Here is some thing that our Fsdo put out at a meeting worth a try
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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
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......
....you can't just copy an old field approval as data and send it in without a new stamp in box 3. ....
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."
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.
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.
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???