Bill,
There are a few problems with the FAAs response in establishing LSA status
for your Coupe.
Since the question was addressed through an anonymous (on the FAAs part)
channel, theres no FAA person who takes responsibility for the answer.
They can say anything and blow you off at no risk to themselves.
And, it seems, they kind of did so.
For example, the application for airworthiness certificate the FAA looked at
was dated 4/21/1947 but the plane was manufactured a year and two months
earlier on 2/11/1946. Fortunately, in this one case, that probably wont
invalidate it as an always-was-a-C.
You state that:
> I find no reference to a 337 converting it to
> a "D", no amended Airworthiness Certificate,
> nor a logbook entry.
Thats great and would give me good confidence in your planes status, on
its face. I presume you carefully reviewed the FAA documents CD which is
where (Im guessing) you found the prior registrations claiming D status
and found no form 337 showing conversion.
It looks, in the reply, like the FAA clerk never evaluated your question,
does it meet the requirements of LSA?. The answer to that is certainly
not addressed in the response. Heck, the clerk doesnt even state
conclusively that it is, now, a 415-C just saying that it appears to be
an Ercoupe 415-C! Argh! Bureaucrats!
This letter, Im afraid, wont help the owner in proving legal Sport Pilot
operations in the plane.
What we need is a letter from an FAA official, probably from the FSDO (Im
guessing), saying:
This aircraft was built as a 415-C (or 415-CD).
A review of the records shows that the airworthiness certificate was never
changed to show conversion to any higher gross weight model.
(For some cases:) Though a form 337 was found showing conversion to model
D along with logbook entries to that effect, these do not constitute legal
conversion to model D. Only the inspection and issuance of a new
airworthiness certificate can make this change and this was not done.
(For some cases:) Any registration as a model D was erroneous and has no
effect upon the gross weight of the aircraft.
Therefore, this aircraft meets and has always met the requirements stated in
Part 1 Definitions and Abbreviations, §1.1 General definitions
Light-sport aircraft.
<signed appropriately responsible FAA official>
Without such a letter, some planes are in an ambiguous state. A current
owner may lose the proper value of the plane when selling and might be in
danger of legal or insurance repercussions. An innocent buyer, to whom it
was represented as LSA legal, may have the same loses.
If the FAA has no airworthiness certificate change, then it may be possible
to get a definitive letter from the FAA.
If there is a form 337 on file with the FAA showing a model change and/or
there are logbook entries showing a change, well, good luck. I hope the FAA
goes with the airworthiness certificate is everything option. (Yeah, I
know, logbook entries could get lost.)
We want to protect buyers. We also want to protect the value of current
owners.
JMHO
Ed
Ed Burkhead
http://edburkhead.com/Ercoupe/index.htm
ed -at- edbur???khead.yyy change -at- to @, remove the ??? and change
yyy to com
_____
From: [email protected] [mailto:[email protected]] On
Behalf Of Bill BIGGS
Sent: Saturday, September 12, 2009 6:42 PM
To: [email protected]
Subject: FW: [ercoupe-tech] FW: Is she a C or D FAA Reply
Ed,
You are welcome to post this email.
Bill
_____
To: [email protected]
From: [email protected]
Date: Tue, 17 Jul 2007 10:10:37 -0500
Subject: [ercoupe-tech] FW: Is she a C or D FAA Reply
Here is the FAA reply
Bill
_____
Subject: Re: (Other) - Problem
From: [email protected]
To: [email protected]
Date: Tue, 17 Jul 2007 10:05:09 -0500
According to our records, N87248 appears to be an Ercoupe 415-C serial 421.
The application for airworthiness dated 4-21-47 verifies this.
jv
-----<[email protected]> wrote: -----
To: 9-AMC-AFS750-Aircraft/AMC/f...@faa
From: <[email protected]>
Date: 07/13/2007 11:22AM
Subject: (Other) - Problem
Subject: Problem
Customer Name: Bill Biggs
Customer E-mail Address: [email protected]
Customer Phone: 254-774-8099
Application: (Other)
Aircraft Description: Ercoupe 415C N87248
Comments: I am William Biggs, 211 Runway Ln., Temple,Texas 76504 the owner
of Ercoupe N87248.
I need clarification as to the model of my Ercoupe.
The current registration and Airworthiness certificate list this as being a
415C but some previous registration certificates on record in Ok., City
reference it as a 415D.
I find no reference to a 337 converting it to a "D", no amended
Airworthiness Certificate, nor a logbook entry.
What is the correct model designation of my Ercoupe and does it meet the
requirements of LSA.
Thanks,
Bill Biggs
