The International Cessna^® 170 Association

AR Dave wrote:Eric, yes i'm just talking about scanning logbooks, 337's etc & burning them on to a CD?
I didn't mean to restart a discussion on STC / 337's that stopped on Mar 22, 2004.

Dave, just because a pot's cold doesn't mean that you shouldn't give it a little stir!

Eric

zero.one.victor wrote: What about 337's for avionics installations? Another grey area.......

Eric

According to the Avionics Inspector at SAT-FSDO avionics installations do not require a Form 337 if they are simple replacements or additions to existing avionics and do not directly interface with flight controls (like an autopilot would.) Replacing a Nav/Com with another does not require a 337....not even if the autopilot uses it for navigation.
If a new installation requires alteration of airframe structure, wt and balance is "significantly" altered, and/or electrical requirements are exceeded by 80% of generated capacity...then a Form 337 is required. (Other issues are also in need of being addressed, but strictly speaking, that is the trigger for a 337.)

George, is this FAA inspector's position OFFICIAL? In other words, is it documented by an FAR or an AC, or is it just on that particular inspector's verbal say-so? And maybe in another FSDO's jurisdiction a 337 is required? There was a recent discussion on another topic about this sort of "determination".

George in our Allentown PA FSDO area, the inspector requires a 337 for ALL avionics installations of ANY equipment that was not on the TCDS and installed per the original specifications. None of the avionics shops in the area will argue or they'd be shut down.

I know cause I asked when I moved and installed new radio equipment.

Very Sad

whatever FSDO's area you are working in, they are your local gurus and their INTERPRETATION of the FAR's, Advisory Circulars, FAA Guidance, etc is the law. Good luck contradicting them.

When our company moved to eastern ND, the Fargo FSDO became our new lords. They didn't want anything to do with our aircraft mods (for cloud seeding/research) and so I was able to talk them into letting me go back to my old friends at Rapid City FSDO for the field approvals. what a pain, but less so than trying to re-educate new guys that weren't familiar with our stuff and needs.

whether I do something under my own A&P and IA, or under our repair station certificate, the local feds are the ones whose opinion of the rules is what counts. sometimes you can nudge them, but not often.

zero.one.victor wrote:George, is this FAA inspector's position OFFICIAL? In other words, is it documented by an FAR or an AC, or is it just on that particular inspector's verbal say-so? And maybe in another FSDO's jurisdiction a 337 is required? There was a recent discussion on another topic about this sort of "determination".

Well, he's the OFFICIAL Avionics Inspector for SAT-FSDO and he told me he's tired of filing them. He said they're unnecessary because they do not meet the definition of a major alteration or repair. But if an aircraft owner or repairman wishes to fill up the FAA's file on the airframe with paperwork...it's not illegal to do so....go ahead and mail them in. They'll file them....and the time spent doing it will simply put what they consider real work farther down in the que.
For the definition of a Major Alteration see: FAR 43, Appdx A, (a)(1)....not a word mentions avionics (except in the case of altering the basic design of the radio not in accordance with 1: the radio mfr's specs 2: the TSO, if any, or 3:an AD note. In other words, if you just install it in accordance with installation instrucitons....then no major alteration occurred and no 337 is required.
For the definitiion of Major Repair see: FAR 43, Appdx A, (b)(1)....not a word mentions avionics except calibration of radio equipment. (nothing about installation.)
I have knowledge of an inspector who ramp-checked a friends aircraft, and he grounded the airplane with a condition tag because he noticed the instrument panel had been changed from the original 1962 design to a custom design. All the logbooks had was an entry that the instruments had been overhauled and relocated in a newly constructed panel. The mechanic (an A&P only) showed up at the inspector's supervisors office and requested to be shown where the instrument panel was included in the definition of major alteration. The condition tag was revoked without further discussion, and the original inspector had to personally issue a letter to be included in the aircraft's records rescinding the condition tag.

Eric,

There is no gray area at all on TCDS equipment. If its on the TC, and as noted by another poster, applicable to your airplane's serial number, it can be installed (per good practices in AC 43) on your aircraft with merely a logbook entry.

An example: My airplane is currently wearing Federal AWB-2500 retractable wheel skis. These skis are called out on the TC for the 170B. There is a logbook entry in my maintenance logs noting the original installation, and each subsequent installation, but there is no 337, and Oklahoma City knows nothing about it, and hopefully never will. These skis require installation of cables, tabs for attachment of cables, hydraulic lines, a reservoir, a pump, and other stuff I've failed to mention. In other words, it is a complex installation.

Nevertheless, it is approved on the TC, there are installation drawings available, and all the parts are specified. A logbook entry is all that's required.

You are mixing apples and oranges. This is NOT a major alteration, by FAA definition.

EDO 2000 floats are approved on the 170 TC, as are a whole bunch of skis. No 337 is required, and regardless of your FSDO's interpretation of the rules/regs, they can not require you to file a 337 on something that is approved on the TC.

One of the reasons the field approval process has gotten to be such a mess is that the FAA "encouraged" everyone to field approve everything, even stuff that didn't need to be approved, such as minor alterations and things that are approved on the TC.

Here's another kink: When someone establishes a repair station with the FAA, there are options on how they file paperwork with the FAA. In some cases, the repair station work order is a legal substitute for a form 337 on installation of an STC.

My airplane had the AVCON conversion done by a certified repair station. There is paperwork out the wazoo on this installation, including a logbook entry which references a work order number, but NO 337. There is also no 337 on file with the FAA. I was concerned about this, checked with the FAA and they told me it was cool, as long as I still have the logbook and the work order (the repair station is now out of business). On the other hand, being paranoid, I decided to have the mechanics submit a retroactive 337 for the conversion, so that if something happens to the logbooks, OK City will still have records of the installation. So, I'm violating my own advice, but in this case, I think its to my advantage to do so, even though the FAA says its not necessary.

For what its worth. There are more kinks and wrinkles in this stuff than you can believe.

By the way, a friend had an IFR certified GPS installed, and the avionics guy submitted a 337 for the installation. The FSDO sent it back, saying it wasn't required, as long as the appropriate testing was done. These guys musta just transfered up from George's neighborhood. An IFR box? Works for me, but I'd probably want something in writing, in the event I get in a discussion elsewhere.

Mike Vivion

Certainly there's no harm done in filing the 337 on a IFR GPS installation,...but unless there was a significant change in wt/bal.....the installation of an IFR (or any other) GPS does not meet the definition of "major alteration or repair" per FAR 43, AppdxA. (which is valid and applicable to all FSDOs. So no 337 should be executed.

George
I believe there may be a recent (last year) change in the status of how and what is required to have a IFR GPS installed and the installation certified for IFR use.

When I installed my Garmin 155 three years ago it was very definitely spelled out in the AC that a 337 was required because installation of "new" technology such as a GPS for navigation WAS a major alteration. Every single IFR GPS that is installed and intended to be used for IFR use had to have the installation certified.

In my case in our FSDO there was a one 337 required to install the GPS and other required switches and indicators since our FSDO believes that if it didn't come from the factory that way it must be a major alteration.

I then have a second completely different 337 just certifying the previously installed equipment installation meets the FAA criteria as installed which required flight tests and a flight manual supplement be written and approved for just this installation.

I personally was on a first name basis with my FSDO avionics inspector and did all the work including paper work (supervised by my IA) myself so I know this intimately.

Again I've heard at least some of this has recently changed. Apparently the FAA has recognized that GPS is not "new" technology.

Maybe they've just recognized that a GPS installation doesn't meet the definition of "major alteration".

I had the same experience as Bruce.... one 337 for the GPS install, a second 337 for the IFR certification.

That was the procedure for an IFR box, but as noted, there appears to have been a "re-interpretation" of the rules at this point.

For a while, they wanted a 337 certifying that the unit had been tested, yada, yada, for IFR flight. That requirement really had nothing to do with the physics of installation, though I guess one could argue an antenna placed in the wrong spot could create problems, but that's called following manufacturer's instructions, not necessarily FAA guidance.

The guys here now are saying what George is describing: Avionics installations do not require a 337, even in the event that they are IFR approved.

That's good news, I reckon.

Mike

mvivion wrote: If its on the TCDS, it is most certainly approved data. For floats, as an example, an IA has to do the initial installation, primarily because it will require some cutting and fitting, attachment of cables, etc, and it will require a new W & B, which an owner can't do. But, once done, the IA simply makes a logbook entry to the effect that EDO floats were installed per the TC, on this date, and new weight and balance calculated. That's all that's required-no 337 required, or desired.
Mike Vivion

Mike just curious, why do you say an IA must do it instead of an A&P since it is not technically a major alteration.
Brian
(In the past I always thought these were major alterations requiring a 337, using the TDCS as the approved data, but see on several sights no one else thinks this way.)

I think when you mention a 337, a lot of people automatically think "field approval". There are 337's in my airplane's file going way back-- documenting everything from a TOTAL rebuild of the airplane ("fuselage assembly-complete replaced with used airworthy fuselgae assembly-complete...") to recovering of the wings & several different radio installations.
Most are signed off for return to service by an IA, only a few are signed off by an FAA Inspector (box 3). In my humble non-A&P/IA opinion, a 337 would seem to be required for a major repair or alteration, even if that repair or alteration is in compliance with the TCDS. Only a repair or alteration that is not in compliance with the TCDS or an approved STC should require an FAA sign-off or "field approval".
A good example is a set of Edo 89-2000's. They're approved on the TCDS, so no further approval is needed, but that seems to me like a major alteration which requires a 337 to be filed. Now in this case, a TCDS- approved alteration, can an A&P sign off for RTS or must it be an IA? Or if it is determined that a 337 is NOT required, and the work is documented only by a logbook entry, can an A&P sign off the logbook entry or is an IA required to do that?
I still feel this whole 337/logbook entry thing is a grey area, judging by the differing opinions we all seem to have.

Eric

That's the way I've always interpreted it Eric. I was taught that the first time you put skis or floats on an airplane it is a major alteration requiring an AI to inspect the finished product (not to do the actual work- an AI is an inspector, not a mechanic), after that, if the same equipment is used, it only requires an A&P or pilot to install it and logbook entry. Now the hitch is, I thought all major alterations required a 337 (except in the case of a certified repair station). I may have been wrong all these years but if installing the skis the first time per TDCS is not considered a major alteration, why would an IA have to inspect it?