Vintage Aircraft Replacement & Modification Article

[Steve Pierce]

I have gotten a few field approvals in the last few years but it takes due diligence and a good PMI (Primary Maintenance Inspector).

[Vagabondblues]

I should have considered the responses to my comment on the time it takes for Government to work. The EAA has been lobbying the FAA for years to streamline the process for replacement of obsolete parts on vintage aircraft. The FAA responded with VARMA. No comments about how long it took the FAA to respond....

VARMA is noting new, its not an Regulation or Order, its simply a way to increase the A&P community knowledge and confidence in substituting obsolete parts and materials in vintage aircraft using the Advisory Circulars.

The Advisory Circulars already exists, AC 23-27, 20-62 and 43-18. The problem is that the ACO (Engineers) don't speak Mechanic and Mechanics don't speak Engineer. ACO's and DAR'S work to strict procedures, Field Approvals, STC's, PMA approval, but there is no procedures for an A&P or Owner trying to use the AC to replace an obsolete part on a vintage aircraft.

VARMA is the ACO's official review of the rationale a A&P or Owner is intending to use to comply with the AC. A document (Permission or Denial letter) is then issued by the ACO to the A&P or Owner with the FAA findings. That is what I am waiting on. I don't mind waiting a long time if it works. With acceptance of my rationale, I can pass it on to other owners and mechanics to use in their projects.

Todd

[dgapilot]

I should have considered the responses to my comment on the time it takes for Government to work. The EAA has been lobbying the FAA for years to streamline the process for replacement of obsolete parts on vintage aircraft. The FAA responded with VARMA. No comments about how long it took the FAA to respond....

VARMA is noting new, its not an Regulation or Order, its simply a way to increase the A&P community knowledge and confidence in substituting obsolete parts and materials in vintage aircraft using the Advisory Circulars.

The Advisory Circulars already exists, AC 23-27, 20-62 and 43-18. The problem is that the ACO (Engineers) don't speak Mechanic and Mechanics don't speak Engineer. ACO's and DAR'S work to strict procedures, Field Approvals, STC's, PMA approval, but there is no procedures for an A&P or Owner trying to use the AC to replace an obsolete part on a vintage aircraft.

VARMA is the ACO's official review of the rationale a A&P or Owner is intending to use to comply with the AC. A document (Permission or Denial letter) is then issued by the ACO to the A&P or Owner with the FAA findings. That is what I am waiting on. I don't mind waiting a long time if it works. With acceptance of my rationale, I can pass it on to other owners and mechanics to use in their projects.

Todd

While FAA is talking VARMA and various ACs there is still a lot of unknowns. That said, AC43-18 doesn't even apply to an A&P, it only applies to 145 Repair Stations that have a quality System. A&Ps have been permitted to fabricate parts for as long as there have been airplanes! The guys that wrote AC43-18 have no idea about aviation maintenance other than air carrier stuff. Unfortunately so many A&Ps don't understand the certification process. AC43-201A covers how to process Field Approvals and the AFS-300 job aid provides guidance on what is able to be Field Approved. A field Approval is nothing more than a mini STC and needs to be regarded the same way. You need to define what the alteration is, identify what applicable regulations are being impacted and show how the alteration satisfies the intent of the regulation. I've done a lot of IA seminars on this very issue knowing that the A&Ps and IAs are short on this knowledge.