STC removal requirments

mike mcs repair said:

so sad, SJ removed R&R... that's where this one needs to go.... a couple good Fu&^ this, and that politician is a BASt76d, and we'd never need to suffer this again....

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I don't think so. I think its good to know what is out there and how people interpret things. Kinda reminds me of the old control zone (class D) thread we had a few years back. A few people got their hackles up, but it was good to see how the interpretation of the regs change as we lose perspective of how they were originally written.

dgapilot said:

Back to the original question, if the items were installed at one time, does the removal of them rise to the level of a Major Alteration? Use the flow chart to see. If it does, then the person doing the work is required by 43.9 to file a 337.

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But that is the stickler. Do you consider the act of removing and installing a propeller in and of itself a Major endeaver? I don't. I do consider the initial installation of one that wasn't previously approved a major alteration. but once it has been approved for my airplane it then becomes a minor alt to remove or install it. Log it, if it has a flight manual supplement, remove it or put it in the manual, reference the correct weight and balance and move on. The only ICA needed is the one that came with the STC if its that new of an STC.

Now if I cut and welded a Supercub into a widebody version, and then later decided to cut and weld it back to original, you may have a point. but only because of the cutting and welding. If it was bolt on, bolt off-- NO.

This thread has drifted from Bob's original question in a manner in which we all can hopefully become more knowledgeable.

dgapilot said:

ICAs are not FAA Approved, so there is no approval process beyond the IA signature on the 337.

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On occasions when I've needed to write an ICA as part of a 337, the FAA-PMI has informed me that he didn't like a portion and wanted it rewritten. That is telling me that ICAs are FAA Approved. If they are not FAA Approved, it was beyond his authority to tell me that he did not like it and to change it.

dgapilot said:

When I do approvals for floats, I always write an ICA into the approved data about seasonal changes.

It is always fun to discuss these issues. Hopefully we can all learn from one another. I didn't mean to come on strong, but just wanted to be sure Bob wasn't getting blamed for my comments.

David

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It has been my experience that float installations are approved as part of the TC (minor alteration for the installation, A&P log book entry) or as either a single or multiple use STC (major alteration for the installation, IA form 337 and log book entry). Under what authority do you "do approvals for floats"? The acquisition of an STC for a float installation is a major endeavor involving engineering and extensive flight testing. If there is a third method of doing a float approval, been there and done that, I would be interested in learning about it.

Alteration work that has been properly documented by Form 337 is just that, "documented".

It is also noted in the log books as having been performed and documented by 337.

Removal of the Alteration does not "undocument" the aircraft.

IF........ if removal of an alteration requires major repairs (removal of Polyfiber fabric to install Stewarts System) or (tubing replacement, removal of a widebody Cub alteration)......

....the major repair would need documentation by Form 337. .......and a log book notation of the major repair necessary by the removal of the STC'ed alteration...........

The logbook entry has recorded the work effort!

There is no need of action to "unapprove" data that the earlier 337 approved.

Any argument with this position would need support from an FAR for me to see my position differently


Doesn't this make alot of sense?

cubdriver2 said:

...He's an A&P, IA, DAR, vDER. ...

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I know what designated airworthiness reps & designated engineering reps are, but what's a vDER?

mike mcs repair said:

so sad, SJ removed R&R... that's where this one needs to go.... a couple good Fu&^ this, and that politician is a BASt76d, and we'd never need to suffer this again....

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I disagree.
I don't see anyone losing their temper and flaming anyone.
Lots of airplane guys I know don't know squat about the ins and outs of paperwork,
so I have to go on websites like this one to participate in a discussion like this--
both enjoyable & educational.

Bob. "Show me the FAR". Same words I would live by if I lived in your zipcode.

Does "your" FSDO know something the rest of us do not? If so, "show me the FAR". In other words "make it stick and posess teeth".

seriously! Dmc

There are so many things worth fighting over - this is not one of them. I admit to cheating some - a while back I took the aileron spades (STC) off, then put them back on without 337 either way. Statute of limitations is up, or I would not tell . . . But for me, doing a 337 for removal is trivial. And, if I can do eight in one year, I do not have to go to IA school.

I tried to fight the narrowing of our cross runway. They paved it to much higher standards than it used to be, and to its full width of 150'. Then they striped it down to 75' Idiots. When I inquired, they said it was to save money. That is the kind of stuff I would think is worth fighting

bob turner said:

There are so many things worth fighting over - this is not one of them.

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I disagree. Maybe not among ourselves, but with the FAA. Each new generation of FAA whizzes come up with more things you can't do. We've virtually lost Cam 8. Bet no one here even knows what a follow on field approval is, little own one of the FAA guys.
something similiar to this issue happend a few years back in Texas. Some New FAAers started writing up AG Pilots for switching from their spray system to a spreader without going thru the whole shebang each time. The Ag industry put a stop to it. Needs to happen here too if this is now their official interpretation of how things have to be.

We got people to realize you can actually fly into or out of Class D airspace VFR even if the official observation point is below VFR Minimums, we can do it here too.

Where's Flip Flop when we need him !!!!

S2D said:

Where's Flip Flop when we need him !!!!

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He moved further south.

bob turner said:

...I tried to fight the narrowing of our cross runway. They paved it to much higher standards than it used to be, and to its full width of 150'. Then they striped it down to 75' Idiots. When I inquired, they said it was to save money. That is the kind of stuff I would think is worth fighting

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Good luck trying to prevent any public agency from spending money foolishly!
Same sort of deal at my airport, FAA seems determined to totally rebuild our runway, to the tune of about $2M, although it's only 27 years old and in pretty good shape.
Since our most recent "airport master plan" projects current usage at an average of 180 operations per day (reality x a factor of about 4), no wonder they think it's worn out.

Yeah. Next week our instrument runway gets repainted. To my eyes, the markings are all in great shape. My friends all say that the airport pays for it, but I think we are hosing the taxpayers. We now have two well qualified people in the office weekends and holidays; in previous years when we had twice as much traffic we did not need weekend patrols.

Speaking of traffic - today was cloudy and rainy, and my Cub and I scored 24 "operations." That is likely 10% of today's totals at the eleventh-busiest GA airport.

We are our own worst enemy...