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Strange local FAA requirement on Tailbeacon ADSB


cliffy

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This is also form the FAA. 
seems if it’s on the STC AML and it is NOT a FAR 1.1 definition of major, it can be a log entry..

“Therefore, an alteration done in accordance with a STC would constitute a major alteration if it "might appreciably affect weight, balance, structural strength, performance, powerplant operation, flight characteristics, or other qualities affecting airwmihiness" or "is not done according to accepted practices or cannot be done by elementary operations." 14 C.F.R. § 1.1. Any such alteration would require the completion of FAA Form 337.”


https://www.faa.gov/about/office_org/headquarters_offices/agc/practice_areas/regulations/interpretations/data/interps/2016/bowers - (2016) legal interpretation.pdf

 

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Classic lack major-minor of clarity, but I do agree the letter from FAA counsel would have more weight then a comment on their home page.  Will save that one in my archives. That said, it’s not too hard to submit the 337 as a belts and suspenders approach.

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General wisdom seems to be that since an STC is a change to the Type Certification a 337 is always required.   The letter is interesting, but I've never heard of it being cited before.   The caveats of "other qualities affecting airworthiness" and "elementary operations" are potential escape routes for the FAA to cause you problems should they decide to, so filing the 337 is the conservative approach when there is a question.   I think that's why it's so overdone.

The tailbeacon does have an STC with an AML, so whether or not a 337 is filed I think if the installation is done according to the STC the local guy would be disagreeing with the folks in OKC, not the owner or the installer.

 

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Upon reading the referenced letter closer, I’m not sure they did much in the way of clarifying things.  In the case of an STC, even this one, I still come to the conclusion that a 337 would be the preferred way.  At work, typically if it changes the approved flight manual, it falls under major.  This would be one of those other qualities.  In this case, the fact that you need to turn on the lights all the time might be that factor.  The Mooney being CAR 3 might leave an opening.  Ultimately, I don’t think a lack of 337 would be a huge issue until an annual in a region where the interpretation is different, in which case that IA can inspect the install an issue a 337.

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10 hours ago, jetdriven said:

The wingtip sky beacon is a minor alteration, thus no 337 form. But the whole premise of leaving  the NAV lights on ( especially while not being placarded) it is pretty stupid. Also a lot of aircraft, when you turn the NAV lights on it dims the landing gear and the clock and the radio lights. Then you can’t see it the gear is down or up because the lights are too dim to see.

And another thing, the wingtip sky beacon strobe light is a joke. It’s not as bright as an iPhone flashlight and the pattern is pretty terrible too. But somehow they conned the FAA into accepting  it as meeting the requirements. 

As far as the strobe light goes - being that our airplanes were designed between 1957 and 1971 the strobe light has to meet FAR 23.1397 and 23.1401 specifying  brightness (at least 100 effective candela), horizontal coverage (360 degrees)and angle above and below vertical axis (30 degrees). After 1971 it jumps to 400 candela and either 30 degrees up to 1977 or 75 degrees after 1977 (dates mm/dd specific). 

The notion of the gear lights dimming with nav lights on can/will be an issue that I had not thought of, nice catch!

In my case, if I decide to keep the airplane beyond 1 or 2 more years I will probably go for the Appareo Stratus as part of a panel  makeover (minor not a flush). For right now however the Skybeacon and its right wing counter part was the most effective way for me to go. Lots less labor (as I do it myself :-) 

And as mentioned, in the installation, the nav light switch HAS to be placarded to be left on from startup to shut down, just like the anti-collision light switch now. Here's where LED nav lights really shine (pun intended!:-). 

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9 hours ago, RLCarter said:

@steingar not sure about others but the GDL-82 has an optional annuciator light should it stop sending all the data required, after 2020 I'm sure ATC will tell you if it isnt working and your in mandated airspace....:D

I was thinking of the thingies that hang off the wingtips or the tail beacon.  How do you now they're working, other than a nastygram from the FAA when they fail?

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There is a small light on each one depicting whether or not it is working although you can not see it inflight in a low wing airplane. It can be a preflight item to check however. But you will find out when ATC says its not working. Again, preflight item if ADSB airspace is contemplated but if it fails inflight no different than any other ADSB. Of course the preflight check has to be outside where the GPS system can be seen by the Skybeacon. Inside a metal hangar probably won't cut it.

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10 hours ago, EricJ said:

General wisdom seems to be that since an STC is a change to the Type Certification a 337 is always required.   The letter is interesting, but I've never heard of it being cited before.   The caveats of "other qualities affecting airworthiness" and "elementary operations" are potential escape routes for the FAA to cause you problems should they decide to, so filing the 337 is the conservative approach when there is a question.   I think that's why it's so overdone.

The tailbeacon does have an STC with an AML, so whether or not a 337 is filed I think if the installation is done according to the STC the local guy would be disagreeing with the folks in OKC, not the owner or the installer.

 

I think it is overdone. At the top of the 337 form, it says for major alterations. Then go read the far part 1 definition of major alteration.  

“14 CFR Part 1.1

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. 

Minor alteration means an alteration other than a major alteration.””

I get the STC changes the type certificate of their plane and it it should be documented, but the installing mechanic decides whether it’s major or minor. Not the person who made the Rosen sunvisors. To install the ADSB wingtip Beacon you fit the unit in place of the removed NAV light assembly. You not change any holes or even hardware.

Anyway that letter from their regional Counsel explains it just the same

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6 hours ago, MB65E said:

Run the wire and be done.  Make the guy happy and don’t call him again. 

I have yet to see the need to turn off ADSB. 

-Matt

If you do that it won't be in compliance with the STC and won't qualify as "properly altered" according to the STC or FARs.   The guy put himself between a rock and a hard spot.

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If I were to run a wire, I would consider running it to the switched power out of the transponder that brings up the encoder (in other words, to the encoder power) such that the ADS-B is always on when the transponder is on.....or simply give it a dedicated breaker on the avionics bus.  Paperwork wise, I would note this as a minor alteration to the STC within the 337.  

Oh, came across this today, just to add to the list of documents that make this not so clear.

https://www.faa.gov/nextgen/equipadsb/installation/media/ADS-B_Out-In_Installation_Tech_Paper(9-25-17).pdf

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To me this is very simple, does the STC paperwork say "FAA approved?"

If it does, your local FAA guy has no say in the matter. His fight is with the higher-ups. In the meantime, I would install it and turn it on as the STC says.

When I was going through upgrade training at my current job, I found a couple of things that seemed strange and probably not the most safe as far as procedures. I asked the FAA guy directly about it, his response? "What does it say on the bottom of the page?"

 

There is no way you can get violated in this.

 

All that being said, It definitely makes sense to have it active anytime the Avionics Master is on.

 

 

Sent from my Pixel 2 XL using Tapatalk

 

 

 

 

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Rule 1 is never ask the FAA a question if you can’t stand to hear the answer. ;)

A big problem with the FAA is the autonomy granted to the regions in setting local policy. The STC was clearly intended for major changes. The first sentence on the second page of the legal interpretation emphasizes that. As such it makes sense that a 337 is required when implementing an STC. 

The problem is that some regions required STCs for simple things- like Rosen sun visors. Other regions allowed such things to be done by simpler means like PMA. Now the FAA has a problem because of these inconsistencies. I’m sure headquarters isn’t all that interested in issuing an opinion that says all those FAA Approved STCs are wrong. Though the opinion seems to say that an STC that doesn’t meet the definition of a major alteration does not require a 337, I think the safest course is file a 337 if an STC is involved. No one will ever question it. As Don Maxwell once told me, “It’s just a piece of paper.”

To be clear, I agree with Byron and the interpretation letter — it’s the FAA’s misapplication of the STC for minor alterations that has caused any confusion that exists  Nonetheless, many IAs and local FAA inspectors will insist on 337s.

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  • 3 months later...
On 9/17/2019 at 11:48 AM, Immelman said:

I have the wingtip skybeacon.... and that is exactly what the install manual says to do. So we wired it up like the manual said and put the placard on like the manual said.

Why on earth should the local FAA guy be getting involved if there is an STC etc and approved install manuals that cover this???

Where did you get the placard? Did you just make one? I'm about to install the Uavionix TailBeacon on the Grumman.

 

Thanks in advance.

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2 hours ago, docjeffry said:

Where did you get the placard? Did you just make one? I'm about to install the Uavionix TailBeacon on the Grumman.

 

Thanks in advance.

The placard was included with my TailBeacon.  Have you opened the box??

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17 minutes ago, Immelman said:

I put a skybeacon on my wingtip in early 2019.

I dont think it came with a placard. We used a label maker...

Interesting.  I bought mine at the beginning of December through Aircraft Spruce.  And, not that it should matter, mine is a TailBeacon not a SkyBeacon.

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On 9/17/2019 at 12:32 PM, cliffy said:

I know of one owner who wants to put a Tailbeacon on his Cherokee (pt 91) but the local FAA guy is insisting on running a wire from the radio master switch to activate it saying that he fears the pilot will not remember to turn on the nav lights (the STC approved way) and activate the ADSB every flight. 

It’s actually contrary to my reading of the tail beacon installation manual as you’d then have no method of shutting your nav lights off as a unit.  It would also be contrary to the airworthiness limitations section of the STC.  
 

if uavionix was smart they’d run a separate set of lead for the adsb power that could run off the transponder circuit breaker should the installer choose to do so (but still be able to use an alternate nav light power source).  
 

Tell your buddy to have his IA install, submit a 337 and not talk to the FSDO anymore.  Ie pretend like he never talked to the FSDO in the first place.  He would be acting entirely within the Regs.  
 

https://www.faa.gov/nextgen/equipadsb/installation/media/ADS-B_Out-In_Installation_Tech_Paper(9-25-17).pdf  

 

^^^ you cant just do a minor mod log entry and call it a day for ADSB according to this. 

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