337/STC

[1473C]

I think there may be more going on internally within the FAA concerning both Change 16 and the STC process than meets the eye. When 10/1/03 ( Change 16 date ) rolled around I was in the middle of an STC process for the 170B. The STC involved substitution of a PMA part, not approved for the airplane, for the approved part which has a history of failure. My STC plan was accepted previous to 10/ 01. During November the FAA informed me that they had changed their minds and would not issue an STC because they considered the change to be minor and therefore not eligible for an STC. I argued that if I had signed off the change myself as a minor, when I was substituting a non-approved part for an approved part, the enforcement side of the same FAA would not buy my argument. I argued that 21.93 clearly states that any change that effects strength and reliability is major. They would not buy my argument at the ACO. The FSDO told me that they would not issue a 337 for the change since they considered it to be major. Backed into a corner, I called the the ACO supervisory office in Kansas City and the Change 16 supervisor in Washington D.C. . Both offices said that the ACO was incorrect and must consider an STC. The ACO then informed me that my project would be held up until they were able to have regional meetings concerning FAA policy on 337's and STC's. Last week I was told by the ACO that my STC would be granted. Sorry for the length of this, but the point is the FAA wants to curtail both 337's and STC's.

 

[Steve Pierce]

You are still dealing with individuals. I have been very lucky and nothing has changed as far as Field Approvals. Everything they do to improve the system seems to muddy the waters in my opinion.