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 see there is a Forum in Anchorage on May 2nd. I hear there are no more Field Approvals... again. What has everyone been experiencing?
Tim
In my shop.
Field approvals & masectomies... 5c.
Nimpo Lake Logan... boonie SuperCubber
200mi (300km) from nearest stoplight... just right! - "Que hesitatus fornicatus est"
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.
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"?
Can he find data, other field approvals, and/or 337s which may help his request? Or is it just plain NO! Which FSDO?Originally Posted by gkm
Idaho FSDO said "No".
He spoke with someone in Anchorage who said "no".
The upcoming forum in Anchorage may prove to be very interesting.
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.
The following is the FAA's guideline for field approvals. http://fsims.faa.gov/PICDetail.aspx?...25734F0076663A 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.
N1PA
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!
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!
I heard 8th. Which is it?.. Link ?.
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...aspx?eid=44018
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
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....
The dreaded ramp inspections could start all over again. "What's in your wallet"?
I hear some D.A R. s may be authorizield to do field approvals?
travel light freeze at night
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!
Where I live, unless somebody "drops a dime", ramping pilots ended about 10 years ago.
"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
Tim
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.
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.
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.
Steve Pierce
"When everything seems to be going against you, remember that the airplane takes off against the wind, not with it."
Henry Ford
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
Tim
So why do they only have these kinds of informative meetings in Ak?
Piper J-5A C-90 N40877
J-5 Project Pictures
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."
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....) 'breaker 1-9.. this is the mixed up mechanic...' or so I gave my self when I was 7..
Last edited by mike mcs repair; 04-30-2012 at 11:56 PM.
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.
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.
Here is some thing that our Fsdo put out at a meeting worth a try
advisory circ.pdf
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
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?
Steve Pierce
"When everything seems to be going against you, remember that the airplane takes off against the wind, not with it."
Henry Ford
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
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.
Steve Pierce
"When everything seems to be going against you, remember that the airplane takes off against the wind, not with it."
Henry Ford
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
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.
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
adv. cir.jpg
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
Piper J-5A C-90 N40877
J-5 Project Pictures
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