Civil Registration of Warbirds

[Rajay]

I'm going to go off on a little rant half-cocked. Half-cocked because I can't put my hands on the appropriate reference right now, but maybe one of you can help me with that.

I KNOW that I have read somewhere (an AC if not an actual FAR) that when ex-Warbirds are registered by a civilian owner with the FAA, they are supposed to use the manufacturer's serial or "construction" number and NOT the ex-military serial or in the case of the USN, the Bureau of Aeronautics (BuAer.) number (or BuNo.) Yet still, so many warbirds continue to be registered with those ex-military serials. What's up with those guys who supposedly take such pride in sweating all of the picky details?

This is true of the last Albatross that was built; N42MY is currently registered with its ex-USN BuAer. No. 148329 as its serial number. It's true Grumman serial number is G-464. Apparently Mirabella Yachts has recently (7 mos. ago) sold it to Sherman Aircraft Sales....

One of the ex-partners in Antilles Seaplanes still has N1048V registered to him at Aero Accessories Inc. using its USN BuAer. No. 37793. It's Grumman serial number was B-46. It also does not exist any longer. It was parted out and scrapped and the fuselage was sold to Sam Damico in Pittsford, NY for him to use to rebuild N327, Grumman G-21A s/n 1051, that crashed and burned in Penn Yan, NY several years ago.

I also noticed this with Taigh Ramey's prize UC-45J, which apparently was also recently sold; the "current" FAA registration database entry has its status listed as "in question" and "registration pending." The new applicant is listed as the "Military Beech 18 Heritage Foundation" in Maple Valley, WA and the date of application is listed as July 6, 2009. On the TwinBeech.com Web page about this airplane, it is always identified by its BuAer. No. 29585 (or 029585) - only by looking at the large version of the photo of the trophy for the 1999 EAA "Most Authentic Warbird" at Oshkosh can you barely make out that it was registered as N75018 at the time.

According to Joe Baugher's military aircraft serial number database, UC-45J BuAer. No. 29585 was part of a contract block of aircraft that ranged from 29551 to 29668 - supposedly a block of 118 aircraft. I've found errors in Braugher's database before, especially with regard to Gooses. In this case, he lists BuNo. 29553 as c/n 6995 and 29646 as c/n 7882; that's a difference of 94 aircraft with a range of 888 serials. There's something wrong there. Also for ex-N75018, now N585PB (BuNo. 29585) he lists a c/n of 721. That also must be a typo; apparently there's a digit missing.

Other Gooses (for examples - since they are my speciality) still in the FAA registration database with incorrect or ex-military serials are:

N2579B is using ex-BuNo. 37821, but it should be Grumman c/n B-74

N5542A is using ex-BuNo. 37281, but that is not even a Goose (JRF) Bureau Number. Per Baugher, 37281 belonged to a Lockheed PV-2 Harpoon, N7263C, which crashed near Winslow, AZ on June 12, 1974. According to my research and a process of interpolation, N5542A was ex-BuNo. 37780 and its Grumman c/n was B-33.

N5548A is using a completely crazy, apparently ex-USAF format serial (75-7661) which has no correlation to any reality in regard to Gooses. This Goose was part of the batch of JRF-6B’s built for the British and as such it was assigned USN BuNo. 0206B on the procurement contract. In any case, it is Grumman c/n 1150.

N742PC is another apparent correlation or interpolation error compared to the Joe Baugher database. It is registered with serial number 37782. I have it in my database as Grumman c/n B-34, which correlates to ex-BuNo. 37781 based on the original procurement contracts. If it truly was 37782, then its Grumman c/n would be B-35. Either way, the use of 37782 is incorrect.

Eddy Haynes’ GooseCentral.com Web site lists Goose serial number B-34 as being registered as CF-IOA, and it is supposed to have crashed in 1964. On the other hand, the Canadian Historical Aircraft Registration database (a feature not available from the FAA for US-registered aircraft, by the way) has no record of any aircraft ever being registered as CF-IOA (or per later convention, C-FIOA.)

In case any of you are restorers out there considering taking umbrage from this rant, let me finally say this is really all a back-handed way of pointing out how little the left hand of the FAA knows what its right hand is doing. In the case of the examples I made of Grumman Gooses, TC No. 654 clearly spells out the valid serial number range, 1001 to 1200 and B-1 to B-145 (and I am also picky about the use of the hyphen or dash. Many Gooses in the second range are currently registered without the dash in their serial number. Technically that is also incorrect.) Why then would the FAA even accept a registration with a serial number that was outside of those two ranges? Just doing their job as usual?

NOTE: I just got through looking at all of the Grumman Albatross registrations that I could find (by searching via all of the various model numbers.) I came up with 85 "current" FAA registrations - not one of them used a Grumman c/n on their registrations (in the G-XXX format); almost all appeared to be an ex-USAF, USN, or USCG serial number, except for the Conroy turbine (Rolls Royce Dart) conversion (where did A4-77 come from? It's Grumman c/n was G-77....)

[davem]

"Eddy Haynes’ GooseCentral.com Web site lists Goose serial number B-34 as being registered as CF-IOA, and it is supposed to have crashed in 1964. On the other hand, the Canadian Historical Aircraft Registration database (a feature not available from the FAA for US-registered aircraft, by the way) has no record of any aircraft ever being registered as CF-IOA (or per later convention, C-FIOA.) "

The historical record database only goes back to 1982 - CF-IOA crashed on May 28, 1964, so you will not be able to get info online from Transport Canada. You should be able to obtain some data and perhaps the accident report from the Public Archives of Canada:

http://www.collectionscanada.gc.ca/index-e.html

[51fixer]

I am unaware of any rule that specifies what a Serial Number is to the FAA from the WWII time period.
A military A/C is ordered under a contract and is issued a Military S/N. When being built the company building it uses a company number but to the military it is known by the contact issued serial number. All through it's military use the records are kept by the Military S/N as far as I have seen or know of. I have received record cards by requesting the Military S/N.
A P-51 I take care of is known as 44-73029. The bill of sale when it returned to the states from Nicaragua lists it along with about a dozen other P-51s all by the Military S/N. All FAA paper work uses this number. I don't even know what its NAA number is. The data plate has the 44-73029 number on it. There is a picture from the 1950s and it has the 44-73029 on it. That is its identity.
There are even a few Cavalier Mustangs that have 1960s military S/Ns.

[Jack Cook]

We registered a AT-6 using the serial of a A-20B Havoc Top that

[Rajay]

As I first said, I KNOW that I have seen a specific statement, probably in an Advisory Circular (which of course is not "mandatory" or "regulatory" in nature), that says that the military serial is NOT to be used and that only the manufacturer's serial should be used for civilian registration documentation of ex-military aircraft.

As soon as I can find it again, I'll post the reference.

Of course, there is also 14 CFR Part 45.13(a)(3) that also specifies the use of the "Builder's Serial Number" for purposes of aircraft identification, although in this particular case it is in regard to the data tag.

On the military versions of the Grumman Goose such as "my" JRF-5, Grumman included both its own serial number (B-115) as well as the USN BuNo. (87721). I believe it also referenced the original procurement contract number, but I don't have the actual tag in front of me right now.

[Rajay]

We registered a AT-6 using the serial of a A-20B Havoc Top that

I kinda liked the visual image of the "wannabe bomber" Grumman Goose using the Navy BuNo. of a PV-2 Harpoon, but I also have to admit that an AT-6 pretending to be an A-20 is more of a stretch.

[Jack Cook]

The FAA guy walked into the hanger with of spam cans and 1 T-6 and said which ones the T-6!

[John Dupre]

Don't forget that FAA regs and circulars are all in how you parse the language. If the wording is that "a" manufacturer's serial number will be used and the manufacturer used both an in house and customer number then you could say either one works. On the other hand if the wording is that "the" manufacturer's serial number will be used and the manufacturer called its internal number a construction number, or hull number or article or whatever but not a "serial" number then you could say the customer's serial number was the only "serial" number used.

As a bureaucracy the FAA often doesn't know what its' various hands are doing. Some one showed me the regs on the old Limited registrations. As we understood it the Limited reg would expire if the registration was ever cancelled or otherwise lapsed. The guy showing me could think of a half dozen warbirds flying with Limited registrations that he knew had been deregistered at some time. His FAA inspector was interpreting the registration literally. The aircraft in question had been deregistered at some point in its history so it could not be re registered in Limited. The fact that other FSDOs had done it didn't matter.

[Rajay]

Don't forget that FAA regs and circulars are all in how you parse the language...
As a bureaucracy the FAA often doesn't know what its' various hands are doing. Some one showed me the regs on the old Limited registrations. As we understood it the Limited reg would expire if the registration was ever cancelled or otherwise lapsed. The guy showing me could think of a half dozen warbirds flying with Limited registrations that he knew had been deregistered at some time. His FAA inspector was interpreting the registration literally. The aircraft in question had been deregistered at some point in its history so it could not be re registered in Limited. The fact that other FSDOs had done it didn't matter.

And if you liked that one, consider the following:

"14 CFR Part 21.181 Duration (of Airworthiness Certificates)

(a) Unless sooner surrendered, suspended, revoked, or a termination date is otherwise established by the Administrator, airworthiness certificates are effective as follows:

(1) Standard airworthiness certificates, special airworthiness certificates—primary category, and airworthiness certificates issued for restricted or limited category aircraft are effective as long as the maintenance, preventive maintenance, and alterations are performed in accordance with Parts 43 and 91 of this chapter and the aircraft are registered in the United States."

Does that mean that as soon as maintenance, preventive maintenance, and alterations are NOT performed in accordance with Parts 43 and 91 of this chapter, the Airworthiness Certificate is no longer valid?

You know those Warbirds that have been sitting on the ramp for years, if not decades....

So, your Annual Inspection has expired, but now you can't just do a new Annual Inspection; you have no longer maintained your aircraft per "Parts 43 and 91 of this chapter" and you have to turn in your Airworthiness Certificate, right?

[RMB]

That dosnt say if you are out of annual,mail in the cert. It says if not maintained the cert is not EFFECTIVE. It hasnt been "surrendered, suspended, revoked, or a termination date is otherwise established by the Administrator"
It is the same if you pilot BFR lapses. Your license isnt revoked. It is just not EFFECTIVE until you get a BFR.

[51fixer]

Don't forget that FAA regs and circulars are all in how you parse the language...
As a bureaucracy the FAA often doesn't know what its' various hands are doing. Some one showed me the regs on the old Limited registrations. As we understood it the Limited reg would expire if the registration was ever cancelled or otherwise lapsed. The guy showing me could think of a half dozen warbirds flying with Limited registrations that he knew had been deregistered at some time. His FAA inspector was interpreting the registration literally. The aircraft in question had been deregistered at some point in its history so it could not be re registered in Limited. The fact that other FSDOs had done it didn't matter.

And if you liked that one, consider the following:

"14 CFR Part 21.181 Duration (of Airworthiness Certificates)

(a) Unless sooner surrendered, suspended, revoked, or a termination date is otherwise established by the Administrator, airworthiness certificates are effective as follows:

(1) Standard airworthiness certificates, special airworthiness certificates—primary category, and airworthiness certificates issued for restricted or limited category aircraft are effective as long as the maintenance, preventive maintenance, and alterations are performed in accordance with Parts 43 and 91 of this chapter and the aircraft are registered in the United States."

Does that mean that as soon as maintenance, preventive maintenance, and alterations are NOT performed in accordance with Parts 43 and 91 of this chapter, the Airworthiness Certificate is no longer valid?

You know those Warbirds that have been sitting on the ramp for years, if not decades....

So, your Annual Inspection has expired, but now you can't just do a new Annual Inspection; you have no longer maintained your aircraft per "Parts 43 and 91 of this chapter" and you have to turn in your Airworthiness Certificate, right?

Help me out here, do you own or fly any aircraft?
You seem to approach this like you have discovered something new in spite of these rules having been law for decades.
There are thousands of pages of regulations which apply to flying. Not all the rules apply to each aircraft as some are for airliners, charter, GA, experimental, foreign built, homebuilts, limited, restricted and general aviation. It is like a puzzle connecting the FARs that apply to each situation.
You do not revoke an airworthiness Certificate or Surrender it if it is out of annual. The aircraft must be airworthy to operate. The Airworthiness Certificate has nothing to do with whether the aircraft is safe to fly or inspected properly. It is a necessary part of the paperwork to own and operate an A/C, warbird or other wise.
The warbirds you have mentioned in your concerns come in 3 types covered under 3 categories. The Standard Category is an aircraft that at sometime somebody took the time and expense to certify that the warbird met all the requirements at the time that any aircraft was required to. It is the same as a Piper or Cessna in essence. The T-6 is in this category.
The Limited Category was where someone had to do the paperwork and follow the above but the CAA (1940s version of the FAA) had a less stringent protocol for this category. The Limited Category was only in effect for a short period of time. I believe by 1949 or so they quit using this for further applications. This is from an operations standpoint pretty much like a Standard Category A/C. You also get 1-2 pages of Operating Limitations you got to follow.
The Experimental Category is split into several types. Warbirds are typically Airshow/Exhibition. The Operating Limitations are multiple page documents, up to notebook size, and contain the specifics on how you operate the A/C.
An Experimental registered A/C doesn't mean the aircraft is a flying experiment, just that the A/C either doesn't meet or hasn't been proven through the FAA process, to meet the criteria of what is needed for a Standard Airworthiness Certificate.
Rich

[Cvairwerks]

The Type Certificate for the Stinson L-5 states the following:

Serial Nos. eligible All AF Serial Numbers. Use manufacturer's serial number if available

As Stinson didn't use s/n's, you have to use the AF assigned s/n.

[Taigh Ramey]

The Beechcraft you are referring to as my "prize UC-45J" 029585 is actually an RC-45J photo recon Beech. It was sold a while ago and the new owner has recently decided to put the aircraft in the name of a foundation built around the aircraft hence the recent registration change. This bureau number will not appear in a list of UC-45J aircraft.

When I bought the Beech from the Pima Air Museum she already had the registration N75018 which was assigned when she went to the Department of Agriculture for a screw worm eradication project.

The TCDS for this Beech says that "Serial Nos. eligible (use manufacturer's Serial Nos. when available)"

The same TCDS has a chart with Beech serial numbers and corresponding military serial numbers but not all models have those corresponding numbers. The RC-45J was one that didn't have a manufacturer’s serial number listed on the TCDS. I believe that there is one listed on the manufacturer’s data plate on the door well which, as I recall, had an N prefix for the Navy contract. It may be N-721 (I am not sure as I am at home now) as most all of these post war Beech serial numbers had one or two letters in front of one, two or three digits. (Axxx Civil D-18, AFXXX USAF C-45 series, BAxxx civil E-18 series, CAxxx Canadian military 3 series, Nxxx US Navy SNB/UC-RC series etc.)

The main data plate in the RC-45J is actually a Navy produced data plate which only lists the Bureau number and the last Navy overhaul date.

I think that it is perfectly legitimate to use the Navy Bureau number as a serial number for the registration of this aircraft. The Navy used it exclusively and the number is painted on the Beech especially the last three and four digits of the bureau number. This is how I referred to this Beech and so did the people who flew her in the service. I even tried to get a matching N number but it was taken.

My interpretation of this is that it is not a hard specific rule or regulation that must be adhered to “or else”. There is flexibility in the guidance which is necessary because there is a decided lack of documentation from the various manufacturers that will produce a direct correlation between manufacturer’s serial numbers, construction numbers and military serial numbers. Many manufacturer’s have been absorbed over the years and it has been my experience that the new corporate legal teams prefer to eliminate as much of the old records as possible to reduce possible liability.

I remember asking Beech (Raytheon/Hawker Beech…) for a copy of a drawing that was specifically called for in the TCDS to bring an ex military Beech into compliance for initial airworthiness certification. Beech said they would not sell or give me a copy but they would send it to my local FSDO where I could look at it. I could not copy it at all but I could look at it and make notes. Now why would letting out a copy of this doc be such a problem? I have run into the same problems with Boeing when trying to obtain a copy of a B-17 drawing. They will not let anything out through official channels but of course the information is available elsewhere especially through the back door via the right person.

Many ex military Twin Beech's were also registered with their civil model designations which, causes maintenance problems in my book. There are significant differences between a D-18 and a UC-45J but there are many military aircraft that have assumed the civil model designation. AD's come into play with the model differences and we have found many aircraft that have never had certain AD's complied with simply because they were registered as their civil counterpart.

Yes there is a wide range of problems with the civil registry that has been going on since the registration began. Yes there are many folks that have pulled the wool over the eyes of the FAA and will continue to do so. It really boils down to the specific inspector or DAR who does the initial work. Many rely on the word of the applicant but a lot don’t. There are as many horror stories out there about problems registering an aircraft that is perfectly legit as there are ones that slipped by the feds. I think the feds are aware of this and they are doing something about it. They are presently cleaning up the registry and bouncing out aircraft whose owners do not respond to the tri-annual inquiry cards. Many aircraft do not exist anymore and some are being bounced out simply because of out of date addresses. If you haven’t received a card for a while you should check to be sure your registration is current and okay. You can do so here:

http://registry.faa.gov/aircraftinquiry ... rtxt=75018

It certainly isn’t a perfect system but for the most part it has been good to me.

[Rajay]

Help me out here, do you own or fly any aircraft?
You seem to approach this like you have discovered something new in spite of these rules having been law for decades.
There are thousands of pages of regulations which apply to flying. Not all the rules apply to each aircraft ... It is like a puzzle connecting the FARs that apply to each situation.

Rich

Yeah, I fly - I have my Commercial & Instrument tickets. I have been a professional A&P for more than 20 years and now I work in Quality Assurance on an aircraft assembly line. That job is all about making sure the plane AND the paperwork are 100% correct for the FAA. I'm just playing "Devil's Advocate" here to point out how vague, confusing, and seemingly contradictory the FAR's can be - and I'm trying to have some fun by stirring things up while I'm at it.

Like the man already said, it's all in how you parse the language. That is why one of the other Wixers has a salutation about taking away dangerous objects from people - and starting with typewriters. And of course, the immortal Bard said "the Pen is mightier than the sword." They were all talking about the same thing; language is a powerful tool than can be easily misused if extreme care is not taken or practiced regularly.

Shakespeare also said "the first thing you do, kill all the lawyers." I tend to alter the sentiment slightly and claim that if we never had lawyers, we would never need lawyers. The FARs are proof enough of that. I think that if lawyers hadn't been involved in writing the FARs, they'd be much simpler and easier to understand. Nobody thinks or talks like that, so why write stuff like that?

That last thought has the potential to launch a whole new thread based on my contention that aviation litigation is always fundamentally flawed when they get rid of everyone who knows anything about it when they impanel a jury. If I am ever involved in that kind of litigation, I want everyone on the jury to be a pilot or mechanic - otherwise they wouldn't constitue a jury of my peers! The lawyers would never go for it because they would get away with spinning their legal BS.

I used the word "invalid" before. A literal interpretation of the FARs I mentioned earlier would be that such an Airworthiness Certificate (out of Annual) would not be "effective." Just what exactly does that mean? That is all I am really asking above.

Last edited by Rajay on Mon Jul 18, 2011 10:42 am, edited 1 time in total.

[Rajay]

A P-51 I take care of is known as 44-73029. The bill of sale when it returned to the states from Nicaragua lists it along with about a dozen other P-51s all by the Military S/N. All FAA paper work uses this number. I don't even know what its NAA number is. The data plate has the 44-73029 number on it...That is its identity.

Interpolating from the information in Joe Baugher's military aircraft serial number database, P-51D-25-NA USAAC Serial Number 44-73029 should have carried North American Aviation s/n 122-39488. He didn't have that exact information, but as I said, I calculated that by interpolating from some of the others for which he did have the NAA serials.

He also had listed that 44-73029 was surplused to Nicaragua as GN122, that it came back to the US as N7999A, and that since 1969, it has been registered as N51JB.

The current FAA database has the serial number for N51JB listed as "44-73029-A" - got any idea what the extra "A" is all about? Maybe it is from the "Aero Classics" that is included in the "Manufacturer Name" along with "North American" now.