S
StewartB
Tonight, at Romig Middle School, 5-9PM, the FAA will discuss the changes to the Field Approval process, or as they say, "the transition" to the new policy. I'll try to go.
SB
SB
FlipFlop
Registered User
Maintaining at Flight Level Zero, requesting lower
T.J. Hinkle said:
Ditto Stewart, I'd like to know the answer to that one too... Ask them if you get an "Alaska Approval" to mount antlers on the top of your 180 and fly to "Lovely" Fresno, get ramped and questioned about the antlers, does the approval work in "Lovely" Fresno, or do you have to ship the 180 to the Alaska stateline to get home...
S
StewartB
Don't ask. I didn't go. I'll get the scoop from one of the FSDO guys. The meeting is about the same stuff I already posted.
SB
SB
Big AK
Registered User
BIG Alaska
Didn't learn anything new, except that a bunch of guys listening to the Feds will always end up in a bitch session. OOps, that's not new either.
The answer to TJ's question is: by authority of the federal law requiring the FAA to consider Alaska's "unique operating environment" when making new laws. Even the meeting chair, Mark Wilson, a good Fed., joked about the difference in the air in the lower 48, and how it affects flight.
Basically, field approvals will require more and better documentation. Also, major changes to type design (say, something like Cub flaps extended inboard toward the fuselage) will not be field approved, but will require an STC to be legal country-wide.
Anything field approved before the end of this month (SEPT. 2003) is grandfathered in, unless some problem is discovered, then they'll issue an AD covering the mod. After that, mechanics will be spending more time on documenting mods. and talking to engineers than they will spend performing the modifications.
It's a bitch. But, eventually all the great and worthy Cub mods will be available as STC's because someone will have poneyed-up the dough to make it so. Let's hope it isn's F.A.D. or J.R. that get all the marbles. No disrespect.
DMC
The answer to TJ's question is: by authority of the federal law requiring the FAA to consider Alaska's "unique operating environment" when making new laws. Even the meeting chair, Mark Wilson, a good Fed., joked about the difference in the air in the lower 48, and how it affects flight.
Basically, field approvals will require more and better documentation. Also, major changes to type design (say, something like Cub flaps extended inboard toward the fuselage) will not be field approved, but will require an STC to be legal country-wide.
Anything field approved before the end of this month (SEPT. 2003) is grandfathered in, unless some problem is discovered, then they'll issue an AD covering the mod. After that, mechanics will be spending more time on documenting mods. and talking to engineers than they will spend performing the modifications.
It's a bitch. But, eventually all the great and worthy Cub mods will be available as STC's because someone will have poneyed-up the dough to make it so. Let's hope it isn's F.A.D. or J.R. that get all the marbles. No disrespect.
DMC
narov
Registered User
Wichita, KS
Ok question regarding field approvals and tire installs. "4. ACTION. ASI's are no longer authorized to approve tundra tire
installations using the field approval process. " ( http://www.safetydata.com/tundra.htm )
So has anybody been able to get tundra tires approved after '97? Or are all of the installations by STC?
And after Oct. 1 then for sure by STC only?
Carlon
installations using the field approval process. " ( http://www.safetydata.com/tundra.htm )
So has anybody been able to get tundra tires approved after '97? Or are all of the installations by STC?
And after Oct. 1 then for sure by STC only?
Carlon
FlipFlop
Registered User
Maintaining at Flight Level Zero, requesting lower
PA12driver
Registered User
Battle Ground, WA
No disrespect but there are at least (4) agencies of this great Country that "stand above the law"
1) the IRS
2) the FAA
3) the TSA
4) the NTSB
Where the hell were all those so called elected representatives "of the people, for the people"???
Isn't Alaska still part of the USA?? Just wait till the lawyers get ahold of this mess when a plane flys to the lower 48 on an vacation and gets ramped!
Tim
Another reason to go Experimental homebuilt!
Sorry, Steve, you can move my comment to the rant and rage section if you want!
1) the IRS
2) the FAA
3) the TSA
4) the NTSB
Where the hell were all those so called elected representatives "of the people, for the people"???
Isn't Alaska still part of the USA?? Just wait till the lawyers get ahold of this mess when a plane flys to the lower 48 on an vacation and gets ramped!
Tim
Another reason to go Experimental homebuilt!
Sorry, Steve, you can move my comment to the rant and rage section if you want!
S
StewartB
Tim,
You apparently are confused. Remember several months ago the change in Field Approvals, or the idea that the process was going away? Then Cuby posted the Field Approval handbook that defined what could and what couldn't be approved? Well, as of Oct. 1st Alaska is playing by the same rules as the rest of you. The only reason our compliance date was delayed was because Alaskans convinced our Senators to act on our behalf. (Hey Diggler, recognize the concept?) So, now we're the same, with the "Legacy" approval being an exception that will allow some local leeway for a couple of years. That policy allows mods that have been normally approved in the past to be approved FOR USE IN ALASKA ONLY. The idea is to give guys in the middle of projects some time to get the engineering to have modifications approved correctly. Otherwise their planes could not be considered airworthy. That policy seems like a benefit for pilot/owners, say.... guys like me in the middle of highly modified projects. It will also provide time for some guys to actually get STCs for some of the mods we all do. If you fly a Cub, you should be happy with this provision, since almost all the mods you want started here.
SB
You apparently are confused. Remember several months ago the change in Field Approvals, or the idea that the process was going away? Then Cuby posted the Field Approval handbook that defined what could and what couldn't be approved? Well, as of Oct. 1st Alaska is playing by the same rules as the rest of you. The only reason our compliance date was delayed was because Alaskans convinced our Senators to act on our behalf. (Hey Diggler, recognize the concept?) So, now we're the same, with the "Legacy" approval being an exception that will allow some local leeway for a couple of years. That policy allows mods that have been normally approved in the past to be approved FOR USE IN ALASKA ONLY. The idea is to give guys in the middle of projects some time to get the engineering to have modifications approved correctly. Otherwise their planes could not be considered airworthy. That policy seems like a benefit for pilot/owners, say.... guys like me in the middle of highly modified projects. It will also provide time for some guys to actually get STCs for some of the mods we all do. If you fly a Cub, you should be happy with this provision, since almost all the mods you want started here.
SB
PA12driver
Registered User
Battle Ground, WA
SB,
The complaint is it shouldn't take an DER, STC and $$$ to weld an tab on a fuselage to hang your headset, or for that matter to reroute the scat house to better clear the cowl? make a glass nose bowl/cowling, stuff the seat with a sleeping bag, put a reinforcement under the heel brake area, put nutplates in place of pk screws, on and on and on!
You are right most Major,useful mods" are or will be STC'd for the most "popular models", however many are not and with the added cost and delay of STC approval, most "new ones" (those using new and improved material) will not be.
The rate of new STC development has already fallen off considerably!
That is my point!
Tim
The complaint is it shouldn't take an DER, STC and $$$ to weld an tab on a fuselage to hang your headset, or for that matter to reroute the scat house to better clear the cowl? make a glass nose bowl/cowling, stuff the seat with a sleeping bag, put a reinforcement under the heel brake area, put nutplates in place of pk screws, on and on and on!
You are right most Major,useful mods" are or will be STC'd for the most "popular models", however many are not and with the added cost and delay of STC approval, most "new ones" (those using new and improved material) will not be.
The rate of new STC development has already fallen off considerably!
That is my point!
Tim
S
StewartB
Tim,
You can do most of that stuff even now. I read the FA guidelines and didn't find much to disagree with. Even the mechanics will adjust to the paperwork requirements. If you want to rationalize going experimental, go for it. I always consider the FA argument from the standpoint of "what would I accept if I were buying a plane with a book full of FA's?" I've seen some approved mods that I wouldn't trust. I wouldn't buy a plane with a nose bowl you fabricated in your garage. I've said before that I don't want an experimental. I also don't want a certificated plane with loosely-approved experimental mods. Seems like the FAA has provided for all of us.
SB
You can do most of that stuff even now. I read the FA guidelines and didn't find much to disagree with. Even the mechanics will adjust to the paperwork requirements. If you want to rationalize going experimental, go for it. I always consider the FA argument from the standpoint of "what would I accept if I were buying a plane with a book full of FA's?" I've seen some approved mods that I wouldn't trust. I wouldn't buy a plane with a nose bowl you fabricated in your garage. I've said before that I don't want an experimental. I also don't want a certificated plane with loosely-approved experimental mods. Seems like the FAA has provided for all of us.
SB
PA12driver
Registered User
Battle Ground, WA
SB,
In theory you are right! When I lived and flew/built airplanes in Alaska, I would agree with you, most of the guys at the FSDO were reasonable, and would gladly come and look, work with and approve mods that "made sense", yes indeed there were some that "loosely approved".
In the lower 48 there "has" been much more subjectivity as to what would be approve and what would not be approved. (It all depended on the individual in the office? I am hopeful that the new 'guidelines" will help, as there is a provision for discussion of approval between FSDO offices.
My (opinion) is the FAA no longer wants to hold their inspectors responsible for the "decision" to approve (many today are not "engineers", soooooo they have pushed that over to the responsibility of an DER in the private sector. Ok now we have another layer of involvment, raising the cost of GA. Is it necessary??? I would love to see some stitistics that show the cause of accidents in GA aircraft that could be pinned on the Quality of the modification approved by an FA??? anyone?
Tim
Each to there own as to Certified or not. (each has its place and purpose) Good luck on your project completion.
In theory you are right! When I lived and flew/built airplanes in Alaska, I would agree with you, most of the guys at the FSDO were reasonable, and would gladly come and look, work with and approve mods that "made sense", yes indeed there were some that "loosely approved".
In the lower 48 there "has" been much more subjectivity as to what would be approve and what would not be approved. (It all depended on the individual in the office? I am hopeful that the new 'guidelines" will help, as there is a provision for discussion of approval between FSDO offices.
My (opinion) is the FAA no longer wants to hold their inspectors responsible for the "decision" to approve (many today are not "engineers", soooooo they have pushed that over to the responsibility of an DER in the private sector. Ok now we have another layer of involvment, raising the cost of GA. Is it necessary??? I would love to see some stitistics that show the cause of accidents in GA aircraft that could be pinned on the Quality of the modification approved by an FA??? anyone?
Tim
Each to there own as to Certified or not. (each has its place and purpose) Good luck on your project completion.
S
StewartB
Tim,
I figure the restrictive FA process can't do anything but protect the value of certificated planes. It establishes a set of rules and boundaries that these planes have to conform with. Exactly my argument against experimental planes. Are there good experimentals? Absolutely. I don't care. This is an asset value issue. You always say your plane works really well. It's certified isn't it? Have you really been unfairly restricted in what you can do to it?
SB
I figure the restrictive FA process can't do anything but protect the value of certificated planes. It establishes a set of rules and boundaries that these planes have to conform with. Exactly my argument against experimental planes. Are there good experimentals? Absolutely. I don't care. This is an asset value issue. You always say your plane works really well. It's certified isn't it? Have you really been unfairly restricted in what you can do to it?
SB
SuperCub MD
Registered User
Collins, Wisconsin
I'm lost here...What "rules" are different in Alaska? Just packed up a Cub and sent it off to Alaska this morning that has a whole stack of approvals done by me, including a FA. When it gets up there, it's still going to be legal right? So now that it is based in Alaska, if it comes back down, are my approvals void? If I bring a Cub down from Alaska, why wouldn't approvals done on it be legal here? If it has FA's done in Alaska, would I have to redo them here?
Doesn't make any sense, I want to see where this is written in the regs.
Yes TJ, still doing FA's down here. I just did a FA a week or two ago, under what I guess must be this "new" system, and it was no different from any other I have ever done since the ICA's became manditory.
SB, You are hitting the issue right on the head. It's all about conformity to a certain standard. If we didn't have standards to hold all these planes to, we wouldn't have all these wonderful old machines still around to play with. Even with the current system, enough screwed up stuff gets done to these planes, there has to be a boundary set somewhere.
Tim, the things you think ar minor, may not be. What if your weld on headset hook is in a unsafe location, and scewers your brain in turbulance? What if the scat tube you relocate in the cowl jams the engine controls? What if your sleeping bag seat or reinforced floorboards jam the flight controls? What if your homemade fiberglass nose bowl ends up weighing 100 pounds? Maybe you would miss these things, but luckily, there is a system in place where some trained pro aircraft inspectors are going to have to check these things for you, it's called the current FA process.
Doesn't make any sense, I want to see where this is written in the regs.
Yes TJ, still doing FA's down here. I just did a FA a week or two ago, under what I guess must be this "new" system, and it was no different from any other I have ever done since the ICA's became manditory.
SB, You are hitting the issue right on the head. It's all about conformity to a certain standard. If we didn't have standards to hold all these planes to, we wouldn't have all these wonderful old machines still around to play with. Even with the current system, enough screwed up stuff gets done to these planes, there has to be a boundary set somewhere.
Tim, the things you think ar minor, may not be. What if your weld on headset hook is in a unsafe location, and scewers your brain in turbulance? What if the scat tube you relocate in the cowl jams the engine controls? What if your sleeping bag seat or reinforced floorboards jam the flight controls? What if your homemade fiberglass nose bowl ends up weighing 100 pounds? Maybe you would miss these things, but luckily, there is a system in place where some trained pro aircraft inspectors are going to have to check these things for you, it's called the current FA process.
PA12driver
Registered User
Battle Ground, WA
Guys,
Don't get me wrong I am not against 'an level of quality'. We have that system in place, the challenge has been that the FAA has approved good work and bad work, depending on whom submitted the FA to Whom. It still is that way! As for quality work being done either experimental or certified, I have seen, as well as have any of you that "actually" work on small planes? seen as much crappy work come from "certified" repair stations, AP's, IA's as from the garage of a homebuilder??? It not was the case there would not be as many "sqawks" to redo previous work done "during the last annual". MD trust me I am not talking about just throwing fibreglass at a nose bowl, or welding a tab anywhere. The point is it doesn't take an STC to do minor work.
A perfect example is "Tundra Tires" The FSDO in Hillsboro not to long ago refused to FA the "Bias 29's" that came off another PA18 that were installed not an year earlier under a FA?? The same plane was flown to Boise ID where there was not a problem getting the work approved. Now the attitude is to "not" FA any modification that has similar work done under an existing Similar STC??? We could go on and on, but as T.J. says it wasn't broke for the last 60 years so other then to CYA why the additional work and headache. If there needs to be consistancy lets just be sure that the FAA inspectors are consistant, qualified and willing to 'share information between regions (where expertice in one region is lacking)
How about making sure that "certified mecahnics" actually have 'practical' experience to work on the type of aircraft that comes into there shop?
Damn this is a nagging topic, anyone got any good hunting stories?
Tim
Don't get me wrong I am not against 'an level of quality'. We have that system in place, the challenge has been that the FAA has approved good work and bad work, depending on whom submitted the FA to Whom. It still is that way! As for quality work being done either experimental or certified, I have seen, as well as have any of you that "actually" work on small planes? seen as much crappy work come from "certified" repair stations, AP's, IA's as from the garage of a homebuilder??? It not was the case there would not be as many "sqawks" to redo previous work done "during the last annual". MD trust me I am not talking about just throwing fibreglass at a nose bowl, or welding a tab anywhere. The point is it doesn't take an STC to do minor work.
A perfect example is "Tundra Tires" The FSDO in Hillsboro not to long ago refused to FA the "Bias 29's" that came off another PA18 that were installed not an year earlier under a FA?? The same plane was flown to Boise ID where there was not a problem getting the work approved. Now the attitude is to "not" FA any modification that has similar work done under an existing Similar STC??? We could go on and on, but as T.J. says it wasn't broke for the last 60 years so other then to CYA why the additional work and headache. If there needs to be consistancy lets just be sure that the FAA inspectors are consistant, qualified and willing to 'share information between regions (where expertice in one region is lacking)
How about making sure that "certified mecahnics" actually have 'practical' experience to work on the type of aircraft that comes into there shop?
Damn this is a nagging topic, anyone got any good hunting stories?
Tim
S
StewartB
TJ,
No law says Alaska is different. That's the point. Our delayed implementation of the FA handbook is over. On Oct. 1st we're all the same. We've been different for the last six months. I like the new order. It defines very well what can be approved with and without engineering, and what can't be approved, period.
SB
No law says Alaska is different. That's the point. Our delayed implementation of the FA handbook is over. On Oct. 1st we're all the same. We've been different for the last six months. I like the new order. It defines very well what can be approved with and without engineering, and what can't be approved, period.
SB
PA12driver
Registered User
Battle Ground, WA
SB,
Perhaps I was still thinking of the last 6 months? Sounds good if there now is uniformity? I guess time will tell and as always if there is enough sqweek, the wheel will get greased.
So have you heard whether Crash got his 18 flying??
Tim
Perhaps I was still thinking of the last 6 months? Sounds good if there now is uniformity? I guess time will tell and as always if there is enough sqweek, the wheel will get greased.
So have you heard whether Crash got his 18 flying??
Tim
S
StewartB
Tim,
I don't think so. I know he hunted in the 14. By the way, ODM (one dead moose) last Saturday, 49" with 3 brow tines on both sides @ 175 yards with a 300 Weatherby and a Barnes X bullet. I was by myself. I forgot just how much work that is. I'll have forgotten by next year, though.
SB
I don't think so. I know he hunted in the 14. By the way, ODM (one dead moose) last Saturday, 49" with 3 brow tines on both sides @ 175 yards with a 300 Weatherby and a Barnes X bullet. I was by myself. I forgot just how much work that is. I'll have forgotten by next year, though.
SB
narov
Registered User
Wichita, KS
TJ,
The way this reads, it appears the inspector cannot outright refuse to do a FA because he is afraid or lacks experience, but rather seek guidance from someone else in the FSDO. Seems like you could push the issue since this is taken straight from their own handbook. (Although you wouldn't want to anger him to much I guess)
8300.10 ch. 16
"(3) Flight Standards District Offices (FSDO)
must ensure that the lack of an ASI?s experience or
qualifications does not necessarily stop the approval
process. The lack of ASI qualifications does not mean
the FSDO should deny a field approval and tell the
applicant that they need an STC. The ASI can seek
assistance from another ASI or FSDO, as appropriate."
my 2 Cents worth,
Carlon
The way this reads, it appears the inspector cannot outright refuse to do a FA because he is afraid or lacks experience, but rather seek guidance from someone else in the FSDO. Seems like you could push the issue since this is taken straight from their own handbook. (Although you wouldn't want to anger him to much I guess)
8300.10 ch. 16
"(3) Flight Standards District Offices (FSDO)
must ensure that the lack of an ASI?s experience or
qualifications does not necessarily stop the approval
process. The lack of ASI qualifications does not mean
the FSDO should deny a field approval and tell the
applicant that they need an STC. The ASI can seek
assistance from another ASI or FSDO, as appropriate."
my 2 Cents worth,
Carlon
PA12driver
Registered User
Battle Ground, WA
TJ, SB, My point exactly! It is still usens against them, and they have the power to say NO, and the only way to fight it is to spend all your money and still not get the Darn plane flying, it is one thing if it is a personal toy, quite another if you are half way through a rebuild/repair to a customer plane, So the mechanics I know are just refusing to do anything that is not STC'd, Again the FAA gets their way, and so it goes.
TJ, surely you got pictures? Post some, I am sure others would love to see them!
SB, My back hurts just thinking about it! (do you have Bill Firmin's Phone number by chance??)
Later guys,
Tim
TJ, surely you got pictures? Post some, I am sure others would love to see them!
SB, My back hurts just thinking about it! (do you have Bill Firmin's Phone number by chance??)
Later guys,
Tim
S
StewartB
Tim,
Check your PM's.
Stewart
Check your PM's.
Stewart
PA12driver
Registered User
Battle Ground, WA
Thanks SB, got it!!
Tim
Tim
PA12driver
Registered User
Battle Ground, WA
This just copied from the Alaska Airmens Newsletter!
FAA Change 16 (Field Approvals) implemented today. This change to the 8300.10, Volume 2, Chapter 1 Handbook, affects Alaska?s field approval process. Any field approved mods made prior to today (October 1, 2003) are grandfathered in, but from this point forward field approvals must go through a committee approval process. Request for field approvals must be submitted on form 8110-3 to an FAA ASI (Aviation Safety Inspector). Change 16 also makes it necessary for aircraft with field approved modifications accepted after October 1, 2003 to obtain ferry permits to travel outside of Alaska, as the Certificate of Airworthiness will only be valid within Alaska. That means you cannot travel to Russia, Canada or the Lower 48 without a ferry permit. The Alaska Airmen?s Association is appealing Change 16.
Don't even tell me that this is the same as before!! Folks this is proposterous!! Sure hope some AVIATION ATTORNEY gets ahold of this and files suit against the FAA~ WHAT MAKE ALASKA'N APPROVED FA'S ANY DIFFERENT THEN THOSE APPROVED IN THE REST OF THE USA??? i GUESS THE FAA CONSIDERS ALASKA OUT SIDE THE "UNITED STATES"
Tim
FAA Change 16 (Field Approvals) implemented today. This change to the 8300.10, Volume 2, Chapter 1 Handbook, affects Alaska?s field approval process. Any field approved mods made prior to today (October 1, 2003) are grandfathered in, but from this point forward field approvals must go through a committee approval process. Request for field approvals must be submitted on form 8110-3 to an FAA ASI (Aviation Safety Inspector). Change 16 also makes it necessary for aircraft with field approved modifications accepted after October 1, 2003 to obtain ferry permits to travel outside of Alaska, as the Certificate of Airworthiness will only be valid within Alaska. That means you cannot travel to Russia, Canada or the Lower 48 without a ferry permit. The Alaska Airmen?s Association is appealing Change 16.
Don't even tell me that this is the same as before!! Folks this is proposterous!! Sure hope some AVIATION ATTORNEY gets ahold of this and files suit against the FAA~ WHAT MAKE ALASKA'N APPROVED FA'S ANY DIFFERENT THEN THOSE APPROVED IN THE REST OF THE USA??? i GUESS THE FAA CONSIDERS ALASKA OUT SIDE THE "UNITED STATES"
Tim
