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Thread: Cleveland wheel Kit STC

  1. #1
    Tom3holer's Avatar
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    Cleveland wheel Kit STC

    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.

  2. #2
    wireweinie's Avatar
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    Are they PMA'd? Check on the parts manual. If Cleveland brakes are listed as an option, just bolt them on.

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    mike mcs repair's Avatar
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    Put them on.


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    hotrod180's Avatar
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    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.
    Cessna Skywagon-- accept no substitute!

  5. #5
    wireweinie's Avatar
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    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.

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    mvivion's Avatar
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    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

  7. #7
    wireweinie's Avatar
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    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?

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    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.

  9. #9
    Tom3holer's Avatar
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    Thank you Hotrod180 that should solve the problem.

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    Quote Originally Posted by wireweinie View Post
    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!

    https://www.airframesalaska.com/Alaskan-Bushwheel-199-62-Wheel-and-Brake-Assembly-p/abi-199-62.htm

    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.
    Cessna Skywagon-- accept no substitute!

  11. #11
    wireweinie's Avatar
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    Original post was concerning an A185F. Cleveland wheels and brakes are listed in the parts manual.

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  12. #12
    Tom3holer's Avatar
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    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.

  13. #13
    Grand Pooh Bah soyAnarchisto's Avatar
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    Cleveland wheel Kit STC

    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?
    Last edited by soyAnarchisto; 06-17-2022 at 10:57 PM.

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    Cleveland wheel Kit STC

    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/excelExte...3-ea7e6dff944a

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  15. #15
    Crash, Jr.'s Avatar
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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.
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    Oh, this is interesting! More, please.

  17. #17
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    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.
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    Quote Originally Posted by Crash, Jr. View Post
    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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    Crash, Jr.'s Avatar
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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.
    Last edited by Crash, Jr.; 06-18-2022 at 02:11 PM.
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    Quote Originally Posted by Crash, Jr. View Post
    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.

  22. #22
    Grand Pooh Bah soyAnarchisto's Avatar
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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?

    Click image for larger version. 

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    Last edited by soyAnarchisto; 06-20-2022 at 11:23 AM. Reason: addin in pic of the STC

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    Quote Originally Posted by soyAnarchisto View Post
    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?

    Click image for larger version. 

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


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    Grand Pooh Bah soyAnarchisto's Avatar
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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.

    Quote Originally Posted by dgapilot View Post
    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.

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    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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  27. #27
    Crash, Jr.'s Avatar
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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.

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    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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    Grand Pooh Bah soyAnarchisto's Avatar
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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/...-62A%20Kit.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.
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    Quote Originally Posted by soyAnarchisto View Post
    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/...-62A%20Kit.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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    I don't know if this will help or not but here is an example. My 180 has a Cleveland kit available, number 199-62. I can put that kit on my airplane using a Cleveland stc (I can't remember if it actually needs an STC but the gist is the same, it's approved on my airplane). The main wheel of that kit is Cleveland part number 40-75d. ABI makes a PMA equivalent under ABI part number 40-75d. I can replace the Cleveland wheel with the ABI PMA part with a logbook entry. Now if you wanted to replace the Cleveland wheel with another part number that was not PMA'd for that Cleveland part number, you would have to get a field approval or an STC.

    Wayne
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    The 62a kit uses a wheel specified by Cleveland to be p/n 40-75aa. I did not see that part on the ABI website but they specifically state that they have a PMA'd 62a kit. I'm going to guess they have a PMA'd 40-75aa wheel, too. If so, again, you can replace with a logbook entry.

    I found it somewhat interesting that the FAA gave the PMA for a wheel with a different material used (aluminum instead of mag). An improvement in my opinion, I just thought you had to essentially copy the part. Guess not.

    Wayne
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    Quote Originally Posted by stoldriver View Post
    The 62a kit uses a wheel specified by Cleveland to be p/n 40-75aa. I did not see that part on the ABI website but they specifically state that they have a PMA'd 62a kit. I'm going to guess they have a PMA'd 40-75aa wheel, too. If so, again, you can replace with a logbook entry.

    I found it somewhat interesting that the FAA gave the PMA for a wheel with a different material used (aluminum instead of mag). An improvement in my opinion, I just thought you had to essentially copy the part. Guess not.

    Wayne
    PMA can be by “identicality” but doesn’t have to be. You can get PMA by showing compliance to a regulation along with form fit and function, or several other ways.


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    mvivion's Avatar
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    It is an incredible indictment of the FAAs certification system that discussions of this type are regularly featured on this forum. I realize certification requires safety of flight assurances, but it certainly seems to this non mechanic that the FAA couldn’t make a mechanics or manufactures job much more difficult if they tried.

    I would like to thank every one of you who puts your signature in maintenance logbooks, and those who are courageous (or crazy) enough to certificate and produce products for light aircraft for your efforts and courage. Please keep up the good work!

    MTV
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    Grand Pooh Bah soyAnarchisto's Avatar
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    Like I said.... an episode of Murder, She Wrote! And now I have a plot twist. Thank you stoldriver for pointing this out to me.

    I did not notice this 40-75aa wheel part requirement, nor did any of the two IAs or the A&P I'm working with. So if one were to file the Parker SA63GL STC for a legal installation of the Cleveland 199-62a kit, is it then legal to do a swap of those mythical 40-75aa wheels with the ABI 40-75T (6 bolt) because they are PMA'd for the 180? I read through the PMA paperwork from ABI last night and I can find no mention of what parts they can replace - other than 40-75T wheels. And if I can replace any old Cleveland wheel that is PMA'd for my airframe, why did I need any STC in the first place? Aren't I back to bolting them up with a log entry from an A&P?

    What is a conscientious aircraft owner to do? It should not be this hard to figure this out. The circular logic is maddening. Ask 10 different pros and you get 10 different opinions.

    I echo MTV's sentiment about you guys in the trenches signing logs and I really appreciate the expertise and commentary. Thanks again for your input. Yet another educational event for me in aviation.

    Quote Originally Posted by dgapilot View Post
    PMA can be by “identicality” but doesn’t have to be. You can get PMA by showing compliance to a regulation along with form fit and function, or several other ways.


    Sent from my iPad using Tapatalk

  36. #36
    Grand Pooh Bah soyAnarchisto's Avatar
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    Okay, I got a return call from Parker technical support. Guy was awesome, even though it took him a week and a half to return my initial call. He confirmed for me 2 things:

    1) Parker does not individually sign or assign their STCs to individual serial numbers. So it is, in fact completely free and open to use. You do not have to, nor can you purchase a specific approval to use the SA63GL which covers both 199-62 and 19962A kits - the entire kit - more on this in a bit

    2) The 199-62A kit does only include the 40-75AA wheel which according to the parker parts catalog a 6-bolt, chrome disc version of the 40-75T. The only difference between the two being the inclusion of 3 bolts on the face for the dust cover. ABI does not appear to make a version that supports the little hub cap dust cover.

    Now re-reading again the PMA paperwork for the ABI-199-62A kit the FAA gave permission to replace the 199-62 kit or the 199-62A with either the ABI-199-62 or the ABI-199-62A as a whole. I think that's how the 40-75AA wheels can be replaced legally by the 40-75T from ABI. For information, the Atlee Dodge STC, SA02231AK has the exact same issue about referencing the Cleveland kit number 199-62 and 199-62A. I don't know why people would buy it, especially if they have the 185F which isn't on it. So save yourself 3 hundo. You cannot mix and match parts from ABI within 199-62, you go all ABW or all Cleveland.

    For reference, here is the PMA paperwork for the ABI kit:
    https://www.airframesalaska.com/v/vs...20No.%2004.pdf

    That's it I'm climbing outta this rabbit hole and not looking back. I hope this information is useful to somebody else down the road.

    Case closed.
    Last edited by soyAnarchisto; 06-23-2022 at 05:28 PM. Reason: added link to pma

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