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Compliance by copying

Compliance by copying

Compliance by copying

(OP)
Hi

A few years ago I came across an FAA AD that I think grounded an aircraft type (or revoked the TC), because its compliance had been justified on the basis that it was a exact copy of an existing Type Certified Aircraft.

I can't remember the aircraft type and am not having any luck finding it.

Does anyone know which AD it was, or know of a FAA policy document, etc covering this ground.



I should point out this question is due to lovely little mess that I am watching from the side lines.

RE: Compliance by copying

Mac,
Very often a TDC is invalidated if the aircraft design is sold, and production is started again by some other company. When this occurs the TC is issued again as a later revision. A good example of this is Aeronca which has changed hands several times and the TCs have been invalidated, then issued again, with a later revision number. There were some similar goings on with the steel tube and fabric Piper aircraft.
B.E.

You are judged not by what you know, but by what you can do.

RE: Compliance by copying

The basic policy is in FAR 21 isn't it? I don't refer to 21 very often, but the rules governing the issuance, maintenance, transfer, and revocation of a type certificate are spelled out. The production certificate associated with the manufacturer is another matter, but also a prerequisite to the sale of a type certificated aircraft.

If the system works properly, the type certificate holder must "demonstrate to the Administrator" that compliance has been shown to all requirements, and similarity only applies in cases where that same applicant certified the first article to which the next is compared.

STF

RE: Compliance by copying

approved by copied is ok IF you have access to all the original data. The problem usually is "we're using a design that someone else certified", so the design is good (in practice) but you don't know how it was shown to be good, nor what "deals" were done. This is another one of those things that was done in the old days, and probably sometimes it shouldn't've been done.

Quando Omni Flunkus Moritati

RE: Compliance by copying

Brian, T
he TC isn't invalidated, the production certificate is what goes away if the type design is sold or the production facility is moved. The TC will always be in effect. The net is that you can no longer produce the aircraft, or parts if there is no PC in effect. One could produce parts if they were to get PMA for the parts in question.

Helio is an example of an aircraft that the TC was sold and someone tried to make parts based only on the TC. I don't recall an AD, but there was a SUPS (Suspected Unapproved Parts) notice that went out.

I believe both Eclipse and Adam Aircraft both had their TCs suspended for a period, but again, not by AD. A Type Certificate is just like any other certificate issued by FAA. If FAA wants to suspend or revoke a certificate there are specific procedures called out in 14CFR13 that must be followed.

David

RE: Compliance by copying

David,
What about aircraft that do not, have a production certificate, that are produced under TC only, with the FAA inspecting, each one, produced?
B.E.

You are judged not by what you know, but by what you can do.

RE: Compliance by copying

Brian,
You are correct, if one has permission from the TC holder, 1 copy can be produced provided they have all the original data, and can produce their copy to that data. It requires a full conformity of every part in the aircraft. That said, they can't make any spare parts "to sell" unless they have either a PC for the aircraft, or a PMA for the part.

David

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