FAA approval

[debiassi]

Hi there, anyone out there had any dealings with FAA DER's in obtaining DER approval for major modifications. I recently bought a mooney 252 from Switzerland and imported it to the UK via Denmark for obvoiuse tax efficiency reasons. After going through the process of switching to the N register, I now have to prepare all oif the paperwork for the DAR to issue the certificate of airworthiness. I was led o believe that there were bi- lateral agreements in place between EASA and the FAA but there are still un solved issues in respect to those. So the route is to obtain DER approval for any modifications that dont have existing TC's STC's etc. The main issue is that a garmin 430/340/330 stack was installed and fully coupld to the autopilot. This was done in Switzerland and certified as a major mod by the Swiss FOCA. But the FAA say that this isnt acceptable and the mod has to be resubmitted to an FAA approved Design Engineering Representative. I had to have a Garmin agent reproduce the drawings and then submit them to the US and was told the process would take a couple of weeks and amount to in the region of 2500 us dollars. This was almost 2 months ago. Has anyone come across and ovecome similar problems and if so through which company and in what time frame.

[AC-DC]

$2500? :mad::mad:
6 years ago I was quoted $750 for the same thing.

[IO540]

Most UK avionics etc shops use D.E.R. Associates (http://www.derassociates.com) who I believe charge around 300 bucks per signature.

But somebody has to prepare the stuff to send to them.

[Genghis the Engineer]

I'm not an FAA DER, but have a similar UK status. Realistically, I might not charge you that little. US$2,500 sounds pretty good value for a major mod.

G

[IO540]

There might be a lot more to this, both ways.

This plane is going onto N-reg, and FAA Major Mods are listed in Part 43 Appendix A. Everything not in that list is not a major mod. But it could fall under a different heading.

However, I have heard of installations like this, being just avionics, done as a minor mod, and why not? It isn't structural, and the installation is no rocket science; you basically install the kit and wire it up as per the wiring diagrams in the back of the installation manuals. Most avionics installers are basically wiremen.

The items may even be on the Mooney type certificate... in which case no approval at all is required.

EASA makes a big meal out of avionics, for no justifiable reason.

This is why, sadly, one needs to ask different avionics shops how they would do it, and use the one which is pragmatic. One needs to only follow the law as it is written; there is no need to over-interpret the regs.

A 337 for the kit mentioned, if one is necessary, could come to 4 digits.

[Genghis the Engineer]

I suspect that it's the autopilot coupling which makes it a major mod; otherwise, I'd agree that this was minor on most aeroplanes.

G

[IO540]

Yes, quite possible. No further details have been posted... Normally, a GNSx30 would couple to a modern AP using ARINC i.e. a few wires, no big deal. It's interesting why that makes it a major mod. Especially as, more than likely, the AP is the type on the plane's type certificate.

[Squeegee Longtail]

"I'm not an FAA DER, but have a similar UK status. Realistically, I might not charge you that little. US$2,500 sounds pretty good value for a major mod"

... and that'll be why a lot of people go to the N-reg then.

[IO540]

Yes. While routine scheduled maintenance is hardly different between N and G, the modification approval regime is much better under N.

The FAA regs still leave plenty of scope for a creative interpretation, but at least they are mostly written down, making it easier to separate a major mod (which needs a 337, DER, etc) from a minor mod (which can be field installed so long as certain requirements are met).

Also never forget what a lot of people do forget: if the gadget you are fitting is on the aircraft type certificate (for the applicable airframe S/N range) then it can go straight in - no approval is required. The TC is what enables the aircraft manufacturer to build the planes in the first place :) The mfg doesn't have to apply to EASA or FAA for approval for the GNS530 they screw in on the production line...

[debiassi]

Not exactly sure what makes it the major mod, may well be the autopilot coupling. There are a couple of other issues which have 337's for conformity. It took a while to find the correct procedure to follow, I'm not questioning the amounts I have been quoted, I have already agreed the price, its time its actually taking after originally been told it would be a two week process. I am also now informed that the same outcome can be obtained by having an approved faa avionics shop inspect and certify the installation.