Airworthiness Certificate

[8359]

I purchased my C120 in November. Late January I finally received the registration in my name. With that I also received permission to change the N-Number (the seller wanted to keep the N-Number on there). The N-Number change form gave me instructions to prepare the form in duplicate, mail one into Oklahoma and keep the other with the airplane until I got the new registration. It also instructed me to go into the FSDO to get a new Airworthiness Certificate issued. The Airplane has the original Airworthiness Certificate from 1956 with the original N-Number. I guess when the previous owner changed the N-Number in 2005 he never got a new AWC.

I went into the FSDO today to get a new AWC and ran into an issue. The inspector said that the previous owner had applied for a light sport/experimental certificate in 2005 and it was denied. He said because the AWC I have from 1956 doesn't match the most recent N-Number it isn't valid and he needs to "look into it." He's going to order the Aircraft's file from Oklahoma and get back to me next week. He said not to worry, he didn't think it would be an issue but he needed to verify some things before he issued the new one. He also mentioned they may have to do a walk around at the airport.

Has anyone run into anything like this? I know he told me not to worry, but I am worried I'm going to end up with a paperweight.

[2066]

The "walk around" may morph into a conformity inspection, ensuring (to FAA's satisfaction) that the aircraft conforms with the TCDS. There are more qualified and experienced folks around here to provide more of what to expect, but as I understand it the aircraft will need to "conform" to exactly how it came from the factory, plus any subsequent modifications (...via documented STCs or "field approvals"). That'd probably be a worse case...but, the suggestion that he told you "not to worry" may be a good sign that it'll be a simple (relatively) paperwork action resulting in the new C of A. In any event, the pre-buy you accomplished prior to purchase likely confirmed that all is "legal" and up to date, so it may well be a non-issue anyhow..."not to worry(?)". Keep us posted. Mac

[8340]

No matter what, you will not end up with a paper weight of aluminum. I have not dealt with anything like this but don't fret. On a side note, let me know when he is coming through so my airplane won't be at the airport. Ha ha.

Joshua

[V529]

Well, you've ran into an issue that falls outside the norm............
I would treat this seriously but hope for the best.

I would go back to the offensive a little bit. Try to help yourself.



Do the s/n's on all the paperwork you have match? Does the s/n on the airplane match your paperwork?

"THAT" is the most important thing .......... hopefully in your favor. You might "help your situation" by taking good quality digital photos(N number and Data plate, with legible s/n) and taking them into the FSDO. That may provide them with enough reason to not do a "walk around". When you take pictures also stand back and take some distance shots. As in the fuselage with the N number on the side and your paperwork "readable" in view, so that they can see you are taking pictures of your airplane in your hangar and not "just an airplane". (too many times owners take close ups of their issue and email them to me, I however need a frame of reference, not just a close up of a crack in a door frame lets say. What I need to see where on the entire door frame is the crack located? get the picture? )

This is all about comfort level and making sure the FAA know what and who they are dealing with.

Do you have continuous log books back to day one? Second plus in your favor if so.

No doubt an honest mistake and oversight, but regularly the FAA deals with legitimate fraud and they need to know that Fraud isn't "you".

Try these steps above if you can to prove the airplane is what you say it is.

IF you end up with a visit:
Perception can be reality. This is not the time for missing fuel tank placards(quantity and type of fuel) this is not the time to not have a missing or non existent compass correction card. To have Non TSO'd seat belts. To have oil/fuel/liquids dripping out of the bottom of your airplane.

Do you see my point? You want clean, well presented, well documented airplane to show off. No holes in the instrument panel or loose wires coming out under the instrument panel.

Good log books with nicely done log entries are a plus.

IF you get into a conformity inspection. (I seriously doubt it, but avoid if possible) this is no joke. I do this regularly, about 4-6 a year on heavy twins or business jets that are much newer than our aircraft and usually better documented. I plan on about 40-50 manhours.
Lets help you avoid this scenario.

[4004]

Your inspector is getting educated as how to resolve - with you present , he had to put you off - don't mean to be blunt - but indicator was when he said he had to "order records" from OKC!! FAA FSDO people have direct access to the OKC records immediately online, so possibly he didn't know but should have been trained when hired. Some years ago, a FSDO contact that I had great rapport with ( with both had worked at Langley, me while it was NACA and he about 20 years later when it became NASA and he later went to FAA), and I was searching for certain OKC info on a number of different aircraft and would call him with the N number and he would immediately pull up the record and respond - saved me $$$$. In another situation locally, with a young fellow that I had watched mature and is a lawyer, mentioned to me that he was having a problem with the Texas FAA folks about a high performance experimental aircraft paperwork item. I referred him to my contact and he called while we were standing in the FBO lobby and mentioned my name - saw him few days later and he was smiling ear-to-ear - problem resolved. Just remember that one is not dealing with a "standardized" organization but a government agency with a lot of "individuals'. each with power to make one "unhappy"!

I said all that to let you know what you are dealing with and hopefully you wont have a problem. Sometimes phone calls are better than "walk-ins" to give one time for education - so approach carefully. Do exactly what Victor has recommended with the visual evidence that leaves no mental interpretation of the aircraft. Sounds like your FSDO is so close-by that that may prompt the onsite visit - locally, if they have to travel, travel money can be a problem.

In previous years, our FSDO had an ASI assigned to specific areas but that has changed and now the "Frontline Manager" for airworthiness looks at each incoming item and assigns to whomever he chooses for each case. In mid December I called about a 337 Field Approval and the ASI male who answered the phone explained the flow process but said since I had discussed the tech aspects with him , to go ahead and send directly to him and he would present to Frontline Manager and possibly the FM would allow him to process. On their FSDO roster he is listed as an Avionics ASI and this was not avionics. Bottom line, he did handle and approved as written with prompt return after shutdown.

One more, you as "owner/operator" are certainly in order in pursuing this issue but be extremely careful when mentioning any personal work, san A&P, that you are doing on the aircraft - there again you may do certain maintenance work per Part 43 and other work as long as your A&P is directly supervising your efforts - be prepared to have that contact name available and understood, should an ASI walk up, since they may be near you.


With that, we'll pass the collection plate and have the final hymn and I'll vacate the podium. 2C

PS The guidebook for the ASIs, etc prompts them to seek help within the organization for issues that they don't have experience in.

Edd
Edd

[8359]

Thanks for the feedback and all the tips everyone.

The airplane is in amazing shape, it was fully resorted down to the frame in 2015. I have photos of the entire process from the previous owner. I'm confident if he did a walk around it would be difficult to find anything to complain about unless he was being really picky. But I do hope it doesn't come to that as I know that just opens doors. All the paperwork does match SNs, but I do not have logbooks back to the beginning. I'm missing a few years in the 60s.

He told me his biggest concern was that a light sport/experimental certificate was denied, but he didn't see any record of when it was requested. So he wanted to see if he could track that down and figure out when/why it was requested.

We'll see what happens, he promised me a call back later next week.

Edit: One thing I didn't think about, I believe the data plate has C85 as engine, mine has an O-290-D per STC, is that an issue? Is there a method to updating the data plate?

[6643]

There is no need to update the data plate with the new engine. The STC paperwork "supersedes" the engine information on the data plate. (Make sure the engine data plate matches the records!)

Missing logs from 50 years ago should not be an issue.

At the very beginning of the Light Sport era there was an STC issued (to our own David Lowe) to allow a 120/140 to operate under the Light Sport category, at 1320 gross, by a pilot operating under Light Sport rules. When the final rule came out, after the STC had been approved, it contained wording explicitly prohibiting the modification spelled out in the STC. My guess is this is one of a few planes where the STC was "installed" then never approved.

It may be that the registration number was changed at the same time, and, in the confusion, the Airworthiness Certificate was never updated.

As long as your current Airworthiness Certificate, Registration, data plate and logs all reflect the same serial number, I don't think you have a long term problem.

[8359]

FSDO just called, they are going to issue me a new Airworthiness Certificate. He did not find anything in the file disqualifying the aircraft. He did however say he would need to confiscate the old certificate from 1956 I guess it was supposed to be updated in 1958 but never was so he can't let me keep it. As much as I'd love to have it for the aircraft's file, I don't want to fight him too much on this.

Thanks everyone for the insight!

[2066]

FSDO just called, they are going to issue me a new Airworthiness Certificate. He did not find anything in the file disqualifying the aircraft. He did however say he would need to confiscate the old certificate from 1956 I guess it was supposed to be updated in 1958 but never was so he can't let me keep it. As much as I'd love to have it for the aircraft's file, I don't want to fight him too much on this.

Thanks everyone for the insight!

GREAT news -- thanks for the update!! Mac

[6298]

I looked at several 120’s and 140’s, and most if them are in 1956. I even found one that was 1955. Our airplanes were CAA certified whe they were made. The FAA was formed around 1956 and airplanes were issued FAA airworthiness certificates.
Glad you are getting a new one. Fly!