Mod Works Inc.

[MisfitSELF]

2 hours ago, EricJ said:

I still think a reasonable avenue to pursue is to get the FAA to declare the STCs abandoned.   It takes time for that to get through the pipeline, but the sooner somebody starts it the sooner it gets done.   If it doesn't get declared abandoned there should at least then be contact info for whoever responded to the FAA.

Again -- an "abandoned STC" doesn't help me -- just read through this lengthy thread.  It will not give me approval to install it on my aircraft when I never had the approval in the first place.   Getting it declared "abandoned" only allows the FAA to provide the engineering data to current STC holders for the purpose of continued airworthiness.  The FAA can't give away something they don't own -- in this case the "rights" to the design and the "rights" to sell it still belong to Mod Works.  Per 91.403:  A person must not alter an aircraft based on a supplemental type certificate unless the owner or operator of the aircraft is the holder of the supplemental type certificate, or has written permission from the holder.

[PT20J]

Maybe you need to hire a private investigator to track him down. 

[EricJ]

9 minutes ago, MisfitSELF said:

Again -- an "abandoned STC" doesn't help me -- just read through this lengthy thread.  It will not give me approval to install it on my aircraft when I never had the approval in the first place.   Getting it declared "abandoned" only allows the FAA to provide the engineering data to current STC holders for the purpose of continued airworthiness.  The FAA can't give away something they don't own -- in this case the "rights" to the design and the "rights" to sell it still belong to Mod Works.  Per 91.403:  A person must not alter an aircraft based on a supplemental type certificate unless the owner or operator of the aircraft is the holder of the supplemental type certificate, or has written permission from the holder.

This was clarified previously as well.   The FAA can release the approved data to a requester without the approval of the owner.   This is specifically described in the FAAs procedures and is essentially the reason for the abandonment status.

[MisfitSELF]

1 hour ago, EricJ said:

This was clarified previously as well.   The FAA can release the approved data to a requester without the approval of the owner.   This is specifically described in the FAAs procedures and is essentially the reason for the abandonment status.

But that doesn't give me permission to install on my tail number.  This process doesn't get around FAR Part 91.403.

Essentially it would be "great, I have the engineering data --- now what?  Start the process to generate my own STC?"  I think I'm better off seeing if I can get a field approval as my next step.

Edited February 16, 2023 by MisfitSELF

[RobertGary1]

18 minutes ago, MisfitSELF said:

But that doesn't give me permission to install on my tail number.  This process doesn't get around FAR Part 91.403.

Essentially it would be "great, I have the engineering data --- now what?  Start the process to generate my own STC?"  I think I'm better off seeing if I can get a field approval as my next step.

Use the engineering data to support your 337. 

[PT20J]

42 minutes ago, MisfitSELF said:

Again -- an "abandoned STC" doesn't help me -- just read through this lengthy thread.  It will not give me approval to install it on my aircraft when I never had the approval in the first place.   Getting it declared "abandoned" only allows the FAA to provide the engineering data to current STC holders for the purpose of continued airworthiness.  The FAA can't give away something they don't own -- in this case the "rights" to the design and the "rights" to sell it still belong to Mod Works.  Per 91.403:  A person must not alter an aircraft based on a supplemental type certificate unless the owner or operator of the aircraft is the holder of the supplemental type certificate, or has written permission from the holder.

Do you have a copy of the STC and AML? I would think that a lot of IAs would sign a 337 with that documentation without the permission letter. The letter, while required, is often perfunctory. Many STC holders just publish a blanket form letter that's not specific to any aircraft. I have a number of STCs from previous owners in my airplane file and I don't have copies of the permission letters for some of them. Owners that don't understand record keeping don't keep a lot of documentation that they should because they think the logbooks are all that is required. No one inspecting my airplane has ever asked me for the permission letters for the STCs installed. 

Now, if you don't have a copy of the STC and AML, that's a different problem because the IA will not have any way to ascertain that the mod was approved for your make and model.

Skip

[Schllc]

On 12/4/2022 at 7:45 PM, T. Peterson said:

incompetent bureaucracy.

That is redundant….

[EricJ]

1 hour ago, MisfitSELF said:

But that doesn't give me permission to install on my tail number.  This process doesn't get around FAR Part 91.403.

Essentially it would be "great, I have the engineering data --- now what?  Start the process to generate my own STC?"  I think I'm better off seeing if I can get a field approval as my next step.

The restriction noted in the FAA guidelines is that the data cannot be used to develop a new STC, but you don't need to do that unless you want to sell it to other people.    If you want to use it as the approved data for a 337 to modify your own airplane,  that appears to be well within the guidelines and intent of the abandonment status. 

[LANCECASPER]

On 2/15/2023 at 5:10 PM, jlunseth said:

I have been on Mooneyspace for probably eleven or twelve years now. I remember this topic coming up way back then, and every two or three years since. Stories are all the same. I don't know Coy Jacobs so have nothing to say about the shop or the quality of work. What I can say is that many people have been looking for the STC's for a long time and no one has found them yet, or even a trail in the right direction. One of the things about STCs for better or worse is that in the case of things like the 261 (or 2) conversion, the work may be limited to the original STC owner. Not sure the STCs if they exist could be transferred any longer. Best of luck, let us all know if you find anything. 

But if you are thinking of the 261(2) conversion, my question would be why? The cost is probably so high today that you should just sell your 14v 231 and buy a 252 or  Bravo.

Don't get me wrong, I love my 231. But for my money the conversion today would not be worth it. You would still not have a 28V system. 

Exactly!

27 years ago this was a very expensive conversion. Back then TSIO360 factory reman engines were in the $30,000-$35,000 range - now it's double that. Labor was around $50 an hour, now it's at least double that. Plus the cost of the STC back then, which is not available today. Even if a person did find a legal way to do it they'd have as much into it as a 252 and it's still not a 252 when they go to sell it one day. There are many reasons that the 252 carries a premium over the 231 - the MB engine, a lot of airframe improvements  and of course having an electrical system that will run everything you want at the same time. I had a 231 from 1993-96 and even considered this conversion back then. By the time I would have done the conversion, put in a new interior and painted the airplane and minor upgrades to the panel I would have had close to $235,000 into it, which would have been crazy. Financially I would have been buried into that airplane, never even coming close to be able to sell it for what I had into it.  I 1996 I ended up buying a factory demo Bravo for $335,000 with a warranty and never regretted it. The panel was light years ahead of what I had in the 231. Several years later when I sold the Bravo I got 88% of what I had into it - and that was me selling it to Jimmy Garrison. I could have got more for it had I retailed it. Jimmy liked the airplane so much he flew it for at least five years. (Ironically the next owner of my 231 did exactly what i wasn't willing to do - a 262 conversion with new interior, panel and paint)

[Schllc]

It appears to just be the normal learning curve. 
When you enter aviation, it’s hard to believe just how onerous and obtuse the rules are for things.
I bought a g1000 ovation before I got my ppl, and a I remember all the patient people explaining to me why I couldn’t just bolt a turbo or turbo engine onto my plane. 
The scale of the market, along with some of the idiotic rules in the FAR’s, is just very different from anything else in our world. 
What often seems simple and logical, is complex and impossible, not to mention financially unjustifiable. 

[jlunseth]

On the 337 issue, the truth is you would probably not get a 337 for the conversion. I have direct, recent experience. The FSDOs recently are taking a harder stance on 337s, especially where an STC already exists. The one I tried to do was to put a backup alternator on my engine in place of the vacuum pump. It was not approved. In part, the FSDOs do not grant 337s where there is an STC because they are protecting the party that got the STC. In part, they are trying to move people towards the STC process.

[N201MKTurbo]

47 minutes ago, jlunseth said:

On the 337 issue, the truth is you would probably not get a 337 for the conversion. I have direct, recent experience. The FSDOs recently are taking a harder stance on 337s, especially where an STC already exists. The one I tried to do was to put a backup alternator on my engine in place of the vacuum pump. It was not approved. In part, the FSDOs do not grant 337s where there is an STC because they are protecting the party that got the STC. In part, they are trying to move people towards the STC process.

The FAA said they hate it when you just send in a 337 for a field approval out of the blue. Especially when you have already have done the modification. They would like you to contact them first and work out the details of the field approval ahead of time. They should know the 337 is coming around before it gets there. Not all 337s require an FAA signoff, but a field approval does.

[Pinecone]

2 hours ago, jlunseth said:

On the 337 issue, the truth is you would probably not get a 337 for the conversion. I have direct, recent experience. The FSDOs recently are taking a harder stance on 337s, especially where an STC already exists. The one I tried to do was to put a backup alternator on my engine in place of the vacuum pump. It was not approved. In part, the FSDOs do not grant 337s where there is an STC because they are protecting the party that got the STC. In part, they are trying to move people towards the STC process.

Except in this case, the STC will have been declared abandoned, so there is no longer a party to protect.

[PT20J]

I believe @MisfitSELF was only trying to install the flush gear doors which he bought somewhere. 

[1980Mooney]

1 hour ago, PT20J said:

I believe @MisfitSELF was only trying to install the flush gear doors which he bought somewhere. 

I believe you are correct. And you previously asked him if he has a copy of the STC and AML but I don’t see any response. Presumably he has the parts (some or all) but no paperwork- no copy of STC, no AML, no drawings and no instructions. 

[1980Mooney]

2 hours ago, Pinecone said:

Except in this case, the STC will have been declared abandoned, so there is no longer a party to protect.

Except in this case this particular STC has not been declared abandoned. 
 

Per 8110.120 an STC can only be declared abandoned three (3) years AFTER formal request is made in writing. And that is after the FAA has searched for the owner or heirs. If the FAA finds any owner or heir the “abandonment process” is stopped. - ie the STC is Not Abandoned. 
https://www.faa.gov/documentlibrary/media/order/8110.120.pdf

The FAA lists 35 STC's currently owned by Mod Works and they are all listed as "Current".  

Mod Works Inc. exists legally as an "inactive" company.  An "inactive" company means that it still exists in the eyes of the law but that it has no activity taking place.   Until the company is dissolved, it will still exist.  An inactive company still owns its assets (STC's in this case) until dissolved.

Tim Coons is listed as the Chairman, Secretary, Treasurer and Agent.  Lisa Coons is also listed as a Secretary. - see Florida Sec of State or OpenCorporates. 

You can find either Tim Coons or Lisa Coons on the internet. If we can find them then the FAA will find them. And if they pass then the FAA must and will find their heirs.  At that point the STC is NOT ABANDONED. 

 

 

[1980Mooney]

5 hours ago, jlunseth said:

On the 337 issue, the truth is you would probably not get a 337 for the conversion. I have direct, recent experience. The FSDOs recently are taking a harder stance on 337s, especially where an STC already exists. The one I tried to do was to put a backup alternator on my engine in place of the vacuum pump. It was not approved. In part, the FSDOs do not grant 337s where there is an STC because they are protecting the party that got the STC. In part, they are trying to move people towards the STC process.

 

4 hours ago, N201MKTurbo said:

The FAA said they hate it when you just send in a 337 for a field approval out of the blue. Especially when you have already have done the modification. They would like you to contact them first and work out the details of the field approval ahead of time. They should know the 337 is coming around before it gets there. Not all 337s require an FAA signoff, but a field approval does.

Exactly - this STC is not “Abandoned”. It is still “Current” although the company is inactive and the owner apparently is not interested in conducting any business. However it is still intellectual property owned by ModWorks and hence Tim/Lisa Coons. Your mechanic may figure out how to install these gear doors but you/he still need the Coon’s approval to utilize their intellectual property in order to properly install the modified gear doors. @LANCECASPER has been very passionate in other posts about the unapproved use of STC intellectual property as being theft. 

Edited February 17, 2023 by 1980Mooney

[MisfitSELF]

6 hours ago, jlunseth said:

On the 337 issue, the truth is you would probably not get a 337 for the conversion. I have direct, recent experience. The FSDOs recently are taking a harder stance on 337s, especially where an STC already exists. The one I tried to do was to put a backup alternator on my engine in place of the vacuum pump. It was not approved. In part, the FSDOs do not grant 337s where there is an STC because they are protecting the party that got the STC. In part, they are trying to move people towards the STC process.

That is similar feedback to what I got from the Atlanta FSDO office about 2 years ago -- never mind they stated it would take months to years to go through the process of declaring the STC "abandoned"   I keep circling back to my best option being getting a letter from Mr. Coons simply stating I have permission to use the STC.

 

Bruce 

[Pinecone]

1 hour ago, 1980Mooney said:

Except in this case this particular STC has not been declared abandoned. 

The discussion moved to start the process to have the STC declared abandoned.  

[1980Mooney]

2 hours ago, Pinecone said:

The discussion moved to start the process to have the STC declared abandoned.  

You missed my point.  I believe that Timothy Theodore Coons and Lisa Coons and their heirs can be found and contacted.  It is totally the decision of the Coon's (and not the FAA) regarding disposition of their valid current STC's.  If the Coons want to sit on their owned STC's as "current" but not sell any new STC certificates to plane owners, then that is their decision and theirs alone - that is a "business decision".  We don't know the details - it might trigger an old claim, perhaps maybe there is a nasty divorce, and it is jointly owned with neither partner wanting to accommodate the other - it doesn't really matter why. The FAA cannot force people or companies to sell product if they don't want to.  And the FAA cannot steal "intellectual property" from existing people or entitles that want to retain it, just so the FAA can give it away free to people asking that it be declared abandoned.   The Coons can decide if they want to retain the STCs as "current" of alternately "surrender" the STCs to the FAA.  See https://www.faa.gov/documentlibrary/media/order/8110.120.pdf

From 8110.120 Page 18.  It is very clear - if you find the holder then the request to abandon is "NO". No means No - Not abandoned.  The end of the request.

@MisfitSELF makes a good point - try to contact Timothy T. Coons - see his pilot credentials below.  Online searches show he is 62 with addresses and phone in Florida.

Edited February 17, 2023 by 1980Mooney

[Pinecone]

Prove it. Track them down and find out.

It was a SUPPOSITION.

[EricJ]

That's another reason why people who want to use the STCs might want to start a request for the abandonment process.   If any owners or heirs care, they'll have to respond to the FAA to prevent it from becoming declared abandoned.   If nobody responds, then the STCs are declared abandoned and requesters can have access to the data.  If somebody responds, then perhaps whoever responds can be contacted regarding access.  

[jlunseth]

13 hours ago, N201MKTurbo said:

The FAA said they hate it when you just send in a 337 for a field approval out of the blue. Especially when you have already have done the modification. They would like you to contact them first and work out the details of the field approval ahead of time. They should know the 337 is coming around before it gets there. Not all 337s require an FAA signoff, but a field approval does.

We sent the request in before doing the work. “We” was Lasar at my request. The FSDO was aware the request was coming. I am grateful for Lasar’s help but it got us nowhere. We had a prior 337 for the same change that Lasar had done several years ago. The work was never done because we could not get 337 approval.

[captbly]

On 2/17/2023 at 1:48 PM, 1980Mooney said:

You missed my point.  I believe that Timothy Theodore Coons and Lisa Coons and their heirs can be found and contacted.  It is totally the decision of the Coon's (and not the FAA) regarding disposition of their valid current STC's.  If the Coons want to sit on their owned STC's as "current" but not sell any new STC certificates to plane owners, then that is their decision and theirs alone - that is a "business decision".  We don't know the details - it might trigger an old claim, perhaps maybe there is a nasty divorce, and it is jointly owned with neither partner wanting to a

FYI  Lisa is Tim's Sister