The History Of The Aleutian Goose – Part 2
By David H. Marion – As previously noted, the actual conversion work done by the Fish & Wildlife Service on N780 in Anchorage was quite far along by January 1970 and continued to outpace the official documentation and engineering approvals that were nominally required by the FAA and applicable regulations. Copies of official records obtained from the FAA archives in Oklahoma City clearly show that the aircraft in question was converted by FWS directly from its legacy Navy JRF-5 configuration to their planned final model “G-21F” configuration without the formal paperwork really ever catching up with it. It also happened without it ever being even so much as worked on, much less formally converted or officially re-certified as a model G-21G actually by McKinnon.
In the middle of their Goose conversion project, FWS took steps first to formally re-certify and re-register N780 from its original identification as a former Navy model JRF-5, Bu. no. 37819, as a civilian model G-21A, serial no. B-72. On November 1, 1970, they submitted an application for a new certificate of registration identifying it as such and on which it was noted that the aircraft total time in service was only 1,460.8 hours. That was followed up on January 6, 1971 when FAA inspector Dale L. Hanson incongruously signed off on a new Standard Certificate of Airworthiness for it in the Normal category. He did so in spite of the fact that the aircraft no longer “conformed” as a Grumman G-21A, was no longer “normal” by any stretch of the imagination, and at that time was not actually flyable or otherwise “airworthy.” Not quite 3 weeks later however, the installation of the TPE331 engines was apparently completed and FWS applied for a new Special Certificate of Airworthiness in the Experimental category on January 22, 1971, which in turn was also approved by FAA Inspector Hanson.
In May 1971, the formal application was finally made to the FAA for the new hydraulic system in the form of Supplemental Type Certificate (STC) no. SA514AL. In a project status memo dated October 28, 1971, Propulsion Engineer Gary Killion noted that FWS personnel were anticipating being able to start the initial flight test program “on or about 15 Dec  in Los Angeles” but apparently that did not happen and it turned out to be a bit optimistic. Even so, notes of other FAA correspondence made during that same time frame show that they were still conducting static tests of the new hydraulic system in February 1972.
Those same notes suggest that some of, if not the actual, very first flight tests of the Aleutian Goose may have occurred on Friday, March 10, 1972. The FAA notes mention “tufted flight demonstrations” that were being flown by Theron Smith during which he was observed by Fish & Wildlife’s Jerry Lawhorn and FAA Alaskan Region engineering chief, Robert W. Stephens flying “chase” in a Cessna 180. The first aircraft of any new design are often covered with small tufts of yarn or string during flight test programs in order to visually monitor airflow patterns over and around the airframe. The FAA notes mention as well that the following day was spent discussing “problems illuminated by tuft patterns” on this very much modified Goose.
Catching-Up Details and Paperwork
During March 1972, FWS personnel apparently also completed several minor systems modifications to the aircraft including a new oxygen system and a new combustion heater mounted in the front baggage area, for which a couple of FAA Forms 337 were filed on March 9th 1972 and March 15th 1972 respectively. Later reports also note that a formal Pre-flight Type Certification Board meeting was held on March 30, 1972 at which the differentiation of oversight of various aspects of the overall conversion project between the FAA offices in Anchorage and Los Angeles was determined.
On July 21, 1972, Strato Engineering’s owner and chief engineer, Abe M. Kaplan, (DER* LA-10) endorsed an FAA Form 8130-3 “Statement of Compliance with FARs” certifying the design and engineering substantiation of the new hydraulic system. This step was a precursor to final approval of STC no. SA514AL by the FAA. However, there was once again another large gap in the official records between then and September 1973. The associated FAA correspondence notes similarly indicate what they called a “long pause” in the Aleutian Goose program between March 1972 and May 1973.
(*A Designated Engineering Representative or DER is an independent engineer working under the authority of an appointment by the FAA on their behalf.)
The FAA notes further show that on May 17, 1973, they got word indirectly from Theron Smith that he was planning to conduct an “unsymmetrical flap flight test soon” after which he expected to be ready to take the aircraft down to Los Angeles to conduct the final, formal flight test program with the FAA inspectors there. This particular flight test was necessary because the flaps on each wing were activated independently so there was a chance that a partial failure of the system could cause a flap to go down on one side but not on the other, creating potential control issues due to the uneven lift and drag on each wing that would result. In hindsight too it became obvious that their estimate of being ready for the formal flight tests in Southern California was still overly optimistic.
Changes in Project Oversight
The large gaps in the records of the Aleutian Goose conversion project may be as well at least partially attributed to the fact that in July 1973, the Office of Aircraft Services (OAS) was formed within the US Dept. of the Interior and OAS took over combined responsibility for all USDI-owned aircraft that had been previously operated in Alaska almost independently by the Bureau of Land Management (BLM) and FWS. There had been something of a sibling rivalry between FWS and BLM but when OAS was formed, most of the senior managers came from BLM, apparently much to the consternation of the folks remaining at FWS. It was also at the point that OAS took over control of the USDI aircraft in Alaska that all of the FWS plans to convert two additional Gooses and eight more Beavers to have turbine engines, in the words of Jerry Lawhorn, “went down the tube.”
During September 1973, FWS and OAS personnel in Anchorage apparently completed further detail modifications including installation of a second combustion heater, this time mounted in the aft fuselage, and removal of the original retractable landing lights underneath each wing in conjunction with installation of new, smaller, retractable Grimes landing lights on each side of the nose of the airplane. FAA Forms 337 for each modification were filed on September 20th and 21st, 1973. One of the new landing lights was oriented along the longitudinal axis of the airplane for use in an in-flight attitude and the other oriented slightly downward for use while taxiing on the ground.
On October 23, 1973, another FAA Form 337 was filed; it was for the installation of dual navigation lights mounted in what was the bottom of each wingtip float, about 6 inches back from the front. When the floats were retracted up to form the wingtip on each side, one of the lights was slightly below the centerline and the other equally offset above. This was a completely different configuration for the wingtip navigation lights than the ones used by McKinnon and approved for the model G-21G and other McKinnon G-21 series conversions, almost all of which utilized a single nav light installed exactly in the center of the front of each float.
FAA Alaskan Region engineering chief Bob Stephens wrote a letter to Gary Killion and other FAA engineering staff based in Los Angeles on December 11, 1973. In that letter, he noted the status of various aspects of the project being overseen by the FAA’s Anchorage office separately from the major structural and engine modifications covered by the initial project outline. The first item on his list was the fact that wing metalizing (replacement of the original doped fabric covered sections of the outboard wing panels behind the aft spar with very thin sheet aluminum) had been completed and for which a new STC, no. SA467AL, had been issued by the FAA office in Anchorage. However, there is no longer any record of that STC in the FAA online database and no formal record of it was ever included in the official records of the Aleutian Goose that were archived in Oklahoma City. Note that STC no. SA467AL must have been a unique (“one-time only”) STC and in some way different from the wing metalizing standards used previously by McKinnon and already approved as his drawing no. MPD-2200 under STC SA4-1109 and TC 4A24.
More Details, Paperwork, and Test Flights
The December 11, 1973 letter also detailed progress on the combustion heater installations, the not-yet-approved new hydraulic system, installation of new radar and avionics, exterior lighting, cabin interior accommodations, a completely new electrical system, and modifications to the cabin entry door and emergency exit hatches, on which all of the sills were lowered to make egress easier. That letter further noted that “a copy of the latest conformity inspection reports” had been prepared by Alaska Region airworthiness inspector Fred Klouda (AAL-ACDO-31) under terms of the previous agreement regarding the division of responsibilities for inspection and oversight between the Anchorage and Los Angeles offices of the FAA and that it was attached as well.
In spite of the fact that it is not reflected in any way in the official documentation for the airplane, the informal or unofficial FAA correspondence notes also suggest that the Aleutian Goose was probably flown down to Southern California and was there during the period from November 1973 until February 8, 1974. During that time, some preliminary flight testing was apparently conducted with engineers and inspectors from the FAA Western Region Engineering Office in Los Angeles actually located in nearby Van Nuys, CA. The focus during those early flight tests seems to have been limited to validating the new hydraulic system that had been installed in the aircraft to run both the landing gear and the wing flaps.
On February 21, 1974, Alaska Region Engineering Chief Bob Stephens issued final approval through the FAA office in Anchorage for STC SA514AL to cover the installation of the new hydraulic system. The system was powered by a single, stand-alone, electric motor-driven, hydraulic pump and a hand pump was used as a backup. In the case of the FAA Form 8110-2 (the actual Supplemental Type Certificate) issued by Stephens at that time and the Form 8110-3 “Statement of Conformity” previously issued in July 1972 by DER Abe Kaplan also for the hydraulic system project, the airplane was already identified as “McKinnon G-21G serial no. 1240” even though it had not yet otherwise been so identified, much less officially certified or registered as such.
The project apparently kept limping along bit by bit and the next most significant milestones in the conversion of the Aleutian Goose occurred in March 1974. That month, FWS finally made a formal application to the FAA to re-register it as “McKinnon G-21G serial no. 1240” and a Form 8050-1 “Application for Aircraft Registration” was submitted on March 5, 1974. On March 18, 1974, it was followed up with an informal, handwritten note sent from OAS “Quality Control Specialist” Jarret L. Lawhorn to the FAA Aircraft Registration Branch in Oklahoma City in which he claimed that “N780 has been converted to a McKinnon G-21-G as per type certificate 4A24 and has been issued a McKinnon Serial Number 1240.” The note further requested that a new certificate of registration be issued accordingly and sent to OAS in Anchorage. Of course, Lawhorn did not say that the new serial number or even a new data tag had been issued actually by McKinnon – because they had not.
Also during March 1974, numerous further minor detail modifications were documented as well by means of additional FAA Forms 337. Note that FAA Forms 337 are typically used to document “major alterations and repairs” to type-certificated aircraft under the “maintenance” authority of Part 43 of the Federal Aviation Regulations and they have no formal part in the “production” of a new aircraft under Part 21. Aircraft so altered do not become something else or a new type of aircraft; they remained certified and officially identified as they were previously; a Grumman G-21A modified by means of an STC remains certified under TC 654 and remains officially identified as a Grumman G-21A.
All of the Forms 337 submitted by FWS to the FAA in March 1974 were done as individual Field Approvals through the Anchorage office of the FAA and they covered the installation of new Aeroflash anti-collision lighting on the bow and vertical fin, a battery temperature monitoring system, an electric horizon gyro (a flight reference instrument,) utility power outlets around the cockpit and cabin, supplemental downward oriented spotlights under the wings at Wing Station (WS) 282 (i.e. 282 inches out each wing from the centerline of the aircraft fuselage,) a new Emergency Locator Transmitter (ELT) installation, and a completely new King avionics package that had been installed in the instrument panel.
Finally too an application was made for a new or amended Special (i.e. Experimental) Certificate of Airworthiness and on all of this documentation the aircraft was for the first times consistently identified as “McKinnon G-21G serial no. 1240” still in spite of the fact that it had not been “built” by McKinnon nor had ever been “conformed” as a model G-21G as is required by FAR 45.13(a) in order for it to be officially so identified.
Even More Paperwork and Catching-Up
The rest of 1974 and the first half of 1975 may have been, from what can be inferred from additional gaps in the official records and reports obtained from the FAA archives in Oklahoma City, a matter of playing “catch up” with all of the engineering documentation that had been lagging behind the actual conversion work done on the airplane itself during the whole course of the project. It was not until November 3, 1974 that a final application was made to the FAA by OAS for what nominally became “McKinnon’s” STC no. SA2809WE to cover almost all of the differences between Fish & Wildlife Service’s de-facto model “G-21F” design and the two “real” model G-21G aircraft previously converted and re-certified as such actually by McKinnon ( a photo of one of those “real” McKinnon G-21G aircraft was included in Part 1.)
By that same time frame, the people at FWS and OAS were calling their Aleutian Goose a “McKinnon G-21G (STC)” which supposedly meant that it differed from a standard McKinnon-built model G-21G because of the installation of “major alterations” in the forms of STC nos. SA2809WE and SA514AL. That terminology however differed from McKinnon’s own nomenclature whereby he described aircraft that he had both converted under TC 4A24 and also modified or altered by means of additional STCs as “Hybrids.” That fact is further evidence that FWS was continuing to do, as they had done all along, their own thing on the Aleutian Goose project without any meaningful input or contribution from McKinnon after 1970.
This fact was further emphasized even more just a couple of years later when on March 12, 1976, the FAA Western Region Engineering Office in Los Angeles approved an OAS request to amend STC no. SA2809WE to allow changes in the aircraft’s “zero fuel weight”* and associated documentation included in its Airplane Flight Manual (AFM.) This was done without any input or approval from McKinnon himself in spite of the fact that he was the nominal owner of the STC in question. The FAA went so far as to issue a revised STC directly to OAS and requested that they return the original version of the actual supplemental type certificate to them, indicating clearly that STC no. SA2809WE, which was nominally owned by McKinnon, was not even in his possession.
(*”Zero Fuel Weight” is the maximum weight limit to which an aircraft can be loaded beyond which the only other thing that can be loaded on board is fuel.)
In any case, numerous engineering reports were prepared by Strato Engineering Inc. to substantiate and support both STC no. SA2809WE in particular and the Aleutian Goose project in general. Those reports covered not only the installation of the Garrett TPE331 engines and the 40-inch fuselage extension, but the revised flight control system and dorsal fairing, the “tour bus” windshield, the new belly fuel tank, re-location of the tailwheel (5 inches lower than standard for the G-21 series) and a myriad of other details aside from the new hydraulic system that was certified separately by means of STC no. SA514AL.
Some nine months after the formal application for STC no. SA2809WE was submitted by FWS to the FAA in November 1974, the aircraft was apparently ready to begin its final, official flight test program with the FAA in Southern California. On August 5, 1975, Jerry Lawhorn wrote a letter to the FAA Western Region Flight Test Office in Van Nuys, CA and requested issuance of an updated “Experimental” certificate of airworthiness and appropriate special operating limitations in order to test fly the aircraft for the purposes of “research & development” and to “show compliance with the FARs.”
On that application too, in addition to showing a total Time in Service of 1,465.8 hours prior to its conversion, it was noted as well that a further 1,643 hours of interim flight testing already had been done on the Aleutian Goose since its initial conversion while operating as a non-certified, “public-use” (i.e. Federal Government-owned) aircraft outside the nominal jurisdiction of the FAA. On August 11, 1974 the new certificate of airworthiness (Experimental) and associated operating limitations were issued by inspector G. L. Lincoln of the FAA Western Region Aircraft Engineering District Office in Van Nuys, CA, and soon thereafter FWS personnel began preparations for another long ferry flight with the Aleutian Goose from Anchorage down to Los Angeles.
A Problem Revealed
On the actual flight down from Alaska to California, Jerry Lawhorn later recounted an ironically prescient story about how the aircraft was initially found to be a bit unstable in yaw. The pilots and mechanics on board had a lot of time during the flight to discuss it and they figured that some kind of lateral instability had been inadvertently introduced as a result of the 40-inch fuselage extension that had been added to the cockpit area, all of which was in front of the original center of gravity. It was theorized that the vertical planform of the fuselage was essentially a double camber airfoil in its own right and by moving the effective center of pressure so much farther ahead of the center of gravity, any little bit of lateral divergence in yaw would almost instantaneously create a positive angle of attack relative to the airflow along the flat-sided body of the aircraft. That would in turn generate even more lateral “lift” further exacerbating the problem and causing the aircraft to diverge and yaw even more.
Even so, Lawhorn also made note of the fact that during one of the first legs of their trip, from Yukutat at the top of the Inside Passage through the “panhandle” of southeastern Alaska down to Seattle, the aircraft picked up a rough accumulation of airframe ice which actually caused the unstable yaw tendency to decrease. After they got down to Van Nuys and started working directly with the FAA engineers there, Lawhorn hit upon the idea of replicating the aerodynamic effect of that ice by installing three pieces of aluminum extrusion on each side of the nose of the airplane. The sections of extrusion functioned as lateral “stall strips” which disrupted the airflow along the sides of the fuselage any time the aircraft started to yaw inadvertently again and they effectively killed any sideways oriented “lift” that was generated as a result of the yaw. The stall strips worked well enough that they were later permanently riveted into place and they are clearly visible in any photograph showing the nose of the aircraft taken after 1975.
The joint FWS-FAA flight test operations were based out of the Van Nuys airport and they were supported locally by Volpar’s own aircraft maintenance facility right there on the airport. In addition to the flight testing of the modified aircraft and operational testing of all of its new systems, engine and propeller substantiation and vibration analyses were done by Garrett personnel from Scottsdale, AZ and Hartzell personnel from Ohio. The testing program carried on through the last quarter of 1975 and on November 7, 1975, the primary STC by which the aircraft nominally had been modified, SA2809WE, was approved by the FAA. A little more than a month later, on December 17, 1975, a new Standard Certificate of Airworthiness in the Normal category was issued for the airplane.
At the time that the new certificate of airworthiness was issued in December 1975, the aircraft was listed as having a total of 3,022.9 hours time in service and it was identified as a “1944 McKinnon G-21-G” – but that too was not valid because there was no such thing as a “McKinnon G-21G” before 1969, when the nominal type design was first approved by the FAA – and of course the aircraft in question had not been built actually by McKinnon nor ever conformed as a model G-21G. Even so, a new certificate of registration identifying it in the very same incorrect way was issued to its owner, the US Department of the Interior’s Office of Aircraft Services at that time.
Once again it should be pointed out that a 1944 Grumman G-21A (ex-Navy JRF-5) “Goose” modified by means of an STC is supposed to remain certified and otherwise officially identified as such. An airplane cannot be converted or rebuilt or otherwise transformed into something else (i.e. a new model) except by means of a Part 21 “production” operation. The whole point of the existence of McKinnon’s new (in 1958) type certificate no. 4A24 was that it was triggered by and even in fact required by Title 14 of the Code of Federal Regulations (CFR) §21.19 which still states that: “Each person who proposes to change a product must apply for a new type certificate if the FAA finds that the proposed change in design, power, thrust, or weight is so extensive that a substantially complete investigation of compliance with the applicable regulations is required.”
That particular Federal Aviation Regulation is also directly related to the “Notice” shown on the back of every FAA Form 337, which states in part that “An alteration must be compatible with all previous alterations to assure continued conformity with the applicable airworthiness requirements.” What that means is that multiple STCs or at least “major alterations” cannot be installed on one particular aircraft without some regard for the fact that it may eventually be so greatly changed that it is essentially deemed to be a whole new type design – and building and certifying an example of a whole new type design is always a Part 21 “production” operation – not a Part 43 “maintenance” operation.
It was for those very reasons that after coming up with so many different modifications and STCs for the Grumman G-21A series McKinnon was eventually issued a whole new type certificate (4A24) for the “new” aircraft that he “built” by converting legacy Grumman G-21 series airframes – almost all of which were in fact so extensively rebuilt with new parts that they qualified as and were officially certified as literally “zero-time” new aircraft. McKinnon was also issued new parts manufacturing approval in the form of Production Certificate (PC) no. 409 to cover the fabrication of all of the new parts that he used in his Goose and also Widgeon conversions. Even so, none of his so-called “Super Widgeons” were ever so extensively modified that they were required to be re-certified as completely new models.
A Better Perspective
From that perspective and based on an obviously more through and comprehensive analysis of the applicable regulations than was done at the time, it is clear that instead of being “certified” as a supposedly modified “McKinnon G-21G” the Aleutian Goose was really all along still just a model “G-21F” as originally intended, even though that particular type design was never officially approved as such by the FAA. Nor was it required to be, except as a result of an arbitrary policy decision on the part of senior bureaucrats within the US Dept. of the Interior. As a Federal government-owned and operated “public-use” aircraft, it was officially exempt from FAA regulatory jurisdiction or oversight.
However, the other side of that same coin is the fact that it was “built” actually by the FWS personnel in their own hangar in Anchorage – but they never qualified for any kind of aircraft or even parts “production” authority under FAR Part 21. So in that sense, they were never anything more than “amateur” builders of the aircraft that they converted, so even as a “Fish & Wildlife” model G-21F (because that is who actually built it and as what – Ref. 14 CFR §45.13a) the Aleutian Goose should never have been eligible for anything more than an Experimental certificate of airworthiness after its conversion. It was in essence just an unusually large and somewhat glorified “homebuilt” aircraft the design of which was never approved or type certificated as such by the FAA.
Admittedly, none of that mattered so long as the airplane was fulfilling its primary mission on behalf of the Fish & Wildlife Service, flying wildlife survey and patrol missions, which it apparently did with great success over the next 17 years. The validity, or lack thereof, of its nominal certification after its conversion by FWS did not really matter before 1992. That year however, the Dept. of the Interior finally decided that they no longer had any more need for their unique, custom-built, wildlife survey and patrol aircraft and they put it up for sale at auction through the General Services Administration or GSA. Its subsequent service as a “private” aircraft and its final fate will be the subject of Part 3 to come.
Dave Marion is the Technical Content Editor at Seaplanemagazine.com. As A&P and IA with 29 years of experience in aircraft maintenance, he is also a Commercial Pilot with Airplane, Single & Multi-Engine, and Instrument ratings. He has a BA from Colgate University in 1984 and also graduated cum laude from Embry-Riddle Aeronautical University (DAB) with a BS in Aviation Technology in 1990. He can be reached along with all of the editors via E-Mail: email@example.com