FAA Order 8100.19

Low&Slow

Ancora imparo
The FAAST (FAA Safety Team) is hosting a seminar at UAF in Fairbanks on Friday, January 25th. One of the topics that will be covered is concerning a new piece of regulation that has just been released concerning “destroyed aircraft.” The details of these new rules are outlined in FAA order 8100.19. It contains some phraseology and limitations on aircraft repair that could heavily affect operations and General Aviation.
The author of this FAA order will be giving a presentation at the seminar, which should give a little more clarity to how they plan to make these determinations, who will have final say, how the process will be initiated/followed through with, and who will be in charge of enforcement.
The basic premise is that the FAA is trying to come up with (and essentially has already issued) a method for determining when an aircraft is damaged to a certain degree that the aircraft can no longer be “repaired” and the data tag must be surrendered to the FAA or sent back to the original manufacturer for “rebuild” (often, many of these original manufacturers either no longer exist, or no longer support the models in question). In many cases for super-cub type aircraft, for example, this would result in permanent deregistration of the aircraft in question. These permanent casualties to such a small pool of registered aircraft will no doubt have long-term negative implications especially in places like Alaska.

AK FAASafety Seminar.jpg
 

ppragman

FLIPY FLAPS!
The FAAST (FAA Safety Team) is hosting a seminar at UAF in Fairbanks on Friday, January 25th. One of the topics that will be covered is concerning a new piece of regulation that has just been released concerning “destroyed aircraft.” The details of these new rules are outlined in FAA order 8100.19. It contains some phraseology and limitations on aircraft repair that could heavily affect operations and General Aviation.
The author of this FAA order will be giving a presentation at the seminar, which should give a little more clarity to how they plan to make these determinations, who will have final say, how the process will be initiated/followed through with, and who will be in charge of enforcement.
The basic premise is that the FAA is trying to come up with (and essentially has already issued) a method for determining when an aircraft is damaged to a certain degree that the aircraft can no longer be “repaired” and the data tag must be surrendered to the FAA or sent back to the original manufacturer for “rebuild” (often, many of these original manufacturers either no longer exist, or no longer support the models in question). In many cases for super-cub type aircraft, for example, this would result in permanent deregistration of the aircraft in question. These permanent casualties to such a small pool of registered aircraft will no doubt have long-term negative implications especially in places like Alaska.

View attachment 46320
This is hot garbage. I wish I had time to go up and rant about this.

Why the hell shouldn't you be able to reconstruct an airplane from the data plate?
 

Roger Roger

Paid to sleep, fly for fun
This is hot garbage. I wish I had time to go up and rant about this.

Why the hell shouldn't you be able to reconstruct an airplane from the data plate?
I know. They really should have some data backing this that shows a safety issue with heavily repaired (can’t use the term rebuilt) aircraft. But of course, that data doesn’t exist, because there isn’t a safety concern. AFAIK it’s purely a power play.
 

ppragman

FLIPY FLAPS!
I know. They really should have some data backing this that shows a safety issue with heavily repaired (can’t use the term rebuilt) aircraft. But of course, that data doesn’t exist, because there isn’t a safety concern. AFAIK it’s purely a power play.
I actually just skimmed the order - lots of "concerns" but very little actual information. My favorite quote:

Destroyed aircraft are sometimes approved for return to service after the replacement of all primary structures. In contrast to a new aircraft manufactured from new certified parts under an FAA production approval, the reconstruction of a destroyed aircraft typically includes used and new replacement parts from various sources. Aircraft “repaired” in this manner without the rigorous quality systems of a production certificate may not fully conform to the product’s type design. Without rigorous control of the repair designs and procedures, such aircraft could pose a significant safety hazard to operators and should not be approved for return to service.
Lots of "should" and "could" and no f-ing data.

I really truly wish we had our own aviation authority up here. Things would (shockingly) be far better.
 

trafficinsight

Well-Known Member
This is hot garbage. I wish I had time to go up and rant about this.

Why the hell shouldn't you be able to reconstruct an airplane from the data plate?
Because this is George Washington's axe... The head has been replaced three times and the handle has been replaced four times but this is George Washington's axe!



Sent from my Moto Z (2) using Tapatalk
 

Roger Roger

Paid to sleep, fly for fun
Because this is George Washington's axe... The head has been replaced three times and the handle has been replaced four times but this is George Washington's axe!



Sent from my Moto Z (2) using Tapatalk
I mean, I get it. I just don’t see that it’s a problem. And if the Feds are worried about substandard work from the folks that build new Cub wings or who are repairing steel tube fuselages, they need to crack down on that through their PMA and CRS management. But you know, and I know, and probably they know, that the wings coming out of Univair and the fuselages that Atlee Dodge repairs are better than the ones that came out of Piper 60 years ago.
 

Crop Duster

E pluribus unum
The FAAST (FAA Safety Team) is hosting a seminar at UAF in Fairbanks on Friday, January 25th. One of the topics that will be covered is concerning a new piece of regulation that has just been released concerning “destroyed aircraft.” The details of these new rules are outlined in FAA order 8100.19. It contains some phraseology and limitations on aircraft repair that could heavily affect operations and General Aviation.
The author of this FAA order will be giving a presentation at the seminar, which should give a little more clarity to how they plan to make these determinations, who will have final say, how the process will be initiated/followed through with, and who will be in charge of enforcement.
The basic premise is that the FAA is trying to come up with (and essentially has already issued) a method for determining when an aircraft is damaged to a certain degree that the aircraft can no longer be “repaired” and the data tag must be surrendered to the FAA or sent back to the original manufacturer for “rebuild” (often, many of these original manufacturers either no longer exist, or no longer support the models in question). In many cases for super-cub type aircraft, for example, this would result in permanent deregistration of the aircraft in question. These permanent casualties to such a small pool of registered aircraft will no doubt have long-term negative implications especially in places like Alaska.

View attachment 46320
Keep those data plates. There's a dark market for them in certain backwaters.
They're a bit like Jesus for aircraft. Once you've seen a written off aircraft born again, you'll get the faith.
 

z987k

Well-Known Member
While it is a bunch of crap, it's only an order, which isn't the hardest thing to challenge.

I haven't seen anything from AOPA or the EAA on this though.
 

z987k

Well-Known Member
This is hot garbage. I wish I had time to go up and rant about this.

Why the hell shouldn't you be able to reconstruct an airplane from the data plate?
I like how they put the Alaska one in Fairbanks, far from all the major airframe and wing re-builders. If it were in ANC, you wouldn't be able to get in the building and they'd be chased off with pitchforks.
 

ppragman

FLIPY FLAPS!
I like how they put the Alaska one in Fairbanks, far from all the major airframe and wing re-builders. If it were in ANC, you wouldn't be able to get in the building and they'd be chased off with pitchforks.
I would have literally made a sign like I did for the last protest I was, and heckled them.
 

z987k

Well-Known Member
I would have literally made a sign like I did for the last protest I was, and heckled them.
All this really does is mean you have to fudge a bit in the logbook.

"The FAA does not consider an aircraft to be repairable if all primary structures of the aircraft must be replaced. Replacement of some major components of an aircraft would be considered a repair, but replacement of all of the primary structures of the aircraft is not a repair but a replacement of an aircraft"

So long as one of the primary structures is repairable, you can replace the rest. This really just means you need a data plate and a repairable structure. What 4130 fuselage isn't repairable? Aside from a 200mph CFIT, every 4130 cage I've seen is "repairable". I mean hell, if a single tube isn't bent, "repair" the rest of them.
 
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