2 Attachment(s)
Re: K3 Data Plate Location
Wow, I find this topic fascinating. Not necessarily for the answers it provides but from the standpoint of the personal whims of the inspector – DAR or FAA.
Dave quotes the regs:
45.11 Marking of products.
(a) Aircraft. A manufacturer of aircraft covered under §21.182 of this chapter must mark each aircraft by attaching a fireproof identification plate that—
(1) Includes the information specified in §45.13 using an approved method of fireproof marking;
(2) Must be secured in such a manner that it will not likely be defaced or removed during normal service, or lost or destroyed in an accident; and
(3) Except as provided in paragraphs (d) through (h) of this section, must be secured to the aircraft fuselage exterior so that it is legible to a person on the ground, and must be either adjacent to and aft of the rear-most entrance door or on the fuselage surface near the tail surfaces.
Dave , mounts to the fabric with an additional touch to “D” ring it to the tubing so as not to be lost in case of fire.
Phil does the same minus the “D”ring enhancement.
Kurt and Paul mount to the cover panel below the Elevator. I did as well on both of my airplanes.
Steve mounts his inside visible from the outside.
Jeff was required to mount to a “Structure”
My fist mount location – was on the aluminum closeout. This time the closeout is fiberglass as is Jeff’s vertical stabilizer fairing mount.
My thoughts: I am neither a DAR or FAA, but in my strict reading of 45-11 , Steve’s mount is the only one that violates the reg. as it is inside the aircraft vs. on the "aircraft fuselage exterior. But it was done per the DARs recommendation.
What is it with the total lack of consensus with the powers that be?
I just did a quick scan of the photos I took at the fly-ins we used to host. The trend then was to mount to the fabric under the elevator. Second were the mounts on the closeout under the elevator. Example: In 2003 Debra and John McBean came in the factory Red and white “Turbo” Series 6 N702KF – on the fabric under the elevator. Then a new owner brought the “Jimmy Franklin” Speedster N194KS – on the closeout. Both, of course factory creations
The advice to talk to the DAR might be a good idea, but...?
Re: K3 Data Plate Location
I think mine will be going on the tail section with the D ring. Thanks for the input! Saved by U guys again. Someday soon I hope to show you all what kind of plane U built using this Forum. From what I can seen you done a fine job.
Re: K3 Data Plate Location
I think Highwing's comments provide us with lots of food for thought regarding the phiolosophy of Regulatory Requirements on a wide range of subjects, not just this minor issue. - and most of all - how to deal with it.
Partial quote:
"Wow, I find this topic fascinating. Not necessarily for the answers it provides but from the standpoint of the personal whims of the inspector – DAR or FAA......................What is it with the total lack of consensus with the powers that be?"
I think it is a fair assumption that the heirarchy of governance: constitutional, statutory, rule (regulation) and official policy that all DARs and the FAA work under are the same.......it's the differences among individuals and regional offices not the differences within the governing requirements.
So where does this observed variation come from?
1) There is a case which can be made that some regulations are somewhat vague or ambiguous......but that is a minor part of the story.
2) The primary policy we work with in this business is "AC's" Every one of them starts with wording to the effect "This AC describes an acceptable means, but not the only means, to comply with the requirements..." Some of the variation is guided by multiple options within and beyond the AC. When a rule is promulgated it is nearly impossible to know all the possible applications till it is practiced a while so policy is developed to help with the rule.
3) Regulatory Discretion or Enforcement Discretion.....Overall, the FAA keeps it's people on a pretty short leash and those people working in the system are pretty well aware their career preservation depends on staying on that leash. Discretion is a sticky wicket that isn't talked about very much outside of the regulatory community but it can basically be undestood as the reason you don't get a speeding ticket for going 5 MPH over the limit......yes you and 10,000 others were breaking the speed limit but there are bigger badder fish to fry.....There are two types of regulatory/enforcement discretion....a) where the discretion is granted to a regulator by an official policy (such as an AC or internal policy or order); and, b) where there is no sanction - this latter happening is where we can get confused badly because it is basically a case where an inspector doesn't catch something, oversights the issue or may not be completely versed on the requirement in the first place for one reason or another - we're all human to some extent. So we see stuff on the streets which we are pretty sure doesn't comply with the regulations either because an inspector didn't know or because he/she decided it wasn't important.
I think the upshot is pretty clear.......if we are confident we are complying with the letter of the law, rule or policy we have little to be concerned about. If we aren't certain of how the law, rule or policy applies (usually created by the aforementioned confusion of what we observe on the streets), as Highwing & others have mentioned - best to check with the person who will do the inspection (DAR or FAA Staff).
Variation? - my DAR spent 14 hours on the plane - I hear many spend less. One of the reasons I went with the person I did was because he had a reputation for being thorough and extremely supportive and interested in the experimental aircraft business.
Sincerely,
Dave S
KF7 Trigear
912ULS Warp Drive
Re: K3 Data Plate Location
Dave, I agree. I worked for the federal gov for 45 years. Every time a directive came down from Washington us peons on the ground looked to our regional office...the head shed...for direction on how to implement it. They would write a letter to all their district rangers on the...their...interpretation of what the Washington office had said. We called it 'Management by memo".
Re: K3 Data Plate Location
Mine is riveted to the aluminum that closes off the hole under the horizontal stabilizer. And that way the Fox was registered in the states in the beginning (1992).