December 2014 - Page 2 Aviation Articles

Can You Buy Replacement Aircraft Data Plates on the Internet?

The internet can be a wonderful thing. From the convenience of your computer you can buy most things aviation. Whether you are looking for pilot supplies, aviation paraphernalia or even an aircraft, it is quite likely that you can locate, and complete, your purchase via the internet. But, the convenience of buying through the internet doesn't always mean that you are really receiving the item for which you paid, or that you will be able to actually use the item as anticipated. A recent Legal Interpretation issued by the FAA's Office of the Chief Counsel illustrates this point.

This particular Legal Interpretation responded to a request from an individual regarding an advertisement on an internet auction site promoting the sale of "high quality reproduction aircraft identification plates." Specifically, the individual wanted to know how to determine "whether a reproduction plate is 'eligible for installation on a type certificated product.'"

The Interpretation initially notes 14 C.F.R. § 21.8 states that a part which must be approved by the FAA, such as an aircraft data plate, must be approved for production under a parts manufacturing authority (PMA), a type supplemental order (TSO), in conjunction with type certification procedures, or the catchall: "in any other manner approved by the FAA." It goes on to observe that, not surprisingly, when it comes to installation of data plates on aircraft, the FAA usually relies upon the original aircraft manufacturer to install the data plates on its aircraft.

According to the FAA Chief Counsel, the FAA views the aircraft manufacturer's installation of the data plates as a declaration or representation that the aircraft conforms to its type design. If for some reason the aircraft manufacturer refuses to issue or install data plates, the FAA assumes (yes, the Legal Interpretation actually uses the word "assumes") the aircraft does not conform to its type design.

With that background, the Interpretation then addressed several situations in which the aircraft owner may not have original identification plates issued by the aircraft manufacturer. First, if the data plate is lost, stolen or damaged during maintenance operations, the Interpretation states that the aircraft owner should "seek a replacement from the aircraft's original manufacturer." Unfortunately, since product liability exposure is always a concern for manufacturers, they are reluctant to issue a new data plate and expose themselves to additional potential liability for an aircraft whose condition they have been unable or unwilling to verify. As a result, that option is seldom successful.

Next, the Interpretation addressed the situation in which "the aircraft's original manufacturer is no longer in business or is otherwise unable or unwilling to produce a replacement plate for reasons unrelated to the condition of the aircraft. It observed that FAA Advisory Circular 45-2D, Identification and Registration Marking provides a means of compliance. Referencing Section 6(i)(3) of AC 45-2D, the Interpretation states than an owner or operator may only buy data plates from an approved source after "going through the process" of contacting the local Flight Safety Standards District Office (FSDO) or Manufacturing Inspection District Office (MIDO) for assistance and approval in obtaining a replacement. Unfortunately, neither the Interpretation nor AC 45-2D provide any explanation for what this "process" involves or requires from the aircraft owner or operator, nor does it state what the FSDO or MIDO are obligated to do in assisting or providing approval of a replacement data plate. As a result, it is unclear whether this is truly a practical or viable option.

Finally, in addressing the specific request before it, the Interpretation concludes that "[a] reproduction identification plate sold on an online auction website would presumably be produced by neither the manufacturer nor an FAA-approved alternative source (such as a PMA holder for the article), and therefore it could not indicate to the FAA that an aircraft conforms to its type design." And without an approved data plate to "prove" conformity with the type design, the aircraft would be ineligible for a standard airworthiness certificate.

So, the moral of the story: Simply because you can buy replacement data plates on the internet (or anything else for that matter), that doesn't mean you can use them. At least the individual in this case asked the question before, rather than after, spending good money on "reproduction" data plates. But, as with most purchases, some degree of "caveat emptor" is almost always a good thing.

8 METAR Codes You’ve Always Wondered About

Aviation weather reports are pretty simple once you’ve been trained to read and interpret them, but the more often you fly, the more often you’ll see new and strange codes on METARs (aviation routine weather reports). Some of these are decoded below. A few of these are codes that you may have learned for your check ride but forgot about years later, and others are just plain rare or insignificant.

For more details on METAR codes and other aviation weather reports, check out the FAA advisory circular AC-0045-G, Aviation Weather Services. This particular advisory circular is very thorough, and even if you were previously educated on the codes below, you’re likely to learn a thing or two about Aviation Weather Services from this one.

Here are a few METAR codes that are commonly forgotten, misinterpreted, or never learned. How many do you know?

  1. BKN014 V OVC
    Most of us know that this means there’s a broken cloud layer at 1400 feet AGL. But what’s the ‘V’ mean? The ‘V’ here means that the cloud layer at 1400 feet is variable between broken and overcast. It’s a code that’s not that commonly seen.

  2. CIG 002 RWY11
    If you see the code above and there’s already a ceiling reported earlier in the METAR report, it means that there’s a second station on the field that’s also reporting visibility, and you’ll know this because the specific location will be included. This ceiling is only included if the ceiling at this second station is lower that otherwise reported in the METAR. Here, it means the ceiling is 200 feet at the ceilometer location near runway 11.

  3. SNINCR 2/10
    If the snowfall increases by one inch or more since the previous reported METAR, it’s indicated by ‘SNINCR’ followed by the amount. In the case above, the snow has increased by 2 inches in the past hour, and the total snowfall is 10 inches. This could be easily misinterpreted as a snow increase of 2/10 of an inch, so it's worth remembering.

  4. A01 and A02
    A01 and A02 are types of METAR stations. This code, which is often brushed aside as meaningless by some, distinguishes between a station with a precipitation discriminator (A02) and one without (A01).

  5. $
    The dollar sign at the end of a METAR indicates that the station has self-identified itself as needing maintenance. This one is pretty common, but not all pilots take the time to figure out what it means.
  6. TSB22RAB17GRB23
    This notation gives the time that special weather events began (noted by the ‘B’) and if they’ve ended, what time they ended (noted by an ‘E’). The text above means that thunderstorm began at 22 minutes past the hour, rain began at 17 minutes past the hour, and hail (GR) began at 23 minutes past the hour.

  7. PRESRR
    If the pressure rises or falls at a rate of 0.06 inches per hour, and the difference from the last reported pressure is 0.02 or greater, than the code PRESRR will be used, which stands for pressure rising rapidly, and the code PRESFR will be used to note pressure falling rapidly.

  8. PNO or CHINO LOC
    At the end of a METAR, you may often find an abbreviation ending with ‘NO’. These are most likely sensor status indicators. There are a few different possibilities for these sensor abbreviations. Above, PNO means that the "tipping bucket rain gauge" sensor isn’t working. ‘CHINO LOC’ means that the sensor for the secondary ceiling height indicator is not operating. As you can see, some of these aren’t necessarily intuitive, and will often require you to dig deeper to determine what they mean.

These are just a few of the commonly unknown METAR codes. There are many more, as you’ll discover by reading the advisory circular suggested above.

Which strange codes have you stumbled upon while checking the weather?

Three Levels Of Budgets

As 2014 is in its last month, many of you are looking toward the holidays. One item for those in management positions may be standing in the way of a happy holiday - your budget for the flight department. Too many organizations look at budgeting as a pain filled process. It need not be that way.

Budgeting is a very important tool for planning an organization's use of its most limited resource - cash. Managing  cash is critical for any business or individual. The budget is supposed to be an estimate of the future financial state of your organization. Used correctly, the budget can be an asset in managing your aviation cash rather than a once-and-done exercise.

Within your aviation organization, you probably need three levels of budgeting. Think of them as tactical, operational, and strategic. A tactical budget is the lowest level of budgeting. It may be your training budget for the flight department. You build up the training budget from the tactical level of who goes to train, the cost of the course, and cost of travel to attend the course. It may even include the cost of a temporary pilot to fill in a busy flying schedule. 

The operational level of budgeting is the one as an aviation manager, you need to be the most concerned with on a day to day basis. It covers the main areas of functional responsibility that you have. 

For an aviation operation, maintenance is one of the largest expenses, and one in which the aviation organization can have the most control. However, in order to effectively manage those expenses, you need to know what is expected and be able to measure and track them during the year. Planning for your maintenance may take the most time in your budget preparation. Rather than a single budget item of maintenance, you should have more levels of detail so that you can better manage those maintenance costs. This may include categories like unscheduled, scheduled, parts, external labor, refurbishment, overhaul, etc. 

The budget that you submit to the CFO is used to meet the strategic level of budgeting. The senior leadership and Board of Directors need to know how well the company is meeting its strategic, long-term goals and objectives. The fact that your temp pilot costs $1,000 per day is not important to them. The fact that you are acquiring a $20 million business jet is. One organization that I've worked with has three line items in the flight department budget that is  submitted to the CFO: personnel, facilities, and equipment. 

As the flight department manager, you need to build up to the strategic level of the CFO from the level of the tactical.  Things like training, maintenance, etc can be done with the help of your team. Assign the Training Captain and an admin to research costs for training. Work with your Director of Maintenance to make sure you cover the all bases for upcoming maintenance in 2015. 

Make sure you have a good estimate on your planned-for flight hours in 2015.   Ask upper management about their intended aircraft usage for the next year, or ideally, several years. Will there be more or less flying, any new destinations, etc? If you are budgeting any optional maintenance items or upgrades, ask if next year or the year after works better for the financial goals of the company. 

Document Your Assumptions. Things will be different next June than they were the previous December.  The biggest changes may be in the variable costs as you fly more or fewer hours than estimated. How will changes in hours flown affect when major maintenance is due? When conditions change, these recorded assumptions will better guide you on revising the budget better than relying on your memory.

As an aviation manager, the budget should be more than just filling a square for your upper management reporting. It is a very useful tool that can enable you to track the effectiveness of your aviation operation. It can also alert you to the future peaks in expenses, such as scheduled major maintenance or an aircraft upgrade.  

Think of a budget as your fiscal flight plan. After take-off you check the winds, your fuel status, and the level of coffee in the urn. Monitor the fiscal flight plan the same way with the same goal: to arrive at your (year end) destination safely and comfortably. 

 

 

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