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Thread: Engine upgrade question

  1. #1
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    Default Engine upgrade question

    I'm posting here instead of the PA15/17 Vagabond section because there are so many great mechanics (and others with knowledge of engine swaps) on this site that might not be reading the Vagabond section.

    I'm very happy with my PA-15 with its A-75 engine, but I think it would be even better with a C-85-8. Today, I spoke with Don Swords, of Don's Dream Machines in Griffin GA. He's the holder of the STC for using O-200 crankshaft in the C-85. He tells me a freshly overhauled Contiental C-85-8 with new cylinders would cost just over $14,000, and labor to remove my A-75 and install the C-86 would be around $800. I know this is a lot of money to spend on a Vagabond, but since I want to stay within the Sport Pilot category, and I think the Vagabond is the best of all the vintage aircraft that fit into the LSA rule, I'm seriously considering it. My take is that Don would do a good job.

    My question is, does this seem a good route for getting a C-85 on my Vagabond? And has any one here had experience with Don's Dream Machines?

    Thanks,

    -Ed

  2. #2
    pmills Guest

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    Ed,
    A couple thoughts. Money is obviously something only you can decide on. If it's worth it to you, then go for it. Next thing to consider is if this can be done and signed off. I checked the FAA website for type certificate and STC data. I also checked the Short Wing maintenance documents. I don't find anything showing that a C85 has been STC'd for installation into a PA-15. Since this aircraft was originally TC'd with the O-145-B2 (65 HP) it will take some paperwork to install an engine with 85 HP into this airframe. Maybe someone else on this site has done this. Or does Don already have this figured into the $800 price for swapping engines? If there is no STC, there is only the field approval method of installing a different engine. And according to FAA Order 8300.10, Volume 2, Change 21, Figure 1-3, the FAA generally will only field approve an increase in horsepower of 10% over the original installation. An increase greater than 10% generally needs an STC.My math says going from 65HP to 85HP is around a 30% increase. My experience with the FAA suggests it will be difficult to obtain a field approval on this installation.
    I don't like being a wet blanket, but if you want things to be signed off correctly (to be able to sell the plane someday, maybe?) you might want to inquire of Don's Dream Machines as to how they intend to handle the paperwork.
    Pete

  3. #3
    d.grimm Guest

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    Ed,
    My PA-15 has a C85-12 and I have the 337 for this one and a copy of another 337 for a C85. Give me your address and I will send you copies.

  4. #4
    Wayne Guest

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    I know of one PA-15 with O-200 cylinders on his engine. I believe these cylinders are a direct replacement for a C-85 or a C-90 I don't remember which one. The fellow moved away a few months ago but I will see if I can contact him and see what paperwork he has. WAyne

  5. #5
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    Default

    if anyone can get ahold of John Wilczac any more he had a field approval that was dated sometime in the 50's [before some certain date] he said that feild approvals dated before such date were "approved data" and if you referanced his they could not deny yours

  6. #6
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    Default

    Jim Beck has a PA-15 with an 85 hp in it. He is a member and posted to the PA-15 forun about his PA-15 for sale some months ago.
    He moved to Altanta from San Marcos, TX a year ago and the plane was still here. Perhaps the paperwork would be of use.

    J.D.

  7. #7
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    Default

    I just recently spent the day with my local FAA rep discussing an engine upgrade for my Clipper. His stance was that anything more than 10 % HP increase would require either an STC or for the change to go through engineering which would take at least 6 months. I had several copies of previous 337's for engine upgrades but he said that they weren't "approved data" no matter when they were done.

  8. #8
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    If the correct block is filled out and signed by the administrator (I forget the number) then it IS approved data. The actions had to take place before (I think ) 1957 and applied only to CAR-3 airplanes. Of course the local inspector will do just what the hell he wants to do anyway.

  9. #9
    pmills Guest

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    Ladies and gents, if you want the real deal on what can be used as approved data, check out the FAA website. I'm not savvy enough to just paste the weblink, but go to faa.gov. Click on the "Orders and Notices" link and open up 8300.10. You will find most of the answers in Volume 2, Chapter 1, page 1-1, Paragraph 5 (A) (4) (f). That is precisely where the FAA states that a CAA Form 337 (NOT the FAA form) dated prior to October 1, 1955 is considered FAA approved data. What is NOT stated and is apparently open to interpretation by the local FAA offices is what I was told: if I wanted to use one of these pre-October 1, 1955 CAA 337s, then I had to follow it exactly. EXACTLY. No deviations. I was told that it could only be used in the same manner as an STC. The problem with these older 337s is that there is usually not enough detail to copy the installation EXACTLY to satisfy the 21st century FAA. I wish you the best if you attempt to do this.Some of you will probably have an FAA inspector who is somewhat human, possibly reasonable, and it may work. Others may end up where I did.
    The other thing to consider is the current requirement for ICA - Instructions for Continued Airworthiness. These older 337s didn't have anywhere near enough detail to satisfy the current requirement for ICA on a major alteration. The old statement that the installation will be inspected in accordance with Part 43, Appendix D and the manufacturer's maintenance manual just doesn't cut it anymore. Check out the sixteen point ICA checklist farther down in the same section of 8300.10. Better have your thinking caps on when you get to this point. As my FAA guy said last year, "Pete, 2006 is the year of ICA, and we will be watching!" Of course, now that your 337s go straight to Ok City instead of your local FSDO, I don't know how they are going to watch something that doesn't cross their desk.
    Keep in mind that if you decide to use a pre-1955 CAA 337 as your data and file it with Ok City instead of letting your FSDO guy see it, if there is a problem later on you face the possiblity of being hit with a violation for each and every time you flew the aircraft with the incorrect paperwork (another gem of caution from my FAA!).
    If you really want to install a larger engine, keep the resale value of the aircraft in order, and avoid FAA violations, the best bet is to start by sitting down with the FAA inspector who is responsible for your area and see if the field approval process will work for him. This idea of taking someone else's 337 and thinking it will work exactly the same for your aircraft with a different FAA inspector involved is really a pipedream.
    By the way, if someone has a field approved alteration, then block 3 on the front page is what the FAA signed. But it still doesn't mean that the same job will be accepted by a different inspector. It just gives you more ammo to argue that they should
    Pete

  10. #10
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    Default

    I think that this may cover it. The page references is:

    http://www.popularaviation.com/Form337.asp

    Approved vs. Acceptable Data
    Getting 337s thru the system has become a real nightmare for aircraft owners, in part because FAA FSDOs want "approved data". 337 approvals dated before October 1, 1955 are treated just like information on the TCDS ("approved data"). This extremely important difference in the definitions between "acceptable data" and "approved data" is what makes early 337 forms so useful and important to us today.

    Four regulations, FAR 65.95, FAR 121.378, FAR 135.437, and FAR 145.51 all require ìapprovedî data for major repairs and major alterations.

    The difference is laid out in Order 8300.10, Vol. 2, Chapter 1, Section 1, (5)(A)(4)(f):

    Approved data can be Type Certificate Data Sheets (TCDS), Airworthiness Directives (AD), Designated Engineering Representative (DER) data, Designated Alteration Station (DAS) data, FAA-Approved data, FAA-Approved ManufacturerÃ*s data, Supplemental Type Certificates (STC) and appliance manufacturers manuals, and Form 337s dated before October 1, 1955.

    If you canÃ*t find approved data of this type, your only chance for getting data approved is to apply to the FAA for an STC or to ask a local FAA inspector for a Field Approval.

    There are three different kinds of Field Approvals for which the local FAA inspector can sign off:

    EXAMINATION of data only: This is the most common form of Field Approval. The mechanic or repairman submits ìacceptableî data to the local FAA office for approval. The ìapproved dataî can be used to perform a major repair or major alteration. Once the data has been approved under this procedure it can be used only for that one aircraft (described in Block 1 of FAA Form 337). However, if you want to do the exact same repair or alteration to another like make or model aircraft you can use the original Form 337 as the basis for obtaining a new Field Approval for the second aircraft.

    PHYSICAL INSPECTION, demonstration or testing of the repair or alteration: This is rarely done except in cases where technicians find unapproved engine or components installed on aircraft, which apparently have been installed for some time. Since the aircraft has flown successfully for many hours, and FAA inspector can, if satisfied with the installation, approve the installation. He does so by signing a new Form 337.

    EXAMINATION of data only for duplication on identical make and model aircraft by the original modifier: This is a procedure that saves the maintenance technician and the FAA a lot of time. For example, one technician wants to install duplicate avionics packages on as many Cessna 501s as possible; or maybe he wants to install duplicate installations of tundra tires on Beech 18s. The technician can submit the data to be approved along with a request that the data approval be extended to other identical aircraft. The FAA inspector, if satisfied, signs Block 3 that grants duplication of the data for the original Form 337. When the technician finishes a duplicate alteration on other aircraft, he sends the FAA a regular FAA Form 337 properly filled out listing the ìapproved dataî on the back and making references to the Field Approval. To avoid problems, attach a duplicate copy of the original Field Approval From 337.
    What Cannot be Approved:
    Some repairs and alterations are so complex they are actually design changes and require an STC. The following alterations are examples of alterations that can't be Field Approved.

    Increase in gross weight and/or changes in center of gravity range

    Installation, changes, or relocation of equipment and systems that may adversely affect the structural integrity, flight, or ground handling characteristics of the aircraft

    Any change (alteration) of movable control surfaces that may adversely disturb the dynamic and static balance, alter the contour, or make any difference (plus or minus) in the weight distribution

    Change in control surface travel outside approved limits, control system mechanical advantage, location of control system component parts, or direction of motion of controls

    Changes in basic dimensions or external configuration of the aircraft, such as wing and tail platform or incidence angles, canopy, cowlings, contour or radii, or location of wing and tail fairings

    Changes to landing gear, such as internal parts of shock struts, length, geometry of members, or brakes and brake systems

    Any change to manifolding, engine cowling, and/or baffling that may adversely affect the flow of cooling air

    Changes to primary structure that may adversely affect strength or flutter and vibration characteristics or damage the tolerance design philosophy

    Changes to systems that may adversely affect aircraft airworthiness, such as:
    Relocation of exterior fuel vents
    Use of new type or different hydraulic components

    Tube material and fittings not previously approved


    Changes to oil and fuel lines or systems that may adversely affect their operation, such as:
    New types of hose and/or hose fittings

    Changes in fuel dump valves

    New fuel cell sealants

    New fuel or oil line materials

    New fuel or oil system components


    Any change to the basic engine or propeller design controls, operating limitations, and/or unapproved changes to engine adjustments and settings having an affect on power output

    Changes in a fixed fire extinguisher or detector system that may adversely affect the system effectiveness or reliability, such as:
    Relocation of discharge nozzle or detector units

    Use of new or different detector components in new circuit arrangements

    Decreasing amount or different type of extinguishing agent

    li> Changes that do not meet the minimum standards established in a Technical Standard Order (TSO) under which a particular aircraft component or appliance is manufactured


    Modifications to approved type (TSO) radio communications and navigational equipment that may adversely affect reliability or airworthiness, such as:
    Changes that deviate from the vacuum tube or semiconductor manufacturer's operating limitations
    Any changes to IF frequency
    Extension of receiver frequency range above or below the manufacturer's extreme design limits
    Major changes to the basic design of low approach aids
    Changes that deviate from the design environmental performance

    Changes to aircraft structure or cabin interior of aircraft that may adversely affect evacuation of occupants in any manner

  11. #11
    d.grimm Guest

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    Just reinforces my original idea that you better find a airplane that is the way you want it because you probably won't be able to change it.

  12. #12
    pmills Guest

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    Ed, were you able to find out how Don's Dream Machines intends to sign off the engine swap if you decide to do it?

  13. #13
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    It is almost always cheaper to buy the airplane the way you want it rather than modify one. There are lots of 85 hp PA-15s. Perhaps the guys at don's dream machines has a relationship with their local FAA.

  14. #14
    pmills Guest

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    They may have some relationship with their local FAA. They have a really nice website and list their three STC's for modifying engines with O-200 parts. The STC's are showing on the FAA website as well. Seems they also have access to DAR and either DME or DMR capabilities. I still don't quite see how they would sign off the engine swap to a C85 in a PA15 with the abilities listed on their web site. Maybe they have a DER who will handle the paperwork. Or maybe there is something a DMR can do that I haven't heard about. Pretty sure I know what a DAR and DME can do, and it doesn't include approving data for major repairs and alterations.

  15. #15
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    A DER can approve the data.

  16. #16
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    He asked me if there is an STC for the swap, and I told him there are plenty of 337's supporting the upgrade, and we left it at that.

    I'm sort of busy today, and I've only had time to skim what others have posted, but I'm beginning to think this may be more difficult than I anticipated.

    I'll get around to reading the posts more carefully tomorrow, and go from there.

    The response to my post has been fantastic. It's what I love about this board. The depth of knowledge here is astounding.

    Thanks to all who have posted so far. I owe you.

    Hopefully I'll be able to work this out.

  17. #17
    pmills Guest

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    I agree, a Designated Engineering Representative (DER) can approve data. I work with about half a dozen who are on staff where I work. I also have a friend outside of work who is a structures DER. However, I have found that some folks think one way to sidestep the FAA is to persuade a DER to sign an FAA Form 8110-3 approving the data for the job they want to do. What many folks don't clearly understand is that
    1) DERs have definite limitations on their authority. There are DER ratings for various specific areas, such as structures and flight systems.
    2) DERs are literally tied with apron strings to their FAA advisor. This FAA person is responsible for every bit of activity performed by a DER. Each DER is required to submit an activity report at least annually to their FAA advisor and the advisor is supposed to review everything the DER has done. And believe me, the FAA will hammer a DER who approves data beyond the scope of the DER's authority. And one thing a DER absolutely cannot do is approve data for an alteration that is supposed to be done only by STC!

    I mention this to help any members who may think that they can hire a DER to avoid the problems associated with alterations that are categorized by the FAA as needing to be done only through the STC process (such as engine upgrades exceeding 10% HP). Here and now in aviation as we have it, I really doubt that any DER who values their ticket will take an old 337 showing an engine upgrade and try to write an 8110-3 approving the data as a way to avoid the STC process. If anyone is lucky enough to get a DER to approve this kind of job, pay them twice what they ask and file the 337 as fast as you can! Just kidding - bear in mind that the FAA has the power to override a DER approval and invalidate the entire job if they, the FAA, feel they have proof that the DER acted outside the scope of the DER's authority. To the FAA, it is exactly the same scenario as an IA acting outside the scope of the IA's authority - if an IA signs off a job improperly the FAA can ground the aircraft. Doesn't make any difference if the poor schmuck owner thought the IA was doing it correctly. Guess who is left holding the grounded aircraft? (Guess how I know this!!!)

    Pick your A&P's, IA's and DER's carefully. If you pick them incorrectly, it is your aircraft that is grounded, not theirs. Then the lawyers start getting rich.

  18. #18
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    You can do the research yourself and have a DER approve it and help you submit it to the ACO. Like you said mot DERs are specific to a certain field (structures, powerplant, propulsion, etc.) In my experience you have to find someone with the specific knowledge and relationship with the ACO. The ACO can make or break you just like an Airworthiness Inspector. I am sure Don Swords has a good working relationship with the FAA and some engineers to be able to get it done. It has been done a lot with proper documentation so that should help.

  19. #19
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    In view of the fact that you are not really modifying anything in the engine on an engineering evaluation basis, and are not modifying the structure other than maybe the mounting of the engine and would be interested in performance and stress on the existing airframe, wouldn't you need to be looking for a DAR, (Designated Airworthiness Representative?) as opposed to a DER (Designated Engineering Representative.)

  20. #20
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    It's amazing to me on these previously accomplished modifications why the anal retentive nature of the FAA. This is like regulating dirt. They have been around that long and have the same service difficulties.

    There are several paths the FAA could take to certify the modification, not least among them their own regulations. The problem is that the lawyers run the FAA just like everything else.

    There are no reasons why not operationally. Many have been done, before 1955 which make it approved data just like TCDS data. The TCDS are no more specific than the data on the old 337's. What is necessary are some inspectors with common sense who are not afraid of their own shadows. They look for reasons to deny rather than how to accomplish something. They reward deniers rather than accomplishers.

    Every day I deal whith people who tell me why things can't be done rather than peolpe who tell me how something can be done.

    My opinion is that we have already paid for the time of the FAA inspectors. Noe they want us to pay even more to be over regulated.

    Correct me if I am wrong here. The 337's say replaced 65 hp with 85 hp engine? what else is there? The form factor of the engine is the same. The fuel lines are the same. The weight si slightly different. The fuel flow is higher. These things have been tested before and found to be OK.

    Someone with more money than good sense ought to do this mod just to hammer it by the FAA for the hell of it in my opinion.

    Just an opinion.
    J.D. Barron

  21. #21
    pmills Guest

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    To my knowledge, according to Part 183 of the regs and the couple FAA Orders dealing with designees, DARs handle approvals of airworthiness certificates and related conformity inspections on the basis of approved data. Also to my knowledge, the same regulatory guidance says that only DERs can approve data. This has typically taken me down the path of seeking a DER in order to obtain FAA approved data when performing a major repair or alteration. A DAR is the person who issues ferry permits, airworthiness certificates for aircraft and export articles and can also perform conformity inspections related to initial STC projects.

    In the case under discussion on this thread, I would expect the services of a DER are more likely to fill the bill than those of a DAR.

    As always, my opinions, life experiences, successes and failures are based only on those FAA personnel with whom I have worked. Other folks may have substantially different outcomes with different FAA personnel and may think I have a screw loose since their results don't match up with a doggone thing I have written here

  22. #22
    Stephen 998 Guest

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    Put a Rotax 912s in and be done with the FAA Certification process.

  23. #23
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    I have often thought that the Rotax would sure make a nice engine choice for my Vag.

  24. #24
    Artie Gallegos Guest

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    I have the C-85-8 on my J-3. Its a completely different aircraft compared to the C or A65's. When I had my engine rebuilt a few years ago I went with the STC'd O-200 crank, pistons etc....I ordered mine through Aircraft Specialties. Let me tell you what a difference it was. They claim no horsepower improvements but everybody I talked to agrees its somewhere in the mid 90's hp. T.O. (solo) about 150-200 ft and climb around 800fpm! I hope you get your approval because you will be smiling for weeks after that first flight...

  25. #25
    Stephen 998 Guest

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    Yes, I've been dreaming that someday after I retire I should build a Vag from scratch and the try the Rotax. First I need to see how much extra time I get in retirement.

  26. #26
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    Now here is a vagabond with a 85 hp engine that may be of interest. There are a few other mods as well.
    Here is the link to the page: http://www.nasm.si.edu/research/aero/aircraft/helio.htm

  27. #27
    pmills Guest

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    If it is of interest, here is the 337 the FAA approved for me when I pursued a field approval for changing from 125 HP to 135 HP on a PA20. This particular aircraft was a low serial number for which the 135 HP was not eligible by type certificate. I had to spend a fair amount of time documenting that the basic components of the aircraft were the same for either engine. And since the increase in horsepower was less than ten percent, it made for a fairly easy approval. However, you can also see the ICA that I had to write up. The interesting thing is that this field approval also got a gross weight increase! This is because I wrote the limitations as being the same for the PA 20 "135" and those limitations have a gross weight of 1950 lbs instead of the 1800 lbs for the PA 20. I pointed this out to the FAA inspector and also pointed out that FAA Order 8300.10 says gross weight increase is supposed to be done via STC. His rationale was that the increase could be field approved since it was listed in the type certificate for that aircraft with that engine. And who says miracles don't happen?
    Well, doggone it, the file limit is 19.5 KB and this 337 is 65.5 KB. I sent it to the SWPC webmaster some time ago to put in the maintenance documents, but it never showed up. Guess if someone wants to see this, let me know and I will email it to you.

  28. #28
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    Default 337

    if you want to email it to me, i'll make it available on my site.

    andy2220@earthlink.net
    Andy Anderson
    PA-22/20-150

  29. #29
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    Another case of having money in the bank but we can't use it on worth while things for the club. Thanks Andy. It appears you think more of this data than the SWPC powers that be.

  30. #30
    pmills Guest

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    Andy,
    I'll try to get it to you tomorrow. Somehow the pdf file showing the signature copy got corrupted and my hard drive won't read it. Thanks for the response, maybe this will help someone else down the road.

  31. #31
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    Quote Originally Posted by pmills
    Andy,
    I'll try to get it to you tomorrow. Somehow the pdf file showing the signature copy got corrupted and my hard drive won't read it. Thanks for the response, maybe this will help someone else down the road.
    Pete

    I got the file and it is posted on the secondary site (link to that page is on primary site) It is last entry under STC'd items column.


    andy
    Andy Anderson
    PA-22/20-150

  32. #32
    pmills Guest

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    Andy,
    Thanks for taking the time to post this. You maintain a real nice site.
    Again, to anyone who is interested, I can't claim that you can cut and paste a different owner and tail number and then expect your FSDO to approve this. I recognize that each FSDO is different and may balk at something my FSDO felt was ok (such as the statement about the operating limitations which included the gross weight increase). But from what I've seen recently, if you do your homework about what has been approved in the recent past, what the FAA Order 8300.10 outlines as "field approveable" vs "STC only",and meet the Feds more than halfway with the ICA typed the way they are looking for, then you stand a reasonable chance of getting a field approval. Hope I don't come across as "preachy" since I know a lot of members have been very successful in getting field approvals, but I know everybody doesn't have that level of experience and may feel a bit uncertain how to start and what is needed.
    Cheers
    Pete

  33. #33
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    Quote Originally Posted by d.grimm
    Ed,
    My PA-15 has a C85-12 and I have the 337 for this one and a copy of another 337 for a C85. Give me your address and I will send you copies.
    Dave gave me copies of the 337 for the engine and also wingtanks. Posted it on my web page, it's on the second page or additional page linked at the bottom and top of the page with SWP data
    Andy Anderson
    PA-22/20-150

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