ANC99LA146

The private pilot, who was also a mechanic with an inspection authorization, was landing the airplane from a ferry flight after the airplane had been involved in a previous accident (see ANC99LA155). The pilot/mechanic said that immediately after touchdown, the nose wheel began to vibrate. The nose gear assembly collapsed, and the engine firewall to which the temporary nose gear assembly had been attached, sustained substantial damage. Inspection by an FAA airworthiness inspector revealed that a nose landing gear assembly from an earlier model Cessna 182 had been installed without a shimmy damper, and without provision for connection to the steering bungees. A doubler had been installed on the previously damaged firewall to provide mounting structure for the nose gear assembly. A review of photographs taken at the first accident site revealed that substantial damage to the left wing, left horizontal stabilizer and left elevator (including missing the outboard 4 inches of elevator, and the left elevator tip counterweight), tail cone and empennage, and lower engine cowling existed prior to the ferry flight. The FAA issued a ferry permit for the airplane but did not inspect the airplane, nor verify the extent of damage which existed prior to the flight occurring. The airplane had received its last annual inspection on July 18, 1997, 26 months before the first accident.

On September 10, 1999, at 2122 Alaska daylight time, a Cessna 182 airplane, N1881X, sustained substantial damage when the nose gear assembly collapsed during the landing roll on runway 33 at Merrill Field, Anchorage, Alaska. The private pilot was not injured. The flight was being conducted under 14 CFR Part 91 as a ferry flight. The flight departed the Farewell Airstrip, Farewell, Alaska, about 2000 for Merrill Field. Visual meteorological conditions prevailed at the time of the accident, and a VFR flight plan was filed.

The pilot holds an airframe and powerplant (A & P) mechanic certificate with an inspection authorization (IA). He was ferrying the airplane after installing the nose gear assembly, and completing additional field repairs to damage sustained in an earlier accident on September 6, 1999 (reference NTSB report number ANC99LA155).

The pilot/mechanic told the NTSB investigator-in-charge (IIC) during telephone interviews on September 13 and 15, that upon landing at Merrill Field, the nose gear assembly began to vibrate and collapsed.

An FAA airworthiness inspector inspected the airplane on September 15. His inspection revealed the engine firewall to which the temporary nose gear assembly was attached had buckled. According to the FAA inspector, a metal doubler had been installed on the firewall prior to the ferry flight to provide an attachment point for the nose wheel assembly. This nose wheel assembly was from an earlier model Cessna 182, and did not incorporate a shimmy damper. The nosewheel assembly also did not incorporate connections to attach the steering bungees from the rudder pedals.

Photographs taken by the Alaska State Trooper who discovered and documented the previous accident (ANC99LA155) were reviewed by the FAA inspector, and the NTSB IIC. These were compared to the aircraft after landing at Merrill Field. It was determined that there was substantial damage to the left wing, left horizontal stabilizer and elevator (including missing the outboard 4 inches of elevator, and the left elevator counterweight), tail cone and empennage, and lower engine cowling prior to the ferry flight. Additional substantial damage occurred to the firewall during the landing at Merrill Field in the area of the doubler which was installed to support the nose landing gear.

The NTSB IIC reviewed photographs of the engine firewall taken after the accident at Merrill Field with the pilot on December 8. These photographs showed two rows of empty rivet holes in the firewall. The pilot told the IIC that he had attached the upper portion of the temporary nosewheel assembly to the firewall using approximate number 8 size machine screws through these holes. He stated that when the nosewheel folded down under the airplane, the screws pulled out of these holes in the firewall. The pilot stated that no damage was done to the metal firewall when the attaching hardware pulled through. The photographs showed a stack of at least four large area washers between the firewall, and the doubler angle installed by the pilot/mechanic. The pilot stated he had to bend and deform the doubler in order to get the nosewheel assembly to fit because of the existing damage to the firewall.

The pilot/mechanic told the IIC that it was acceptable to fly the airplane back to Anchorage with the nosewheel assembly in this configuration because he was only going to land once. He stated he had to shorten the rudder trim cables about five inches, and run the cables over metal instead of pulleys because of the firewall and tailcone deformation. He indicated this was acceptable because it was only for one flight, and he had recovered numerous other airplanes in the same fashion.

The airplane was flown initially 10 miles from a gravel bar (location of accident ANC99LA155) to the 4,790 feet long by 145 feet wide Farewell Airstrip. There was no special flight (ferry) permit issued for this flight.

The FAA Anchorage Flight Standards Office issued a ferry permit to the pilot/mechanic on September 9, which stated the airplane could be flown from the Farewell Airstrip to Merrill Field for the purpose of maintenance. This route was about 100 miles, and required flying over a densely populated portion of Anchorage. The issuing inspector was the Principal Maintenance Inspector assigned to oversee the pilot/mechanic who works as the Director of Maintenance for an air taxi company.

The ferry permit stated the pilot must hold a least a "MEL" pilot certificate. The pilot did not hold a rating for multiengine airplanes. The permit further stated: "The aircraft will be inspected by a Certificated Airframe and Powerplant Mechanic or Repair Station. A notation which includes appropriate certificate number and signature will be made in the aircraft maintenance records to certify that the aircraft is safe for the intended flight and that no airworthiness directives that prohibit the flight are outstanding....Inspect left wing root and attaching points for damage prior to flight....Record all discrepancies found in aircraft log book."

The pilot/mechanic wrote an addendum to the aircraft logbook, and attached it to the ferry permit, which stated: "Date 9-10-99 Tach 655.7 I certify that I have inspected this aircraft and have determined that the requirements of this document have been met. This document shall remain a part of the aircraft records until superceded. Horizontal L Hand -Horizontal mount, aft fuselage, elevator, prop strip, firewall, nose gear, lower cowl, rudder trim, LH wing outboard."

No logbook entry was found which described the extent of damage to these components, nor corrective actions. No entry was found stating that the left elevator was missing the entire section outboard of the left outboard elevator hinge prior to the flight. No entry stated that the left elevator horn and balance weight was missing prior to the flight.

14 CFR Part 43.13 Performance Rules states in part: "(b) Each person...performing preventative maintenance, shall do that work in such a manner...that the condition of the aircraft, airframe...will be at least equal to its original...condition (with regard to aerodynamic function, structural strength, resistance to vibration...).

14 CFR Part 91.7, Civil Aircraft Airworthiness, states in part: "The pilot in command shall discontinue the flight when unairworthy mechanical...or structural conditions occur."

14 CFR Part 91.13 states in part: "No person may operate an aircraft in a ...manner so as to endanger the life or property of another."

14 CFR Part 21.197 Special Flight Permits, states in part: "(a) A special flight permit may be issued for an aircraft that may not currently meet applicable airworthiness requirements but is capable of safe flight, for the following purposes: (1) Flying the aircraft to a base where repairs, alterations, or maintenance are to be performed..."

14 CFR Part 21.199 Issue of special flight permits, states in part: "(a) ...an applicant...must submit a statement...indicating ...(4) the ways...in which the aircraft does not comply with the applicable airworthiness requirements...."

FAA Order 8130.2D, FAA Airworthiness Inspectors Handbook, states in part: "Section 11. Special Flight Permits, 171. Special flight permits are issued for aircraft that may not meet applicable airworthiness requirements, but are capable of safe flight. A special flight permit is not an authorization to deviate from the requirements of Part 91."

FAA Order 8130.2D also states: "171.g. No person may operate a product to which an AD applies...If an AD requires compliance before further flight...a special flight permit shall not be issued." Research revealed the most recent annual inspection of the airplane had been completed on July 18, 1997, 26 months prior to the accident. No record of AD compliance was found after this annual inspection. The pilot/mechanic tol