mtv wrote:

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.[/quote]

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[/quote]

I'm not sure you are correct Mike. The J and K models only list 2960 and 2970, and all previous models have the 2870. So no mention of the 2870 on the J and K. Unless there is an STC for the 2870 I don't think they are legal on them, per the TC. Also, every single model has the floats listed in the TC paragraph for each model, which makes it legal per the STC. It also has the "data pertinent to all models" at the end which lists equipment legal for every model. The champ TC does similar, except floats are not listed under the 7CCM...

hotrod180 wrote: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.

Yes, the FAA said the long delay in responding to my discovery motion was due to the amount of work and short staff due to the pandemic.

Odd, those factors didn't prevent them from playing Miss Marple meets Sherlock Holmes. Their initial letter contained statements provably untrue through the FAA's own records. I took an attorney to the informal and the FAA representatives told a story that in key aspects differed from the initial letter.

Then the single record released in the discovery motion contained a third version of what happened.

hotrod180 wrote:Did something else happen to put you on the FAA's radar?

I am not accusing anyone of anything, but I have a previous personal history with one of the inspectors.

A1Skinner wrote: every single model has the floats listed in the TC paragraph for each model, which makes it legal per the STC. It also has the "data pertinent to all models" at the end which lists equipment legal for every model. The champ TC does similar, except floats are not listed under the 7CCM...

The Piper, Taylorcraft, and Aeronca TCDSs are written slightly differently, most likeley they had different authors.

A PA-18 on floats is a defacto PA-18S. A BC-65 on floats is a defacto BCS-65, a 7AC on floats is a defacto S7AC. Nowhere in those three STDCs does it require... Or even permit... the overstamping of a data plate with an "S" to change a model, and it would have to be a pretty small "S" on the T-craft.

NONE of the paragraphs in A-759 give float ITEMS for non "S" aircraft. AC, BC, CC, DC, EC... Have the wheels listed, SAC, SBC, SCC... Have floats listed. Did Aeronca ever built an airplane that left the factory on floats? There are a bunch, where are all the STCs?

If the FAA has been unaware of this persistent lawlessness, a clearly specious option, for its entire 63 year existence of what value is it?

A1Skinner wrote:

mtv wrote:

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[/quote]

I'm not sure you are correct Mike. The J and K models only list 2960 and 2970, and all previous models have the 2870. So no mention of the 2870 on the J and K. Unless there is an STC for the 2870 I don't think they are legal on them, per the TC. Also, every single model has the floats listed in the TC paragraph for each model, which makes it legal per the STC. It also has the "data pertinent to all models" at the end which lists equipment legal for every model. The champ TC does similar, except floats are not listed under the 7CCM...[/quote]

Yes, you're correct on the J and K model 180. That's due to the GW of those planes being too high for 2870s. But, your point emphasizes the fact that there is NO standard format when it comes to Type Certificates. That's somewhat understandable when you consider the length of time involved. But, even airplanes certificated fairly close together have disparities in the TC.

Again, have you ever installed and/or flown a Piper PA-18 on floats? If so, how was it LEGALLY installed, considering your position on the "S" question?

Here's the section of the TC that's pertinent:

"IV. - Model PA-18S "150" and PA-18AS "150", 2 PCSM (Normal Category only), Approved October 1, 1954.Models PA-18S "150" and PA-18AS "150" same as corresponding models PA-18 "150" and PA-18A "150" except landing gear."

So, does that imply that you can just stick the floats on and logbook entry and you now have a PA-18S "150"?

And, by the way, the GW of the SC 150 also increases when it goes on floats....from 1750 to 1760.

I know of one gent who was a judge and owned a SC. Wanted it on floats, and wanted it designated a PA-18S. Mechanics said just bolt on the floats, logbook entry, and go. FAA was totally confused by the request to re-designate the airplane model, and said just do it, essentially. I don't know what they ultimately did there, but the judge did get it "legal" somehow.

Here's the verbiage for the Champ:
VII - Model S7CCM, 2 PCSM (Normal Category), Approved March 15, 1949Same as 7CCM except for increase in maximum weight, float and auxiliary ventral fin linstallation.

Yes, the verbiage in the TC is SLIGHTLY different than that in the Champ TC, but that seems to be true of virtually every TC.

That's why we have mechanics I guess....to figure all this stuff out....maybe.

MTV

mtv wrote:

A1Skinner wrote:

mtv wrote:

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

I'm not sure you are correct Mike. The J and K models only list 2960 and 2970, and all previous models have the 2870. So no mention of the 2870 on the J and K. Unless there is an STC for the 2870 I don't think they are legal on them, per the TC. Also, every single model has the floats listed in the TC paragraph for each model, which makes it legal per the STC. It also has the "data pertinent to all models" at the end which lists equipment legal for every model. The champ TC does similar, except floats are not listed under the 7CCM...[/quote]

Yes, you're correct on the J and K model 180. That's due to the GW of those planes being too high for 2870s. But, your point emphasizes the fact that there is NO standard format when it comes to Type Certificates. That's somewhat understandable when you consider the length of time involved. But, even airplanes certificated fairly close together have disparities in the TC.

Again, have you ever installed and/or flown a Piper PA-18 on floats? If so, how was it LEGALLY installed, considering your position on the "S" question?

Here's the section of the TC that's pertinent:

"IV. - Model PA-18S "150" and PA-18AS "150", 2 PCSM (Normal Category only), Approved October 1, 1954.Models PA-18S "150" and PA-18AS "150" same as corresponding models PA-18 "150" and PA-18A "150" except landing gear."

So, does that imply that you can just stick the floats on and logbook entry and you now have a PA-18S "150"?

And, by the way, the GW of the SC 150 also increases when it goes on floats....from 1750 to 1760.

I know of one gent who was a judge and owned a SC. Wanted it on floats, and wanted it designated a PA-18S. Mechanics said just bolt on the floats, logbook entry, and go. FAA was totally confused by the request to re-designate the airplane model, and said just do it, essentially. I don't know what they ultimately did there, but the judge did get it "legal" somehow.

Here's the verbiage for the Champ:
VII - Model S7CCM, 2 PCSM (Normal Category), Approved March 15, 1949Same as 7CCM except for increase in maximum weight, float and auxiliary ventral fin linstallation.

Yes, the verbiage in the TC is SLIGHTLY different than that in the Champ TC, but that seems to be true of virtually every TC.

That's why we have mechanics I guess....to figure all this stuff out....maybe.

MTV[/quote]

I think we are saying the same thing Mike. That just because a plane is on the same TC does not mean you can convert them to different designations. So if a float is not mentioned on one of the models, how is it legal to put on that model? It would need an STC. If the float, or any accessory is listed in the TC then it's legal to install. Simply stating that it is the same except adding such and such, does not mean you can just add such and such and now have the other model. And just because an accessory is listed on the TC for one of the models does not necessarily make it legal to install on the other models. I've never put a PA-18 on floats. But if an inspector were being very picky, technically you would require an STC as approval for the install. These are reasons I like to be very clear on log entries, and stay on the good side of the people making and enforcing the rules. It's not unknown that the inspectors interpret certain regs differently and can possibly enforce based on their interpretation, lest you spend a bunch of time and money fighting them. I try my best to make sure any history I have with them is good, as I'm sure you do as well.

Well, as I noted, a judge in Fairbanks decided his Super Cub needed to have an "S" designation. The mechanics went round and round with him and the Flight Standards office in FAI, and with the Region. FAA and mechanics said: Not required, and no way to do it. Just stick the floats on and it BECOMES a PA-18S. I never heard how that came out.....maybe the FSDO field approved it. Totally bogus.

There IS no STC for EDO 2000 floats on a Super Cub, and never will be, because they are approved on the TC. The TC is quite clear: The PA-18S is simply a PA-18 with the specified floats installed. I don't know how much clearer English they could have used.

Same goes for that Champ.....

MTV

mtv wrote:Well, as I noted, a judge in Fairbanks decided his Super Cub needed to have an "S" designation. The mechanics went round and round with him and the Flight Standards office in FAI, and with the Region. FAA and mechanics said: Not required, and no way to do it. Just stick the floats on and it BECOMES a PA-18S. I never heard how that came out.....maybe the FSDO field approved it. Totally bogus.

There IS no STC for EDO 2000 floats on a Super Cub, and never will be, because they are approved on the TC. The TC is quite clear: The PA-18S is simply a PA-18 with the specified floats installed. I don't know how much clearer English they could have used.

Same goes for that Champ.....

MTV

Again, I agree. Floats do turn it into a S model, but that change has to at least be documented in the log book and flight manual to ensure the proper coinciding documents are carried.

A1Skinner wrote:

mtv wrote:Well, as I noted, a judge in Fairbanks decided his Super Cub needed to have an "S" designation. The mechanics went round and round with him and the Flight Standards office in FAI, and with the Region. FAA and mechanics said: Not required, and no way to do it. Just stick the floats on and it BECOMES a PA-18S. I never heard how that came out.....maybe the FSDO field approved it. Totally bogus.

There IS no STC for EDO 2000 floats on a Super Cub, and never will be, because they are approved on the TC. The TC is quite clear: The PA-18S is simply a PA-18 with the specified floats installed. I don't know how much clearer English they could have used.

Same goes for that Champ.....

MTV

Again, I agree. Floats do turn it into a S model, but that change has to at least be documented in the log book and flight manual to ensure the proper coinciding documents are carried.

Oh, I agree, at the very least, a float weight and balance must be on board, because empty weight changes, and GW may also. Other things will be determined by the aircraft type.

MTV

A1Skinner wrote:[Again, I agree. Floats do turn it into a S model, but that change has to at least be documented in the log book and flight manual to ensure the proper coinciding documents are carried.

I take it that you're not an A&P/IA. This is basic stuff taught and tested. At least it used to be. Nowhere in this thread did I read that there didn't need to be an entry in the logs or any of that. Also required will be an amended equipment list and weight and balance, along with the appropriate placards, since this is an old enough airplane to not require a flight manual. It goes without saying in the mechanic's world. That's ALL that's needed. Go find a mechanic and try to tell them you want an STC to accomplish something that's already approved via the Type Certificate. THAT's not what an STC is for...it's a Supplement to the Type Certificate....to approve something that is NOT included on the Type Certificate. Same goes for a Form 337. Sadly, many don't get this anymore.

If you really want to get in trouble...start putting marks on and changing letters/numbers on data plates! We have to have VERY specific instructions and permissions to do so. It's not legal to swap them back and forth either, without express permission.

I think the main problem here is that someone isn't versed in standard Type Certificate knowledge and that the S7CCM sheet isn't immediately following the 7CCM data sheet. I would hope that the Fed that was mentioned in the original post, just looked at the next description in line, and it wasn't the "S" version, so they assumed that it didn't exist.

So yes, as long as the long stroke gear has not been installed at some point in this aircraft's life, it meets the LS criteria. If it's had that gear on (according to an entry in the logs, since once again, this is covered by the Type Certificate), it's not elegible in either configuration, from what I understand of the regs.

John

hardtailjohn wrote:

A1Skinner wrote:[Again, I agree. Floats do turn it into a S model, but that change has to at least be documented in the log book and flight manual to ensure the proper coinciding documents are carried.

I take it that you're not an A&P/IA. This is basic stuff taught and tested. At least it used to be. Nowhere in this thread did I read that there didn't need to be an entry in the logs or any of that. Also required will be an amended equipment list and weight and balance, along with the appropriate placards, since this is an old enough airplane to not require a flight manual. It goes without saying in the mechanic's world. That's ALL that's needed. Go find a mechanic and try to tell them you want an STC to accomplish something that's already approved via the Type Certificate. THAT's not what an STC is for...it's a Supplement to the Type Certificate....to approve something that is NOT included on the Type Certificate. Same goes for a Form 337. Sadly, many don't get this anymore.

If you really want to get in trouble...start putting marks on and changing letters/numbers on data plates! We have to have VERY specific instructions and permissions to do so. It's not legal to swap them back and forth either, without express permission.

I think the main problem here is that someone isn't versed in standard Type Certificate knowledge and that the S7CCM sheet isn't immediately following the 7CCM data sheet. I would hope that the Fed that was mentioned in the original post, just looked at the next description in line, and it wasn't the "S" version, so they assumed that it didn't exist.

So yes, as long as the long stroke gear has not been installed at some point in this aircraft's life, it meets the LS criteria. If it's had that gear on (according to an entry in the logs, since once again, this is covered by the Type Certificate), it's not elegible in either configuration, from what I understand of the regs.

John

So the question is, why did this plane get a 337 in the first place? Lisa does state that there is a log entry along with a 337. I'm assuming it's because someone way back when didn’t do their proper homework either. And since the plane has a 337 for the float install, what trumps what? The 337 or the TC? Honest question.

A1Skinner wrote:

hardtailjohn wrote:

A1Skinner wrote:[Again, I agree. Floats do turn it into a S model, but that change has to at least be documented in the log book and flight manual to ensure the proper coinciding documents are carried.

I take it that you're not an A&P/IA. This is basic stuff taught and tested. At least it used to be. Nowhere in this thread did I read that there didn't need to be an entry in the logs or any of that. Also required will be an amended equipment list and weight and balance, along with the appropriate placards, since this is an old enough airplane to not require a flight manual. It goes without saying in the mechanic's world. That's ALL that's needed. Go find a mechanic and try to tell them you want an STC to accomplish something that's already approved via the Type Certificate. THAT's not what an STC is for...it's a Supplement to the Type Certificate....to approve something that is NOT included on the Type Certificate. Same goes for a Form 337. Sadly, many don't get this anymore.

If you really want to get in trouble...start putting marks on and changing letters/numbers on data plates! We have to have VERY specific instructions and permissions to do so. It's not legal to swap them back and forth either, without express permission.

I think the main problem here is that someone isn't versed in standard Type Certificate knowledge and that the S7CCM sheet isn't immediately following the 7CCM data sheet. I would hope that the Fed that was mentioned in the original post, just looked at the next description in line, and it wasn't the "S" version, so they assumed that it didn't exist.

So yes, as long as the long stroke gear has not been installed at some point in this aircraft's life, it meets the LS criteria. If it's had that gear on (according to an entry in the logs, since once again, this is covered by the Type Certificate), it's not elegible in either configuration, from what I understand of the regs.

John

So the question is, why did this plane get a 337 in the first place? Lisa does state that there is a log entry along with a 337. I'm assuming it's because someone way back when didn’t do their proper homework either. And since the plane has a 337 for the float install, what trumps what? The 337 or the TC? Honest question.

I’ve worked with mechanics who submitted a 337 for installation of floats, based on the TC. Required? No. Their logic: Get it documented in the FAA system. A mechanic can submit a 337 for most anything…..required or not…..just goes in the A/C record.

MTV

A1Skinner wrote:
So the question is, why did this plane get a 337 in the first place? Lisa does state that there is a log entry along with a 337. I'm assuming it's because someone way back when didn’t do their proper homework either. And since the plane has a 337 for the float install, what trumps what? The 337 or the TC? Honest question.

No, the question is what, if anything, does that 337 say that would knock it out of meeting LS requirements? Like MTV said, some mechanics do a 337 for things that they don't have to. Doesn't make it right, but it's done. I had an inspector about 25 years ago tell me, when in doubt, submit one, because he'd never seen anyone get a violation for submitting one if it wasn't needed, but he'd seen them get a violation for NOT submitting one when it was needed.
If the 337 has something that changes the installation from the installation called out in the Type Certificate, and it was used for a Field Approval, then that would be the ruling document. If the 337 was just submitted and not needed, I'd say the Type Certificate is the ruling document. I'd love to see the approval for the data used, or reference to approved data. Just saying, "installed floats" without some sort of approved data, doesn't work at all. That's the worst part of these online discussions...you can't examine all the documents and weed through the bogus stuff.
I'd guess that your statement that someone didn't do their proper homework is most likely right on the money.
John

hardtailjohn wrote:

A1Skinner wrote:
So the question is, why did this plane get a 337 in the first place? Lisa does state that there is a log entry along with a 337. I'm assuming it's because someone way back when didn’t do their proper homework either. And since the plane has a 337 for the float install, what trumps what? The 337 or the TC? Honest question.

No, the question is what, if anything, does that 337 say that would knock it out of meeting LS requirements? Like MTV said, some mechanics do a 337 for things that they don't have to. Doesn't make it right, but it's done. I had an inspector about 25 years ago tell me, when in doubt, submit one, because he'd never seen anyone get a violation for submitting one if it wasn't needed, but he'd seen them get a violation for NOT submitting one when it was needed.
If the 337 has something that changes the installation from the installation called out in the Type Certificate, and it was used for a Field Approval, then that would be the ruling document. If the 337 was just submitted and not needed, I'd say the Type Certificate is the ruling document. I'd love to see the approval for the data used, or reference to approved data. Just saying, "installed floats" without some sort of approved data, doesn't work at all. That's the worst part of these online discussions...you can't examine all the documents and weed through the bogus stuff.
I'd guess that your statement that someone didn't do their proper homework is most likely right on the money.
John

I agree 100%. That why I kept saying a good proper log entry would likely have solved any questions. Not saying anyone didn't know that life entries were needed, but clearly they were not adequate with enough info in this case. If they were this would all be fairly straight forward.

I wouldnt be so sure about that, frankly.

I’ve had two cases where a mod was covered by a legal, proper and FAA approved field approval, and an Inspector tried to ground the plane because HE didn’t think it was legal to issue a field approval on those things. Both these Inspectors were idiots. Both got booted from good civil operations because they were idiots.

Trust me, there are a lot of good Inspectors out there, but there are some idiots.

MTV

mtv wrote:....I’ve worked with mechanics who submitted a 337 for installation of floats, based on the TC. Required? No. Their logic: Get it documented in the FAA system. A mechanic can submit a 337 for most anything…..required or not…..just goes in the A/C record.

FAA form 337 is for a "major repair and alteration".
Isn't removing the landing gear & installing floats considered a "major alteration"?
A 337 doesn't indicate the repair or alteration isn't already approved by TCDS, STC, or whatever --
it is just to document it.
I've seen 337's (properly) submitted for things like wing repairs,
done in accordance with factory manuals & AC43.13--
no special approval needed, just a return-to-service signoff.
Also seen them done when changing from one TCDS- approved engine model to another--
again, no special approval needed, just a return-to-service signoff.

Best thing is to do what you gotta do and don’t make a bunch of noise about it in the Web. [emoji41]

hotrod180 wrote:

mtv wrote:....I’ve worked with mechanics who submitted a 337 for installation of floats, based on the TC. Required? No. Their logic: Get it documented in the FAA system. A mechanic can submit a 337 for most anything…..required or not…..just goes in the A/C record.

FAA form 337 is for a "major repair and alteration".
Isn't removing the landing gear & installing floats considered a "major alteration"?
A 337 doesn't indicate the repair or alteration isn't already approved by TCDS, STC, or whatever --
it is just to document it.
I've seen 337's (properly) submitted for things like wing repairs,
done in accordance with factory manuals & AC43.13--
no special approval needed, just a return-to-service signoff.
Also seen them done when changing from one TCDS- approved engine model to another--
again, no special approval needed, just a return-to-service signoff.

Is float installation on an airplane for which floats are approved on the TC a "Major Alteration" or a "Major Repair"? No, it is not. In fact, an A & P mechanic can install such floats with a logbook entry. It is neither a repair, nor an alteration. It's part of the type design.

Submitting a form 337 is fine, but not required. Now, if the floats were installed per an STC, such as Wipline floats on a Super Cub, for example, NOW it's a major alteration and a 337 IS required.

MTV

How is an aircraft "legally converted," maybe a catechism class?

Unless the GW was increased, the Luscombe 8A, B, C, and D, are SP eligible aircraft. The 8E at 1400 pounds GW isn't. If we equate GW with MTOW, which any logical person would. I had dismissed a possibility before, but considering this, I am rethinking my position.

The FAA lists it as an 8A, the owner says it was "converted to 8E as authorized by factory letter." This is from Univair's online copy of said letter:

"COPY OF LUSCOMBE BULLETIN DATED August 4, 1947... B. TO CONVERET FROM MODEL 8A TO 8C. Alternate Plan. See Note 1. 1. Replace fuselage tank with two 12.5 gallon wing tanks..." Done. "2. Replace engine or modify for increased horsepower..." Same s/n engine. "3. Install new fuel lines, fittings, fuel selector valve, shaft and control assembly, placard and pressure vent fuel caps. 4..." Done. "5. Replace propeller... 6..." Done. "7. Re-rig controls per new control travel limits. 8. Install cover plates... 9. New Weight and Balance Statement."

If I proceed, I need to ensure that a few items on the letter were "done."

A factory built 8C or 8D has a 75 hp engine an 8E has an 85hp. The service letter continues.

"C. TO CONVERT FROM MODEL 8A to 8E. A-65, C-85-12F. See notes 1 and 3. 1. Change engine on same engine mount. If engine driven starter and generator are included, this will necessitate a new firewall assembly to accommodate their accessories. 2. Install new throttle controls. 3. Install mixture control..."

It has wing tanks, and a 337 notes the same. Which because they are on the TC as "optional" is I guess redundant. But it has the original engine control, no mixture knob, and no Gremlin system. Maybe it was "legally converted" to an 8C, but it wasn't "legally converted" to an 8E because all the steps were not completed.

Again, the FAA has a copy of a 337 for the wing tanks. I'd want to see what else they have. The current owner didn't do the work. He understands what was "actually" done to this airplane, but is disinterested in the paperwork: "The guy I bought it from had an A&P do it. Since the FAA transferred the registration afterwards it was obviously done correctly."

True, but it's still registered as an 8A. Is this a potential minefield?

Thanks

Lisa

Lisas7ECA wrote:....Unless the GW was increased, the Luscombe 8A, B, C, and D, are SP eligible aircraft. The 8E at 1400 pounds GW isn't. If we equate GW with MTOW, which any logical person would.....
The FAA lists it as an 8A, the owner says it was "converted to 8E as authorized by factory letter." This is from Univair's online copy of said letter:......
Maybe it was "legally converted" to an 8C, but it wasn't "legally converted" to an 8E because all the steps were not completed.....

#1: does the airframe data plate, airframe logbook, or any form 337 actually say "converted to model 8E"?
#2: Does the weight & balance sheet indicate a higher legal gross weight than 1320?

If the answer to both questions is no, I'd say it is still an 8A regardless of whatever mods were done to it.
A friend of mine, who is a Luscombe guru, would describe it as "an 8A, configured as an 8E"--
but still an 8A, and as such, still legal for sport pilot ops.

Thanks Hotrod.

The silly anti-virus software blocks me when I quote your last post.

Nope, no such statement, so I'm good.

Just out of curiosity if there was such a statement, and that would open a can of worms I have no interest in. I wonder what the effect would be given that certain modifications that were required were clearly not performed.

Lisa