Parts & Material Substitutions on Vintage A/C

[Steve Pierce]

Looks like there is an awareness out there.

http://www.faa.gov/aircraft/draft_docs/ ... C23-27.pdf (http://www.faa.gov/aircraft/draft_docs/media/DraftAC23-27.pdf)

Approval: This material substitution on secondary structure is a minor repair or alteration and should be documented by logbook entry.

Looks like this would allow the substitution of aluminum stringers for wood.

[Larry Huntley]

I understand this draft is open for comments. We had best fill their inbox! Larry

[Steve Pierce]

Here is a link to submit a comment. http://www.faa.gov/aircraft/draft_docs/ ... oc_Type=AC (http://www.faa.gov/aircraft/draft_docs/display_docs/index.cfm?Doc_Type=AC) I think this Advisory Circular could be a step in the right direction.

[JohnW]

I, too feel this is a step in the right direction. This basically just reinforces what has been the way that business has SUPPOSED to be being done, right along. It speaks to the long practice (that was WRONG) of applying for Field Approval for any and all "changes" to an aircraft even when they were defined decades ago as being "MINOR" in nature. "When in doubt, fill one out." And...thereby putting the "responsibility" for the alteration on an FAA grunt (which NEVER happened anyway. They approve "data", they were never an "Engineering Department". That is ACO, and they are GOOD at what they do). The idea is that FAA has too many "BS Field Approval Requests", AS WELL AS the fact that many ASIs went overboard with their Field Approval authorization, approving "Major Alterations" that were in fact actually DESIGN CHANGES to a Type Design. This has been a no-no since before CAMs and CARs were written, but means of compliance WAS provided for such stuff. Two problems resulted...an unmanageable "workload" for Inspectors Authorized to buy back Field Approvals (too many, or none), and failure of certificated mechanics to make the initial decision as to whether a task was Major or Minor. The A&Ps and IAs that were in the best "standing" with FAA for decades have been the ones that recognized the difference between Major and Minor, yet still requested "guidance" when a task seemed to be in a "Gray Area". Its "our" job to decide what is Major or Minor, and it's FAA's job to decide whether we toe the line. "DON'T screw it up", or in other words "Be cautious and get an 'opinion from the Cops' if it might go either way". Just, DON'T be "wrong" intentionally or accidentally. THAT is how I see the "recent changes" to Field Approval procedures the last few years (as clarification, not new material), AND this "old ragbag" A.C. is talking about doing it how it was supposed to be done all along. Furthermore, Advisory Circulars "provide one means (but not the ONLY means) of compliance with Regulations" but are not "Regulatory" in themselves. Yeah, that's all good. What seems to be the problem with this?

One thing I fear seeing is a "list" of what we "CAN" or "CANNOT" do, specifically (and I hope there are people with that mentality "in charge" at FAA). Any such "list" would not only tell us how to reason (think), it would LIMIT US to what is on the list and to ONLY what is on the list. This would NOT be a good thing. Once you "dumb something down" so that even the least willing to think is able to understand it, you are WAY over-regulated. I don't want to see that. A Man needs to know not only his "limitations"... he needs to know his "responsibilities" as well and he shouldn't give away that responsibility for "no reason" because he is too lazy to think or unwilling to take a position. Asking "Mother, may I?" for every little thing (and getting Field Approvals for things honestly needing Engineering evaluation) is not where we want to be, and NOT where FAA was meant to be or is NOT where they seem to be taking this. Oh, they COULD!!! They are, after all, T.H.E. "Bureaucracy" and they can get Stupid Crap past the ignorant Politicians (all it has to do is put money in someone's pocket!), but all-in-all they have "played nice" pretty much (as far as the Big Picture is concerned) for an awfully long time. I would HATE to see that changed because someone wants to do "more" than what SHOULD be done (or LESS as the case may be).