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The
Type Clubs tent is behind the EAA Vintage Aircraft
Association headquarters at AirVenture. Photo by David
Sakrison |
DERs
— designated engineering representatives—play a crucial role in
keeping vintage aircraft flying. When a vintage airplane needs a
major repair, a field modification, or a newly fabricated part to
replace an original part, the DER is the one who approves the
engineering data, certifying that the data are consistent with or
superior to the original. The DERs are engineers-for-hire, whose
knowledge of a particular aircraft system or structure has been
certified by the FAA. Although they are not FAA employees, DERs help
to streamline the work of the FAA in approving engineering data and
field modifications.
Vintage
aircraft present special challenges for their owners, DERs, and the
FAA. "The expertise on these older aircraft is not in the
FAA," said H.G. Frautschy, executive director of EAA’s
Vintage Aircraft Association. "And that expertise will never
again be in the FAA. The guys at the FAA who had that expertise came
out of the aircraft industry in the 1930s, ’40s, and ’50s when
it was new," he said. "They and their expertise have aged
out of the agency."
The
FAA’s current cadre of DERs is focused mainly on new approvals and
engineering work. And they are typically limited to data approvals
on a particular system or structure.
"You’ll
have an engine DER, a propeller DER, a landing gear DER, an airframe
DER, and so on," said Frautschy. "And if you want to hang
a 90-horse engine on a plane that left the factory with 65 horses,
you might need to hire three DERs to get the engineering approvals—an
airframe DER, an engine DER, and a propeller DER. If you want to
modify the landing gear on an old Aeronca, you might have to hire
the same DER who is an expert in Boeing 747 landing gear struts. For
the owner or restorer," he said, "the cost of hiring those
DERs can be prohibitive."
On
Wednesday at EAA AirVenture Oshkosh, Frautschy met with Kim Smith,
John Colomy, and David Showers of the FAA’s Small Airplane
Directorate to discuss the possibility of certifying a "new
breed" of DERs—"vintage DERs" whose demonstrated
expertise covers an entire vintage airplane. A VDER’s authority
would be limited to one make of aircraft, though a single VDER could
be certified for multiple aircraft. As proposed by VAA, VDERs would
have "holistic" authority to approve engineering data on
any system or structure on the specific aircraft.
"They would
still have to demonstrate their expertise to receive VDER
privileges," said Frautschy, "but the basic structures and
systems designs of these vintage aircraft are covered within the
education of any aeronautical engineer."
"Most
of these [vintage] airplanes were hand-built," Frautschy
explained. "They contain few if any castings or forgings. They
use simple wood or metal structures and relatively simple
engines."
The
people who have the expertise on these airplanes are in the type
clubs, Frautschy said, and their expertise is broader and more
comprehensive than a single system or structure. "It makes
sense," he added, "for the FAA to tap that expertise to
assist owners and the FAA." A large type club like the American
Bonanza Society might have several VDERs with expertise in various
Bonanzas or Bonanza systems, Frautschy said. The Piper Cub Club
might have a "Cub VDER" with spinner-to-tail expertise on
the J-3 Cub. Other type clubs might share one or more VDERs with
broad expertise on a variety of similar airplanes. "The
idea," he explained, "is simply to make the best use of
the vintage expertise that’s already out there."
Small
Airplane Directorate Manager Kim Smith and her colleagues told
Frautschy the idea made sense to them, too. It would reduce
administrative review time at the FAA and would also provide for
continuity, since the same VDERs would be involved in most of the
approvals on a particular type of vintage airplane.
To learn more about
EAA’s Vintage Aircraft Association and about aircraft type clubs,
visit the VAA HQ and the Type Clubs Tent, south of Aeroshell Square
at AirVenture, or visit online at www.EAA.org/vintage.
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