VARMA: Throwing the dog a bone

10/13/2023

UPDATE: VARMA - No Bone... just us old dogs.  Looking for younger pups!

 

When I first heard about the VARMA plan, I was skeptical.  Anything with FAA involved tends to have flaws.  So I blogged my opinions here.

http://dc65stc.blogspot.com/2023/04/varma-throwing-dog-bone.html

 

Within days, I got a call from Scott Fohrman (FAA) and Tom Charpentier (EAA).  They wanted to explain the process.  So I listened.  I have known Scott for several years.  He is one of the few at FAA who have historically been a champion for vintage certified aircraft.  So he took the ball (at the urging of EAA) on this to come up with a way he can use his position in the FAA, following existing rules and policy, to do his part to help owners navigate the FAA quagmire. They call it VARMA.  Good on Scott.  But I don't think many at FAA are on his side.  I gather that this VARMA thing is a one-man (Scott) show with FAA. But, it turns out I am now less skeptical now and can see that this is good.  I still worry somewhat about dealing with the FAA, who often open up worm cans that can really make life tough.  But I don't believe Scott is that kind of fellow.  Let's just hope he doesn't retire soon.

 

So take a look into it.  VARMA may just be the help you need.  As a DER myself, I am doing everything I can to help out with approvals of technology upgrades for Vintage airplanes.  I have a huge back-log of work in this area.  I love my job but it is sometimes overwhelming.  It is good to have at least someone (Scott) at the FAA who are also working in this area.  Honestly there are not enough people doing what me and Scott are trying to do.

 

SO... for a longer term plan, I am looking for an apprentice or two to mentor into this field.  If you know a passionate young antiquer... send them my way!!

******** 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.  

CAP Taylorcraft Buyer's Guide for Summer 2020 is Here

March 2020 marks our TEN YEAR ANNIVERSARY of being the care-taker of the Taylorcraft Engine Upgrade STC # SA1-210.  Better known as the "Gilberti STC", this set of documents have stood the test of time and are still useful as FAA approved data, now 52 years later (as of May 26th 2020).  While we are talking statistics, we went back and counted to find that Certified Aeronautical Products, LLC (CAP) has provided service in one way or another to almost 300 Taylorcrafts since we began business in 2003. Specifically, we have served 209 B-series, 75 D-series, and 10 F-series.  We've enjoyed every plane and getting to know every Taylorcraft owner, every Taylorcraft restorer, and every Taylorcraft pilot that we've met.

Click to View Buyers Guide

In honor of Mr. C.G. Taylor and Mr. Jack Gilberti, we are now issuing our Taylorcraft's Buyer's Guide for Summer 2020.  This guide contains most of what we have learned over the past 10+ years, about upgrading and maintaining Taylorcraft B-series airplanes.  As a few of these great airplanes have now reached the age of 80 years, many will be hitting that milestone over the next few years.  There's not a better time than now to clean up that lovely plane and make the effort to do some upgrades.  We are here to help you take good care of your sweet flying Taylorcraft, just like it has taken care of you for all these years.Just like the venerable Taylorcraft airplanes we support, the Gilberti STC and CAP are still here for continued flight for many more years into the future.

Another post that helps provide some explanation was provided back in 2018.  Click Here. Then after you review the buyers guide and the 2018 post, get your questions together and give us a call or email.

254-715-4773

barnstmr@aol.com

Thanks to all of our great friends and Taylorcraft customers!

- - - - 

p.s. Stay tuned for some sweet new announcements in the next few weeks!.. 

CUSTOMIZE YOUR VINTAGE RIDE!

Many have asked... Can I Customize my Antique Airplane?  

The  short answer is most likely YES.
The longer answer is "Lets look at the details and the cost and see if its worthwhile".   

At CAP, we try to provide certification services that Vintage Airplane owners and operators really want, but have a hard time finding the legal paperwork to do. We have been at this long enough to have learned a lot of ways to approach these things.  We have collected engineering data too from many sources. And we've developed some analysis and test methods to address certain requirements.  So you might be surprised how affordable we can get the job done.  Of course, there are regulations and limits to what can be approved.  But we try to approach every job with optimism, to see if there's a way.   If so, Terry Bowden the Vintage DER, can help.

HOW TO GET IT DONE:
The best way to approach this is for you to provide us with a list of all the changes you are trying to make legal.

Airplane make / model / serial no. or registration no.
Engine model
Propeller model
Engine mount (short or long)
Exhaust configuration (original/luscombe/hanlon wilson/etc.)
Fuel system configuration (nose only/nose + wing tanks/etc.)
Starter (yes/no) - if yes, make and model
Generator (yes/no) - if yes, make and model

Alternator (yes/no) - if yes, make and model

Battery (yes/no) - if yes, make and model
List of equipment by make and model (if applicable) such as radios, lights, brakes

Remember, just tell us what's been changed from the original TC approved configuration.  Once you provide the list, we can go through it and give you a price for the approved paperwork.

Terry is a second generation Lifetime member of the Antique Aircraft Association. 

DER Approved Data

Through the magic of PayPal, let C.A.P. provide a convenient and quick way to address your DER approval needs. A typical simple DER approval of your data usually costs around $250.00, depending on the complexity and the engineering discipline(s) involved.

C.A.P. supports all DER disciplines as follows.
Structures - Powerplant Installation - Mechanical systems & Equipment - Electrical systems & Equipment - Engines - Flight Analyst - Flight Test Pilot - Acoustics

Email us today at barnstmr@aol.com to request your DER approval. We'll send you an invoice via PayPal for Major Repairs and/or Major Alterations. This method is not always possible for complex or unusual design changes. So if you're not suer give us a call first at 254-715-4773 and describe your needs. If we agree this can be a simple approval and the data is available or simple to produce, it is easy... just scroll down and order your FAA-DER approval form 8110-3.

With this approval in hand, your A&P/I.A. will have what he needs to execute the FAA form 337 for fast and efficient return-to-service.

B-17G Texas Raiders

I had the unique opportunity and pleasure to work on a certification project for one of the greatest airplanes to ever fight for our country... a B-17G Flying Fortress, "Texas Raiders".


This airplane is operated by the Commemorative Air Force (CAF) - Gulf Coast Wing in Houston, TX. For years, B17G operators have been struggling with turbo-supercharger reliability issues, even after disabling the turbos by removing the wastegate butterfly and compressor wheels. This problem has intensified as replacement parts have become nearly extinct.
CAF - Gulf Coast Chief Maintenance Officer, Chuck Conway designed a modification that solves the problem and still looks fairly authentic to the untrained eye. A new welded pipe assembly was fabricated with an overboard outlet to dump exhaust overboard just ahead of the turbo-supercharger. The design bolts up to the turbos which remain installed as the original and thus retain the authenticity. For now, the modification has only been done on the #1 and #4 engines on Texas Raiders. Modifications for the #2 and #3 engines is planned for this fall, after the airshow season.


When the CAF first contacted me, through my friend Mark, I was skeptical that we might be able to clear all the FAA hoops for certification in time for their first airshow just three weeks ahead. We got busy anyway and remained optimistic... CAF members from all over Texas and elsewhere sent me information that enabled me to assemble a technical report. I received great support from my FAA counterparts and was able to secure special authorization to approve the data myself as a DER. This turned out to be a blessing, enabling the A&P/I.A. to submit the 337 directly to FAA OKC and return the airplane to service himself, based on having approved data.

This was my first encounter with a "Limited" type certificate aircraft. This presented some unusual certification issues and challenges. Using FAA processes, it became necessary to select and establish the appropriate certification basis for the change. My FAA advisor agreed with the approach I proposed and so the rest was a matter of technical details. The CAF guys got busy and prepared the airplane for a ground test and with the results, I had everything needed to make the approval.

When things go well as they did on this project, I truly love my job. It is nice to be able to contribute to keeping this kind of historical machine alive for folks to enjoy. This project truly was a team effort, which couldn't have been done so quickly without the input from many folks. Still the CAF folks really have been appreciative for the work I did. Here's what some of the CAF team-members had to say.

"Terry: Thanks very much for taking on the Herculean task of straightening out the paperwork on Texas Raiders! ...Your input and expertise on this project was the KEY to successfully putting this aircraft back on the show circuit! I am really looking forward to meeting you, and thanking you, in person! Best wishes. Doc"

"Terry, ...All the CAF folks spoke of how much they enjoyed meeting you and how they appreciated your work. I'm glad it finally worked out OK. You pulled off in 18 days what the first guy had sat on for 6 months, so in their mind you worked a miracle... Mark"

And here's what Chuck Conner had to say in his monthly column in the May 2010 issue of "Cowl Flaps", the CAF GCW Newsletter...


So with the approval in hand, "Texas Raiders" made it to its first scheduled air show after a 7-year restoration. It just so-happened that this show was in Temple Texas just 20 minutes from my house. So, on Friday April 30, my wife and two of our kids came along to go see the airplane. The flight crew, led by Buddy Cooksey treated us all to a personal tour of the airplane. I am sure we will not soon forget this experience.


I need to acknowledge my my friend Mark Julicher and thank him for recommending me for the work. Mark also prepared some of the continuing airworthiness data for this bird. Others who were helpful were David Carr, Chuck Conway, Don Price, Walt Thompson, Peter Hakala, Jimmy Stahl, Randy Wahlberg, and Ron Dietes. In a matter of 15 days, start-to-finish, we accomplished the FAA approval for some exhaust changes which make the airplane safer and enabled the CAF Gulf Coast Wing to get the airplane legal and available for the 2010 Air Show season.