Speaking of that, does anyone recall the STC # and holder for that mod? There are probably more than one.
OK. I'll be the one.
Just why would you need an STC to move the oil cooler? The basic design has not been changed. Still two hoses connected to an air cooled, oil filled, radiator. No valves or other similar components added into the system. What makes this project rise to the level of a major modification? Read FAR 43, appendix A.
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My IA told me the same thing AFTER i had purchased the STC.. he looked at me like I was stupid and said why?? In his opinion, it is not required either.I guess I'm in all sorts of trouble now, lol, cause I'm not seeing it and I'm not changing my ways.
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I am not a big fan of a rear oil cooler. Makes it a pain in the ass to work on that mag and robs air from #4 cylinder. My plane came with it so I kept it, but would not change unless I had a good reason. DENNY
STC?
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Install a flat baffle tight against the back of the cylinder extending high with a bent forward lip. This will funnel cool air into the cylinder and also allow cool air to pass over the top into the oil cooler. I also tilted the top of the oil cooler back for an even flow through the cooler.I moved mine back during my engine overhaul. If I hadn’t have sold the old cooler hoses and brackets I’d move it back to the front. I had nice and even CHT spreads. Not anymore.
Would not the fact that the original Harrison cooler is listed as “required equipment” on the Type Certificate require an STC?
All true, but how do you sign off that the cooling in the new location will be as good as the original location? How do you document that part of the "minor" alteration?Same style of cooler, just new location.
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Same style of cooler, just new location.
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What do you say about this DGA?
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Well your Honor
When I move the cooler to the rear baffle, I consider it a minor mod as the oil cooler still works by ram air moving through an oil filled radiator. And with this installation no new/different parts were introduced into the oil cooling circuit, so the oil cooling circuit of the engine has not been altered. Also, as the baffling is not a structural item, fitting the oil cooler to it still does not rise to the level of a major structural modification.
If I'm to be executed for this, I request a firing squad, at dawn, and I want a good Dominican cigar.
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If I'm to be executed for this, I request a firing squad, at dawn, and I want a good Dominican cigar.
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I didn't say you were wrong. Just provided the data necessary to make a decision. I think way to many alterations are considered Major and with the proper thought process and decision making would actually be Minor. I recall a time when FAA said ALL radio installations needed to be Field Approvals with no justification as to why and everyone just went along. We now have the tools to help make decisions and support those decisions. I really hate it when A&Ps always run to the FSDO and ask if a given alteration is a major or minor. That is one of the primary functions an A&P should be doing without any need to go to FAA.
I agree totally with using the discretion given to determine the repair status of an alteration and readily apply it.
In the example discussed thou, please guide us with the proper language to use in the records, giving us the authority to remove or change a “required equipment item” (item 109, TCDS 1A2) having such an explicit description; part number and installation drawings.
Not trying to argue but seeking knowledge. I am not confident that I can make a good case in front of the FAA.
If it wasn’t on the TCDS it would be a different ball game.