A&P Won't sign off Annual with EI EGT Analyzer

[AlanA]

My "J" is ready for its first annual since I bought it one year ago.  My new mechanic refuses to sign it off because the original EGT has been replaced with a EI analyzer which he says is not a "primary" part. He wants me to replace it with the old original part.

 

He also has an issue with the nav lights  because the nav lights were replaced with LED lights and don't have a Form 337.  So I am wondering why the last eight mechanics didn't have a problem with it?

 

Also, the "J"  I owned before this one had the same 4 cylinder EGT/CHT guage and that passed as well.  I've seen the same gauge in several other Mooneys too.  I would consider going back to a one cylinder engine monitor a safety issue.  Why would I want to return to monitoring one cylinder when  I have the EI instrument which monitors all four cylinders EGT's AND their CHT's?  And I would consider the LED lights much safer than the original and hotter nav lights too.    I mean is replacing a nav light really a MAJOR alteration that requires a 337?

 

Am I the only one that thinks that these two issues are ridiculous????

[jetdriven]

Is the EGT required instrumentation?  What about the LED's, did you replace the bulbs with LED? That might be a problem. However, the IA cannot refuse to sign off the annual.  He can do the annual, and either sign it off as airworthy or provide a list of discrepancies to the owner. Either way, the annual inspection is done. Repairs are a different matter.

[Jamie]

I don't know the specifics of your situation, but I have an engine monitor that uses a bayonet probe (I'm repeating what I was told... I don't know exactly what is in there), that apparently allows the factory CHT gauge to still work. What does this mean for me? Oh, only that I have a gauge I never, ever look at (factory CHT), and a #3 cylinder that always reads colder than the rest. How this improves safety, I have no idea.

[Marauder]

To Byron's (jetdriven) point, if the single probe EGT is not on the equipment list as required equipment, then it is optional. On my 1975 F, the EGT was an optional accessory and not required in the plane. As for lights, it all depends. If the swap over to LED required a weight and balance change (ex. Removing the strobe ballast) some mechanics consider this a major change and will file a 337. I think if you look through anyone's aircraft logs, you will scratch your head why some things are documented a certain way.

[nels]

I can see your point, unless I'm missing something.

I'll bet that will be the last annual he performs on your plane.

[FAST FLIGHT OPTIONS LLC]

As jetdrive stated he signs the log indicating the annual was completed and the plane is airworthy or the annual is completed and the following discrepancies were noted. If he's refusing to do either dont pay him, get in the plane and leave with it. Simple right?

[N601RX]

On my F the Egt is listed as optional equipment. Also some of the older EI engine monitors list cht and egt as primary, so check your model. IF just the nav bulbs were replaced with led bulbs and the original fixtures are still in place, just stick the original style bulbs back in so he will sign it off. If the entire fixture was swapped out, as long as they used a TSOd fixture many mechanics consider that a minor mod.

[NotarPilot]

I think Marauder hit the nail on the head. If the original EGT gauge was part of the equipment list as "required equipment" then the original EGT gauge should never have been removed. The EI analyzer is pretty much supplemental and can't replace any gauges unless specifically certified to by the FAA which would probably need an STC for that installation.

As for the LED lights I recently went through that ordeal with my local FSDO. The FAA maintenance inspectors I dealt with believed I needed a 337 and field approval to be legal and were able to explain why in great detail. I went so far as to speak with two other maintenance inspectors from two other FSDOs and one agreed with my FSDO while another one said I only needed a logbook entry from an A&P to be legal but I could just submit a 337 to be legal. How's that for consistency? My A&P IA said a logbook entry and 337 was all that was needed but I made the mistake of calling the FAA before anyone else when I started the process, thereby putting them in the loop, which I should never have done in the first place. Lesson learned, talk with your mechanic first.

In the end I got field approval from the FAA and they stamped my 337 which I mailed off to OKC and put a copy in my logbook. IAs all have differing opinions on that stuff. But let me ask you, are the LEDs you have TSO'd or PMA'd? What do you have? LED nav lights? Landing lights? Strobes?

[scottfromiowa]

You did NOT list the EI. I did not "supplement" the single probe Cylinder temp and exhaust temp with installation of my G3 that is CERTIFIED PRIMARY for exhaust and cylinder temps...I REPLACED THEM. When I had a NON-CERTIFIED GEM unit I KEPT the original "PRIMARY" gauges. When I added the G3 I REPLACED the existing old analog gauges. Was the GEM BETTER as it provided four cylinder vs. one digital readouts, YES. There are "rules" and we must follow them for our certified aircraft. I still have original fuel "quantity" gauges AND the housing for all six as THIS was how they were mounted and so was maintained.

I would love to see the regs and liability such that modifying/selling improved fuel quantity indicators that are DIGITAL would NOT be such an issue...but as long as folks that seem to function and have mental comprehension routinely run their planes out of fuel and bend metal and hurt themselves and others because they Run themselves out of fuel...we won't get there.

If your EI is NOT certified PRIMARY you need the original single probes in the aircraft. I don't see the value in upgrading to LED position lights. I have never had a bulb fail. I would rather have wing strobes and a HID landing light for safety upgrades.

There are other great threads on the nuances of LED light installation and the "regs". Coming from EAA it is fun to see what the experimental airframes can "pop in their planes". Some really nice functional avionics that I/we just can't LEGALLY install/have someone install in our plane...for now anyway.

[takair]

Alan

As everybody said, this is not consistent IA to IA and FSDO to FSDO. In the case of the EGT, it is interesting that the EGT is not listed in the TCDS, but called out for leaning purposes in the AFM (at least for my model). Typically, the TCDS lists required equipment. You may want to discuss this fact with your IA. To complicate matters, the EI documentation (for older EIs) specifically says it does not replace the primary gauge. So, in the case of a Mooney....it becomes a gray area. I think other OEMs list it in the TCDS.

As to the LEDs, if TSOd, a log entry is an easier argument. That said, a field approval is not hard and avoids the argument in the future. I'm doing one as we speak for some TSOd replacements. Ask your IA if he would do the paperwork for the field approval.

[orionflt]

The Egt is not a primary instrument fot the mooney, that being said EI has had most all of their instruments certified as replacements for the primary. As for the led nave lights, are they a complete replacement of the assembly's? If they are a 337 is required, if you just used the $30 led bulbs then there is no problem at all. You can use your POH to prove to your mechanic the EGT is acceptable, and you can get info on the LEDs from the manufactures web site. My personal opinion is it my be time to find a new mechanic.

Brian

[N201MKTurbo]

Is the EGT required instrumentation?  What about the LED's, did you replace the bulbs with LED? That might be a problem. However, the IA cannot refuse to sign off the annual.  He can do the annual, and either sign it off as airworthy or provide a list of discrepancies to the owner. Either way, the annual inspection is done. Repairs are a different matter.

 

 

If an IA identifies discrepancies, his job is done, but an A&P needs to address the discrepancies and return the plane to service. In most cases the IA and A&P are the same person, therefore he can hold your plane hostage. You can always take your plane somewhere else to get the work done, although you may need a ferry permit to fly it somewhere else.

 

As for 337s, what is the big deal, fill it out and send it in.

[Alan Fox]

The Egt is not a primary instrument fot the mooney, that being said EI has had most all of their instruments certified as replacements for the primary. As for the led nave lights, are they a complete replacement of the assembly's? If they are a 337 is required, if you just used the $30 led bulbs then there is no problem at all. You can use your POH to prove to your mechanic the EGT is acceptable, and you can get info on the LEDs from the manufactures web site. My personal opinion is it my be time to find a new mechanic.

Brian

I just looked at the EI stc , and it states , That it is for advisory info only , meaning that it is not certified primary....STC and TSO have absolutely nothing top do with an instrument being primary......Also just because an item is not on the TCDS does not mean it is not required.....

[aaronk25]

This is dumb.......do the bureaucrats at the FAA even like airplanes?

I had same issue with the FAA not approving my HID landing light so I said screw it and put it in anyway and told the IA that does my annual he needs to turn a blind eye to it or I'm not giving him my business. I'd go experimental if there were similar priced birds 80k that offer everything the mooney does.

[danb35]

Also just because an item is not on the TCDS does not mean it is not required.....

Since the OP didn't identify which EI monitor he has installed, there's no way you could have checked "the EI stc".  The MVP-50 is a primary replacement instrument for any required engine instrument, but the UBG-16 isn't.  However, if there's no regulatory requirement for an EGT gauge on an M20J, there's no problem with removing the factory instrument.  If it isn't in the FARs (which it isn't), and it isn't in the TCDS (which it also isn't), what would make it a required instrument?

[danb35]

As for 337s, what is the big deal, fill it out and send it in.

Sure, filling out a 337 is easy.  What can be difficult is finding a source of "approved data" to support your major alteration or repair.

[NotarPilot]

As for the led nave lights, are they a complete replacement of the assembly's? If they are a 337 is required, if you just used the $30 led bulbs then there is no problem at all. 

 

I have to say I disagree with this comment.  Shortly after buying my J I purchased the LED replacement bulbs from Spruce for 30 bucks and change.  I even installed them in my plane and everything looked great.  Before I went flying I spoke with an FAA inspector I know and asked him if they were kosher.  With no uncertain terms he said they absolutely were not legal on certificated aircraft.  For a moment I thought "Eh, so what?  Who's gonna to notice?" and considered leaving them on.  But then I thought what would happen if I ever had an accident or incident and my insurance company found out I had knowingly put unapproved parts on my aircraft and might not cover my claim.  Therefore I decided take them out and return the bulbs.  I later got the TSO'd Whelen product, got a field approval and submitted the 337.  Now I don't have to worry about it.  

 

And if you look at the bottom of the item description for those $30 LED bulbs on Spruce you'll see they are described as "Non-PMA."

 

If you insure your plane, which I'm assuming you do, I would guess your policy says your plane has to be airworthy and in-annual to fly.  So just something to really think about.

[bumper]

If you insure your plane, which I'm assuming you do, I would guess your policy says your plane has to be airworthy and in-annual to fly.  So just something to really think about.

 

I've hear this concept repeated often, though I've never heard of a specific example where a claim has been denied due to something awry that was not directly causal. Not saying it hasn't happened, just that I think it the rare insurance company that would even attempt to weasel out of paying such a claim. Case decision holds that unless something is causal and/or involves gross negligence, or something that is specifically excluded in the policy, the insurance company will cover the claim - - and sometimes even when the insured *logically* shouldn't be covered. I know Avemco covers me even if I forget to get my medical renewed in a timely manner and fly without it . . . same goes for aircraft annual. Mistakes happen. Avemco, and I assume other good insurance companies cover you anyway. (Not meant to be legal advice - - check your policy to be sure.)

 

Think about, if this were not the case, the insurance companies would be all over every accident, inspecting each aircraft with a fine tooth comb trying to find any nit that would get them off the hook. And if they behaved in such a manner, customers would quickly go elsewhere. Some insurance companies specifically allow behavior that might not sound reasonable to some, like landing airplanes off field. (Avemco covers my Husky even though I play in the dirt.)

 

bumper

[1964-M20E]

As someone said before have the IA sign off the annual with discrepancies and pay him for the annual and leave.  IMHO this guy is being an a$$.  If he refuses to sign off on the annual have him put that in writing and the take your plane and fly as fast as you can away from there.

 

This is the advantage of having your annual completed before it expires then you can legally fly off weather the IA signs off the annual or not with nothing else since your previous annual is still in force.

[orionflt]

I have to say I disagree with this comment.  Shortly after buying my J I purchased the LED replacement bulbs from Spruce for 30 bucks and change.  I even installed them in my plane and everything looked great.  Before I went flying I spoke with an FAA inspector I know and asked him if they were kosher.  With no uncertain terms he said they absolutely were not legal on certificated aircraft.  For a moment I thought "Eh, so what?  Who's gonna to notice?" and considered leaving them on.  But then I thought what would happen if I ever had an accident or incident and my insurance company found out I had knowingly put unapproved parts on my aircraft and might not cover my claim.  Therefore I decided take them out and return the bulbs.  I later got the TSO'd Whelen product, got a field approval and submitted the 337.  Now I don't have to worry about it.  

 

And if you look at the bottom of the item description for those $30 LED bulbs on Spruce you'll see they are described as "Non-PMA."

 

If you insure your plane, which I'm assuming you do, I would guess your policy says your plane has to be airworthy and in-annual to fly.  So just something to really think about.

I stand corrected about the bulbs, when they first came out the consensus in my area was they were just a replacement bulb, when i just looked into it again it now appears you can install them but you need a 337 and field approval.

thanks for catching this

 

brian 

[Cruiser]

On certified aircraft the FAA views each plane as meeting that criteria when signed off from the factory new. After that, any part of the plane must be shown to meet the original certification criteria.

maintaining airworthiness is done by:

 

1. remaining the original OEM part as installed at the factory

2. PART 43—MAINTENANCE, PREVENTIVE MAINTENANCE, REBUILDING, AND ALTERATION

     a. STC - paperwork

     b. Major repair/modification - form 337

     c. Minor repair/modification - log book entry

 

there are no other choices.

 

Example: as owner you can do preventative maintenance such as replacing light bulbs. This means removing the existing bulb and replacing it with the EXACT SAME BULB. If you put in a different bulb, you are MODIFYING the original design/certification and must comply with #2 above

[jlunseth]

I think that, particularly with respect to Mooneys which tend to be older aircraft, what is required to be in the aircraft and operating in the form of parts identical to those in the aircraft at the time it was certified, is a ocmplicated subject. I think that is particularly true of some of the gauge and instrumentation issues, such as this EGT question.

All Mooneys (and other certificated aircraft) are born under a Type Ceritificate. The TC for all the M20's is at http://www.67m20e.com/Mooney TCDS 2A3 Rev 52 dtd 9DEC10.pdf . The "Required Equipment" list is in the TC. For the J, it says:

In addition to the pertinent required basic equipment specified in CAR 3, the following

items of equipment must be installed: 1(a)(1) or 1(a)(2), ( , ©, or 2(a)(1), 2( (1) and

1©, 101(a), ( , or ©, 102(a), 103(a), 104(a) or ( , 201(a), 202(a), 205(a), 206(a),

301(a) and 303(a), 301( and 303( , 302(a) or ( or ©, 401(a) or ( or © or (d) or

(e) or (f) or (g) or (h) or (i) or (j) or (k) or (l) or (m), 601(a), ( or ©, 602(a) or ( or ©

or (d) or (e).

Very helpful, right? BTW all the emoticons that show up are the websites translation of the footnotes, not my own.

All of the numbers in the paragraph are footnotes to the TC that list items of equipment, makes and model numbers that can be used. In addition to the TC, the paragraph requires that the aircraft comply with CAR 3, which is the older version of the FAR's. There is a Basic Equipment provision at 3.655 which is the familiar "tomato flames" and that lists what (in addition to all the stuff in those footnotes) needs to be present in the aircraft and operating for the aircraft to be airworthy.

There is also an "Equipment List" in the POH. However, that list is misunderstood. It is in the Weight and Balance section of the manual. For each piece of installed equipment, it shows the weight and arm of that piece. If something is removed or substituted that shows up on this list, a new weight and balance has to be created. However, the list does not say that the equipment in it needs to be operating for the aircraft to be airworthy, the equipment needs to be there and in its original location for w&B purposes.

So you should go through the list in the TC and see if there is a requiment of an EGT gauge. I did a quick look through and I did not find one. And this, I believe, is key to the issue of whether an "STC'd as primary" gauge needs to be in the aircraft if the original gauge is removed.

If something is "STC'd" for an aircraft, it simply means that it can be installed in the aircraft. So assuning a gauge is required equipment under the TC, you can have your original factory gauge in the plane, and also install a supplemental gauge like the EI, and it is perfectly legal. However, if a gauge is required equipment, it cannot be removed and replaced with something else unless the replacement is STC'd as the primary readout for that function. One of the issues with replacement is that many required equipment gauges are, by design, part of a system. So while you are thinking only in terms of the gauge itself, the gauge as installed as primary in a system, may have a backup and/or an annunciator and that system was part of the approval process. Further, if the substitute gauge has a different means of being powered up, let's say it is electrical while the original gauge was vacuum or pressure operated, then there may be a need in the FAA's eyes for some kind of monitoring or annunciator on the power source. If the alternator goes, you have no power for that gauge that was once powered by, let's say, vacuum, and there was an annunciator on the vacuum. Complicated.

So the issue of what is supposed to be in a Mooney and operational is not so simple, and I think A&P's can be forgiven for sometimes applying what they may know about more modern aircraft systems, to Mooneys and other older aircraft.

From my quick look at things, I don't think there is any requirement that a J have an EGT gauge, either in the TC/Required Equipment list, or in the CAR's of the FAR's that superseded them. That said, if the EGT was in the "Equipment List" of the aircraft and was removed without redoing the w&b you do have an airworthiness issue, there is no legal w&b.

Another way of looking at it is to check the Limitations section of the POH. If there is a redline for an item you can bet there is going to be a corresponding gauge for a readout on that item and it is going to be part of the Required Equipment. I don't have a J manual, I have a K, but I don't see a redline on EGT's.

Those are my thoughts.

[danb35]

This is the advantage of having your annual completed before it expires then you can legally fly off weather the IA signs off the annual or not with nothing else since your previous annual is still in force.

Incorrect.  If the IA has noted discrepancies, you must have those discrepancies corrected, or obtain a ferry permit, before further flight.  A discrepancy means the aircraft is unairworthy, and it's a FAR violation to operate an unairworthy aircraft (and it'd be pretty hard for you to argue that it was inadvertent if your IA has specifically informed you of the squawk).

[AlanA]

The EI analyzer is a EI SR-BAS.  I know what I am going to do.  I am going to leave the "non-primary" EI gauge there  and reinstall an original EGT gauge even though I will never look at it.  This way I will be legal but also have the safety factor of having all cylinders monitored.  As for the nav lights I am going to replace the bulbs or get a field inspection. 

 

Neither issue is a cost burden.  What makes me mad is the inconsistency with these and other issues like these.

Thanks for all your good comments and ideas!

[201er]

I am going to leave the "non-primary" EI gauge there  and reinstall an original EGT gauge even though I will never look at it.  This way I will be legal but also have the safety factor of having all cylinders monitored.

The whole point is that when it comes to EGT, you don't need to have an original EGT gauge to be legal! I had both for a while but when I needed panel space my factory EGT had to go. Several mechanics have seen my plane with it gone and never a problem. Using some of the arguments previously listed I've been getting by just fine.

 

That said, if you're crazy enough to install one anyway, I have a factory EGT/OAT sitting around I can sell.