D]

As a side note, he does very good work and you may tell him to look a Dakota Cub for his parts. I found them to be top-notch craftsmanship and cheaper than Univair. I believe a complete DC wing kit costs a third less than Univair.

I am in doubt the Dakota Cub parts are not PMAed for use on a certified aircraft. and his aircraft are part 135 certifiable.
I did see the invoice for the wing kits from Univare, $21,000. I have not seen the new fuselage yet.
OBTW, these are not PA-18-180 from cub crafters , these are OEM Piper data tags.

 

[Checkout_my_Six]

Thanks for that,, That is what I must find out.
I've never done the paper on one of his cubs, He's always used CubCrafters for that. So I don't know if they issued a new certificate or signed them off as a rebuild.

do a little research on this....there's been hand slapping for this. You don't want to get caught in the middle of it.

 

[Tom-D]

do a little research on this....there's been hand slapping for this. You don't want to get caught in the middle of it.

Yeah, AMEN!
I've never done this much maintenance under the supervision prior to this.

 

[Tom-D]

Carbon cubs and experimental cubs are limited to no commercial use. They make sense if you are just going to use the plane for personal use but if you want to make it part of a flight school or fly passengers or cargo for hire you can't. A certified cub or super cub is usually going to have a higher resale value than an experimental version equipped the same way just due to the additional limitations.

RTFQ.. then answer it. Bell did.

 

[Checkout_my_Six]

Yeah, AMEN!
I've never done this much maintenance under the supervision prior to this.

Yup....we knew that.

 

[kgruber]

OTOH............it can be dangerous!

 

[Tom-D]

OTOH............it can be dangerous!

Roger is a pretty private person, Don't think he'd be pleased at having his picture posted.

 

[Ravioli]

Roger is a pretty private person, Don't think he'd be pleased at having his picture posted.

Ahem. looks like the same guy in Pic 2 of Post #2, posted by....

 

[Tom-D]

Nice pictures Tom. Your customer/friend does nice work. So my question is does he buy an old Cub and restore it? What original parts does he use if any? Does he only use the data tag?

Yes he does have the old paper work, N number, AWC, log books, Registered in his name.

 

[Tom-D]

Ahem. looks like the same guy in Pic 2 of Post #2, posted by....

You'd be hard put to ID him from that pic.

 

[Checkout_my_Six]

Roger is a pretty private person, Don't think he'd be pleased at having his picture posted.

ok...so we have a name and a face with this. Roger, that.

 

[Ravioli]

ok...so we have a name and a face with this. Roger, that.

And some tail numbers to bump up against the registry for owners named Rodger. 15 more minutes and we'll have his SSN. heehee

 

[Dana]

There's a long time honored tradition of restoring an old plane by jacking the data plate up, sliding a new plane underneath, and lowering it back down. Certainly the FAA knows it, but presumably they prefer seeing an aircraft with solid new parts rather than reusing questionable old parts.

But really how different is it from replacing parts one at a time? The T-Craft I used to own had had the wings replaced at one point with a set of "good used wings", the fuselage was replaced at another time with a new factory fuselage, the tailfeathers at another time. As far as I could figure from the incomplete logbooks, the only original parts were the engine, landing gear, and oh yes, the data plate.

 

[Tom-D]

And some tail numbers to bump up against the registry for owners named Rodger. 15 more minutes and we'll have his SSN. heehee

see where we go with this. ?

 

[Brad Smith]

If all the parts he's using are FAA/PMA approved (Univair), then I have no issue with his approach. I'd have no problem flying in his completed "Cub" as it's basically a new aircraft that looks, smells, flys and is as safe (probably safer!) than the original. His aircraft will have no unseen corrosion in the fuselage tubes or struts, no 70 year old wing spars and fabric guaranteed to last another 35 years if hangared.
His approach is actually better than buying an original than has been crashed and repaired many times and probably has had all its major structures repaired or replaced at one time or another. Building a Cub around a data plate is no different than replacing every part on an old Cub that has suffered a few incidents over the years one piece at a time. He's just compressing the time factor of 70 years into a single year.
As to the legality, it's one of those "don't ask, don't tell" situations. If he bought a wrecked Cub and was only able to save the data plate, this wouldn't even be an issue now, would it? We'd stand back and be amazed at what a fine job he's doing at "rebuilding" his crashed Cub and admire his skills as we walked by his hangar. His Cub "rebuilt" with FAA/PMA approved parts will pass any inspection the FAA would care to require of it and would be safe to fly, and isn't that what the FAA is all about?

Edited:
After reading the regs closely, the FAA makes the determination if the aircraft is destroyed, repairable etc. With the special blessing of the FAA (Glacier Girl?) even an aircraft defined as "destroyed " can be legally brought back to life and flown.
We do not know the entire story in this particular case and cannot say whether he is operating per FAA regulations. It's between him and the FAA. Now that the cat is out of the bag, I hope that he is operating with full knowledge and consent of the FAA.

 

[ktup-flyer]

Exactly what Kyle says he's going to do.

 

[Kenny Phillips]

Why not just build a carbon cub kit or just build it as an experimental cub. The whole needing a data plate thing is stoopit. If you built it from certified parts what is the need for a data plate other than to appease the king.

Because otherwise it must be registered as experimental. It's then likely not worth as much at resale, and can't be rented out.

 

[Tom-D]

If all the parts he's using are FAA/PMA approved (Univair), then I have no issue with his approach. I'd have no problem flying in his completed "Cub" as it's basically a new aircraft that looks, smells, flys and is as safe (probably safer!) than the original. His aircraft will have no unseen corrosion in the fuselage tubes or struts, no 70 year old wing spars and fabric guaranteed to last another 35 years if hangared.
His approach is actually better than buying an original than has been crashed and repaired many times and probably has had all its major structures repaired or replaced at one time or another. Building a Cub around a data plate is no different than replacing every part on an old Cub that has suffered a few incidents over the years one piece at a time. He's just compressing the time factor of 70 years into a single year.
As to the legality, it's one of those "don't ask, don't tell" situations. If he bought a wrecked Cub and was only able to save the data plate, this wouldn't even be an issue now, would it? We'd stand back and be amazed at what a fine job he's doing at "rebuilding" his crashed Cub and admire his skills as we walked by his hangar. His Cub "rebuilt" with FAA/PMA approved parts will pass any inspection the FAA would care to require of it and would be safe to fly, and isn't that what the FAA is all about?

Yeah ! that is why he gets 250K for them.

 

[Bell206]

I am in doubt the Dakota Cub parts are not PMAed for use on a certified aircraft.

D Cub parts come in several versions to include PMA'd. A PMAd LH 18 wing uncovered runs about $3K less than Univair.

Data plate reading (sections 6.4/6.5)
https://www.faa.gov/documentLibrary/media/Advisory_Circular/AC_45-2E.pdf

 

[Brad Smith]

AC45-2E (6.8.2) is the "gotcha" line. Actually pretty clear if one takes the time to read it.

 

[Bell206]

His Cub "rebuilt" with FAA/PMA approved parts will pass any inspection the FAA would care to require of it

If he used all Piper parts he probably could get away with it. However, since a lot of PMA parts in the Super Cub world (e.g., Univair/Dakota ribs, Airframe Alaska kits) are made different and in all cases have part numbers marked on them, a quick look would show the difference. But if they're all replaced... The old days of building under a data plate are gone thanks to a small group of profiteers. Unfortunately, it's impossible to separate the good guys, like this Cub, from the bad guys so the rules are finally being enforced.

 

[Stewartb]

Technically illegal. If has has a significant part of the original airplane he can do it. From a data tag? Not allowed. I know guys do it but the smart ones don't talk about it on the internet.

 

[Bell206]

There's a long time honored tradition of restoring an old plane by jacking the data plate up, sliding a new plane underneath, and lowering it back down.

"Was" is the key word here. After several OEMs went after data plate builders/swappers in the 80s, it has fallen out of favor and the Feds began enforcing the rules. At one time it was the only way to get certain aircraft like a Stearman. The only thing that has really changed is the FAA has finally defined what is a repairable aircraft and they require you to follow the rules that have always been there, i.e., you can't build an aircraft from only a data plate. Section 3 in Order 8100.19 further explains this. However, there are some CRSs that can push these types of repairs to the limit, but they operate under FAA approved processes which is a little different than this Cub.