Questions from the Cockpit: The numbers are wild

“I have a question, Wildman.” 

“Shoot,” I replied. Wildman is my Top Gun call sign. Not that I’ve attended Top Gun. In fact, my only Navy jet experience is sitting in the cockpit of a static-display T-2 Buckeye at the USS Midway Museum in San Diego. The title is purely honorary, bestowed on me by my students for my high-energy, unorthodox, outside-the-box, sure-to-get-me-fired-someday teaching style.

Or, maybe it’s simply because Wil + D = Wild. Hard to say. But I’ll take the ego-building source of the call sign over the simple explanation any day of the week.

Of course, I knew what was going to happen next. This fresh-scrubbed, cherub-faced, wet-behind-the-ears pup of a pilot in the upper left corner of my Zoom screen was about to ask a question that the old, grey-haired master didn’t know the answer to. And having just taught this same pup that it’s disingenuous and dishonorable to fend off questions you don’t know the answer to with the old, “Well of course I could tell you, but you’ll learn more by looking it up for yourself” crap, I would be forced to fess up that I didn’t know the answer. The proper response, instead, is “I’ll have to get back to you on that,” a line I find myself deploying nearly every day of the week, Monday through Friday. 

You see, for the last year, my day job has been teaching Certified Flight Instructor (CFI) candidates how to be better teachers. To do this, my curriculum is built largely around how to deploy something called the Fundamentals of Instruction, or FOIs (pronounced fohies in the biz) in the classroom, on the ramp, and in the cockpit.

But part of learning to be a CFI also entails memorizing the finer points of a multitude of regulations and endorsements that are part and parcel of flight instruction. This focus on the minutia of the flight training business often causes my students to over-think things, and come up with the most twisted, mind-boggling questions imaginable. 

We had just finished a section on how to go about teaching student pilots airworthiness requirements, including maintenance and maintenance paperwork: Annuals, 100-hours, airframe logs, engine logs, propeller logs, and the FAA Form 337.

The 337’s full name is: “Major Repair and Alternation-Airframe, Powerplant, Propeller, or Appliance.” Airplane mechanics need to fill one out and submit it to the FAA pretty much any time they do any work on an airplane that requires a tool other than a screwdriver.

The CFI candidate’s question was, “Why do they call it a Form 337? Is that the reg that requires it?” 

Naturally, I said, “Well of course I could tell you, but you’ll learn more by looking it up for yourself.” 

Which produced the desired good-natured laughter from my 30 or so students.

Then I quickly reviewed my memory banks. I knew that most airplane maintenance stuff that we in general aviation need to worry about is in Part 43 of the FAA regs, and that Part 43 is actually a relatively small set of regs, with only 17 sections, much less 337.

Of course, Title 14 of the Code of Federal Regulations, where all things related to airplanes live, actually has 1,399 parts, but I had never heard of Part 337, so I rather doubted that it would come into play. (I looked it up later and it is an unused number, reserved for future use, under the procedural regulations section of the Office of the Secretary of the Department of Transportation for Aviation Proceedings.)

“I’ll have to get back to you on that,” I said, pressing my clicker to move on to the next PowerPoint slide.

After class, I used my office hours to search for the answer. After office hours, I used my cigar and bourbon time to search for the answer. After my cigar and bourbon time, I gave up and went to bed. The next morning, I fired off an email to the FAA.

No doubt, when Tammy Jones of the FAA’s Office of Communications opened my email, she rolled her eyes and thought, I wish this Wildman would stop writing me with all these crazy questions. Instead, she replied, “I’ll have to get back to you on that.”

As it turns out, quoting Jones’ email from a week or so later: “The form you referenced was created in 1954 by the Office of Management & Budget. Forms were sequential, so Form 337 has nothing to do with regulations or guidance at the time; simply a form number next in line. The form was not changed when a new numbering system was created because it is a crucial record for aircraft maintenance history.”

Naturally that led me to wonder what Forms 336 and 338 had been. Digging around in scans of old federal registers at the Library of Congress website, I discovered that Form 338 was apparently the Wholesale Liquor Dealer’s Semiannual report. 

That’s wild.

It doesn’t seem to exist anymore but, of course, Jones tells us that at some point the feds changed to a new numbering system — I wasn’t sure if that was a reference to the 1980 Paperwork Reduction Act or if the FAA had undertaken a renumbering itself at some point, but I wasn’t wild about the idea of pestering her any further on the subject. 

In today’s world, there’s an Optional Form 336 that’s used by the other FAR — not the Federal Aviation Regulations — but the Federal Acquisition Regulations. This FAR Form 336 is called a Continuation Sheet. Apparently, you use it with a number of other forms if you run out of space. But I wasn’t able to find out if this form also dates back to the 1950s.

There’s also a Form N-336 that’s used to request a hearing for a decision on a naturalization proceeding. In this case, the form links to Section 336 of the Immigration and Nationality Act regs. Wildly enough, this act was passed in 1952, so in theory, the form number being related to the act could be a coincidence.

Oh wait, for that to be true, it would mean that the federal government didn’t create any new forms for a full two years.

And even I’m not wild enough to believe that.