Narrative:

Ferry flight from home airport to ZZZ, us, for wkend special event. Upon landing, I was immediately approached by 2 FAA inspectors for a typical ramp check at preshow events. One examiner in particular was thorough in his inspection of the aircraft, its paperwork, and in debriefing my passenger about my preflight briefing before departure to ZZZ. At this time he suggested 3 items that I should address, none of which included the placement of the plane's airworthiness certificate, which is tucked into a clear plastic pouch that is attached onto a hinged headrest that also acts as a hatch-way to a small luggage compartment. When the headrest is closed, the certificate is not in plain sight. This arrangement is very similar to a 'pitts-special.' the skybelt is a small semi-opened cockpit bi-plane and this arrangement serves to protect this paperwork from WX and aerobatic maneuvers. I have been flying this plane for 3 yrs and have been ramp checked in many FSDO areas and canada and never experienced any difficulty with this arrangement. Day #2 at XA45, I was PIC towing a glider which was performing in the special event. Flight was uneventful. XA30-XB45, the skybelt flew an aerobatic act at the special event by another pilot. AB45 I, alone, was approached again by the same FAA examiner that was most thorough the previous day and asked to see the plane's paperwork again (XC18). This was the first time that the placement of the airworthiness certificate was brought to my attention. He reviewed this documentation again and looked through the waiver trying to find any information that addressed this issue. Not being totally satisfied with this arrangement, he suggested that I review this matter with the owner, review carefully the rules to see if it complied, and that he could 'let it go' and no more would be said about it. Our standard procedure is to have this headrest down before boarding, therefore, the certification is in the cockpit reference for all to see. Only when I, the pilot, boards do I then FLIP the headrest up and secure it in position. This arrangement has even been pointed out to other inspectors before and even resulted in comments like 'good idea' and 'no problem.' day #3 at XA45, arriving at the airport for the pilot's briefing, I was once again approached by this particular inspector who seems upset now and was asked to accompany him for a private meeting to discuss 'certain matters.' I was somewhat surprised now and not wanting this meeting to be private, I requested that others be present, which now seemed to make him angry. I was then informed I was in violation of 91.203(B). He asked for my pilot certificate, obtained information from it and handed it back. His final response to me was that I would be contacted by mail should there be any need for further review and that he was going to perform a full 'blue ribbon' review of the plane's certifications and limitations. Being my first experience confronting an agitated FAA inspector, I was somewhat taken aback. Fortunately for me the tow pilot, and the glider set, was a saturday only performance. However, I did ferry the plane back to the home airport. Still shaken by this encounter, I waited until this particular FAA representative left the ramp area and consciously took extra time and precautions for my preflight check, pretkof duties, and while flying, to assure a safe trip home for me and my passenger. This flight was uneventful and the airworthiness certificate in question was 'clipped' onto the dash/instrument panel for the entire flight. Corrective action: 1) I still believe our arrangement meets the intent of 91.203(B), 2) tape or attach the certificate in a place that will expose it to the elements as possible, 3) obtain a waiver similar to most 'pitts'. P.south. I fixed the first 3 items called to my attention on day #1.

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Original NASA ASRS Text

Title: A STEEN SKYBOLT EXPERIMENTAL ACFT PLT OWNER WAS RAMP CHKED PRIOR TO SPECIAL EVENT. DURING ACFT INSPECTION BY FAA INSPECTOR, RPTR LEARNED THAT THE CERTIFICATE OF AIRWORTHINESS IN THE ACFT DID NOT MEET THE INTENT OF THE FAR DISPLAY REQUIREMENTS.

Narrative: FERRY FLT FROM HOME ARPT TO ZZZ, US, FOR WKEND SPECIAL EVENT. UPON LNDG, I WAS IMMEDIATELY APCHED BY 2 FAA INSPECTORS FOR A TYPICAL RAMP CHK AT PRESHOW EVENTS. ONE EXAMINER IN PARTICULAR WAS THOROUGH IN HIS INSPECTION OF THE ACFT, ITS PAPERWORK, AND IN DEBRIEFING MY PAX ABOUT MY PREFLT BRIEFING BEFORE DEP TO ZZZ. AT THIS TIME HE SUGGESTED 3 ITEMS THAT I SHOULD ADDRESS, NONE OF WHICH INCLUDED THE PLACEMENT OF THE PLANE'S AIRWORTHINESS CERTIFICATE, WHICH IS TUCKED INTO A CLR PLASTIC POUCH THAT IS ATTACHED ONTO A HINGED HEADREST THAT ALSO ACTS AS A HATCH-WAY TO A SMALL LUGGAGE COMPARTMENT. WHEN THE HEADREST IS CLOSED, THE CERTIFICATE IS NOT IN PLAIN SIGHT. THIS ARRANGEMENT IS VERY SIMILAR TO A 'PITTS-SPECIAL.' THE SKYBELT IS A SMALL SEMI-OPENED COCKPIT BI-PLANE AND THIS ARRANGEMENT SERVES TO PROTECT THIS PAPERWORK FROM WX AND AEROBATIC MANEUVERS. I HAVE BEEN FLYING THIS PLANE FOR 3 YRS AND HAVE BEEN RAMP CHKED IN MANY FSDO AREAS AND CANADA AND NEVER EXPERIENCED ANY DIFFICULTY WITH THIS ARRANGEMENT. DAY #2 AT XA45, I WAS PIC TOWING A GLIDER WHICH WAS PERFORMING IN THE SPECIAL EVENT. FLT WAS UNEVENTFUL. XA30-XB45, THE SKYBELT FLEW AN AEROBATIC ACT AT THE SPECIAL EVENT BY ANOTHER PLT. AB45 I, ALONE, WAS APCHED AGAIN BY THE SAME FAA EXAMINER THAT WAS MOST THOROUGH THE PREVIOUS DAY AND ASKED TO SEE THE PLANE'S PAPERWORK AGAIN (XC18). THIS WAS THE FIRST TIME THAT THE PLACEMENT OF THE AIRWORTHINESS CERTIFICATE WAS BROUGHT TO MY ATTN. HE REVIEWED THIS DOCUMENTATION AGAIN AND LOOKED THROUGH THE WAIVER TRYING TO FIND ANY INFO THAT ADDRESSED THIS ISSUE. NOT BEING TOTALLY SATISFIED WITH THIS ARRANGEMENT, HE SUGGESTED THAT I REVIEW THIS MATTER WITH THE OWNER, REVIEW CAREFULLY THE RULES TO SEE IF IT COMPLIED, AND THAT HE COULD 'LET IT GO' AND NO MORE WOULD BE SAID ABOUT IT. OUR STANDARD PROC IS TO HAVE THIS HEADREST DOWN BEFORE BOARDING, THEREFORE, THE CERTIFICATION IS IN THE COCKPIT REF FOR ALL TO SEE. ONLY WHEN I, THE PLT, BOARDS DO I THEN FLIP THE HEADREST UP AND SECURE IT IN POS. THIS ARRANGEMENT HAS EVEN BEEN POINTED OUT TO OTHER INSPECTORS BEFORE AND EVEN RESULTED IN COMMENTS LIKE 'GOOD IDEA' AND 'NO PROB.' DAY #3 AT XA45, ARRIVING AT THE ARPT FOR THE PLT'S BRIEFING, I WAS ONCE AGAIN APCHED BY THIS PARTICULAR INSPECTOR WHO SEEMS UPSET NOW AND WAS ASKED TO ACCOMPANY HIM FOR A PVT MEETING TO DISCUSS 'CERTAIN MATTERS.' I WAS SOMEWHAT SURPRISED NOW AND NOT WANTING THIS MEETING TO BE PVT, I REQUESTED THAT OTHERS BE PRESENT, WHICH NOW SEEMED TO MAKE HIM ANGRY. I WAS THEN INFORMED I WAS IN VIOLATION OF 91.203(B). HE ASKED FOR MY PLT CERTIFICATE, OBTAINED INFO FROM IT AND HANDED IT BACK. HIS FINAL RESPONSE TO ME WAS THAT I WOULD BE CONTACTED BY MAIL SHOULD THERE BE ANY NEED FOR FURTHER REVIEW AND THAT HE WAS GOING TO PERFORM A FULL 'BLUE RIBBON' REVIEW OF THE PLANE'S CERTIFICATIONS AND LIMITATIONS. BEING MY FIRST EXPERIENCE CONFRONTING AN AGITATED FAA INSPECTOR, I WAS SOMEWHAT TAKEN ABACK. FORTUNATELY FOR ME THE TOW PLT, AND THE GLIDER SET, WAS A SATURDAY ONLY PERFORMANCE. HOWEVER, I DID FERRY THE PLANE BACK TO THE HOME ARPT. STILL SHAKEN BY THIS ENCOUNTER, I WAITED UNTIL THIS PARTICULAR FAA REPRESENTATIVE LEFT THE RAMP AREA AND CONSCIOUSLY TOOK EXTRA TIME AND PRECAUTIONS FOR MY PREFLT CHK, PRETKOF DUTIES, AND WHILE FLYING, TO ASSURE A SAFE TRIP HOME FOR ME AND MY PAX. THIS FLT WAS UNEVENTFUL AND THE AIRWORTHINESS CERTIFICATE IN QUESTION WAS 'CLIPPED' ONTO THE DASH/INST PANEL FOR THE ENTIRE FLT. CORRECTIVE ACTION: 1) I STILL BELIEVE OUR ARRANGEMENT MEETS THE INTENT OF 91.203(B), 2) TAPE OR ATTACH THE CERTIFICATE IN A PLACE THAT WILL EXPOSE IT TO THE ELEMENTS AS POSSIBLE, 3) OBTAIN A WAIVER SIMILAR TO MOST 'PITTS'. P.S. I FIXED THE FIRST 3 ITEMS CALLED TO MY ATTN ON DAY #1.

Data retrieved from NASA's ASRS site as of July 2007 and automatically converted to unabbreviated mixed upper/lowercase text. This report is for informational purposes with no guarantee of accuracy. See NASA's ASRS site for official report.