Eye of Experience #44:
The old saying that
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.
...Radio Station License...
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.
...Weight And Balance
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.
Safekeeping the Records
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.
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