******** My original post below...*********************
In their usual dramatic headline fashion, the EAA has announced VARMA, a “New Parts Program Big Win for Vintage Fleet” touting this as a great accomplishment achieved ‘after years of EAA Advocacy efforts’. The acronym they’ve created stands for Vintage Aircraft Replacement and Modification Articles
http://discover.eaa.org/fRV250NCN2r
Don’t get your hopes up too high. Really, there’s nothing to see here. At least nothing new anyway. In fact, be sure to pay attention to the definition for the kinds of parts they quote as allowed under the new VARMA program, which they declare “The program applies to parts whose failure would not “prevent continued safe flight and landing.”
Wait.. if this sounds familiar, it is because it is the same definition that has existed for years for minor alterations and Category 3 (no safety affect) parts. And if you know your regulations, these parts do not require anything more than a logbook entry because they are minor alterations. Check out these FAA Advisory Circular excerpts.
AC 23-27 Talks about safety benefits in substituting original parts that fall under the same definition.
AC 43-18 chg 2 uses the same definition to define Category 3 parts and goes on to say these parts only require “acceptable” data (not approved data).
Vintage aircraft owners and aircraft mechanics who understand these guidance documents have been applying this concept legally for years. Take note that the EAA announcement also states… “VARMA uses several existing FAA policies to create a program that requires no new regulations, orders, or advisory circulars.”
While admitting this is nothing new, what the article fails to point out is the fact that the FAA has snubbed the EAA in the real effort they’ve tried for years to achieve regarding relief for Vintage Airplane part substitutions, namely their MOSAIC proposal. This was originally conceived as a sort of “owner approval” type of program where replacement parts could be left to the discretion of airplane owners. It was a push to go beyond the existing “Owner Produced Parts” provision, which has also been around for decades.
It seems the FAA has thrown the EAA advocacy warriors a VARMA bone in lieu of the full course MOSAIC meal they were after. Nonetheless, we have a “Big Win” for old airplanes.
Take our advice. Get yourself educated if this subject matters to you. Seriously, the kind of substitutions that fall under the VARMA definition are Minor Alterations and should not require a 337 as a Major Alteration. Follow VARMA and you’re likely to bog down in an FAA quagmire of deciding the fate of your project.
