Trade offs between an F and J model

[mooniac15u]

2 hours ago, Shadrach said:

Everyone is reluctant because it does not fit the definition of a major alteration (major mod is your term, let’s stick to the FAA’s verbiage). Seat rails are not a structural component of the airframe and that is what is meant by “structural”. By your definition drilling any hole would require a 337 because there is no such thing as a hole that does not affect the structure of the object being drilled. The question revolves around whether the object being drilled is structural to the airframe. The answer in the case of seat rails is no. Your CG argument doesn’t hold water either. Neither the CG range nor the max gross weight of the aircraft is being altered.  Extending the seat’s CG station aft slightly while keeping it within the factory specified CG range does not constitute a major alteration.  It does not affect weight, balance, structural strength, performance, powerplant operation, flight characteristics, or other qualities affecting airworthiness.

It appears as though you’re trying to make this into something that it’s not. I would never try and get in between a man and his desire to generate paperwork. Knock yourself out when it comes to your own aircraft.  I am genuinely confused by your determination to inflate such a minor change made on someone else’s airplane into a Major Alteration. I’m not saying you wouldn’t be able to find a FSDO to except it as such, but there are still quite a few commonsense folks at the FAA that would tell you that this does not meet the definition of a Major Alteration. 

Tell this guy:

Do you think he ran off and hired a DER without the FSDO telling him he had to?

[Paul_Havelka]

38 minutes ago, Marauder said:

I’ll add a little commentary about this topic. When I was based further north, my IA approached the local FSDO about adding a sub panel in my plane on the pilot’s side of the panel. The FSDO said nothing was needed other than a log book entry that it was installed.

Fast forward 19 years. I am now located further south and am in the middle of an avionics upgrade. The local FSDO happened to be in the avionics shop reviewing their certification. They see the sub panel and tell the shop it is strictly forbidden. They required the sub panel to be removed. Fortunately I was making space in the panel with the upgrade and was able to move things up and eliminate the sub panel.

So, even the “authorities” don’t agree on these topics. I suspect that is one of the reasons the FAA is trying to consolidate these functions into a central function.


Sent from my iPad using Tapatalk Pro

Fortunate for you that you were planning for this anyway.  Is it not possible when getting clarification (like from the original FSDO) to get something in writing from them that you could reference in the logbook entry?

"Avionics sub-panel installed on pilot side.  Only logbook entry needed as per FSDO.  Reference correspondence dated ??/??/??"

Sorry if this is a newb question but I am a newb so cut me some slack..lol

[Shadrach]

50 minutes ago, Igor_U said:

yeah, seen this before

Is it only me finding this ironic? Quite a few posters are claiming it is minor alteration while supporting documents is filed as Major?

It's not ironic but more par for the course. The term "courtesy 337" is a term I've actually heard repair station DOMs use in the GovCon world.  Those guys file 337s if they remove carpeting from the passenger compartment or an ashtray from a seat.  There was a great HID landing light deal from Xevision years ago. While they made OEM landing lights for Diamond Aircraft, they did not go through the STC  process for other makes.  We did a group buy on the Mooney list.  You could make an argument either way about that alteration as you are adding a high voltage ballast to the electrical system that was previously not present.  On the other hand the current draw of new ballast was far less than the previous incandescent.  All of the buyers traded paperwork. The inconsistency from FSDO to FSDO across the country was worse then you could imagine.  337s were rejected as unnecessary, 337's were rejected as not comprehensive enough, 337's were rejected as not being worded to the FSDO's liking.  It was a complete $hitshow that was only visible because we were all on the Mooney mailing list.  FSDOs can and do interpret the rules incorrectly at times. It's my opinion that as more and more unnecessary 337's are filed the more the perceived authority over minor alterations expands.  The definition as of today found in 14 1.1  spells it out quite clearly:   

Major alteration means an alteration not listed in the aircraft, aircraft engine, or propeller specifications—

(1) That might appreciably affect weight, balance, structural strength, performance, powerplant operation, flight characteristics, or other qualities affecting airworthiness; or

(2) That is not done according to accepted practices or cannot be done by elementary operations.

So for the first part of the definition which of the following is appreciably affected by drilling the additional hole and placing the seat in a locked position slightly aft of previous most aft position.

Weight? - no

Balance? - no 

Structural strength? - no

powerplant operation?- no

Flight characteristics?- no

Other qualities affecting airworthiness?- no

For the second part of the definition it is important to point out that this part of the definition has ZERO to do with with the object being modified and everything to do with practices.  Drilling a hole in a seat rail is easily accomplished using methods/practices acceptable to the administrator.

Finding someone that has interpreted the rules beyond what is stated above is no great hardship.  There are a few in this thread.  However, it's not doing us any favors when dealing with a new FSDO employee that's never turned a civilian wrench. 

As an aside, The coolest thing about that paper work was being reminded of the late Yuri Avrutin (RIP).  I never met him in person, but he was quite a character in the Mooney community. 

[Shadrach]

1 hour ago, mooniac15u said:

Tell this guy:

Do you think he ran off and hired a DER without the FSDO telling him he had to?

As I stated above, I go by the FAA's definitions.  I didn't realize we were now defining FARs by the actions of individual bureaucrats (see my last post).  If we are going to go down that road, then we should not bother with concise FARs.   IIRC you're a lawyer by profession and that may be affecting how you are viewing this. The FARs are not common law.  FSDOs do not set "FAR precedents".  If they did, we'd have a smörgåsbord of conflicting precedents to choose from.

Also the second post clearly states that this can be had as a factory option. If that is indeed the case (and I don't know that it is), it should definitely not require a DER's blessing.  

The 3rd post by Knute simply confirms what I would already suspect about any FSDO in NORCAL (I lived in the Bay Area for many years).  In a state that needs to placard everything to the point of making placards nearly meaningless, I can't say I'm shocked to learn that the FSDO felt the need to turn a simple mod into an over-papered CF.

Edited April 19, 2019 by Shadrach

[Shadrach]

2 hours ago, Creekrat said:

Fortunate for you that you were planning for this anyway.  Is it not possible when getting clarification (like from the original FSDO) to get something in writing from them that you could reference in the logbook entry?

"Avionics sub-panel installed on pilot side.  Only logbook entry needed as per FSDO.  Reference correspondence dated ??/??/??"

Sorry if this is a newb question but I am a newb so cut me some slack..lol

Depends on the FSDO. There is a program called the Consistency & Standardization Initiative.  It was put in place for exactly the reasons that I have outlined in previous posts.  If at anytime you receive conflicting determination from a FSDO you may inform them that you would like to initiate the CSI process.  Whether or not it's a good idea to start that pissing contest is another matter.

Edited April 19, 2019 by Shadrach

[Andy95W]

5 hours ago, Igor_U said:

yeah, seen this before

Is it only me finding this ironic? Quite a few posters are claiming it is minor alteration while supporting documents is filed as Major?

Not really ironic, truthfully it shows how much has actually changed (for the better!) at the FAA since the year 2000.

Back then, most FSDOs required a field approval for a new instrument panel in a standard 'T' configuration. Now everyone agrees it's a minor alteration. Most IAs still thought a new COM radio required a 337.  NORSEE was the start of lots of changes, primarily with shoulder harnesses and AOA.   Now we're seeing the benefits from Garmin, TruTrak, etc. 

[Igor_U]

 

8 minutes ago, Andy95W said:

Not really ironic, truthfully it shows how much has actually changed (for the better!) at the FAA since the year 2000.

 

True,

I had a go through all that song and dance with my IA back then when installing 201 aft-side windows on my FI believe he had to rewrite the 337. Few weeks ago I've completed RHS panel upgrade (with GTX335 etc..) and there were no questions asked. And yet, I'm afraid we might see a change from FAA due to "Max factor"... I hope not. 

[skykrawler]

I can't tell you I read all 10 pages of these comments....but one of the things that led me to select my 81 J model was the reduced noise.  This airplane has the double thickness window on the door (exhaust side) and a more substantial insulation for sound deadening.  I read about this incremental change in a couple of places.   I rode in E and F models and other people who have as well tell me this J is a lot quieter inside.   Even with ANR engine noise in the E & J is quite loud.  This was also a complaint I had with DA-40....and the DA-40 vents were loud as hell.  The newer Diamonds must be better.

[EricJ]

8 hours ago, Igor_U said:

yeah, seen this before

Is it only me finding this ironic? Quite a few posters are claiming it is minor alteration while supporting documents is filed as Major?

That was probably one of the easier $500 jobs that DER ever did, and also some easy money for the IA to file the 337.   Don't expect people to turn your money away because you've asked them to do something that isn't necessary.   Filing a 337 doesn't make it necessary, and it doesn't make it a major alteration.

Ima get my IA and retire on unnecessary 337s.