Has anyone fabricated a new placard for the manual flap handle? Is that legal, or must I use the Beech decal (which I can’t find)?
Has anyone seen a discrepancy between their POH and the TCDS, on the maximum (third notch) flap extension setting? On my plane (1975 C23 Sundowner (M-1743), the POH says 35 degrees but the TCDS says 30 degrees.
FLAP HANDLE PLACARD
Credit to Bob Steward:
If the TCDS spells out the text and placement for the placard, you can legally fabricate it. If it spells out a specific Beech part number instead, technically you must have that part number on your plane. I put it on the grip portion rotated such that the text is facing the pilot.
Realistically, if the TCDS spells out both the data and a part number, and you can’t get the part number any more, your sole remaining option is to fabricate it using the “approved data” in the TCDS. If the needed data is not spelled out in the TCDS, you can try to get it from the decal on another aircraft, or from an illustration in the illustrated parts manual, and cite the decal part number and content as the approved data. The approved data can be used by an A&P-IA to submit a Form 337 to the FAA to make the homemade placard “legal”.
I have had an opinion from one other A&P-IA, who has said that under the recent FAA “clarification” of requirements for field approvals, this would qualify as a “minor change”, having no need for a field approval, At best, it might simply require a log entry to validate the content of the decal, citing the “approved data” source, as the data and its location in the plane remains unchanged.
Things like this seem to be highly subject to the opinions of different A&P-IAs and FAA-FSDO staff, and each opinion-holder can always readily cite the foundation for their opinion. The FAA “clarifications” on both 337 requirements and on ADs also most often seem to just add more mud to already murky water.
One club member recently fabricated that placard by photo copying the AFM version at 120% size onto adhesive backed label paper, installed it on the flap handle, and then covered it with some 1″ ID clear heat-shrink tubing. Seems like it would be hard to get any more “approved data” than that. It would certainly look like the original decal, and with the clear heat-shrink on it, it should last the remaining life of the airframe (if no one paints over it). Only the material used to make the decal would differ from the original decal. The one-inch diameter clear heat-shrink can be found at an electronics supply store (usually NOT at Radio Shack). It is most commonly found in three-foot lengths, and is not tremendously expensive. You could always sell lengths of your leftovers to fellow members, to avearge out the modest cost if necessary.
Credit to Bob Steward on the 30 degree versus 35 degree third-notch flap extension setting:
I would normally say that the TCDS is THE definitive reference.
Interesting note: The TCDS requires a placard of 30 Deg for the third notch, but it also has a section for the control surface movements that lists the Wing Flaps Down at 35 Deg +/- 1 deg. The Maneuvering Speed is also different than the placard by 1 mph. The AFM-POH describes the third notch as 35 Deg. The combined evidence suggests that the TCDS has a typo in the 30 degree number, as both the POH/AFM and the TCDS control surface travel section agree.
Throughout the TCDS, the maximum flap travel extension setting shows 35 degrees, with the exception of 30 degrees up through SN M-554. All the subsequent models and Serial Numbers show 35 degrees. It is in the Placards section, item “b.”, where the conflict occurs. The early Model 23 shows two extension settings, of 15 and 30 degrees. This matches the M-001 through M-554 serial number range, for which the TCDS does show a maximum extension of 30 degrees. The three extension settings shown on the placard in “b.”, for all the later models, are 15, 25, and 30 degrees. Since both the POH and the TCDS Travel Limits show a max travel of 35 degrees, the “30” is virtually certain to be a typo for these later aircraft.
Also note that the TCDS DOES NOT refer to a Beech part number for the placard; the TCDS instead spells out the content. That means you should be free to fabricate your own replacement placard, with the caveat that you should do your best to make it conform to the original. I would still advise making the log entry for the minor interior refurbishment, stating the work done and the “approved data” that was the basis for the new decal (TCDS page and section, and POH page and section).