Be sure engine accessories havePMA approval. FAA-PMA shouldstamped on the part.

ONE OF THE MOST CONFUSING

aspects of restoring a cer-tificated aircraft is lettercombinations like TC,STC, and PMA. They startpopping up when, for in-stance, you ask, "What arethe rules pertaining to re-placement parts I'll needfor my airplane?" and"What was the originaltype of engine and pro-peller on the airplanewhen it was manufac-tured?" and "Can I substitute an-other engine or propeller?"

Using the prop and engine exam-ple, selecting something other thanthe original equipment may be amoot point because the airplane'stype certificate (TC) dictates the en-gine and propeller combination theFAA has approved. Most lAs (air-frame and powerplant mechanicswith an FAA inspection authoriza-tion) will have copies of type certifi-cates for different airplanes, and youcan find them on the FAA website at

STCs, PMAs,and Other

Confusing LettersWading through the alphabet soup

of aircraft restorationRON ALEXANDER

www.airweb.faa.gov (select TCDS, fortype certificate data sheet).

Federal Aviation Regulations willgovern any number of decisionsyou'll make regarding the manufac-ture or replacement of parts on anolder production airplane, and you'llhave to document all repairs and al-terations. Let's look at some of themore common phrases and formspertaining to production aircraft.

Type CertificatesAccording to the FAA, "type certifi-

cate data sheets and specifi-cations (TCDS) set forth es-sential factors and otherconditions which are neces-sary for U.S. airworthinesscertification." Aircraft, en-gines, and propellers thatconform to a U.S. type cer-tificate are eligible for a U.S.airworthiness certificationwhen found to be in a con-dition for safe operationand when all ownership re-quirements have been met.

TCDSs include the specifica-tions, and generally they are com-piled from details provided by theholder of the type certificate, butthe FAA may request and incorpo-rate additional details when condi-tions warrant. And the TC itselfspells out the official certificationspecifications of an aircraft, en-gine, or propeller when the FAAfirst certificated the item.

The TC gives its holder author-ity to manufacture the certificateditem to the public. For an airplane,

86 MARCH 2002

it lists the manufacturer and theairplane's specifications, and theTC holder must adhere to thesespecifications when manufactur-ing the airplane.

Any number ofdecisions you'll moke

regarding themanufacture or

replacement of parts•l on an older airplane

will be governed byregulations. You'll also

have to documentrepairs and alterations

that are made.Restoring a certificated airplane

usually means you're dealing witha TC issued years ago. No matterhow old, those specifications re-main in effect. For example, in thelate 1920s the Stearman AircraftCompany manufactured its modelC3-B, and I'm fortunate enough toown one currently undergoingrestoration. A simple TC from aStearman C3-B includes:

T.C. NUMBER: ATC 55MODELS: Stearman Aircraft C3-

B, 3 POLESTEARMAN AIRCRAFT COM-

PANYEngine: Wright J-5 220 hpFuel: 68 gallonsOil: 8 gallonsNo. passengers: 2Baggage: 52 lbs.Maximum weight: 2,830 lbs.Certification basis: Approved

Type Certificate No. 55Serial numbers: 1 to 247 eligi-

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and position lights equipment, 20lbs.; flares, 43 lbs.; battery, 55 lbs.,cockpit heaters, 10 lbs.; 78 gallonfuel capacity

NOTE 1: All model C2-Bs eligibleprovided they conform to theabove specifications. (The modeldesignation was changed fromC2-B to C3-B.)

NOTE 2: Airworthiness certificatemust include the following unlessit has been satisfactorily demon-strated to an inspector of CivilAeronautics that such notation isunnecessary: "INTENTIONAL AC-ROBATICS PROHIBITED."

This is a simple TC, but notice that itspecifies the engine type along with theairplane's data. Most TCs are more ex-tensive, allowing for different engineand propeller combinations and otherdata. The Stearman C-3B Type Certifi-cate allows only one type of engine—the Wright J-5.

Notice, too, the reference to an ad-

justable metal propeller. The point is,when restoring an airplane you mustrefer to this data. If you plan to vary theengine, propeller, or make any struc-tural modifications from the way theaircraft came from the factory, you'llneed FAA approval.

STC—Supplemental type CertificateThe FAA defines a supplemental typecertificate (STC) as, "Specificationsused to record the approval of majoralterations performed on any of theproducts for which they were issued."In short, someone has received FAAapproval for an alteration to a certifi-cated airplane, and this person hasearned an STC as part of the FAA ap-proval process so you can make thesame alteration to your airplane (for aprice, naturally) without repeating theoriginal approval process.

For example, Stearman originallycovered its C-3 with Grade A cottonfabric and nitrate dope, but I want to

use the Poly-Fiber covering system in-stead. As a manufacturer, Poly-FiberInc. applied for an STC to use its cov-ering system on the Stearman C-3B.The FAA approved the STC and as-signed a number—SA1008WE.

To legally cover my C-3B with Poly-Fiber, I'll fill out FAA Form 337 (see de-scription below) and note on it thatSTC SA1008WE was installed accordingto the written instructions. Because theC-3B is a certificated airplane, an A&Pmust endorse this notation. Form 337also gives the A&P an opportunity toelaborate on the covering process bydefining types of materials, number ofcoats, colors, and more.

If an aircraft is not on the list ofthose eligible to use an STCed item,its owner can apply for an FAA fieldapproval by including a conform-ity statement with the requiredForm 337. Using the Poly-Fiber ex-ample, the conformity statementform is in the Poly-Fiber proce-

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dure manual. An IA would thenapprove the work and sign Form337, which returns the airplane toservice. One copy of the Form 337stays with the airplane while theother goes to the local FAA office.

PMA—Parts Manufacturer ApprovalIf you simply want to replace apart on an airplane that is nolonger in production, you can doso if the new part has been manu-factured in accordance with cer-tain criteria. To earn FAA partsmanufacturer approval the re-placement part must be createdusing approved materials andmanufacturing techniques.

In short, a PMA replacement parthas to be equal to or better than theoriginal part. And it must have aclear paper trail that tells where thematerial for the part came from,who made the part, and who in-spected it. If you are installing PMAparts, you should have no paper-work hassles because the parts havealready been approved for installa-tion on your airplane.

FAR 21.303, Replacement andModification Parts, further definesthis process:

(a) Except as provided in para-graph (b) of this section, no personmay produce a modification or re-placement part for sale for installa-tion on a Type Certificated productunless it is produced pursuant to aParts Manufacturer Approval issuedunder this Subpart.

(b) This section does not apply tothe following:

(1) Parts produced under a type orproduction certificate.

(2) Parts produced by an owner oroperator for maintaining or alteringhis own product.

(3) Parts produced under an FAATechnical Standard Order.

(4) Standard parts (such as boltsand nuts) conforming to establishedindustry or U.S. specifications.

FAR Part 21 spells out the re-quirements for earning PMA, and

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the process requires a serious in-vestment of time and money. Ifyou think you are buying a PMApart, check the paperwork thor-oughly and the part—it must bestamped "FAA-PMA." Rememberthat the PMA approves the partonly. In some instances you mayneed an STC to use the part onyour aircraft.

Several exceptions to FAR 21.303are noteworthy, especially to anaircraft restorer. The parts pro-duced by the original manufac-turer are exempt if producedunder the type certificate. Notethat the airplane's owner or opera-tor can manufacture a part, whichis common when a needed re-placement part is no longer pro-duced and cannot be found.

FAR 21.303 was intended togive owners and operators of olderaircraft relief from having to meet

the strict FAA-approved type de-sign requirements for a PMA.But—and there's always a but—every part an owner/operator ormanufacturer builds to replace anunavailable part must meet theoriginal type design.

This FAR requires the part to bemanufactured in one of threeways: 1) Using the manufacturer'sPMA or the technical service orderholder's type design data, 2) Ob-tain approval from a designatedengineering representative (DER)for the part, or 3) The owner/oper-ator must submit design data tothe FAA for approval. The refer-enced type design data may be onfile either with the FAA or theoriginal manufacturer.

As you can see, this process canbe cumbersome and the regula-tions may be interpreted differ-ently within FAA regional offices.

Antique or classic aircraft re-storers should use good judgmentand not abuse this regulation. Itwas not created to allow an indi-vidual to circumvent the rules us-ing a PMA or other approved partduring the restoration process.

Field ApprovalIf your restoration project requiresa repair or alteration that doesn'tfall into one of the FAA-approvedmethods of doing the work, it willrequire a field approval, which theFAA defines as "an approval by anauthorized airworthiness safety in-spector (ASI) of a major repair oralteration that is accomplished byone or more of the following, asappropriate: 1. Examination ofdata applicable to one aircraft only.2. Physical inspection, demonstra-tion, testing, etc. of one aircraftonly. 3. Examination of data only

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for use on multiple aircraft of thesame make and model."

How easy it is to get a field ap-proval depends on what you'redoing and where you live. Theprocess varies among FAA offices,but the agency is striving for stan-dardization of the process. Sincethis process varies, work withyour local FAA Flight StandardsDistrict Office (FSDO) and your IAto determine if you need a fieldapproval and the best way to pro-ceed. Understand that a field ap-proval for replacement of parts orrepairs becomes necessary only ifthe other methods describedabove don't apply.

FM Form 337FAA Form 337 documents majorrepairs or alterations to aircraft,and the aircraft's return to service,and records these things in the air-craft owner's and FAA's files. Theform's official title is, "Major Re-pair and Alteration," with a sub-head that reads, "Airframe,Powerplant, Propeller, or Appli-ance." That just about coverseverything on the airplane.

You should review previous337s on your airplane and ensurethat new ones generated duringthe restoration process are com-pleted correctly and consistently.These documents are part of yourairplane's maintenance historyand are part of the aircraft's per-manent logs.

Now you are better prepared tounderstand these FAA terms, defini-tions, and forms and are ready tostart — or finish — your restorationproject. By understanding theseterms and how and when they apply,you'll be in a position to produce abetter restoration accompanied bythe correct FAA paperwork.

Further questions should beaddressed to EAA's Aviation In-formation Services departmentat 888-322-4636, Ext. 4821, orinfoserve@eaa.org.

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