Alaska Aviation Administration?

[Bruce Fenstermacher]

.. They are the Federal Aviation Administration, not the Alaska Aviation Administration. I am not sure why I see all the posts that say the FAA up here does things differently. I actually think maybe shops down south just do not research and try to do things legally and work with their inspectors. Come on guys, is it really that adversarial down south with the FAA?

Actually things are different in Alaska and here is one law that makes it so.

• Section 40113(f) of 49 U.S.C. requires the Administrator, when modifying regulations in title 14 of the CFR in a manner affecting intrastate aviation in Alaska, to consider the extent to which Alaska is not served by transportation modes other than aviation, and to establish appropriate regulatory distinctions. Because the majority of potentially affected operators are in Alaska, this proposed rule could, if adopted, affect intrastate aviation in Alaska.

I've never been in Alaska so I have no first hand experience. I only know what I've read from other experience. I do know that a few years ago when the famous change 15 came into effect which brought ICAs and started the end of field approvals. It was rescinded in Alaska. So at least for a while there were two sets of rules.

I'd guess the difference really in the mechanics and FAA between lots of the lower 48 and Alaska is experience. I'd bet there are more mechanics with first hand experience pushing the envelope to maintain smaller aircraft in Alaska. That breads folks with experience to work for the FAA in Alaska. I think its probably more of a mind set. In Alaska where aircraft are used for survival the mentality is how can we make this happen safely. In the lower 48, while I know there are some, I don't know a single pilot in the lower 48 who relies on his aircraft for basic survival.

The mentality seems to be here with the mechanics and FAA is that we are safer not trying to make this happen. I've been an aircraft owner for twenty years and I have lots of friends who own aircraft and I know a few folks with their IA. Over that time I've never been able to talk a single IA into approaching the FAA for any field approvals. I'm talking simple stuff like approving an AeroFlash strobe system, standard equipment on later 172s but not approved for a 170. Quite frankly I can't think of single local aircraft owner friend of mine who has either.

[Metal Master]

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The mentality seems to be here with the mechanics and FAA is that we are safer not trying to make this happen. I've been an aircraft owner for twenty years and I have lots of friends who own aircraft and I know a few folks with their IA. Over that time I've never been able to talk a single IA into approaching the FAA for any field approvals. I'm talking simple stuff like approving an AeroFlash strobe system, standard equipment on later 172s but not approved for a 170. Quite frankly I can't think of single local aircraft owner friend of mine who has either.

Since the FAA sent out the letter to us IA’s quite a few years ago and actually for a while stopped doing field approvals at all. Once they had regrouped and re-written their guidance on field approvals I have done three field approved modifications to various aircraft. I work full time for Boeing Now and do not have as much time.
I installed a Ford alternator (later Cessna) on a 1963 172 which previously had a generator. On the same aircraft I installed Aeroflash Strobe lights on the wing tips. I also installed and had field approved Aeroflash strobes on the wing tips of my own170A
I had no difficulty obtaining these field approvals using the supporting data and wiring Diagrams from later Cessna model aircraft.
I had calculated the load analysis for these installed items, written continued airworthiness instructions and presented the proposed 337’s to the FAA inspectors prior to making the alterations. However I can tell you that if you were paying me full hourly billing to do all of this work if there was an STC available you would most likely chose to go that direction.
The FAA’s guidance according to the inspector when I presented the Field approvals for the alternator and strobe lights on the 1963 172 was that if there was an Existing STC for a similar installation even if it were for the installation of different products that they are not supposed to approve the request. However because it was equipment installed in a similar fashion using the original manufactures (Cessna) wiring Diagrams and parts. And that I had addressed all of the continued airworthiness issues and load analysis. He approved the installations.
I have been an aircraft owner for over 22 years. I have been an aircraft mechanic for over 40 years and an IA for over 25 years. I have done field approvals for many complicated things in that time, Forest service antenna and radio installations. Traffic watch and reporting, Micro wave FM transmitters and even paraplegic flight control installations in aircraft they were not STC’d for with STC’d equipment.
It does take a real need and understanding of the Field approval process and the trust of FAA inspectors that you are working with. This has all been done out of and with the Inspectors in the Seattle FSDO.
I have worked in Alaska and things are different

[marathonrunner]

I did not mean to stir up a can of worms. AC 43-210 is pretty specific on how to go about the field approval process and is standard nationwide. I know of several IAs in Washington, Nebraska, Alabama, California and Massachusetts that are using this process and not having any problems. Yes it is time consuming and you do have to do your homework but it is still possible to get field approvals nationwide, not just in Alaska.

Also you should checck with your inspector or the local FAA office as some items that were field approved in the past are merely logbook entries. Check the FARs also as they also spell out what constitutes a major or minor modification. AC23-27 is worth reviewing as well for aircraft built before 1980. I believe most if not all 170s fit into this category. The times they are a changin and in some ways it is easier to get things done legally and in some it takes more time and research on the part of the IA doing the approval. Once you have done a few and figure out the process and what the FAA is looking for paperwork wise it will go smoother in the future. There is a learning curve for the new process but it is not impossible. Oh and by the way I do not work for the FAA. I have owned and operated my own shop since 1982 as well as being an air taxi pilot in many parts of Alaska on floats, wheels and skis, single and multi engine. I have had my A&P since 1975 and my IA since 1982. I am still learning and if I stop learning I should just hang up the wrenches. I am also a gold seal flight instructor. The learning curve never ends.

[KS170A]

I was able to get my Aveoflash LED nav/strobe/position light assemblies field approved fairly easily. I just submitted a data package per AC210, answered a few questions via phone call with the FSDO and picked up the stamped 337 a few days later. If you have the data to substantiate what you want to do, a field approval shouldn't be difficult.

[Bruce Fenstermacher]

Josh thanks, I did actually get my AeroFlash system approved but not with the initial help of any IA. I ran into a FSDO inspector at work and asked him what I should do about a system installed by persons unknown. He said write a 337 and ICA and submit it. That is when I showed him the "sample" 337 and ICA I'd written in anticipation of his response and asked what changes if any I needed to make. He said none and took it with him to return to me approved since he didn't have his stamps.

That is when I asked him about an IFR GPS installation I wanted. He said you need a 337, ICA and an AFM supplement, do you have those. Of course I did. He reviewed them had me make some minor changes to the AFM supplement then took them as well. 3 days later I had the approved 337s. This after months of trying to get any IA just to ask the FAA how to proceed.

Hopefully things have changed with the new procedural guidance. I know I just stopped trying to get IA cooperation regarding contacting the FSDO about anything.

[minton]

I feel that the "New" (AC-210) way is far better for all involved. In the past it was a very subjective matter for the FSDO. Now with good guidelines I have had no problems getting approvals. The only area that still plagues the approval process is the consumer wanting something for nothing. ie the AI's time developing the paper trail. I as an 40 year AI still have the need to pay my bills. Endless phone calls ( brain pickers) from clients ties up my time, just to be told at the end that it's outragious to have to be charged a fee for my research and application time. Enough of those calls add up to alot of waisted, non billable manhours. Thats why AI's don't like to deal with Field Approvals. It has nothing to do with the process.

I have no problem with those who want to go straight to the source and go it alone.

[marathonrunner]

Minton

I cannot agree with you more. I too have had less hassles with the new system as opposed to the opinion of the new inspector you got when there was an FAA crew change. When I let people know of the time it will take to do the paperwork up front many say go ahead and many also walk away. Ther is no reason that an experienced and qualified expert in this area should work for free. We are not living in million dollar homes and driving Beemers. Often times our clients are. For them and most folks, aviation is a hobby and something they have to justify to the significant other. Keeping costs down for their hobby is imperative. I am not downplaying that aspect but as you said we too have bills to pay, hangars to afford, utilities to pay and all that goes with being in business. One would not go to a doctor based on cost. When you have a medical problem you want the best health care available no matter the cost. Your life depends on it. Everyones life depends on the work we do to aircraft including the paperwork to make sure everything is done to the best of our abilities. It is not just one life it is the other seats involved as well. You would think people would get a grasp on this aspect but it has not happened in my lifetime. Going to the guy who will do an annual based on a recent picture of the aircraft in flight seems to be status quo for many until they have real problems. When that happens then they wonder how all those other guys could have missed or signed off the annuals with all those problems. Unfortunately most of the problems were known by the owner/ operator and "deferred" until a later date. It amazes me how often owners will look at the list of discreps and say that we wont do this one and it is always based on cost. Maybe we should go back to the days when IAs actually had to issue the airworthiness certificate each annual and it actually did meet the type specs or as amended. There would be many grounded aircraft if we did.

[GAHorn]

I feel that the "New" (AC-210) way is far better for all involved. In the past it was a very subjective matter for the FSDO. Now with good guidelines I have had no problems getting approvals. The only area that still plagues the approval process is the consumer wanting something for nothing. ie the AI's time developing the paper trail. I as an 40 year AI still have the need to pay my bills. Endless phone calls ( brain pickers) from clients ties up my time, just to be told at the end that it's outragious to have to be charged a fee for my research and application time. Enough of those calls add up to alot of waisted, non billable manhours. Thats why AI's don't like to deal with Field Approvals. It has nothing to do with the process.

I have no problem with those who want to go striaght to the source and go it alone.

AMEN! Time is their hobby...but it's the Mx technician/IA's livlihood!