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!
- and b. Equipment must be TSO
- Installer must have a “statement of compliance”
- Installer and owner must have a document from the STC holder identifying the aircraft receiving the installation.
- Must hook it up correctly
- Must hook it up and program it correctly (6 categories).
- All must be in accordance with 14 CFR sect. 43
- Must verify operation – flight or ramp test.
- 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.