September 2, 2001 Eye of Experience #44:
Paperwork |
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The old saying that
September 2, 2001
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| About the Author ... |
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Howard Fried started flying with the Army Air Corps in WWII, where he
served both as a multi-engine instructor pilot and in combat piloting B-17s.
After a stint teaching sociology and on-the-air and management jobs in the
radio business after the war, he turned to teaching flying again full-time.
Over 40,000 general aviation hours later, he is still instructing
and running his own flight school. Along the way he administered over 4,000 flight tests
as a Designated Examiner until victimized by rogue FAA
officials.
He has authored two popular flying books aimed at student pilots and
instructors, Flight Test Tips and Tales and Beyond The Checkride, and a
series of audio tapes, Checkride Tips from
Flying's Eye Of The Examiner.
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 Not
long ago, Rick Durden and I wrote companion columns on the subject of
buying
and selling airplanes. Now it is time to discuss airplane paperwork — the
maintenance records which provide a complete history of everything that has
been done to the airplane since it left the factory as well as a complete
equipment list of all the components and appliances in and on the airplane and
which consist of the aircraft and powerplant (engine) logs and the FAA Forms
337 (Major Alteration and Repair).
Every student pilot is taught the acronym ARROW and they all know what it
stands for (Airworthiness Certificate, Registration, Radio Station License,
Operating Limitations, and Weight and Balance) but very few know the real
meaning of these documents.
As an examiner, I would ask my private applicants to explain just what that
airworthiness certificate "thing" is, who issues it, and how it is renewed. And
I would get some unbelievable answers. Frequently, the answer was, "I
just don't know." I was particularly anxious to hear the answer to the
question, "How is it renewed?" I would accept any one of three
answers: It is never renewed in the sense that a new certificate is issued
upon renewal. This is true, but it is an incomplete answer.
 It is renewed by the certificated mechanic or mechanic with inspection
authority when he/she makes an entry in the aircraft log stating that he or
she has personally inspected this aircraft and finds it to be in airworthy
condition. This is a better answer, but one can then ask, "The mechanic
with inspection authority signed it off as airworthy on January 22. It is now
May 14, and the airplane has flown 87 hours since the sign-off. How do I know
it is airworthy today?"
This leads to the best answer of all: "I renew it. Every time I do a
walk-around pre-flight inspection, I am saying in effect that I have
personally inspected this airplane and find it in airworthy condition for the
operation I intend to perform today."
If I got either answer one or two, I would explain that answer three is the
best as a means of impressing the heavy responsibility that rests on the
pilot, for, after all, he or she is directly responsible for the flight.
Everyone seems to know that this is a certificate issued when an aircraft
changes ownership and that it sets forth the name and address of the entity
that is the registered owner. The registration is pretty straightforward (it
shows to whom the aircraft is registered at the FAA's
Aircraft Registry in the
Aeronautical Center in Oklahoma City) and is frequently used as proof of
ownership.
On this one there seems to be some confusion. The FCC (Federal
Communications Commission) requires that there be a license for every active
transmitter in the United States. Formerly, there was also a requirement that
anyone who spoke word one on the radio, any radio, was required to have at
least a minimum type Restricted Radio Telephone License, but with the advent
of the CB-radio craze, the FCC found this one impossible to police, so the
requirement was dropped (for domestic purposes — if you fly in a foreign
country you still must have one). I found a great many applicants laboring
under the misapprehension that the Radio Station License is also no longer
required, although it certainly can be.
 As in interesting sidelight, it is worthy of note that several years ago,
back when it was a requirement for anyone who spoke into a live microphone on
the air to hold at a minimum a restricted radiotelephone permit issued by the
FCC, the FCC made a nationwide check to see who was in violation. Guess what
they discovered? Pilots were almost all in compliance; truckers and cab
drivers were mostly in compliance. The biggest group of violators was law
enforcement! That's right, every cop riding around in a patrol car and using
the radio was supposed to have an FCC license, but very few did!
There must be documentation aboard the aircraft listing the operating
limitations, and this is another area of great misunderstanding.. The basic
regulation states that for every aircraft built (that specific machine, by
serial number) must have an Approved Flight Manual that includes its operating
limitations and containing sufficient data to work a weight and balance
problem. The regulation goes on to state that in its option the manufacturer
of an airplane with a maximum certificated gross takeoff weight of less than
6,000 pounds may set forth the operating limitations in the form of placards
and markings conspicuously placed about the cockpit in plain view of the
pilot.
Until 1978, Cessna always exercised this option with respect to the C150
and C172, and this posed a problem when they changed to providing an Approved
Flight Manual (AFM). In these older light Cessnas, there would always be a few
sheets of paper with current weight and balance data shoved into a side pocket
(usually down by the left ankle of the pilot) along with the Airworthiness
Certificate and Registration.
When Cessna decided to join the rest of the world (I understand under
pressure from GAMA, the General Aviation Manufacturers
Association), it
created a problem for those of us in the training business. You see, the new
Approved Flight Manuals were exactly like the little Owner's Handbook that
Cessna had always produced. The only difference being that the Approved Flight
Manual is in loose-leaf form so that it can be revised as changes occur, and
the Owner's Handbook is a permanently bound booklet. At our school, and at
many others I'm sure, we supplied each training airplane with a copy of the
Owners Handbook, a supply we were constantly replenishing, for when a student
would gather up his or her material (charts, etc.) after a flight, he/she
would frequently stuff the little Owners Handbook in his/her flight bag and
take it away. Now, however, with Cessna's change in policy, if a student or
renter inadvertently steals one of these things, it is an Approved Flight
Manual, a required document! The solution, of course, was and is to photocopy
the thing, keep the original in the office under lock and key, and place the
copy in the airplane. (More on this subject in a moment.)
 Any airplane that has been in service for any length of time at all will
have several changes to its weight and balance data. These changes usually
show up on the ubiquitous FAA Form 337 (Major Alteration and
Repair), although
a change in the weight may be simply entered in the aircraft log. If an
airplane has been in service for quite a long time, there are likely to be
several changes in its weight and balance data, and it is not always easy to
find the current one. Each time a change is made, whether it be by logbook
entry, 337 form, or otherwise, the mechanic or technician who makes the change
must write in bold letters the word "superceded" (along with the
date and the manner in which the change is entered and his signature and
certificate number) across the last entry showing the last prior change, so
all the pilot must do is find the entry that doesn't say
"superceded" and that's the current weight and balance data.
Of course, finding this is not always easy to do if the airplane is old and
many changes have been made.
Also, it is my understanding that if a component weighing less than six
pounds is added to an airplane a change in the weight and balance data is not
necessary. Whoever makes the change need only note it in the maintenance
records and use the word "negligible" with respect to the change in
weight.
And finally, of course there must be sufficient data aboard the aircraft to
work a weight and balance problem. Whenever there is any change in the
equipment installed in the aircraft, or otherwise something is done to it to
change the weight or its location, an entry must be made in the aircraft
records. A Form 337 usually accomplishes this, but it may be in the form of an
entry in the aircraft log.
The importance of keeping the aircraft paperwork in a safe place cannot be
overemphasized to the aircraft owner. The value of an airplane is greatly
reduced if its paperwork is incomplete, and the task of attempting to recap
the history of an airplane is nothing less than monumental. I cannot recommend
the following procedure strongly enough: Every aircraft owner should photocopy
every single scrap of paper relating to his/her airplane, place the required
paperwork copies in the airplane and keep the originals someplace other than
at the airport!
 In 1998, I bought an airplane that was built in 1957, 41 years earlier, and
one reason I bought it was because it had complete records from day one. I
then set to work photocopying all the paperwork. Believe me, I almost wore out
my copy machine. There was well over 1,000 pages of material. The airplane
has several mods on it, and each has its own STC (Supplemental Type
Certificate), not to mention the numerous upgrades in the avionics over the
years, each of which required a new Form 337 and new weight and balance data.
My friend Jerry Temple, an honorable airplane broker and dealer who
specializes in twin Cessnas, has written a couple of excellent articles on the
care of aircraft paperwork and he maintains that the difference in value
between an airplane with complete paperwork and one without is enormous, and
he is certainly correct.
 Of course anyone who purchases an aircraft has a search of the title done
to make sure that it has a clear title. In this regard, it should be noted
that banks and other financial institutions are in a hurry to record any liens
they may hold, but they are very lax in the discharge of a lien when it is
paid off! As an example, I once was buying an airplane for cash. The title
search showed an outstanding lien that I knew had been paid off several years
earlier. In attempting to contact the lienholder (a small local bank) I
discovered that the bank had either gone out of business, or more likely been
gobbled up by another bank.
It took several weeks of diligent work to locate the new bank, and get them
to issue a release of lien. The lesson here is that when you pay off an
aircraft lien, demand that the lienholder issue you a release of the lien. Be
firm and insistent. You are entitled to this release and it should be recorded
at the aircraft registry at the FAA Aeronautical Center in Oklahoma
City. When
buying an airplane, make very sure that the search shows a clear title. It is
up to the seller to see that this is provided. Then you won't have to go
through what I did in tracking down the lienholder (bank) and demanding that
it issue and record a release of lien.
And remember, a title search only turns up recorded liens. I remember one
time when a lienholder repossessed an airplane that we had leased from the
owner and had on our line. When it was repossessed, some expensive equipment
that belonged to us was installed. The lienholder refused to give these things
back, claiming that they belonged with the airplane. Well, our shop had done
some work on the airplane for which we had not been paid, so I rushed right
out and recorded a mechanics' lien on the airplane and added the value of the
equipment. I subsequently noticed ads with the airplane pictured, and learned
that it had been sold more than once with my lien tagging right along.
Finally, three or four years later, a smart buyer refused to conclude the
purchase of that airplane until the lien was discharged. I was threatened by a
couple of lawyers demanding that I release the lien. I readily agreed, saying
I would do so just as soon as my property was returned and my bill paid. I got
my money and my stuff. Then I released the lien. What all this amounts to is
this: Buyer beware!
 If you own an aircraft, make sure the paperwork is in order and kept in a
safe place. If you are planning to buy an aircraft, make sure the paperwork is
complete and in proper order. And that may not even be enough! I have never
hesitated to buy an airplane with major damage history, provided that it has
been properly repaired. I once bought a less-than-year-old Skyhawk that had
been blown over in a windstorm. All the paperwork indicated that it had been
properly repaired but it never flew quite right. After sending it to the FAA
for a CFI checkride with an applicant, the operations inspector who had
conducted the flight test called out an airworthiness (maintenance) inspector
to look at the airplane. He grounded it, saying that the repairs were badly
botched up and the airplane needed a new wing, flap and aileron. After much
difficulty, and the filing of a lawsuit, we got the shop that did the bad work
to pay to have it redone. The moral here is: All may not be what it seems.
Usual Boilerplate: If you have a comment regarding this column, please post it here rather than
sending it to me by direct email. That way others may benefit from your input.
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