K3 Data Plate Location

[bbryan]

OK, screwed up my data plate, stamped out my name wrong, don't match my registration, Other than that, where are you guys locating the ID plate. Thought I read somewhere it needs to be either at door frame or tail section and readable from the outside on the ground. I'm not seeing a lot of options here for a fabric plane. Any suggestions?

[avidflyer]

FAR 14 CFR 45:11 gives the requirements. (Behind rearmost door, or on the tail surfaces) I've seen some that were riveted to the aluminum that closes off the hole under the horizontal stabilizer. That is what I would probably do. Jim Chuk

[Dave S]

The last part of subpart 2 below is where fabric aircraft can be a challenge.

To meet this standard, I made the data plate of stainless steel with an equivalent sized stainless steel backer for the other side of the fabric and attached a D shaped stainless steel loop riveted to the whole business around a tube behind the fabric - spaced so nothing rubs on anything. Located it below the HS midway between the bottom of the tail access hole and bottom of the fuseelage.

Dave s
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.

[PapuaPilot]

I am doing the same as Dave S. I glued an aluminum piece to the inside of my fabric under the horizontal stabilizer that I will rivet my data plate to.

If you put your data plate on a removable panel it doesn't meet the standard of CFR 45.11 (a)(1). Most likely the DAR will not allow it to be on a removable panel.

[Kurt.A]

Mine is as stated by Avid Flyer, riveted on to the removable aluminum panel under the horizontal stabilizer. Been there for 20 years now.

[Av8r_Sed]

Mine is in the same location. Mounting on the fabric is a problem because the plate can disappear if there's a post crash fire (not to say it hasn't been common practice.)

[DesertFox4]

Mounting on the fabric is a problem because the plate can disappear if there's a post crash fire (not to say it hasn't been common practice.) Why not make two identical plates and mount one permanently inside the tail of the fuselage in case of fire. One riveted to the fabric near the tail with a backing plate, which is always viewable, and one for the worst case event.
I suppose it would still be up to the individual DAR as to conformity with the law but might show the builder's effort to comply with the spirit of the law.

FYI- I left my data plate off until the DAR came to inspect and asked him where he would put it. After some thought, my DAR had me put it inside the cockpit behind the pilot seat viewable through the little triangle window on an aluminum plate used to seal around the flaperon push pull tube. Per the law, it is viewable from the outside, and it is behind the furthest rear door. Since he chose the location of course he signed off on it. Go figure.

[bbryan]

I think I will talk to my DAR, if I don"t the way my luck has been going it will be wrong. I built my avid in nine months, been working on the K3 for 7 years, I must be getting slower as I age. Starting to get concerned I will kick the bucket before I get to fly. Only thing left is data plate an ELT and some bookwork. Gee, that should only take me 6 months. The shift work is murder on projects.

[Dave S]

Bob,

Checking with the DAR would remove any doubt.

Per my earlier response ".............I made the data plate of stainless steel with an equivalent sized stainless steel backer for the other side of the fabric and attached a D shaped stainless steel loop riveted to the whole business around a tube behind the fabric........." was the conclusion I came to after asking my DAR.....basically the whole plane could burn and the stainless steel data plate would be hanging on the fuselage tube by the D shaped strap secured to the data plate with SS rivets.

It's important that you get these things done so you can fly:)

Sincerely,

Dave S

[Jch]

FWIW, data plate construction and location was about the only thing that was at issue with my inspection (FAA). We had discussed it before the inspection...it had to be stainless steel, "attached to structure" behind the doors. My first plate was SS, behind the door, attached to a steel backer plate, but attached to fabric. I sent a picture to the FAA inspector and he said he wanted to see it on "structure". I made a new one and attached it to the side trailing edge of the vert stab. (on an airfoiled tail) below the horiz stab....Inspector was happy and there was not one other issue during the inspection. (completed 5/28/2014)

[HighWing]

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...?

[bbryan]

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.

[Dave S]

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

[t j]

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".

[Icefox]

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).