Thursday, September 19, 2019

Report on MOSAIC - it will affect you, What is it?


This is the first of perhaps several blog posts on the MOSAIC topic.  This topic should be of great interest to followers of this blog as it stands to impact a large portion of the GA flying fleet.  Certified Aeronautical Products, LLC, being in the business of FAA Approved Aircraft Systems and Performance Upgrades, is experienced in the current issues that MOSAIC intends to address, particularly for “Legacy Aircraft”.  We intend to follow this issue and provide input whenever and however possible as this topic develops.





Recently, there has been an increase in news reports on an FAA and general aviation (GA) industry initiative called Modernization of Standard Airworthiness Certificates (MOSAIC).  I have been hearing about this for a couple of years, however this topic became of greater interest to me last month when the Experimental Aircraft Association (EAA) released an announcement made by acting FAA Administrator, Dan Elwell at the 2019 EAA Air Venture convention at Oshkosh, Wisconsin.  I have begun learning more on this topic over the past month. One thing I have found is that there is not much public awareness on this topic.  So, I was delighted to hear that there was going to be a presentation on MOSAIC this year at the 2019 GA Engine Summit that I have attended annually for the past three years. 



About the GA Engine Summit – This is an invitational forum hosted by the FAA Boston Aircraft Certification Office.  Many in this office are assigned as “standards” staff to work on certification standards for aircraft engines and propellers.  The intent of the meeting is for industry representatives to interact with FAA personnel (from various segments of the agency) and discuss issues pertinent to GA aircraft, engines, and propellers.  Attendees of this meeting include representatives from various FAA certification offices around the country, from reciprocating engine manufacturers (OEMs) and parts manufacturers (PMA holders), propeller manufacturers, aircraft modifiers (STC holders), industry organizations (AOPA, EAA, AAA, and ARSA), FAA designees (ODA, DER, DAR), and other aircraft engine and propeller industry experts.  The 2019 summit was the fourth annual gathering for this event.



This initial posting on the MOSAIC topic is strictly my own record of the GA Engine Summit presentation as I remember and interpreted it.  My intent is to provide accuracy in this report to help educate our blog audience. I hope to generate interest and input from others on this topic.   If I mis-interpreted any important points or have recorded anything in error, I stand open for correction by others who were in attendance or who are more knowledgeable on this subject.  If you intend to comment, please advise the readers whether your comments are your opinion or factual.  If facts are presented, please cite your references.  I’ll do the same.  For this first posting, I’ll try to keep my opinions out and focus on documenting the presentation.  I’ll save my own personal opinions and proposals for separate postings.  The primary focus of this report is on the "Legacy Aircraft" aspects, for which I and the readers of this blog are most interested. 


MOSAIC: Improving Amateur-Built, LSA, and Legacy Aircraft
presented at the 2019 GA Engine Summit at FAA ACO – Burlington, MA
by Doug MacNair, EAA Vice President of Government Relations.

The MOSAIC topic was presented to a small but diverse audience of about 30 or 40 attendees at the GA Engine Summit on September 18, 2019.  Doug MacNair from EAA did a good job of explaining the MOSAIC concepts and laying out what the EAA is proposing.  But at the same time, he admits that nobody (neither FAA nor industry) knows what the final result will look like. Doug reported that this is a real and active program currently underway at FAA "headquarters", the standards/rulemaking staff in Washington DC, with over 50 staffers working on it.  The presentation was quite interesting to say the least, but it is very complex.  There is a lot more to it than has been made public so far.  To summarize, MOSAIC a long way from having a clear definition. 

In general, the MOSAIC concept covers major reform in three areas. 
  1. Easing the Experimental Amateur Built (E-AB) 51% rule to grow the "kit" industry
  2. Expanding the limits of Light Sport Aircraft (LSA) to enable more pilots to fly more airplane types
  3. Addressing certain problems with "legacy aircraft" - EAA is proposing a solution as something similar to a new owner maintenance category. 
The main point of justification by EAA for its proposal is that there is statistical evidence showing that "experimental" aircraft safety has improved on par with the safety record of aviation as a whole.  No real tangible numbers were presented on this. However, both Doug and Sean Elliott (also from EAA) described how all of the subject airplanes fall into a low or the lowest tier on the "safety continuum" (more on this below).  Doug noted that the majority of these aircraft are operated for personal and recreational use

The following are some of the points I noted as related to “legacy aircraft”.
  • How MOSAIC came about and why it is going to really happen - David Oord (AOPA) gave a brief explanation.  Congress has mandated regulatory changes to deal primarily with UAS (drones), electric powered aircraft, and other emerging technologies by a certain date (I missed the exact date but it is due in 2023 I think).  Recognizing that the mandated changes will affect Part 21 and are going to happen, both the FAA and Industry see this as a rare opportunity to get some changes into Part 21 that they've wanted for a long time.  An earlier presentation at this conference emphasized that the FAA is getting hammered with these types of new and novel projects at a pace so rapid that they cannot keep up.  The existing regulations don't adequately cover certification standards for them. FAA and industry resources are being consumed with efforts to come up with appropriate standards through arduous processes for proposing rules on a case by case basis.  The Part 21 changes are intended to settle and curtail most of this.  The bottom line is GA industry and FAA want to seize this opportunity to also address certain known GA issues.  MOSAIC is one of the main efforts for this. 

  • The concept of "modernization" of standard airworthiness certificates has to do with trying to streamline and reduce costs for equipping legacy airplanes with "safety enhancing" equipment.  Doug cited mostly avionics equipment like TCAS, ADS-B, auto-pilot, LED lighting, etc. as some examples of "safety enhancing” items.  It was explained that the certification standards that apply to "legacy airplanes" stand in the way of these safety enhancing technologies because it drives up the cost.  

  • There is no current definition of "legacy airplanes".  However, the slide Doug showed proposed that the EAA considers them as "aircraft over a certain age, 30 years or more". He outlined that these airplanes are used almost exclusively for personal and recreational use.   They are lumping a majority of Type Certificated airplanes into this one category.  To me, having a prior notion of legacy airplanes being much older than 30 years, I went away with a different picture than the one I expected.  As I listened and learned more about the problems being identified, I developed some more of my own personal opinions that I will talk about in a later blog post. 

  • Size of the Legacy Aircraft Fleet: One question I asked was "How many of the current flying fleet includes these legacy aircraft".  No hard number was quoted, but the room consensus was that it is a majority of the 150,000 flying GA airplanes.  

  • As mentioned EAA's justification comes from a broad look at what has been dubbed "the safety continuum".  There have been numerous committees among industry, FAA, NTSB, and others talking about this for the past several years.  It is what they call a refined approach to dealing with safety where accident rates are studied and the outcome is a grouping of aircraft in terms of the many factors that affect safety. It is a risk-based approach to studying aircraft safety.  It is a complex attempt to consider everything that affects safety (examples: number of passengers, weight, stall speeds, amount of fuel carried, age, complexity of systems, how they are operated, number of engines, type of construction, etc.).  The point of the EAA proposal is that the airplanes on the lower end of the safety continuum do not require as stringent regulation as those on the higher end.  It was discussed that the FAA has already begun to address some of this by the amendments recently made to 14 CFR Part 23 airworthiness standards for small airplanes.  The rule changes at amendment 54 have broken down small airplanes into 4 different classifications.  The standards for new small airplanes that str low speed, lighter weight airplanes, fewer passengers, etc. are relaxed more than those for higher-risk airplanes.  

  • The EAA’s justification specifically with respect to relaxing the "Maintenance" standards were pitched on a slide with the following bullets:
    • Maintenance related accidents for amateur built are similar to that if TC'd aircraft of comparable type, size, and operation
      • Example: 4.5% of PA-28 accidents vs. 4.3% of all amateur-built accidents (including true experiments).
    • Maintenance privileges for TC'd aircraft, operators, and operations similar to amateur built may be appropriate. 

  • I found the presenter had very little backup for his assertions about the overall safety of GA aircraft, both certified and experimental.  A lengthy report was published by the NTSB in 2011 about the safety of E-AB aircraft.  Since then, I am not aware of any detailed reports that have quantitative data.  The presenter did make reference to the findings of the 2011 NTSB and some of the changes that came from it.  He noted that improvements have been realized and that the E-AB safety record has improved dramatically since 2011.

  • The EAA proposal as related to the legacy aircraft fleet was broken down on a single slide as follows:
    • Opportunity to align legacy TC fleet with E-AB and E-LSA to a degree
    • Opportunity for a new non-commercial category
      • Parts - (approval) based on fit, form, function
      • Modernized equipment/avionics installation on same basis
      • Approvals at field level
      • maintenance by A&P, owner-operator, repairman 

  • Special Airworthiness Certificates: In side discussions before and after the presentations (and based on prior conversations I had with the MOSAIC Program Manager in Washington DC) I have learned that the EAA proposal for MOSAIC to include adoption of a new special airworthiness category for legacy airplanes is no longer being considered and will not happen.  Instead, the focus is shifting more toward streamlining of approvals for replacement parts and other types of relief to the problem.

  • Some discussion during the presentation noted that strides have already been accomplished by FAA in the area of Risk Based PMA Process as a streamlining approach.  There’s also an existing industry document published by MARPA and adopted by FAA to allow streamlining approvals for non-safety significant parts.  These are steps in the same direction as intended by MOSAIC.
There were not a lot of opportunities to ask questions specific to legacy aircraft because the meeting attendees got into a lengthy discussion about the safety continuum.  Still it was a very informative presentation that I appreciate having the opportunity to hear.  I look forward to future participation in the development of MOSAIC.


END OF REPORT

[note] I apologize for the random font sizes in this report.  I am experiencing a lack of expertise in HTML formatting.  Always learning.... TLB


Acronyms from this blog post:
AAA, Antique Airplane Association
ACO, FAA Aircraft Certification Office
ADS-B, Automatic Dependent Surveillance—Broadcast
AOPA, Aircraft Owners and Pilots Association
ARSA, Aeronautical Repair Station Association
EAA, Experimental Aircraft Association
DAR, Designated Airworthiness Representative (FAA delegation)
DER, Designated Engineering Representative (FAA delegation)
E-AB, Experimental – Amateur Built Aircraft
E-LSA, Experimental Light Sport Aircraft
FAA, Federal Aviation Administration
GA, General Aviation
LED, Light Emitting Diode
MARPA, Modification and Replacement Parts Association
MOSAIC, Modernization of Standard Airworthiness Certificates
NTSB, National Transportation Safety Board
ODA, Organization Designation Authorization (FAA delegation)
PMA, Parts Manufacturer Authority
STC, Supplemental Type Certificate
TC, Type Certificated
TCAS, Traffic Collision Avoidance System
UAS, Unmanned Aircraft System 


Watch for future postings about this topic.  PLEASE LEAVE YOUR COMMENTS BELOW.  Thank you! 

Tuesday, April 23, 2019

Re-Visiting Taylorcraft AD 51-09-03

Does your Taylorcraft Comply?

This is an old Airworthiness Directive that has been around so long, that many airplane logbooks may have had a "complied with" logbook entry years ago.  Inspectors need to verify this and not just assume that once complied with means always complied with.  It is possible that the required device could have been removed or lost during re-build.  That's what happened on my Taylorcraft.  CAP recommends that Taylorcraft owners and operators should re-visit this important safety issue.

The AD came about as a result of an accident where a pilot inadvertently turned the FUEL OFF when he intended to pull CARB HEAT ON.  This is an easy mistake to make if you are not looking at the knobs but rather going "by feel".  The knobs are right next to each other.

As a safety remedy, Taylorcraft came up with a simple clip device that installs on the fuel shut-off knob.  The AD says... "Taylorcraft P/N B12-947-3 or equivalent is considered satisfactory."

Read the Full Text of the AD Here.

One major problem is... This part is not available anymore.  OK so the next option is to come up with an equivalent one.  But the next problem is.... what is it supposed to look like?  Are there any old-timers still around that might know?  For me, the solution has come through the Taylorcraft Forum and from some internet searching.  It all boils down to this...  We need a device that meets the intent of the AD.  And the good news is that the AD gives the following as a clear description of the intent:

"The device is to prevent inadvertent operation of the fuel shutoff valve by requiring a definite and positive movement by the pilot before the control can be operated."

Well here is what I came up with for my airplane:  I fabricated this myself as an "owner produced part".


It is the small silver device that is mounted with the fuel shut-off control anchor nut.  I made it from .032 Aluminum 2024-T3.  I made it in such a way that I believe it meets the intent of the AD.  You have to move it slightly downward to turn fuel on or off. Some folks worry about fatigue, so they have made them from spring steel.  But on mine, fatigue isn't an issue. I have had this in there now for the past 150 hours or so and it works great.  I just made it so that the movement is not so much that you are yielding the aluminum.  

After researching this a bit, I patterned this after one that I saw on the Taylorcraft Forum, which I believe might be an actual Taylorcraft part.  See the red clip in the photo below.


 Here is another one I saw online as used on a pre-war Taylorcraft.  Red Clip in the center panel.


 Another fellow posted this one he made from a broom-handle clip.  It is a spring-steel device that should suffice.  It just looks like it might be difficult to operate (in my opinion).



Either way, I believe all of these designs do meet the intent of the AD and may help save some souls from an inadvertent engine out circumstance.

Fly Safe - and Keep the Antiques Flying!





 



Thursday, March 21, 2019

SERVICE BULLETINS

Looking for a service bulletin for CAP STC's?  Click on the "STC' TAB above then scroll down to the yellow highlighted link.

or Click here:

Sunday, January 27, 2019

Airworthiness Maintenance Inspection Notes, A-1231 Curtiss-Wright

Back before the FAA existed, aviation in the USA was under the authority of the Department of Commerce's Civil Aeronautic Administration (also called the CAA).


In those days, much information was published in the interest of safety. Unfortunately, these documents are not readily available today.   Similar to today's Airworthiness Directives (AD's) were publications known as Airworthiness Bulletins or Airworthiness Maintenance Bulletins and were considered mandatory safety items.  Other CAA documents similar to today's Special Airworthiness Information Bulletins (SAIB's) were Airworthiness Maintenance Inspection Notes (AMIN).  These documents include safety related inspection items that should be required at annual inspection.  These are generally considered to be mandatory as well, but this is not verified. The AMIN's are aircraft model specific. 

We recently obtained a copy of document no. A-1231, Airworthiness Maintenance Inspection Notes for Curtiss-Wright Aircraft, dated July 7, 1941.  Covered in this document are annual inspection requirements for Travel Air biplanes and monoplanes (including CW Travel Air), Curtiss Robin, CW Jr., CW Sedan, and CW Condor.  CAP has taken the time to reproduce the four pages because they were hardly legible.  While we claim no responsibility for the technical content of these documents, we wanted to make this information available here for historical information to restorers, operators, and enthusiasts of the grand old flying machines.





Thanks to our very good friend and Curtiss Robin restorer, Lane Tufts, for providing copies of the original document.


Maintenance Bulletin No. 4 dated  December 27, 1938 - Curtiss-Wright Travel Air shock absorbers.  This one is mentioned by SPECIAL NOTE 12 in the above AMIN.

 

I am pretty sure this one was provided by Darrell Starr.


Call for Papers
CAP is looking for more of these old CAA documents and we intend to use this blog as a collection center for such information.  If any of our readers run across these old CAA documents, please send them to us and we will make these hard-to-find documents available here.

Saturday, December 15, 2018

STC SA1-210, Explained

I get many calls about the options available when doing engine upgrades on the Taylorcraft BC-Series airplanes under STC # SA1-210 (formerly known as the Gilberti STC).  It usually takes a pretty long phone call to go through all of it.  So I thought maybe it would be helpful to share some of the main points here.  If you are seriously considering the purchase of upgrade paperwork, I recommend that you read through this post, and then study our latest catalog.  This should help you get a bit up to speed on the configuration choices you have.  Write down your questions and then give me a call and we'll figure out the best package for your Taylorcraft.
I'll start off with some background history and this should help you understand how this STC has evolved and maybe it will explain a bit about how the FAA approvals are structured. 


2016 Keith & Joann Walker from Charleston IL
BC12-D with STC SA1-210 Configuration A

ORIGINAL STC 1958 - Jack Gilberti


Configuration A incorporates a C85-8 engine with the original (short) engine mount and the resulting configuration is equivalent to the factory TC A-696 model BC12D-85.  This retains original cowl/baffle/engine control cables/exhaust/ etc.  The fuel system has to be updated to have at least one wing tank and the fuel lines have to be verified at least 3/8 inch size.  This configuration has no electrical system.  It has the option to install some simple wing fitting modifications that allow maximum weight to upgrade from 1200 to 1280 pounds. Eligible propellers are the same as the TC A-696 model BC12D-85.

Configuration B incorporates a C85-12 engine with a replacement (long) engine mount and the resulting configuration is equivalent to the factory TC A-696 model BC12D-4-85.  The "4" means that the engine mount and cowling are extended longer by about 4 inches. Originally it was expected that the starter and generator would be the old style (heavy) Delco brand.  So that's the reason for the mount extension.   This configuration requires conversion to a larger baggage compartment and added electrical system with battery mounted about 24 inches aft of the seat back.  This offset's the CG change due to the extended engione mount. The fuel mods are required same as config A.  Cowling requires modification, a different exhaust is required, longer control cables are required.  The same max. weight of 1280 pounds applies if optional wing mods are done.Eligible propellers are the same as the TC A-696 model BC12D-4-85.
If you are considering this option (or any long mount option), I always recommend that you try to find an airplane already modified or a model 19 or F19 and go for a flight.  You will discover that the handling characteristics are different from what you may already know as the nimble B-series Taylorcraft.  To some this may be desirable. To some, it can be a surprising disappointment after going through all the work to do this mod. It's hard to describe this difference, but just imagine that your rudder authority is just a bit slower in reaction time.  Not in a bad way, just different. 

STC UPDATE IN 1971


Configuration B was revised to declare the resulting configuration the same as TC 1A9 model 19.  This configuration is physically exactly the same as the prior described Configuration B (BC12D-4-85) in every way, except it was approved to operate at a maximum weight of 1500 pounds (if optional wing mods are done) - equivalent to the factory model 19 per TC 1A9 (under CAR 3 regulations).  As such it also became a "Flight Manual Required" airplane and no longer a "placard only" airplane.  All of the same fuel/cowl/exhaust/baggage/etc mods apply as aforementioned Configuration B.  Eligible propellers are the same as the TC 1A9 model 19.
By the STC wording, you essentially have the option under Configuration B to go with 1280 or 1500 pounds maximum weight.  The former keeps the airplane within the LSA weight limit.  The latter takes the airplane over the LSA limit.

STC TRANSFER TO CAP in 2010


Certified Aeronautical Products took over the management of the STC in 2010.  We have expanded the options beyond those approved in the STC, made possible through major alterations approved by a DER.  We call these STC deviations. These major alterations do not require additional STC but are incorporated under FAA form 337.  Rather than mention of them all here, please look at the catalog.  For example, a DER can approve certain non-standard propellers. Another example.... we offer DER approved deviation paperwork to substitute a C85-12 engine on Configuration A.  This makes it possible to have an electrical system (with the short engine mount) when modern lightweight starter and alternators are used... because we've determined that they fit.  It's a tight fit, though.  You'll find you might have to de-mount the engine to get your starter on and off.  But its not that hard to do.  So the DER approved deviations have opened the door to many additional configuration options for these modified Taylorcrafts.  Again, most are listed in our catalog.


Previously, I mentioned different exhaust.  Well, when you mount an alternator to the back of a C85-12 it will interfere with the cross-over tube on the original B-series exhaust.  Something has to be done.  If you want to fabricate your own, we can provide the Gilberti drawing for the model 19 style that extends the cross-over pipe farther aft.  The same exhanst configuration was done at the factory for the BC12D-4-85, 19, and F19 models.  Another more popular option nowadays is to convert to the Luscombe style split headers or Cessna 150 Hanlon Wilson style exhaust. We can provide DER approved paperwork for either of these or others, like Aeronca and more.
 

OTHER STC SA1-210 Deviation work

Our DER has approved some de-rated installations of C90 or O-200A engine (de-rated by limiting RPM to that for 85 hp).
Through DER and FAA FSDO/ACO coordination, we have also supported a few deviations to substitute an O-200A engine rated at 100 hp. This is equivalent to TC 1A9 model F19.  We had to do an analysis of a specific engine mount design, so a new mount is required (or you can order an F19 mount from Univair).

There are a lot of options.  Study our catalog and then give us a call with your questions.  We will gladly help you tailor your Taylorcraft with approved paperwork.