Field Approvals

[bob turner]

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]

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]

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]

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]

....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]

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]

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]

[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]

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]

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]

Tim,
Down here in Maine our FSDO won't even hear about fiel approvals. Been that way for some time

Good luck. Joe

[skywagon8a]

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]

Bob, I think the handbook is pretty cut and dry. What are you trying to field approve?

[mike mcs repair]

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]

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_polic...tly_published/
I don't see it at first glance....

[bob turner]

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]

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]

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]

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.]

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.
Forget the field approvals, its a done deal.

[bob turner]

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]

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.

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]

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]

FAA help and cooperation: It ebbs and flows...

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

[bob turner]

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]

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] 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) [hr][/hr][1] 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

[mike mcs repair]

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!!