[f-AA] Pretty new part

['Botijo G' via aeronca]

Ok too much flack In Facebook. So going back to what works better. New parts to mount the original aluminum wheel pants.
10 days removing fiberglass and bondo from them and now each is pounds lighter. So now with the new parts I can assemble it in a spare gear leg to work on them

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[Richard Murray]

Looks fabulous.

Richard in OH who avoids the FB vortex as much as possible to insure I maintain a healthy attitude.

Sent from an NDB

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['Botijo G' via aeronca]

Thanks I just love the transfer from 1D to 3D specially when I have never seen the original part

Sent from an NDB

On Jun 19, 2025, at 11:54 AM, Richard Murray <murra...@gmail.com> wrote:



[Richard Murray]

Did you have it machined or is that 3D printed

[Mark Peterson]

Sorry that someone pushed back on your excellent machining.   As far as IA approval when I did the Chief it was approved with all the parts at the time of the final inspection an approval for flight.  I was transparent about what was made and the specs for it with documentation.  I didn’t make a fuss over every part.

Sent from my iPhone 

On Jun 19, 2025, at 12:28 PM, 'Botijo G' via aeronca <aer...@westmont.edu> wrote:

 Thanks I just love the transfer from 1D to 3D specially when I have never seen the original part

['Botijo G' via aeronca]

Machined

Sent from an NDB

On Jun 19, 2025, at 12:30 PM, Richard Murray <murra...@gmail.com> wrote:



[Richard Murray]

What did that cost? Would they make a couple more?

[Scott Johnson]

Looks beautiful Raf. Facebook has been great for parts and meeting a few people here and there, but man asking a question is almost pointless. 

Scott, who keeps having a heel brake master cylinder linkage failure on the citabria. 

['RALEIGH RASMUSSEN' via aeronca]

A properly fabricated owner-produced part installed by an A&P mechanic needs no AI involvement unless it is part of a major repair or alteration, which this item obviously is not.

['RALEIGH RASMUSSEN' via aeronca]

Here’s a plain English discussion on owner-produced parts. This article may not mention it, but owner-produced parts are eligible for installation on only that owner’s plane — no one else’s. In other words, ok to sell the plane with the part installed but not ok to sell the part by itself.

 

https://www.aopa.org/news-and-media/all-news/2024/january/09/aircraft-maintenance-owner-produced-parts

[Mark Peterson]

One thing that a EAA forum underscored is that the FAA ruling is really directed to the IA to allow it.  Rather than the owner to produce it.  It gives leeway to approval.  Now if new IAs know Cam 4 rules.

Sent from my iPhone 

On Jun 19, 2025, at 6:10 PM, RALEIGH RASMUSSEN <rale...@comcast.net> wrote:



['Botijo G' via aeronca]

Yeah the faa had a presentation on that not too long ago

Sent from an NDB

On Jun 19, 2025, at 7:56 PM, Mark Peterson <mrpet...@msn.com> wrote:

 One thing that a EAA forum underscored is that the FAA ruling is really directed to the IA to allow it.  Rather than the owner to produce it.  It gives leeway to approval.  Now if new IAs know Cam 4 rules.

['RALEIGH RASMUSSEN' via aeronca]

The regulation is 21.9 (a) (5). It applies to parts for type certificatated aircraft regardless of the certification basis — not just our old CAR 4 aircraft.

[Mark Peterson]

You miss my aim.  It is the IA who has a need to know CAM 4 standards to approve the apart, not just Part 23 that is being trained now.

Sent from my iPhone 

On Jun 19, 2025, at 8:18 PM, RALEIGH RASMUSSEN <rale...@comcast.net> wrote:



['RALEIGH RASMUSSEN' via aeronca]

An AI doesn’t need to approve the part. Doesn’t matter whether the certification basis is CAR4 or FAR 23, the part needs to conform to the OEM specifications.

[Mark Peterson]

But to sign off an annual that the plane is conforming to the TC…

Sent from my iPhone 

On Jun 19, 2025, at 10:16 PM, RALEIGH RASMUSSEN <rale...@comcast.net> wrote:



[Richard Murray]

To be correct our pre-war aircraft do not have Type Certificates. They have Aircraft Specification sheets which prescribed the needed placards the aircraft must display.

AC 23-27 permits the replacement of unobtainium parts.

Owner produced parts can be anything the owner hands to a mechanic to install. The issue of airworthiness then falls upon the inspector.

['RALEIGH RASMUSSEN' via aeronca]

Richard Murray, we must have gone to different mechanic schools; my understanding of owner-produced parts is quite different from yours.

 

Here’s how FAA lawyers interpret the regulations. I’m kind of thick-headed sometimes, but despite reading it repeatedly I cannot find a way to make it square with your comments. 

 

https://drs.faa.gov/browse/excelExternalWindow/FAA000000000LEGALINTPR1991001PDF.0001

 

By the way, I checked a dozen Type Certificate Data Sheets and Aircraft Specifications for Aeroncas from the C-2 through the 15AC.  All airplanes in those Data Sheets and Specifications are Type Certificated, so the legal interpretation applies to them.

[Mark Peterson]

It’s being over thought here.  One, you cannot do a part that is still commercially available as a new part.  The FAA will not disrupt the business.  Second, the part must conform as equal or better than the part it replaced and must conform to the engineering of the original.  Aeroncas are lucky since we have so many blueprints. Third, the owner can supervise a third party to make the part.  Fourth, the ruling is intended to make a path for IAs to approve said part.  That’s it.  Not rocket science.  And yes, you need to know CAM 4 regs at the time of production for Aeronca. That is OEM.

Sent from my iPhone 

On Jun 21, 2025, at 9:11 AM, 'RALEIGH RASMUSSEN' via aeronca <aer...@westmont.edu> wrote:



[Dion]

Raleigh,

The IA does not need to approve the part when it is installed as a minor modification or as a owner produced replacement part BUT, the IA does need to know that part is approved (appropriate to the certification basis for that particular aircraft, ie. CAR 4) when that IA does the annual inspection or that IA may make the assumption that it is an unapproved part.  That being said, I do not have a problem with owner approved parts as long as the documentation is correct and in the aircraft records (logbooks).  I worked hard for and continue to work hard to maintain my IA status and a great relationship with both my local FSDO Inspectors and the aircraft owners for whom I inspect and help them maintain their aircraft in both airworthy and in condition for safe flight.  

Dion Carr

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From: "'RALEIGH RASMUSSEN' via aeronca" <aer...@westmont.edu>
To: "aeronca" <aer...@westmont.edu>, "Mark Peterson" <mrpet...@msn.com>
Sent: Friday, June 20, 2025 12:16:02 AM
Subject: Re: [f-AA] Pretty new part

['RALEIGH RASMUSSEN' via aeronca]

Dion,

 

Thank you for the response; It’s well-thought out and makes perfect sense, although I have some comments about this statement: “. . . the IA does need to know that part is approved (appropriate to the certification basis for that particular aircraft, i.e. CAR 4) when that IA does the annual inspection . . .”

 

If Rafael ensures his part is produced in accordance with the original equipment manufacturer’s drawing and makes a logbook entry attesting to that, shouldn’t that be sufficient assurance to the AI doing the annual inspection that the part meets all applicable airworthiness standards? It seems unnecessary for Rafael or the AI to know the specific, individual CAR 4a airworthiness standards applicable to the part. Hasn’t the airplane manufacturer already verified those airworthiness requirements were accounted for in the design and manufacturing specifications for the part, and were reflected in the drawing? Wouldn’t that same logic extend to other replacement parts produced per an OEM drawing, regardless of the airplane’s certification basis? (Granted the situation is different for a part fabricated per AC 43.13-1 or -2 rather than per an OEM drawing.)

 

If a part fails due to hidden production deficiencies, shouldn’t liability be justly attributed to the part’s producer and not to the AI who signed off the annual?

 

I fully acknowledge there are circumstances where maintainers (and sometimes owners) need to know (or at least be aware of, and able to find) specific airworthiness requirements of the certification basis. This is often the case for major repairs and alterations where no approved data exists, but can also be relevant in more common maintenance situations.

 

That’s my two cents worth. Additional constructive comments from anyone are welcome; I strive to keep learning. Thank you

On 06/23/2025 8:22 PM PDT Dion <dcc...@mediacombb.net> wrote:

 

 

Raleigh,

The IA does not need to approve the part when it is installed as a minor modification or as a owner produced replacement part BUT, the IA does need to know that part is approved (appropriate to the certification basis for that particular aircraft, ie. CAR 4) when that IA does the annual inspection or that IA may make the assumption that it is an unapproved part.  That being said, I do not have a problem with owner approved parts as long as the documentation is correct and in the aircraft records (logbooks).  I worked hard for and continue to work hard to maintain my IA status and a great relationship with both my local FSDO Inspectors and the aircraft owners for whom I inspect and help them maintain their aircraft in both airworthy and in condition for safe flight.  

Dion Carr

 

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From: "'RALEIGH RASMUSSEN' via aeronca" <aer...@westmont.edu>
To: "aeronca" <aer...@westmont.edu>, "Mark Peterson" <mrpet...@msn.com>
Sent: Friday, June 20, 2025 12:16:02 AM
Subject: Re: [f-AA] Pretty new part

 

An AI doesn’t need to approve the part. Doesn’t matter whether the certification basis is CAR4 or FAR 23, the part needs to conform to the OEM specifications.

On 06/19/2025 9:34 PM PDT Mark Peterson <mrpet...@msn.com> wrote:

 

You miss my aim.  It is the IA who has a need to know CAM 4 standards to approve the apart, not just Part 23 that is being trained now.

 

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