Reflections On The Grumman G-111
Written by David H. Marion – After Seaplanemagazine.com published Part 3 of my Spotter’s Guide for the Grumman Albatross, I received a very nice e-mail from Ray Wolfe, who in addition to his day job as an airline pilot is a renowned Grumman Albatross flight operations expert. Ray was a close friend and business partner of Chuck Kimes, the American Airlines captain who died in the tragic crash of the twin-turbine Aleutian Goose in the United Arab Emirates (UAE) in February 2011. Together they ran Seaplane Operations LLC, which along with Grumman Albatross maintenance and restoration expert Dennis Buehn used to sponsor annual Albatross fly-ins and training seminars on Lakes Havasu and Mead in southern Nevada. Ray also helped “crew” Dr. Bill DaSilva’s warbird Grumman HU-16C Albatross (N7025N, msn G-409, ex-USN Bu. no. 141262) when it was used to fly medical personnel and supplies into Haiti after the 7.0 earthquake that struck there in January 2010.
Ray also very generously shared with me a 47-page compilation of his research on Grumman Albatrosses, including histories of each aircraft and interesting tidbits about their production, etc. One such tidbit that was previously unknown to me was the fact that Chrysler Corporation (yes, the automobile manufacturer) apparently subcontracted the primary hull aerostructure fabrication and subassembly of 227 Albatross airframes out of the total of 466 aircraft eventually built by Grumman. The Chrysler-built hulls were manufactured in its Evansville, Indiana plant and were then shipped to Grumman’s main factory in Bethpage, New York for final assembly and completion.
In his notes on the G-111 commercial variant conversions that were done in the 1979 to 1983 timeframe, Ray mentioned that one of the “commonly asked” questions he gets about the G-111 variant is “could a standard Albatross be converted today into a G-111?” – to which his “short answer is NO.” He goes on to explain that in his opinion “even if you had all the drawings, tooling, etc., and performed every modification, without the production certificate authority you would still not have an airplane that could be certificated as a G-111.” I had to tell him however that I respectfully disagree with that assessment.
Ray was correct when he mentioned that the two PC’s previously used by Grumman to convert military-surplus HU-16 series aircraft into FAR Part 25 Transport-category certified aircraft eligible for commercial operations (PC’s nos. 23 and 1050 for Grumman’s factories in Stuart, FL and St. Augustine, FL respectively) are no longer in effect. Still, in my opinion, the fundamental issue is not the existence or lack of an FAA-approved Production Certificate.
As most Seaplanemagazine.com readers will already be aware, I used to work for Antilles Seaplanes LLC on their project to attempt to establish new production of the legacy McKinnon Enterprises Inc. model G-21G twin-turbine “Super Goose” the type design for which was FAA-approved under Type Certificate no. 4A24 in 1969. Also that the model G-21G was itself a conversion of older Grumman model G-21A aircraft that were originally manufactured under TC no. 654 between 1938 and 1945.
In McKinnon’s case, while he did have his own FAA-approved Production Certificate (no. 409) it was not geared toward the manufacture of whole new aircraft. Instead it granted approval only for the manufacture of new parts and STC “kits” that McKinnon both sold to others on an individual basis and also used to modify G-44 Widgeons and to convert legacy Grumman G-21A Gooses into essentially new, literally “zero-timed” McKinnon G-21 series aircraft under TC 4A24. All of those converted Goose aircraft however were not certified via PC 409. Instead McKinnon signed off the conversion of each and every one of them under the auspices of FAR Part 21, Subpart F – “Production under Type Certificate.” Accordingly it is my contention that in theory someone could come along and do the exact same thing to convert a legacy HU-16 Albatross into a “new” G-111 without having a PC of their own, but it would not be easy.
There of course would be several other caveats as well, the primary one of which is that to do so, you must either own the requisite Type Certificate (i.e. no. A22SO) or have explicitly written permission or a license agreement from the current owner to use it. (Ref. 14 CFR 21.6) In a nutshell, that satisfies the conditions that Ray mentioned in regard to having “all the drawings, etc.” However, for production under FAR Part 21, Subpart F, you also have to prove to the FAA that you have the capability to carry out the required fabrication and conversion work – the “tooling” and the “know-how” to use it. You also have to create and establish to the FAA’s satisfaction some sort of Quality Management System (QMS) or Approved Production Inspection System (APIS.) The reason for that is the fact that a “conversion” is still officially speaking a rebuilding and production or manufacturing operation under Part 21.
In the past and with too many “McKinnon” turbine Goose conversions in particular for another example, the people doing them (other than McKinnon himself that is) did not seem to appreciate the fact that such conversions are governed under FAR Part 21. Because McKinnon had so many individual Supplemental Type Certificates (STC) applicable to the Grumman G-21 series, it was incorrectly thought that both his and their own conversions were simply a matter of having their A&P mechanics install a bunch of STC’s as “major alterations” under FAR Part 43 and then waving a magic wand over the FAA Forms 337 and other associated paperwork to re-identify their conversions as new “McKinnon” aircraft. They were wrong.
As I have tried to explain over and over again in the course of several previous articles that I have written about those “McKinnon” Goose conversions, they were properly identified as such if and only if that particular conversion was carried out actually by McKinnon. Because conversion of an aircraft is technically-speaking a manufacturing or production operation, whoever does the conversion becomes the de facto new “builder” of the aircraft in question. (Ref. 14 CFR 45.13a)
So, for another example when Theron A. Smith and his team at the Fish & Wildlife Service (FWS) in Anchorage, Alaska converted the aforementioned Aleutian Goose, which was originally conceived as a stand-alone new model G-21F, it was wrong of them to claim subsequently that it was a modified “McKinnon G-21G” because it was never worked on or certified as such actually by McKinnon. In fact, FWS personnel did all of the conversion work and it was only loosely based on engineering data borrowed from McKinnon for the airframe changes and from Volpar for the installation of the unique Garrett (now Honeywell) TPE331-2UA-203D engines.
In reality, the real problem with doing a new conversion of a G-111 Albatross is not whether or not you have a PC, it’s whether or not you have the TC, a factory, and a quality system. In that context, Ray was essentially correct that from the standpoint of the people most likely asking him the question “could a standard Albatross be converted today into a G-111” who I assume are most likely to be current owners of military surplus “warbird” Grumman HU-16 Albatrosses, the short answer effectively is “no.” But that is not the long or only answer.
It would not be feasible or cost effective for just one owner to try to make just one new conversion, but that does not mean that it is impossible. Economically speaking, it would be feasible and cost effective to setup the necessary factory and production line only if several or even many old aircraft could be converted or a similar number of new G-111 aircraft were built from scratch. It is also important to note that the only way that any such “new” G-111 aircraft would be identified as “Grumman” would be if Grumman actually built them – and Grumman no longer exists as such since its merger with Northrop in 1994. They also no longer own the requisite TC no. A22SO.
In fact, rumors have abounded for several years now that the current owner of TC A22SO, a company called Amphibian Aircraft Technologies, LLC, (aka Amphibian Aerospace Industries) is in fact trying to build a new factory and establish a production line for both new G-111 and new HU-16 series aircraft – in Australia of all places. Articles appeared in: From 9/27/2016:The Daily Telegraph in Australia, ABC News Australia, Lakes Mail in Australia from 10/19/2016: Flight Global and from 2/22/2017: The Daily Telegraph in Australia again.
But so far as I have heard, they have not yet made any real progress. I’m sure though that most if not all of Seaplanemagazine.com’s readers and other Albatross enthusiasts out there will join me in wishing them the best of luck!
Dave Marion is the Technical Content Editor at Seaplanemagazine.com. As A&P and IA with 30 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: firstname.lastname@example.org