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Thread: ADS-B paperwork?

  1. #1

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    ADS-B paperwork?

    A buddy came to my hangar with a 337 asking my advice.

    He said:

    1. Installing the GDL-82 is a minor alteration. Garmin has an STC for a Mooney.

    2. The FAA has said that a 337 must be filed with an ADS-B installation.

    I was unable to advise him - I have yet to do such an installation. My initial impression was - if it is major, you need approved data for a Cub, not a Mooney, and murtherfore, if it really is a minor alteration, you should not file a 337.

    Enlighten us?

  2. #2
    Eddie Foy's Avatar
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    Didn't do a 337 when I installed my Garmin GTX 335 with integral WAAS GPS and ADS-B out. It was a transponder swap.
    "Put out my hand and touched the face of God!"

  3. #3

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    Read Part 43 Appendix A. Also when you swap a new 91.413 check is required to be recorded.

  4. #4
    algonquin's Avatar
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    I'm not telling anyone else what to do , I myself file a 337, log entry and in this case have the TXP checked and a logbook entry for that. Also include a statement of the flt check in the log book entry. I believe this will get to be a can of worms with many different approaches to it, but if one were to get into a jam over its use in the field and the FAA investigates and no IA signature or 337 it will get much more complicated and expensive than just getting it signed off to start with.my 2C only.
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  5. #5
    skywagon8a's Avatar
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    TECHNICAL PAPERAFS-360-2017-1(Rev 0, 09/25/2017)INSTALLATION OF ADS-B OUT EQUIPMENT

    https://www.faa.gov/nextgen/equipads...r(9-25-17).pdf
    N1PA

  6. #6
    Eddie Foy's Avatar
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    I was mistaken. Upon further examination, My IA did file a 337 for the transponder.

    Quote Originally Posted by Eddie Foy View Post
    Didn't do a 337 when I installed my Garmin GTX 335 with integral WAAS GPS and ADS-B out. It was a transponder swap.
    "Put out my hand and touched the face of God!"

  7. #7
    Steve Pierce's Avatar
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    I believe Pete posted the document I read and have used. They want a 337 filed with the settings used for the install and if you don't have the test equipment and use a flight test to verify another 337 when it passes.
    Steve Pierce

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  8. #8
    Eddie Foy's Avatar
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    The red tape is staggering. The reasonable man would think that passing the flight test for the rebate would be enough.

    Quote Originally Posted by Steve Pierce View Post
    I believe Pete posted the document I read and have used. They want a 337 filed with the settings used for the install and if you don't have the test equipment and use a flight test to verify another 337 when it passes.
    "Put out my hand and touched the face of God!"

  9. #9
    skywagon8a's Avatar
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    Quote Originally Posted by Eddie Foy View Post
    The red tape is staggering. The reasonable man would think that passing the flight test for the rebate would be enough.
    You're catching on Eddie. When you spend a lifetime in the cockpits of military or airline planes, you don't get exposed to the inner workings of the FAA as much as you think that you have been. This is part of the reason that those of us who are retired from those professions as well as those positions which are outside the cockpit welcome the E-AB no electric route. We finally have the opportunity to raise our middle finger in the direction of the FAA without repercussions.
    N1PA
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  10. #10
    Eddie Foy's Avatar
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    Does anyone even review 337s that are sent in or do they just file them? I use my middle finger with alot of Feds.

    I filed the performance report in the log showing a pass with the original 337. That's all they get from me.


    Quote Originally Posted by skywagon8a View Post
    You're catching on Eddie. When you spend a lifetime in the cockpits of military or airline planes, you don't get exposed to the inner workings of the FAA as much as you think that you have been. This is part of the reason that those of us who are retired from those professions as well as those positions which are outside the cockpit welcome the E-AB no electric route. We finally have the opportunity to raise our middle finger in the direction of the FAA without repercussions.
    "Put out my hand and touched the face of God!"

  11. #11
    skywagon8a's Avatar
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    Quote Originally Posted by Eddie Foy View Post
    Does anyone even review 337s that are sent in or do they just file them? I use my middle finger with a lot of Feds.
    In the old days when they were sent to the FSDO, your PMI reviewed them before sending them to OK city. If they didn't like them, they had 30 days to get back to you for corrections. Now? I suspect that they are just filed.

  12. #12
    Steve Pierce's Avatar
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    Another document to help confuse.
    Attached Files Attached Files
    Steve Pierce

    Everybody is ignorant, only on different subjects.
    Will Rogers

  13. #13

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    Steve - thanks. I just read all of that.
    It says: once a system is approved by STC on one aircraft, it becomes an approved minor alteration on another.
    A 337 is required.
    Then it gives a logbook and AFM entry.

    I suppose we just follow it to the letter - but I have for years thought that one could not use a 337 for a minor alteration.

    So now this single form is used for:
    1. Major repair
    2. Major alteration using approved data
    3. Major alteration using STC
    4. Major alteration via field approval
    5. Minor alteration when adding ADS-B, assuming it was STC'd on a different manufacturer's aircraft.

    They need one of those 350 page ACs to explain all this - and mechanics need a law degree?
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  14. #14

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    Here we go - I was hoping I wouldn't have to do this:


    FAA Memorandum of March 2, 2016

    FAA Policy for installation of ADS-B – 5 pages long. Clear as mud.

    Here is my take: please note that the copy function on my computer screwed up the paragraphs below - they were a,b, and then c thru i. I cannot edit them!


    1. and b. Equipment must be TSO


    1. Installer must have a “statement of compliance”
    2. Installer and owner must have a document from the STC holder identifying the aircraft receiving the installation.
    3. Must hook it up correctly
    4. Must hook it up and program it correctly (6 categories).
    5. All must be in accordance with 14 CFR sect. 43
    6. Must verify operation – flight or ramp test.
    7. Documentation required:


    Must submit a 337. Block 8 must state, along with the obvious make and model information , “ The installed ADS-B OUT system was shown to meet the equipment performance requirements of 14 CFR sect. 91.227”.

    Also note this exact same statement must be in the aircraft permanent records, which I would interpret to mean the airframe logbook. One could say the 337 was part of the permanent record, but why push it?

    The memo answers questions:

    Can an ADS-B system that does not meet requirements be installed? Answer – YES – and it looks like the field approval process is the way to do it.

    Do you need an AFM revision? Again, YES. It does not need FAA approval; you merely add the following statement:

    “The installed ADS-B OUT system has been shown to meet the performance requirements of 14 CFR sect. 91.227.”

    This one is tricky – my avocation is reading law books. This is the best I can get out of this one:

    The holder of the ADS-B Type Certificate can make minor alterations.

    An example: The equipment is STC’d for a Mooney. To put it in a Cub involves a minor alteration to the STC.

    But to do that, the holder of the TC needs to get a “method acceptable to the FAA for approval” before submitting the 337.

    Finally, there is a helpful chart at the bottom – the FAA loves these charts, but as an engineer and attorney, they make my head hurt. Here, again, is my take:

    TSO? Yes. Then is there a “Compliance Statement?” Yes. Then can we avoid major stuff like antennae in pressurized hulls? Yes. Are we going to use the TC holder’s instructions? Yes. Then we can install it. Any deviation from that requires a field approval.

    Summary? A 337 and AFM revision are required. It is a major alteration by definition, but the change from Mooney to Cub is a minor alteration. That minor alteration must be approved by the FAA – presumably the holder of the TC has done that. Probably should enter a statement in the airframe log matching the one on the 337.

  15. #15
    kase's Avatar
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    Quote Originally Posted by Steve Pierce View Post
    I believe Pete posted the document I read and have used. They want a 337 filed with the settings used for the install and if you don't have the test equipment and use a flight test to verify another 337 when it passes.
    I did 2 337s for my install. One for the STC and the other for the flight test. Samples provided by the manufacture. Pretty easy. Took 15 min.
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