Is the data plate the aircraft?

Pi1otguy

Pi1otguy

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What part of an aircraft is the aircraft for registration and regulatory purposes? Is it simply the data plate?

If so, does this mean one could theoretically do an extreme Ship of Theseus in aviation?

Hypothetically, let's say Bob lands an old 210 a bit hard, he's uninjured but it burst into flames, and burns to ashes except the piece with the data plate. Could you buy that piece, go into your well equipped garage full of machining tools sheet metal, etc, look up the specs for that make & model, rebuild the plane? Would you then be able to renew the registration as the same plane?

And why is aviation so full of things you can do but probably shouldn't?
 
You'll need the airworthiness certificate, too.

There is a long history of people jacking up the data plate, rolling the rest of the aircraft out from under it, and lowering it onto a new airframe. Sometimes a piece or two of the old plane, like a longeron or tachometer, will be reused.
 
iu
 
Not saying it's legal, just that it happens, especially in the case of a valuable antique.

OTOH, the T-Craft I used to own had at various times a new factory fuselage, wings replaced with a set of "good used wings", tailfeathers, etc. As near as I could figure it the only original parts were the instrument panel, cowling grilles and some of the chrome trim, and one landing gear. All legal and duly logged.
 
Pi1otguy said:
Could you buy that piece, go into your well equipped garage full of machining tools sheet metal, etc, look up the specs for that make & model, rebuild repair the plane?
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FTFY. At one time, yes. However, in the past 5 years things changed to maybe but doubtful.
Pi1otguy said:
Would you then be able to renew the registration as the same plane?
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Maybe.
Pi1otguy said:
And why is aviation so full of things you can do but probably shouldn't ?
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Not really. You just need to know what you're doing before you start.
Dana said:
Not saying it's legal, just that it happens, especially in the case of a valuable antique.
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Perfectly legal provided the proper methods and procedures are followed. Unfortunately the acts of a number of idiots over the years have made this part of aircraft repair and restoration more limited.
 
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Dana said:
Not saying it's legal, just that it happens, especially in the case of a valuable antique.

OTOH, the T-Craft I used to own had at various times a new factory fuselage, wings replaced with a set of "good used wings", tailfeathers, etc. As near as I could figure it the only original parts were the instrument panel, cowling grilles and some of the chrome trim, and one landing gear. All legal and duly logged.
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Kind of reminds me of Abe Lincoln’s axe that he cut down the proverbial cherry tree with. Over the subsequent years, the handle had been replaced three times and the head twice.
 
An FAA Safety Inspector that I once knew owned a CE 180 and it was hit by another airplane when parked. The worst damage was caused by the prop and it ate up the fuselage beyond repair. Most of the rest was untouched. He knew that I went to many various airports in the region and asked me to be on the lookout for a 180 fuselage. I never found one, but he did and rebuilt his plane. Over time.
A freelance A&P once opened his desk draw and showed me a stack of data plates for Bell 47's. Someone once told me that there were more BH47s on the registry than Bell ever built. It was real easy and profitable to buy a data plate and find the parts to
build one.
 
I thought I had read recently that the FAA was looking to tighten up this loophole. I know it was a big discussion among the warbird community, as so many of the currently flying warbirds started as not much more than a trashed airframe with a reasonably straight data plate.
 
History suggests it is far more lucrative to "secure" investment dollars with the "airplane" a-la Tarron Bhomas.

Until you get caught of course. Pilots are some spiteful mofos if you push them far enough. :D
 
It also seems that its easy to make a data plate.
 
Let'sgoflying! said:
Possibly applicable? see (e)


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.
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When you read a reg with an embedded reference, you have to review the reference too, since that is part of the meaning of the reg.

In this case, para (d)(2) says:
(d) Persons performing work under the provisions of Part 43 of this chapter may, in accordance with methods, techniques, and practices acceptable to the FAA—
...
(2) Remove an identification plate required by § 45.11 when necessary during maintenance operations.
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Also relevant is para (c):
Except as provided in paragraph (d)(2) of this section, no person may remove or install any identification plate required by § 45.11, without the approval of the FAA.
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So, you can remove aircraft data plates for maintenance and reinstall in the same aircraft without FAA approval. Removal for any other reason, or installation in another aircraft, requires FAA approval.
 
Greg Bockelman said:
Kind of reminds me of Abe Lincoln’s axe that he cut down the proverbial cherry tree with. Over the subsequent years, the handle had been replaced three times and the head twice.
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It was G Washington that supposedly did that. Abe was the rail splitting guy. But ... nice point made there. One of those Science You Tube Channels mentioned that our cells dies and are replaced. About every 7 years there is a complete replacement. So... Am I who I think I was??
 
midwestpa24 said:
I thought I had read recently that the FAA was looking to tighten up this loophole.
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They issued an Order in 2018 that consolidated all the guidance on defining the difference between repairable vs destroyed aircraft. While it does push the narrative in one direction it still provides paths to repairing extensively damaged aircraft. It also does not remove the ability to "assemble" an aircraft from salvage or surplus parts which a number of warbirds fall under, however, there have been other limitations been put on these type aircraft by other guidance.
 
Ed Haywood said:
So, you can remove aircraft data plates for maintenance and reinstall in the same aircraft without FAA approval. Removal for any other reason, or installation in another aircraft, requires FAA approval
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But isn't it the "same" aircraft? Just so happens 95% of the aircraft was exceeded tolerance and required major repairs.

Something similar to a common practice in CA of tearing down all but 1 wall and remodeling the house to reduce the tax assessment.
 
When I was first shopping for a 182, 20 years ago, one of the ones I saw advertised was apparently a data plate rebuild. The same S/N, but different N-number had been rolled up in a ball on the side of a mountain several years prior (even found a pic of the accident scene). From what I saw, I'm really not sure how much was salvageable beyond the data plate...
 
WDD said:
One of those Science You Tube Channels mentioned that our cells dies and are replaced. About every 7 years there is a complete replacement. So... Am I who I think I was??
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Let's ask 23andme for a copy of your data plate.
 
Replaced fuselage, wings, and engine. See 337 on file. Ops check good.
 
Pi1otguy said:
But isn't it the "same" aircraft? Just so happens 95% of the aircraft was exceeded tolerance and required major repairs.
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Provided the remaining 5% is considered primary structure you're good to go. Been that way for eons. Unfortunately, the number of less honorable people in aviation has increased so now you're stuck having to live with the results of their BS. Is what it is.
 
I believe the FAA would disagree with plate swapping where the majority of the original aircraft was changed out, (not even as much as in the OPs hypothetical).
In this example, such an aircraft’s CofA was revoked after much work & expense to repair it.
Other accounts refer to the occurrence as fraudulent, which brings to mind the possibility of an airman’s certificate action.
Think about the practicality here, as well. Couldn’t a buyer potentially get a pile of parts which were sold as 2500hrs TIS, when many were actually 20,000 hrs? Some aviation parts also have life-limits, also a consideration.
The article quotes where the FAA used 14 C.F.R. § 45.13(e) in their arguments, which I linked earlier.

The Data Plate Dance | DOM Magazine

dommagazine.com dommagazine.com
 
Maxnr said:
An FAA Safety Inspector that I once knew owned a CE 180 and it was hit by another airplane when parked. The worst damage was caused by the prop and it ate up the fuselage beyond repair. Most of the rest was untouched. He knew that I went to many various airports in the region and asked me to be on the lookout for a 180 fuselage. I never found one, but he did and rebuilt his plane. Over time.
A freelance A&P once opened his desk draw and showed me a stack of data plates for Bell 47's. Someone once told me that there were more BH47s on the registry than Bell ever built. It was real easy and profitable to buy a data plate and find the parts to
build one.
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If a data plate was used from a bh47 that was originally built by bell, how could that account for more than they built? The math don’t math.
 
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Let'sgoflying! said:
I believe the FAA would disagree with plate swapping
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Data plate swapping has been illegal since the CAA days. However, had TRE, the company in your posted example, pursued approval to move the plate to another fuselage or kept and repaired a portion of the original fuselage it would have been a different story.

For example, there are a number of STCs that allow for the legal replacement of a complete airframe which includes the approval to move the data plate from the original airframe to the replacement 3rd party airframe. Same with engines where the OEM provides approval to move the original data plate to new, replacement crankcases.
Let'sgoflying! said:
Couldn’t a buyer potentially get a pile of parts which were sold as 2500hrs TIS, when many were actually 20,000 hrs?
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Yes. And that is/was part of the problem, or worse, as some people did this on purpose for solely profit regardless of the consequences. It was these people that led to the OEMs getting more involved in the disposition of their older aircraft, insurance companies becoming more involved on their side after excessive hull damage, and the FAA to issue their Order on destroyed or scrapped aircraft.

The end result, all the above severely restricted a legit, but often unknown, side of the business where extensively damaged aircraft were repaired to like-new condition. There are a couple of excellent examples of this on PoA. And if properly set up this work could be very lucrative hence the rise of the illegal side. But where it is having its biggest impact is in the legitimate support side of the current flying legacy aircraft, i.e., the private recreational side.
 
I built a brand new PA-12 about 15 years ago. The only used parts were a spar and a couple of wing ribs and those didn't come from the original -12. I swapped the data plate to the new PMA airframe. Perfectly legal. Then I sold the pre-rebuild logbooks for $4K. Why anyone would pay that for them is a mystery to me. During that build I bought a PA-18 wreck to get some parts. I sold that plane's data tag, logs, and a chunk of the original airframe for $4K. It was resurrected as a newly rebuilt PA-18 and was used in a guide operation until it was wrecked again. Legal? Probably not perfectly so, but it does get done and those planes get signed into service by ethical IAs.

Building airplanes from spares used to be a thing. Cubcrafters poaching on the Piper PA-18 TCDS stirred that pot and got the regs tightened up. They were building new airplanes and making new data tags calling them PA-18s, so Piper got the liability. The FAA changed the regs and forced Cubcrafters to get their own TCDS under Part 23, and that's no easy feat.
 
Checkout_my_Six said:
Is data singular.....or plural? :cool:
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OMG, I don't care what anybody else says, data is singular. Making data plural is like making car plural because there might be more than one person in it.
 
Salty said:
OMG, I don't care what anybody else says, data is singular.
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LOL And I see I screwed it up myself.

silently fixed to remove the evidence
 
I knew a guy who would say ......dataR. Not sure what he meant by that. :oops:
 
Salty said:
I repeat. I don't care what anybody else says.
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So you're inventing your own rules of English?

I'd rather use the correct term. I have no wish to sound uneducated.
 
Dan Thomas said:
So you're inventing your own rules of English?

I'd rather use the correct term. I have no wish to sound uneducated.
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Data is a collection of information. A collection is singular.
 
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