Alright, here is a good one for you. Stene in Montana manufactures and
sells very nice fiberglas tips for elevators, stabilizers, wings, and
rudders, mostly for Pipers and Cessnas. You can find these parts advertised
in TAP and on the internet. I have inspected, painted, and installed
several of these fairings and was impressed with their workmanship. They
are very well-made. The plastic parts replaced by these Stene parts are
probably from Cessna. They are probably Royalite. Besides being
ill-fitting and ugly, they are brittle and crack and break of easily,
especially at the rivet holes. After a few years they get brittle and break
away.

An aeroplastics company in Texas sells these fairings too, and they are
PMA'd. I do not know how much more costly they are than Stene's but
understand the extra expense is substantial.

Now why should you be stuck with PMA'd parts when Stene's, which are NOT
PMA'd are just as servicable, just as durable? And if Stene's are not
legal, then how does Stene get off selling them?

Yesterday I looked at a 172 with all new Stene tips on the empennage
surfaces. They were quite beautiful. And, by the way, I saw this
aircraft's sister ship flying with most of the tips broken off and gone back
in the summer, so you can't very well say that the absence of one or more of
these fairings, or one having cracked and broken, is a hazard, can you?

What am I missing here, Gene?

" jls" > wrote in message
...
>
> Alright, here is a good one for you. Stene in Montana manufactures and
> sells very nice fiberglas tips for elevators, stabilizers, wings, and
> rudders, mostly for Pipers and Cessnas. You can find these parts
> advertised
> in TAP and on the internet. I have inspected, painted, and installed
> several of these fairings and was impressed with their workmanship. They
> are very well-made. The plastic parts replaced by these Stene parts are
> probably from Cessna. They are probably Royalite. Besides being
> ill-fitting and ugly, they are brittle and crack and break of easily,
> especially at the rivet holes. After a few years they get brittle and
> break
> away.
>
> An aeroplastics company in Texas sells these fairings too, and they are
> PMA'd. I do not know how much more costly they are than Stene's but
> understand the extra expense is substantial.
>
> Now why should you be stuck with PMA'd parts when Stene's, which are NOT
> PMA'd are just as servicable, just as durable?
>

Because non-PMA parts will cause the aircraft to fall out of the sky without
warning.


>
> And if Stene's are not legal, then how does Stene get off selling them?
>

Probably because no law is broken until the parts are placed in service.

Isn't part of your A&P authority the ability to determine that the
parts you have are identifcal to the original, and therefor approve
them? We don't get PMA's on screws and bolts.

In article et>,
"Steven P. McNicoll" > wrote:

>
> Because non-PMA parts will cause the aircraft to fall out of the sky without
> warning.

unless, of course, the paperwork has been properly completed.

--
Bob Noel
looking for a sig the lawyers will like

On 28 Dec 2004 16:47:05 -0800, "Robert M. Gary" >
wrotD:

>Isn't part of your A&P authority the ability to determine that the
>parts you have are identifcal to the original, and therefor approve
>them? We don't get PMA's on screws and bolts.

An A&P can only install approved parts - that includes screws of a
type approved by the manufacturer. The manufacturer builds the parts
under their manufacturing authority and not via the PMA process.

An A&P does not have the skill set or engineering degree to make that
evaluation. Maybe they are being installed via an STC which is an
engineered and approved package. As long as the A&P follows the STC
he can install them, documenting the work with a 337.

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"Don Hammer" > wrote in message
...
> On 28 Dec 2004 16:47:05 -0800, "Robert M. Gary" >
> wrotD:
>
> >Isn't part of your A&P authority the ability to determine that the
> >parts you have are identifcal to the original, and therefor approve
> >them? We don't get PMA's on screws and bolts.
>
> An A&P can only install approved parts - that includes screws of a
> type approved by the manufacturer. The manufacturer builds the parts
> under their manufacturing authority and not via the PMA process.

I have read that they can install owner manufactured parts?

If this guy says he is an A&P, he's just trolling Don't feed the
trolls. A&P's know not to ask these types of questions. He's from
the manufacturer and is generating interest. Let him go through all
the **** like everyone else and get the PMA.

On 28 Dec 2004 16:47:05 -0800, "Robert M. Gary" >
wrote:

>Isn't part of your A&P authority the ability to determine that the
>parts you have are identifcal to the original, and therefor approve
>them? We don't get PMA's on screws and bolts.

>> An A&P can only install approved parts - that includes screws of a
>> type approved by the manufacturer. The manufacturer builds the parts
>> under their manufacturing authority and not via the PMA process.
>
>I have read that they can install
>owner manufactured parts?

They can but the owner needs to show that the part is identical to the
original. Not better, not different identical. A writer for Lightplane
Maintenance documented how he made is own fiberglass rudder tip for his Cessna
right up to installing it and then removing it on advice from the FAA that it
did not meet their definition of an owner produced part. Of course your FAA
may vary depending on location.

You can of course by and install Stene's parts and in all likelihood most
future A&P IAs will not notice or ignore them. But you or a future owner might
well run into someone who is more than normally observant and determined to
document the condition of the aircraft and the owner might find himself having
to decide all over again if Stene's were really worth it.

John Dupre'

" jls" > wrote in message
...
>
> Now why should you be stuck with PMA'd parts when Stene's, which are NOT
> PMA'd are just as servicable, just as durable? And if Stene's are not
> legal, then how does Stene get off selling them?

What the f*** are you talking about? Stene's parts _are_ PMA'd. From their
web site:

" jls" > wrote in message
...
>
> Now why should you be stuck with PMA'd parts when Stene's, which are NOT
> PMA'd are just as servicable, just as durable? And if Stene's are not
> legal, then how does Stene get off selling them?

What the f*** are you talking about? Stene's parts _are_ PMA'd. From their
web site:

http://www.steneaviation.com/aboutus.html

"Stene Aviation started manufacturing replacement fairings for Cessna
aircraft in 1992 and now have the most complete line of PMA'd parts to be
found outside of Cessna ."

And you call _me_ clueless?

"Juan Jimenez" > wrote in message
...
>
> " jls" > wrote in message
> ...
> >
> > Now why should you be stuck with PMA'd parts when Stene's, which are NOT
> > PMA'd are just as servicable, just as durable? And if Stene's are not
> > legal, then how does Stene get off selling them?
>
> What the f*** are you talking about? Stene's parts _are_ PMA'd. From their
> web site:
>
> http://www.steneaviation.com/aboutus.html
>
> "Stene Aviation started manufacturing replacement fairings for Cessna
> aircraft in 1992 and now have the most complete line of PMA'd parts to
be
> found outside of Cessna ."
>
> And you call _me_ clueless?

Yeah, if Stene's parts are PMA'd, I'm mistaken, and you're still dumb as a
gum stump. And clueless too.

>>I have read that they can install
>>owner manufactured parts?
>
>They can but the owner needs to show that the part is identical to the
>original. Not better, not different identical. A writer for Lightplane
>Maintenance documented how he made is own fiberglass rudder tip for his Cessna
>right up to installing it and then removing it on advice from the FAA that it
>did not meet their definition of an owner produced part. Of course your FAA
>may vary depending on location.
>

What regulation allows someone to manufacture and install something on
their own, or anyone else's aircraft?



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On Wed, 29 Dec 2004 21:21:35 -0600, Don Hammer > wrote:

>
>>>I have read that they can install
>>>owner manufactured parts?
>>
>>They can but the owner needs to show that the part is identical to the
>>original. Not better, not different identical. A writer for Lightplane
>>Maintenance documented how he made is own fiberglass rudder tip for his Cessna
>>right up to installing it and then removing it on advice from the FAA that it
>>did not meet their definition of an owner produced part. Of course your FAA
>>may vary depending on location.
>
>What regulation allows someone to manufacture and install something on
>their own, or anyone else's aircraft?

14CFR 21.303, Replacement and modification parts

(a) Except as provided in paragraph (b) of this section, no person may produce a
modification or replacement part for sale for installation on a type
certificated product unless it is produced pursuant to a Parts Manufacturer
Approval issued under this subpart.

(b) This section does not apply to the following:
(1) Parts produced under a type or production certificate.
(2) Parts produced by an owner or operator for maintaining or
altering his own product.

Ron Wanttaja

Thanks Ron,
I learn something every day. I guess that begs the question of what
happens when that aircraft with that home-made part is sold to someone
else? Where does that leave off? Can I make my own cylinders in the
garage machine shop? If I decided to purchase my own small aircraft,
it would want to make me do a serious pre-buy inspection. I work with
transport category aircraft and we don't make our own parts.

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"Don Hammer" > wrote in message
...
>
> What regulation allows someone to manufacture and install something on
> their own, or anyone else's aircraft?
>

Regulations don't allow things, they prohibit things or set requirements.

On Wed, 29 Dec 2004 22:16:17 -0600, Don Hammer > wrote:

>Thanks Ron,
>I learn something every day. I guess that begs the question of what
>happens when that aircraft with that home-made part is sold to someone
>else? Where does that leave off? Can I make my own cylinders in the
>garage machine shop? If I decided to purchase my own small aircraft,
>it would want to make me do a serious pre-buy inspection. I work with
>transport category aircraft and we don't make our own parts.

Well... I think the phrase "...for maintaining or altering his own product"
pretty much precludes this being done on most transport-category planes. The
*owner* of the plane must make the part. There's no provision for hiring
someone to make the part for them.

This is what may prevent the owner from installing a hardware-store valve under
this clause. The owner isn't "producing" the valve. I suspect the owner could
buy some brass and machine one, but buying something as an off-the-shelf part
would seem to be violating the letter of the regulation.

Ron Wanttaja

Gawd, what a moron...

<plonk!>

" jls" > wrote in message
...
>
> "Juan Jimenez" > wrote in message
> ...
>>
>> " jls" > wrote in message
>> ...
>> >
>> > Now why should you be stuck with PMA'd parts when Stene's, which are
>> > NOT
>> > PMA'd are just as servicable, just as durable? And if Stene's are not
>> > legal, then how does Stene get off selling them?
>>
>> What the f*** are you talking about? Stene's parts _are_ PMA'd. From
>> their
>> web site:
>>
>> http://www.steneaviation.com/aboutus.html
>>
>> "Stene Aviation started manufacturing replacement fairings for Cessna
>> aircraft in 1992 and now have the most complete line of PMA'd parts to
> be
>> found outside of Cessna ."
>>
>> And you call _me_ clueless?
>
> Yeah, if Stene's parts are PMA'd, I'm mistaken, and you're still dumb as a
> gum stump. And clueless too.
>
>

That's not QUITE true, Ron. If you dig into some of the opinions of the
Chief Counsel you will find that if the owner drew up the plans for making
the part, specified the materials and finish, and took it to his local
machine shop where he oversaw the work, (s)he did not have to do the actual
production machining or other processing him/herself.

Jim



"Ron Wanttaja" > wrote in message
...
> On Wed, 29 Dec 2004 22:16:17 -0600, Don Hammer > wrote:

.. The
> *owner* of the plane must make the part. There's no provision for hiring
> someone to make the part for them.

JDupre5762 wrote:
> They can but the owner needs to show that the part is identical to
the
> original. Not better, not different identical.

I've heard that particular opinion before, and it was shared by my
local FSDO. Of course this is the same FSDO that bounced a 337 on the
basis that the manufacturer's installation manual, which was FAA
approved (and labeled as such) and bore a revision number and date
nonetheless did not constitute approved data. As it happens their
opinion on owner-produced parts is no better - it is absolutely
inconsistent with the wording of Part 21, which refers to parts
manufactured to maintain or ALTER (emphasis mine) the owner's product.

Certain repairs/alterations are major, and in those cases the FAA has
decided that since an A&P is not an engineer (usually - and in any case
need not be) he is not to use his judgment in that area, making major
repairs and alterations based only on FAA-approved data (if he can
figure out what that is - clearly just because it says FAA-approved
does not mean the local FSDO will accept it as such). On the other
hand, certain repairs/alterations are minor (by definition - those that
are not major, meaning those not listed in 14CFR43) and in those cases
the A&P is permitted to use his own best judgment as long as the work
is perormed in a manner acceptable to the administrator.

One of our long-time contributors (Jim Weir) has made a business of
selling kits allowing owners to self-produce parts to alter (in minor
ways) their aircraft.

So the bottom line is that something as inconsequential as a plastic
wintip could very reasonably be installed as an owner-produced part.

> A writer for Lightplane
> Maintenance documented how he made is own fiberglass rudder tip for
his Cessna
> right up to installing it and then removing it on advice from the FAA
that it
> did not meet their definition of an owner produced part. Of course
your FAA
> may vary depending on location.

Unfortunately that last sentence says it all. It should not be that
way, but it is. In fact, that's really what makes it impossible to
maintain the old airplanes safely and economically and stay legal. The
FAA is changing.

Years ago, when I had just started working towards my A&P, I
participated in the rebuild of a Champ. It had started life without
electrics. That was fine in 1946 when it was built, and it would in
fact have been legal to keep it operating that way even five decades
later, under the shelf of a major Class B. However, that wasn't what
the owner wanted. He wanted an electrical system, with radio and
transponder - the basic minimum in the closing years of the century. I
put in a radio stack on that airplane, and we got a field approval for
it all. The guy who field approved it had been with the FAA for
decades.

Just a couple of years later, it was time to do it again - the same
mods to the same make and model Champ. However, things had changed.
The FAA inspector who had issued our field approval had retired. The
one who took his place was unwilling to issue a field approval at all -
not even on the basis of the previous field approval. He told us we
were going to have to get an STC.

In the end, the owner found a guy in a different FSDO - another old guy
who was willing to sign off. One day he will retire too.

In the past, the field approval process was the sensible and correct
way to get modern technology into these old airplanes and keep them
flying. When that process existed and worked, there was really no
excuse for installing unapproved parts. The people who administered
the process were old hands, knowledgeable, and would work with you.
That's gone now. Today, the only reasonable options are illegal,
immoral, or fattening. You FSDO-shop hoping to find a way. You do the
installation by dark of night and pretend it's not there. Or you let
the planes fly in their original condition and wonder why
maintenance-related accidents are going up.

Michael

>>They can but the owner needs to show that the part is identical to the
>>original. Not better, not different identical. A writer for Lightplane
>>Maintenance documented how he made is own fiberglass rudder tip for his Cessna
>>right up to installing it and then removing it on advice from the FAA that it
>>did not meet their definition of an owner produced part. Of course your FAA
>>may vary depending on location.
>>
>
>What regulation allows someone to manufacture and install something on
>their own, or anyone else's aircraft?
>
The one that is conveniently made up based upon an interpretation of
what idiots on newsgroups say! I'm sure you'll get a few "soundbites"
or should I say regulations quoted, but they usually don't give you
the entire picture. Again, conveniently. People believe what they
want to believe. ANd didn't I ask you all not to feed the troll that
started this (like I am)?
>
>
> Posted Via Usenet.com Premium Usenet Newsgroup Services
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<< >What regulation allows someone to manufacture and install something on
>their own, or anyone else's aircraft?
>
The one that is conveniently made up based upon an interpretation of
what idiots on newsgroups say! I'm sure you'll get a few "soundbites"
or should I say regulations quoted, but they usually don't give you
the entire picture >><BR><BR>


FAR 21.303 (b) 2

http://www.faa.gov/avr/afs/news/archive/Jul_Aug2002/Parts.htm

http://www.awp.faa.gov/fsdo/ans_jan2_98.htm

http://www.faa.gov/avr/afs/news/archive/julyaugust/IvsWe.htm

AC 21-29

How many more do you want?


--
Dr. Nuketopia
Sorry, no e-Mail.
Spam forgeries have resulted in thousands of faked bounces to my address.

On 08 Jan 2005 08:24:13 GMT, (nuke) wrote:

><< >What regulation allows someone to manufacture and install something on
>>their own, or anyone else's aircraft?
>>
>The one that is conveniently made up based upon an interpretation of
>what idiots on newsgroups say! I'm sure you'll get a few "soundbites"
>or should I say regulations quoted, but they usually don't give you
>the entire picture >><BR><BR>
>
>
>FAR 21.303 (b) 2
>
>http://www.faa.gov/avr/afs/news/archive/Jul_Aug2002/Parts.htm

1st piece of bull**** based on an opinion
>
>http://www.awp.faa.gov/fsdo/ans_jan2_98.htm

and this doesn't mean squat! Tell yo o how to drive but not how to
tay under the speed limit.
>
>http://www.faa.gov/avr/afs/news/archive/julyaugust/IvsWe.htm

And I just guess that the sound bite crew can only read the parts that
they want to read.
>
>AC 21-29
>
>How many more do you want?

What I'd like to see is for you to find and list the section where the
owner needs to make the part of equivalent design and engineering.
Here's a hint. Where does one find the specs on a part? Where does
one find someone who can verify that the new part is within specs?

Now don't shoot the messenger, these rules don't apply to me,
especially when it's my ass in the air and I know I can make a better
part. Just want you to realize that the whole idea is full of hot air
and not actually as legal as you think.

On Sat, 08 Jan 2005 14:07:56 -0500, Gene Kearns
> wrote:

>On Sat, 08 Jan 2005 06:49:00 -0600, Jon A. > wrote:
>
>
>>
>>What I'd like to see is for you to find and list the section where the
>>owner needs to make the part of equivalent design and engineering.


>If you are looking for a "cook book" version of what to do... it
>doesn't exist. The "authorized person" performing maintenance or
>alteration is going to have to exercise some discretion and undertake
>some liability for their actions. That is why many A&P/IAs are totally
>gun shy about making any decisions and ask for FAA 337 approval for
>"minor" jobs. (Which the FAA, by it's own guidance, shouldn't
>approve.) The basic guidance is given in FAR 43.13 and FAR 21.303.

Precisely! That's why everyone feels that as an owner, they're
qualified to "make" a part. Ain't true.

>>Here's a hint. Where does one find the specs on a part?
>
>Very simple. It is either reverse engineered from the original part or
>drawings are procured from the manufacturer or from the FAA via the
>Freedom of Information Act. If you alter a part by making it "better,"
>you'd better make sure your enhancements don't, themselves, cause
>unforeseen problems. And the onus of "better" is on you and the
>installer.

You're on the right track, Gene. But I would like to see you (or
anyone for that matter) get a set of engineering drawings from Cessna,
Piper or Beech using the Freedom of Information Act. The FAA doesn't
have these. Did you ever try to get a set of engineered drawings from
an STC holder? You would have better luck following them as they
drive home to see if they toss any money out of the window.
>
>>Where does one find someone who can verify that the new part is within specs?
>>
>
>Again, very simple. The owner declares the part airworthy (which means
>that it is within specs) and the inspector and/or installer verifies
>same at installation. (Feel a little exposure there????) Otherwise,
>seek approved data via field approval..... then you only have to do
>it like the FAA said was OK....
>

I guess that a DER is just a nobody. Oops, did I just give an answer?


>>Now don't shoot the messenger, these rules don't apply to me,
>>especially when it's my ass in the air and I know I can make a better
>>part. Just want you to realize that the whole idea is full of hot air
>>and not actually as legal as you think.
>
>It isn't as full of hot air as it is potential liability. This is
>really no different than a person or company seeking PMA approval and
>trying to prove that their product is equal to the original part or
>better than the original part and that the alterations meant to
>improve the part don't cause problems themselves. It is a task
>accomplished on a daily basis.

Yes, but not without the pain, endurance and expense.

The only trick is that you can get engineering specs - - - - no, I
just can't give that one away. Too many high powered people will be
real ****ed!

On Sun, 09 Jan 2005 11:42:03 -0500, Gene Kearns
> wrote:

>On Sat, 08 Jan 2005 18:53:48 -0600, Jon A. > wrote:
>
>>
>>You're on the right track, Gene. But I would like to see you (or
>>anyone for that matter) get a set of engineering drawings from Cessna,
>>Piper or Beech using the Freedom of Information Act. The FAA doesn't
>>have these.
>
>Yes, they do.... but you won't get a copy as long as the company is
>in business. You can, however, get drawings via FOA from the
>Guvernmint! Ever wonder how Superior got the drawings on the Lycoming
>engines? Yep..... guvernmint contracts... FOA.
>
>But, you are right. If you want to make a Cessna wing skin, you'll
>have to reverse engineer it.
>
>>Did you ever try to get a set of engineered drawings from
>>an STC holder? You would have better luck following them as they
>>drive home to see if they toss any money out of the window.
>
>Ditto above.
>
>>
>>I guess that a DER is just a nobody. Oops, did I just give an answer?
>>
>
>Yeah.... and that really bothers me. The bean counters at the FAA are
>trying to push as much "approval" off on these designees as possible.
>They know that it simply isn't affordable. (And they say they learned
>their lesson with the DAMIs....)
>
>>
>>Yes, but not without the pain, endurance and expense.
>
>Uh..... you forgot..... reams of paperwork.....

Yawn away and keep believing that by shouting a myth a million times
it'll become true.

On Sun, 09 Jan 2005 21:24:19 -0500, Gene Kearns
> wrote:

>On Sun, 09 Jan 2005 19:44:45 -0600, Jon A. > wrote:
>
>>The only trick is that you can get engineering specs - - - - no, I
>>just can't give that one away. Too many high powered people will be
>>real ****ed!
>>
>
>Really? Yawn.....