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Field Approvals

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
 
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.:wink:

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

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






[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




 
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!!
 
Has anyone tried to get a field approval lately? Am trying to put a gear driven alternator in a cub.

Any info helps, thanx.
 
Yes. I got one in January for PA11 lift struts on a J-3. Then I tried for one to install Grove brakes on a Champ. It has been on the same inspector's desk for six months. He has not officially turned it down.

There is a new manual governing this stuff - I'll post a link in my next post. It is not much changed, but a couple of places mandate that they tell you when they turn you down.

For 2013, my airport is down to exactly 50% of its 1977 operations. Martha Lunken says there are five times as many inspectors now as there were in 1990 or so. That is why they are too busy to do these things, and also why aborted takeoffs are now a very big deal. When the tower asks why you aborted, tell them it was for training purposes.
 
For 2013, my airport is down to exactly 50% of its 1977 operations. Martha Lunken says there are five times as many inspectors now as there were in 1990 or so. That is why they are too busy to do these things,

Back then the FAA Inspectors knew what a Champ or a Cub was along with the difference between an A-65 and C-90.
 
Thanks guys for the info, last night found out about 8300.16 and AFS300 after I asked the ?on here so will now find out how the process works.
 
There are some STC's for these on other airframes. I would get paperwork on them to include with your package.
 
I went through the field approval process earlier this year. Called and emailed the inspector multiple times each week and found that they were responsive, and willing to help out. What I also learned is that under normal circumstances, they will not sign a field approval if there has ever been a STC that is the same or would accomplish the same thing. The current FAA guidance shows how to fill out the paperwork with the numbered approach "line 1- aircraft make, line 2, owner etc.) but my guy wanted a mix between the old school text and description with the new numbered approach. Making his requested changes and adding some math (disk brake conversion) we were good to go. Whole process still took about 6 weeks, but was overall a great exchange. Being willing and able to communicate often on my end helped out. Wichita fsdo.
 
It is a form of Ball Busting which the FAA enjoys inflicting on their employers (us). They need to show how busy and important they are.:sad:
Ignorance slows down the process.
 
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Bob,
I tried for several years to get a field approval to install hydraulic brakes on a 7AC. Always some type of road block but in the end what it came down to was exactly how silflexer said 'What I also learned is that under normal circumstances, they will not sign a field approval if there has ever been a STC that is the same or would accomplish the same thing.'
I could not get an approval due to WagAero having an STC'd kit available. Granted this kit is very expensive, to the tune of $4500!!! This does not included installation. I decided I didn't need better brakes that bad so left the plane on floats. Sold it last year and have gone the experimental route. Owning an experimental is almost like being a free person!! I can pretty much do as I please. Case in point, I am ordering new cylinders/pistons for a big bore kit on the Rotax, Nothing involved other than sending my money, they arrive and I put them on. Log book entry and I'm golden. :) I sure likw this experimental stuff after close to 30 years dealing with certified airplanes. Life is good!!
 
WWhunter, I'm surprised that you weren't able to get your field approval based on the fact that the hydraulic brakes are TC approved on the 7GCB. The 7GCB uses the same Scott master cylinders as the Cub. Since the 7AC and the 7GCB are on the same TC, it should have been rather easy.
 
This came today from my PMI. Thought that you all might be interested. He also attached several pdf files which I don't know how to attach to this post.


I realize this may not apply to all of you but, in case you find a need to request a field approval, I hope this will help. I know it’s a lot of info, but if you can get through it; it will speed up the process for us, and you too. Attached is guidance we now use for major alterations. The 337 data package should be reviewed and approved by the FSDO before beginning work.

Data Package:
Complete the 337 with the 16 elements as shown in figure 5-1 of 8300.16 (see note on page 20), provide all drawings and approved data to complete a Field Approval data package. Fig 3-1(page 4) is a flow chart that shows the approval process overview. (I attached a sample 337 with an acceptable format, more or less depending on the alteration, but it must have the 16 ICA elements or it will be returned).

The FAA will then use the Major Alteration Job Aid to determine if it can be field approved, requires an STC or will be a coordinated field approval with the ACO (Aircraft Certification Office). This document is found on-line via a hyper-link in order 8300.16. (All copies attached is subject to revision).

If your proposed alteration/repair will require engineering evaluation it is referred to as a coordinated field approval. This is determined by the Major Alteration Job Aid (located on page 13 for Normal category aircraft, Operational Characteristics, item D5; which is attached above and also can be accessed via this link: http://www.faa.gov/about/office_org/headquarters_offices/avs/offices/afs/afs300/ ). Include enough information for the engineers at the ACO to be able to make a determination. If they find the alteration acceptable they will provide you with a Memorandum that will become part of the 337.

Additional Information:
DER Note: The FAA inspector does not have to approve an alteration on a 337 as long as a DER has substantiated ALL of the elements of the alteration (8300.16 Chapter 2). (It will be noted on the 8110-3 whether the data is approved for the entire alteration or not. If not, then the DER approved data (8110-3) will not be for the installation portion of the alteration. It will then require field approval which will complete the process. If the 8110-3 includes ALL elements of the alteration, including the installation, it does not need to be sent to the FSDO for field approval).

NOTE: FAA Order 8110.37 addresses field approvals by reinforcing that DERs are not authorized to perform them. It also recommends including a note in the body of FAA Form 8110-3 that states, “This approval is for engineering design data only and is not an installation approval.” This does not prevent the data from being used as the basis for a major alteration or repair. When sufficient DER data has been obtained, the approval process applicable to the alteration is complete; the product can then be inspected for conformity and approved for return to service. The person performing the alteration, rather than the DER, is then responsible for conforming and approving the installation. DER data is not a field approval, but is approved data that, like other approved data, can be used in the performance of major alterations or repairs without further approval if the data addresses the entire alteration or repair. In this case, you do not need to request a field approval from the FAA. FAA Order 8300.16 provides guidance on this subject and is available at http://www.airweb.faa.gov/rgl.


Advisory Circular 43-210 is still referenced in the FAA Order and has a field approval check list in Appendix 1.

Appendix 2 of AC 43-210 contains a sample compliance checklist. Use this list when reviewing applicable regulations to show compliance in the alteration. It takes some research, but will ensure that the data package will be less likely to be rejected when you submit it.


A 337, incorporating an STC as approved data, does not need to be sent to our office (for approval) as long as it is approved for that aircraft via S/N, N-number or on the approved model listing; however, it still needs to include the 16 ICA elements.

A minor alteration as defined, does not require a 337. See 14 CFR 43 Appendix A for major alterations and repairs to airframe, propellers, powerplants and appliances.


xxxxxxxxxxx
Principal Maintenance Inspector
Federal Aviation Administration
 
I did not re-read the entire thread, but note that I am a contributor.

In the very recent past I have obtained three field approvals - Two for Grove brakes on Aeroncas, and one for replacing the master cylinders on my Cub.

It took begging, groveling, and multiple visits/appointments. The inspector was very nice during the entire process, and in the end he merely pulled out his stamp and we were done. The two non-AOG approvals took 15 months start to finish, with no engineering evaluation or re-writes. The AOG approval took a month, four contacts, and possibly the help of a now-retired inspector from another FSDO. The brakes are a dramatic change, according to the Aeronca owner. A tremendous increase in safety on the ground.
 
Well, Bob, if you will follow what Pete posted it just might go a little faster? Then again it IS the FAA and they're not happy until you're not happy.

John Scott
 
I am smart enough to have programmed Maxwell's equations in a computer, but I am not smart enough to know how to use that FAA job aid flow chart.

I think I am done fighting this stuff. My Cub and my Decathlon are exactly the way I want them, and all these Aeroncas belong to other people. It was very satisfying to see how easily the mechanical brake airplane was converted, and how much better its ground handling was.


Do you know that the mechanical brake Aeronca wheels are close to a grand each, used? Most are cracked.
 
looking for some experiences guys have had recently with the field approval process vs simple log book entry..

I am looking at a cub that has gar aeros done by field approval with 1.25 inch axles wiith the cleveland 30-60 double puck brakes. It now has the 30-52 ABI double puck brakes. these are the more robust version. Atlee Dodge has an STC to install the 30-52 brakes on cubs but the stc specifies 1.50 inch axles.

Is this a change that can be done with a simple log book entry? It is a minor change that affects little.
 
I take it they installed a sleeve over the axle to adapt the 1 1/2" wheel to the 1 1/4"? I would get a field approval if that is the case.
 
I hear some D.A R. s may be authorizield to do field approvals?

DARs with Function Code 51 can do Field Approvals within the limitations FAA imposes. We are required to use the AFS300 job aid, and AC43-210A. We are also limited to doing Field Approvals within the FSDO where we are supervised.

DER's with Major Repair and Major Alteration authorization can do Engineering approvals within their specialty, and DERs have no geographic boundaries. DERs are also limited to doing Engineering Approvals identified in the AFS300 job aid, so about the same as a Field Approval, just different paperwork. Most DERs only have one specialty, so for a given approval you may need to use multiple DERs. In my case, I'm limited to vintage aircraft, but can do structures, systems, engines and engine installations.

David Schober
 
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