Major versus minor alteration; voltage regulator

[Shadrach]

38 minutes ago, Yetti said:

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

 

 

It is not on the approved model list. The STC document does not authorize the installation of this voltage regulator on the M20K. 

This is a minor alteration that must be approved by the mechanic installing.

[N201MKTurbo]

In the past, you could phone your favorite inspector directly. Once you have a relationship with a guy, he will tell you what you need to do without worrying about getting in trouble. Now at our FSDO when you contact them it goes into a call pool and your call gets randomly routed. I called my inspector on his cell and although he answered my question, he said he wasn't supposed to do that and I was supposed to use the new system. The new system sucks...

[Shadrach]

1 hour ago, N201MKTurbo said:

In the past, you could phone your favorite inspector directly. Once you have a relationship with a guy, he will tell you what you need to do without worrying about getting in trouble. Now at our FSDO when you contact them it goes into a call pool and your call gets randomly routed. I called my inspector on his cell and although he answered my question, he said he wasn't supposed to do that and I was supposed to use the new system. The new system sucks...

I have been told that FSDOs are not doing any field approvals.  It seems that not only is there no institutional incentive to do so but there is also a professional disincentive to work through field approvals.

[Yetti]

Zeftronics is the answer.   

Zeftronics https://zeftronics.com/shop/r15300/  

Should be the right one.

Check for proper fit and paperwork.

 

[N201MKTurbo]

1 hour ago, Shadrach said:

I have been told that FSDOs are not doing any field approvals.  It seems that not only is there no institutional incentive to do so but there is a professional disincentive to work through field approvals.

I have never tried to get one, so I can’t say. I had a friend who got one a couple of years ago. He didn’t have any trouble. He produced a professional drawing package and data package and had it reviewed by a DER.  
 

I think that is where most people go wrong. The first thing to do is write a letter to the FSDO stating what you propose to do and how you propose to do it. You should put a requested timeline on it so the inspector doesn’t put it into his ignore pile. If you are not totally lame with your request, meaning you have researched the process and the requirements to meet the regulations and stated your plan to meet the regulations. If you do all that, they will give you the go ahead or tell you what you are missing. They are likely to call you on the phone so include your contact info.
 

If you just send in a 337 and ask them to sigh it, they will probably tell you to go pound sand. Everything should be agreed to before they get the 337. 

[Shadrach]

12 minutes ago, N201MKTurbo said:

I have never tried to get one, so I can’t say. I had a friend who got one a couple of years ago. He didn’t have any trouble. He produced a professional drawing package and data package and had it reviewed by a DER.  

The ASI gets no points for doing field approvals and could be held liable if a 337 is later deemed to be have been outside the FAA guidelines. Under such circumstances, why would anyone want their name on a 337?

[N201MKTurbo]

59 minutes ago, Shadrach said:

The ASI gets no points for doing field approvals and could be held liable if a 337 is later deemed to be have been outside the FAA guidelines. Under such circumstances, why would anyone want their name on a 337?

Because it is their job. They cannot just refuse to do it because they don’t want to. They are required to tell you why they cannot do it. Now, it may take them months to get around to telling you. Especially if you give them some lame paperwork. It’s also likely they will require a DER to review it claiming they don’t have the expertise to evaluate it. That is where the relationship comes into view. If they know you and know you know what you are doing, things can happen. If they don’t know you and you just show up out of the blue, they are not going to go out of their way to make things happen.

These guys are constantly signing off stuff. The airlines are always doing custom repairs and modifications that need field approval. But they know the ropes and deliver packages that are complete. Like I said before, if you don’t know what all the procedures are, ask. If you bring them a package with all the i’s doted and all the t’s crossed, they will get it done. If you give them crap, they will be in no hurry to review it and write a detailed report about what you did wrong.

[Shadrach]

10 minutes ago, N201MKTurbo said:

Because it is their job. They cannot just refuse to do it because they don’t want to. They are required to tell you why they cannot do it. Now, it may take them months to get around to telling you. Especially if you give them some lame paperwork. It’s also likely they will require a DER to review it claiming they don’t have the expertise to evaluate it. That is where the relationship comes into view. If they know you and know you know what you are doing, things can happen. If they don’t know you and you just show up out of the blue, they are not going to go out of their way to make things happen.

These guys are constantly signing off stuff. The airlines are always doing custom repairs and modifications that need field approval. But they know the ropes and deliver packages that are complete. Like I said before, if you don’t know what all the procedures are, ask. If you bring them a package with all the i’s doted and all the t’s crossed, they will get it done. If you give them crap, they will be in no hurry to review it and write a detailed report about what you did wrong.

I’m just relaying what I was told by several folks on the fed side. 

[MB65E]

To the OP- just get your IA!

-Matt 

[EricJ]

4 hours ago, Shadrach said:

I have been told that FSDOs are not doing any field approvals.  It seems that not only is there no institutional incentive to do so but there is also a professional disincentive to work through field approvals.

I've attended multiple presentations by FSDO reps over the past year where they specifically made the point that, yes, they do field approvals, they are doing them, and don't hesitate to ask for one.   That may not apply to all FSDOs, but it apparently does apply to some.

[mooniac15u]

4 hours ago, Yetti said:

Zeftronics is the answer.   

Zeftronics https://zeftronics.com/shop/r15300/  

Should be the right one.

Check for proper fit and paperwork.

 

That is a 14V regulator. OP said he has a 28V system.

[Fly Boomer]

5 hours ago, Yetti said:

Zeftronics https://zeftronics.com/shop/r15300/  

Should be the right one.

Check for proper fit and paperwork.

 

If his airplane is a 252, it has a 28 volt system.

EDIT:  I need to read to the bottom before posting.  @mooniac15u beat me.

[tony]

19 hours ago, 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. 
 

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.

Ross, I really don't think you know how the FAA works, I probably need to say doesn't work.  The FAA has ACOs, MIDOs, FSDOs, and none of the talk to each other.  The engineering side would agree per 14CFR21.93 (a) this is a minor change.  But the operational side who holds airworthiness in their hand says, there is no engineering to support the change.   So here we are, stuck in a place where the airplane sits on the ground for paperwork.

Life is short and I'd rather go fly then argue over who is right.  

The OP needs to just draw up a an engineering drawing that supports this change in his specific airplane, throw an 8110 on the engineering (not the part), and then use that with the FSDO.  This happens everyday.

Edited August 28 by tony

[A64Pilot]

Ref field approvals.

It’s true that apparently FAA inspectors years ago were told that they could be held legally responsible for their decisions.

I don’t know why or when that occurred but think it’s sort of obvious isn’t it? Every job I can think of you to some extent can be held liable, DR’s, Cops, mechanics, bankers etc. 

Of course to my knowledge no FAA inspector ever has, I think they use it as an excuse from doing work, by and large the FAA is lazy, want to get something from the FAA? It’s not hard just do all the work for them and present them with a through and complete job.

I used to get field approvals all the time, in fact I got serial field approvals, which the FAA specifically says they won’t do, for those your supposed to get an STC, did yiu know there are even one time STC’s a great many actually, for instance nearly every new bizjets interior is covered under a one time STC for example.

It was for Satloc GPS guidance and boom control equipment for Ag planes, I was going to get an STC, but they literally came out with new models every few months and you just couldn’t get either an STC or factory drawings approved before that model was obsolete.

https://www.satloc.com/falcon-and-falcon-pro/

I’ve been out of the system for a few years but the FAA “que” system was well established even back then, entering the Que to get your answers could literally get you into a FSDO across the Country.

Every day the FAA more and more becomes management, their intent is that all the work will be done by designees and their job will be to manage the designees, that’s not in writing but in Certification of aircraft you will never get there without several DER’s. I’ve Certified several aircraft, mostly derivations of one model, but one was on paper a completely new airplane.

IA’s in the history of aviation is s relatively new thing, prior to IA’s the FAA would re-issue an Airworthiness cert every year after the Annual inspection, performed by the FAA. Then they decided that was too much work, so the IA was created.

Don’t try to become outhouse Lawyers, there are the Regs of course and we can all read, but the Regs are intentionally written to allow for quite a bit of interpretation, what you think the regs plainly say, very often isn’t the interpretation of the FAA. Arguing with a bunch of people on the internet won’t get you anywhere, the only thing that might is calling the FSDO and pleading your case.

Now the honest truth is there is almost zero chance any FAA rep will ever get wind of you installing an “improper” voltage reg  or even prop for that matter. The only time I’ve ever seen that become an issue is when one mechanic calls the FSDO on another because they are fighting, once there is a written complaint, the FAA must respond.

I’ve seen aircraft with complete tails from a different aircraft on them, entire firewall forward assemblies from other aircraft in them, certainly wrong engines and props before. 

I’m not saying do that, because I’ve seen people come very, very close to Prison time for less

Its I think like being on some kind of forum where people fly simulators of aircraft, so therefore they think they know what actual flying is like

[Shadrach]

5 minutes ago, tony said:

Ross, I really don't think you know how the FAA works, I probably need to say doesn't work.  The FAA has ACOs, MIDOs, FSDOs, and none of the talk to each other.  The engineering side would agree per 14CFR21.93 (a) would say this is a minor change.  But the operational side who holds airworthiness in their hand says, there is no engineering to support the change.   So here we are, stuck in a place where they airplane sits on the ground for paperwork.

Life is short and Id rather go fly then argue over who is right.  

The OP needs to just draw up a an engineering drawing that supports this change in his specific airplane, throw an 8110 on the engineering (not the part), and then use that with the FSDO.  This happens everyday.

I have a pretty good idea of how the FAA works. Which is why I suggested they really don’t need to be involved. It’s a minor alteration. The problem is that so many interpret the regs to say what they think they mean rather than what they actually say. So the problem is not returning it to service. It’s keeping it in service when another IA looks at it several years later.

[A64Pilot]

If anyone cares, this is a little history of how the IA came about.

https://www.aviationpros.com/aircraft/maintenance-providers/article/11281307/faa-feedback-the-rest-of-the-story

See FAA or CAA employees and or designees have ALWAYS carried personal liability, the FAA of course works hard to ensure they aren’t liable though. 

[Jetrn]

update: After numerous phone calls with voicemails once a week; in fairness the owner does leave a voicemail later in the day, today called 5x, text and email. The owner did reach out via text and state his tech is still on medical leave and is struggling to hire, and struggling to keep the company open. I did ask him to not to repair my voltage regulator and send it back to me and he did as requested, should arrive thursday. International avionics did have my voltage regulator for 2 months. In fairness my plane was down for other problems, propeller overhaul, cowl flap motor overhaul, carpet install, pilot seat articulating seat support bar was crack and need to be welded.. As of today the plane is back together, seat will be ready on thursday and just need the voltage regulator.

My plan: Discussed with IA, he's in the camp I need a 337. I do see both sides of the argument. I ordered 2 voltage regulators today from aircraft spruce and should arrive on Thursday.  My old voltage regulator will arrive on Thursday also. I will reinstall old voltage regulator for now and fly with 1 inop regulator. For those who asked the voltage regulator PN 9500581001. The retrofit kit is 940170-503. I looked through my logs and there is no entry for this voltage regulator with a build date 0507. I reached out to laser today but they don't have the installations drawings. I will reach may reach out Maxwell also. I had to send email to mooney tech support but they are out of office until September 5. Plan for 337 is to submit retrofit drawing and plane power installation drawing and installation manual as part of paper package for field approval.

I did reach out to the Sacramento FSDO today and left a voicemail as instructed. I will try and find and email of an inspector to inquire they would like to see as part of the paper package. I may also try the Oakland FSDO.

I will update as things progress further and thank you for the discussion.

 

[Yetti]

17 hours ago, mooniac15u said:

That is a 14V regulator. OP said he has a 28V system.

My understanding is he has dual voltage regulators.   That being said it looks like Zeftronics has DARs on staff so they could design and approve what is needed.

[Yetti]

Just now, Yetti said:

My understanding is he has dual voltage regulators.   That being said it looks like Zeftronics has DARs on staff so they could design and approve what is needed.

And what is funny about all this is it looks like Zeftronics are using PWM as the technology to regulate the voltage in a fancy box with a Cannon plug.   Could probably buy off the shelf for $75.00   YMMV

[mooniac15u]

31 minutes ago, Yetti said:

My understanding is he has dual voltage regulators.   That being said it looks like Zeftronics has DARs on staff so they could design and approve what is needed.

Dual regulators to manage two alternators on a 28V system.

[FlyingDude]

On 8/18/2024 at 2:25 PM, Jetrn said:

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 don't know if this was answered before.  Did you ascertain that the Planepower regulator is matched with the alternator you have on your plane?  A certain change in field current is going to translate into a certain change in voltage at a certain load.  Most probably those 2 alternators have different stators and rotors.  If the pulley diameters are different, that already shows you that their load profile lies on different rpm ranges...  Therefore their control loops will be different. leading to malfunction.  You cannot just assume that those 2 alternators can be governed by the same regulator just because they are fitted on the same Mooney model.  It may be the case, but it cannot be assumed...

Then again...  As you are an AP, installing the new alternator should not be too much of a problem for you.  It is for sure time consuming, but certainly within your capabilities.  Why don't you just get the full planepower kit and be done?  How much will you save by keeping the old alternator and getting the new regulator (assuming it can be done technically and legally).  I don't know if you've addressed this before.

[201Mooniac]

9 hours ago, Jetrn said:

I did reach out to the Sacramento FSDO today and left a voicemail as instructed. I will try and find and email of an inspector to inquire they would like to see as part of the paper package. I may also try the Oakland FSDO.

I really wish you good luck with this and hope you are successful getting this done but when I tried to replicate a field approval that had previously been approved  I was told don't even bother trying as they won't approve it.  I asked what additional information they would need and they told me to speak with a DER but not to be hopeful.  This was to add a B&C standby alternator to my M20J.  This was during COVID though so maybe they have loosened up a bit, at least I hope so.  If they approve this for you maybe I'll take another go at my project.

[Marc_B]

@Jetrn I wonder if there is any chance that Ken Pethe (IAI) could speak with Don Maxwell to get your VR's overhauled given the circumstances?  When I dealt with this before, I called Maxwell and he said he could overhaul them unless they were labeled IAI and if so they needed to be sent back to them.  If there is an issue with getting this done at IAI, perhaps Maxwell's tech could still do it with approval from IAI??  Not sure the reason or background as to why Maxwell wouldn't service IAI VRs?

I suspect that the boxes are simple electronics that could easily be serviced with the specs found in the Mooney Service Manual.

I also called Zeftronics and Plane Power and they said they didn't have a 28V VR for a dual alternator system that would work in my Mooney...or perhaps they just said that as they didn't have one that was STC'd for the M20K dual alternator??

[Shadrach]

1 hour ago, FlyingDude said:

I don't know if this was answered before.  Did you ascertain that the Planepower regulator is matched with the alternator you have on your plane?  A certain change in field current is going to translate into a certain change in voltage at a certain load.  Most probably those 2 alternators have different stators and rotors.  If the pulley diameters are different, that already shows you that their load profile lies on different rpm ranges...  Therefore their control loops will be different. leading to malfunction.  You cannot just assume that those 2 alternators can be governed by the same regulator just because they are fitted on the same Mooney model.  It may be the case, but it cannot be assumed...

Then again...  As you are an AP, installing the new alternator should not be too much of a problem for you.  It is for sure time consuming, but certainly within your capabilities.  Why don't you just get the full planepower kit and be done?  How much will you save by keeping the old alternator and getting the new regulator (assuming it can be done technically and legally).  I don't know if you've addressed this before.

I did not address it specifically, however I “assumed” compatibility after referring to the TCDS (see my earlier post.) The 24V M20J and M20K do indeed have different alternators (TCM and Lycoming specify different accessories), however both 24V J an K systems specify the same voltage regulator options (Precise Flight DGR-2 or the Electrodelta VR802). Perhaps I’m all wet. Being that you’re an electrical engineer, perhaps you can shed light on how a voltage regulator that is approved as a drop-in replacement in one application would be out of spec in another when the component being replaced is the exact same part number?

[kortopates]

Personally, i think this is the wrong place for the discussion and that it should be with your FSDO PMI.

But real point of my discussion is that Consolidated Aircraft in New York has most of the drawings for the Mooney 28V regulators and should be able to IRAN yours with paperwork.
If they don’t have the drawings they can still repair it without paperwork.

see https://www.consolac.com/

No need to buy a new $$ one!


Sent from my iPhone using Tapatalk