Adding a G5 require a 337?

[Echo]

7 hours ago, Trimetric said:

This is a good discussion.  I'm an A&P, hard in the books studying for the IA test.  I see some definite errors in thinking in some of the above comments.

First, everything the FAA does is covered by CFRs and not by woms (word of mouth, like we sometimes had in the military).  And in searching, I find nothing in writing that says an STC requires a 337.  Some have said - "an STC is by definition a major alteration".  I find this not to be true.  If that "definition" is in the CFRs, I can't find it so please let me know if you do.

A major alteration is defined in 14 CFR part 1 and further spelled out in part 43, Appendix A.  Nowhere do I see it written that an STC has anything to do with the concept of major/minor.

The Bowers letter, like many legal documents has to be read with extreme attention to detail.  This whole argument keys on one word in the letter (second main paragraph) - the word "certain".  Counsel Peter uses the word "certain" i.e. "certain STCs require the completion of an FAA 337" and I think that resolves the question right there.  Obviously, as we all know, applying an STC that involves a major alteration will absolutely require a 337 - not because of the STC but because of the major alteration.  And therefore, contrarily and logically, applying an STC that involves a minor alteration does not require further documentation than the aircraft log book.

If Counsel Peter had not used the word "certain" the story would be completely different and all STC applications would require a 337 instead of "certain" ones.

The second to last paragraph of the letter seems to contradict this and require the 337 but actually does not - "The person performing an alteration in accordance with an STC must comply with all the requirements of section 43.9".  And that makes perfect sense.  43.9 directs that "each person who (blah blah) alters an aircraft" make an entry in the maintenance record.  It further requires in paragraph 43.9 (d) that major repairs and alterations be documented per Appendix B where we find the 337.  Again, there's no mention of the term "STC".

So what do we learn? To me, the Bowers letter confirms what we already knew about documentation requirements for major and minor alterations and does not direct us to fill out a 337 just because we use an STC as data to make the alteration.  That makes perfect sense to me and that's what I plan to do going forward.  If it's a minor alteration, I'll reference the STC as approved data in the log book and not file a 337. Of course, the title of the form is in fact - "Major Repair or Alteration" and therefore by definition is not relevant for minor alterations as defined in 43 Appendix A.

Some have said, "just file the 337".  Ok, you could do that but IMO, you're wasting time and money, using the wrong form, and not properly doing the job as an IA if the alteration is clearly minor.  But if the alteration could be interpreted to be major, of course, file a 337.

Obviously though, many alterations we make to our airplanes are actually minor so they should be done by an A&P with a log book entry referencing "acceptable data".

Please let me know if you find I've got my facts wrong.  I think this is an important concept for all A&Ps and IAs to understand.  And I appreciate what everyone has written about this since it forced me to dig in the books.

Thanks -  John McClanahan, Atlanta

This brings me to a question I have regarding a recent purchase.  A Whelen LED Landing Light purchased used.  It is STC'd for my aircraft.  I believe this to be a minor alteration as it is same footprint and requires no other hardware to install.  Weight change is minimal.  Can my IA install with a logbook entry and NOT submit a 337 for install?

Edited January 19 by Echo

[EricJ]

46 minutes ago, Echo said:

This brings me to a question I have regarding a recent purchase.  A Whelen LED Landing Light purchased used.  It is STC'd for my aircraft.  I believe this to be a minor alteration as it is same footprint and requires no other hardware to install.  Weight change is minimal.  Can my IA install with a logbook entry and NOT submit a 337 for install?

IMHO, if you have an IA that you're working with, their opinion is the one that matters since their signature is going in your logbook.

[Trimetric]

Regarding Lancecasper's question - I see nothing in the policy statement regarding connecting the G5 to other systems.  It's basically about having a backup battery and dedicated circuit breaker.   It seems pretty straightforward to meet the requirements and install as a minor alteration.

Regarding trouble down the road with another IA, I think an appropriate log book entry can forestall this kind of thing, for example - "this installation qualifies as a minor alteration IAW 14CFR Part 43  Appendix A and FAA Policy Statement PS-ACE-23-08.  No 337 required".  If someone wants to argue with that then they need to pull out references to CFRs.  If they can't support their opinions in that manner then the argument falls apart.

I see this all the time in forums.  Someone asks a question and all you get is un-supported opinions and I think this and that when what you really need is the facts of the matter (with references) and not something like I know a guy who knows a guy who's done it this way for 40 years and etc..LOL..

Anyway, thanks again for writing

John McClanahan

[Trimetric]

Regarding Echo's question - Minor alteration, can be done by an A&P, log book entry.  

Reference Part 43 Appendix A, paragraph (xii) - Major alterations - "Changes to the basic design of the ...electrical system"  are major alterations.

14 CFR Part 1, definitions - Minor Alteration - "An alteration other than a major alteration."

Clearly this is a minor alteration.  Install with a log book entry.  No IA involvement needed.

[philiplane]

17 hours ago, Trimetric said:

Additionally, regarding the question that started this thread about installing a G5, FAA Policy Statement PS-ACE-23-08 allows electric attitude indicators to be installed as a minor alteration if certain requirements are met.  You can find it by Googling "FAA PS-ACE-23-08".

Again, if it's a minor alteration, the 337 is not needed or appropriate.

Hope this helps -

John McClanahan, Atlanta

 

That policy statement mostly refers to electric driven attitude indicators in place of vacuum driven. They're still gyros, but driven by a different power source. Substituting a Castleberry electric attitude indicator in place of a vacuum-driven AI is a minor alteration. The Sandia AI is in the electronically-driven category, halfway between the Castleberry AI and the G5.

The G5 is not just an electric attitude indicator. The G5 falls into the EFIS category, which is completely different, because it performs more than one function. That's why Garmin went the STC route, to eliminate the haphazard way that many installers alter airplanes. The installation instructions cover all the bases in the AC, and in the relevant regs.

[A64Pilot]

Since when did policy statements, letters etc become law as in regulations?

Answer is they aren’t, the FAA doesn’t like having to write and or change FAR’s it’s a lot of work, so they often don’t, they write policy letters, advisory circulars etc and try to hold you to them.

I know because I’ve met the letter of the law meaning an FAR for Certification and been denied because it didn’t meet an AC, which is advisory only, it’s in the name.

By the way I, actually we fought the ATL ACO and won, it wasn’t much of a battle.

So these letters and interpretations etc are not law, any more than an AC is.

An STC is a modification of type data, it’s in the name. Any modification to type data is a Major, any Major requires an IA and a 337. Many, many specific statements you cant find in any FAR so you won’t find an STC requires a 337.

‘Even AOPA agrees, decent short article by the way

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

“Any STC is, by definition, a major alteration and also requires a 337 form.”

Unfortunately the STC process is and has been misused in the past and continues to be so. Rosen did so I’m sure as an attempt to stop knock-offs as most of their installations are plainly minor. I’ve not seen every one so I can’t say all.

In truth you will get different answers from different inspectors, the most conservative answer is to file the 337, they aren’t even reviewed by the FAA anymore at the FSDO like they used to be, you could file a 337 for installing a small block chevy motor in your mooney, it would go into the aircraft files with no one the wiser, because they are so important no one looks anymore

[McMooney]

20 hours ago, Echo said:

This brings me to a question I have regarding a recent purchase.  A Whelen LED Landing Light purchased used.  It is STC'd for my aircraft.  I believe this to be a minor alteration as it is same footprint and requires no other hardware to install.  Weight change is minimal.  Can my IA install with a logbook entry and NOT submit a 337 for install?

you can install it with a logbook entry

[A64Pilot]

3 minutes ago, McMooney said:

you can install it with a logbook entry

So how do you obtain the STC? 

[A64Pilot]

I’ll answer my own question.

Most likely if one is still required Whelen will give it to you if asked, I don’t think they did the STC as a way to make money, but as a way to sell the lights

As I posted earlier Whelen didn’t want to STC their original LED light the Parmethius. At least I think it was their original, the issue was did it meet the FAA requirements for a landing light, meaning the TSO. Well it seemed the FAA never got around to writing a TSO, so how do you meet something that doesn’t exist? Old lights were sort of Grandfathered in, because it’s always been that way.

One way is by STC, an Alaskan company named floats Alaska had an STC for LED landing lights so Whelen just bought theirs, knowing I’m sure that if they left it to the FAA to approve LED lights for landing lights they would be waiting for a long time.

That was at least ten years ago when I was installing them in new aircraft.

Anyway since then I don’t know if the FAA got around to writing a TSO for landing lights or if it just got out of hand and everyone is sourcing LEDs for position lights etc and just installing them or what. Maybe the FAA wrote a letter  

But to get to the root of the question, I can’t buy a piece of equipment that was STC’d for that aircraft and simply install it on mine, I as in my aircraft has to have an STC to cover it, the STC stays with the aircraft, it does not transfer with the part.

Example when I sold my Bushwheels I contacted AK Bushwheels and they sold the STC to my buyer for $50 and my aircraft kept the STC, even though it didn’t have a set of Bushwheels anymore. If later I bought another set so long as they wrre the same I wouldn’t have to buy another STC

[OR75]

4 hours ago, A64Pilot said:

I’ll answer my own question.

Most likely if one is still required Whelen will give it to you if asked, I don’t think they did the STC as a way to make money, but as a way to sell the lights

As I posted earlier Whelen didn’t want to STC their original LED light the Parmethius. At least I think it was their original, the issue was did it meet the FAA requirements for a landing light, meaning the TSO. Well it seemed the FAA never got around to writing a TSO, so how do you meet something that doesn’t exist? Old lights were sort of Grandfathered in, because it’s always been that way.

One way is by STC, an Alaskan company named floats Alaska had an STC for LED landing lights so Whelen just bought theirs, knowing I’m sure that if they left it to the FAA to approve LED lights for landing lights they would be waiting for a long time.

That was at least ten years ago when I was installing them in new aircraft.

Anyway since then I don’t know if the FAA got around to writing a TSO for landing lights or if it just got out of hand and everyone is sourcing LEDs for position lights etc and just installing them or what. Maybe the FAA wrote a letter  

But to get to the root of the question, I can’t buy a piece of equipment that was STC’d for that aircraft and simply install it on mine, I as in my aircraft has to have an STC to cover it, the STC stays with the aircraft, it does not transfer with the part.

Example when I sold my Bushwheels I contacted AK Bushwheels and they sold the STC to my buyer for $50 and my aircraft kept the STC, even though it didn’t have a set of Bushwheels anymore. If later I bought another set so long as they wrre the same I wouldn’t have to buy another STC

Not sure what Wheelen light bulb you are i referring  to but I am guessing that would be PMA'ed (like a light bulb, tire, tube , oil filter, battery, ...) for your aircraft (basic replacement). Part number but no serial number. 

[Ibra]

Looking at 337, it does two functions in block 8 and block 3, 

- If one uses data in box 8 that are already approved by FAA via STC, then FAA stamping box 3 is pretty much useless?

- If one uses field approval sign-off in box 8 for unapproved data after major alteration, then FAA has to countersign in box 3

I think the chain of approval is the only distinction between 337 major alteration and stc alteration, the choice of the form is irrelevant…

Also, shortcuts like “STC => major => 337” are not helpful when it comes to (standard) changes that are are done by STC across all designs (LED lights, Rosen visors, G5 replacement of AI): the FAA does not have “standard change” category to would deal with this intersection, so most mechanics and inspectors will fill 337 instead of splitting hairs, the pilots also like to have reassurance for future sale or pre-buy and ask to send  337 just in case

What about aircraft re-painting? it needs fresh weight & balance with control surface rebalance and has some gotcha, it’s pretty standard across all designs, so what is the certification path and rational for such work?

Maybe one should compile the list of “universal STC” that don’t need to follow 337 (adds nothing other than red-tape), then agree with FAA to publish that list? there won’t be much debate between pilots, IA/AP or FSDO on this…

Edited January 20 by Ibra

[Jsno]

When in doubt, I send in a 337.  Doesn't take long to fill out.

[A64Pilot]

11 hours ago, OR75 said:

Not sure what Wheelen light bulb you are i referring  to but I am guessing that would be PMA'ed (like a light bulb, tire, tube , oil filter, battery, ...) for your aircraft (basic replacement). Part number but no serial number. 

Another wide misconception, you’re not alone a neighbor is still pissed at me for telling him that the Odyssey battery is a PMA battery, but it’s not legal in his 182.

I was trying to help, but now he knows and I guess he didn’t like it, shoot the messenger. PMA does not constitute approval for a particular aircraft. PMA just means parts approval authority, that means the manufacturer has demonstrated to the FAA that they can manufacture parts and meet all requirements to do so. 

What you’re referring to is often called a “Standard part” something that can be used on any aircraft not requiring a special part for an application, many if not most electrical parts for example are standard parts.

Usually, but not always standard parts meet a TSO, Technical Standard Order, which specifies the performance standard for the part, for example one would expect the TSO for a landing light might specify a min brightness level, possibly beam width etc. 

Usually but not always is relevant because if you dig into just about any FAR you will find exceptions. Some say they were intentionally written to be vague and full of loop holes, maybe they are right.

But the FAA never got around to writing a TSO for landing lights, like many things it was just sort of taken for granted that people would buy lights made by GE etc meant for aircraft and not say a Sears garden tractor light because it would fit, and most of course did. 
 

Then along came LED’s, many manufacturers like Aeroleds for example, I’ll use his because I’ve worked with him and he’s a good guy who makes a good product who would sell you a light but would tell you that it’s up to the installer to determine if it was a minor or major etc. he was being honest I’m not knocking him. HID’s came out about the same time, similar problem, they are similar to a filament light bulb but require a ballast.

Whelen manufactured the Parmethius and as they are the big boys in lighting I’m sure didn’t want to sell with the it’s not approved disclaimer.

The issue as I understand it was the FAA has a policy I guess I’ll call it that makes approval easier if your building essentially the same thing that’s already been approved or has been in existence forever, like say a Butyl tire inner tube, so if you build a Butyl inner tube that’s just as thick etc and the same way as say Goodyears approval is easy.

But make one out of a new material approval is going to be much harder, even if it’s superior.

The problem with LED’s is they are nothing like an incandescent bulb, there is no filament in a vacuum etc, there are electronics etc., so while they both produce light it’s by an entirely different method, so the FAA was scratching their heads on LED’s and moving at the normal FAA pace of maybe next year.

Whelen of course wanted to sell their lights, an Alaskan company named floats Alaska had an STC to sell LED landing lights, so Whelen chose to buy their STC as opposed to waiting on the FAA to decide what they wanted to do. Being as it was an STC that meant an IA got involved, the requirement for a continuous airworthiness document spelling out what required maintenance and servicing etc had to be done etc. Which is silly for a light hull of course but it allowed Whelen to sell light bulbs.

This was years ago when I was an aircraft manufacturer and was attempting to get rid of incandescent bulbs as frankly they were in my opinion outdated and no million dollar new airplane should come with them anymore than our radios ought to have tubes.

As that was likely almost a decade ago surely the FAA has addressed LED’s by now and hopefully written a TSO that specifies min luminosity, beam focus, possibly color temp etc. but I honestly don’t know.

An issue with just installing things that require an STC is one day you may decide to sell, and it’s likely that whoever inspects the records will take note of the missing 337’s etc, and sloppy and or missing records are a red flag when buying an airplane. It doesn’t mean the airplanes bad of course but it could help devalue it.

I would think think it more likely you winning the Lottery than you getting into hot water with the FAA if you chose to install an STC’d product yourself, the FAA just doesn’t care and doesn’t monitor GA to that level thankfully, they do monitor mechanics, but almost never the aircraft, unless it’s something so obvious that they can’t ignore it, like an airplane on the ramp with bent prop tips for example.

An airplane with neat, properly kept records without missing items helps sell better than one that isn’t, beyond that it seems to a great extent owners often do as they please.

 

 

[OR75]

2 hours ago, A64Pilot said:

Another wide misconception, you’re not alone a neighbor is still pissed at me for telling him that the Odyssey battery is a PMA battery, but it’s not legal in his 182.

I was trying to help, but now he knows and I guess he didn’t like it, shoot the messenger. PMA does not constitute approval for a particular aircraft. PMA just means parts approval authority, that means the manufacturer has demonstrated to the FAA that they can manufacture parts and meet all requirements to do so. 

What you’re referring to is often called a “Standard part” something that can be used on any aircraft not requiring a special part for an application, many if not most electrical parts for example are standard parts.

Usually, but not always standard parts meet a TSO, Technical Standard Order, which specifies the performance standard for the part, for example one would expect the TSO for a landing light might specify a min brightness level, possibly beam width etc. 

Usually but not always is relevant because if you dig into just about any FAR you will find exceptions. Some say they were intentionally written to be vague and full of loop holes, maybe they are right.

But the FAA never got around to writing a TSO for landing lights, like many things it was just sort of taken for granted that people would buy lights made by GE etc meant for aircraft and not say a Sears garden tractor light because it would fit, and most of course did. 
 

Then along came LED’s, many manufacturers like Aeroleds for example, I’ll use his because I’ve worked with him and he’s a good guy who makes a good product who would sell you a light but would tell you that it’s up to the installer to determine if it was a minor or major etc. he was being honest I’m not knocking him. HID’s came out about the same time, similar problem, they are similar to a filament light bulb but require a ballast.

Whelen manufactured the Parmethius and as they are the big boys in lighting I’m sure didn’t want to sell with the it’s not approved disclaimer.

The issue as I understand it was the FAA has a policy I guess I’ll call it that makes approval easier if your building essentially the same thing that’s already been approved or has been in existence forever, like say a Butyl tire inner tube, so if you build a Butyl inner tube that’s just as thick etc and the same way as say Goodyears approval is easy.

But make one out of a new material approval is going to be much harder, even if it’s superior.

The problem with LED’s is they are nothing like an incandescent bulb, there is no filament in a vacuum etc, there are electronics etc., so while they both produce light it’s by an entirely different method, so the FAA was scratching their heads on LED’s and moving at the normal FAA pace of maybe next year.

Whelen of course wanted to sell their lights, an Alaskan company named floats Alaska had an STC to sell LED landing lights, so Whelen chose to buy their STC as opposed to waiting on the FAA to decide what they wanted to do. Being as it was an STC that meant an IA got involved, the requirement for a continuous airworthiness document spelling out what required maintenance and servicing etc had to be done etc. Which is silly for a light hull of course but it allowed Whelen to sell light bulbs.

This was years ago when I was an aircraft manufacturer and was attempting to get rid of incandescent bulbs as frankly they were in my opinion outdated and no million dollar new airplane should come with them anymore than our radios ought to have tubes.

As that was likely almost a decade ago surely the FAA has addressed LED’s by now and hopefully written a TSO that specifies min luminosity, beam focus, possibly color temp etc. but I honestly don’t know.

An issue with just installing things that require an STC is one day you may decide to sell, and it’s likely that whoever inspects the records will take note of the missing 337’s etc, and sloppy and or missing records are a red flag when buying an airplane. It doesn’t mean the airplanes bad of course but it could help devalue it.

I would think think it more likely you winning the Lottery than you getting into hot water with the FAA if you chose to install an STC’d product yourself, the FAA just doesn’t care and doesn’t monitor GA to that level thankfully, they do monitor mechanics, but almost never the aircraft, unless it’s something so obvious that they can’t ignore it, like an airplane on the ramp with bent prop tips for example.

An airplane with neat, properly kept records without missing items helps sell better than one that isn’t, beyond that it seems to a great extent owners often do as they please.

 

 

an Odyssey battery is FAA PMA ? 

[A64Pilot]

19 minutes ago, OR75 said:

an Odyssey battery is FAA PMA ? 

One is, but here’s the deal it’s only PMA IF you buy a battery box STC for a couple of Piper aircraft and the C-180 and 185.

It’s NOT PMA for anything else. Pretty sure but not certain about the 180 and 185. Just looked the attached link lists applicable aircraft, more have been added since I last looked it seems

https://www.batterymart.com/p-hawker-sbs-J16-aircraft-battery.html?gad_source=1&gclid=Cj0KCQiA-62tBhDSARIsAO7twbaLi7pv89kShGwP64ft0gtcT50oFDO-NfCDYwOKXC4coU08JroCPf8aAmUQEALw_wcB

I promise you when you drill into EVERY FAR the answer is, it depends.

Odyssey link

https://www.odysseybatteries.com/odyssey/sbsj16.html

[Fly Boomer]

7 hours ago, Ibra said:

Maybe one should compile the list of “universal STC” that don’t need to follow 337 (adds nothing other than red-tape), then agree with FAA to publish that list? there won’t be much debate between pilots, IA/AP or FSDO on this…

Some say that asking FAA for clarification may lead to a ruling or opinion you will wish you had not asked for.

[A64Pilot]

12 minutes ago, Fly Boomer said:

Some say that asking FAA for clarification may lead to a ruling or opinion you will wish you had not asked for.

But, they are here to help  

Remember their motto “we aren’t happy, until your not happy”

[Ibra]

31 minutes ago, Fly Boomer said:

Some say that asking FAA for clarification may lead to a ruling or opinion you will wish you had not asked for.

Indeed, there is that risk of losing legal flexibility if people seek clarification  

[Pinecone]

7 hours ago, A64Pilot said:

What you’re referring to is often called a “Standard part” something that can be used on any aircraft not requiring a special part for an application, many if not most electrical parts for example are standard parts.

Usually, but not always standard parts meet a TSO, Technical Standard Order, which specifies the performance standard for the part, for example one would expect the TSO for a landing light might specify a min brightness level, possibly beam width etc. 

Usually but not always is relevant because if you dig into just about any FAR you will find exceptions. Some say they were intentionally written to be vague and full of loop holes, maybe they are right.

But the FAA never got around to writing a TSO for landing lights, like many things it was just sort of taken for granted that people would buy lights made by GE etc meant for aircraft and not say a Sears garden tractor light because it would fit, and most of course did. 

Well, the standard aircraft landing light is NOT a light designed and made for aviation use.

It is a 1920s Ford tractor head light.

[EricJ]

1 hour ago, Pinecone said:

Well, the standard aircraft landing light is NOT a light designed and made for aviation use.

It is a 1920s Ford tractor head light.

Many Mooney parts were adapted from other applications.    Supposedly the landing gear pucks were tractor engine mounts.   My hangar neighbor with an M20A said some of the cable pull controls, like for the cowl flaps, were choke cables or something, and you could see the automotive branding on them if you looked close enough.   The voltage regulators in old Cessnas are Delco units straight out of pickup trucks, with an 'A' hand-stamped on the end of the part number.  Many GA alternators cross to automotive units or very close.  This is why "standard parts" are prevalent and why VARMA is helping to get IAs to recognize that such substitutions are not necessarily evil.   An example used in the FAA presentation on VARMA that I attended was about getting a NAPA starter relay approved for a Cessna 150 because it was a virtually identical part.

And landing lights are even easier because there's essentially no requirements that need to be met other than it "provides illumination" and is "safe for operation".

 

[M20F]

Good work, 2 pages in and we are onto tractor lights.  I knew we could do it, onto page 3!

[Ibra]

Assume one install 2*G5 via STC+337, does installing GAD13 (for OAT, TAS, Wind) require another 337? or logbook entry will do? 

Edited January 23 by Ibra

[Igor_U]

Good questions,

My IA handled similar situation (adding USB "Smart charger" to already installed CGR30 engine monitor) with logbook entry and referring to the existing STC/337.

21 minutes ago, Ibra said:

Assume one install 2*G5 via STC+337, does installing GAD13 (for OAT, TAS, Wind) require another 337? or logbook entry will do? 

 

[Ibra]

On 1/24/2024 at 12:18 AM, Igor_U said:

My IA handled similar situation (adding USB "Smart charger" to already installed CGR30 engine monitor) with logbook entry and referring to the existing STC/337

My IA thinks that would work as well