Anti-collision and form 337

[rotorman]

When upgrading with a TSO'd anti-collision beacon from the factory one is a form 337 required?

[EricJ]

I don't think it meets the definition of a major alteration or repair, so my opinion would be no 337 is required.    The opinion that matters is your IA, so whatever he says should be your best answer.

 

[A64Pilot]

If it’s an STC, then yes. 

If it’s a replacement beacon going into the same place as the original and performing the same function and doesn’t require any rewiring, then I would consider it a minor modification and just a logbook entry.

If your having to cut holes in the airplane and riveting in doublers  etc, then one could argue that’s a major, I don’t think so, but remember it’s actually up to the installer to determine.

There may be something I’m unaware of of course, like I had a clock I put in my Maule and ot was an STC, or Rosen sun visors that are an STC.

Edited February 5, 2022 by A64Pilot

[carusoam]

Well that just about covers it….

Let’s ask the light supplier… in case there is anything else…

Calling @OSUAV8TER (swapping out anti-collision beacon, major, minor, log entry?)

Best regards,

-a-

[OSUAV8TER]

On 2/5/2022 at 8:43 PM, carusoam said:

Well that just about covers it….

Let’s ask the light supplier… in case there is anything else…

Calling @OSUAV8TER (swapping out anti-collision beacon, major, minor, log entry?)

Best regards,

-a-

I consider it a minor alteration but that decision is left to the installing maintenance professional.

[Marc_B]

One MSC who put in the LEDs on my aircraft said: The Whelen LED lights are TSO’d and do not require a 337 because the aircraft was already equipped with these position lights and no modification was made to the airframe in order to install them.  We verified this with our local FISDO (FAA location) they stated this was correct.

The MSC I have my aircraft at for annual now says I need a 337 completed. 
 

So I guess this is just open for individual IA interpretation?  Hmmm.  

[EricJ]

5 minutes ago, Marc_B said:

So I guess this is just open for individual IA interpretation?  Hmmm.  

Yes, this happens a lot.   This is why I said earlier that the only opinion that matters is your IA's, since he signs your annual every year as airworthy.   OSUAV8TER is correct that the installer initially determines if it is major or minor, but it also has to pass through the IA gate at annual.

IMHO it does not fit the definition (FAR 43.1) or description (FAR 43 Appendix A) of a major alteration according to the regs, but I'm not installing it or signing your logbook.   Even if it is an STC it doesn't necessarily need a 337 if it is a minor alteration according to FAA legal.   Your previous MSC was also correct that substituting like TSO for like TSO has been described as suitable by the FAA in AC 20-41A.   They don't even have to be the same TSO, just "functionally similar".

So there's plenty of basis for not calling it a major, but the bottom line is that if the installer and/or your IA think it is a major, then it is a major.

[A64Pilot]

1 hour ago, Marc_B said:

 

 

So I guess this is just open for individual IA interpretation?  Hmmm.  

That is actually what the FAR says, actually I believe it says something along the lines of the person doing the install is responsible to determine if it’s a major or not.

Many trip to well I can’t get into trouble if I always go conservative and fill out a 337, and some I suspect charge for the 337 of course.

Some things are clear cut, a supplement to the type certificate is unquestionably a major, but that’s been abused in my opinion, like Rosen deciding their sun visors are a major alteration and getting an STC. The clock in my Maule was an STC. Hard to see the logic.

This may help

https://www.aopa.org/news-and-media/all-news/2014/october/08/aircraft-maintenance-major-vs-minor-alterations

Edited February 9, 2022 by A64Pilot

[N201MKTurbo]

So, what’s the big deal with filling out a 337? They aren’t hard to fill out. The FAA doesn’t scrutinize them anymore. Your IA gets brownie points for submitting them. What is everybody afraid of?

[EricJ]

Misguided people keep saying, erroneously, that an STC always requires a 337, but it does not according to FAA legal.   The Bowers letter by Lorelei Peter, Assistant Chief Counsel of Regulations, addressed this specific topic and basically said if it isn't a major alteration it doesn't need a 337.   e.g., there is an STC for certain sun visors, but it would be difficult to argue that they meet the definition of a major alteration, and sun visors aren't specified in the TCDS.   According to the Bowers letter those could be installed without a 337, as could any STC that is not a major alteration.

I do agree, though, that a 337 isn't that big of a deal and it does provide a permanent record of an installation since a copy goes in the aircraft file at the FAA.   This is particularly useful if the alteration has ICA or other guidance that would be helpful or required for for future owners, especially in the event of lost logs or allowed deletion of records past one year old.   For a beacon or similar lighting, though, I'm not sure it provides much value if it is obvious that it's installed and the manufacturer and part number are plainly evident.

It still boils down to what the installer and/or IA think, though.   Other opinions won't matter.

Edited February 9, 2022 by EricJ

[Mooney Dog]

26 minutes ago, N201MKTurbo said:

What is everybody afraid of?

I dont think its fear more than its the "oh boy one more thing to file" 

[N201MKTurbo]

3 hours ago, Mooney Dog said:

I dont think its fear more than its the "oh boy one more thing to file" 

But it isn’t much harder than posting on this forum.

[carusoam]

4 minutes ago, N201MKTurbo said:

But it isn’t much harder than posting on this forum.

As long as it doesn’t require pictures…. 
 

Posting pics around here seems to be a bit extra challenging… some days.

-a-

[A64Pilot]

You may have some letter saying that an STC isn’t necessarily a Major, but I doubt most inspectors will agree, even that AOPA article I linked to said that an STC by definition, is a major, it’s a change in the Type Certificate, file the form and avoid the argument.

What it’s supposed to be is that an STC provides Approved Data for the installation of or modification of an aircraft or part when that installation or modification is Major

Now I agree wholeheartedly that the STC process has been abused and I can’t understand why, if nothing else many Countries don’t accept US STC’s and that would seem to hurt the manufacturer. I’ve had to remove STC’s to export aircraft.

Pretty sure even our Brothers to the North can’t use a US STC unless transport Canada has approved it, but as I don’t maintain any Canadian aircraft I have no idea how difficult that is or if maybe even all US STC’s are approved already.

Edited February 9, 2022 by A64Pilot

[A64Pilot]

People aren’t afraid of filing a 337, but an A&P can’t, it requires an IA, and as an IA I don’t like wasting time and filing a 337 for sun visors and or a clock is wasting time.

I guess that makes me a grumpy old man?

You guy’s like Mike Busch, maybe this article will help 

https://resources.savvyaviation.com/wp-content/uploads/articles_eaa/EAA_2015-06_alterations.pdf

Edited February 9, 2022 by A64Pilot

[hypertech]

I have an STC for a hub cap.  Its stupid.  My IA looked at it, thought it was stupid, and proceeded to file the 337 anyway.