FAA and STC files?

[Dave Rutherford]

Does the FAA keeps records that would permit one to locate the owner of any given STC? I recently heard from a fellow who would like to use STC SA1044WE, but he can’t find the owner. Also, I was asked if there was an STC for installing an O-200 engine in a Mite. I think there is, but how do you locate the owner? It seems reasonable to me that there would be a central registry since the paperwork has to pass through the FAA.

[Keith Mackey]

Dave:

The FAA does keep records that would permit one to locate the owner of an STC. The database is here:

http://www.airweb.faa.gov/Regulatory_and_Guidance_Library/rgstc.nsf/MainFrame?OpenFrameSet

Per this database, I find that STC SA1044WE is owned by: Aero Spec, 240 North Dale , Fullerton CA 92631. It was issued 01/01/1961 and very likely the company is no longer around. He should check with the NM-100L Los Angeles Aircraft Certification Office Tel: (562) 627-5200 who controls the STC as to the current status.

An STC is like a license or a patent. The holder of an STC has the right to sell authorization to use the FAA Approved data that he owns. Possession of the STC document does not constitute rights to the design data or installation of the modification. The STC and its supporting data (drawings, instructions, specifications, etc.) are the property of the STC holder. You must contact the STC holder to obtain rights for the use of the STC.

I find no STC issued for the installation of an O-200 on a Mite.

If I wanted to install an O-200 and keep the airplane certified in the normal category, I would attempt to get a "Field Approval" on the installation. (This would be the equivalent of a one time only STC). This can be done on an FAA 337 form. If there is no approved data, either an FAA inspector will have to approve the 337 form (legal, but probably not going to happen in this lifetime) OR it will be necessary to hire a DER (designated engineering representative) who is an individual designated by the FAA to provide engineering services. The DER is an independent contractor and will charge for his services. The role of the DER is to provide the "approved data" that the FAA can use at their discretion to grant a field approval. To locate a DER, download the directory from:

http://www.faa.gov/other_visit/aviation_industry/designees_delegations/designee_types/media/DERDirectory.pdf

I would suggest contacting several DER's to find one with experience in these types of aircraft that would be qualified, based on the DER's experience, knowledge and comfort level of the installation, without going through a bunch of expensive testing. Rates can vary considerably between DER's. Once the 337 form is approved by an FAA inspector, it will apply only to that particular aircraft. It is not an STC. Other operators who wish to make the same modification, could submit a copy of that 337 as the basis for approved data that the FAA could, at their discretion accept for additional approvals of other aircraft.

The above statements are my opinions only and should not be relied upon by anyone without them independently verifying the correctness of what I have stated above.

[Joelj]

Hi Keith - Do you have any way of tracking down STC #SA2-1506 that covers installation of a C75-12 with a Flottrop prop? My mechanic has searched the FAA database and can't find it.
I'm trying to find documented proof of an A75-8 with a Flottrop prop on a Mite.
Thanks for any help or advice you might be able to provide.
Joel

[Keith Mackey]

Joel:

Your mechanic is correct. STC #SA2-1506 that covers installation of a C75-12 with a Flottorp prop is not listed in the FAA STC data base. This STC uses the old numbering system, so, if it was ever issued, it was a long time ago. It could be one that was surrendered, canceled, revoked or is a phony number that was never approved. None of these options help you.

I further checked to see if any other STC's covered this installation, including those issued for a C75-12 engine or a Flottorp propeller. I found none.

The only STC's I find covering engine changes on "mites" are:
SA3-483 Installation of Continental C85-12 on a M-18C55
and
SA1044WE Continental A75-8 65hp engine and McCauley 1B90-CM/6753 propeller.

Okay, so where does that leave you... Here's what I suggest.
Do you have a FAA form 337 covering installation of the engine and propeller under that STC? If so, that indicates that the FAA accepted whatever documentation of approved data was submitted to them with the 337 and you should be in good shape even if you can't locate the STC holder.

In any case, I always suggest that aircraft owners order copies of all the documentation in the possession of the FAA for their airplane. It only costs 10 bucks to get a CD with every single document in the FAA file on a particular aircraft. Order it from:

http://www.faa.gov/licenses_certificates/aircraft_certification/aircraft_registry/copies_aircraft_records/

What happens is sometimes 337's exist for a particular installation, but the owners copies have been lost. This is a way to recover the missing docs. OR sometimes unscrupulous mechanics will give the owner a 337 and never mail it into the FAA because they know it won't be accepted. The owner goes away happy thinking he has an approved installation and the FAA never knows about it until some incident occurs. If this is the case, the aircraft is not in an airworthy condition and is grounds for denial of any insurance claim.

In any case, the CD will show you where you stand approval wise for your installation. If you wish to mail me copies of your paperwork, I'll be glad to review them and make suggestions.

At this point, you either find proper documentation or you don't. It is not unusual for a sharp I.A. to discover an unapproved installation and then produce a 337 form in retrospect making it legal. To do this, the I.A. needs FAA Approved data. The Approved data can be an STC or a 337 that was "Field Approved' by the FAA as described in my previous post in this thread.

There are probably several mites flying around with field approved engine installations that are different from the original. Building a database of these would help you to establish a case for your installation that would make it easier for a DER to get the job done if you can't find approved data for your installation.

You may wish to identify any mites with an installation similar to yours by searching the FAA registry:

http://registry.faa.gov/aircraftinquiry/

You can find all mites registered in the US on this site. For each M-18 aircraft you identify, you can go to the page for that airplane, scroll down to "Airworthiness" and look at what is listed next to "classification". If it is experimental. no approval was needed, so these records won't help you. You can look at Engine Manufacturer and Engine Model in the same section to find out what engine the FAA thinks is on the airplane. (Might be interesting to start with yours).

If you can contact the owner, he might provide information or just order the CD of records for that N number and you'll have the basis for approval of that installation that you can present to your I.A. to be used as evidence of approved data for a new 337 on your installation. Complicated, but should work.

So you've got five options:
1. Find the basis for approval of your current installation.
2. Get you current installation Field Approved.
3. Convert your configuration to one that complies with an STC to which you obtain permission to use.
4. Create your own STC.
5. Surrender your airworthiness certificate and apply for an experimental certificate for research and development or complying with regulations.

This subject is not well understood and is quite complex. The above statements are my opinions only and should not be relied upon by anyone without them independently verifying the correctness of what I have stated above.

Keith

[Joelj]

Keith -
You certainly know your stuff. Thanks for all the insight - I will follow each and every suggestion given. I work with a DAR at my company who knows a few of the local DER's as well as the FAA inspectors. I'm hoping those connections will work in my favor.
I'll keep you posted and if I find any evidence that helps me - I'll be sure to submit it to Dave Rutherford for posting and sharing on the site.
Joel

[Glenn]

Joel:

Ed Soncrant, now in Hemet, put an 0-200 in his Mite in accordance with the C-85 STC. He convinced the Fed's that C-85's were very rare and that he could only find 0-200's on the used market. Now the insides of an 0-200 are nothing like an 85. Totally different. But they went to the 0-200 operating manual and looked at the power chart of were the 0-200 produces 85hp and redlined the tach there. I personally spent a day hovering over the documents of this HEAVILY modified mite. Every mod Ed is all documented and has the FAA's blessing. You shouldn't have much troubles de-rating your Mite.

[Keith Mackey]

Glenn is correct. The aircraft in question owned by Ed Soncrant is listed on this site as N18ED. A quick check of the FAA registry indicates that the airplane does indeed have an O-200 installed:
http://registry.faa.gov/aircraftinquiry/NNumSQL.asp?NNumbertxt=18ED&cmndfind.x=8&cmndfind.y=18

However, also note that it's classification is Experimental category, so the paperwork on this installation probably won't establish FAA approved data for a Standard category airplane. You can pretty much do whatever you want with an experimental category airplane without the need for STC's or 337's.

[Glenn]

I am unaware of the experimental staus of Ed's airplane. As you know, you can not take a certified airplane and make it experimental except for certification testing. I owned the Ercoupe used for the 0-200 STC. The logs and documents showed that it was put into the experimental catagory and re-issued a standard airworthiness certificate after the test. However, Oklahoma City still showed it as Experimental. Flew almost 30 years that way and no one caught it. What a mess to clear that up. I still have a Nimbus II sailplane (for sale) that I purchased just because it was still registered as experimental as it was when imported into the US. Imagine my surprise when I get the ship home and find in the documents that it was put in the standard catagory 35 years ago! The pisser was that the airworthiness certificate was missing. I really wanted the original experimental catagory and the Fed's wouldn't let me have it. Bastards. Anyway, it went thru a whole bunch of annuals and no one noticed the AW certificate was even missing. Look it up, N3CB. I think it still shows it as experimental. I have a replacement standard airworthiness certificate. I'm not going to worry about what the Oklahoma City's data base reads. Apparently this is not uncommon.

When I saw Ed's Mite all the mod's had been signed off by the Fed's. He had a 337 for everything including the "85hp" 0-200 engine. Mod's included moving the panel, seat, and fuel tank back about 4", a Toyota Corolla brake handle for a flap handle, a Cessna style trim wheel, homemade disk brake system, warbird style throttle/carb heat/mixture hand quadrant, the list goes on and on. Everything is well documented like a textbook. I think Ed must have had some photos of an FAA guy in a compromising position. I really don't know how he got away with some of the stuff he did. Too bad Ed will never be able to fly the plane again. It's been in pieces for years and needs a lot of work. I don't think the experimental catagory would be too much of an issue to remove. Best thing to do is to undo everything he did to it. The panel is full of crap. He has an A-4 Skyraider annuciator panel of all things in it. Probably from all his years at Douglas. Very nice guy.

BTW: Ed also had a brand new wood prop for a Lycoming Mite and I think it was a Flottorp. The good one that you can't get anymore.