Missing 337’s for old avionics

[SSimpson77]

Greetings Mooneyspacers, I’m a new member who is going through my first purchase of a 1965 M20C. Low time pilot (81 hrs-no retract) looking to build hours commute for work at same time. Pre-buy, inspection, and annual is done with the owner fixing some squawks and minor items my A&P/IA found. 
Plane is in great condition albeit only about 70 hours in last 5 years. Thats some of the squawks I am getting taken care of. (Hoses, tires, 91.411&91.413).

My question is this- the plane has an SL60 installed and I did not see a 337 filed when I had the records pulled up by Oklahoma. The log book states it was done in the late 90’s, but the only record that came up was installation of the sig-400 around that time.  Additionally the KT-76a 337 wasn’t in there, but plane has it. Does the FAA sometime lose these records? I would think getting them signed off would be fairly easy but I do plan on changing the transponder within the next few months anyways. 
 

sorry for long post- again new pilot/blogger/low time texter/ but love this forum and the ideas and bantering that goes on it!

Steven

[carusoam]

Welcome aboard Steven,

Update your avatar data when able...

include a pic of your new ship.

There is a recent thread around here regarding the FAA and their ability to keep records...

Best regards,

-a-

[Andy95W]

Welcome, Simpson.

I have never heard of the FAA losing 337s in modern times.  Not saying it isn't possible, but definitely not likely.

There are really only 2 reasons why the 337 isn't there- it either didn't need one, or the installer didn't submit it.

If the SL60 was installed as a VFR GPS, it was a minor alteration and technically doesn't require a 337.  Most installers will often still submit one (myself included) because it creates an additional means of documenting the installation.  Your KT-76 transponder installation, likewise, was a minor alteration and doesn't require a 337.

For your SL60 GPS to be used IFR, that does require a 337 because it requires a change to the Aircraft Flight Manual, which is a major alteration.  Those actually have to be signed off as a Field Approval by the FAA.  What happened a lot back in the 1990's was that GPS units were installed IAW an IFR installation, and the owner was supposed to return to the shop at a later date to conduct the test flight required to complete the IFR paperwork- but the owner forgot or sold the airplane.  Therefore, your installation is legal, but not for use IFR for enroute, terminal, or approaches.

[PT20J]

Hi Steven,

Congratulations for being so thorough. There are two copies of the 337s. One goes to the FAA and one is given to the owner. I suppose the one mailed to the FAA could get lost in the mail, but if the FAA doesn’t have it and it’s not in the seller’s possession, then it probably never got filed. It’s not a big deal unless you have a real nit picky IA (no one has ever checked for old 337s on my planes) so long as the W&B was updated. But, if you are concerned you could make the seller bring the paperwork up to date as a condition of sale. 

The low use would be more of a concern if the engine was not pickled due to possible rust in the cylinders and camshaft/lifters especially if it lived in a high humidity area.

Skip

[SSimpson77]

Thank you for your input. 
Have to figure how to downsize the mp on the pics to upload them.

I had the engine borescoped and looked great. No rust or pitting in cylinders or anywhere on the motor for that matter. I was extremely concerned with that being a first time buyer and not wanting to have any major downtime for first few years of ownership. (Gotta build those hours to get the insurance down). It lived in Las Cruces NM, and mid-Ohio for its whole life. 
Had SB208B also completed and no corrosion and looked immaculate. 
Im sure I will find some things along the way, but the bones are great, no damage history or major airframe alterations done. 
Wish it had some Waas GPS, but with the advancement of technology, I think some great stuff is coming down the road. 
 

I will check this week if GPS was ever approved for IFR. Unfortunately that unit has zero database updates avail anymore so only using it for the vfr/gps and comm side. 

 

 

[Yetti]

Do you have an equipment list?   Was the equipment list updated?   W&B records should also reflect the change.   Since the spar was not cut many times a 337 is needed.

[EricJ]

2 minutes ago, SSimpson77 said:

Weight and balance was updated, and equipment list according to books updated.

I’m  not sure what you mean by “spar hasn’t been cut many times” 

I am just a bit concerned that if a IA did require the paperwork at sometime, I didn’t want to deal with that. It’s just a weird deal, do I make the owner get it re-filed. (Is that even possible with an out of database/non-supported gps) Is it non compliant to use even as a comm radio and vfr/gps? Seems like everything in a certified a/c needs approval somewhere. 

337s are only required for major alterations or repairs.   The list of things that qualify as "major" alterations or repairs appears in the FARs, Part 43 Appendix A.   As has been previously pointed out, neither of those installations are major alterations or repairs, especially if the GPS is (since it now can only be) used for VFR only.    Your transponder needs an alt and potentially IFR cert every two years, and if that's been done or is still current you should be golden.

During the first annual inspection on my airplane after I purchased it my IA found a bunch of missing STCs and 337s...e.g., a Hartzell Top Prop had been installed after a prop strike and the shop never filed the paperwork.   My IA just filed everything for me, it was not a big deal.

 

[PT20J]

Call Greg Baker @Baker Avionics. He’s on the field in Grants Pass and will tell you what you need. 541-205-9141.

Skip

[skykrawler]

Technically the 337 has to be done within a brief amount of time after the installation.  Also, I don't know how an IA would sign a 337 for something he didn't install - after all he is signing the installation was done in compliance with many standards.  For example, how can he vouch for the correctness of the crimps in a connector?  I don't have a dog in the fight - but the whole 337 thing has a lot of mystery.

[SSimpson77]

Does anyone else read there post and have an ‘I just answered my own question’ moment! Luckily I didn’t post, you guys already answered it.

After reading your guys responses I’m sure it’s legal, not for IFR but why make owner re-file it if it can’t be updated to use for IFR anyways. 
All log books reflect the correct W&B since alterations. 
 

I will post pictures once test flight done and keys are in my hands. Don’t want to make it sound like it’s mine just yet. 
 

I will be back soon  asking everyone for “how to” by end of week I’m sure! 
 

eric, sorry I was typing this and just saw your post! 
 

the other day I woke in a panic mode and thought to myself “I forgot to check which prop and hub it had!” Literally went through books at 3am and so relieved to find it was the b type hub, and I had checked that three times already. 

Edited March 17, 2020 by SSimpson77

[SSimpson77]

Thank you PT20J, they are good people there. I’ll give them a cal

[EricJ]

25 minutes ago, skykrawler said:

Technically the 337 has to be done within a brief amount of time after the installation.  Also, I don't know how an IA would sign a 337 for something he didn't install - after all he is signing the installation was done in compliance with many standards.  For example, how can he vouch for the correctness of the crimps in a connector?  I don't have a dog in the fight - but the whole 337 thing has a lot of mystery.

337s have two main signature spots, one for the person doing the work, and the other for the IA approving the work.   It's very common that the IA doesn't do the installation or the work, just approves that the installation is airworthy.   The form is constructed specifically for this process.

 

[PT20J]

Every time Form 337 comes up on MS, ... oh, never mind

https://www.faa.gov/documentlibrary/media/advisory_circular/ac_43.9-1f.pdf

Skip

[Yetti]

1 hour ago, PT20J said:

Every time Form 337 comes up on MS, ... oh, never mind

https://www.faa.gov/documentlibrary/media/advisory_circular/ac_43.9-1f.pdf

Skip

And then someone chimes in that ACs are not regulatory and then we have a TSO discussion.

[PT20J]

9 minutes ago, Yetti said:

And then someone chimes in that ACs are not regulatory and then we have a TSO discussion.

Yep,

https://www.faa.gov/documentLibrary/media/Advisory_Circular/AC_21-46A.pdf

[Flybeech21]

AC's are not regulatory.  But, not adhering to them is evidence proving careless or reckless operation.

[skykrawler]

I sense exasperation.....the AC says:

FAA Form 337 will be executed in duplicate with one signed copy given to the aircraft owner and one copy forwarded to the FAA within 48 hours

In my records is a 337 was submitted for the Bracket air filter installation saying 'installed previously by unknown...'    I suppose this is one way apply such attribute.  (arse covering).

When it comes to annual inspections we are at the mercy of the IA.   I am very diplomatic with mine.   It's all the FAA's fault

[EricJ]

14 minutes ago, skykrawler said:

In my records is a 337 was submitted for the Bracket air filter installation saying 'installed previously by unknown...'    I suppose this is one way apply such attribute.  (arse covering).

Same here.   The Brackett filter was one of the missing STC/337s on my airplane as well.   Here's what my IA put on the 337 he filed for my airplane:

"The following items were found during Annual Inspection with no 337 Forms in the aircraft records:  1) Brackett BA-6210 air filter, 2) Hartzell model HC-C2YR-1BFP/F797 propeller with spinner.  I have inspected these installations and find that they conform with their installation Instructions and their STCs.

The approval data used for these items is STC #SA71GL for the Brackett Air Filter and STC number SA02414CH-D for the Hartzell propeller."

That pretty much covers everything needed to my knowledge.

[Yetti]

I did help my IA with a situation.   He believed a new ELT would need a 337.   With a little prompting.   He looked it up.  

Edited March 18, 2020 by Yetti