Re-registration challenge

[Eric Brown]

This story starts in Nov 2017. I purchased a damaged C150L that had been de-registered. I didn't know it at the time, but the de-registration was because it was listed as "scrapped/destroyed". I have been dealing with the FAA registration branch since Dec. 2017. In Jan 2018 they told me that I needed to supply photos of the assembled "whole and complete" airplane before it can be registered. I continued with work on the airplane in order to reach a point of photo submission. In June 2021 the photos were submitted. Today (7-17) I received a letter confirming a review of the photo packet. However, registration is still denied because of a new FAA order 81200.19, that became effective in Oct 2018 stating that I must work with a FDSO. DER, or ACO to come up with plan to "prepare an approved repair scheme" and submit it before the airplane can be registered.

NOW ...... it's a little late for that ! I feel that I should have been informed of the new requirement 2 1/2 yrs. ago. It would have worked much better that way. It is apparently one of those bureaucracy things where they forget that you exist until you contact them with the last set of their instructions.

Gasp /wheeze / pant ........... has anyone out there dealt with a similar problem and able to give an exasperated airplane owner some advise ???

Yes, I will be calling the locals and OK City.

Thanks

[skyfixer8]

I would suggest getting with a good DER, and explain what is needed. Being in EAA, you have access to their resources and they can point you in the right direction. As an A&P, I have to deal with the FAA sometimes and it gets frustrating. Good luck

[martymayes]

Using the document (I think you meant to cite) FAA Order 8100.19,

Are you using the dispute process in Chapter 4 to show the aircraft was not destroyed and therefore repairable under the FARs???

If so, it looks like you need to show repairs were done around at least one non-destroyed primary structure of the aircraft. That would be your repair process. Submit and have them give it the necessary blessing. Might need to get an official definition of a "primary structure" to make sure you're in compliance.

It looks like once your repair process is approved, they will flip the switch at the registry and allow the plane to be registered.

[Eric Brown]

I believe chapter 4 often deals with damage caused by an accident in which an FAA or NTSB investigator would determine the airplane condition. This airplane was damaged on tie down by a windstorm and was determined to be scrap by Wentworth Aircraft (scrapyard) hwo de-registered it. I don't know of any photos showing the airplane condition at time of de-registration.

[martymayes]

I believe chapter 4 often deals with damage caused by an accident in which an FAA or NTSB investigator would determine the airplane condition. This airplane was damaged on tie down by a windstorm and was determined to be scrap by Wentworth Aircraft (scrapyard) hwo de-registered it. I don't know of any photos showing the airplane condition at time of de-registration.

It says in ch 4: "14 CFR § 47.41(b)(2) does not specify who makes the determination that an aircraft is destroyed or scrapped. Typically, a knowledgeable party makes such a determination with the concurrence of the registered owner."

It says in ch 4: "The determination that an aircraft is destroyed may be refuted by evidence submitted by an owner that the aircraft is repairable."

It says in ch 4: "For an aircraft to be considered eligible for repair, it must have at least one primary structure around which a repair can be performed"

Might need an official FAA definition for "primary structure"

It says in ch 4: "By presenting the cognizant FAA FSDO or ACO with a repair process detailing how the damaged aircraft can be repaired around at least one non-destroyed primary structure of the aircraft" one can dispute that the aircraft was destroyed.

Finally, it says in ch 4: "When the responsible FSDO or ACO approves the repair after reviewing all accompanying data, finds it in compliance with applicable regulations, and the aircraft is properly identified, the aircraft would no longer be considered destroyed or scrapped and appropriate changes would be made to the aircraft’s file to permit its registration."

And that seems to cover it.

[Eric Brown]

Well guys ..... I'm working with an ASI at my local FSDO. When he calls the registration branch, he admits that they are a little confusing. The ASI is recommending that I prepare a repair scheme, but nothing to in depth because there is no published guidance to prepare one and send it to him for review / approval and then on to OK City. The repair scheme has been E-mailed to the ASI. More news when it happens.