Parts and Uncoperative Type Certificate Holder

[N.HEALD]

One for the engineers on here.......

We own a rather scarce aircraft of which only 18 were ever made in the mid 1970's the aircraft is currently on its annual and a few issues have come to light, one of which is exfoliation of the rudder mounting. This is a relatively simple alloy part. We and our maintainance organisation have attempted in vain to contact EIS Aviation in Germany who are the Type Certificate holder, hoping to obtain a new part, or the origional engineering drawings etc. EIS Aviation do not respond to email or answer their telephone and from talking to other Fournier owners the general view is that EIS are about as helpfull as a concrete parachute.

Our predicament is therefore what is the best way forward? Are there any advantages to trying to have the aircraft "orphaned" and put on a permit to fly? Would that make it easier to have replacement parts fabricated?

Any and all suggestions most welcome, Im sure we are not the first with this kind of a problem

[wrench1]

What is the exact model name, model number, and serial number?

W1

[N.HEALD]

Sportavia-Putzer RS180 Sportsman G-VIZZ is the aircraft in question.

[wrench1]

Definitely a rare aircraft. One option you may have is to research parts and information for the Fournier RF-6 as it appears the RS180 was developed from this previous model. Another model that was developed from the RF-6 was the Slingsby T67 Firefly under EASA Type Cert. A390.

Even though these other models are different than your RS180 they may very well have a lot more in common parts wise under the exterior skins since they share a common origin in the RF-6.

I'd start by contacting Slingsby ( Slingsby Advanced Composites Ltd. (http://www.marshall-slingsby.com/support.html) ) and see if you can talk to someone who might have worked on the T67. Even though the newer models are composite there might be an option for you to "upgrade" your RS180 with a certified T67 part.

Other places to contact would be Fournier or Slingsby private owners clubs and see if you can find out how they would support their similar type aircraft. Fabricating your own parts is possible...at least on my side of the pond...but this is usually very complex even for a small aircraft.

Good luck.

W1

[AdamFrisch]

Don't know how it works in EASA regualations, but under FAA and part 91, there is room for owner supplied/manufactured replacements. There must be some equivalent to the field approval in EASA land. If all else fails, then just replace it with your own manufactured part - who's ever going to know?

[Golden Rivet]

who's ever going to know?

168 people at the current count...;)

[SeldomFixit]

Plus those who attend the funeral. :p

[N.HEALD]

We need to do things by the book, just a shame the "book" is so awkward at times, We have already spoken to Fournier people re the RF6 genes and potential parts, problem is EIS are the Type Certificate holder for that as well, going by feedback they dont want to support any of the Fournier/Sportavia aircraft. The parts in question are very simple parts, and opinion is that they would be very easy to manufacture to an OEM or higher quality, but the rules dont make this easy.

All suggestions welcome

[wrench1]

N...

After looking over the EASA regs you may have another avenue to pursue. I'm not very versed in the EASA process but it appears the RS180 fits the requirements of an European Light Aircraft 1 or ELA 2. If this can be applied to the RS180 then it will give you formal relief in the installation of certain parts on your personal aircraft per EASA Part 21, Subpart K, 21.A.307 (C).

I also ran across this EASA Proposal dated Feb 2013 that specifically addresses parts installation on ELA aircraft:
http://www.easa.europa.eu/certification/docs/certification-memorandum/EASA%20Proposed%20CM-21%20A-K-001%20Issue%2001_Installation%20of%20parts%20and%20appliance s%20without%20EASA%20Form%201%20in%20ELA_PUBL.pdf

And this presentation from 2010 that may offer other avenues to pursue:
http://www.easa.eu.int/flightstandards/doc/Better%20regulation%20for%20General%20Aviation%20-%20presentation%20on%20the%20status%20of%20activities%20%28J uly%202010%29.pdf

If the above doesn't pan out, you could seek guidance on treating this replacement as a Repair under Part 21, Subpart M. If it is a simple item it maybe classified as a "minor" repair and this would further reduce your investment and approval process.

W1

[N.HEALD]

Thanks Wrench1, interesting reading. I would imagine though that the lower rudder mounting bracket falls within the primary controls bit so may not be eligible :*

[MurphyWasRight]

Don't know how it works in EASA regualations, but under FAA and part 91, there is room for owner supplied/manufactured replacements. There must be some equivalent to the field approval in EASA land.

Now to get really devious:
If there are any of this aircraft type in American hands could you have the owner fabricate/install the part under the above and sell you the used OEM part for your aircraft?

Obviously that would be more expensive than just doing it locally.

[wrench1]

N...

For what it is worth...I'd come up with a viable method to fabricate the part needed...then approach the CAA or proper authorities with your plan under either the ELA angle or as a repair per Subpart M and see what their response would be.

This would be the direction I would follow on this side of the pond...but as I mentioned I don't know all the options on your side. At least you would then know where you stood...and might even find out you may have another option not so obvious.

I have personally been surprised in the past when I approached the local authorities with this type of problem and found out I had actually over-thought the whole problem.

Murph...
No, that wouldn't be an option. On this side the definition is very specific in that to fall under "owner produced" part it must be installed on the owner's aircraft. If all the applicable guidelines are followed and the aircraft is returned to service then that part is serviceable for that aircraft only. Now if the owner were to sell the entire aircraft that part is still valid but only for that aircraft. The only relief in this area is with items classified as "standard" parts.

W1

[NutLoose]

You could ask the CAA, they may be able to suggest an alternate, or contact the company on your behalf,

I would also register on the Flypast forums as a lot on there deal with older aircraft and the oddballs see

Historic Aviation - Key Publishing Ltd Aviation Forums (http://forum.keypublishing.com/forumdisplay.php?f=4)

[MurphyWasRight]

Murph...
No, that wouldn't be an option. On this side the definition is very specific in that to fall under "owner produced" part it must be installed on the owner's aircraft.

My plot was to remove the serviceable OEM part from the American AC and replace it with the owner fabricated part which would meet the above conditions.
Then the used but OEM part should be acceptable for the OP AC.

[wigglyamp]

Submit a Form 32 Minor change/minor repair to EASA stating that no TC support is available and gain approval to fabricate the part that way. Then give the approved data to an EASA Part 21G so they can make the part and issue a Form 1. I'm trying this route right now to release a used part from an accident-damaged aircraft for use on something where there are also no OEM parts available.

[jxk]

My understanding is that you could have the part manufactured if you have the drawing - but I think that the OP said he didn't or couldn't get it.

[wigglyamp]

My reasoning behind the Form 32 route is to get a drawing approved to make a new part -perhaps by reverse-engineering the defective part. It's possible EASA could reject the Form 32 as they could classify the change as 'Major', in which case a Part 21J design company would have to do the work as a Major change/major repair. In this cas, It will start getting seriously expensive for what could be a very simple component.

[wigglyamp]

Part 21G scopes tend to be quite simple e.g 'Sheet Metal components' or 'wiring Harnesses' so as long as the scope covers the type of part, then the specific part number doesn't need to be on the 21G approval -just needs to be on the approved design data.

[ivor toolbox]

Contact CAA to remind type cert holder of their responsibilities, and maybe try the LAA,
(formerly PFA) if you decide to orphan the aeroplane.

Ttfn

[MLHeliwrench]

In some other cases operators of rare types have got together and created a joint venture. This corporation would seek out the appropriate approval to manufacture certain high wear or short life parts. The group split costs according to how many of the type each company owned. Dealing with the type certificate holder as a group of operators gets things going faster too.

[MurphyWasRight]

Contact CAA to remind type cert holder of their responsibilities,


Although obviously not legaly binding one could try sending the cert holder a set of (reversed engineered) plans with a cover letter stating that lack of response will be considered to be approval.

That might at least get their attention.

Reminds me of a story about hot air balloons, which use Velcro to seal the top of the envolope.
The main stress is taken by a rope laced over the seam, when landing pulling the rope seperates the seam, quickly dumping the hot air and killing lift.

There was a landing accident involving delayed dumping and as usual the (USA) lawyers sued everyone remotely involved including the Velcro manufacturer Dupont.

As a response Dupont sent a classic knee jerk lawyerly letter to all owners of hot air balloons informing them Velcro should not be used in hot air balloons.

This was despite the type cert for the balloons specifying Velcro etc.

An owner who was also a lawyer crafted an equally lawyerly reply stating that per Duponts explicit instructions he had removed the Velcro from his balloon and would be updating then after the test flight.

[Edgar Jessop]

As wigglyamp indicates the legal way to do this, if you can't get the OEM parts, is to get a 21J to draw up a scheme for the required part and get a contracted 21G to manufacture it. The problem you may have is getting a 21J to agree to do this, as it's clearly a critical part and the question they will raise is how do they prove their design will be safe to fly without access to the original material specs, surface treatments, stress calcs etc.