New FAA program: Vintage Aircraft Replacement and Modification Article (VARMA)

[aviatoreb]

9 hours ago, EricJ said:

The M20 series was certificated in 1955.   The M20K was added to the TCDS in 1978.

Wow!!!! This is awesome!  For all of us then

[Pinecone]

11 hours ago, hammdo said:

Owner Produced Parts - was a hot topic for a while on here…

-Don

One instance where there was a issue with the FAA due to how it appeared.

Otherwise OPP are fine.

[carusoam]

It’s a sign…

Even the FAA is down with OPP!!!  

- Naughty By Nature  (for the full lyrics…)

 

-a-

[0TreeLemur]

On 4/8/2023 at 1:02 AM, aviatoreb said:

Wow!!!! This is awesome!  For all of us then

Yes!  Fantastic news for us all!

[cliffy]

As a caution one should read the entire VARMA article (as hot linked in paragraph 1)

to understand the hoops one must pass through to get a substitute part approved for use.

You just can't run out to NAPA and buy a fuel pump and put it in. 

There is a procedure and it has to go through the local ACO.

[jetdriven]

So the local ACO simply ignores it. 

[cliffy]

Could be

 

Remember these are all CAREER bureaucrats who are very reluctant to do anything that could come back to them. 

Edited April 10, 2023 by cliffy
add

[EricJ]

1 hour ago, cliffy said:

As a caution one should read the entire VARMA article (as hot linked in paragraph 1)

to understand the hoops one must pass through to get a substitute part approved for use.

You just can't run out to NAPA and buy a fuel pump and put it in. 

If it meets all the requirements you can, via the pre-existing ACs that are cited in the document.  It's nothing new.   As @N201MKTurbo mentioned, an FAA rep described this at a recent IA seminar, i.e., buy parts from NAPA, put them on your airplane.   You do have to verify that they meet requirements, but that's always been the case.

1 hour ago, cliffy said:

There is a procedure and it has to go through the local ACO.

From my reading it appears that this new process is a means for a seller to get parts pre-blessed as being able to be sold for use in vintage aircraft.   Given that there is evidently a process to go through (which I still haven't seen described on a numbered FAA document), it'll cost somebody money to get the approval.   I don't know why somebody would go through that process to get an incremental increase in sales for a low-margin product, but we'll see.

[carusoam]

Signs that the FAA is getting friendlier by the day…

They have always left the door ajar for us…

But we have traditionally forgotten how, or were afraid, to squeeze through it…

Our interest in squeezing through also depended a lot on whether there was a company around that was supporting our needs…  

no need to squeeze through a door if the company is around to make parts AT affordable prices and decent deliveries…

 

Holy cow Mooney International had huge… Budgets…..  

Start a list of parts we are using…

that silly air filter on the vac system that had a big price tag related to the part number that was placed over the original manufacturer’s decal…. Had to go…  

Best regards,

-a-

[EricJ]

15 minutes ago, carusoam said:

Signs that the FAA is getting friendlier by the day…

They have always left the door ajar for us…

But we have traditionally forgotten how, or were afraid, to squeeze through it…

Our interest in squeezing through also depended a lot on whether there was a company around that was supporting our needs…  

no need to squeeze through a door if the company is around to make parts AT affordable prices and decent deliveries…

 

Holy cow Mooney International had huge… Budgets…..  

Best regards,

-a-

One thing that has changed is the shortage of A&Ps, especially for GA, and this is also aggravated by parts shortages/supply chain issues.   So keeping things airworthy has become more challenging, and the FAA seems to recognize this.

[0TreeLemur]

1 hour ago, EricJ said:

So keeping things airworthy has become more challenging, and the FAA seems to recognize this.

They have to acknowledge this or "vintage" piston certified GA dies.  The focus, attention, and money spent on GA today sits squarely in turboprop/turbine land.

[1980Mooney]

The FAA "VARMA" Document link posted by @hammdo seems to be from about 2008 and the FAA circular which governs this posted by @A64Pilot (as noted by him) is from 2009. 

I am struggling to find the "New" in any of this.   Haven't we been living with this "program" as applied for the last 15 years?  So what if a FAA Rep mentioned it in a seminar.

What am I missing?

[1980Mooney]

5 hours ago, EricJ said:

One thing that has changed is the shortage of A&Ps, especially for GA, and this is also aggravated by parts shortages/supply chain issues.   So keeping things airworthy has become more challenging, and the FAA seems to recognize this.

Apples and Oranges.  A shortage of A&P's is unrelated to expensive or hard to find parts.  Sourcing a solenoid from NAPA vs. from Aircraft Spruce or Aviall is not going to change the population of A&P's.  

Are you suggesting that the FAA is going to open the floodgates to allow either Owners or "shade tree mechanics" to conduct and sign off on maintenance and repair of Certified Aircraft?  It is not just A&P's that are in short supply - I would argue that there are very few true automotive mechanics left.  Most are just "parts changers".  The tests are automated, and they just replace parts when the computer tells them.  

[Fly Boomer]

5 minutes ago, 1980Mooney said:

Apples and Oranges.  A shortage of A&P's is unrelated to expensive or hard to find parts.  Sourcing a solenoid from NAPA vs. from Aircraft Spruce or Aviall is not going to change the population of A&P's.  

Are you suggesting that the FAA is going to open the floodgates to allow either Owners or "shade tree mechanics" to conduct and sign off on maintenance and repair of Certified Aircraft?  It is not just A&P's that are in short supply - I would argue that there are very few true automotive mechanics left.  Most are just "parts changers".  The tests are automated, and they just replace parts when the computer tells them.  

I think all the pieces of "the system" are hide bound and slow to change -- FAA, mechanics, and owners.  As someone else pointed out, some of these "changes" were published 15 years ago, and we are just starting to catch up.  It's a little like ignoring the benefits of a borescope, and insisting on a cylinder change (or complete top) if compression gets soft.  I'll bet I can find two mechanics who insist on new cylinders when they get soft for every one you find who uses a good quality borescope, and is a fan of swapping roto-coils and grinding valves in situ.  We are all evolving, but it's slow going.

[A64Pilot]

4 hours ago, 1980Mooney said:

The FAA "VARMA" Document link posted by @hammdo seems to be from about 2008 and the FAA circular which governs this posted by @A64Pilot (as noted by him) is from 2009. 

I am struggling to find the "New" in any of this.   Haven't we been living with this "program" as applied for the last 15 years?  So what if a FAA Rep mentioned it in a seminar.

What am I missing?

Pilots / owners aren’t informed, and that’s understandable as they aren’t in most cases aviation professionals, for the majority it’s a hobby.

Then some high profile person who has a following in social media etc writes an article and suddenly everyone is talking about it

Sometimes this leads to let’s call it misinformation where they hear of something from a professional who has a financial interest and what they hear is skewed towards what they want to hear as well, that increases the money the professional makes or maybe just increases their popularity, popularity is a huge driver, not just money.

So be careful, be sure you read the FAR yourself, carefully. Usually I have to read one several times as I’m not a lawyer.

The FAA isn’t out to “get” any small airplane owners, there is very little public endangerment from owners of Private aircraft and the FAA recognizes this, but every now and again they have to come out and growl to try to put a leash on something when they are led to believe by a complainant that a policy is getting out of hand. Often said complainant also has a financial interest, so the FAA is between a rock and a hard place. Often unless the FAA is made to take action other than the growl, nothing happens.

To actually take action requires a shed load of work for the FAA and frankly most often they had rather not do the work, that’s why if you want something from the FAA, particularly in a timely manner, do all of their work for them, this is why DER’s DAR’s and IA’s exist.

Make an official complaint and the FAA has to address the complaint. As an owner if you register a complaint against an A&P, they WILL get a visit from the FAA, not saying they will be drug off in handcuffs, but the complaint will be investigated, and the results of the investigation will be filed with the complaint and I assume as the complainant you are advised of the results, but never having made a complaint I’m not sure.

The FAA has continually expanded the liability and responsibility an owner can take upon themselves in the maintenance of their aircraft.

Used to be (many years ago) a pilots liability pretty much ceased in how they operated the aircraft, anything broke and the A&P was liable if something was incorrect, now how the pilot / operator have had it maintained it is more in the spotlight too and you can see that in the regs.

Take an OPP for example, you produce a part that later after you have sold the aircraft and this part fails and it could have attributed to an accident.

It’s possible if a lawyer gets involved AND you have significant assets that you may find yourself in court, defending those assets, even if your part was clearly superior to the PEM part. My opinion is the likelihood of that happening is proportional to the size of your assets

As the manufacturer, YOU are responsible, not the actual producer etc.

Other than laziness it’s one reason why I’m not likely to ever build an aircraft, although it’s my understanding that it’s pretty much unheard of for the manufacturer of an Experimental aircraft to be sued, perhaps it’s because of the big experimental placard? Any reasonable pilot has to know it’s was amateur built, but it’s not hard to argue that a buyer wasn’t aware of OPP’s?

 

[aviatoreb]

2 hours ago, A64Pilot said:

Pilots / owners aren’t informed, and that’s understandable as they aren’t in most cases aviation professionals, for the majority it’s a hobby.

Then some high profile person who has a following in social media etc writes an article and suddenly everyone is talking about it

Sometimes this leads to let’s call it misinformation where they hear of something from a professional who has a financial interest and what they hear is skewed towards what they want to hear as well, that increases the money the professional makes or maybe just increases their popularity, popularity is a huge driver, not just money.

So be careful, be sure you read the FAR yourself, carefully. Usually I have to read one several times as I’m not a lawyer.

The FAA isn’t out to “get” any small airplane owners, there is very little public endangerment from owners of Private aircraft and the FAA recognizes this, but every now and again they have to come out and growl to try to put a leash on something when they are led to believe by a complainant that a policy is getting out of hand. Often said complainant also has a financial interest, so the FAA is between a rock and a hard place. Often unless the FAA is made to take action other than the growl, nothing happens.

To actually take action requires a shed load of work for the FAA and frankly most often they had rather not do the work, that’s why if you want something from the FAA, particularly in a timely manner, do all of their work for them, this is why DER’s DAR’s and IA’s exist.

Make an official complaint and the FAA has to address the complaint. As an owner if you register a complaint against an A&P, they WILL get a visit from the FAA, not saying they will be drug off in handcuffs, but the complaint will be investigated, and the results of the investigation will be filed with the complaint and I assume as the complainant you are advised of the results, but never having made a complaint I’m not sure.

The FAA has continually expanded the liability and responsibility an owner can take upon themselves in the maintenance of their aircraft.

Used to be (many years ago) a pilots liability pretty much ceased in how they operated the aircraft, anything broke and the A&P was liable if something was incorrect, now how the pilot / operator have had it maintained it is more in the spotlight too and you can see that in the regs.

Take an OPP for example, you produce a part that later after you have sold the aircraft and this part fails and it could have attributed to an accident.

It’s possible if a lawyer gets involved AND you have significant assets that you may find yourself in court, defending those assets, even if your part was clearly superior to the PEM part. My opinion is the likelihood of that happening is proportional to the size of your assets

As the manufacturer, YOU are responsible, not the actual producer etc.

Other than laziness it’s one reason why I’m not likely to ever build an aircraft, although it’s my understanding that it’s pretty much unheard of for the manufacturer of an Experimental aircraft to be sued, perhaps it’s because of the big experimental placard? Any reasonable pilot has to know it’s was amateur built, but it’s not hard to argue that a buyer wasn’t aware of OPP’s?

 

That seems well said.  So it’s about how lawyers operate and our legal system for such things much more about how the Faa operates that is key.

So I interpret - those with big assets can’t afford to buy cheap parts.

[0TreeLemur]

7 hours ago, 1980Mooney said:

Apples and Oranges.

Yes, but the certified piston GA end of the orchard is in trouble from my perspective- both in terms of mechanics AND parts.  That's all I'm saying.

[EricJ]

8 hours ago, 1980Mooney said:

Apples and Oranges.  A shortage of A&P's is unrelated to expensive or hard to find parts.  Sourcing a solenoid from NAPA vs. from Aircraft Spruce or Aviall is not going to change the population of A&P's.  

They are related in that they both contribute to increasing difficulty in maintaining aging (maybe all) aircraft.

8 hours ago, 1980Mooney said:

Are you suggesting that the FAA is going to open the floodgates to allow either Owners or "shade tree mechanics" to conduct and sign off on maintenance and repair of Certified Aircraft?  It is not just A&P's that are in short supply - I would argue that there are very few true automotive mechanics left.  Most are just "parts changers".  The tests are automated, and they just replace parts when the computer tells them.  

Owners already can conduct and sign off on maintenance and repair of certified aircraft.    It's done all the time.   Any Preventive Maintenance (which is a pretty broad category) can be conducted and signed off by owners/operators.    The Coleal legal opinion letter from the FAA indicates that the list of PM items in Part 43 Appendix A is not comprehensive.   OPP and owner PM can be combined for PM tasks.

[A64Pilot]

20 hours ago, aviatoreb said:

That seems well said.  So it’s about how lawyers operate and our legal system for such things much more about how the Faa operates that is key.

So I interpret - those with big assets can’t afford to buy cheap parts.

That’s just an opinion of mine, just my belief.

But as an example when my Son got run over by a hit and run driver and the driver was caught, first the driver had no insurance and his license had been revoked so no help there, we could easily have won a lawsuit, but as nothing could be collected why spend the money?

Lawyer said these people are “judgement proof” said I could frame the judgement and hang it on the wall because that’s all my Son would get.

So if the asserts are small the Lawyer won’t take the case and if your paying out of pocket they will advise you to not pursue.

I suspect a lot of these lawyer adverts advertising they got 1mil for their client from a distracted driver are BS, they may have gotten a 1 mil judgement, but if the assets aren’t there it won’t be collected

Maule has no liability insurance, hasn’t for years if ever. Story circulates that every few years a team of Lawyers shows up at the factory and I guess takes a look at the books and leaves, Maule doesn’t get sued as the assets just aren’t there.

 

[A64Pilot]

20 hours ago, 0TreeLemur said:

Yes, but the certified piston GA end of the orchard is in trouble from my perspective- both in terms of mechanics AND parts.  That's all I'm saying.

Has been for a long time, I used to think they would just age out, but now I’m thinking at least for complex aircraft lack of parts will be what kills them.

‘Just try for instance to OPP a landing gear actuator.

Piper Cubs and the like will stay alive as long as engine parts exist, but complex aircraft need a supply of complex parts

[aviatoreb]

21 hours ago, A64Pilot said:

Has been for a long time, I used to think they would just age out, but now I’m thinking at least for complex aircraft lack of parts will be what kills them.

‘Just try for instance to OPP a landing gear actuator.

Piper Cubs and the like will stay alive as long as engine parts exist, but complex aircraft need a supply of complex parts

I think the same thing mostly - but the motivated will be able to keep their aircraft going for some time as the less motivated give up their aircraft for dead and they become part donors.

I used to think that piston aircraft would end when the fuel disappeared.

[carusoam]

An example to keep an eye on…

The V-tail Bonanza has been coming up against the grim reaper for some time…

Their magnesium (?) skinned tail feathers seem to be out of production for some reason…

Making hangar rash a death sentence…

The B-society has been offering rewards for a solution…

I don’t know the status on this debacle lately…

Sorry to the brand B guys if I have all of these details mixed up.

Best regards,

-a-

[RoundTwo]

On 4/10/2023 at 11:23 AM, 0TreeLemur said:

Yes, but the certified piston GA end of the orchard is in trouble from my perspective- both in terms of mechanics AND parts.  That's all I'm saying.

I don’t understand what you’re saying. Parts are plentiful and cheap. Just look at how easy it is to fix a charging system problem that uses a 35 yo VR802 regulator. Things couldn’t be any simpler, quicker and cheaper. 

[vorlon1]

13 hours ago, carusoam said:

Their magnesium (?) skinned tail feathers seem to be out of production for some reason…

It's my understanding that Textron is again producing some...

[MikeOH]

12 minutes ago, vorlon1 said:

It's my understanding that Textron is again producing some...

Oh, I'll bet they are quite reasonably priced, too!