Local scuttlebutt in that the FAA is getting out of the Field Approval business.
Have heard they plan to cancel most if not all existing F.A.'s, requiring that all installed Field Approvals be removed.
I just love the FAA for their wisdom.
Local scuttlebutt in that the FAA is getting out of the Field Approval business.
Have heard they plan to cancel most if not all existing F.A.'s, requiring that all installed Field Approvals be removed.
I just love the FAA for their wisdom.
It's not quite that bad!...
The FAA recently issued a revision to Order 8300.10, Chapter 1, Perform Field Approval of Major Repairs and Major Alterations, that is more restrictive, especially for rotorcraft, as to what the Inspector can approve...
There is no requirement to cancel previous approvals...
Remember, field approvals can only be cancelled by the approval holder, voluntarily surrendering the approval, or by the FAA filing a violation against the approved aircraft's Airworthiness Certificate...
And you guys laugh at me for having an experimental Cub-y...
Here is an email I just got from our local FSDO regarding field approvals.
Looks like they're going to make it tougher and/or more costly.
Howdy Dave
Yes there are some new restrictions. Most of those apply to the FSDO
Inspector and limit his / her activities. In a nutshell the bulletin does
not allow us to do the field approvals that we have been doing for years.
If you have internet access go to faa.gov and then regulations/ bulletins
and look up Handbook Bulletin for Airworthiness HBAW 02-03.
We will be in PIR this friday for a 135 meeting and will be discussing
this. Currently you may request a Field Approval and we may have to send
it to our Engineers (time) or your engineers (money).
More to follow I am sure -- Pete
We are hearing the same thing here in Alaska. For a long time you could get almost anything approved as long as your A.I. and FAA inspecter signed off on it. Now the word is, if there is an STC out there that is close your modification, you need to buy it and follow it exactly as written. Glad I am working on the PA-18 project now instead of the 14. Just about every mod you can do on a PA-18 has an STC. Crash
Would be lot less problem if the FAA would hire local FSDO inspecters with an engineering degree, instead they insist on moving people into the field inspection division out of the clerks labor pool.
They have no business Making Mechanics "purchase STC'd similar to their field approval requests" This is what Part 43 was written for!
All this is going to do is push GA further toward the Experimental catagory.
The Bottom Line is the FAA is not Qualified in the Field office to handle the requests of the field.
The Manufactures, and Legal beagles win again!
Tim
All the old inspectors with practical experience are retiring. Now we get ones whose only experience is in a classroom. The FAA employs more lawyers than anything. Enough said.
Steve
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Well I can tell you pretty straight whats goin on with this. I got trapped in FAA hell last month (can I say that here?). They will no longer give field approvals that effect gross weight, weight and balance, or center of gravity. You must now hire a DER (designated engineering rep) and basically go through the same hoops as if you were applying for an STC! They made this change on Sept 13th, you guessed it, my GW increase was pending at the time. (Only filed it in Aug, but don't get me started) Now their response is, "don't even ask". I guess I'll just have to leave my anvil behind when I'm on floats.
Ken
I'll stir it up a little. In Anchorage, the FAA is pretty well represented by some guys that used to be in the mechanic's business and others that were in the air taxi business. Most everybody liked them then, and they seem the same to me now. Good guys. As for field approval of gross weight increases, CG envelopes, and weight and balance, these same guys as you say, aren't engineers. It would be impossible for a government agency to fairly administer the approval of fundamental changes to a certified airplane. We all saw inconsistency in the past. One guy denies a 337, call another guy, it's approved. I wouldn't allow such inconsistency in my business. As much as I don't like some things the government does, this policy makes some sense. Piper made a good airplane. Some creative people have developed mods that work. They design the mods and prove them, and...put their names on them. There are specific installation instructions and flight manual supplements. There is product liability. The FAA isn't and shouldn't be in the business of allowing us to change fundamental design criteria of a certified airplane without engineering and testing. Otherwise, the proven airplane becomes an experiment. There is a section in the FAR's that allow that, right?
stewartb,
The problem is still within the FAA? There is no consistancy in their process? I I agree in theory with everything you said. I also respect and agree that the STC holder did infact do the engineering (some arguably necessary, some not) He desires to get paid for what he did! (That is what our patent process was designed for)?? Why should Aviation be any different? To deny 'any' FA for any modification that modifies the CG, is a broad stroke that fixes nothing! Every addition changes the WB and CG. I can agree on major mods such as new engine combinations, seat location, stablizer mounting, airfoil changes, etc. but to require engineering to us a thicker Aluminum for baffle material? give me a break!, or to put safety cables on the gear that don't have an ATLEE stamp on them?, give me a break!, or to use a gas strut to hold the window open? and so on and so on. This is just bureacratic crap!
My FAA inspector has been around to see my 12 lately, and there were no problems. In fact, he offered some pretty crafty solutions. The tone of the meeting was one of cooperation. On my 12, there are lots of details that aren't covered by STC's, and I need to make accommodation for some of the mods that are STC'd. No arguements, just common sense. I was told that deviations to existing STC's will get tough, and field approval of a mod that is available by STC would be really hard. I can live with that. The mods that will be denied are generally not mods I want to do.
And... a question for you mechanics. Are safety cables a major alteration? Gas assist cartridges on a door? As Tim says, some STC's don't really need engineering. Some of these products probably don't need a 337. What do the FAR's say? (Read 'em like you were a lawyer.)
cool deal, perhaps I am over reacting to a situation not as wide spread as it appears from this area? hope so! Thanks for the encouraging words as to some remaining common sense in the FSDO office!
Tim
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I downloaded the Bulletin http://www.faa.gov/AVR/AFS/HBAW/HBAW0203.DOC last night and fell asleep reading it. Man what nightmares I had. I'm not good at interpreting things, just ask my English teachers, but I don't see a lot of changes. For example under "Alterations Not Eligble For Field Approvals" it states "(2) Changes in the certified center of gravity range limits (e.g., decreasing the forward limit or increasing the aft limit)." I didn't think that could be approved on a Field Approval anyway. Some of you other guys read it and let me know your thoughts.
Steve
Steve, you're correct, those items never have been field approvable... Obviously, if we screw something new on the plane it adds weight/changes CG, this is no problem... But, you've never (within recent history) been able to get a field approval to change limits...
The only difference I can see is a clearer definition of what was to go through engineering. Yes, they are being more careful than they used to be, but with the flack they have taken on certification and approvals, what do you expect? I've heard all this wild talk of there being a end to the field approval process for years, useally from people who don't actually do them. Relax, it doesn't seem that much, if anything has changed. It will just take a little longer.
RELAX?
This is the same entity that said, you gotta take off your perfectly serviceable, dual Bendix mags, throw them away and pay thousands for a new set.
This is the same entity that said, take that Brackett filter off and throw it away and buy a new one.....because of one failure on an illegal installation.
Frankly, I think, in general, we are dealing with (fill in your own expletive here) at the FAA.
?What?
I still have dual Bendix mags, and a Brackett filter, all of which are still legal, lots of planes do...
If it gets to bad, then "we" go to work for the FAA, then we can be the bad guys, right?
Like most of the "Big" companies, Government included, there are lots of good people there! They are just not in control--the lawyers, lobbiest, and "special iterest groups", are in control of the decisions they make
oops, sorry this should got to the Rant and Rave section!!
Nuf said!
Tim
I forgot about stewartb's question. My thinking, and the opinion I have always gotten from the Fed's is that when in doubt weather something is major/minor is to just submit the 337. If it is something that simple, it should get approved without any question, and than it is DONE, and no one will ever be able to question it.
Good Point Mark!
I have experieced the same! It seems that the IA's that have the least challenge with the local FSDO's are the ones that do the cleanest job with the submittion of paperwork!
The old saying "if you can't dazzle them with brilliance, baffle them with Bull ****"
Tim
Not to say that many IA's aren't brilliant!
94-06-09Originally Posted by SuperCub MD
94-01-03R2
96-09-06
I think some of you guys are making the assumption that everything will go on as-is. The information I am getting indicates that the Field Order directives are coming from the top and our friendly and accommodating local inspectors will have nothing to say about it. It's being billed as, the end of an era.
To say the least, I'm not optimistic and have always felt that the higher ups would like to see the end of general aviation, at least on the individual level.
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TJ,
This is a two edged sword! I am not an IA but I have worked with many and I am amazed at how different, everyone, Feds, and IA's interpret the regs? I agree with the FEDS and with the position of "most" IA's that it would be alot easier if the regs could be written cut and dry, unfortunately the work that is being done, or requested to be done is work done on "older a/c that, now with technology, experience and yes even engineering expertise from the field, a "Better mousetrap" is possible--The challenge is that the liability of the modification has all to often fallen back on the "original manufactures", or to the Repair shops, A/C owners, and anyone else that has two cents to rub together! Just you mentioning dragging an Attorney into the frickas get's my hackles up!
It is no doubt that the top wants to 'eliminate the modification of GA aircraft by anyone other than the original Manufacture! Sorry to say the only way they are going to accomplish that is to insist that "every" submittal for modification will be presented "with engineering" data. Doing so will make it to costly to the owners to have the work done! This will lessen the work you and other IA's do and you will eventually go broke and when that happens then GA small aircraft ownership will cease!
Is it any wonder that the homebuilt industry is booming!
Tim
Idelete
There's no question that the FAA is leaning toward the Designee program... Just look at the operations side of the house, FAA inspectors don't do private/commercial rides anymore, DPEs do them... Want an LOA in your warbird?... Find a designee with a LOAA, or maybe it's an eieio... As someone mentioned before, if you want a "complex" field approval, you can wait for FAA engineering (ACO) to assign a 757/767 engineer to your project, or you can employ the services of Designated Engineering Rep. (DER)... Personally, I'd go with the DER because they usually have more experience with toy airplanes... Some of them are really good and helpful, like the one who lives close to PA12Driver...
As Tim pointed out, liability is killing us... A few years back an FAA inspector would tend to stick his neck out to help... Those days are gone, now he'd get it lopped off...
Its all about liability. If there is an STC the STC holder is liable. If the manufacture designed it he is liable. Cover Thy Ass.
Steve
PS. The only airplanes that I see that don't need annuals are the ones that sit in the hanger for years and never fly. But when it is time to fly it will be a major job. Guy brought a Bonanza to this airport the other day that hadn't been annualled since 1998. Mouse droppings every where. I don't see how he stood to fly it the 10 minutes it took to get here. He caught 14 mice so far. I don't waste my time annualling airplanes that don't need to be annualled. My customers bring their airplanes to me because they don't want any questions in the back of their mind as to the airworthiness of their plane. Over the years I've pissed off all the cheap skate winers and they go elsewhere. Luckily there are enough people that appreciate what I do that keeps me in buisiness. It's back to liability, if my name goes in the book its done to the best of my ability. My problem is I have a consionce and I like to sleep at night.
Wow, That advise scares me TJ. I think the day a have to keep a lawyer available to threaten the Feds or anyone with, will be the day I turn in my ticket. There are easier, much more lucrative ways to make a living.
I don't want to give a customer their plane back and tell them, "Hey, I think it's legal, but if someone else inspects it and thinks I'm wrong, here is the name of my lawyer." I think the customer would be happer knowing I did I little extra paperwork to keep them legal? And if I threaten the Fed's with my lawyer to get a approval, what type to treatment will I receive when I seek the next approval?
Yes, it's getting harder. But I think I will get a lot more done if I work with the system rather than against it. I have never not been able to get an approval for what I want to do, and I'm not going to pick a fight just for the sake of picking a fight.
The AD thing, which is a different subject, but since you went to the trouble of looking them up, I'll respond.
I have done the AD's you mention many times. Calling out a bad (small) batch of capacitors is bad? If you have one of these capacitors installed you can find them one of two ways, research the AD or wait till the mag quites. The AD route is worse? The coil and rotor AD just roots out the few remaining 30+ year old parts which were poorly manufactured in the first place, most had been replaced by then because of failure or maintance anyway. Neither require scrapping the mag, I put the proper parts in a lot of them, and they are still running fine.
The airfilter is a perfect examply of how a AD comes about these days. A gasket came loose and was injested, and a plane crashed, and law suits flew everywhere. The manufacturer deamed their current design flawed, and revised it to make sure the gasket does not get injested, more, I'm sure for liability reasons than a real problem if the original filter is installed properly. The manufacturer than tells the FAA that their original product is flawed and should be replaced with the improved part. What is the FAA supposed to do? Tell the manufacturer that their old product is fine, and they won't issue the AD? That would leave the liability on them, and it ain't going to happen in todays litigious society. Anyway, the end result is that if you have one of the old filters, you have 500 hrs to replace it with the new design. If you wait till your element needs replacing anyway and buy the complete unit, you will get the better designed filter for a whopping 30 bucks extra out of pocket. Is that really the end of the world?
Mark...
Excellent points, very well written...
Not all ADs are perfect and some have even been rescinded, but there is a reason for them and it's usually the manufacturer that initiates them and who knows their product better than the manufacturer?... That's a rhetorical question...
Thanks David,
As a note before anyone else jumps in, I am NOT going to defend every AD out there, some of them are just plain silly.
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Yes TJ, different trails, same conclusion I think. I don't try to create extra paperwork if I don't think it is warrented. But if it falls into a "grey area", I'd rather get the FAA's stamp to cover my bases. Then if for some reason the FAA want's to pull the approval, they have to admite that one of their own was wrong, instead of just saying that some country roob with a pen (me) was wrong. Understand that I do greatly appreciate your opinons, and the opinions of any others who have been doing this for much longer that I have. I've still got a long way to go, and may be a little nieve(sp) and overly optimistic.
Mark:
Agreed. If you can't argue with friends, who will you argue with? If you argue with enemies, they may kick your butt!
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