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Thread: Field Approvals - is there an appeals process?

  1. #1

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    Field Approvals - is there an appeals process?

    I am about to have two field approval requests turned down. One of them is dirt-simple; I found a Piper PA-18 kit for Clevelands on a J-5 (they have been there for over a third of a century, with a 337 approved by an IA).
    The inspector is saying I have not fully described the installation. He has indicated that I may have to get an STC.

    The other request is more complicated, so I can understand his reticence - it is a hydraulic disc brake conversion for a CAR4a aircraft. It is almost identical to two other field approvals I hold for Aeronca conversions, and I used pretty much the same wording, only with a lot more drawings and TSO wheels and brakes. As far as I can tell, CAR4a aircraft only need brakes if they are transports!

    I believe this is the same ASI who was going to violate me for installing non-TSO Com radios. I got the distinct feeling that he still wants my IA, and is looking for an excuse.

    I am going to ask him for a formal rejection letter. Once he does that, am I dead in the water, or is there a process to get a second opinion?

    These are not my aircraft - I shouldn't care whether the owners ever get approved. I just thought it best that their aircraft be legal and safe. All of my Cubs have field-approved discs and reservoir masters, so I am personally ok.

    I should note that I hold well over a dozen field approvals, including disc brake conversions as well as engine and fuel systems alterations. I am stumped with this really easy attempt.

  2. #2
    RaisedByWolves's Avatar
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    I was told if you get the denial letter you can go to any fsdo you want. My fsdo refused to give me a denial letter.


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    They are pretty much required to give you a very specific denial letter. They often just delay forever.
    Some of my field approvals have taken a very long time to do, and others were instantaneous. There is no correlation with difficulty. It has more to do with the ASI.

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    cubdrvr's Avatar
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    Come to South Dakota...............ask JB.
    "Sometimes a Cigar is just a Cigar"

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    AC43-210A is the guide for Field Approvals. The hardest thing is developing a Compliance Checklist. You need to research the applicable regulations, then describe how your project will comply with those regulations. The other document to know inside out is the AFS-300 job aid. That is what helps identify what needs to go STC and what can be a Field Approval.

    The big issue is that many FSDOs don’t have Inspectors that are qualified to issue Field Approvals.


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    Steve Pierce's Avatar
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    Pretty well spelled out here. https://www.faa.gov/documentlibrary/...r/ac_23-27.pdf Google AC 23-27 if my link doesn't work. The existing STC on the PA18 is pretty well spelled out and the drawing that Cleveland provides should make it a slam dunk.

    I got aggravated with a PMI who told me he would approve a deviation to an STC and then after the work was done he said he couldn't approve it. I went to the head of the FSDO and tried reasoning with him. After getting no where I told him it was pretty chickenshit cause all the data was there. Basically I was installing a C85 in place of an A65 via an STC except I didn't want the gross weight increase to keep the aircraft LSA. Was told the FSDO couldn't approve it cause it needed a flight manual supplement. Called the ACO and they said no problem, sent me an AC on making out a flight manual supplement but told me I had to submit it through the FSDO. They were pissed that I went to the ACO and didn't like when I told them I tried going through them but they didn't volunteer the information. Got it done but took quite a bit of time and getting a little aggressive with those in charge. Therefore when someone asks me if I have a good relationship with my FSDO I tell them they know my name.
    Steve Pierce

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    mvivion's Avatar
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    Bob,

    All I can say is good luck. There seems to be nobody in the FAA, right up to the Administrator, who will overturn ANYthing another FAA employee has disapproved. Witness the Biplanes Inc decision. Been there with a field approval, inspector screwed up, but it still took all kinds of crap to get it done, including ANOTHER field approval.

    MTV

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    Steve Pierce's Avatar
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    Quote Originally Posted by mvivion View Post
    Witness the Biplanes Inc decision.
    What is this?
    Steve Pierce

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    I am familiar with 23-27. I just discovered that my offer to bring drawings in was not forwarded to the ASI. That may be part of the problem. The other part of the problem is that I drew an ASI who has about zero respect for me (or maybe anybody else). His boss thinks I am a good guy, so all is not lost yet. Maybe I will post an excerpt.

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    Gordon Misch's Avatar
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    I thought DERs could do field approvals. Maybe I was wrong?
    Gordon

    N4328M KTDO

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    They can. You pay them and they produce approved data. Or you get an ASI to do them free. I prefer the latter.

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    mvivion's Avatar
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    Quote Originally Posted by Steve Pierce View Post
    What is this?
    Part of the warbirds decision, that required flight instructors to be “qualified” to instruct in Experimental aircraft.

    my approval came as a response to an email to an FAA person in Florida (poor bugger). No qualifications, no experience, just send an email. And the Administrator at OSH last year said, this pisses him off worse than it did us. Really? I’d have sent the FAA lawyer who came out with that to Attu.

    MTV

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    DERs cannot do field approvals. They can only approve engineering data within their delegated functions. The data can be used to support a field approval.
    DARs with the proper delegation can, ASI can, DERs cannot.
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    Quote Originally Posted by rck View Post
    DERs cannot do field approvals. They can only approve engineering data within their delegated functions. The data can be used to support a field approval.
    DARs with the proper delegation can, ASI can, DERs cannot.
    A DER with Major Repair and Major Alteration authorization can approve data within their specialty for use in Major Repairs and Major Alterations. You need to read the 8110-3 carefully as there will be a statement on the form indicating that the approval is for everything required or is NOT for everything. If the firm indicates it covers everything, no further approval is required and cite the 8110-3 and reports or drawings on block 8 of the 337 and you are good to go.

    If the 8110-3 indicates it doesn’t provide all the necessary data, then you need to find another DER with the required specialty, or go to the FSDO inspector or a DAR for a block 3 field approval for the missing data.

    The hardest part of any approval is building your compliance checklist, figuring all the applicable regulations you need to show compliance to determines the type of DER or DERs that you need. In any case, DERs and DARs are restricted to approving only the things in the AFS-300 job aid. The job aid helps to keep you from broaching the Major Change in Type Design” threshold of 21.93 that forces you to go STC.


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    Quote Originally Posted by dgapilot View Post
    A DER with Major Repair and Major Alteration authorization can approve data within their specialty for use in Major Repairs and Major Alterations. You need to read the 8110-3 carefully as there will be a statement on the form indicating that the approval is for everything required or is NOT for everything. If the firm indicates it covers everything, no further approval is required and cite the 8110-3 and reports or drawings on block 8 of the 337 and you are good to go.

    If the 8110-3 indicates it doesn’t provide all the necessary data, then you need to find another DER with the required specialty, or go to the FSDO inspector or a DAR for a block 3 field approval for the missing data.

    The hardest part of any approval is building your compliance checklist, figuring all the applicable regulations you need to show compliance to determines the type of DER or DERs that you need. In any case, DERs and DARs are restricted to approving only the things in the AFS-300 job aid. The job aid helps to keep you from broaching the Major Change in Type Design” threshold of 21.93 that forces you to go STC.


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    Correct, but the DER cannot sign the 337 "approving" the field approval. That is clearly defined in Order 8110.37F. You may have ALL the approved data you need, but a DER cannot sign an FAA Form 337. You are correct...the AFS-300 job aid is very helpful for an applicant if they choose to follow it.

  16. #16
    cubdrvr's Avatar
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    Remember when there were 2 skinny handwritten logbooks in a manila envelope? And AD's were one page long?
    We're fortunate to have a very accommodating FSDO.........one that stayed open, or accessible, the past couple years.
    Before the maintenance chief in RAP retired he did 7 cub FA's for me......the last one I submitted involved mounting JATO bottles on my cub struts ( and yeah, that one didn't fly)
    "Sometimes a Cigar is just a Cigar"
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  17. #17

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    Quote Originally Posted by rck View Post
    Correct, but the DER cannot sign the 337 "approving" the field approval. That is clearly defined in Order 8110.37F. You may have ALL the approved data you need, but a DER cannot sign an FAA Form 337. You are correct...the AFS-300 job aid is very helpful for an applicant if they choose to follow it.
    No, a DER can not sign a 337, but if the 337 cites all the required approved data (the DER 8110-3 that says it covers ALL the requirements) then the IA can sign block 7 with no additional approval required.


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    BC12D-4-85's Avatar
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    Recently a DER with the proper authorization and FAA agreement issued a deviation to a STC I have already installed and he owns. Gross weight was increased 40# on conventional gear. I received paperwork confirming and updating the TCDS, required placards, and an authorization for my S/N Taylorcraft. My IA will submit a 337 citing that deviation paperwork and give me a copy for my records.

    Gary
    Last edited by BC12D-4-85; 07-20-2022 at 12:43 PM. Reason: SP

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    The way I see it, "thou shalt not deviate." So you install the approved whatever exactly as shown on the 337, sign the logbook, and then after that you follow the rules - minor alterations are still legal, and if you have approved data you can do a major alteration, just like with the original type certificate.

    I think my ASI is softening a bit. He explained what he wanted for the Cleveland wheels, and I provided it. We shall see. I may have to print out all 38 pages of the Parker manual in duplicate. I can do that.

  20. #20

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    Quote Originally Posted by bob turner View Post
    The way I see it, "thou shalt not deviate." So you install the approved whatever exactly as shown on the 337, sign the logbook, and then after that you follow the rules - minor alterations are still legal, and if you have approved data you can do a major alteration, just like with the original type certificate.

    I think my ASI is softening a bit. He explained what he wanted for the Cleveland wheels, and I provided it. We shall see. I may have to print out all 38 pages of the Parker manual in duplicate. I can do that.
    Bob, I’ve done a number of approvals for Cleveland wheels and brakes on lots of airplanes, Cubs, multiple Wacos and several others. So long as you can show the wheels and brakes were certified on an airplane equal or greater weight and landing speed and the wheel tire combination provides the required prop clearance that satisfies about 90% of what’s needed. If you need to fabricate something for the torque plate, that may prove a little more challenging. Now the other item necessary is the ICAs. For that Cleveland provides a Technicians Guide and that satisfies the ICA.


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  21. #21

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    I have done only one Cleveland field approval - 310 wheels and brakes on the UPF-7. I have done two Aeroncas with Grove parts, three Grove master cylinder alterations, three fuel tank installations, one door latch (had to modify the rib) a C-90-12 on a Cub, two approvals for PA-11 wing components on a J3. Oh, and I am embarrassed to say, one field approval for pop rivets in a PA-18 wing. Yuk!

    I thought, with that track record, I sort of knew what I was doing. Nope. Let me find an excerpt.

    Yeah, here:

    Do you realize that I do not have to do any field approvals that don’t have data that I’m satisfied with? I’m not about to waste any more time with you on this if all you want to do is argue and try to sell the virtues of the alteration
    .

    maybe I am too argumentative, but I try to be polite about it. He may have softened up after this post -we'll see.
    Last edited by bob turner; 07-20-2022 at 07:38 PM.
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    RaisedByWolves's Avatar
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    It’s the new faa world order. They don’t do anything except try and violate people.
    I had previously approved friend approvals and got the run around for over a year. Back and forth with more and more and more data and my pmi told me I don’t understand why you need a ski field approval, it’s spring time. I said great give me a formal denial letter and we will go on our ways. Oh I don’t have to do that, said your technical orders say otherwise. He wouldn’t give me the denial.
    I was doing a pre buy for a guy when I got that news, I called the faa every sorry name in the book, turns out he works for another fsdo. He asked to see my paperwork and I showed him. He said holy cow I’ve never seen this much supporting data. Why didn’t it get approved? Who is your pmi? Ohhhhhh that guy, he’s still a giant a hole huh? He was a prick 20 years ago. Turns out he field approved a cargo hook on a heli that had an inadvertent release and hurt some people, which it was an install error, didn’t follow the field approval. This guy said I get to my desk on Tuesday will that be soon enough to sign them off? Turns out shortly after the local FSDO’s orders got changed, he called me pissed off saying they took away there field approval authority and ferry permit authority.

    It sure would be nice if the faa doesn’t want to do there job, for liability or whatever, if they would put it on the IA’s. Give us the ability to decide if we have enough data to feel comfortable field approving something. I mean we are the guys working everyday in the field.


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  23. #23
    skywagon8a's Avatar
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    Quote Originally Posted by bob turner View Post
    Do you realize that I do not have to do any field approvals that don’t have data that I’m satisfied with?
    This part has always been true.
    N1PA

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    Quote Originally Posted by RaisedByWolves View Post
    It’s the new faa world order. They don’t do anything except try and violate people.
    I had previously approved friend approvals and got the run around for over a year. Back and forth with more and more and more data and my pmi told me I don’t understand why you need a ski field approval, it’s spring time. I said great give me a formal denial letter and we will go on our ways. Oh I don’t have to do that, said your technical orders say otherwise. He wouldn’t give me the denial.
    I was doing a pre buy for a guy when I got that news, I called the faa every sorry name in the book, turns out he works for another fsdo. He asked to see my paperwork and I showed him. He said holy cow I’ve never seen this much supporting data. Why didn’t it get approved? Who is your pmi? Ohhhhhh that guy, he’s still a giant a hole huh? He was a prick 20 years ago. Turns out he field approved a cargo hook on a heli that had an inadvertent release and hurt some people, which it was an install error, didn’t follow the field approval. This guy said I get to my desk on Tuesday will that be soon enough to sign them off? Turns out shortly after the local FSDO’s orders got changed, he called me pissed off saying they took away there field approval authority and ferry permit authority.

    It sure would be nice if the faa doesn’t want to do there job, for liability or whatever, if they would put it on the IA’s. Give us the ability to decide if we have enough data to feel comfortable field approving something. I mean we are the guys working everyday in the field.


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    In some ways I agree with you, but in recent years I’ve seen IAs that can’t even make a log book entry much less determine if they have sufficient data. You would be surprised at the blank stares I get if I ask if they have a compliance check list! Sometimes I get “what’s that” other times I get “it’s too much work”. In any case, that should ALWAYS be your starting point for any alteration. Unless you know what regulations you need to show compliance to, you have no idea how to design the alteration and what data may be required.


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    I got the “Declination” letter yesterday. I always thought declination was something used in celestial navigation. Main reason - cannot simultaneously submit two requests. Secondary reason - wheels and brakes require an STC.
    Letter encouraged me to seek an STC.

    They almost immediately backed off the STC part, but stated that even with the 37 page Parker installation manual they were unable to determine that Clevelands would work on a J 5.
    I will apparently need to submit drawings for the J5 gear leg,along with the PA-18 leg. If anybody has a scannable version of either it would be appreciated. I think both are identical to the J3 leg, but not sure for the J5.
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    Who ever you were talking to at FAA doesn’t even know their own policy. Item E1 in the AFS-300 job aid clearly says it would be EVL or evaluation. I’ve done lots of DER approvals for different wheels and brakes and gotten lots of field approvals as well. If you want to send me your 337, it is likely I can do a FA for you since I no longer have geographic restrictions.


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    Exactly what I need!

    Thanks Dave - they were looking at transports (STC) and then helicopters (ENG). I suggested item E1 and they said ok. Still not happy with my data - but they won't be able to argue that form/fit has not been supplied when I show them the J3/J5 gear leg. They were really unhappy when I stated installation is identical without proving it with Piper data.
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  29. #29
    Steve Pierce's Avatar
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    AC23-27 has a whole section on wheels and brakes. I would have fun getting this one approved. All the data is there and they can't say no.
    Steve Pierce

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  30. #30
    hotrod180's Avatar
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    Quote Originally Posted by bob turner View Post
    .....I am going to ask him for a formal rejection letter. Once he does that, am I dead in the water, or is there a process to get a second opinion?
    ....
    If this inspector just keeps putting you off, but puts nothing on paper,
    I think you would be free to seek approval from another inspector or another FSDO.
    I would think you don't want a letter in your airplane's file that documents that you were turned down.
    Cessna Skywagon-- accept no substitute!

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    I don't think such correspondence goes in the aircraft permanent records. It is just part of a formal process, and apparently they have to give you a "reasonable time" to fix your submission.

    So I am submitting, probably in two weeks, duplicate hard copies of the 337, the 37 page installation manual, and drawings for the J5 and PA-18 gear leg.

    There is conflicting guidance on what to submit when using STC components on "similar" aircraft. One FAA document (AC23-27) says you have to re-submit all the supporting documentation originally used to get the STC. That, of course, won't happen - it is proprietary stuff.

    Another document allows "experience" as sufficient - one would think that, in the case of Cleveland wheels having been on the aircraft for a quarter-century, there was enough "experience" to fulfill that requirement.

  32. #32
    algonquin's Avatar
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    Bob I’m fast reaching the point of “ if it makes the aircraft safer” just do it and let the FAA inspector that hasn’t ever looked at anything that wasn’t painted gray with jet engines wonder .
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  33. #33
    RaisedByWolves's Avatar
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    Quote Originally Posted by algonquin View Post
    Bob I’m fast reaching the point of “ if it makes the aircraft safer” just do it and let the FAA inspector that hasn’t ever looked at anything that wasn’t painted gray with jet engines wonder .
    Wasn't on there when the IA annualed it.
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  34. #34
    Steve Pierce's Avatar
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    Quote Originally Posted by algonquin View Post
    Bob I’m fast reaching the point of “ if it makes the aircraft safer” just do it and let the FAA inspector that hasn’t ever looked at anything that wasn’t painted gray with jet engines wonder .
    Not me cause then they hang me out to dry. Read the regs and make them do their job.
    Steve Pierce

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    These are not my aircraft, and I do not make a living doing this. I am trying to bring one into compliance (I usually get rapid help with that sort of effort) and give the other owner paperwork in case he stops cheaping out and wants decent brakes.

    The latest update - the inspector says I don't even mention wheels or brakes in block 8. Of course the first sentence says "Found Cleveland wheels and brakes, parts # . . .).

    He also says the 37 page Cleveland installation manual doesn't have enough information in it. It has the PA-18 gear leg, detailed info on how to torque the bolts, where the bolts come from, static and dynamic limits on all components except AN hardware, and even insists that it is a good idea to use new cotter pins.

    More next week.

  36. #36
    skywagon8a's Avatar
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    Bob, you need to become best friends with that inspector's boss. Things get done then, sometimes not to that inspectors advantage. I can tell stories about this.
    N1PA

  37. #37
    Steve Pierce's Avatar
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    Have you read AC23-27?
    Steve Pierce

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    Yes, Steve - many times. Word for word after your last post. I am ready with excerpts.

    In fact, maybe I will post the excerpts - they come from about four sources. The feds are changing them all the time, and even change the Order number to screw me up, but I study this stuff.

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    Excerpts from 23-27 and related FAA guidance:

    AC 23-27

    Section 1.a. says “. . . You may use the data in this AC as approved data for substantiating parts . . . substitutions . . .”

    Section 4 says “This AC intends to . . . expedite the field approval process . . .”

    Section 5: “Examples of substituted parts include . . . wheels and brakes.”

    Section 5.e. discusses current industry standards, of which the TSO is surely a candidate.

    Section 5.f. discusses the need for data if the part might affect safety if it failed. It would seem that the TSO addresses that data.

    Section 7.c.(3) suggests that if one can establish that the part is at least equal in performance and safety to the part it replaces, then substitution is possible.

    Section 8.c. defines a standard part as one manufactured in complete compliance with acceptable standards for such parts.

    Section 8.e. says that a field approval is the standard way of authorizing installation, and:

    Section 9.d.(3) states that a PMA is not required for a TSO part.

    ---------------------------------
    Excerpts from Order 8900.1 Vol 4 Chapter 9

    4-1185
    A. Major Alterations. The list in Figure 4-68, Eligibility Considerations For Field Approval, describes methods of approval for typical major alterations. This list is not all-inclusive; examine each project on a case-by-case basis. If an alteration is not on the list, it may be eligible for a field approval; however, each alteration must be evaluated on a case-by-case basis. Items not listed should be treated as Evaluation (designated by the letters “EVL”). Alterations on transport category aircraft with 30 or more passenger seats or operating under part 121 should be considered Engineering (designated by the letters “ENG”) and must be coordinated with the RO.


    4-1191 References
    · AC 23-27, Parts and Materials Substitution for Vintage Aircraft.
    4-1192 Procedures
    4) Denial of Proposed Alteration/Repair Approval. If the applicant is unwilling or unable to comply with the requirements to obtain the requested field approval, terminate the process by notification in writing to the applicant. This notification should include the reason for denial. The applicant should be given the opportunity to make necessary corrections within a reasonable amount of time from receipt of notification.

    AC 43-210

    This is a straightforward AC that first denies that it is regulatory in nature, and then flat out states that if the words “shall” and/or “will” appear in an instruction, they reflect a regulatory requirement. Then, in § 102(b)(2) it says an ASI will provide a written response with reasons for denial, if a field approval request is to be denied. It gives only four reasons for denial (section c).

    CAR4a

    is the controlling document for all Piper Cubs prior to the PA-18. Requirements are “simply” codified, and currently available on-line.

    Notably, landing gear is covered on pp 21, 26, and 27. A detailed structural discussion is held in part 4a.477, where it says wheels have to be “certified” in accordance with part 15. Part 15 is on page 1- a single paragraph covering the certification of an entire aircraft.

    Brakes are interesting – they are required on transport aircraft (4a.483-T). Tailwheels are even more interesting – “may be any type or model, and are not certificated.” And yet, folks are still getting field approvals for tailwheels?

    Now to Order 8300.16 CH 1

    I think this replaces the earlier guidance cited above from 8900.1. Not sure . . .

    This is from Chapter 4 – really difficult to follow paragraph numbering, but try
    4-2.e(4):

    Typically, data that meets a more stringent airworthiness standard when applied to an alteration requiring a less stringent airworthiness standard is normally acceptable

    That little excerpt would seem to indicate, for instance, that a Cleveland wheel and brake assembly that meets certification requirements of CAR 3 would be more than sufficient for the less stringent CAR 4a. See Type Certificate 1A2 for approved Cleveland wheels and brakes on a CAR 3 Cub-type aircraft.

    8-5.b - Analysis as Part of a Data Package. In many cases, the analysis may have been accomplished as part of a data package for an STC or other approval that is being used as the basis for an alteration. In these cases, it is not necessary that it be done again provided it is appropriate to the alteration in question. Like the entire field approval process, the goal is to ensure operational safety and aircraft airworthiness

    From the Appendix:

    Substantiating Data. Technical data used to show that an article complies with the applicable airworthiness standards. Compliance may be shown by tests, analysis, experience, and/or computations appropriate to the maintenance, alteration, or continue-in-service condition of the article being evaluated. Substantiating data shown to comply with the applicable airworthiness standards is acceptable to the Administrator. This is because it establishes that the article meets the regulatory requirements and would be returned to its original or properly altered condition by use of this data.

    [emphasis mine - bob]

  40. #40
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    They tend to start paying attention when you start quoting stuff like this cause you prove you know more about the subject than they do and they need to do their homework.
    Steve Pierce

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