Major versus minor alteration; voltage regulator

[Jetrn]

Mooney M20k-252 with duel 28v voltage regulator, part number specific to m20k. Voltage regulator was sent to international avionics in texas for repair 2 months ago. Service tech is on extended medical leave with no time frame for returning. I would like to install the plane power 28v voltage regulator R1244, this part is approved for other mooney models.
I am a licensed a&p and when going through the FAA decision tree and reading 14 cfr 21.93; I arrive at installing the plane power voltage regulator to be a minor repair. I have spoke with an IA and he feels that it needs a field approval. but According to 14 CFR 21.93, “A ‘minor change’ is one that has no appreciable effect on the weight, balance, structural strength, reliability, operational characteristics, or other characteristics affecting the airworthiness of the product. All other changes are ‘major changes’ (except as provided in paragraph (b) of this section).”

Definitions provided in 14 CFR Part 1.1 state, “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.”

And “minor alteration means an alteration other than a major alteration.”

For me the key words are reliability and operational characteristics. I would be installing 2 modern solid state voltage regulators.

Thanks in advance for the input.

[Hank]

I'm no A&P, but I agree with you. So many A&Ps and IAs seem to want extra work and approvals before doing something--filing unnecessary 337s and asking for DER / DAR approval. But I don't understand their reasoning, and it has never been offered.

Did you ask your IA why he thinks this is a Major Alteration, and why a DER would be required?

[KSMooniac]

I agree with Hank. Ask your IA to defend his position and as he goes through the logic he might convince himself that your view is indeed rational and correct.

Too many are spring-loaded today to avoid making a decision and defer to some other authority out of fear of the consequences. In your case there really is no downside.

Sent from my motorola edge plus 2023 using Tapatalk

[Jetrn]

The IA felt, because it was a mooney specific part number. I would need a field approval, I would need the specs for the old component and new component to be submitted for field approval. I take the view this is an industry standard component with that is a modern solid state device that will provide cleaner power to the modern avionics installed. The R1224 is is approved for mooney's A-G models. Plane Power was no help when calling.

[EricJ]

The installer determines whether it is major or minor, so if you're installing it and you're comfortable with it, go for it.    It sounds like you've done some reasonable homework to come to your conclusion.    My methodology is usually that if I'm comfortable standing in front of a judge and saying, "this is why I did this", then I'm good.    Being able to show a path through the decision tree and reasonable interpretation of the regs is a good way to do that.

And really the only IA opinion that matters is the one that'll sign off the annual for that airplane.   Asking IAs that aren't going to do that is just going to generate a lot of confusion (sadly).   

 

[Jetrn]

EricJ, I am comfortable with doing the installation. Yes, the IA is the one who signs off my annuals for the plane. He is not strict in his interpretation of the regulations and has been around a long time. I think I may have to sit down with him again and discuss the FAA flow chart.

[Marc_B]

1 hour ago, Jetrn said:

Service tech is on extended medical leave with no time frame for returning.

I suspect you mean Kenneth Snowden.  I hope he's okay, but suspect that he may be close to retirement anyways as he's been with IAI for a LONG time!  I hope IAI has another service tech in training, as when I was dealing with the same issue for 28V dual regulator there was nothing PMA'd for this and I was told by Don Maxwell that they could service VR's but if it was an IAI regulator it would have to go back to them.

[Larry]

Is your original regulator one that Don Maxwell will repair/IRAN?  It may be worth a call.

[McMooney]

4 hours ago, Jetrn said:

Mooney M20k-252 with duel 28v voltage regulator, part number specific to m20k. Voltage regulator was sent to international avionics in texas for repair 2 months ago. Service tech is on extended medical leave with no time frame for returning. I would like to install the plane power 28v voltage regulator R1244, this part is approved for other mooney models.
I am a licensed a&p and when going through the FAA decision tree and reading 14 cfr 21.93; I arrive at installing the plane power voltage regulator to be a minor repair. I have spoke with an IA and he feels that it needs a field approval. but According to 14 CFR 21.93, “A ‘minor change’ is one that has no appreciable effect on the weight, balance, structural strength, reliability, operational characteristics, or other characteristics affecting the airworthiness of the product. All other changes are ‘major changes’ (except as provided in paragraph (b) of this section).”

Definitions provided in 14 CFR Part 1.1 state, “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.”

And “minor alteration means an alteration other than a major alteration.”

For me the key words are reliability and operational characteristics. I would be installing 2 modern solid state voltage regulators.

Thanks in advance for the input.

if specs are equal or greater, i'd go with it, sounds totally reasonable.

[Shadrach]

On 8/18/2024 at 3:02 PM, Jetrn said:

EricJ, I am comfortable with doing the installation. Yes, the IA is the one who signs off my annuals for the plane. He is not strict in his interpretation of the regulations and has been around a long time. I think I may have to sit down with him again and discuss the FAA flow chart.

Suggesting that a there is a strict interpretation of the definition as written that make this a major alteration is a mistake. Words mean things.

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, does it meet any of the criteria in (1)?

W&B - No

Structural Strength - No

Performance - No

Powerplant operation - No

flight characteristics - No

Other qualities affecting airworthiness - Well this is the catch all, but I would say a good test of whether it affect airworthiness is whether or not It affects the physical operation of the aircraft in an measurable way. In other words, are there operational parameters in which the replacement VR would operate differently than the original?  If the answer is no, it’s very hard to make the case that it affects airworthiness.

As far as (2) goes, I’m assuming you wouldn’t even be considering the installation if you weren’t able to do so in accordance with practices acceptable to the administrator.

So what we have here in essence is a reading of the actual reg versus an interpretation that is not at all commensurate with the actual definition codified in the regulations by the FAA. 
 

People have to stop playing this game. We have a responsibility to ensure that regulations are interpreted as they are written.

[MikeOH]

3 minutes ago, Shadrach said:

People have to stop playing this game. We have a responsibility to ensure that regulations are interpreted as they are written.

Well, "people" needs to start with the FAA!  Who, historically, have been famous for 'interpreting' the regs any way they damn please...AFTER the fact

So, while I agree 100% with your analysis on the VR topic it is not hard to see why a paranoid A&P/IA may be ultra conservative (perhaps even has a 'once burned, twice shy' story).

[Shadrach]

15 minutes ago, MikeOH said:

Well, "people" needs to start with the FAA!  Who, historically, have been famous for 'interpreting' the regs any way they damn please...AFTER the fact

So, while I agree 100% with your analysis on the VR topic it is not hard to see why a paranoid A&P/IA may be ultra conservative (perhaps even has a 'once burned, twice shy' story).

I don’t see how you get bitten by reading the words as they’re written. Interpreting this as a major alteration would require ignoring the regulation as it is written.

I have seen an odd culture within the DOD industry. I heard the term “courtesy 337“ used by a chief maintenance inspector on several occasions. One was specifically regarding the removal of carpeting from a King Air. My response is how is that a major alteration and how is it a “courtesy”. 
His response was the ASI at the FSDO appreciated the documentation.

I understand that it’s important to maintain the relationship with the FSDO, but absurd is absurd

[MikeOH]

@Shadrach

100% agree these things are completely absurd  I was merely offering up a possible reason why A&P/IAs 'play along'; your King Air carpet 'courtesy' example is proof of my point, sad as it is.  Until people 'rock the boat' nothing is going to change.  And, I suspect it won't as businesses   need to 'go along with absurdity to get along with government fiefdoms'; to buck the broken 'system' when your competitors cave is probably a pretty bad business plan.

[Shadrach]

On 8/18/2024 at 7:47 PM, MikeOH said:

@Shadrach

100% agree these things are completely absurd  I was merely offering up a possible reason why A&P/IAs 'play along'; your King Air carpet 'courtesy' example is proof of my point, sad as it is.  Until people 'rock the boat' nothing is going to change.  And, I suspect it won't as businesses   need to 'go along with absurdity to get along with government fiefdoms'; to buck the broken 'system' when your competitors cave is probably a pretty bad business plan.

The same mechanism that took the Soviets to “We pretend to work and they pretend to pay us”…

[A64Pilot]

Call the FSDO, I bet they would consider it a Major, based on ramifications of possible failure if nothing else.

If it were considered a standard part, then you could use one from a car or tractor or whatever.

In my opinion this is what Field Approvals are for, shouldn’t be that difficult to get one IF you get a reasonable inspector, many won’t do field approvals anymore

[jetdriven]

What’s the far part 1 definition of a major alteration? 

[tony]

Dont ask the FSDO, just get a DER to sign an 8110 and move on.  

[Shadrach]

13 hours ago, A64Pilot said:

Call the FSDO, I bet they would consider it a Major, based on ramifications of possible failure if nothing else.

If it were considered a standard part, then you could use one from a car or tractor or whatever.

In my opinion this is what Field Approvals are for, shouldn’t be that difficult to get one IF you get a reasonable inspector, many won’t do field approvals anymore

They don’t get to just “consider it” anything. You’ve made no case for why this is a major.  FAA must make the case based on the situation and the applicable FARs as written.

You've also not made a case for why there is an increased risk of failure.  Why would a TSO/PMA’d Voltage regulator, approved for service in other Mooneys with the exact same specifications, but a different P/N have a different propensity for failure? 

This is the kind of thinking that needlessly makes GA maintenance more challenging and quite frankly detracts from safety rather than enhance it. 
 

At the end of the day this is about the installing mechanic’s comfort level and understanding of the FARs and their confidence that their interpretation is correct and defendable. Unfortunately folks are becoming more and more averse.

[Shadrach]

59 minutes ago, tony said:

Dont ask the FSDO, just get a DER to sign an 8110 and move on.  

Why would an 8110 be required for an FAA/PMA part?  Good luck finding a DER would do that.

[A64Pilot]

Just now, Shadrach said:

They don’t get to just “consider it” anything. You’ve made no case for why this is a major.  FAA must make the case based on the situation and the applicable FARs as written.

You've also not made a case for why there is an increased risk of failure.  Why would a TSO/PMA’d Voltage regulator, approved for service in other Mooneys with the exact same specifications, but a different P/N have a different propensity for failure? 

This is the kind of thinking that needlessly makes GA maintenance more challenging and quite frankly detracts from safety rather than enhance it. 

I don’t “need” to make any kind of case. I’m not trying to do the install, just trying to advise the person who is that it is advisable to call and ask, as an A&P if nothing else he needs to develop a friendly relationship with his inspector if he hasn’t gotten one already, asking advice is one way to develop that. 

As I said, give the FSDO a call and ask them, as a 40 yr A&P and 15 year or so IA I feel sure I know what their answer would be. It might just possibly start with wondering why the manufacturer didn’t include your model Mooney in with the others.

Using your logic I’d be able to use engines, props and all kinds of other things on my Mooney, because they are approved on other Mooney’s.

[A64Pilot]

1 minute ago, Shadrach said:

Why would an 8110 be required for an FAA/PMA part? 

PMA only means that the part was manufactured by a manufacturer that has FAA approval to make parts, it has zero to do with applicability on any one aircraft.

I can’t put PMA helicopter pistons in my engine for example

[Shadrach]

1 hour ago, A64Pilot said:

PMA only means that the part was manufactured by a manufacturer that has FAA approval to make parts, it has zero to do with applicability on any one aircraft.

I can’t put PMA helicopter pistons in my engine for example

Agreed and neither does an 8110…It is focused on the part, not its compatibility. Those Helo pistons are still airworthy and don’t require an 8110. Their installation is another matter.

I appreciate your experience and expertise. I only wish you would actually read what’s been said and reserve your critiques for things that I have actually said.

An 8110-3 determines compliance with airworthiness standards for the part.

FAA Form 8110-3 is titled "STATEMENT OF COMPLIANCE WITH THE FEDERAL AVIATION REGULATIONS" and is used to approved or recommend for approval the data used in making alterations or repairs to aviation products or articles. Only FAA designees are allowed to issue this form.

[Niko182]

whats the part number? I might have a spare VR for a 252. The eagle and the 252 share voltage regulators. I got my voltage regulator from a 252 with dual alternators. even though they had different part numbers, I opened the voltage regulator case, and the only difference was that there were the same 2 voltage regulators in the case. I just took it out and put it in the eagle voltage regulator case.

[Shadrach]

4 hours ago, A64Pilot said:

I don’t “need” to make any kind of case. I’m not trying to do the install, just trying to advise the person who is that it is advisable to call and ask, as an A&P if nothing else he needs to develop a friendly relationship with his inspector if he hasn’t gotten one already, asking advice is one way to develop that. 

As I said, give the FSDO a call and ask them, as a 40 yr A&P and 15 year or so IA I feel sure I know what their answer would be. It might just possibly start with wondering why the manufacturer didn’t include your model Mooney in with the others.

Using your logic I’d be able to use engines, props and all kinds of other things on my Mooney, because they are approved on other Mooney’s.

You're not reading before you post. Airworthiness of the part in question and compatibility are two separate issues.  

I argued that if the definitions of a minor alteration which is clearly codified in the FARs is met, than it is up to the AMT installing to determine what they are comfortable with doing. 

You made an appeal to your authority - "as a 40 yr A&P and 15 year or so IA I feel"

Then you proceeded to insinuate that I was suggesting complete parts compatibility between all aircraft- "Using your logic I’d be able to use engines, props and all kinds of other things on my Mooney, because they are approved on other Mooney’s."

I never said any such thing. Once again...for changes that meet the definition of minor alterations, I think that PMAd parts with operationally identical specifications but different part numbers can be installed as a minor alteration...

"It might just possibly start with wondering why the manufacturer didn’t include your model Mooney in with the others."

There are a whole host of reasons why a model might not be included in the application list. Some times it's a simple oversight or a paperwork omission. Sometimes it's a lack of data available for a specific model. Sometimes there is a compatibility issue.  In this case, perhaps it's because it would cause the battery to explode thereby blowing the airframe into pieces and causing it to plummet to the ground in a fiery mess...or...bare with me here, everything would be A'OK given per the TCDS that the components of the charging systems of each model are virtually identical save for a slightly lower capacity Alternator option on some J models...

J Model

K model

 

 

 

[Yetti]

Does it have an STC = yes.  Is it on the approved model list?  So you are changing the TC with an STC.   Send in the 337 with the STC paper.   Done.    Link to STC   https://planepower.aero/wp-content/uploads/2018/02/STC-SA11137SC-17-1001-17-0000-PP.pdf