EAA Comments On FAA Order On ‘Destroyed And Scrapped’ Aircraft


The Experimental Aircraft Association (EAA) filed comments this week on a new FAA advisory circular (AC). The so-called “Destroyed and Scrapped Aircraft” AC makes “heavy reference” to the like-named FAA Order 8900.19, which the association said was issued in 2018 without the opportunity for public comment. According to the EAA, the new AC determines that aircraft deemed destroyed or scrapped cannot be rebuilt.

According to Order 8900.19, a “destroyed” aircraft is defined as having no repairable “primary structures” and a “scrapped” aircraft “has been discarded and disposed of in a manner that it cannot be repaired to an airworthy condition.” EAA wrote that reasonable interpretation of the rule would permit all but the most severely damaged aircraft to receive appropriate repairs and return to service.

However, EAA wrote, “As with any FAA policy, EAA aims to ensure consistent, reasonable application in the field. While we are not aware of significant problems in the use of this policy in the past five years, EAA’s comments to the AC urge the greatest flexibility possible, including the expanded use of designees in determining a damaged or disposed aircraft’s status and developing a plan for return to service.”

EAA said that wider use of designees with extensive practical experience would reduce the workload of already overburdened FAA field offices. “This change would not remove the [Flight Standards District Office] or [Aircraft Certification Branch] from being eligible to review repair data; rather, it would provide an additional option to the builder/repairer to utilize, if desired.”

Mark Phelps
Mark Phelps is a senior editor at AVweb. He is an instrument rated private pilot and former owner of a Grumman American AA1B and a V-tail Bonanza.

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  1. “the new AC determines that aircraft deemed destroyed or scrapped cannot be rebuilt.”

    So planes like the B-29 “Doc” were illegally rebuilt?

    • “b. For an aircraft to be considered eligible for repair, it must have at least one primary
      structure around which a repair can be performed; ”
      I’m sure this was the case with ‘Doc’, so that would constitute a repaired aircraft.