Fitting "non certified" avionics as secondary instruments

[Papa Whisky Alpha]

I have read this thread with interest. I have just returned from the Flying Show at the NEC where my wife bought me an "Aware" as a Christmas present. Am I invalidating my ARC and / or C of A if I fit this device in my a/c ? I note on the blurb that the CAA has commended it.

PWA

[IO540]

Wigglyamp raises an interesting point about the NY IFO not processing 337s anymore.

I found this too, when i tried to get a GPS approach approval for my plane. They gave the avionics shop (the last of the three that tried this) a right run-around, clearly not wanting to do it.

The DER route to get around this is a good one but is a lot more expensive...

Isn't there one other option which is to fill in a 337 (which needs an IA, etc) and send it off, wait for X months, and if one hears nothing, one can install it as proposed? That way, the NY IFO not co-operating would not matter.

[Fuji Abound]

My experience comes form some years back wanting to fit a moving map GPS. There wasnt a convenient space in the panel so I explored various other options.

It is attractive to think that the installation would be straight forward, however in the design assessment it is clear there is much to consider, including the ability to read and operate the instrument, the instruments impact if any on cockpit visibility, electrical safety and integrity of the fitting. In reality none of that is unreasonable.

I am most certainly not one for over regulation and the costs involved and hassle in mod approvals of this sort maybe out of proportion, however, I think the principle is sound - which is that if you fly a certified aricraft the C of A provides some comfort professional expertise has been applied to the selection and installation of the equipment fitted.

You may believe you can do as good a job in making this assessment as an approved shop (and doubtless some can) but some equally cant.

[maxred]

Recent certification

I have just been asked to remove, not only the Garmin hand held unit, but the temporary mount on the dash due to 'not on the original equipment list'.

I have been told that anything, not covered by an STC, or incorporated by a certified original equipment list, cannot remain at time of certification, and for subsequent inspections. - N REG

[englishal]

Can't it be signed off on a 337 ?

Don't 337's go to Heathrow these days?

[maxred]

Not sure where the form goes, but my understanding is that the 337 is for Major Repair/Alteration.Almost like a new STC application, which as IO poiints out could take months.

I capitulated in the case of the GPS, by temporarily removing it for an easier life.

These issues, (normally) crop up when you fall foul of the regs, as in the case of certification (new), or major sign off work.

The situation is of course correct, in that the equipment, if altered since manufacture, where it was certified, to be replaced by anything 'non certified', must be removed for sign off. A fair enough point I think.

[Pilot DAR]

Being a Canadian guy, eh, I will not claim to know all the ins and outs of the FAA 337 form system. What I do believe, however, is that "approvals" for modifications by "337" are being issued by the FSDO (flight standards distric office), as opposed to the ACO (aircraft cerification office). As I mentioned earlier, the possible absence of the aircraft certification perspective in the "approval" process, may result in an oversight of a certification consideration. That is not to say that the "mechanic's" perspective is not very valuable, and appropriate, it just might not be complete from a "showing of design compliance" perspective.

I hold this opinion, because there is history of 337 "approved" modifications not being accepted by Transport Canada, when an American aircraft is imported into Canada. I have had to issue new STC approvals to cover a mod found to be on the aircraft by 337, which the purchaser could not, or was unwilling to, remove.

Of course things get carried away, and I can say that 5% of inquiries I receive about approving a mod, I send away with advice (sometimes a letter) as to why my evaluation says it's not even a mojar mod, and does not require a formal approval. The measure I use (with some caution for interpretaion differences) is found here:

Okay... I'll put it up later, it seems Transport Canada's website is down right now.

[wigglyamp]

Form 337

There seems to be some confusion on when/how the 337 is used. In the US, most 337s are used as part of a 'Field Approval'. In this way, the FAA FSDO inspector approves the data that is used for the modification (this could be a follow-on from an existing STC that isn't directly applicable to the subject aircraft), or it could be the manufacturer's installation manual. The FSDO inspector will make a statement in box 3 confirming approval of the data. One the installation has been carried out, the repair station or IA will make the box 7 approval for return to service after the A&P or repair station has cleared box 6 for conformity of the modification to the apprpoved data, which will be listed on the back page of the 337.
In the alternative case, the installation data will already be approved by an STC (this may be an AML STC with hundreds of aircraft listed such as for the JPI EDM700), or it could be data approved by a DER on an 8110-3. In this situation, the IA or repair station will just sign the box 7 and there will be no FAA entry in box 3. Once the aircraft is released to service via the 337, the completed form is sent to FAA in Oklahoma, not to the FSDO.
Therefore, in all cases, the 337 must be completed and signed with approved data of some form BEFORE the aircraft can fly. You can't submit an un-approved form to a FSDO or ACO and believe that you can fly whilst waiting for it to be signed off.
For a minor change, the 337 is not used. A minor change just requires a logbook entry.

[IO540]

I have been told that anything, not covered by an STC, or incorporated by a certified original equipment list, cannot remain at time of certification, and for subsequent inspections. - N REG

You have been told bollox, like so many others..... who told you this? Email me if you prefer. Whoever told you this cannot spell

mike
india
november
oscar
romeo

mike
oscar
delta

Don't 337's go to Heathrow these days?

AIUI, 337s go to your local FSDO, and "your local FSDO" in Europe is the NY IFO.

the 337 is for Major Repair/Alteration

Exactly right. Add "only" after that, too

I capitulated in the case of the GPS, by temporarily removing it for an easier life.

That is fair. But you could have installed a power connector in the dash, and got that signed off. It would need its own CB otherwise it cannot be signed off (meaninfully).

there is history of 337 "approved" modifications not being accepted by Transport Canada, when an American aircraft is imported into Canada. I have had to issue new STC approvals to cover a mod found to be on the aircraft by 337, which the purchaser could not, or was unwilling to, remove.

EASA do that all the time, to FAA certification.

They like to quote famous accidents which involved bodged work. This is a ripe area for digging out examples - just like the Private Eye has a very easy time nowadays with so many of today's politicians being crooked What they ignore is that a lot of work done by EASA shops is also crap, and a lot of potential safety enhancing equipment is not installed in Europe because the paperwork is prohibitive and/or it is so difficult to find an avionics shop which understands the regs. I have heard some appalling stories from Germany, on a friend's plane, where EASA caved in only when the owner told the avionics shop to abandon the project, and they would have lost their approval fees.

On an N-reg, there is a theoretical route which uses a US-based (inland) FSDO. This is possible because the aircraft is anyway owned by a US citizen/company, and if the address is in the USA, the FSDO will have no way of knowing the aircraft is actually living outside the USA. This is difficult because one needs to assemble gold plated paperwork that enables the package to be presented by a US based IA who probably has not seen the aircraft. It can be done in some cases where sight of the aircraft is not necessary; for example this is the case with EASA GPS approach approved flight manual supplements which is just a paperwork purchase.

In the alternative case, the installation data will already be approved by an STC (this may be an AML STC with hundreds of aircraft listed such as for the JPI EDM700), or it could be data approved by a DER on an 8110-3. In this situation, the IA or repair station will just sign the box 7 and there will be no FAA entry in box 3. Once the aircraft is released to service via the 337, the completed form is sent to FAA in Oklahoma, not to the FSDO.

Is the above "send in the STC and wait for no reply procedure" usable only with an STC for that airframe S/N range (or an AML STC)?

[wigglyamp]

There is no 'Send in the STC and wait for no-reply procedure'. The aircraft cannot fly once modified via a Major change or STC until a Form 337 is fully completed and signed off with correct data. The submission to FAA in Oklahoma is for record keeping and not for approval.

[IO540]

There is no 'Send in the STC and wait for no-reply procedure'. The aircraft cannot fly once modified via a Major change or STC until a Form 337 is fully completed and signed off with correct data. The submission to FAA in Oklahoma is for record keeping and not for approval.

I meant doing the 337 before the work is done.

AIUI, one is entitled to seek an FAA ruling on a proposed mod, and if they don't object, you can do it. Is this absolutely not true? It appears to be a standard US procedure.

[wigglyamp]

Yoy are correct in that for a field-approval, you should seek the agreement of the FSDO and get them to sign box 3 before the work is done, so that immediately on completion of the mod, the IA or repair station can return the aircraft to service using Box 7. However, if the FAA don't reply, this is not an acceptance, and unless the 337 is correctly filled out and approved, the aircrat still can't fly.

[IO540]

OK, so one can send a 337 to Oklahoma, and one has to wait to get it back.

That's fair enough.

That is surely a useful option for cases where the NY IFO is not playing ball.

Has anybody tried this?

Of course if Oklahoma simply says "this is foreign" and passes it to the NY IFO which then bins it....

[wigglyamp]

Sorry - you're missing my point. Oklahoma just record the completed 337 - they don't approve it. It you want to get a field-approval on a 337, you have to go through your FSDO. In 20 years of doing small aircraft, I've never managed to get a 337 field-approved in UK, so always use the DER-approved 8110-3 route.

[Pilot DAR]

Okay, TC's website seems to be working again. This document is the "test" for your proposed mod being "major" or not. It is guidance, not the last word, but it get's you close for knoiwng which route to follow, minor mod logbook entry, or STC approval...

Part V - Standard 571 Appendix A - Criteria for the Classification of Modifications and Repairs - Transport Canada

[IO540]

Some interesting wording in there...

(8) reduce the storage capacity of the primary battery?
(9) affect a communication system required by the approved type design?
(10) affect instruments, or indicators that are installed as part of a system required by the approved type design?


Any addition whatsoever will potentially do (8) so any electrical equipment is a major mod.
Any navigational equipment whatsoever will potentially do (9) so any radio equipment is a major mod.

Likewise for (10).

In 20 years of doing small aircraft, I've never managed to get a 337 field-approved in UK, so always use the DER-approved 8110-3 route.

Have you tried?

You know me I have investigated various potential avionics work, via various UK shops (because I like to get my ducks in a row at the outset, to avoid the situations and downtime which some pilots end up stuck in) and I think you are more or less alone in using the DER route. The others seem to be trying to push stuff through the NY IFO, but last time I tried it (for the GPS FM supplement; happy to email you the details) this route did not appear to work [anymore].

[wigglyamp]

Thanks for the TC modification definitions. It's very similar to EASA's table in AMC21A91. The significant difference between TC/FAA and EASA is that under EASA, a Minor change still requires approved data and is not just a logbook certification. In reality, our EASA Minor change is the same as an FAA Major alteration, and STCs are directly equivalent.

[wigglyamp]

337 field approvals

IO-540.
I talked to the current FAA avionics field inspector from LHR during a recent repair station audit at your home airfield and he advised that they have no obligation to undertake field-approvals outside the US, and that he didn't have the time to deal with them. His predecessor did clear a couple of flight manual supplements for me for BRNav and TAWS-B but wouldn't consider field approvals.

[IO540]

That explains quite a lot then

So the only options for a UK based N-reg are

- DER
- a Minor Mod

I believe all DERs are in the USA. This one is used by some European firms; their website is really informative

[wigglyamp]

The third option for UK N-reg operators is to install something that already has an FAA STC covering the specific aircraft type - then all that is needed is an FAA IA or repair station to sign the 337. Aspen EFD1000 or Garmin G500 no hassle, but want a Sandel 3500 ? - you need a DER!