Be sure engine accessories have PMA approval. FAA-PMA should

stamped on the part.

ONE OF THE MOST CONFUSING

aspects of restoring a certificated aircraft is letter combinations like TC, STC, and PMA. They start popping up when, for instance, you ask, "What are the rules pertaining to replacement parts I'll need for my airplane?" and "What was the original type of engine and propeller on the airplane when it was m a n u f a c tured?" and "Can I substitute another engine or propeller?" Using the prop and engine example, selecting something other than the original equipment may be a moot point because the airplane's type certificate (TC) dictates the engine and propeller combination the FAA has approved. Most lAs (airframe and powerplant mechanics with an FAA inspection authorization) will have copies of type certificates for different airplanes, and you can find them on the FAA website at

STCs, PMAs,

cate data sheets and specifications (TCDS) set forth essential factors and other conditions which are necessary for U.S. airworthiness certification." Aircraft, engines, and propellers that conform to a U.S. type certificate are eligible for a U.S. airworthiness certification when found to be in a condition for safe operation and when all ownership requirements have been met. TCDSs include the specifications, and generally they are compiled from details provided by the holder of the type certificate, but the FAA may request and incorporate additional details when conditions warrant. And the TC itself spells out the official certification specifications of an aircraft, engine, or propeller when the FAA first certificated the item. The TC gives its holder authority to manufacture the certificated item to the public. For an airplane,

and Other Confusing Letters

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MARCH 2002

Wading through the alphabet soup of aircraft restoration RON ALEXANDER www.airweb.faa.gov (select TCDS, for type certificate data sheet). Federal Aviation Regulations will govern any number of decisions you'll make regarding the manufacture or replacement of parts on an older production airplane, and you'll have to document all repairs and alterations. Let's look at some of the more common phrases and forms pertaining to production aircraft. Type Certificates

According to the FAA, "type certifi-

it lists the manufacturer and the airplane's specifications, and the TC holder must adhere to these specifications when manufacturing the airplane.

Any number of decisions you'll moke regarding the manufacture or replacement of parts l • on an older airplane will be governed by regulations. You'll also have to document repairs and alterations that are made. Restoring a certificated airplane usually means you're dealing with a TC issued years ago. No matter how old, those specifications remain in effect. For example, in the late 1920s the Stearman Aircraft Company manufactured its model C3-B, and I'm fortunate enough to own one currently undergoing restoration. A simple TC from a Stearman C3-B includes: T.C. NUMBER: ATC 55

MODELS: Stearman Aircraft C3B, 3 POLE STEARMAN AIRCRAFT COMPANY Engine: Wright J-5 220 hp

Fuel: 68 gallons Oil: 8 gallons No. passengers: 2 Baggage: 52 lbs. Maximum weight: 2,830 lbs. Certification basis: Approved Type Certificate No. 55 Serial numbers: 1 to 247 eligible. Approval expired 7/1/32. Required equipment: Inertia starter, adjustable metal propeller, cockpit, and engine covers Optional equipment: Landing Sport Aviation

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Aircraft Building and position lights equipment, 20 lbs.; flares, 43 lbs.; battery, 55 lbs., cockpit heaters, 10 lbs.; 78 gallon fuel capacity NOTE 1: All model C2-Bs eligible provided they conform to the above specifications. (The model designation was changed from C2-B to C3-B.) NOTE 2: Airworthiness certificate must include the following unless it has been satisfactorily demonstrated to an inspector of Civil Aeronautics that such notation is unnecessary: "INTENTIONAL ACROBATICS PROHIBITED." This is a simple TC, but notice that it specifies the engine type along with the airplane's data. Most TCs are more extensive, allowing for different engine and propeller combinations and other data. The Stearman C-3B Type Certificate allows only one type of engine— the Wright J-5. Notice, too, the reference to an ad-

justable metal propeller. The point is, when restoring an airplane you must refer to this data. If you plan to vary the engine, propeller, or make any structural modifications from the way the aircraft came from the factory, you'll need FAA approval.

use the Poly-Fiber covering system instead. As a manufacturer, Poly-Fiber Inc. applied for an STC to use its covering system on the Stearman C-3B. The FAA approved the STC and assigned a number—SA1008WE. To legally cover my C-3B with PolyFiber, I'll fill out FAA Form 337 (see deSTC—Supplemental type Certificate scription below) and note on it that The FAA defines a supplemental type STC SA1008WE was installed according certificate (STC) as, "Specifications to the written instructions. Because the used to record the approval of major C-3B is a certificated airplane, an A&P alterations performed on any of the must endorse this notation. Form 337 products for which they were issued." also gives the A&P an opportunity to In short, someone has received FAA elaborate on the covering process by approval for an alteration to a certifi- defining types of materials, number of cated airplane, and this person has coats, colors, and more. earned an STC as part of the FAA apIf an aircraft is not on the list of proval process so you can make the those eligible to use an STCed item, same alteration to your airplane (for a its owner can apply for an FAA field price, naturally) without repeating the approval by including a conformoriginal approval process. ity statement with the required For example, Stearman originally Form 337. Using the Poly-Fiber excovered its C-3 with Grade A cotton ample, the conformity statement fabric and nitrate dope, but I want to form is in the Poly-Fiber proce-

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dure manual. An IA would then approve the work and sign Form 337, which returns the airplane to service. One copy of the Form 337 stays with the airplane while the other goes to the local FAA office.

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PMA—Parts Manufacturer Approval

If you simply want to replace a part on an airplane that is no longer in production, you can do so if the new part has been manufactured in accordance with certain criteria. To earn FAA parts manufacturer approval the replacement part must be created using approved materials and manufacturing techniques. In short, a PMA replacement part has to be equal to or better than the original part. And it must have a clear paper trail that tells where the material for the part came from, who made the part, and who inspected it. If you are installing PMA parts, you should have no paperwork hassles because the parts have already been approved for installation on your airplane. FAR 21.303, Replacement and Modification Parts, further defines this process: (a) Except as provided in paragraph (b) of this section, no person may produce a modification or replacement part for sale for installation on a Type Certificated product unless it is produced pursuant to a Parts Manufacturer Approval issued under this Subpart. (b) This section does not apply to the following: (1) Parts produced under a type or production certificate. (2) Parts produced by an owner or operator for maintaining or altering his own product. (3) Parts produced under an FAA Technical Standard Order. (4) Standard parts (such as bolts and nuts) conforming to established industry or U.S. specifications. FAR Part 21 spells out the requirements for earning PMA, and

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Aircraft Building the process requires a serious investment of time and money. If you think you are buying a PMA part, check the paperwork thoroughly and the part—it must be stamped "FAA-PMA." Remember that the PMA approves the part only. In some instances you may need an STC to use the part on your aircraft. Several exceptions to FAR 21.303 are noteworthy, especially to an aircraft restorer. The parts produced by the original manufacturer are exempt if produced under the type certificate. Note that the airplane's owner or operator can manufacture a part, which is common when a needed replacement part is no longer produced and cannot be found. FAR 21.303 was intended to give owners and operators of older aircraft relief from having to meet

the strict FAA-approved type design requirements for a PMA. But—and there's always a but— every part an owner/operator or manufacturer builds to replace an unavailable part must meet the original type design. This FAR requires the part to be manufactured in one of three ways: 1) Using the manufacturer's PMA or the technical service order holder's type design data, 2) Obtain approval from a designated engineering representative (DER) for the part, or 3) The owner/operator must submit design data to the FAA for approval. The referenced type design data may be on file either with the FAA or the original manufacturer. As you can see, this process can be cumbersome and the regulations may be interpreted differently within FAA regional offices.

Antique or classic aircraft restorers should use good judgment and not abuse this regulation. It was not created to allow an individual to circumvent the rules using a PMA or other approved part during the restoration process. Field Approval

If your restoration project requires a repair or alteration that doesn't fall into one of the FAA-approved methods of doing the work, it will require a field approval, which the FAA defines as "an approval by an authorized airworthiness safety inspector (ASI) of a major repair or alteration that is accomplished by one or more of the following, as appropriate: 1. Examination of data applicable to one aircraft only. 2. Physical inspection, demonstration, testing, etc. of one aircraft only. 3. Examination of data only

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FM Form 337

FAA Form 337 documents major repairs or alterations to aircraft, and the aircraft's return to service, and records these things in the aircraft owner's and FAA's files. The form's official title is, "Major Repair and Alteration," with a subhead that reads, "Airframe, Powerplant, Propeller, or Appliance." That just about covers everything on the airplane. You should review previous 337s on your airplane and ensure that new ones generated during the restoration process are completed correctly and consistently. These documents are part of your airplane's maintenance history and are part of the aircraft's permanent logs. Now you are better prepared to understand these FAA terms, definitions, and forms and are ready to start — or finish — your restoration project. By understanding these terms and how and when they apply, you'll be in a position to produce a better restoration accompanied by the correct FAA paperwork. Further questions should be addressed to EAA's Aviation Information Services department at 888-322-4636, Ext. 4821, or [email protected]. Sport Aviation

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