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mit greb
04-25-2012, 09:50 PM
I see there is a Forum in Anchorage on May 2nd. I hear there are no more Field Approvals... again. What has everyone been experiencing?

NimpoCub
04-25-2012, 10:46 PM
In my shop.
Field approvals & masectomies... 5c.

gkm
04-26-2012, 12:56 AM
I heard that the FAA will not consider a field approval for the installation of 8.50 x 6 tires on my friend's Cessna 170. He is not really happy about this.

ColoZKS6
04-26-2012, 01:33 AM
I heard this, too. Not even mechanical to disc wheel and brake conversions. Are field approvals going away in lieu of "one-time STC's"?

8GCBC
04-26-2012, 01:49 AM
I heard that the FAA will not consider a field approval for the installation of 8.50 x 6 tires on my friend's Cessna 170. He is not really happy about this.

Can he find data, other field approvals, and/or 337s which may help his request? Or is it just plain NO! Which FSDO?

gkm
04-26-2012, 02:41 AM
Idaho FSDO said "No".
He spoke with someone in Anchorage who said "no".
The upcoming forum in Anchorage may prove to be very interesting.

bob turner
04-26-2012, 02:53 AM
They owe it to us to make this clear. My FSDO is very reluctant, but has not said no. I have a pending request with TSO parts, complete engineering data, excerpts from 23-27 and the inspector's TO that indicate approval should be forthcoming or a written reaon for disapproval should issue. So far it has been over two months and two inspectors. Maybe time to get clear guidelines.

skywagon8a
04-26-2012, 06:44 AM
The following is the FAA's guideline for field approvals. http://fsims.faa.gov/PICDetail.aspx?docId=E748AA8119D00C248525734F00766 63A It is lengthy. All of the procedures are listed including a flow chart of how to accomplish the approval. I don't see a flat NO for an answer. Perhaps the FSDOs which say NO just don't WANT to do it, are "lazy" or "don't want to do their job".

Last year at the IA meeting our FSDO spent a great deal of time telling us how to get a field approval accomplished. A flat "NO" was not part of the discussion. It is up to us to get everything in order first, to expedite the process. Cross all the "T"s and dot all the "i"s before you ask for the approval.

cubunltd
04-26-2012, 09:33 AM
I just got a field approval last week. No hassles. In fact the guys at my FSDO will help you with the wording if it needs corrected etc. Guess I'm lucky to have personal at my FSDO with knowledge and common sense. Oh by the way, most of these guys fly also!

8GCBC
04-26-2012, 12:31 PM
At my FSDO I know many of the GS's personally. I have taught some to fly, worked on aircraft with them in their younger days etc.. I have had a really good relationship with them.

BTW Some other pilot/A&P DO NOT!

mike mcs repair
04-26-2012, 03:42 PM
I see there is a Forum in Anchorage on May 2nd. I hear there are no more Field Approvals... again. What has everyone been experiencing?
I heard 8th. Which is it?.. Link ?.

chetharris
04-26-2012, 05:36 PM
It was scheduled fot the 8th of May. They had too much interest, so they cancelled. It seems from looking at the "process," they do not want to issue field approvals.
http://www.faasafety.gov/SPANS/event_details.aspx?eid=44018

mike mcs repair
04-26-2012, 06:25 PM
Now I am confused. More. 2 or 8 or canceled?

mike mcs repair
04-26-2012, 06:31 PM
Now I am confused. More. 2 or 8 or canceled?
I just put a call in to the guy listed on that link.... Waiting for a call back

mike mcs repair
04-26-2012, 06:34 PM
Just a thought from late 1980's again, when they wouldn't field approve tundra tires... The owners quit getting annuals done, since their was NO way to get their plane airworthy, and they HAD to have them to use the planes up here.... I bet we will see that start up again....

8GCBC
04-26-2012, 07:54 PM
The dreaded ramp inspections could start all over again. "What's in your wallet"?

prifly
04-26-2012, 09:25 PM
I hear some D.A R. s may be authorizield to do field approvals?

AK-HUNT
04-26-2012, 09:43 PM
The dreaded ramp inspections could start all over again. "What's in your wallet"?

I got ramped several times last year. All in semi remote areas of ak. Guys said the bosses sent them all out of office for hunting season. To ramp away accidents no doubt.

Three falls back had FAA drop in on us with Helo but it wasn't a "ramp check." It was a "safety check"

Btw it was a long ranger on lease. Your tax dollars.

8GCBC
04-26-2012, 09:49 PM
I got ramped several times last year. All in semi remote areas of ak. Guys said the bosses sent them all out of office for hunting season. To ramp away accidents no doubt.

Three falls back had FAA drop in on us with Helo but it wasn't a "ramp check." It was a "safety check"

Btw it was a long ranger on lease. Your tax dollars.

Wow. That is pretty aggressive. Sounds like the DEA in Hawaii!

8GCBC
04-26-2012, 09:57 PM
Where I live, unless somebody "drops a dime", ramping pilots ended about 10 years ago.

mit greb
04-27-2012, 08:12 PM
"Field Approval Meeting and Open Forum Discussion"
Topic: Changes to the Major Repair / Major Alteration Field Approval Process
On Tuesday, May 8, 2012 at 5:30 PM
Location:
Wendy Williamson Auditorium, University of Alaska
Wendy Williamson Auditorium, Bldg #12
2533 Providence Drive
Anchorage, AK 99508
Select Number:





Description:
In June of 2011, the guidance that FAA Aviation Safety Inspectors use to perform Field Approvals of major repairs and major alterations changed. Specifically, Figure 4-68 of FAA Order 8900.1, Volume 4, Chapter 9, Section 1 was revised.

Although this change in the Airworthiness Inspectors Handbook has affected the timeliness to process some major repairs and major alterationsvia Field Approval’s, the FAA is still processing Field Approvals.

The FAA is hosting an event to convey recent changes to the Field Approval process and to solicit feedback and recommendations from the Alaskan industry groups, repair stations, air carriers, mechanics, pilots and the general public.

O'Brian is gone. How much longer till the Field approval is too.

This is what I got I wasn't looking at it when I wrote the first Post. Some of you guys down south let the rest of us know what is up.

Thanks

bob turner
04-27-2012, 08:41 PM
I only have access to what pops up when I google 8900.1, but this is my impression of what it says:

Fig 4-69 - These lists are not all-inclusive, and each alteration should be evaluated on a case-by-case basis. . . . Additionally, . . . ASI should review . . . AC . . .for specific types.

Also 4-1192 D 4 seems to indicate that the ASI should notify the applicant in writing, and should include the reason for denial, as well as a reasonable opportunity to correct the application.

I was denied once, and they did it by ignoring my application. I am somewhat timid about insisting on a written denial, since I depend on the good will of these guys, and usually get it.

T.J.
04-27-2012, 10:25 PM
My PMI once told me No more Field Approvals without DER documentation or submit it to our (FAA) engineers. They were 3 years behind at that time. This is on the Kenai Peninsula. I understand Anchorage is still getting some Field Approvals?
Typical fsdo shuffle. One will and one won't.

Steve Pierce
04-28-2012, 08:40 AM
TJ, I still get them even though they tell me they can't. I quote chapter and verse what is linked above and they start back peddling. It is kinda a sport to show them what they can do and get them to do it.

mit greb
04-30-2012, 09:40 PM
Field Approval Meeting and Open Forum May 8th, 2012 - Cancellation Notice
Notice Number: NOTC3698

The field approval meeting and open forum to discuss the recent policy changes in the approval of major repairs and major alterations scheduled on Tuesday May 8th , 2012 between 5:30 PM to 8:30 PM at the UAA Williamson Auditorium has been postponed until further notice.
Reason for Postponement:
Based on feedback received from the public and FAA resources in the last two weeks, several internal FAA meetings have taken place to discuss ways to improve our response time and address the recent impact of the changes contained in figure 4-68 of FAA Order 8900.1, Volume 4, Chapter 9, Section 1. Based on these discussions, the policy holders AFS-300, Aircraft Maintenance Division and the Aircraft Engineering Division located in Washington D.C. are in the process of implementing immediate changes to address the concerns identified. Based on these immediate changes, FAA Management decided that it would be more appropriate to delay the upcoming meeting, implement the changes and allow an appropriate amount of time to measure results. After the results are gathered, they will reschedule the trip to Alaska to address any further concerns if needed. Your patience in this matter is greatly appreciated.
Contact person if needed. Mark Wilson 907-350-5080

behindpropellers
04-30-2012, 10:08 PM
So why do they only have these kinds of informative meetings in Ak?

Ole Bob
04-30-2012, 10:25 PM
Just a thought from late 1980's again, when they wouldn't field approve tundra tires... The owners quit getting annuals done, since their was NO way to get their plane airworthy, and they HAD to have them to use the planes up here.... I bet we will see that start up again....

In about 1987 when I was under the "control" of the Atlanta FSDO there was a really nice bunch of inspectors. These were older guys who had scars on their hands and grease under their fingernails. I called one of them one day to ask about putting in a bigger engine in a guy's airplane. The simple answer from the Inspector was, "you'll never get it approved by the guys here because the FAA lawyers have scared the devil out of us about personal libility if anything happens. Sorry."

mike mcs repair
04-30-2012, 11:13 PM
I just put a call in to the guy listed on that link.... Waiting for a call back

and I did get a call back from the guy listed there, Andy, he was helpful and said like mit greb posted, the Washington feds thought it was more important to finish the new 'fix' or whatever they are activly working on, than to stop work on that, come have a meeting in AK, and then change the rules/fix a week later or such..... so it sounds like something is in the works, I don't understand what, because I have not done any field approval stuff since last spring.....
basically stay tuned, was the message.... (ps.. nice guy, he reads here, knew my handle here when I said my last name....:o:o:o ) 'breaker 1-9.. this is the mixed up mechanic...' or so I gave my self when I was 7..

absocountry2
05-01-2012, 01:43 AM
Looks like they are going to make changes and see how it works before they have a meeting. If it gets sorted we may not need another meeting.

Chris Campbell
05-07-2012, 12:30 AM
We have been held up for months now on a simple field approval for otter Cleveland wheels and brakes. We have 2 other otters already approved but they said we can't use those field approvals for data anymore except as "acceptable" data not "approved" data. Anyways we have "acceptable" data in the form of previous and operating approvals. The last word now is that is has to go to DC for approval. Crazy. They other option they gave us was to go back to the Goodyear brakes while they sort this out.....The same brake that the pilots report are not effective. So now they FAA is impeding safety. Safety is not near as important as compliance apparently.

Chuck Avon
05-07-2012, 06:53 AM
Here is some thing that our Fsdo put out at a meeting worth a try



6493

Cub Builder
05-07-2012, 10:41 AM
Here is some thing that our Fsdo put out at a meeting worth a try
6493

I did a number of 337s last fall on a TriPacer ground up rebuild exactly as outlined in this circular and filed them with the FAA in OKC. Some of the mods were approved STCs, but about half were based on previous field approvals that we copied and supplied as approved data. None were rejected or returned. We didn't even talk to the local FSDO. The process as outlined in AC 23-27 worked for us. This Circular covers "Substantiating parts or materials substitutions to maintain the safety of old and out of production aircraft".

-CubBuilder

Steve Pierce
05-07-2012, 10:49 AM
Cub Builder, Who approved your field approvals? My understanding on filing 337s with OK City was ones not requiring a field approval. OK City simply files them. What modifications were your 337s on?

Cub Builder
05-07-2012, 12:00 PM
I guess I didn't explain that very well. We were using data from previously approved field approvals. Wrote that data up on the 337s referencing the previous approval for a like aircraft and supplied a copy of the 337 where the data was originally approved as an attachment to the 337s we filed.

As I'm sure you know, a field approval 337 will have the inspectors name, the approving FSDO and date of approval on it. Once you have a copy of the 337 with that data, you can copy it, reference that data, and do the same mod to the same model of aircraft using the data from the old 337 to demonstrate that the FAA has already approved the data.

Some clubs like the short wing Pipers or some people selling plans for mods will supply a copy of a 337 with their field approval, which can be copied and used as approved data. And of course you can get copies of the 337s on any aircraft from the FAA, so they can also be had that way.

So as to be clear on this, I am not an IA. I did the paperwork and wrote it up as the mechanic of record, then had the work inspected and the 337s signed by the one of the IAs I work with. I would have to go look at my records from this TriPacer, but I would guess we filed 5 or 6 337s using a previously approved field approval as the approved data. Maybe it will come back to bite me in the butt some day, but I believe I did exactly what is outlined in AC 23-27.

-CubBuilder

Steve Pierce
05-07-2012, 12:11 PM
You might want to check with your FSDO on this. Previously approved 337s are acceptable data, not approved data, you still have to have the FSDO Inspector sign the 337 as a field approval.

mike mcs repair
05-07-2012, 12:13 PM
I guess I didn't explain that very well. We were using data from previously approved field approvals. Wrote that data up on the 337s referencing the previous approval for a like aircraft and supplied a copy of the 337 where the data was originally approved as an attachment to the 337s we filed.

As I'm sure you know, a field approval 337 will have the inspectors name, the approving FSDO and date of approval on it. Once you have a copy of the 337 with that data, you can copy it, reference that data, and do the same mod to the same model of aircraft using the data from the old 337 to demonstrate that the FAA has already approved the data.

Some clubs like the short wing Pipers or some people selling plans for mods will supply a copy of a 337 with their field approval, which can be copied and used as approved data. And of course you can get copies of the 337s on any aircraft from the FAA, so they can also be had that way.

So as to be clear on this, I am not an IA. I did the paperwork and wrote it up as the mechanic of record, then had the work inspected and the 337s signed by the one of the IAs I work with. I would have to go look at my records from this TriPacer, but I would guess we filed 5 or 6 337s using a previously approved field approval as the approved data. Maybe it will come back to bite me in the butt some day, but I believe I did exactly what is outlined in AC 23-27.

-CubBuilder

Thats not how it works, you then need to get ANOTHER feild approval based on the old field approvals. You cant just send them in. Yes no one reads them in Ok.. but you dont have legle 337 without a new stamp in that block......

Cub Builder
05-07-2012, 01:01 PM
Thats not how it works, you then need to get ANOTHER feild approval based on the old field approvals. You cant just send them in. Yes no one reads them in Ok.. but you dont have legle 337 without a new stamp in that block......

Interesting. It may come back to bite us on the butt at some point in time. I guess the confusion comes from the wording on page 7 paragraph 4 of AC 23-27 where it says you can use a previous field approval as the "basis" for approval on your aircraft. It implies that it should be approved, does not clearly state that it is approved. Thanks for the interpretation. I know many are interpreting that as it "is" approved, as doing the paperwork that way was was recommended and signed by the IA we used.

-CubBuilder

bob turner
05-07-2012, 01:02 PM
I have only read 23-27 about a dozen times. Some very bright folks believe that previous field approvals are in fact approved data for these aircraft - I am not yet convinced, but have an open mind.

The A/C explicitly says you can use automotive hydraulic hoses with a logbook entry. It also says that it itself is approved data, but does not really explain what that means. The body is confusing, but it, along with Order 8100.1 seem to indicate that the ASI should be approving substitution field approvals.


Opinion: with documents like this, be careful about making definitive statements. One IA may interpret them one way, and another IA may see things differently. Ambiguous writing does not lend itself to certainty.

Chuck Avon
05-07-2012, 02:24 PM
Here is a reference from a meeting in Nashville Tn i have spoke to the inspector before we sent in the 337 for the B&C alternator and he said fill out 337 let IA sign off put all ready approved 337 in its complete form with my 337 and mail it to OKC and its done


6496

behindpropellers
05-07-2012, 02:41 PM
I can see that for parts, but not changes.

So can I replace the J-5 elevator system with the PA-18 elevator system as it says in that article? I already have a letter saying I can use the J-3 STC as data and another previously approved 337 for the same mod- but told I cannot get it approved.

Tim

bob turner
05-07-2012, 02:54 PM
Approved data means no field approval. Acceptable data, or a basis for approval, generally means an ASI has to sign it. But if you get a letter from an ASI allowing a differnt interpretation, you are probably golden.

You can mail anything you want to OKC - they just file it, probably using temp workers or something. My FSDO used to review my 337s, and would often pick up minor errors. They refuse to do that now. It is a strange form - you have to sign and date it twice. They want to be sure you are sure. Or something.

So if you choose to interpret aomething in your favor - say, like the word "basis" in a document that says it is approved data if you do exactly as it says, and send the 337 to OKC, then nobody will probably ever challenge you - even if the rest of the world disagrees with your interpretation.

Opinion.

Steve Pierce
05-07-2012, 10:06 PM
It says you may use those approvals as the basis for the approval on your aircraft. I have sat in many meetings with the people who drew this AC up and I think people are reading things into it. Seems pretty straight forward to me.

bob turner
05-08-2012, 12:35 AM
I disagree - the appendices are straightforward, but the main body is written to cause confusion, and as you can see, it has caused confusion.

Chris Campbell
05-09-2012, 01:55 AM
Ok the FAA folks told me that for repairs, previous field approvals can be used as approved data, but for Modifications they can only be "acceptable data". seems confusing. But I know that you can't just copy an old field approval as data and send it in without a new stamp in box 3. That practice used to be common but always has been illegal. I'm surprised any IAs would sign off on that now. maybe in the 1980s. I've seen many older Piper's rebuilt with nothing but copies of other plane's 337s as data...even for the STCs......not legal...never was.

mike mcs repair
05-09-2012, 02:30 AM
....you can't just copy an old field approval as data and send it in without a new stamp in box 3. ....

that was my understanding of it also....

but who knows at the moment.... as we are about to go through another change...

bob turner
05-09-2012, 03:03 AM
Caveat: pre some date around 1955 337s are approved data. Certain other categories of 337s are approved data. Repairs done in accordance with 43-13 or manufacturer drawings (major repairs) are approved data, and the 337 goes to OKC without the stamp in block 3. If it is approved data it does not need the ASI approval.

Opinion.

Steve Pierce
05-09-2012, 07:42 AM
Bob, Repairs done via 43-13 would not need a field approval. Aircraft got new airworthiness certificates every year up until 1956 or so. Therefore they see any modification done prior to that date approved data. You can also lose your Airworthiness Cert. and have them inspect your airplane and issue another one. At that point any mod done is approved. This could be a catch 22 but a long time DAR told me about this method.

Ole Bob
05-09-2012, 12:22 PM
[QUOTE=Steve Pierce;536348]It says you may use those approvals as the basis for the approval on your aircraft. I have sat in many meetings with the people who drew this AC up and I think people are reading things into it. Seems pretty straight forward to me.[/QUOTE

My own "opinion" is that Steve is correct. Very strightforward and clear. I've already done it with no problems. In fact I remember after my first reading of the AC thinking, "WOW! Something from the Feds that makes perfect sense and is very easy to understand."

bob turner
05-09-2012, 10:10 PM
Well, I agree with Ole Bob, but when you haul an approved 337 in there and ask the ASI if he will stamp it on the basis of that prior field approval, does he have to? AC 23-27 could be interpreted that way.

bob turner
05-22-2012, 02:27 PM
Let's not lose this thread. I am about to press the issue gently - my latest application has been "in" for over two months, with no official response, and has been pawed over by three ASIs.

What would help me is contact with some friendly person who was in on the 23-27 deal. My PMI is saying unofficially that they cannot do it if the block on that figure says ENG or STC. My interpretation is that it should be on a case by case basis, using ACs as a guide.

The FAA really shoud be giving us better guidance. Either do away with field approvals, or make it so they have to give us a written response with precise reasons, and an appeal process.

chummie
05-23-2012, 07:02 AM
Tim,
Down here in Maine our FSDO won't even hear about fiel approvals. Been that way for some time

Good luck. Joe

skywagon8a
05-23-2012, 07:13 AM
Well, I agree with Ole Bob, but when you haul an approved 337 in there and ask the ASI if he will stamp it on the basis of that prior field approval, does he have to? AC 23-27 could be interpreted that way.

It is my understanding that an ASI does not "have to" sign any field approval if he/she does not want to. It is their personal choice. It could be because there is something wrong with the application or just as simple as "I don't want to". In the latter case take it to the guy at the next desk. If you are sure that your application is valid, keep it moving up the rungs of the ladder.


Let's not lose this thread. I am about to press the issue gently - my latest application has been "in" for over two months, with no official response, and has been pawed over by three ASIs.

What would help me is contact with some friendly person who was in on the 23-27 deal. My PMI is saying unofficially that they cannot do it if the block on that figure says ENG or STC. My interpretation is that it should be on a case by case basis, using ACs as a guide.

The FAA really shoud be giving us better guidance. Either do away with field approvals, or make it so they have to give us a written response with precise reasons, and an appeal process.

It is my understanding, I don't have the AC in front of me, that if the block says ENG or STC then the FSDO guy, who has been asked to field approve the 337, should be the one to contact engineering. Engineering will then either approve or provide guidance towards completion. This has been my experience in the past.

The application having been "in" for over two months with no response is inexcusable. I though that they were supposed to act within 30 days. I once installed a set of floats on a plane that had been approved on that same type of plane on a 337 which was dated prior to that cutoff date in 1955. Three months after I sent in the 337 my PMI called and told me he needed to inspect the installation. He came and looked it over and pretended to be reading the log books. Then he said that he didn't feel comfortable and would not approve the 337. I called a friend, who happened to be the regional director at the time. The 337 was approved and the PMI mysteriously transferred to Singapore. Don't read anything into this. I'm just saying.

Steve Pierce
05-23-2012, 07:36 AM
Bob, I think the handbook is pretty cut and dry. What are you trying to field approve?

mike mcs repair
05-24-2012, 10:40 AM
anyone hear if the 'new' changes have been made yet?? as of a week or so before AK trade show the FAA guy I spoke with said Washington was a week or two away from having new rules written/worked out..... anyone know where to look?? do they get put up on the fed register or such???

mike mcs repair
05-24-2012, 10:43 AM
anyone hear if the 'new' changes have been made yet?? as of a week or so before AK trade show the FAA guy I spoke with said Washington was a week or two away from having new rules written/worked out..... anyone know where to look?? do they get put up on the fed register or such???

http://www.faa.gov/regulations_policies/rulemaking/recently_published/
I don't see it at first glance....

bob turner
05-24-2012, 01:18 PM
Steve - the handbook, like most stuff of this nature, is anything but "cut and dry". 8100.1 clearly states that each application should be considered on a case by case basis, and references AC 23-27, in addition to stating that the ASI should use ACs to make decisions.

The handbook indeed says that if an applicant thinks the restrictions of figure 4-65 do not apply, he can ask the ASI to call or e-mail the ACO for guidance. A telephone call can get around the restrictions.

If the FAA intends to not issue field approvals, they shoud just be honest about it and say so.

bob turner
06-09-2012, 02:18 AM
Thanks to Mike for finding this - I searched for "field approvals" in the title, and this one did not come up.

AC 43-210 is an interesting document - it says, first, that statements containing " shall" and "will" reflect "regulatory intent" , whatever that is, and goes on to say that a field approval request can be denied for only one or more of four stated reasons. It says the ASI "will" respond in writing with a stated reason.

But if they can ignore AC 23-27, which is "approved data", then they can surely ignore one that speaks of "regulatory intent".

Opinion.

Steve Pierce
06-09-2012, 09:47 AM
8100.1 has a cut and dry check list of what can and can not be approved, what must go to engineering and what needs an STC. If it is addresses in that check list/flow chart then I am going to push till it is done.I arm myself with their own documents. I asked before and never got an answer,what are you trying to field approve?

mike mcs repair
07-23-2012, 09:43 PM
any updates?????....

only heard something about a 5? step process now?? with your local AND DC feds???? 90 DAYS to find out if it will be approved or NOT!

T.J.
07-24-2012, 01:40 AM
Mike:
Basically, what they are telling us is, forget it. They do not want to do field approvals and they will not do them. They will make the rules/regulations so complicated no one will be willing to pay for the paperwork. Your guvment at work.
However, you can be assured, the suits and the PC correct bureaucrats in DC are doing a hell of a good job of passing rules/regulations to protect the flying public! Yea Right!
How many years have we been doing field approvals under the old rules/regulations? Did it work? I think it did.
Their primary purpose to is to protect their jobs. Period.
Most of the folks that write the rules/regulations wouldn't know a PA-18 from a Cessna 150. But, they know enough to write regulations controlling the issuance of field approvals for these planes. That is impressive!
Wish I was that smart.:wink:
Forget the field approvals, its a done deal.

bob turner
07-24-2012, 02:42 AM
Almost six months now, and no response, except for "good luck" from the forwarding inspector. There are so many ways they are unconsciously trying to kill GA. This is but one - our new half million dollar magnetic card entry system is another.

The funny thing is, those who are doing the most to kill it depend on it for their paychecks! At my airport we are running at 53% of our 1977 operations, and are doing so with roughly ten times the number of full time airport employees, one of whom will probably retire at 200 grand a year.

This is all guess and opinion, except for the 53% number, which I got from an official-looking post in the admin office.

Oh, and we are repaving to make it better for the jets. Soon they will be the only customers.q

skywagon8a
07-24-2012, 06:29 AM
Most of the folks that write the rules/regulations wouldn't know a PA-18 from a Cessna 150. But, they know enough to write regulations controlling the issuance of field approvals for these planes. That is impressive!
Wish I was that smart.:wink:

Years ago I made application for an STC for a belly tank on a Cub. I made the application through the Anchorage engineering office. Since I live in Taxachusetts the FAA engineer made a courtesy call to the New England region to discuss the project. The NE engineer asked the Anchorage engineer "What happens if the Cub makes a gear up landing?" With that the Anchorage engineer said that it has been nice talking to you have a nice day. The project was handled totally in Anchorage, where the FAA folks have a lot of common sense. You folks in Alaska don't realize how lucky you are having the FAA cooperation that you do, or at least did then.

sierra bravo
07-24-2012, 03:36 PM
This morning I had a conversation with a rep from Flight Standards in the ANC FSDO. Field approvals are not dead. There have been changes made to the process including some change types that are specified to require STCs, including wheels and brakes for example. The AK Region is working to get the manual revised for those problematic items and is making progress. Those change requests are forwarded to Washington for coordinated approval. Standard requests are not, but out sounds like some are bounced downtown to the ACO. Take the internet chat with a grain of salt. Call the ANC FSDO if you want the story. It's enlightening.

aktango58
07-24-2012, 03:44 PM
FAA help and cooperation: It ebbs and flows...

They are just people, with personalities, bias and priorities.

bob turner
07-24-2012, 07:13 PM
I guess Mark is correct. Sometimes it is "no way" and other times it is"gimme that" and I walk out with block 3 signed and stamped.

sierra bravo
08-01-2012, 10:17 AM
For those of you who aren't on the FAAST mailing list, here's an email I received re: the field approval process status.





FAA Safety Team | Safer Skies Through Education


Field Approval Update
Notice Number: NOTC3975

Field Approval Update



In June of 2011, the FAA Aircraft Engineering Division and Aircraft Maintenance Division issued Change 159 to FAA Order 8900.1 which changed the types of alterations Aviation Safety Inspectors (ASIs) could approve using the field approval process.

Certain alterations which were historically field approved at the Flight Standards District Office (FSDO) level were reclassified as requiring a Supplemental Type Certificate (STC). Flight Standards and the Aircraft Engineering Division developed this guidance to address concerns that aircraft being modified and/or repaired under the field approval process meet their certification criteria and that the field approval process is applied in a standardized manner.

Due to the suggestions made from the Alaskan Region, Headquarters leadership has re-evaluated FAA Order 8900.1 and developed a web-based field approval job aid to assist in determining field approval eligibility.

Beta testing of the web-based field approval job aid began on July 17, 2012 and the job aid is slated to be implemented in roughly thirty days if beta testing proves successful (note: the web based job aid is for reference only at this point) . [1] (https://mail.summitwindows.net/exchange/stewartb/Inbox/%22Field%20Approval%20Update%22%20-%20FAASafety.gov.EML?cmd=Open#_ftn1)

Our first impression of the job aid is that it is a substantial improvement to the field approval guidance which will be welcomed by the general public. The job aid would return many proposed field approvals back to their pre-June 2011 status.

FAA Headquarters has requested that all public questions, comments and recommendations concerning the job aid be consolidated into one response from the Alaskan Region. The public should send all feedback to adam.geber@faa.gov and we will consolidate and forward the comments to FAA Headquarters for consideration.

Alaskan Region Flight Standards and the Anchorage Aircraft Certification Office will continue to work with the aviation community in Alaska. We understand that questions may arise, so please feel free to call either your assigned Principal Inspector or the Anchorage ACO.

(SEE ATTACHED PDF FILE FOR ADDITIONAL INFORMATION)





[1] (https://mail.summitwindows.net/exchange/stewartb/Inbox/%22Field%20Approval%20Update%22%20-%20FAASafety.gov.EML?cmd=Open#_ftnref1)ATTACHED IS A LINK TO THE PROPOSED INTERACTIVE WEB-BASED FIELD APPROVAL JOB AID.

http://www.faa.gov/about/office_org/headquarters_offices/avs/offices/afs/afs300/media/Major_Repair_Alteration_Job-Aid.pdf (https://mail.summitwindows.net/exchweb/bin/redir.asp?URL=http://www.faa.gov/about/office_org/headquarters_offices/avs/offices/afs/afs300/media/Major_Repair_Alteration_Job-Aid.pdf)

mike mcs repair
08-01-2012, 10:45 AM
Changes in basic dimensions or external aerodynamiccontour/configuration of the aircraft such as wing and tail planformor incidence angles, canopy, contour or radii, the location of wingand tail fairings, winglets, wing lift struts, tiptanks, windows, anddoors.

wow only needs ENG not stc.... i was surprised to see that!!

68D
06-23-2014, 01:11 AM
Has anyone tried to get a field approval lately? Am trying to put a gear driven alternator in a cub.

Any info helps, thanx.

bob turner
06-23-2014, 12:59 PM
Yes. I got one in January for PA11 lift struts on a J-3. Then I tried for one to install Grove brakes on a Champ. It has been on the same inspector's desk for six months. He has not officially turned it down.

There is a new manual governing this stuff - I'll post a link in my next post. It is not much changed, but a couple of places mandate that they tell you when they turn you down.

For 2013, my airport is down to exactly 50% of its 1977 operations. Martha Lunken says there are five times as many inspectors now as there were in 1990 or so. That is why they are too busy to do these things, and also why aborted takeoffs are now a very big deal. When the tower asks why you aborted, tell them it was for training purposes.

bob turner
06-23-2014, 01:00 PM
http://www.faa.gov/documentLibrary/media/Order/8300_16.pdf

Steve Pierce
06-23-2014, 01:11 PM
For 2013, my airport is down to exactly 50% of its 1977 operations. Martha Lunken says there are five times as many inspectors now as there were in 1990 or so. That is why they are too busy to do these things,

Back then the FAA Inspectors knew what a Champ or a Cub was along with the difference between an A-65 and C-90.

68D
06-23-2014, 01:42 PM
Thanks guys for the info, last night found out about 8300.16 and AFS300 after I asked the ?on here so will now find out how the process works.

Steve Pierce
06-23-2014, 01:45 PM
There are some STC's for these on other airframes. I would get paperwork on them to include with your package.

silflexer
06-23-2014, 04:44 PM
I went through the field approval process earlier this year. Called and emailed the inspector multiple times each week and found that they were responsive, and willing to help out. What I also learned is that under normal circumstances, they will not sign a field approval if there has ever been a STC that is the same or would accomplish the same thing. The current FAA guidance shows how to fill out the paperwork with the numbered approach "line 1- aircraft make, line 2, owner etc.) but my guy wanted a mix between the old school text and description with the new numbered approach. Making his requested changes and adding some math (disk brake conversion) we were good to go. Whole process still took about 6 weeks, but was overall a great exchange. Being willing and able to communicate often on my end helped out. Wichita fsdo.

okmike
06-23-2014, 07:00 PM
Just got one for nose fork and bigger tires on early 182

bob turner
06-23-2014, 09:25 PM
It is inconsistent. There oughta be some form of "equal protection" involved in this.

skywagon8a
06-24-2014, 05:24 AM
It is a form of Ball Busting which the FAA enjoys inflicting on their employers (us). They need to show how busy and important they are.:sad:
Ignorance slows down the process.

WWhunter
06-25-2014, 08:24 AM
Bob,
I tried for several years to get a field approval to install hydraulic brakes on a 7AC. Always some type of road block but in the end what it came down to was exactly how silflexer said 'What I also learned is that under normal circumstances, they will not sign a field approval if there has ever been a STC that is the same or would accomplish the same thing.'
I could not get an approval due to WagAero having an STC'd kit available. Granted this kit is very expensive, to the tune of $4500!!! This does not included installation. I decided I didn't need better brakes that bad so left the plane on floats. Sold it last year and have gone the experimental route. Owning an experimental is almost like being a free person!! I can pretty much do as I please. Case in point, I am ordering new cylinders/pistons for a big bore kit on the Rotax, Nothing involved other than sending my money, they arrive and I put them on. Log book entry and I'm golden. :) I sure likw this experimental stuff after close to 30 years dealing with certified airplanes. Life is good!!

skywagon8a
06-25-2014, 08:42 AM
WWhunter, I'm surprised that you weren't able to get your field approval based on the fact that the hydraulic brakes are TC approved on the 7GCB. The 7GCB uses the same Scott master cylinders as the Cub. Since the 7AC and the 7GCB are on the same TC, it should have been rather easy.

skywagon8a
06-02-2015, 01:26 PM
This came today from my PMI. Thought that you all might be interested. He also attached several pdf files which I don't know how to attach to this post.


I realize this may not apply to all of you but, in case you find a need to request a field approval, I hope this will help. I know it’s a lot of info, but if you can get through it; it will speed up the process for us, and you too. Attached is guidance we now use for major alterations. The 337 data package should be reviewed and approved by the FSDO before beginning work.

Data Package:
Complete the 337 with the 16 elements as shown in figure 5-1 of 8300.16 (see note on page 20), provide all drawings and approved data to complete a Field Approval data package. Fig 3-1(page 4) is a flow chart that shows the approval process overview. (I attached a sample 337 with an acceptable format, more or less depending on the alteration, but it must have the 16 ICA elements or it will be returned).

The FAA will then use the Major Alteration Job Aid to determine if it can be field approved, requires an STC or will be a coordinated field approval with the ACO (Aircraft Certification Office). This document is found on-line via a hyper-link in order 8300.16. (All copies attached is subject to revision).

If your proposed alteration/repair will require engineering evaluation it is referred to as a coordinated field approval. This is determined by the Major Alteration Job Aid (located on page 13 for Normal category aircraft, Operational Characteristics, item D5; which is attached above and also can be accessed via this link: http://www.faa.gov/about/office_org/headquarters_offices/avs/offices/afs/afs300/ ). Include enough information for the engineers at the ACO to be able to make a determination. If they find the alteration acceptable they will provide you with a Memorandum that will become part of the 337.

Additional Information:
DER Note: The FAA inspector does not have to approve an alteration on a 337 as long as a DER has substantiated ALL of the elements of the alteration (8300.16 Chapter 2). (It will be noted on the 8110-3 whether the data is approved for the entire alteration or not. If not, then the DER approved data (8110-3) will not be for the installation portion of the alteration. It will then require field approval which will complete the process. If the 8110-3 includes ALL elements of the alteration, including the installation, it does not need to be sent to the FSDO for field approval).

NOTE: FAA Order 8110.37 addresses field approvals by reinforcing that DERs are not authorized to perform them. It also recommends including a note in the body of FAA Form 8110-3 that states, “This approval is for engineering design data only and is not an installation approval.” This does not prevent the data from being used as the basis for a major alteration or repair. When sufficient DER data has been obtained, the approval process applicable to the alteration is complete; the product can then be inspected for conformity and approved for return to service. The person performing the alteration, rather than the DER, is then responsible for conforming and approving the installation. DER data is not a field approval, but is approved data that, like other approved data, can be used in the performance of major alterations or repairs without further approval if the data addresses the entire alteration or repair. In this case, you do not need to request a field approval from the FAA. FAA Order 8300.16 provides guidance on this subject and is available at http://www.airweb.faa.gov/rgl.


Advisory Circular 43-210 is still referenced in the FAA Order and has a field approval check list in Appendix 1.

Appendix 2 of AC 43-210 contains a sample compliance checklist. Use this list when reviewing applicable regulations to show compliance in the alteration. It takes some research, but will ensure that the data package will be less likely to be rejected when you submit it.


A 337, incorporating an STC as approved data, does not need to be sent to our office (for approval) as long as it is approved for that aircraft via S/N, N-number or on the approved model listing; however, it still needs to include the 16 ICA elements.

A minor alteration as defined, does not require a 337. See 14 CFR 43 Appendix A for major alterations and repairs to airframe, propellers, powerplants and appliances.


xxxxxxxxxxx
Principal Maintenance Inspector
Federal Aviation Administration

bob turner
06-02-2015, 02:46 PM
I did not re-read the entire thread, but note that I am a contributor.

In the very recent past I have obtained three field approvals - Two for Grove brakes on Aeroncas, and one for replacing the master cylinders on my Cub.

It took begging, groveling, and multiple visits/appointments. The inspector was very nice during the entire process, and in the end he merely pulled out his stamp and we were done. The two non-AOG approvals took 15 months start to finish, with no engineering evaluation or re-writes. The AOG approval took a month, four contacts, and possibly the help of a now-retired inspector from another FSDO. The brakes are a dramatic change, according to the Aeronca owner. A tremendous increase in safety on the ground.

Longwinglover
06-02-2015, 06:06 PM
Well, Bob, if you will follow what Pete posted it just might go a little faster? Then again it IS the FAA and they're not happy until you're not happy.

John Scott

bob turner
06-02-2015, 08:14 PM
I am smart enough to have programmed Maxwell's equations in a computer, but I am not smart enough to know how to use that FAA job aid flow chart.

I think I am done fighting this stuff. My Cub and my Decathlon are exactly the way I want them, and all these Aeroncas belong to other people. It was very satisfying to see how easily the mechanical brake airplane was converted, and how much better its ground handling was.


Do you know that the mechanical brake Aeronca wheels are close to a grand each, used? Most are cracked.

markmunro
05-30-2017, 04:22 AM
looking for some experiences guys have had recently with the field approval process vs simple log book entry..

I am looking at a cub that has gar aeros done by field approval with 1.25 inch axles wiith the cleveland 30-60 double puck brakes. It now has the 30-52 ABI double puck brakes. these are the more robust version. Atlee Dodge has an STC to install the 30-52 brakes on cubs but the stc specifies 1.50 inch axles.

Is this a change that can be done with a simple log book entry? It is a minor change that affects little.

Steve Pierce
05-30-2017, 07:32 AM
I take it they installed a sleeve over the axle to adapt the 1 1/2" wheel to the 1 1/4"? I would get a field approval if that is the case.

dgapilot
06-07-2017, 10:52 PM
I hear some D.A R. s may be authorizield to do field approvals?

DARs with Function Code 51 can do Field Approvals within the limitations FAA imposes. We are required to use the AFS300 job aid, and AC43-210A. We are also limited to doing Field Approvals within the FSDO where we are supervised.

DER's with Major Repair and Major Alteration authorization can do Engineering approvals within their specialty, and DERs have no geographic boundaries. DERs are also limited to doing Engineering Approvals identified in the AFS300 job aid, so about the same as a Field Approval, just different paperwork. Most DERs only have one specialty, so for a given approval you may need to use multiple DERs. In my case, I'm limited to vintage aircraft, but can do structures, systems, engines and engine installations.

David Schober

bob turner
06-08-2017, 01:04 PM
We are having a bit better success with field approvals in the last few months. Same guys, more helpful.