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Cleveland wheel Kit STC

Tom3holer

Registered User
Cape Cod
As I had posted on another thread I just bought the Airframe Alaska wheel/brake kit for my A185F as it said it was approved for that model.
The issue is it does not come with an STC I just discovered. So how does one install these legally. I do have a very good rapport with my IA.
 
Are they PMA'd? Check on the parts manual. If Cleveland brakes are listed as an option, just bolt them on.

Web
 
I have a copy of the Cleveland STC # SA63GL for the 199-62 wheel & brake kit.
It is not marked as being applicable to my specific airplane.
Good for 180 - 180J, also 185 - 185F.
Also have the two installation drawings referenced on the STC.
I can scan them & email to you if it would help.
It does state "Cleveland Wheel and Brake Conversion Kit P/N 199-62" though,
so dunno if it would technically be applicable to the ABI kit, or the 199-62A kit.
 
Check the book for your specific serial number aircraft. Cleveland wheel/brakes are listed there. That makes them PMA'd. If your serial number falls in that run, any Cleveland part numbers are just bolt on items. No STC needed. The parts book becomes your 'documentation'.

If you need a parts manual, download one or ask here for it.

Web
 
I ordered wheels and brakes from Airframes. They don’t own the STC for my plane. They’d told me they were approved. I called and a couple days later, I had an STC from Atlee Dodge, no additional charge.

MTV
 
Please explain the STC. Cleveland wheels and brakes are already in the parts manual for a C-185F. Match the part numbers and bolt them on. Why would an STC be required for parts already in a manufacturer's parts manual?

Web
 
I think he wants 8:50 tires. Most just put them on too, but I think the Clevelands are only good through 8:00 tires.
I am not sure, but if I were going to do this I would check with Grove.

I admit to a lot of 180 time on 8:50s without any specific approval. I plead "statute of limitations." Airplane works fine; no brake disc problems on paved runways.
 
Check the book for your specific serial number aircraft. Cleveland wheel/brakes are listed there. That makes them PMA'd. If your serial number falls in that run, any Cleveland part numbers are just bolt on items. No STC needed. The parts book becomes your 'documentation'. If you need a parts manual, download one or ask here for it. Web

"Check the book" -- what book, the Cessna IPC?
My hard copy is at the airport, but I just checked my digital version of the 1953-62 C180/182 IPC
and see no mention of Cleveland wheels & brakes.
Yet the Airframes website sez

3-bolt, 1 1/2" axle, aluminum direct replacement for the Cleveland 199-62 wheel and brake kit.

Kit comes with (2) ABI 40-75D 6" wheel assemblies and (2) ABI 30-52N brake assemblies (including bearings, races, bolts, etc).

The ABI-199-62 wheel and brake kit is approved for:
- Cessna series 180, 185, and 206
-And now approved on A185-E, and A185-F models!

[FONT=Verdana,Arial,Tahoma,Calibri,Geneva,sans-serif]https://www.airframesalaska.com/Alaskan-Bushwheel-199-62-Wheel-and-Brake-Assembly-p/abi-199-62.htm[/FONT]

In my case, I already have a Cleveland 199-62 brake kit on my airplane,
installed per their STC, so if I replaced it with an ABI kit it would be legal.
But starting from scratch (aka a Macauley set-up)? Maybe not so much.
 
Thank you all again for the advice. The issue is that yes the Cleveland wheels are approved for my serial number under their STC but I want to install the Airframes wheels.
My IA says he feels comfortable doing it with the Cleveland STC I have on hand.
 
Working these old planes sometimes makes me feel like I'm in a Murder, She Wrote detective episode...

So my '55 180 has at some point had the original (goodyear/cessna/mccauley? 0541103-52) wheel and brake assembly replaced with a single puck Cleveland wheel and brake setup. I am going through the logs and paperwork and cannot find any STC or 337 entries for that change. Fast forward to now, I had a failed brake line and decided to upgrade to double pucks from ABW the ABI-199-62A. I purchased a caliper set from a 3rd party (new never installed) and bought a brand new set of 6-bolt ABW 6" wheels, and fabbed up new hard lines and aeroquip 303 hoses. Great, right? Now sorting out the paperwork - since I can't seem to figure out whether or not the cleveland wheels and brakes are listed in the parts manual, do I need an STC to install the replace (and legalize) the previously installed single puck clevelands with the double pucks?

I thought this would be a simple log entry that any A&P could do. Not so?
 
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The ABI 199-62A kit is PMAd for 180, 185 and others. If it is like other ABI PMAs, it doesn’t specify PMA for xxx airplane when modified per STC xxx, so it should be bolt on and log book entry. It isn’t your fault if ABI or FAA screwed up the paperwork. If you really want to cover yourself, get a Field Approval, but it really doesn’t need it.

https://drs.faa.gov/browse/excelExternalWindow/87b1c1be-433e-43ff-a1d3-ea7e6dff944a

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Just to clarify a PMA is much like a TSO but directed towards specific aircraft models or toward an STC instead of being a blanket aircraft parts standard like TSO is. What a PMA is not is an installation approval by itself based on "approved models". That approved model list is simply a list of aircraft that are eligible either under separate STC (Piper, Cessna), inclusion of parts on the TCDS (Aviat), or optional equipment drawings added to an aircraft manufacturers drawing set for a specific plane (Maule, American Champion).

If the aircraft you're installing the ABI wheels and brakes on has wheels and brakes of the exact same part number listed in the parts manual or TCDS then you're good to go, that is your installation approval. If they do not however, like the A185F, then you will need an STC. The A185F does list Cleveland wheels and brakes however it's 40-75B and 30-52 not 40-75D and 30-52N part number ABI wheels. This is a pretty pedantic difference but by strict legal definition they are different models of wheel and brake. For most Cessna aircraft Atlee Dodge STC SA02231AK is needed and is sold for the 199-62/62A kits. For Piper aircraft using the 199-71 kit, SA11RM from Univair is sold to cover J3's through PA-18's. Other manufacturers like Maule and American Champion have been able to add approved drawings to allow for upgraded wheels and brakes to be installed by referencing the drawing number as an approval for installation.

Unfortunately the Atlee Dodge STC excludes the A185E and A185F so that is problematic for that specific aircraft if the owner wants to use ABI wheels and brakes. Cleveland holds the STC (SA63GL) for their wheel and brake kits (but doesn't sell it separately) which is why the FAA hasn't granted an STC to ABI for PMA'd copies of the same kits.

Hopefully that clears things up but bear in mind that depending on how open minded a mechanic is there may be some wiggle room in there but these are just strict legal definitions of how a PMA approval works in terms of installation approvals. I'm also just a parts salesman so I'm sure Steve Pierce can jump in here to clean up any points where I'm off in my legal understanding.
 
Pma is just a legal copy of a part and can substitute that part. You can't (stc) a pma of a part if someone already owns said stc for that specific model. Unfortunately you must have permission from the stc holder and they probably aren't interested in supporting competitors. Of course legal bureaucracy could at any point change to suit the needs of the faa. Currently though the legal definition would require the Cleveland stc or any holder of that specific cleveland conversion stc.
 
Just to clarify a PMA is much like a TSO but directed towards specific aircraft models or toward an STC instead of being a blanket aircraft parts standard like TSO is. What a PMA is not is an installation approval by itself based on "approved models". That approved model list is simply a list of aircraft that are eligible either under separate STC (Piper, Cessna), inclusion of parts on the TCDS (Aviat), or optional equipment drawings added to an aircraft manufacturers drawing set for a specific plane (Maule, American Champion).

If the aircraft you're installing the ABI wheels and brakes on has wheels and brakes of the exact same part number listed in the parts manual or TCDS then you're good to go, that is your installation approval. If they do not however, like the A185F, then you will need an STC. The A185F does list Cleveland wheels and brakes however it's 40-75B and 30-52 not 40-75D and 30-52N part number ABI wheels. This is a pretty pedantic difference but by strict legal definition they are different models of wheel and brake. For most Cessna aircraft Atlee Dodge STC SA02231AK is needed and is sold for the 199-62/62A kits. For Piper aircraft using the 199-71 kit, SA11RM from Univair is sold to cover J3's through PA-18's. Other manufacturers like Maule and American Champion have been able to add approved drawings to allow for upgraded wheels and brakes to be installed by referencing the drawing number as an approval for installation.

Unfortunately the Atlee Dodge STC excludes the A185E and A185F so that is problematic for that specific aircraft if the owner wants to use ABI wheels and brakes. Cleveland holds the STC (SA63GL) for their wheel and brake kits (but doesn't sell it separately) which is why the FAA hasn't granted an STC to ABI for PMA'd copies of the same kits.

Hopefully that clears things up but bear in mind that depending on how open minded a mechanic is there may be some wiggle room in there but these are just strict legal definitions of how a PMA approval works in terms of installation approvals. I'm also just a parts salesman so I'm sure Steve Pierce can jump in here to clean up any points where I'm off in my legal understanding.

I disagree. PMA is a design, production and installation approval. Please see FAA Order 8110.42D paragraph 2-8 (f). It states that if the article the applicant is seeking PMA on is a major change in type design, then FAA is to direct the applicant to the STC process. If the article were considered a major change in type design, then the PMA would specify that STC. In this case it does not, so no STC is required. Next step would be to determine if it is a major alteration or minor alteration. For this, you use the definition in 14 CFR 1.1, 14 CFR 43 Appendix A and the flow chart in AC43.210 A. The flow chart actually includes the 1.1 definition as well as the 21.93 definition, so if we walk through that flow chart, we know it is an alteration, since FAA didn’t require an STC as part of the PMA, we haven’t crossed the threshold of major change in type design, it isn’t in the type specifications, it doesn’t change and W&B limitations, it doesn’t change performance, it doesn’t change engine operation, it doesn’t change flight characteristics, and it doesn’t impact “other factors affecting airworthiness, so the flow chart gives us Minor Alteration. A review of Appendix A section 1 for airframe alterations one could make an argument for a change to the landing gear and to the hydraulic system, but I disagree, the gear is still the same, simply substituting wheels and brakes that have already been shown to meet the regulatory requirements based on the weight of the aircraft. Same with the hydraulic system. The basic system design is still the same, master cylinders actuating wheel cylinders. All in all, when you do the review above, it drives you to a minor alteration.

The big difference between TSO and PMA is that PMA is an installation approval. TSO is a design specification, TSOA is a design and manufacturing approval, but not an installation approval. PMA is a design, manufacturing and installation approval. That’s what AFS-640 (FAA trading center in Oklahoma City) has been teaching to inspectors and designees for at least a decade


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Try and be clear about what aircraft specific installation you are talking about. I assume you're referring to the A185F example above. The PMA in question covers a lot of aircraft for which the 199-62 and 199-71 wheels and brakes are a major change from what is previously approved for installation. PMA approval will not cover installation of double puck brakes on aircraft previously approved with another type of brake (Mccauley) or single piston brakes or even drum brakes like on the Piper models. Those would be a major change not a minor one.
 
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Try and be clear about what aircraft specific installation you are talking about. I assume you're referring to the A185F example above. The PMA in question covers a lot of aircraft for which the 199-62 and 199-71 wheels and brakes are a major change from what is previously approved for installation. PMA approval will not cover installation of double puck brakes on aircraft previously approved with another type of brake (Mccauley) or single piston brakes or even drum brakes like on the Piper models. Those would be a major change not a minor one.

If it is a 185F, it isn’t covered by the PMA. That said, it should be easy to get a Field Approval for it based on AC23-27. I’ve done quite a few wheel and brake Field Approvals just in the last couple months.


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I just applied for a field approval - Cleveland wheels and brakes presumably PMA for the PA-18, but found on a J5, complete with a 337 signed in 1996, hinting that the PA-18 approval was "approved data" for the J5.

I would be happy to consider it a minor alteration - but my FSDO approves these sorts of things as field approvals.

That's why I am following this interesting discussion.
 
For the 180, there's no need for a field approval. There is a STC. My question is do I need that to be filed, or is this a minor alteration that any A&P can do with a log entry?

And I'm confused about whether I need to buy the Atlee Dodge STC through ABI as other folks have told me that the STC is not specific to any serial number aircraft and I can use SA63GL with the free downloaded STC doc - see below. Do I need to purchase the $300 SA02231AK STC from ABI?

stc_clevelandDoublePuck_SA63GL.png
 

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For the 180, there's no need for a field approval. There is a STC. My question is do I need that to be filed, or is this a minor alteration that any A&P can do with a log entry?

And I'm confused about whether I need to buy the Atlee Dodge STC through ABI as other folks have told me that the STC is not specific to any serial number aircraft and I can use SA63GL with the free downloaded STC doc - see below. Do I need to purchase the $300 SA02231AK STC from ABI?

View attachment 61484

If it is an STC, by definition it is a Major Alteration and requires a 337.


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So there are 2 STCs, SA02231AK and SA63GL. Incidentally, SA63GL appears to cover model 185F. It also appears to be limited to 8.00 tires - of course I have 8.50s installed with the Atlee Dodge approval letter.

Can I use the (free?) SA63GL STC above? If I need to purchase SA63GL to get one for my specific serial number, who do I buy it from?

Or do I just buy it the SA02231AK STC from ABI/Atlee Dodge?

rhetorical question - why is this stuff so hard to figure out? Everybody has double puck clevelands on their 180s it seems.

If it is an STC, by definition it is a Major Alteration and requires a 337.


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I think the answer is you must have permission of the owner to use an STC. Sometimes the owner will say “use my products and you may use the STC.” See the Stitts or Cooper manuals.

But if you don’t have that in writing, you must purchase the paperwork. Think of it as a patent of unlimited duration.
 
You need written permission of the STC owner to use an STC on a specific aircraft. I may be wrong, but I think Cleveland will only give permission if you buy the wheels and brakes from them.


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The above are correct. Cleveland sends out a permission letter with the STC if you buy the boxed wheel and brake kit from them. Without the permission letter it's not of much use.

The A185F is excluded from the Atlee STC so that won't do you much good. PM me and I may be able to help.
 
Sounds like the Field Approval route will be your answer. Some FSDOs will still do them. They just removed the geographic restrictions from DARs, so you can work with a DAR or a DER to get the approval. Unlike the FAA, designees charge for their service.


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So, It's now clear to me that not all STC's are created and used in the exact same way. Yes, you must have permission (letter of authorization), but some of the STCs grant that permission through a generic letter that you can use with the purchase of a kit - which after talking to a local IA had no problem filing the STC with only the STC documentation provided by Parker Hanneflin here:

https://www.parker.com/parkerimages... Brake Division/Kit Documents/199-62A Kit.pdf

Basically the LOA says if you purchase the kit (199-62A) then you have approval to install it and file a 337. I didn't have to purchase the STC directly - just as though you can buy the 199-62A through Aircraft Spruce. Just for good measure, I called the Parker technical support hotline to ask if I needed to, or what the process was to purchase the permission letter signed specific to my aircraft. They never called me back.

Here is exactly what the LOA in the STC says:

NO OTHER APPROVALS NECESSARY AUTHORIZATION TO INSTALL:
With the sale of this STC KIT, OWNER of the Supplemental Type Certificate agrees to permit the buyer or buyer’s agent or agency to use the certificate to alter the product under the terms and conditions of this STC.

So there are IAs that can interject their own interpretation here. Just goes to show you need to shop around to find an IA that understand this. But it seems that anyone can buy a 199-62A kit, new or used, from Parker or ABI since it's a PMA'd replacement for the Parker kit - it's exactly the same. So basically the STC is free to use if you've purchased the kit - which you will have done if it's in your possession. Someone can try and tell you that you need a signed letter from Parker - but they don't give you that - they give you this blank, generic LOA. This is all you should need.

This should work, even for the 185F. This has been a discussion point for a long time on the forums. SA63GL is basically free seems to be the consensus. It really shouldn't be this hard, or this confusing. Anyway, this is what I just did - and I know others have done.
 
So, It's now clear to me that not all STC's are created and used in the exact same way. Yes, you must have permission (letter of authorization), but some of the STCs grant that permission through a generic letter that you can use with the purchase of a kit - which after talking to a local IA had no problem filing the STC with only the STC documentation provided by Parker Hanneflin here:

https://www.parker.com/parkerimages... Brake Division/Kit Documents/199-62A Kit.pdf

Basically the LOA says if you purchase the kit (199-62A) then you have approval to install it and file a 337. I didn't have to purchase the STC directly - just as though you can buy the 199-62A through Aircraft Spruce. Just for good measure, I called the Parker technical support hotline to ask if I needed to, or what the process was to purchase the permission letter signed specific to my aircraft. They never called me back.

Here is exactly what the LOA in the STC says:



So there are IAs that can interject their own interpretation here. Just goes to show you need to shop around to find an IA that understand this. But it seems that anyone can buy a 199-62A kit, new or used, from Parker or ABI since it's a PMA'd replacement for the Parker kit - it's exactly the same. So basically the STC is free to use if you've purchased the kit - which you will have done if it's in your possession. Someone can try and tell you that you need a signed letter from Parker - but they don't give you that - they give you this blank, generic LOA. This is all you should need.

This should work, even for the 185F. This has been a discussion point for a long time on the forums. SA63GL is basically free seems to be the consensus. It really shouldn't be this hard, or this confusing. Anyway, this is what I just did - and I know others have done.

Not exactly correct. The ABI kit is a PMA group of parts. The Parker kit is a TSO group of parts. The requirement to provide written authorization is found in 14CFR 21.120. It doesn’t specify how that permission is to be given. Some STC holders just give a blanket permission authorization. Others choose to give permission to a specific serial number airplane.


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