Lisas7ECA wrote:They have already cited me.

Yes, its a giant PITA.

Get in touch with AOPA Legal. Seriously. This is BS.

Sorry to hear this....it truly sucks.

MTV

I'm confused..... when did the 11cc come into play?
John

I own a 7ECA which I am told I cannot fly SP as it has a GW of 1732 pounds. For the record, although I have issues with that statement I have not flown it since my medical expired. A friend owns a S11BC which I am told I can legally fly SP as it's GW is only 1350 pounds.

But that's still not mentioning the 11cc. I'm trying to make sure what I said is right, and from reading back, I'm not seeing any reason that what I said isn't.....but then 11cc is mentioned. Did something get deleted, or am I just not seeing? JP256 starts in on STC's and higher gross weights, and none of that was mentioned before?
I'm just trying to make sure I didn't hand out wrong info.
John

Lisas7ECA wrote:I own a 7ECA which I am told I cannot fly SP as it has a GW of 1732 pounds. For the record, although I have issues with that statement I have not flown it since my medical expired. A friend owns a S11BC which I am told I can legally fly SP as it's GW is only 1350 pounds.

So, what did the FAA cite you for??

MTV

In the seventh post, I made a brief comment about the 11CCs GW at 1350 pounds being too heavy to qualify as a SP eligible aircraft.

I didn't state it explicitly, but while I might accept that the 11CC doesn't qualify since A-796, I, lists the GW as 1350. A mere 30 lb over, but over. But the 7CCm was originally certified at 1300 lb and in a later revision the TC was later amended to state the GW "COULD" be increased by adding "Long Stroke Oleo Landing Gear" the fact it "could" didn't constitute a change in GW for aircraft not modified in exactly that way.

The phrases: "As originally certified," "landplane," and "seaplane" do not exist in the regulations they are from the pamphlet which carries no legal authority. Sorta like where the POH disagrees with an FAR, it's just a guide. I have been cited for violating a document without legal authority in a situation where I didn't violate the actual regulation.

Among the incorrect assertions made by the FAA are that while a S11AC is or is not the same as a 11AC on floats... I have both diametrically opposed positions in writing. And the 11CC on 1400s is a S11CC, or it's not according to a different letter. Because apparently the same words mean different things when in A-796 than they mean in A-696.

My view is that A-761, A-758, and A-694 were simply written in slightly different styles, likely by a different person. But even if they don't use precisely the same words, they mean the same thing. These aircraft were certified for use on floats. Taken to it's logical conclusion the FAA's position is that they certify aircraft for something they then aren't legally allowed to do.

Which raises the logical question. If every flight made by every Chief equipped with Edo 1400s was "illegal" back to the day the FAA certified Chiefs to fly on 1400s... How many other pilots have been cited?

If they want to be picayune about the 11AC being in roman numeral "I" and the S11AC being in roman numeral "II," then applying the same precision, none of these aircraft are subject to 14 CFR 1.1 because they don't have stated legal "maximum takeoff weights" they have legal "gross weights."

mtv wrote:So, what did the FAA cite you for??

MTV

Flying with an expired medical.

So, can you explain exactly what happened? You've been quoting the TC and everything, and stated that you got cited for flying with an expired medical. But im assuming that you were flying with what you thought was SP? So you were flying a float plane under the SP gross weight limit? Or what?

I fly for recreation, not as a condition of employment. Some years ago, I enjoyed acrobatics. In time I bought a 7ECA, technically it's a base model Citabria Aurora. Certified acrobatic, it's GW is 1732 pounds. Over time I got to know other folks up in north MN, the UP of MI and northern WI. One owns what we say is a S7CCm based on the: "Serial Nos. Eligible 7CCM-1 and up." and "Same as 7CCM except for increase in maximum weight, float and auxiliary ventral fin linstallation." verbage in A-759." (Note the typo, it returns later.)

I hold an A-SES and a, now-expired, Third Class Medical. The appointment for my most recent physical was cancelled, by the doctor, because under state guidelines set forth in a memo concerning a governor's emergency COVID order it was "non essential." The state courts later held that order exceeded his constitutional authority, but that was after the appointment was cancelled.

The FAA stated that they were not enforcing medical requirements for CPLs and later amended this to include persons whom they deem to "have a need." It does not specifically include any PPLs, although some offices interpret it to. That makes sense, if you are a moron, a guy can fly 140 people to the Bahamas without a medical. I can't fly myself and a fishing pole three lakes over without one.

For the record, in spite of any provably untrue official statements to the contrary, I have not flown my 7ECA since my medical expired. I have flown my friend's S7CCm on numerous occasions, and it was the aircraft I was cited for flying.

It has a GW of 1400 lb, which is less than 14 CFR 1.1's: "1,430 pounds, 650 kilograms, for an aircraft intended for operation on water." The reg doesn't say "seaplane" although the TCDS and LSA pamphlet do, but it's my position that "seaplanes" are by definition "intended for operation on water."

I hold that I am legally flying as a SP under the regs. In a letter the FAA says that 7CCms are not "automatically" made S7CCms by adding floats. Technically that's true, you have to add required fins as well. Which this aircraft does have. I hold that as a licensed pilot with a recently expired medical I can fly as a SP a S7CCm.

A letter says the data plate was not stamped with an "S," so its a 7CCm with a GW of 1350 lb and ineligible. But I see no requirement to stamp a data plate "S" anywhere. Another letter says I need a "FAA Form 8420-2, on which a medical certificate and student pilot certificate are combined," to fly as a SP. And they ask me for a copy, or a letter from my AME, stating they have no record of granting me a 8420-2.

A different letter further states that regardless of whether or not a 7CCm had the long stroke gear installed "the type has has a gross weight of 1350 pounds, which exceeds the LSA maximum for wheeled aircraft." A farsical letter states a 337 was invalid because the A&P "installed" fins and the TCDS said to "linsall" them. Actually it read "linsallation."

A letter says that while "Piper J-2 and J-3; Aeronca Champ; Luscombe 8, 8A, 8B, and 8C; Taylorcraft BC, BCS, and BC-65; Ercoupe 415C and 415 CD; and others as approved are LSA aircraft." A follow up letter lists only new production LSAs, then it further states that I am in error believing that my "7ECA 'Champ' at over 1320 lb GW is LSA eligible, although American Champion does offer a LSA compliant 1320 pound 7EC."

All the FAAs letters are fatally flawed. Perhaps they were written that way intentionally to convey a false narrative for a third party to read. Needless to say, I retained legal counsel a while back.

People around here know me, and I'm paying the mouthpiece, so I don't expect truly objective responses from them.

In fairness, if you are changing the aircraft model designation by adding/removing parts, that should be documented in the log book. To me, changing the designation physically, but not changing the data plate or documenting the change in a logbook makes the plane unairworthy, as it no longer falls under the TC that the data plate states it is in. So they may have a point there. For example, if I take a 150HP Citabria 7GCBC and put HC pistons in it to make it 160HP, the engine is now a different designation and the data plate should reflect that, as well as the logbook.

A log entry similar to this would have solved most of your troubles. "Aircraft designation changed to XXX, I.A.W. TC XXX, by addition of XXX parts".

A1Skinner wrote:In fairness, if you are changing the aircraft model designation by adding/removing parts, that should be documented in the log book.

I would agree if an S7CCm and 7CCm were on different type certificates, but it is the same certificate.

A1Skinner wrote: To me, changing the designation physically, but not changing the data plate or documenting the change in a logbook makes the plane unairworthy, as it no longer falls under the TC that the data plate states it is in. So they may have a point there.

I politely disagree, but at least your argument is logical, the FAA's so-called argument is ludicrous. They don't argue that it's not airworthy, but rather that its still a "landplane," and thus 30 pounds over GW, while it sits on water on floats the TDCS says may be installed.

Of course, they can't argue the aircraft is un-airworthy because then there would be dozens of airplanes and hundreds of violators, which they hadn't noticed in 70 years, instead of just the one.

A1Skinner wrote:A log entry similar to this would have solved most of your troubles. "Aircraft designation changed to XXX, I.A.W. TC XXX, by addition of XXX parts".

This would have been an excellent way to phrase it. But the aircraft is 70 years old and has had a dozen owners and hundreds of pilots. There is an initial log book entry and a filed 337 for the initial installation and rigging of the floats. I don't figure the FAA can be too critical of exact wording, they mispelled "install," and transposed "21.2" into "12.2" saying that a CG range is at 19 to 22 percent of MAC not 22 to 37 percent.

I don't ever claim to be mistake-free. But I can logically articulate a non-self-contradictory decision chain. I have two dozen contradictory letters from the FAA, including more than one where they make blatant factual errors regarding their own registrations and regulations which I can pull up off of their own web site.

The pilots that I know around here interpret 8740s clear authorization of an aircraft owner to remove and replace landing gear items for routine maintenance without an A&P by its nature to permit the removal of wheels and mounting of floats and vice versa. A-759 clearly states that engines may be swapped, but that a new weight and balance must be performed and the data plate must be stamped to reflect this.

Then 759 goes on to say that a landplane may be converted to a seaplane. That wheels and floats may be swapped. It gives weights and arms and states that a new weight and balance must be performed BUT it makes no mention that the data plate must be stamped to reflect this. Possibly because aircraft are frequently swapped back and forth.

Thanks, I do appreciate your input.

Lisa

On the subject of the “S designation” absent from that plane suggesting it’s officially not a seaplane……holy cats! If your attorney hasn’t tumbled to this yet, point out to him that the Piper Super Cub has the same “issue”, only with the “S” in a different spot. In that case, a Super Cub on floats is technically supposed to be a PA-18 S. I’ve flown a lot of Super Cubs on floats, and not one has had the “S designation”, and I’ve never heard of one.

There are differences, of course, which are delineated in the TC. Just as you’ve outlined here in your case.

So, does the FAA assert that when that plane goes back on wheels, the S designator has to be removed from the data plate?

In summary, you’re dealing with morons. I am truly sympathetic. Been there and done that. At least in my cases, they didn’t have the nerve to actually cite me…..just grounded my planes. Which I flew anyway.

The applicability of the medical extension would appear to be moot in any case, because it appears you were legal to fly that airplane under Sport Pilot regs.

Groan! And I didn’t think the FAA could get much dumber. Good luck.

MTV

I guess I'm looking at it a bit differently then you. Yes, you are right, it is on the same TC, but it is under its own paragraph. All of the 7 series, up to and including the 7GCBC are on the same TC as well. To me that doesn't give the legal right to take any previous planes and turn them into a 7GCBC because they are on the same TC.
The W&B envelope is also different from the 7CCM and the S7CCM. So are you carrying a S7CCM flight manual and W&B, or a 7CCM? Small differences, but differences none the less. I hate to agree with the FAA as much as the next guy, but technically they are right, it is a land plane...

mtv wrote:On the subject of the “S designation” absent from that plane suggesting it’s officially not a seaplane……holy cats! If your attorney hasn’t tumbled to this yet, point out to him that the Piper Super Cub has the same “issue”, only with the “S” in a different spot. In that case, a Super Cub on floats is technically supposed to be a PA-18 S. I’ve flown a lot of Super Cubs on floats, and not one has had the “S designation”, and I’ve never heard of one.

There are differences, of course, which are delineated in the TC. Just as you’ve outlined here in your case.

So, does the FAA assert that when that plane goes back on wheels, the S designator has to be removed from the data plate?

In summary, you’re dealing with morons. I am truly sympathetic. Been there and done that. At least in my cases, they didn’t have the nerve to actually cite me…..just grounded my planes. Which I flew anyway.

The applicability of the medical extension would appear to be moot in any case, because it appears you were legal to fly that airplane under Sport Pilot regs.

Groan! And I didn’t think the FAA could get much dumber. Good luck.

MTV

The difference is that the super cub has the exact same W&B envelope for both the 18 and 18S. The 7CCM and S7CCM have different envelopes, which requires different W&B sheets/graphs depending on what model it is configured in. If it's being flown with the wrong data because it hasn't been clarified, and she is following the 7CCM W&B data, then it is technically being operated as a land plane, not float... small petty differences, but still differences. Just sucks that they have finally caught on after many years and she's the one getting caught up in it.

A1Skinner wrote:

mtv wrote:On the subject of the “S designation” absent from that plane suggesting it’s officially not a seaplane……holy cats! If your attorney hasn’t tumbled to this yet, point out to him that the Piper Super Cub has the same “issue”, only with the “S” in a different spot. In that case, a Super Cub on floats is technically supposed to be a PA-18 S. I’ve flown a lot of Super Cubs on floats, and not one has had the “S designation”, and I’ve never heard of one.

There are differences, of course, which are delineated in the TC. Just as you’ve outlined here in your case.

So, does the FAA assert that when that plane goes back on wheels, the S designator has to be removed from the data plate?

In summary, you’re dealing with morons. I am truly sympathetic. Been there and done that. At least in my cases, they didn’t have the nerve to actually cite me…..just grounded my planes. Which I flew anyway.

The applicability of the medical extension would appear to be moot in any case, because it appears you were legal to fly that airplane under Sport Pilot regs.

Groan! And I didn’t think the FAA could get much dumber. Good luck.

MTV

The difference is that the super cub has the exact same W&B envelope for both the 18 and 18S. The 7CCM and S7CCM have different envelopes, which requires different W&B sheets/graphs depending on what model it is configured in. If it's being flown with the wrong data because it hasn't been clarified, and she is following the 7CCM W&B data, then it is technically being operated as a land plane, not float... small petty differences, but still differences. Just sucks that they have finally caught on after many years and she's the one getting caught up in it.

The Super Cub has two different W/B envelopes in the TC for the PA-18. Both apply to the SAME aircraft. Look it up.

Having two envelopes does NOT make it a different airplane.

MTV

mtv wrote:

A1Skinner wrote:

mtv wrote:On the subject of the “S designation” absent from that plane suggesting it’s officially not a seaplane……holy cats! If your attorney hasn’t tumbled to this yet, point out to him that the Piper Super Cub has the same “issue”, only with the “S” in a different spot. In that case, a Super Cub on floats is technically supposed to be a PA-18 S. I’ve flown a lot of Super Cubs on floats, and not one has had the “S designation”, and I’ve never heard of one.

There are differences, of course, which are delineated in the TC. Just as you’ve outlined here in your case.

So, does the FAA assert that when that plane goes back on wheels, the S designator has to be removed from the data plate?

In summary, you’re dealing with morons. I am truly sympathetic. Been there and done that. At least in my cases, they didn’t have the nerve to actually cite me…..just grounded my planes. Which I flew anyway.

The applicability of the medical extension would appear to be moot in any case, because it appears you were legal to fly that airplane under Sport Pilot regs.

Groan! And I didn’t think the FAA could get much dumber. Good luck.

MTV

The difference is that the super cub has the exact same W&B envelope for both the 18 and 18S. The 7CCM and S7CCM have different envelopes, which requires different W&B sheets/graphs depending on what model it is configured in. If it's being flown with the wrong data because it hasn't been clarified, and she is following the 7CCM W&B data, then it is technically being operated as a land plane, not float... small petty differences, but still differences. Just sucks that they have finally caught on after many years and she's the one getting caught up in it.

The Super Cub has two different W/B envelopes in the TC for the PA-18. Both apply to the SAME aircraft. Look it up.

Having two envelopes does NOT make it a different airplane.

MTV

You are correct, I missed the top end loading differences. It may not make it a different airplane, but being on the same TC does NOT make it the same airplane either...
Perfect example, all C180s are on the same TC, you know probably better then most of us that early 180s and late 180s are 2 different animals. Just because they are on the same TC doesn't mean I can flip them between different model designations. Same TC, not the same bird.

A1Skinner wrote: I hate to agree with the FAA as much as the next guy, but technically they are right, it is a land plane...

Which doesn't matter, because the regulation reads "1430 pounds for aircraft intended to be operated on water." It has the straight floats the TCDS specifies, I think it will be operated on water." The FAA should enforce the regulations clear language not some nonsensical interpretation. Failing that they should at least read the regs and not just the pamphlets.

Your argument is logical, but it's not how the regulation reads. In fact taking the FAA's position to it's logical conclusion does the EXACT OPPOSITE of what you state. The FAA doesn't say a PPL can't fly a no "S"-7CCm with floats from a lake. In fact since it's a "landplane" I suppose you don't even need an A-SES, an A-SEL should be just fine. And even though it sits on floats you are legally required to do the weight and balance using the "landplane" W&B figures and be sure to use the "landplane" speeds too.

But there is PROBABLY enough of a margin in the published numbers so you MOST LIKELY won't get into too much trouble doing that. F the laws of physics, the regs say... oops they actually don't... well the guy at the FAA says "you gotta do it this way."

I sent them a letter about this typo 15 years ago: "+17.0, to +21.9, at 1350 lb. +4.9, to +21.9, at 1278 lb. or less."

4.9 inches... 7.7% of MAC... No, it doesn't have a really big canard.

I'm curious how it came to be that you were cited for violating the FAR's?
I haven't heard much about ramp checks in a long time, esp since all the FSDO's seem to be claiming overwork these days.
Did something else happen to put you on the FAA's radar?

Lisas7ECA wrote:

A1Skinner wrote: I hate to agree with the FAA as much as the next guy, but technically they are right, it is a land plane...

Which doesn't matter, because the regulation reads "1430 pounds for aircraft intended to be operated on water." It has the straight floats the TCDS specifies, I think it will be operated on water." The FAA should enforce the regulations clear language not some nonsensical interpretation. Failing that they should at least read the regs and not just the pamphlets.

Your argument is logical, but it's not how the regulation reads. In fact taking the FAA's position to it's logical conclusion does the EXACT OPPOSITE of what you state. The FAA doesn't say a PPL can't fly a no "S"-7CCm with floats from a lake. In fact since it's a "landplane" I suppose you don't even need an A-SES, an A-SEL should be just fine. And even though it sits on floats you are legally required to do the weight and balance using the "landplane" W&B figures and be sure to use the "landplane" speeds too.

But there is PROBABLY enough of a margin in the published numbers so you MOST LIKELY won't get into too much trouble doing that. F the laws of physics, the regs say... oops they actually don't... well the guy at the FAA says "you gotta do it this way."

I sent them a letter about this typo 15 years ago: "+17.0, to +21.9, at 1350 lb. +4.9, to +21.9, at 1278 lb. or less."

4.9 inches... 7.7% of MAC... No, it doesn't have a really big canard.

You are partially correct. Yes, since it's technically a "landplane", it is under the GW limit for LS, as long as it has never had long stroke Oleos put on it. But if you are arguing technicalities, then it could he said that it's not legal to have floats on it since floats are not listed as equipment for the 7CCM, only the S7CCM. This would then require an STC or field approval to put floats on the 7CCM. So then they could cite you for that. Unless the 337 you mentioned earlier is that form, which would make the whole point moot and the TC has no play here. I'm just playing devils advocate to possibly show the other side. I agree that it gets frustrating to deal with the regulators as they flip flop around and miss state many things. But arguing over technicalities often leads no where with them.
Not sure where those station numbers come from, as the TC I'm reading does not match those numbers for the 7CCM or S7CCM.
This is where clear log entries really make the difference. Even though it was moved to floats many years ago, there's nothing in the regs saying that a log entry correcting the issue to state something similar to my post above can't be made at a layer date to rectify the issue. Again, just because both aircraft are on the same TC does not necessarily make them the same aircraft.

You are partially correct. Yes, since it's technically a "landplane", it is under the GW limit for LS, as long as it has never had long stroke Oleos put on it. But if you are arguing technicalities, then it could he said that it's not legal to have floats on it since floats are not listed as equipment for the 7CCM, only the S7CCM. This would then require an STC or field approval to put floats on the 7CCM. Again, just because both aircraft are on the same TC does not necessarily make them the same aircraft.

And so what BASIS would you use to convert that 7CCM to an SCCM, since you argue that the TC says they are different models? That is a specious argument, and if mechanics actually believed that, there would be a lot fewer airplanes on floats.

It is the same aircraft. Install the floats and associated required accessories (Finley’s, etc) and it becomes a SCCM.

You argue the Cessna 180 TC covers a vast range of very different aircraft. That’s true , but in fact, the EDO 2870 floats are approved for EVERY model year, assuming the float kit option is installed. So a 53 180 goes on the same floats, with the same rigging as a 1980 K model. Even though gross weight and many other things changed from model to model.

Per the Type Certificate.

MTV