|
|
|
|
CERTIFICATION AND LUSCOMBE MODEL CHANGES, Correcting the confusion- Some have alleged throughout the years that an airplane certified originally as a Luscombe 8A, would always remain an 8A in the FAA records, despite its later conversion to model 8E or 8F per the Service bulletins and Type Certificate data sheet. That statement is untrue. If one has a converted or upgraded airplane, and the FAA Registry still shows the former model designation; that is because the conversion was not completed in accordance with the guidance of FAA Order 8130.2, and FAA Order 8300.10, both of which apply to model designation changes and airworthiness certification procedures to be followed. There has been considerable confusion over the years about the means by which an aircraft of one model designation -such as a Luscombe 8A-, might be modified to become a different model designation. About 1995, I requested, and received guidance on this issue from the FAA Aircraft Certification Office (ACO, or engineering). That guidance was widely publicized in the Association newsletter and by employees of the Luscombe Foundation. (SEE Issue 151-2001, page 10, ‘Engine and Model conversion’) The FAA asserted then, that such model changes resulted from compliance with approved data such as a service letter and Type Certificate Data Sheet, and a return to service sign-off by a mechanic or IA who made a conformity inspection of the aircraft and work completed via a logbook and/or 337 maintenance entry. This description confirmed the process I had seen documented on several aircraft, so the information was believed to be “correct”. THIS FAA GUIDANCE WAS LATER FOUND TO BE INCORRECT. In early 2002, an FAA inspector called about a data plate for a recently upgraded Luscombe model change. A lengthy discussion about the model change procedures ensued, and his expertise became apparent. I subsequently confirmed his comments with the FAA ACO who had previously provided the improper guidance. A correction about aircraft model changes was again disseminated by in the Association newsletter (SEE Luscombe Assn. Issue 157, page 7, ‘Bad Advice’). Many did not get the message, as was evidenced in a recent Luscombe forum where it was again alleged that, “once an 8A, always an 8A”, remained true because ‘model changes do not affect FAA records’. That is not true, ERGO, WE REPEAT THE FORMER CORRECTION. FAA Order 8130.2, entitled Airworthiness Certification of Aircraft and Related products aka ‘Certification handbook’, governs the inspections and procedures to be followed in completing a modification and model change (Section 27, page 18; Section 29, page 19). This guidance is further supplemented by FAA Order 8300.10, entitled FAA Airworthiness Inspector’s handbook, (Vol. 2, Chapter 225). The essence of this FAA regulatory guidance is as follows:
It would appear that a failure to complete any of the above steps, especially #5, might result in a failure to register the amended model designation with the FAA. As you should be able to determine from the above
regulatory excerpts, a properly completed aircraft model change WILL result in a
re-designation of the model number and issuance of new registration and
airworthiness documents depicting the modified aircraft configuration. If for
some reason your aircraft is modified, but your registration and airworthiness
certificate has not been properly amended, it should be corrected at the first
available opportunity. The regulatory references in this article are available
in Adobe pdf format at the following web addresses: FAA Order 8300.10 I have also enclosed scanned pages of the regulatory references as a handy
attachment. 
 Doug Combs |
|
Send mail to
mr.luscombe@luscombesilvaire.info with
questions or comments about this web site.
|
