Glide computer in certified glider

[Wade G]

In short,
What is required to install a non-TSO’d moving map flight computer IN the panel of my certified glider?
A 337 mess?

WG

[Bob Kuykendall]

On Tuesday, May 8, 2018 at 10:06:56 PM UTC-7, Wade G wrote:
> In short,
> What is required to install a non-TSO’d moving map flight computer IN the panel of my certified glider?
> A 337 mess?
>
> WG

A savvy A&P with a pen.

And a sawzall.

https://www.aopa.org/news-and-media/all-news/2017/april/pilot/savvy-keep-it-minor

--Bob K.

[2G]

On Tuesday, May 8, 2018 at 10:06:56 PM UTC-7, Wade G wrote:
> In short,
> What is required to install a non-TSO’d moving map flight computer IN the panel of my certified glider?
> A 337 mess?
>
> WG

I would think not. If it is not a primary flight instrument, and I assume that you are keeping all of those, it falls into the category of an accessory. Sort of like in flight music. But, by all means, call your local FSDO for clarification. And, if you make the request in writing, the FAA will give you a formal determination. This may be a good idea before going to all the trouble and then having some uninformed mechanic say he can't sign off on your annual because of this unallowed mod.

Tom

[Darryl Ramm]

On Tuesday, May 8, 2018 at 10:06:56 PM UTC-7, Wade G wrote:
> In short,
> What is required to install a non-TSO’d moving map flight computer IN the panel of my certified glider?
> A 337 mess?
>
> WG

Where is your glider A&P?

In short, it depends. But is usually only an A&P entry for a minor change in the maintenance log book. A 337 is required for major changes, and it is extremely difficult to image an flight computer install that is by itself going to qualify as a major change in a glider. There are lots of discussions online from EAA and AOPA about what constitutes minor and major changes, start there if you want to read up on this.

If you have to ask these questions you probably should not be contacting a FSDO. Asking questions there can possibly end you up in a world of hurt and confusion. Its best to leave any questions like that up to the A&P you are working with. Find an A&P who is experienced working on gliders, you want that glider specific knowledge anyhow, and this question will likely be easy for them to discuss with you and answer once they know the specific work involved. And if its for some reason a very unusual install that needs a FSDO discussion or possible 337 filed, let them have that discussion.

[Peter Thomas]

At 07:23 09 May 2018, Darryl Ramm wrote:
>On Tuesday, May 8, 2018 at 10:06:56 PM UTC-7, Wade G wrote:
>> In short,
>> What is required to install a non-TSO=E2=80=99d moving map
flight
>compute=
>r IN the panel of my certified glider?
>> A 337 mess?
>>=20
>> WG
>
>Where is your glider A&P?=20
>
>In short, it depends. But is usually only an A&P entry for a minor
change
>i=
>n the maintenance log book. A 337 is required for major changes,
and it is
>=
>extremely difficult to image an flight computer install that is by
itself
>g=
>oing to qualify as a major change in a glider. There are lots of
>discussion=
>s online from EAA and AOPA about what constitutes minor and
major changes,
>=
>start there if you want to read up on this.
>
>If you have to ask these questions you probably should not be
contacting a
>=
>FSDO. Asking questions there can possibly end you up in a world
of hurt
>and=
> confusion. Its best to leave any questions like that up to the A&P
you
>are=
> working with. Find an A&P who is experienced working on gliders,
you want
>=
>that glider specific knowledge anyhow, and this question will likely
be
>eas=
>y for them to discuss with you and answer once they know the
specific work
>=
>involved. And if its for some reason a very unusual install that
needs a
>FS=
>DO discussion or possible 337 filed, let them have that discussion.
>

The major European manufacturers have general ADs covering
instrument panel and cockpit equipment changes which identify
things you need to check about the item to install (like security,
power consumption etc) This constitutes blanket approval for the
changes, you just quote the AD in the paperwork.(CS-STAN)
I know of Sclhicher, Schempp and DG/LS, there may be others.

Dont know if you can do this in the US

There is an equivalent system under EASA where MFR ADs are not
available (surprisingly helpful) although i doubt many people applied
for an EASA minor mod to change their electric vario. However i
doubt this process would carry to the US.

[Darryl Ramm]

On Wednesday, May 9, 2018 at 12:30:07 PM UTC-7, Peter Thomas wrote:
> At 07:23 09 May 2018, Darryl Ramm wrote:
> >On Tuesday, May 8, 2018 at 10:06:56 PM UTC-7, Wade G wrote:
> >> In short,
> >> What is required to install a non-TSO=E2=80=99d moving map
> flight
> >compute=
> >r IN the panel of my certified glider?
> >> A 337 mess?
> >>=20
> >> WG
> >
> >Where is your glider A&P?=20
> >
> >In short, it depends. But is usually only an A&P entry for a minor
> change
> >i=
> >n the maintenance log book. A 337 is required for major changes,
> and it is
> >=
> >extremely difficult to image an flight computer install that is by
> itself
> >g=
> >oing to qualify as a major change in a glider. There are lots of
> >discussion=
> >s online from EAA and AOPA about what constitutes minor and
> major changes,
> >=
> >start there if you want to read up on this.
> >
> >If you have to ask these questions you probably should not be
> contacting a
> >=
> >FSDO. Asking questions there can possibly end you up in a world
> of hurt
> >and=
> > confusion. Its best to leave any questions like that up to the A&P
> you
> >are=
> > working with. Find an A&P who is experienced working on gliders,
> you want
> >=
> >that glider specific knowledge anyhow, and this question will likely
> be
> >eas=
> >y for them to discuss with you and answer once they know the
> specific work
> >=
> >involved. And if its for some reason a very unusual install that
> needs a
> >FS=
> >DO discussion or possible 337 filed, let them have that discussion.
> >
>
> The major European manufacturers have general ADs covering
> instrument panel and cockpit equipment changes which identify
> things you need to check about the item to install (like security,
> power consumption etc) This constitutes blanket approval for the
> changes, you just quote the AD in the paperwork.(CS-STAN)
> I know of Sclhicher, Schempp and DG/LS, there may be others.
>
> Dont know if you can do this in the US
>
> There is an equivalent system under EASA where MFR ADs are not
> available (surprisingly helpful) although i doubt many people applied
> for an EASA minor mod to change their electric vario. However i
> doubt this process would carry to the US.

This is going down the entirely wrong rat hole. These are usually (FAA's regulatory definition of) minor changes (not related necessarily to anything called the same in Europe) that require no interaction with the FAA and no specific paperwork to approve the change. A maintenance log book entry from an A&P is all that is normally required for this in a type certificated glider. The A&P will choose what instructions they follow, and might well follow EASA minor change instructions. I suspect the thing to be most careful of is not replacing any of the flight instruments required in the type certificate with random flight computer capabilities.

This really should be a brief discussion with a glider A&P... its up to them to work on this and advise owners of what is needed. If stuff is not clear then ask your A&P to explain it to you (there may be reasons) or if they can't do so to your satisfaction then call another glider repair shop.

I recently got roped into advising on a few ADS-B Out/avionics installs in powered aircraft and that reminded me of how much confusion there on ADS-B in GA and on the major vs. minor change stuff and how many assumptions owners can make before talking to a knowledgeable A&P. (Hey Bob, I'd love a ride in that T6 with or without ADS-B Out :-)).

[K m]

On Wednesday, May 9, 2018 at 2:05:51 PM UTC-7, Darryl Ramm wrote:

> This is going down the entirely wrong rat hole.

I was going to say "Looking up a dead horses ass". Granted, there are different interpretations and basis for installations. I once had an AI refuse to sign off an annual because of an S80 until I produced a Factory Service Letter outlining the installation of non TSOd equipment. On my last install (Different glider) I went with the basis outlined in the Maintenance Manual (Which allowed for the installation of ANY GPS). When I did a transponder install a couple of older mechanics said it would involve a 337 but the FAA said this is considered a minor alteration (And has been for some time). A few times, When I was feeling lucky, I talked to the FAA and went all the way up to the Regional Manager for Certification for the Northwest US. This person dispelled a lot of Internet Folklore.
To the OP, just ask around and possibly check with the manufacturer.

[Darryl Ramm]

Transponder installs somehow automatically being a major change and therefore requiring a 337 misinformation is my favorite dead horses ass :-) That old chestnut (must have been a Chestnut horse?) is coming up again in the context of ADS-B Out installs. (and the quicj answer there is most should be minor changes, unless there is some other reason the install is a major change).

[Dan Marotta]

Don't know about gliders yet, but the ADS-B install in my airplane was
accomplished by a shop under an STC.

On 5/9/2018 4:14 PM, Darryl Ramm wrote:
> Transponder installs somehow automatically being a major change and therefore requiring a 337 misinformation is my favorite dead horses ass :-) That old chestnut (must have been a Chestnut horse?) is coming up again in the context of ADS-B Out installs. (and the quicj answer there is most should be minor changes, unless there is some other reason the install is a major change).
>

--
Dan, 5J

[Darryl Ramm]

On Wednesday, May 9, 2018 at 4:02:34 PM UTC-7, Dan Marotta wrote:
> Don't know about gliders yet, but the ADS-B install in my airplane was
> accomplished by a shop under an STC.
>
> On 5/9/2018 4:14 PM, Darryl Ramm wrote:
> > Transponder installs somehow automatically being a major change and therefore requiring a 337 misinformation is my favorite dead horses ass :-) That old chestnut (must have been a Chestnut horse?) is coming up again in the context of ADS-B Out installs. (and the quicj answer there is most should be minor changes, unless there is some other reason the install is a major change).

OK down another rat hole...

"accomplished... using a STC" can means two different things with ADS-B Out..

For 2020 Complaint ADS-B Out you normally need to use an STC as a basis for the pairing of a ADS-B Out tranmitter (e.g. transponder) and GPS Source. And the FAA asks for a "notice only" '337 to be filed with Oklahoma HQ. None of that necessarily makes this a major change, requiring a normal 337 major change to be approved by the FSDO and (typically a STC used as a basis for that approval). This is documented in FAA Policy 8900.362 (yes technically expired but still being followed) that A&P should be aware of. A mistake here seems to be folks assuming they have to do more than the policy exactly says. And usually another example of why you want an experienced glider A&P interpreting this stuff. If the A&P believes the insulation itself *is* a major change then they also need to file a 337 for major change approval with the FSDO.... that should *not* be the case for most glider ADS-B Out installs. (and they will likely immediately run into problems with no STC existing to use as an install basis for any transponder in any glider in the USA, and the typical AML STCs used for that pairing not listing the glider on the AML STC... likely not an issue if all you care about is the pairing being previously approved). If folks incorrectly submit those notice only 337s to the FSDO where they are not required, don't be upset when the FSDO assumes you are seeking major change approval and starts asking for transponder install STCs that don't exist...the FSDO staff are doing what you pushed them to do. I think there should be a type of Hippocratic oath when dealing with regulatory agencies... don't create work/confusion where it does not need to be.

None of 8900.362 applies to experiential gliders and none of 8900.362 applies to TABS installs in certified (or experimental) gliders, since you are not seeking compliance there with 14 CFR 91.225 and 91.227, which is all this policy addresses.

[[email protected]]

"A savvy A&P with a pen."

Probably the best advice here. Even under Transport Canada's somewhat pickier reign all I've ever needed with this sort of installation is the sign off in the log book of an AME.

[2G]

On Wednesday, May 9, 2018 at 2:05:51 PM UTC-7, Darryl Ramm wrote:
> On Wednesday, May 9, 2018 at 12:30:07 PM UTC-7, Peter Thomas wrote:
> > At 07:23 09 May 2018, Darryl Ramm wrote:
> > >On Tuesday, May 8, 2018 at 10:06:56 PM UTC-7, Wade G wrote:
> > >> In short,
> > >> What is required to install a non-TSO=E2=80=99d moving map
> > flight
> > >compute=
> > >r IN the panel of my certified glider?
> > >> A 337 mess?
> > >>=20
> > >> WG
> > >
> > >Where is your glider A&P?=20
> > >
> > >In short, it depends. But is usually only an A&P entry for a minor
> > change
> > >i=
> > >n the maintenance log book. A 337 is required for major changes,
> > and it is
> > >=
> > >extremely difficult to image an flight computer install that is by
> > itself
> > >g=
> > >oing to qualify as a major change in a glider. There are lots of
> > >discussion=
> > >s online from EAA and AOPA about what constitutes minor and
> > major changes,
> > >=
> > >start there if you want to read up on this.
> > >
> > >If you have to ask these questions you probably should not be
> > contacting a
> > >=
> > >FSDO. Asking questions there can possibly end you up in a world
> > of hurt
> > >and=
> > > confusion. Its best to leave any questions like that up to the A&P
> > you
> > >are=
> > > working with. Find an A&P who is experienced working on gliders,
> > you want
> > >=
> > >that glider specific knowledge anyhow, and this question will likely
> > be
> > >eas=
> > >y for them to discuss with you and answer once they know the
> > specific work
> > >=
> > >involved. And if its for some reason a very unusual install that
> > needs a
> > >FS=
> > >DO discussion or possible 337 filed, let them have that discussion.
> > >
> >
> > The major European manufacturers have general ADs covering
> > instrument panel and cockpit equipment changes which identify
> > things you need to check about the item to install (like security,
> > power consumption etc) This constitutes blanket approval for the
> > changes, you just quote the AD in the paperwork.(CS-STAN)
> > I know of Sclhicher, Schempp and DG/LS, there may be others.
> >
> > Dont know if you can do this in the US
> >
> > There is an equivalent system under EASA where MFR ADs are not
> > available (surprisingly helpful) although i doubt many people applied
> > for an EASA minor mod to change their electric vario. However i
> > doubt this process would carry to the US.
>
> This is going down the entirely wrong rat hole. These are usually (FAA's regulatory definition of) minor changes (not related necessarily to anything called the same in Europe) that require no interaction with the FAA and no specific paperwork to approve the change. A maintenance log book entry from an A&P is all that is normally required for this in a type certificated glider. The A&P will choose what instructions they follow, and might well follow EASA minor change instructions. I suspect the thing to be most careful of is not replacing any of the flight instruments required in the type certificate with random flight computer capabilities.
>
> This really should be a brief discussion with a glider A&P... its up to them to work on this and advise owners of what is needed. If stuff is not clear then ask your A&P to explain it to you (there may be reasons) or if they can't do so to your satisfaction then call another glider repair shop.
>
> I recently got roped into advising on a few ADS-B Out/avionics installs in powered aircraft and that reminded me of how much confusion there on ADS-B in GA and on the major vs. minor change stuff and how many assumptions owners can make before talking to a knowledgeable A&P. (Hey Bob, I'd love a ride in that T6 with or without ADS-B Out :-)).

I didn't know that you were an A&P.

Tom

[Darryl Ramm]

On Wednesday, May 9, 2018 at 6:24:07 PM UTC-7, 2G wrote:

> I didn't know that you were an A&P.
>
> Tom

I'm not, and I think you know that. But I do know enough about ADS-B Out to have an intelligent conversation with owners and A&Ps. I've worked with vendors, resellers, STC holders and A&Ps on ADS-B Out install related issues in gliders. And my point there is for type certified gliders work though an A&P otherwise its academic what anybody (including me) thinks,... you need the person who is actually going to do the work/sign the log book to be involved. Which goes back to the point Bob was making by quoting that great AOPA article. I can help with some technical ADS-B questions or provide better contacts to folks, but an A&P really needs to be involved from early on.

[[email protected]]

If the glider was built in Germany there's probably also a TN from the manufacturer giving guidance on installing equipment. Linked as an example is the one Schleicher provides. This sort of thing could be useful if your A&P wants more than the (often very terse) glider manual and the AC 43.13 to go by.

https://www.alexander-schleicher.de/wp-content/uploads/2016/11/2008_TM02_E-II_HB.pdf

[Wade G]

Perfect! The Schleicher note is exactly what I was looking for.
Thanks!

[2G]

On Wednesday, May 9, 2018 at 6:39:26 PM UTC-7, Darryl Ramm wrote:
> On Wednesday, May 9, 2018 at 6:24:07 PM UTC-7, 2G wrote:
>
> > I didn't know that you were an A&P.
> >
> > Tom
>
> I'm not, and I think you know that. But I do know enough about ADS-B Out to have an intelligent conversation with owners and A&Ps. I've worked with vendors, resellers, STC holders and A&Ps on ADS-B Out install related issues in gliders. And my point there is for type certified gliders work though an A&P otherwise its academic what anybody (including me) thinks,... you need the person who is actually going to do the work/sign the log book to be involved. Which goes back to the point Bob was making by quoting that great AOPA article. I can help with some technical ADS-B questions or provide better contacts to folks, but an A&P really needs to be involved from early on.

I suspected it, but wanted to be sure. In that case, you are not an authoritative source on the subject. Yet, you tell others NOT to go to an authoritative source, the FAA - unbelievable! At the end of the day, we all HAVE to answer to the FAA - that is just the way it is, so get used to it.

Tom

[Darryl Ramm]

On Wednesday, May 9, 2018 at 10:17:00 PM UTC-7, 2G wrote:
> On Wednesday, May 9, 2018 at 6:39:26 PM UTC-7, Darryl Ramm wrote:
> > On Wednesday, May 9, 2018 at 6:24:07 PM UTC-7, 2G wrote:
> >
> > > I didn't know that you were an A&P.
> > >
> > > Tom
> >
> > I'm not, and I think you know that. But I do know enough about ADS-B Out to have an intelligent conversation with owners and A&Ps. I've worked with vendors, resellers, STC holders and A&Ps on ADS-B Out install related issues in gliders. And my point there is for type certified gliders work though an A&P otherwise its academic what anybody (including me) thinks,... you need the person who is actually going to do the work/sign the log book to be involved. Which goes back to the point Bob was making by quoting that great AOPA article. I can help with some technical ADS-B questions or provide better contacts to folks, but an A&P really needs to be involved from early on.
>
> I suspected it, but wanted to be sure. In that case, you are not an authoritative source on the subject. Yet, you tell others NOT to go to an authoritative source, the FAA - unbelievable! At the end of the day, we all HAVE to answer to the FAA - that is just the way it is, so get used to it.
>
> Tom

Tom you need to stop misrepresenting what I'm saying. I don't know how to make it simpler for you. I am not saying don't ask the FSDO, I am suggesting doing so *if needed* by going through the A&P doing the work, and be aware of some potential issues before doing that. And in the case of ADS-B Out I've tried to help people by pointing to the main FAA policy document to read. That is the document the FSDO staff are following and will quote when you ask them questions. That may well answer any questions by itself. Have you even read it?

Most A&Ps understand what they are doing, they likely don't need to contact the FSDO or if they do they know exactly who to go to and how to ask questions. They may not appreciate owners contacting a FSDO and creating unneeded confusion or work. It could be a unfortunate way for an owner to ruin a working relationship with their A&P.

I've seen people have issues with ADS-B Out and TABS misunderstandings with their FSDO and I'm trying to help other people avoid similar problems. Are you actually involved in any ADS-B Out or TABS installs? Have you every installed/configured an ADS-B Out system? Dealt with any of FSDO issues related to ADS-B Out installs? Have you helped work with vendors and STC owners to get those STCs available for gliders? Do A&Ps contact you for help doing installs or paperwork or for help when they talk to their FSDO staff? I suspect that's no in all regards for you. Yes for me. But don't let not actually having done anything stop you having lots of opinion here.

Do you even care that your simplistic "contact the FSDO" advice to owners without any caution or extra info might cause people problems? Ah **** it, what the hell, it won't be your problem...

[Tom (TK)]

From another conversation on the same topic...

CFRs.
14 CFR 91 Subpart C— Equipment, Instrument, and Certificate Requirements.
Section 91.205 —Powered civil aircraft with standard category U.S. airworthiness certificates: Instrument and equipment requirements.
(d) Instrument flight rules. For IFR flight, the following instruments and equipment are required:
(2) Two-way radio communication and navigation equipment suitable for the route to be flown.

There are also some general references as to the performance requirements of installed equipment. Please refer to 14 CFR 23 Subpart F Section 23.1301, 23.1309, 23.14 31
At this point it would be the responsibility of the installer to verify that the installed equipment meets the requirements of the above part 23 sections. One means to insure this would be to only install TSO’d equipment. TSO’d equipment is equipment that the FAA has examined and determined that it meets the requirements of Part 23. Another way would be to review the requirements set forth for a particular type of equipment (i.e.
communication or navigation radio) by referring to a particular TSO document. The TSO document will spell out the minimum performance standard for a type of equipment, usually by referencing an industry-standard organization’s documentation such as that of RTCA Inc. (Radio Technical Commission for Aeronautics). At this point in our discussion one might be overwhelmed by the process and choose the path of least resistance and go
with the TSO’d equipment. Or one could look to the manufacturer of the equipment for information as to what standard the equipment was manufactured to. This information is typically found in the specifications section of the equipment’s installation manual. The idea that a piece of equipment meets the requirements of a recognized standard such as a TSO but not have the TSO authorization is backed up in FAA Order 8900.1 Volume 4 chapter 9 Section 2 paragraph 4-1178 General (C) Definitions (10) Meet Minimum
TSO-Established Standards: Means that the equipment need not have TSO approval, but only meet requirements set by the TSO.

The next topic that comes up in the discussion is whether or not the installation is required to be recorded on FAA Form 337 and whether it will require a field approval. These questions are answered by examining the requirements for the use of Form 337 and for field approvals. 14 CFR Part 1 Section 1.1 defines a minor alteration as an alteration that is not a major alteration. Some examples of major alteration are defined in Appendix
A of Part 43. Unfortunately the installation of radio equipment is not appropriately covered in the appendix.

FAA Order 8900.1 Volume 4 Chapter 9 provides guidance as to determining if an alteration is major or minor. It can be broken down into a series of
questions the installer might answer to arrive at a designation of the alteration as major or minor.
General alterations:
• Does the proposed alteration have an appreciable effect on the certificated weight? (i.e. A change in the maximum
takeoff weight limitations, minimum landing weight limitations, etc.)
• Does the proposed alteration have an appreciable effect on the certificated balance? (i.e. A change in the forward or
aft center of gravity limits, etc.)
• Does the proposed alteration have an appreciable effect on the structural strength?
• Does the proposed alteration have an appreciable effect on the performance?
• Does the proposed alteration have an appreciable effect on the powerplant operation?
• Does the proposed alteration have an appreciable effect on the flight characteristics?
• Does the proposed alteration have an appreciable effect on other characteristics affecting the airworthiness?

Yes to any of the above questions: The proposed change is a major change in type design requiring the application for a Supplemental Type Certificate (STC).
• Is it possible that the proposed alteration might have an appreciable effect on the certificated weight? (i.e. A change in the maximum takeoff weight limitations, minimum landing weight limitations, etc.)
• Is it possible that the proposed alteration might have an appreciable effect on the certificated balance? (i.e. A change in the forward or aft center of gravity limits, etc.)
• Is it possible that the proposed alteration might have an appreciable effect on the structural strength?
• Is it possible that the proposed alteration might have an appreciable effect on the performance?
• Is it possible that the proposed alteration might have an appreciable effect on the powerplant operation?
• Is it possible that the proposed alteration might have an appreciable effect on the flight characteristics?
• Is it possible that the proposed alteration might have an appreciable effect on other characteristics affecting the airworthiness?
• Does the proposed alteration alter the wings?
• Does the proposed alteration alter the tail surfaces?
• Does the proposed alteration alter the fuselage?
• Does the proposed alteration alter the engine mounts?
• Does the proposed alteration alter the control system?
• Does the proposed alteration alter the landing gear?
• Does the proposed alteration alter the hull or floats?
• Does the proposed alteration alter the elements of an airframe including spars, ribs, fittings, shock absorbers, bracing, cowling, fairings, and balance weights?
• Does the proposed alteration alter the hydraulic and electrical actuating system of components?
• Does the proposed alteration alter the rotor blades?
• Does the proposed alteration change the empty weight or empty balance which results in an increase in the maximum certificated weight or center of gravity limits of the aircraft?
• Does the proposed alteration change the basic design of the fuel, oil, cooling, heating, cabin pressurization, electrical, hydraulic, deicing, or exhaust systems.
• Does the proposed alteration change the wing or any fixed or movable control surfaces which affect flutter and vibration characteristics?
• Does the proposed alteration convert an aircraft engine from one approved model to another, involving any changes in compression ratio, propeller reduction gear, impeller gear ratios or the substitution of major engine parts which requires extensive rework and testing of the engine?
• Does the proposed alteration change the engine by replacing aircraft engine structural parts with parts not supplied by the original manufacturer or parts not specifically approved by the Administrator?
• Does the proposed alteration include the installation of an accessory which is not approved for the engine?
• Does the proposed alteration include the removal of accessories that are listed as required equipment on the aircraft or engine specification?
• Does the proposed alteration include the installation of structural parts other than the type of parts approved for the installation?
• Does the proposed alteration make any conversions of any sort for the purpose of using fuel of a rating or grade other than that listed in the engine specifications?

Yes or maybe to any of the above questions: The proposed change is a major alteration requiring approved data, recording of FAA Form 337 and a log book entry.

Confirmed no to all: Continue.
• Has the Administrator issued an Advisory Circular that requires the use of approved data for this installation/ alteration?
Yes. Follow the guidance contained in the Advisory Circular.
No. Continue.
• Has the Administrator issued policy (HBAW, FSAW, etc.) that requires the use of approved data for this installation/alteration?
Yes. Follow the published policy.
No. The alteration is a minor alteration with no additional published guidance therefore the use of acceptable data is authorized and the alteration/installation must be recorded in the appropriate maintenance record. Follow the provisions of Part 43, 65 and/or 145 as appropriate.

Appliance alterations:
• Does the alteration affect the basic design of the appliance?
Yes. Continue.
No. The alteration is considered an appliance minor alteration.
• Is the alteration of the basic design of the appliance made in accordance with recommendations of the appliance manufacturer or in accordance with an FAA Airworthiness Directive?
Yes. Continue.
No. The alteration is considered a major appliance alteration.
• Does the change in the basic design of radio communication and navigation equipment approved under type certification or a Technical Standard Order have an effect on frequency stability, noise level, sensitivity, selectivity, distortion, spurious radiation, AVC characteristics or ability to meet environmental test conditions and other changes that have an effect on the performance of the equipment?
Yes. The alteration is considered a major appliance alteration.
No. The alteration is considered a minor appliance alteration.

[[email protected]]

"Yet, you tell others NOT to go to an authoritative source, the FAA - unbelievable!"

The FAA is not necessarily an "authoritative" source. They DO HAVE authority, but they are often sadly ignorant of their own policies, "guidance" and regulations. A couple of glaring examples:

1) Someone inquired about the meaning of the wording in the Centrair Pegase 101A Maintenance Manual that referred to a 3000 hour Structural Life Limit, but also referred to a 3000 hour inspection. The misguided ASE immediately issued an Airworthiness Directive, cramming it through the system in only 88 days, including a 32 day comment period (instead of the minimum 60 days), that ordered owners to cross out all reference to the inspection and throw the glider away at 3000 hours. This in spite of the fact that the glider is certified in Europe with NO LIFE LIMIT as long as it continues to pass the 3000 hour inspection at the appropriate intervals. According to the Bilateral Aviation Safety Agreement (BASA) between FAA and EASA, the European standard should apply. The author of the AD, Greg Davison, when queried about this, replied directly, "We don't pay much attention to that." Once Bob Carlton and I started fighting back on the issue, Mr. Davison's managers circled the wagons and backed him up. It took nine years, support from our Congressmen, Senators and their staff and the likelihood of an actual Congressional Hearing to get the FAA to agree to a Global Alternate Means Of Compliance (AMOC) that extended the Pegase life to 4,500 hours.

2) The same Greg Davison issued a memo concerning the perceived 35 year life limit on the IAR Brasov Twin Lark, implying it was to be removed from service upon reaching the limit. However, this was also wrong. The FAA issued a "clarification" in October 2017 stating that the aircraft can continue in service provided it remains in airworthy condition. (http://www.ssa.org/files/member/FAA%20Memo%20-%20IS-28B2%20-%2010_16_2017%20-%20Signed[2543].pdf)

Mr. Davison is no longer in a position to affect certification or issue Airworthiness Directives.

These are just two examples of erroneous decisions from the FAA resulting from misinterpretations. And I can cite a lot more.

[K m]

On Wednesday, May 9, 2018 at 10:17:00 PM UTC-7, 2G wrote:
Yet, you tell others NOT to go to an authoritative source, the FAA - unbelievable! At the end of the day, we all HAVE to answer to the FAA -

2G, Go to FAA.GOV, Then to the TDC for your glider. Then to the supporting documents outlined therein and any supporting SBs, TNs, and SLs. The FAA is fine with this, why aren't you (Or are you going out of your way to miss the point)?

[2G]

On Wednesday, May 9, 2018 at 11:36:41 PM UTC-7, Darryl Ramm wrote:
> On Wednesday, May 9, 2018 at 10:17:00 PM UTC-7, 2G wrote:
> > On Wednesday, May 9, 2018 at 6:39:26 PM UTC-7, Darryl Ramm wrote:
> > > On Wednesday, May 9, 2018 at 6:24:07 PM UTC-7, 2G wrote:
> > >
> > > > I didn't know that you were an A&P.
> > > >
> > > > Tom
> > >
> > > I'm not, and I think you know that. But I do know enough about ADS-B Out to have an intelligent conversation with owners and A&Ps. I've worked with vendors, resellers, STC holders and A&Ps on ADS-B Out install related issues in gliders. And my point there is for type certified gliders work though an A&P otherwise its academic what anybody (including me) thinks,... you need the person who is actually going to do the work/sign the log book to be involved. Which goes back to the point Bob was making by quoting that great AOPA article. I can help with some technical ADS-B questions or provide better contacts to folks, but an A&P really needs to be involved from early on.
> >
> > I suspected it, but wanted to be sure. In that case, you are not an authoritative source on the subject. Yet, you tell others NOT to go to an authoritative source, the FAA - unbelievable! At the end of the day, we all HAVE to answer to the FAA - that is just the way it is, so get used to it.
> >
> > Tom
>
> Tom you need to stop misrepresenting what I'm saying. I don't know how to make it simpler for you. I am not saying don't ask the FSDO, I am suggesting doing so *if needed* by going through the A&P doing the work, and be aware of some potential issues before doing that. And in the case of ADS-B Out I've tried to help people by pointing to the main FAA policy document to read. That is the document the FSDO staff are following and will quote when you ask them questions. That may well answer any questions by itself. Have you even read it?
>
> Most A&Ps understand what they are doing, they likely don't need to contact the FSDO or if they do they know exactly who to go to and how to ask questions. They may not appreciate owners contacting a FSDO and creating unneeded confusion or work. It could be a unfortunate way for an owner to ruin a working relationship with their A&P.
>
> I've seen people have issues with ADS-B Out and TABS misunderstandings with their FSDO and I'm trying to help other people avoid similar problems. Are you actually involved in any ADS-B Out or TABS installs? Have you every installed/configured an ADS-B Out system? Dealt with any of FSDO issues related to ADS-B Out installs? Have you helped work with vendors and STC owners to get those STCs available for gliders? Do A&Ps contact you for help doing installs or paperwork or for help when they talk to their FSDO staff? I suspect that's no in all regards for you. Yes for me. But don't let not actually having done anything stop you having lots of opinion here.
>
> Do you even care that your simplistic "contact the FSDO" advice to owners without any caution or extra info might cause people problems? Ah **** it, what the hell, it won't be your problem...

Here is what you wrote, in case you forgot:

"If you have to ask these questions you probably should not be contacting a FSDO. Asking questions there can possibly end you up in a world of hurt and confusion."

What part of "hurt and confusion" don't you understand or remember?

The question WAS NOT about ADS-B Out, In, or whatever; it was about adding a non-TSO'd instrument to the panel. Did you forget that also?

Now, you compound it with "They may not appreciate owners contacting a FSDO and creating unneeded confusion or work." As if you KNOW what any A&P is thinking, which you DON'T!

Let's review: you ARE NOT an A&P, you HAVE NOT talked to ANY A&P to back up your concocted statements, and you are HOPING that we will swallow your bluster as FACT. Well, it ISN'T and we WON'T.

Tom

[Darryl Ramm]

On Thursday, May 10, 2018 at 6:52:43 PM UTC-7, 2G wrote:
> On Wednesday, May 9, 2018 at 11:36:41 PM UTC-7, Darryl Ramm wrote:
> > On Wednesday, May 9, 2018 at 10:17:00 PM UTC-7, 2G wrote:
> > > On Wednesday, May 9, 2018 at 6:39:26 PM UTC-7, Darryl Ramm wrote:
> > > > On Wednesday, May 9, 2018 at 6:24:07 PM UTC-7, 2G wrote:
> > > >
> > > > > I didn't know that you were an A&P.
> > > > >
> > > > > Tom
> > > >
> > > > I'm not, and I think you know that. But I do know enough about ADS-B Out to have an intelligent conversation with owners and A&Ps. I've worked with vendors, resellers, STC holders and A&Ps on ADS-B Out install related issues in gliders. And my point there is for type certified gliders work though an A&P otherwise its academic what anybody (including me) thinks,.... you need the person who is actually going to do the work/sign the log book to be involved. Which goes back to the point Bob was making by quoting that great AOPA article. I can help with some technical ADS-B questions or provide better contacts to folks, but an A&P really needs to be involved from early on.
> > >
> > > I suspected it, but wanted to be sure. In that case, you are not an authoritative source on the subject. Yet, you tell others NOT to go to an authoritative source, the FAA - unbelievable! At the end of the day, we all HAVE to answer to the FAA - that is just the way it is, so get used to it.
> > >
> > > Tom
> >
> > Tom you need to stop misrepresenting what I'm saying. I don't know how to make it simpler for you. I am not saying don't ask the FSDO, I am suggesting doing so *if needed* by going through the A&P doing the work, and be aware of some potential issues before doing that. And in the case of ADS-B Out I've tried to help people by pointing to the main FAA policy document to read. That is the document the FSDO staff are following and will quote when you ask them questions. That may well answer any questions by itself. Have you even read it?
> >
> > Most A&Ps understand what they are doing, they likely don't need to contact the FSDO or if they do they know exactly who to go to and how to ask questions. They may not appreciate owners contacting a FSDO and creating unneeded confusion or work. It could be a unfortunate way for an owner to ruin a working relationship with their A&P.
> >
> > I've seen people have issues with ADS-B Out and TABS misunderstandings with their FSDO and I'm trying to help other people avoid similar problems.. Are you actually involved in any ADS-B Out or TABS installs? Have you every installed/configured an ADS-B Out system? Dealt with any of FSDO issues related to ADS-B Out installs? Have you helped work with vendors and STC owners to get those STCs available for gliders? Do A&Ps contact you for help doing installs or paperwork or for help when they talk to their FSDO staff? I suspect that's no in all regards for you. Yes for me. But don't let not actually having done anything stop you having lots of opinion here.
> >
> > Do you even care that your simplistic "contact the FSDO" advice to owners without any caution or extra info might cause people problems? Ah **** it, what the hell, it won't be your problem...
>
> Here is what you wrote, in case you forgot:
>
> "If you have to ask these questions you probably should not be contacting a FSDO. Asking questions there can possibly end you up in a world of hurt and confusion."
>
> What part of "hurt and confusion" don't you understand or remember?
>
> The question WAS NOT about ADS-B Out, In, or whatever; it was about adding a non-TSO'd instrument to the panel. Did you forget that also?
>
> Now, you compound it with "They may not appreciate owners contacting a FSDO and creating unneeded confusion or work." As if you KNOW what any A&P is thinking, which you DON'T!
>
> Let's review: you ARE NOT an A&P, you HAVE NOT talked to ANY A&P to back up your concocted statements, and you are HOPING that we will swallow your bluster as FACT. Well, it ISN'T and we WON'T.
>
> Tom

You are a first class idiot who likes to hear himself talk. I think people her can weigh your advice at face value.

[[email protected]]

" I think people here can weigh your advice at face value."

I don't think his advice is coming from his face.

Darryl- keep giving us updates and explanations of the confusing ADS-B requirements. I appreciate it, as I am weighing my choices.

[Jonathan St. Cloud]

On Thursday, May 10, 2018 at 7:05:46 PM UTC-7, Darryl Ramm wrote:
>
> > Tom
>
> You are a first class idiot who likes to hear himself talk. I think people her can weigh your advice at face value.

I am going to go with Darryl on this too. Not only can Darryl quickly assess another poster's deep character flaws, he is an expert on the FAA alphabet soup and has done much to improve glider pilot's understanding of this complex system.

[2G]

On Thursday, May 10, 2018 at 7:05:46 PM UTC-7, Darryl Ramm wrote:
> On Thursday, May 10, 2018 at 6:52:43 PM UTC-7, 2G wrote:
> > On Wednesday, May 9, 2018 at 11:36:41 PM UTC-7, Darryl Ramm wrote:
> > > On Wednesday, May 9, 2018 at 10:17:00 PM UTC-7, 2G wrote:
> > > > On Wednesday, May 9, 2018 at 6:39:26 PM UTC-7, Darryl Ramm wrote:
> > > > > On Wednesday, May 9, 2018 at 6:24:07 PM UTC-7, 2G wrote:
> > > > >
> > > > > > I didn't know that you were an A&P.
> > > > > >
> > > > > > Tom
> > > > >
> > > > > I'm not, and I think you know that. But I do know enough about ADS-B Out to have an intelligent conversation with owners and A&Ps. I've worked with vendors, resellers, STC holders and A&Ps on ADS-B Out install related issues in gliders. And my point there is for type certified gliders work though an A&P otherwise its academic what anybody (including me) thinks,... you need the person who is actually going to do the work/sign the log book to be involved. Which goes back to the point Bob was making by quoting that great AOPA article. I can help with some technical ADS-B questions or provide better contacts to folks, but an A&P really needs to be involved from early on.
> > > >
> > > > I suspected it, but wanted to be sure. In that case, you are not an authoritative source on the subject. Yet, you tell others NOT to go to an authoritative source, the FAA - unbelievable! At the end of the day, we all HAVE to answer to the FAA - that is just the way it is, so get used to it.
> > > >
> > > > Tom
> > >
> > > Tom you need to stop misrepresenting what I'm saying. I don't know how to make it simpler for you. I am not saying don't ask the FSDO, I am suggesting doing so *if needed* by going through the A&P doing the work, and be aware of some potential issues before doing that. And in the case of ADS-B Out I've tried to help people by pointing to the main FAA policy document to read. That is the document the FSDO staff are following and will quote when you ask them questions. That may well answer any questions by itself. Have you even read it?
> > >
> > > Most A&Ps understand what they are doing, they likely don't need to contact the FSDO or if they do they know exactly who to go to and how to ask questions. They may not appreciate owners contacting a FSDO and creating unneeded confusion or work. It could be a unfortunate way for an owner to ruin a working relationship with their A&P.
> > >
> > > I've seen people have issues with ADS-B Out and TABS misunderstandings with their FSDO and I'm trying to help other people avoid similar problems. Are you actually involved in any ADS-B Out or TABS installs? Have you every installed/configured an ADS-B Out system? Dealt with any of FSDO issues related to ADS-B Out installs? Have you helped work with vendors and STC owners to get those STCs available for gliders? Do A&Ps contact you for help doing installs or paperwork or for help when they talk to their FSDO staff? I suspect that's no in all regards for you. Yes for me. But don't let not actually having done anything stop you having lots of opinion here.
> > >
> > > Do you even care that your simplistic "contact the FSDO" advice to owners without any caution or extra info might cause people problems? Ah **** it, what the hell, it won't be your problem...
> >
> > Here is what you wrote, in case you forgot:
> >
> > "If you have to ask these questions you probably should not be contacting a FSDO. Asking questions there can possibly end you up in a world of hurt and confusion."
> >
> > What part of "hurt and confusion" don't you understand or remember?
> >
> > The question WAS NOT about ADS-B Out, In, or whatever; it was about adding a non-TSO'd instrument to the panel. Did you forget that also?
> >
> > Now, you compound it with "They may not appreciate owners contacting a FSDO and creating unneeded confusion or work." As if you KNOW what any A&P is thinking, which you DON'T!
> >
> > Let's review: you ARE NOT an A&P, you HAVE NOT talked to ANY A&P to back up your concocted statements, and you are HOPING that we will swallow your bluster as FACT. Well, it ISN'T and we WON'T.
> >
> > Tom
>
> You are a first class idiot who likes to hear himself talk. I think people her can weigh your advice at face value.

For the record: you have just conceded the argument (but it wasn't a fair fight to begin with!).

Tom

[[email protected]]

So, 2G (Tom), are YOU an A&P or IA? We know Darryl's qualifications from his cogent ant consistent advice. What are your qualifications?

[2G]

On Thursday, May 10, 2018 at 7:10:29 PM UTC-7, wrote:
> " I think people here can weigh your advice at face value."
>
> I don't think his advice is coming from his face.
>
> Darryl- keep giving us updates and explanations of the confusing ADS-B requirements. I appreciate it, as I am weighing my choices.

So, you think I am full of **** by saying:

"But, by all means, call your local FSDO for clarification. And, if you make the request in writing, the FAA will give you a formal determination."

That is what this is all about.

Tom

[Bob Kuykendall]

On Thursday, May 10, 2018 at 7:48:12 PM UTC-7, 2G wrote:
> So, you think I am full of ****...

I wouldn't have put it in so few words.

[2G]

On Thursday, May 10, 2018 at 11:35:08 PM UTC-7, Bob Kuykendall wrote:
> On Thursday, May 10, 2018 at 7:48:12 PM UTC-7, 2G wrote:
> > So, you think I am full of ****...
>
> I wouldn't have put it in so few words.

If you do call the FAA for guidance, they will likely refer you Advisory Circular AC 43-210A (https://www.faa.gov/documentLibrary/media/Advisory_Circular/AC_43-210A.pdf) “Standardized Procedures for Obtaining Approval of Data Used in the Performance of Major Repairs and Major Alterations.” This covers what constitutes a minor repair:

“3.2.2 Determine the Repair or Alteration Classification. Determine if the repair/alteration is a minor change in type design (as defined in 14 CFR part 21, § 21.93) to the product’s type design; and if so, is it a major or a minor repair/alteration. To determine if a repair/alteration is major or minor, refer to part 43 appendix A. Figure 3-2, Determination of Major or Minor Alteration or Repair, is a flowchart of the field approval evaluation process based on part 43 appendix A.”

The regulation referenced, 14 CFR part 21, § 21.93, explicitly defines what constitutes a minor repair (https://www.law.cornell.edu/cfr/text/14/21.93):

"(a) In addition to changes in type design specified in paragraph (b) of this section, changes in type design are classified as minor and major. 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)."

The addition of instrument not required for certification constitutes a minor alteration (unless it affects the performance of required instrumentation) and meets the above criteria. An FAA airframe inspector are available to answer any questions concerning these regulations. My experience with FAA inspectors is they are really trying to make compliance as easy as possible and are not trying to make your life miserable.

Tom

[[email protected]]

Tom , I suggest when you are already in a hole you stop digging.
Remeber, it is better to keep quiet and be thought a fool than to open your mouth and prove it.

[2G]

On Monday, May 14, 2018 at 5:53:15 AM UTC-7, wrote:
> Tom , I suggest when you are already in a hole you stop digging.
> Remeber, it is better to keep quiet and be thought a fool than to open your mouth and prove it.

Why don't you provide some useful intelligence rather than gutter tripe?

Tom

[[email protected]]

Just had to prove it huh. Go figure.

[jfitch]

On Saturday, May 12, 2018 at 3:10:57 PM UTC-7, 2G wrote:
> On Thursday, May 10, 2018 at 11:35:08 PM UTC-7, Bob Kuykendall wrote:
> > On Thursday, May 10, 2018 at 7:48:12 PM UTC-7, 2G wrote:
> > > So, you think I am full of ****...
> >
> > I wouldn't have put it in so few words.
>
> If you do call the FAA for guidance, they will likely refer you Advisory Circular AC 43-210A (https://www.faa.gov/documentLibrary/media/Advisory_Circular/AC_43-210A.pdf) “Standardized Procedures for Obtaining Approval of Data Used in the Performance of Major Repairs and Major Alterations.” This covers what constitutes a minor repair:
>
> “3.2.2 Determine the Repair or Alteration Classification. Determine if the repair/alteration is a minor change in type design (as defined in 14 CFR part 21, § 21.93) to the product’s type design; and if so, is it a major or a minor repair/alteration. To determine if a repair/alteration is major or minor, refer to part 43 appendix A. Figure 3-2, Determination of Major or Minor Alteration or Repair, is a flowchart of the field approval evaluation process based on part 43 appendix A.”
>
> The regulation referenced, 14 CFR part 21, § 21.93, explicitly defines what constitutes a minor repair (https://www.law.cornell.edu/cfr/text/14/21.93):
>
> "(a) In addition to changes in type design specified in paragraph (b) of this section, changes in type design are classified as minor and major. 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)."
>
> The addition of instrument not required for certification constitutes a minor alteration (unless it affects the performance of required instrumentation) and meets the above criteria. An FAA airframe inspector are available to answer any questions concerning these regulations. My experience with FAA inspectors is they are really trying to make compliance as easy as possible and are not trying to make your life miserable.
>
> Tom

That definition of minor change leaves very wide latitude for minor changes.. Also great latitude for judgement about what is considered a minor change..

[2G]

On Saturday, May 19, 2018 at 7:23:32 AM UTC-7, jfitch wrote:
> On Saturday, May 12, 2018 at 3:10:57 PM UTC-7, 2G wrote:
> > On Thursday, May 10, 2018 at 11:35:08 PM UTC-7, Bob Kuykendall wrote:
> > > On Thursday, May 10, 2018 at 7:48:12 PM UTC-7, 2G wrote:
> > > > So, you think I am full of ****...
> > >
> > > I wouldn't have put it in so few words.
> >
> > If you do call the FAA for guidance, they will likely refer you Advisory Circular AC 43-210A (https://www.faa.gov/documentLibrary/media/Advisory_Circular/AC_43-210A.pdf) “Standardized Procedures for Obtaining Approval of Data Used in the Performance of Major Repairs and Major Alterations..” This covers what constitutes a minor repair:
> >
> > “3.2.2 Determine the Repair or Alteration Classification. Determine if the repair/alteration is a minor change in type design (as defined in 14 CFR part 21, § 21.93) to the product’s type design; and if so, is it a major or a minor repair/alteration. To determine if a repair/alteration is major or minor, refer to part 43 appendix A. Figure 3-2, Determination of Major or Minor Alteration or Repair, is a flowchart of the field approval evaluation process based on part 43 appendix A.”
> >
> > The regulation referenced, 14 CFR part 21, § 21.93, explicitly defines what constitutes a minor repair (https://www.law.cornell.edu/cfr/text/14/21.93):
> >
> > "(a) In addition to changes in type design specified in paragraph (b) of this section, changes in type design are classified as minor and major. 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)."
> >
> > The addition of instrument not required for certification constitutes a minor alteration (unless it affects the performance of required instrumentation) and meets the above criteria. An FAA airframe inspector are available to answer any questions concerning these regulations. My experience with FAA inspectors is they are really trying to make compliance as easy as possible and are not trying to make your life miserable.
> >
> > Tom
>
> That definition of minor change leaves very wide latitude for minor changes. Also great latitude for judgement about what is considered a minor change.

I totally disagree. 14 CFR 21.93 clearly states:

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..

If ANY of these conditions are met, it is a major change requiring the attendant paperwork. You don't make this judgment, your A&P does. And I would consult with an IA who is authorized to sign off on major changes.

Tom

[jfitch]

On Saturday, May 19, 2018 at 8:51:12 AM UTC-7, 2G wrote:
> On Saturday, May 19, 2018 at 7:23:32 AM UTC-7, jfitch wrote:
> > On Saturday, May 12, 2018 at 3:10:57 PM UTC-7, 2G wrote:
> > > On Thursday, May 10, 2018 at 11:35:08 PM UTC-7, Bob Kuykendall wrote:
> > > > On Thursday, May 10, 2018 at 7:48:12 PM UTC-7, 2G wrote:
> > > > > So, you think I am full of ****...
> > > >
> > > > I wouldn't have put it in so few words.
> > >
> > > If you do call the FAA for guidance, they will likely refer you Advisory Circular AC 43-210A (https://www.faa.gov/documentLibrary/media/Advisory_Circular/AC_43-210A.pdf) “Standardized Procedures for Obtaining Approval of Data Used in the Performance of Major Repairs and Major Alterations.” This covers what constitutes a minor repair:
> > >
> > > “3.2.2 Determine the Repair or Alteration Classification. Determine if the repair/alteration is a minor change in type design (as defined in 14 CFR part 21, § 21.93) to the product’s type design; and if so, is it a major or a minor repair/alteration. To determine if a repair/alteration is major or minor, refer to part 43 appendix A. Figure 3-2, Determination of Major or Minor Alteration or Repair, is a flowchart of the field approval evaluation process based on part 43 appendix A.”
> > >
> > > The regulation referenced, 14 CFR part 21, § 21.93, explicitly defines what constitutes a minor repair (https://www.law.cornell.edu/cfr/text/14/21.93):
> > >
> > > "(a) In addition to changes in type design specified in paragraph (b) of this section, changes in type design are classified as minor and major. 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)."
> > >
> > > The addition of instrument not required for certification constitutes a minor alteration (unless it affects the performance of required instrumentation) and meets the above criteria. An FAA airframe inspector are available to answer any questions concerning these regulations. My experience with FAA inspectors is they are really trying to make compliance as easy as possible and are not trying to make your life miserable.
> > >
> > > Tom
> >
> > That definition of minor change leaves very wide latitude for minor changes. Also great latitude for judgement about what is considered a minor change.
>
> I totally disagree. 14 CFR 21.93 clearly states:
>
> 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.
>
> If ANY of these conditions are met, it is a major change requiring the attendant paperwork. You don't make this judgment, your A&P does. And I would consult with an IA who is authorized to sign off on major changes.
>
> Tom

There is very little you can do to the panel that would affect any of those things. As long as the required instruments stayed in place, you could replace the entire panel with a homebuilt one made from crumb board from Home Depot, complete with a lawn sprinkler controller and a hair dryer. Weight, balance, structural strength, reliability, operational or other characteristics? No appreciable affect, hence minor change. Yeah the A&P would need to sign. He's the one with the great latitude for judgement.

[2G]

On Saturday, May 19, 2018 at 9:52:05 AM UTC-7, jfitch wrote:
> On Saturday, May 19, 2018 at 8:51:12 AM UTC-7, 2G wrote:
> > On Saturday, May 19, 2018 at 7:23:32 AM UTC-7, jfitch wrote:
> > > On Saturday, May 12, 2018 at 3:10:57 PM UTC-7, 2G wrote:
> > > > On Thursday, May 10, 2018 at 11:35:08 PM UTC-7, Bob Kuykendall wrote:
> > > > > On Thursday, May 10, 2018 at 7:48:12 PM UTC-7, 2G wrote:
> > > > > > So, you think I am full of ****...
> > > > >
> > > > > I wouldn't have put it in so few words.
> > > >
> > > > If you do call the FAA for guidance, they will likely refer you Advisory Circular AC 43-210A (https://www.faa.gov/documentLibrary/media/Advisory_Circular/AC_43-210A.pdf) “Standardized Procedures for Obtaining Approval of Data Used in the Performance of Major Repairs and Major Alterations.” This covers what constitutes a minor repair:
> > > >
> > > > “3.2.2 Determine the Repair or Alteration Classification. Determine if the repair/alteration is a minor change in type design (as defined in 14 CFR part 21, § 21.93) to the product’s type design; and if so, is it a major or a minor repair/alteration. To determine if a repair/alteration is major or minor, refer to part 43 appendix A. Figure 3-2, Determination of Major or Minor Alteration or Repair, is a flowchart of the field approval evaluation process based on part 43 appendix A.”
> > > >
> > > > The regulation referenced, 14 CFR part 21, § 21.93, explicitly defines what constitutes a minor repair (https://www.law.cornell.edu/cfr/text/14/21.93):
> > > >
> > > > "(a) In addition to changes in type design specified in paragraph (b) of this section, changes in type design are classified as minor and major. 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)."
> > > >
> > > > The addition of instrument not required for certification constitutes a minor alteration (unless it affects the performance of required instrumentation) and meets the above criteria. An FAA airframe inspector are available to answer any questions concerning these regulations. My experience with FAA inspectors is they are really trying to make compliance as easy as possible and are not trying to make your life miserable.
> > > >
> > > > Tom
> > >
> > > That definition of minor change leaves very wide latitude for minor changes. Also great latitude for judgement about what is considered a minor change.
> >
> > I totally disagree. 14 CFR 21.93 clearly states:
> >
> > 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.
> >
> > If ANY of these conditions are met, it is a major change requiring the attendant paperwork. You don't make this judgment, your A&P does. And I would consult with an IA who is authorized to sign off on major changes.
> >
> > Tom
>
> There is very little you can do to the panel that would affect any of those things. As long as the required instruments stayed in place, you could replace the entire panel with a homebuilt one made from crumb board from Home Depot, complete with a lawn sprinkler controller and a hair dryer. Weight, balance, structural strength, reliability, operational or other characteristics? No appreciable affect, hence minor change. Yeah the A&P would need to sign. He's the one with the great latitude for judgement.

Now you are being silly. Adding ADS-B Out to a standard category aircraft, for example, IS NOT a "minor" change, requiring an STC.

Tom

[jfitch]

On Sunday, May 20, 2018 at 9:06:11 AM UTC-7, 2G wrote:
> On Saturday, May 19, 2018 at 9:52:05 AM UTC-7, jfitch wrote:
> > On Saturday, May 19, 2018 at 8:51:12 AM UTC-7, 2G wrote:
> > > On Saturday, May 19, 2018 at 7:23:32 AM UTC-7, jfitch wrote:
> > > > On Saturday, May 12, 2018 at 3:10:57 PM UTC-7, 2G wrote:
> > > > > On Thursday, May 10, 2018 at 11:35:08 PM UTC-7, Bob Kuykendall wrote:
> > > > > > On Thursday, May 10, 2018 at 7:48:12 PM UTC-7, 2G wrote:
> > > > > > > So, you think I am full of ****...
> > > > > >
> > > > > > I wouldn't have put it in so few words.
> > > > >
> > > > > If you do call the FAA for guidance, they will likely refer you Advisory Circular AC 43-210A (https://www.faa.gov/documentLibrary/media/Advisory_Circular/AC_43-210A.pdf) “Standardized Procedures for Obtaining Approval of Data Used in the Performance of Major Repairs and Major Alterations.” This covers what constitutes a minor repair:
> > > > >
> > > > > “3.2.2 Determine the Repair or Alteration Classification. Determine if the repair/alteration is a minor change in type design (as defined in 14 CFR part 21, § 21.93) to the product’s type design; and if so, is it a major or a minor repair/alteration. To determine if a repair/alteration is major or minor, refer to part 43 appendix A. Figure 3-2, Determination of Major or Minor Alteration or Repair, is a flowchart of the field approval evaluation process based on part 43 appendix A.”
> > > > >
> > > > > The regulation referenced, 14 CFR part 21, § 21.93, explicitly defines what constitutes a minor repair (https://www.law.cornell.edu/cfr/text/14/21.93):
> > > > >
> > > > > "(a) In addition to changes in type design specified in paragraph (b) of this section, changes in type design are classified as minor and major. 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)."
> > > > >
> > > > > The addition of instrument not required for certification constitutes a minor alteration (unless it affects the performance of required instrumentation) and meets the above criteria. An FAA airframe inspector are available to answer any questions concerning these regulations. My experience with FAA inspectors is they are really trying to make compliance as easy as possible and are not trying to make your life miserable.
> > > > >
> > > > > Tom
> > > >
> > > > That definition of minor change leaves very wide latitude for minor changes. Also great latitude for judgement about what is considered a minor change.
> > >
> > > I totally disagree. 14 CFR 21.93 clearly states:
> > >
> > > 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.
> > >
> > > If ANY of these conditions are met, it is a major change requiring the attendant paperwork. You don't make this judgment, your A&P does. And I would consult with an IA who is authorized to sign off on major changes.
> > >
> > > Tom
> >
> > There is very little you can do to the panel that would affect any of those things. As long as the required instruments stayed in place, you could replace the entire panel with a homebuilt one made from crumb board from Home Depot, complete with a lawn sprinkler controller and a hair dryer. Weight, balance, structural strength, reliability, operational or other characteristics? No appreciable affect, hence minor change. Yeah the A&P would need to sign. He's the one with the great latitude for judgement.
>
> Now you are being silly. Adding ADS-B Out to a standard category aircraft, for example, IS NOT a "minor" change, requiring an STC.
>
> Tom

I believe that is wrong, but will leave it to others to argue the case. It may be true that adding ADS-B out TO MEET CARRIAGE REQUIREMENTS in a standard category aircraft requires an STC. Regardless, that is very different than Scotch taping a PDA to the dashboard, which is what this thread is about.. I can add 12 of those, not tell a soul, and be completely legal - as long as they don't weigh too much :).

[[email protected]]

Bob K wins the internet today.

[Darryl Ramm]

On Sunday, May 20, 2018 at 9:06:11 AM UTC-7, 2G wrote:
> On Saturday, May 19, 2018 at 9:52:05 AM UTC-7, jfitch wrote:
> > On Saturday, May 19, 2018 at 8:51:12 AM UTC-7, 2G wrote:
> > > On Saturday, May 19, 2018 at 7:23:32 AM UTC-7, jfitch wrote:
> > > > On Saturday, May 12, 2018 at 3:10:57 PM UTC-7, 2G wrote:
> > > > > On Thursday, May 10, 2018 at 11:35:08 PM UTC-7, Bob Kuykendall wrote:
> > > > > > On Thursday, May 10, 2018 at 7:48:12 PM UTC-7, 2G wrote:
> > > > > > > So, you think I am full of ****...
> > > > > >
> > > > > > I wouldn't have put it in so few words.
> > > > >
> > > > > If you do call the FAA for guidance, they will likely refer you Advisory Circular AC 43-210A (https://www.faa.gov/documentLibrary/media/Advisory_Circular/AC_43-210A.pdf) “Standardized Procedures for Obtaining Approval of Data Used in the Performance of Major Repairs and Major Alterations.” This covers what constitutes a minor repair:
> > > > >
> > > > > “3.2.2 Determine the Repair or Alteration Classification. Determine if the repair/alteration is a minor change in type design (as defined in 14 CFR part 21, § 21.93) to the product’s type design; and if so, is it a major or a minor repair/alteration. To determine if a repair/alteration is major or minor, refer to part 43 appendix A. Figure 3-2, Determination of Major or Minor Alteration or Repair, is a flowchart of the field approval evaluation process based on part 43 appendix A.”
> > > > >
> > > > > The regulation referenced, 14 CFR part 21, § 21.93, explicitly defines what constitutes a minor repair (https://www.law.cornell.edu/cfr/text/14/21.93):
> > > > >
> > > > > "(a) In addition to changes in type design specified in paragraph (b) of this section, changes in type design are classified as minor and major. 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)."
> > > > >
> > > > > The addition of instrument not required for certification constitutes a minor alteration (unless it affects the performance of required instrumentation) and meets the above criteria. An FAA airframe inspector are available to answer any questions concerning these regulations. My experience with FAA inspectors is they are really trying to make compliance as easy as possible and are not trying to make your life miserable.
> > > > >
> > > > > Tom
> > > >
> > > > That definition of minor change leaves very wide latitude for minor changes. Also great latitude for judgement about what is considered a minor change.
> > >
> > > I totally disagree. 14 CFR 21.93 clearly states:
> > >
> > > 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.
> > >
> > > If ANY of these conditions are met, it is a major change requiring the attendant paperwork. You don't make this judgment, your A&P does. And I would consult with an IA who is authorized to sign off on major changes.
> > >
> > > Tom
> >
> > There is very little you can do to the panel that would affect any of those things. As long as the required instruments stayed in place, you could replace the entire panel with a homebuilt one made from crumb board from Home Depot, complete with a lawn sprinkler controller and a hair dryer. Weight, balance, structural strength, reliability, operational or other characteristics? No appreciable affect, hence minor change. Yeah the A&P would need to sign. He's the one with the great latitude for judgement.
>
> Now you are being silly. Adding ADS-B Out to a standard category aircraft, for example, IS NOT a "minor" change, requiring an STC.
>
> Tom


No, this is not correct and is misinformation that can create problems for other glider owners.

Show us one regulation or FAA policy that states an ADS-B Out install is necessarily a major modification....

ADS-B Out installs can "require an STC?" yes, in a very specific way, as one (the most common) way to justify the pairing of a specific ADS-B transmitter and GPS Source. That use of an STC is special and does *not* automatically make the install a major alteration, but that seems to be confusing Tom here.

---

So people do not cause themselves problems by believing this wrong information here is more explanation: (or just remember this is here and point your A&P at it if needed).

Wether an ADS-B Out install is a major or minor modification in a certified aircraft has the same tests applied to it as any other modification. That's because there is *no* FAA regulation or policy saying an ADS-B Out install is a major modification, so the normal rules apply.

Once upon a time an ADS-B Out install in a type certified aircraft was more complex, it's simpler now. So be careful about looking at old information.

For the last few years the FAA policy uses an STC as (the most common) basis for pairing the transponder and GPS source, and requires the installer to follow the relevant STC documentation for pairing those devices. That STC is not necessarily used there as the basis for the approval of a major modification (and since there are no glider-specific STCs for any of these installs, or even a basic transponder install, those STC likely do not cover enough for an install in a glider to do so). The FAA was being very pragmatic here about avoiding problems with pairing different devices and wanted to know that devices paired in actual installs had been proven to work well together and documented in a prior STC.

The key FAA policy document guiding all this is N 8900.362 https://www.faa.gov/regulations_policies/orders_notices/index.cfm/go/document.information/documentID/1029526 (People wanting more technical info can also read AC 20-165B https://www.faa.gov/regulations_policies/advisory_circulars/index.cfm/go/document.information/documentID/1028666). And yes this policy document is past its expiration date, but is still the reference doc being used by FSDOs and others (the expiration date issue has been explained a lot elsewhere, Google for it if curious). Section 6 in that policy describes the requirements for "subsequent installs" using an STC to justify the pairing, and is pretty straightforward.

That policy requires filing an "notification only" (the term commonly used to refer to doing that, but the policy does not use that exact term) 337 with FAA HQ in Oklahoma, not with the FSDO. That does *not* make that installation automatically a major change, and does not anywhere require filing that 337 with the FSDO for major modification approval. If the A&P IA determines the change is a major modification (separate from anything to do with that is is "ADS-B") then they could would file a 337 for approval with the FSDO as normal for a major modification.

Some folks have unfortunately read that the policy and see mention of 337s and are not reading clearly what it says and assume they *have* to file the 337 with the FSDO, the FSDO may see an inbound 337 and assumes the A&P is seeking approval for a major change... and that might start a pile of unnecessary work. Read the policy document carefully and follow it, it's really that simple.

Owners may want to talk to their A&P IA before they do an ADS-B Out install and ask them what paperwork they plan to file/where/why if it's different than what I'm outlining here it may be a good to check they are familiar with that FAA policy N 8900.362.

---

Other general things to help A&Ps and glider owners:

There is no paperwork/notice only 337 to file for any ADS-B Out or TABS install in any experimental aircraft.

For 2020 Complaint installs in a type certified glider: you need to use a Trig TT22 transponder and TN70 GPS Source (since its actual TSO-C145c approved). All the glider community Trig dealers know how to get the TT22+TN70 STC paperwork from Peregrine (Trig's STC development partner). Your A&P will want to get that paperwork, even though again its not being used to support a major alteration approval.

Do NOT do a SIL-3/"2020 Compliant" install in a type certified aircraft using a non-TSO-C145c or similar actual TSO approved GPS source. And the FAA could easily spot that something is up as there won't be that notification only 337 filed for your aircraft in their database. The TN72 CAN be used to do TABS SIL=1 in a type certified glider, but not 2020 Compliant ADS-B Out. There is no paperwork to file anywhere for a TABS install. Double check any such install to make sure you are transmitting SIL=1 not SIL-3.

Since the TN72 is a "meets performance requirements..." but not actual TSO-C145c or similar GPS source, you can do a 2020 Compliant SIL-3 install with a TN72 and TT22 in a *experimental* glider (but not a type certificated glider) again, there is no FAA paperwork to file for a TABS install, just a maintenance log book entry.

Pull an FAA ADS-B flight report for all installs, ideally the first few flights, for both 2020 Compliant ADS-B Out or TABS. https://adsbperformance.faa.gov/PAPRRequest.aspx I'm happy to help people look at the reports and make sure they look OK.

[2G]

On Sunday, May 20, 2018 at 5:19:22 PM UTC-7, Darryl Ramm wrote:
> On Sunday, May 20, 2018 at 9:06:11 AM UTC-7, 2G wrote:
> > On Saturday, May 19, 2018 at 9:52:05 AM UTC-7, jfitch wrote:
> > > On Saturday, May 19, 2018 at 8:51:12 AM UTC-7, 2G wrote:
> > > > On Saturday, May 19, 2018 at 7:23:32 AM UTC-7, jfitch wrote:
> > > > > On Saturday, May 12, 2018 at 3:10:57 PM UTC-7, 2G wrote:
> > > > > > On Thursday, May 10, 2018 at 11:35:08 PM UTC-7, Bob Kuykendall wrote:
> > > > > > > On Thursday, May 10, 2018 at 7:48:12 PM UTC-7, 2G wrote:
> > > > > > > > So, you think I am full of ****...
> > > > > > >
> > > > > > > I wouldn't have put it in so few words.
> > > > > >
> > > > > > If you do call the FAA for guidance, they will likely refer you Advisory Circular AC 43-210A (https://www.faa.gov/documentLibrary/media/Advisory_Circular/AC_43-210A.pdf) “Standardized Procedures for Obtaining Approval of Data Used in the Performance of Major Repairs and Major Alterations.” This covers what constitutes a minor repair:
> > > > > >
> > > > > > “3.2.2 Determine the Repair or Alteration Classification. Determine if the repair/alteration is a minor change in type design (as defined in 14 CFR part 21, § 21.93) to the product’s type design; and if so, is it a major or a minor repair/alteration. To determine if a repair/alteration is major or minor, refer to part 43 appendix A. Figure 3-2, Determination of Major or Minor Alteration or Repair, is a flowchart of the field approval evaluation process based on part 43 appendix A.”
> > > > > >
> > > > > > The regulation referenced, 14 CFR part 21, § 21.93, explicitly defines what constitutes a minor repair (https://www.law.cornell.edu/cfr/text/14/21.93):
> > > > > >
> > > > > > "(a) In addition to changes in type design specified in paragraph (b) of this section, changes in type design are classified as minor and major. 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)."
> > > > > >
> > > > > > The addition of instrument not required for certification constitutes a minor alteration (unless it affects the performance of required instrumentation) and meets the above criteria. An FAA airframe inspector are available to answer any questions concerning these regulations. My experience with FAA inspectors is they are really trying to make compliance as easy as possible and are not trying to make your life miserable.
> > > > > >
> > > > > > Tom
> > > > >
> > > > > That definition of minor change leaves very wide latitude for minor changes. Also great latitude for judgement about what is considered a minor change.
> > > >
> > > > I totally disagree. 14 CFR 21.93 clearly states:
> > > >
> > > > 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.
> > > >
> > > > If ANY of these conditions are met, it is a major change requiring the attendant paperwork. You don't make this judgment, your A&P does. And I would consult with an IA who is authorized to sign off on major changes.
> > > >
> > > > Tom
> > >
> > > There is very little you can do to the panel that would affect any of those things. As long as the required instruments stayed in place, you could replace the entire panel with a homebuilt one made from crumb board from Home Depot, complete with a lawn sprinkler controller and a hair dryer. Weight, balance, structural strength, reliability, operational or other characteristics? No appreciable affect, hence minor change. Yeah the A&P would need to sign. He's the one with the great latitude for judgement.
> >
> > Now you are being silly. Adding ADS-B Out to a standard category aircraft, for example, IS NOT a "minor" change, requiring an STC.
> >
> > Tom
>
>
> No, this is not correct and is misinformation that can create problems for other glider owners.
>
> Show us one regulation or FAA policy that states an ADS-B Out install is necessarily a major modification....
>
> ADS-B Out installs can "require an STC?" yes, in a very specific way, as one (the most common) way to justify the pairing of a specific ADS-B transmitter and GPS Source. That use of an STC is special and does *not* automatically make the install a major alteration, but that seems to be confusing Tom here.
>
> ---
>
> So people do not cause themselves problems by believing this wrong information here is more explanation: (or just remember this is here and point your A&P at it if needed).
>
> Wether an ADS-B Out install is a major or minor modification in a certified aircraft has the same tests applied to it as any other modification. That's because there is *no* FAA regulation or policy saying an ADS-B Out install is a major modification, so the normal rules apply.
>
> Once upon a time an ADS-B Out install in a type certified aircraft was more complex, it's simpler now. So be careful about looking at old information.
>
> For the last few years the FAA policy uses an STC as (the most common) basis for pairing the transponder and GPS source, and requires the installer to follow the relevant STC documentation for pairing those devices. That STC is not necessarily used there as the basis for the approval of a major modification (and since there are no glider-specific STCs for any of these installs, or even a basic transponder install, those STC likely do not cover enough for an install in a glider to do so). The FAA was being very pragmatic here about avoiding problems with pairing different devices and wanted to know that devices paired in actual installs had been proven to work well together and documented in a prior STC.
>
> The key FAA policy document guiding all this is N 8900.362 https://www.faa.gov/regulations_policies/orders_notices/index.cfm/go/document.information/documentID/1029526 (People wanting more technical info can also read AC 20-165B https://www.faa.gov/regulations_policies/advisory_circulars/index.cfm/go/document.information/documentID/1028666). And yes this policy document is past its expiration date, but is still the reference doc being used by FSDOs and others (the expiration date issue has been explained a lot elsewhere, Google for it if curious). Section 6 in that policy describes the requirements for "subsequent installs" using an STC to justify the pairing, and is pretty straightforward.
>
> That policy requires filing an "notification only" (the term commonly used to refer to doing that, but the policy does not use that exact term) 337 with FAA HQ in Oklahoma, not with the FSDO. That does *not* make that installation automatically a major change, and does not anywhere require filing that 337 with the FSDO for major modification approval. If the A&P IA determines the change is a major modification (separate from anything to do with that is is "ADS-B") then they could would file a 337 for approval with the FSDO as normal for a major modification.
>
> Some folks have unfortunately read that the policy and see mention of 337s and are not reading clearly what it says and assume they *have* to file the 337 with the FSDO, the FSDO may see an inbound 337 and assumes the A&P is seeking approval for a major change... and that might start a pile of unnecessary work. Read the policy document carefully and follow it, it's really that simple.
>
> Owners may want to talk to their A&P IA before they do an ADS-B Out install and ask them what paperwork they plan to file/where/why if it's different than what I'm outlining here it may be a good to check they are familiar with that FAA policy N 8900.362.
>
> ---
>
> Other general things to help A&Ps and glider owners:
>
> There is no paperwork/notice only 337 to file for any ADS-B Out or TABS install in any experimental aircraft.
>
> For 2020 Complaint installs in a type certified glider: you need to use a Trig TT22 transponder and TN70 GPS Source (since its actual TSO-C145c approved). All the glider community Trig dealers know how to get the TT22+TN70 STC paperwork from Peregrine (Trig's STC development partner). Your A&P will want to get that paperwork, even though again its not being used to support a major alteration approval.
>
> Do NOT do a SIL-3/"2020 Compliant" install in a type certified aircraft using a non-TSO-C145c or similar actual TSO approved GPS source. And the FAA could easily spot that something is up as there won't be that notification only 337 filed for your aircraft in their database. The TN72 CAN be used to do TABS SIL=1 in a type certified glider, but not 2020 Compliant ADS-B Out. There is no paperwork to file anywhere for a TABS install. Double check any such install to make sure you are transmitting SIL=1 not SIL-3.
>
> Since the TN72 is a "meets performance requirements..." but not actual TSO-C145c or similar GPS source, you can do a 2020 Compliant SIL-3 install with a TN72 and TT22 in a *experimental* glider (but not a type certificated glider) again, there is no FAA paperwork to file for a TABS install, just a maintenance log book entry.
>
> Pull an FAA ADS-B flight report for all installs, ideally the first few flights, for both 2020 Compliant ADS-B Out or TABS. https://adsbperformance.faa.gov/PAPRRequest.aspx I'm happy to help people look at the reports and make sure they look OK.

The FAA regulation is the fore-mentioned 14 CFR 21.93. Not convinced - check this out:
https://www.trig-avionics.com/support/u-s-ads-b-stc-program/

I quote from this link:

"The FAA also requires that a certified ADS-B installation is completed in accordance with an FAA STC approval (Supplementary Type Certificate)."

I agree with you that owners SHOULD consult with their A&P and NOT take your bloviations as gospel. They can also talk to the good folks at their local FSDO, the ultimate decision makers on this subject.

Tom

[2G]

On Sunday, May 20, 2018 at 5:19:22 PM UTC-7, Darryl Ramm wrote:
> On Sunday, May 20, 2018 at 9:06:11 AM UTC-7, 2G wrote:
> > On Saturday, May 19, 2018 at 9:52:05 AM UTC-7, jfitch wrote:
> > > On Saturday, May 19, 2018 at 8:51:12 AM UTC-7, 2G wrote:
> > > > On Saturday, May 19, 2018 at 7:23:32 AM UTC-7, jfitch wrote:
> > > > > On Saturday, May 12, 2018 at 3:10:57 PM UTC-7, 2G wrote:
> > > > > > On Thursday, May 10, 2018 at 11:35:08 PM UTC-7, Bob Kuykendall wrote:
> > > > > > > On Thursday, May 10, 2018 at 7:48:12 PM UTC-7, 2G wrote:
> > > > > > > > So, you think I am full of ****...
> > > > > > >
> > > > > > > I wouldn't have put it in so few words.
> > > > > >
> > > > > > If you do call the FAA for guidance, they will likely refer you Advisory Circular AC 43-210A (https://www.faa.gov/documentLibrary/media/Advisory_Circular/AC_43-210A.pdf) “Standardized Procedures for Obtaining Approval of Data Used in the Performance of Major Repairs and Major Alterations.” This covers what constitutes a minor repair:
> > > > > >
> > > > > > “3.2.2 Determine the Repair or Alteration Classification. Determine if the repair/alteration is a minor change in type design (as defined in 14 CFR part 21, § 21.93) to the product’s type design; and if so, is it a major or a minor repair/alteration. To determine if a repair/alteration is major or minor, refer to part 43 appendix A. Figure 3-2, Determination of Major or Minor Alteration or Repair, is a flowchart of the field approval evaluation process based on part 43 appendix A.”
> > > > > >
> > > > > > The regulation referenced, 14 CFR part 21, § 21.93, explicitly defines what constitutes a minor repair (https://www.law.cornell.edu/cfr/text/14/21.93):
> > > > > >
> > > > > > "(a) In addition to changes in type design specified in paragraph (b) of this section, changes in type design are classified as minor and major. 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)."
> > > > > >
> > > > > > The addition of instrument not required for certification constitutes a minor alteration (unless it affects the performance of required instrumentation) and meets the above criteria. An FAA airframe inspector are available to answer any questions concerning these regulations. My experience with FAA inspectors is they are really trying to make compliance as easy as possible and are not trying to make your life miserable.
> > > > > >
> > > > > > Tom
> > > > >
> > > > > That definition of minor change leaves very wide latitude for minor changes. Also great latitude for judgement about what is considered a minor change.
> > > >
> > > > I totally disagree. 14 CFR 21.93 clearly states:
> > > >
> > > > 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.
> > > >
> > > > If ANY of these conditions are met, it is a major change requiring the attendant paperwork. You don't make this judgment, your A&P does. And I would consult with an IA who is authorized to sign off on major changes.
> > > >
> > > > Tom
> > >
> > > There is very little you can do to the panel that would affect any of those things. As long as the required instruments stayed in place, you could replace the entire panel with a homebuilt one made from crumb board from Home Depot, complete with a lawn sprinkler controller and a hair dryer. Weight, balance, structural strength, reliability, operational or other characteristics? No appreciable affect, hence minor change. Yeah the A&P would need to sign. He's the one with the great latitude for judgement.
> >
> > Now you are being silly. Adding ADS-B Out to a standard category aircraft, for example, IS NOT a "minor" change, requiring an STC.
> >
> > Tom
>
>
> No, this is not correct and is misinformation that can create problems for other glider owners.
>
> Show us one regulation or FAA policy that states an ADS-B Out install is necessarily a major modification....
>
> ADS-B Out installs can "require an STC?" yes, in a very specific way, as one (the most common) way to justify the pairing of a specific ADS-B transmitter and GPS Source. That use of an STC is special and does *not* automatically make the install a major alteration, but that seems to be confusing Tom here.
>
> ---
>
> So people do not cause themselves problems by believing this wrong information here is more explanation: (or just remember this is here and point your A&P at it if needed).
>
> Wether an ADS-B Out install is a major or minor modification in a certified aircraft has the same tests applied to it as any other modification. That's because there is *no* FAA regulation or policy saying an ADS-B Out install is a major modification, so the normal rules apply.
>
> Once upon a time an ADS-B Out install in a type certified aircraft was more complex, it's simpler now. So be careful about looking at old information.
>
> For the last few years the FAA policy uses an STC as (the most common) basis for pairing the transponder and GPS source, and requires the installer to follow the relevant STC documentation for pairing those devices. That STC is not necessarily used there as the basis for the approval of a major modification (and since there are no glider-specific STCs for any of these installs, or even a basic transponder install, those STC likely do not cover enough for an install in a glider to do so). The FAA was being very pragmatic here about avoiding problems with pairing different devices and wanted to know that devices paired in actual installs had been proven to work well together and documented in a prior STC.
>
> The key FAA policy document guiding all this is N 8900.362 https://www.faa.gov/regulations_policies/orders_notices/index.cfm/go/document.information/documentID/1029526 (People wanting more technical info can also read AC 20-165B https://www.faa.gov/regulations_policies/advisory_circulars/index.cfm/go/document.information/documentID/1028666). And yes this policy document is past its expiration date, but is still the reference doc being used by FSDOs and others (the expiration date issue has been explained a lot elsewhere, Google for it if curious). Section 6 in that policy describes the requirements for "subsequent installs" using an STC to justify the pairing, and is pretty straightforward.
>
> That policy requires filing an "notification only" (the term commonly used to refer to doing that, but the policy does not use that exact term) 337 with FAA HQ in Oklahoma, not with the FSDO. That does *not* make that installation automatically a major change, and does not anywhere require filing that 337 with the FSDO for major modification approval. If the A&P IA determines the change is a major modification (separate from anything to do with that is is "ADS-B") then they could would file a 337 for approval with the FSDO as normal for a major modification.
>
> Some folks have unfortunately read that the policy and see mention of 337s and are not reading clearly what it says and assume they *have* to file the 337 with the FSDO, the FSDO may see an inbound 337 and assumes the A&P is seeking approval for a major change... and that might start a pile of unnecessary work. Read the policy document carefully and follow it, it's really that simple.
>
> Owners may want to talk to their A&P IA before they do an ADS-B Out install and ask them what paperwork they plan to file/where/why if it's different than what I'm outlining here it may be a good to check they are familiar with that FAA policy N 8900.362.
>
> ---
>
> Other general things to help A&Ps and glider owners:
>
> There is no paperwork/notice only 337 to file for any ADS-B Out or TABS install in any experimental aircraft.
>
> For 2020 Complaint installs in a type certified glider: you need to use a Trig TT22 transponder and TN70 GPS Source (since its actual TSO-C145c approved). All the glider community Trig dealers know how to get the TT22+TN70 STC paperwork from Peregrine (Trig's STC development partner). Your A&P will want to get that paperwork, even though again its not being used to support a major alteration approval.
>
> Do NOT do a SIL-3/"2020 Compliant" install in a type certified aircraft using a non-TSO-C145c or similar actual TSO approved GPS source. And the FAA could easily spot that something is up as there won't be that notification only 337 filed for your aircraft in their database. The TN72 CAN be used to do TABS SIL=1 in a type certified glider, but not 2020 Compliant ADS-B Out. There is no paperwork to file anywhere for a TABS install. Double check any such install to make sure you are transmitting SIL=1 not SIL-3.
>
> Since the TN72 is a "meets performance requirements..." but not actual TSO-C145c or similar GPS source, you can do a 2020 Compliant SIL-3 install with a TN72 and TT22 in a *experimental* glider (but not a type certificated glider) again, there is no FAA paperwork to file for a TABS install, just a maintenance log book entry.
>
> Pull an FAA ADS-B flight report for all installs, ideally the first few flights, for both 2020 Compliant ADS-B Out or TABS. https://adsbperformance.faa.gov/PAPRRequest.aspx I'm happy to help people look at the reports and make sure they look OK.

If you had bothered to contact the FAA (but you can't be bothered and consider them to be a nuisance), they could have provided you with this resource:
https://www.faa.gov/nextgen/equipadsb/resources/media/ADS-B_Out-In_Installation_Tech_Paper(9-25-17).pdf

I quote:

"The purpose of this Technical Paper is to explain the Federal Aviation Administration’s (FAA) policy regarding alterations to aircraft for the installation of Automatic Dependent Surveillance-Broadcast (ADS-B) equipment. This policy applies to aircraft certificated under Title 14, Code of Federal Regulations (14 CFR) § 23, 25, 27, 29, and their predecessor regulations. This Technical Paper provides policy pursuant to compliance with 14 CFR § 91.225 and § 91.227. "

[Darryl Ramm]

On Sunday, May 20, 2018 at 5:58:07 PM UTC-7, 2G wrote:
> On Sunday, May 20, 2018 at 5:19:22 PM UTC-7, Darryl Ramm wrote:
> > On Sunday, May 20, 2018 at 9:06:11 AM UTC-7, 2G wrote:
> > > On Saturday, May 19, 2018 at 9:52:05 AM UTC-7, jfitch wrote:
> > > > On Saturday, May 19, 2018 at 8:51:12 AM UTC-7, 2G wrote:
> > > > > On Saturday, May 19, 2018 at 7:23:32 AM UTC-7, jfitch wrote:
> > > > > > On Saturday, May 12, 2018 at 3:10:57 PM UTC-7, 2G wrote:
> > > > > > > On Thursday, May 10, 2018 at 11:35:08 PM UTC-7, Bob Kuykendall wrote:
> > > > > > > > On Thursday, May 10, 2018 at 7:48:12 PM UTC-7, 2G wrote:
> > > > > > > > > So, you think I am full of ****...
> > > > > > > >
> > > > > > > > I wouldn't have put it in so few words.
> > > > > > >
> > > > > > > If you do call the FAA for guidance, they will likely refer you Advisory Circular AC 43-210A (https://www.faa.gov/documentLibrary/media/Advisory_Circular/AC_43-210A.pdf) “Standardized Procedures for Obtaining Approval of Data Used in the Performance of Major Repairs and Major Alterations.” This covers what constitutes a minor repair:
> > > > > > >
> > > > > > > “3.2.2 Determine the Repair or Alteration Classification. Determine if the repair/alteration is a minor change in type design (as defined in 14 CFR part 21, § 21.93) to the product’s type design; and if so, is it a major or a minor repair/alteration. To determine if a repair/alteration is major or minor, refer to part 43 appendix A. Figure 3-2, Determination of Major or Minor Alteration or Repair, is a flowchart of the field approval evaluation process based on part 43 appendix A.”
> > > > > > >
> > > > > > > The regulation referenced, 14 CFR part 21, § 21.93, explicitly defines what constitutes a minor repair (https://www.law.cornell.edu/cfr/text/14/21.93):
> > > > > > >
> > > > > > > "(a) In addition to changes in type design specified in paragraph (b) of this section, changes in type design are classified as minor and major. 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)."
> > > > > > >
> > > > > > > The addition of instrument not required for certification constitutes a minor alteration (unless it affects the performance of required instrumentation) and meets the above criteria. An FAA airframe inspector are available to answer any questions concerning these regulations. My experience with FAA inspectors is they are really trying to make compliance as easy as possible and are not trying to make your life miserable.
> > > > > > >
> > > > > > > Tom
> > > > > >
> > > > > > That definition of minor change leaves very wide latitude for minor changes. Also great latitude for judgement about what is considered a minor change.
> > > > >
> > > > > I totally disagree. 14 CFR 21.93 clearly states:
> > > > >
> > > > > 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.
> > > > >
> > > > > If ANY of these conditions are met, it is a major change requiring the attendant paperwork. You don't make this judgment, your A&P does. And I would consult with an IA who is authorized to sign off on major changes.
> > > > >
> > > > > Tom
> > > >
> > > > There is very little you can do to the panel that would affect any of those things. As long as the required instruments stayed in place, you could replace the entire panel with a homebuilt one made from crumb board from Home Depot, complete with a lawn sprinkler controller and a hair dryer. Weight, balance, structural strength, reliability, operational or other characteristics? No appreciable affect, hence minor change. Yeah the A&P would need to sign. He's the one with the great latitude for judgement.
> > >
> > > Now you are being silly. Adding ADS-B Out to a standard category aircraft, for example, IS NOT a "minor" change, requiring an STC.
> > >
> > > Tom
> >
> >
> > No, this is not correct and is misinformation that can create problems for other glider owners.
> >
> > Show us one regulation or FAA policy that states an ADS-B Out install is necessarily a major modification....
> >
> > ADS-B Out installs can "require an STC?" yes, in a very specific way, as one (the most common) way to justify the pairing of a specific ADS-B transmitter and GPS Source. That use of an STC is special and does *not* automatically make the install a major alteration, but that seems to be confusing Tom here.
> >
> > ---
> >
> > So people do not cause themselves problems by believing this wrong information here is more explanation: (or just remember this is here and point your A&P at it if needed).
> >
> > Wether an ADS-B Out install is a major or minor modification in a certified aircraft has the same tests applied to it as any other modification. That's because there is *no* FAA regulation or policy saying an ADS-B Out install is a major modification, so the normal rules apply.
> >
> > Once upon a time an ADS-B Out install in a type certified aircraft was more complex, it's simpler now. So be careful about looking at old information.
> >
> > For the last few years the FAA policy uses an STC as (the most common) basis for pairing the transponder and GPS source, and requires the installer to follow the relevant STC documentation for pairing those devices. That STC is not necessarily used there as the basis for the approval of a major modification (and since there are no glider-specific STCs for any of these installs, or even a basic transponder install, those STC likely do not cover enough for an install in a glider to do so). The FAA was being very pragmatic here about avoiding problems with pairing different devices and wanted to know that devices paired in actual installs had been proven to work well together and documented in a prior STC.
> >
> > The key FAA policy document guiding all this is N 8900.362 https://www.faa.gov/regulations_policies/orders_notices/index.cfm/go/document.information/documentID/1029526 (People wanting more technical info can also read AC 20-165B https://www.faa.gov/regulations_policies/advisory_circulars/index.cfm/go/document.information/documentID/1028666). And yes this policy document is past its expiration date, but is still the reference doc being used by FSDOs and others (the expiration date issue has been explained a lot elsewhere, Google for it if curious). Section 6 in that policy describes the requirements for "subsequent installs" using an STC to justify the pairing, and is pretty straightforward.
> >
> > That policy requires filing an "notification only" (the term commonly used to refer to doing that, but the policy does not use that exact term) 337 with FAA HQ in Oklahoma, not with the FSDO. That does *not* make that installation automatically a major change, and does not anywhere require filing that 337 with the FSDO for major modification approval. If the A&P IA determines the change is a major modification (separate from anything to do with that is is "ADS-B") then they could would file a 337 for approval with the FSDO as normal for a major modification.
> >
> > Some folks have unfortunately read that the policy and see mention of 337s and are not reading clearly what it says and assume they *have* to file the 337 with the FSDO, the FSDO may see an inbound 337 and assumes the A&P is seeking approval for a major change... and that might start a pile of unnecessary work. Read the policy document carefully and follow it, it's really that simple.
> >
> > Owners may want to talk to their A&P IA before they do an ADS-B Out install and ask them what paperwork they plan to file/where/why if it's different than what I'm outlining here it may be a good to check they are familiar with that FAA policy N 8900.362.
> >
> > ---
> >
> > Other general things to help A&Ps and glider owners:
> >
> > There is no paperwork/notice only 337 to file for any ADS-B Out or TABS install in any experimental aircraft.
> >
> > For 2020 Complaint installs in a type certified glider: you need to use a Trig TT22 transponder and TN70 GPS Source (since its actual TSO-C145c approved). All the glider community Trig dealers know how to get the TT22+TN70 STC paperwork from Peregrine (Trig's STC development partner). Your A&P will want to get that paperwork, even though again its not being used to support a major alteration approval.
> >
> > Do NOT do a SIL-3/"2020 Compliant" install in a type certified aircraft using a non-TSO-C145c or similar actual TSO approved GPS source. And the FAA could easily spot that something is up as there won't be that notification only 337 filed for your aircraft in their database. The TN72 CAN be used to do TABS SIL=1 in a type certified glider, but not 2020 Compliant ADS-B Out. There is no paperwork to file anywhere for a TABS install. Double check any such install to make sure you are transmitting SIL=1 not SIL-3.
> >
> > Since the TN72 is a "meets performance requirements..." but not actual TSO-C145c or similar GPS source, you can do a 2020 Compliant SIL-3 install with a TN72 and TT22 in a *experimental* glider (but not a type certificated glider) again, there is no FAA paperwork to file for a TABS install, just a maintenance log book entry.
> >
> > Pull an FAA ADS-B flight report for all installs, ideally the first few flights, for both 2020 Compliant ADS-B Out or TABS. https://adsbperformance.faa.gov/PAPRRequest.aspx I'm happy to help people look at the reports and make sure they look OK.
>
> The FAA regulation is the fore-mentioned 14 CFR 21.93. Not convinced - check this out:
> https://www.trig-avionics.com/support/u-s-ads-b-stc-program/
>
> I quote from this link:
>
> "The FAA also requires that a certified ADS-B installation is completed in accordance with an FAA STC approval (Supplementary Type Certificate)."
>

How dense are you? I've just explained why you are wrong about the specific ADS-B Out use of STCs *not* meaning its a major alteration, and how STCs are used to establish pairing for an install, and pointed to the exact FAA policy documents.

And you link to stuff from Trig saying. "The FAA also requires that a certified ADS-B installation is completed in accordance with an FAA STC approval (Supplementary Type Certificate)." Yes you numbat, as in exactly what I'm saying above. None of which makes an ADS-B Out install a major alteration.

Again, show us one regulation or FAA policy that states an ADS-B Out install is necessarily a major modification.... we are waiting...

I really hope it's so obvious you have no idea what you are talking about that people know to ignore you.

---

And for folks who bother to read that Trig link, one thing that is different than stated on that page is several of us have worked with the great folks at Trig and Peregrine to make sure that the TT22+TN72 STC is available to glider industry A&Ps to do installs that are not necessarily normal authorized Trig dealers. Because of the specialized nature of the glider A&P/service market. But of course I don't know what I'm talking about...

[Darryl Ramm]

On Sunday, May 20, 2018 at 6:07:04 PM UTC-7, 2G wrote:
> On Sunday, May 20, 2018 at 5:19:22 PM UTC-7, Darryl Ramm wrote:
> > On Sunday, May 20, 2018 at 9:06:11 AM UTC-7, 2G wrote:
> > > On Saturday, May 19, 2018 at 9:52:05 AM UTC-7, jfitch wrote:
> > > > On Saturday, May 19, 2018 at 8:51:12 AM UTC-7, 2G wrote:
> > > > > On Saturday, May 19, 2018 at 7:23:32 AM UTC-7, jfitch wrote:
> > > > > > On Saturday, May 12, 2018 at 3:10:57 PM UTC-7, 2G wrote:
> > > > > > > On Thursday, May 10, 2018 at 11:35:08 PM UTC-7, Bob Kuykendall wrote:
> > > > > > > > On Thursday, May 10, 2018 at 7:48:12 PM UTC-7, 2G wrote:
> > > > > > > > > So, you think I am full of ****...
> > > > > > > >
> > > > > > > > I wouldn't have put it in so few words.
> > > > > > >
> > > > > > > If you do call the FAA for guidance, they will likely refer you Advisory Circular AC 43-210A (https://www.faa.gov/documentLibrary/media/Advisory_Circular/AC_43-210A.pdf) “Standardized Procedures for Obtaining Approval of Data Used in the Performance of Major Repairs and Major Alterations.” This covers what constitutes a minor repair:
> > > > > > >
> > > > > > > “3.2.2 Determine the Repair or Alteration Classification. Determine if the repair/alteration is a minor change in type design (as defined in 14 CFR part 21, § 21.93) to the product’s type design; and if so, is it a major or a minor repair/alteration. To determine if a repair/alteration is major or minor, refer to part 43 appendix A. Figure 3-2, Determination of Major or Minor Alteration or Repair, is a flowchart of the field approval evaluation process based on part 43 appendix A.”
> > > > > > >
> > > > > > > The regulation referenced, 14 CFR part 21, § 21.93, explicitly defines what constitutes a minor repair (https://www.law.cornell.edu/cfr/text/14/21.93):
> > > > > > >
> > > > > > > "(a) In addition to changes in type design specified in paragraph (b) of this section, changes in type design are classified as minor and major. 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)."
> > > > > > >
> > > > > > > The addition of instrument not required for certification constitutes a minor alteration (unless it affects the performance of required instrumentation) and meets the above criteria. An FAA airframe inspector are available to answer any questions concerning these regulations. My experience with FAA inspectors is they are really trying to make compliance as easy as possible and are not trying to make your life miserable.
> > > > > > >
> > > > > > > Tom
> > > > > >
> > > > > > That definition of minor change leaves very wide latitude for minor changes. Also great latitude for judgement about what is considered a minor change.
> > > > >
> > > > > I totally disagree. 14 CFR 21.93 clearly states:
> > > > >
> > > > > 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.
> > > > >
> > > > > If ANY of these conditions are met, it is a major change requiring the attendant paperwork. You don't make this judgment, your A&P does. And I would consult with an IA who is authorized to sign off on major changes.
> > > > >
> > > > > Tom
> > > >
> > > > There is very little you can do to the panel that would affect any of those things. As long as the required instruments stayed in place, you could replace the entire panel with a homebuilt one made from crumb board from Home Depot, complete with a lawn sprinkler controller and a hair dryer. Weight, balance, structural strength, reliability, operational or other characteristics? No appreciable affect, hence minor change. Yeah the A&P would need to sign. He's the one with the great latitude for judgement.
> > >
> > > Now you are being silly. Adding ADS-B Out to a standard category aircraft, for example, IS NOT a "minor" change, requiring an STC.
> > >
> > > Tom
> >
> >
> > No, this is not correct and is misinformation that can create problems for other glider owners.
> >
> > Show us one regulation or FAA policy that states an ADS-B Out install is necessarily a major modification....
> >
> > ADS-B Out installs can "require an STC?" yes, in a very specific way, as one (the most common) way to justify the pairing of a specific ADS-B transmitter and GPS Source. That use of an STC is special and does *not* automatically make the install a major alteration, but that seems to be confusing Tom here.
> >
> > ---
> >
> > So people do not cause themselves problems by believing this wrong information here is more explanation: (or just remember this is here and point your A&P at it if needed).
> >
> > Wether an ADS-B Out install is a major or minor modification in a certified aircraft has the same tests applied to it as any other modification. That's because there is *no* FAA regulation or policy saying an ADS-B Out install is a major modification, so the normal rules apply.
> >
> > Once upon a time an ADS-B Out install in a type certified aircraft was more complex, it's simpler now. So be careful about looking at old information.
> >
> > For the last few years the FAA policy uses an STC as (the most common) basis for pairing the transponder and GPS source, and requires the installer to follow the relevant STC documentation for pairing those devices. That STC is not necessarily used there as the basis for the approval of a major modification (and since there are no glider-specific STCs for any of these installs, or even a basic transponder install, those STC likely do not cover enough for an install in a glider to do so). The FAA was being very pragmatic here about avoiding problems with pairing different devices and wanted to know that devices paired in actual installs had been proven to work well together and documented in a prior STC.
> >
> > The key FAA policy document guiding all this is N 8900.362 https://www.faa.gov/regulations_policies/orders_notices/index.cfm/go/document.information/documentID/1029526 (People wanting more technical info can also read AC 20-165B https://www.faa.gov/regulations_policies/advisory_circulars/index.cfm/go/document.information/documentID/1028666). And yes this policy document is past its expiration date, but is still the reference doc being used by FSDOs and others (the expiration date issue has been explained a lot elsewhere, Google for it if curious). Section 6 in that policy describes the requirements for "subsequent installs" using an STC to justify the pairing, and is pretty straightforward.
> >
> > That policy requires filing an "notification only" (the term commonly used to refer to doing that, but the policy does not use that exact term) 337 with FAA HQ in Oklahoma, not with the FSDO. That does *not* make that installation automatically a major change, and does not anywhere require filing that 337 with the FSDO for major modification approval. If the A&P IA determines the change is a major modification (separate from anything to do with that is is "ADS-B") then they could would file a 337 for approval with the FSDO as normal for a major modification.
> >
> > Some folks have unfortunately read that the policy and see mention of 337s and are not reading clearly what it says and assume they *have* to file the 337 with the FSDO, the FSDO may see an inbound 337 and assumes the A&P is seeking approval for a major change... and that might start a pile of unnecessary work. Read the policy document carefully and follow it, it's really that simple.
> >
> > Owners may want to talk to their A&P IA before they do an ADS-B Out install and ask them what paperwork they plan to file/where/why if it's different than what I'm outlining here it may be a good to check they are familiar with that FAA policy N 8900.362.
> >
> > ---
> >
> > Other general things to help A&Ps and glider owners:
> >
> > There is no paperwork/notice only 337 to file for any ADS-B Out or TABS install in any experimental aircraft.
> >
> > For 2020 Complaint installs in a type certified glider: you need to use a Trig TT22 transponder and TN70 GPS Source (since its actual TSO-C145c approved). All the glider community Trig dealers know how to get the TT22+TN70 STC paperwork from Peregrine (Trig's STC development partner). Your A&P will want to get that paperwork, even though again its not being used to support a major alteration approval.
> >
> > Do NOT do a SIL-3/"2020 Compliant" install in a type certified aircraft using a non-TSO-C145c or similar actual TSO approved GPS source. And the FAA could easily spot that something is up as there won't be that notification only 337 filed for your aircraft in their database. The TN72 CAN be used to do TABS SIL=1 in a type certified glider, but not 2020 Compliant ADS-B Out. There is no paperwork to file anywhere for a TABS install. Double check any such install to make sure you are transmitting SIL=1 not SIL-3.
> >
> > Since the TN72 is a "meets performance requirements..." but not actual TSO-C145c or similar GPS source, you can do a 2020 Compliant SIL-3 install with a TN72 and TT22 in a *experimental* glider (but not a type certificated glider) again, there is no FAA paperwork to file for a TABS install, just a maintenance log book entry.
> >
> > Pull an FAA ADS-B flight report for all installs, ideally the first few flights, for both 2020 Compliant ADS-B Out or TABS. https://adsbperformance.faa.gov/PAPRRequest.aspx I'm happy to help people look at the reports and make sure they look OK.
>
> If you had bothered to contact the FAA (but you can't be bothered and consider them to be a nuisance), they could have provided you with this resource:
> https://www.faa.gov/nextgen/equipadsb/resources/media/ADS-B_Out-In_Installation_Tech_Paper(9-25-17).pdf
>
> I quote:
>
> "The purpose of this Technical Paper is to explain the Federal Aviation Administration’s (FAA) policy regarding alterations to aircraft for the installation of Automatic Dependent Surveillance-Broadcast (ADS-B) equipment. This policy applies to aircraft certificated under Title 14, Code of Federal Regulations (14 CFR) § 23, 25, 27, 29, and their predecessor regulations. This Technical Paper provides policy pursuant to compliance with 14 CFR § 91.225 and § 91.227. "

Bzzzt wrong again. yet again, pointing back to the exact same stuff I just mentioned. Do you actually bother to read anything carefully?

That paper restates the exact same policy I have explained above in #3. "After initial equipment pairing approval, can applicable ADS-B OUT systems be installed on aircraft not covered by that approval? "

Again, nobody here ever said an ADS-B Out Install is not going to use an STC (to justify pairing). You said something very different, that it was necessarily a major alteration.

Again, show us one regulation or FAA policy that states an ADS-B Out install is necessarily a major alteration....

And just to get in ahead of yet more confusion. Things saying stuff like "may be used for field approval" etc. are not saying an install *is* a major alteration. Its saying if it is then that data may be used to justify that alteration. So again a very simple question, where is exact wording anywhere in FAA regulations or policy documents saying that an ADS-B Out installation in any certificated aircraft is necessarily a major modification?

[2G]

On Sunday, May 20, 2018 at 6:19:17 PM UTC-7, Darryl Ramm wrote:
> On Sunday, May 20, 2018 at 5:58:07 PM UTC-7, 2G wrote:
> > On Sunday, May 20, 2018 at 5:19:22 PM UTC-7, Darryl Ramm wrote:
> > > On Sunday, May 20, 2018 at 9:06:11 AM UTC-7, 2G wrote:
> > > > On Saturday, May 19, 2018 at 9:52:05 AM UTC-7, jfitch wrote:
> > > > > On Saturday, May 19, 2018 at 8:51:12 AM UTC-7, 2G wrote:
> > > > > > On Saturday, May 19, 2018 at 7:23:32 AM UTC-7, jfitch wrote:
> > > > > > > On Saturday, May 12, 2018 at 3:10:57 PM UTC-7, 2G wrote:
> > > > > > > > On Thursday, May 10, 2018 at 11:35:08 PM UTC-7, Bob Kuykendall wrote:
> > > > > > > > > On Thursday, May 10, 2018 at 7:48:12 PM UTC-7, 2G wrote:
> > > > > > > > > > So, you think I am full of ****...
> > > > > > > > >
> > > > > > > > > I wouldn't have put it in so few words.
> > > > > > > >
> > > > > > > > If you do call the FAA for guidance, they will likely refer you Advisory Circular AC 43-210A (https://www.faa.gov/documentLibrary/media/Advisory_Circular/AC_43-210A.pdf) “Standardized Procedures for Obtaining Approval of Data Used in the Performance of Major Repairs and Major Alterations.” This covers what constitutes a minor repair:
> > > > > > > >
> > > > > > > > “3.2.2 Determine the Repair or Alteration Classification. Determine if the repair/alteration is a minor change in type design (as defined in 14 CFR part 21, § 21.93) to the product’s type design; and if so, is it a major or a minor repair/alteration. To determine if a repair/alteration is major or minor, refer to part 43 appendix A. Figure 3-2, Determination of Major or Minor Alteration or Repair, is a flowchart of the field approval evaluation process based on part 43 appendix A.”
> > > > > > > >
> > > > > > > > The regulation referenced, 14 CFR part 21, § 21.93, explicitly defines what constitutes a minor repair (https://www.law.cornell..edu/cfr/text/14/21.93):
> > > > > > > >
> > > > > > > > "(a) In addition to changes in type design specified in paragraph (b) of this section, changes in type design are classified as minor and major. 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)."
> > > > > > > >
> > > > > > > > The addition of instrument not required for certification constitutes a minor alteration (unless it affects the performance of required instrumentation) and meets the above criteria. An FAA airframe inspector are available to answer any questions concerning these regulations. My experience with FAA inspectors is they are really trying to make compliance as easy as possible and are not trying to make your life miserable.
> > > > > > > >
> > > > > > > > Tom
> > > > > > >
> > > > > > > That definition of minor change leaves very wide latitude for minor changes. Also great latitude for judgement about what is considered a minor change.
> > > > > >
> > > > > > I totally disagree. 14 CFR 21.93 clearly states:
> > > > > >
> > > > > > 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.
> > > > > >
> > > > > > If ANY of these conditions are met, it is a major change requiring the attendant paperwork. You don't make this judgment, your A&P does. And I would consult with an IA who is authorized to sign off on major changes.
> > > > > >
> > > > > > Tom
> > > > >
> > > > > There is very little you can do to the panel that would affect any of those things. As long as the required instruments stayed in place, you could replace the entire panel with a homebuilt one made from crumb board from Home Depot, complete with a lawn sprinkler controller and a hair dryer.. Weight, balance, structural strength, reliability, operational or other characteristics? No appreciable affect, hence minor change. Yeah the A&P would need to sign. He's the one with the great latitude for judgement.
> > > >
> > > > Now you are being silly. Adding ADS-B Out to a standard category aircraft, for example, IS NOT a "minor" change, requiring an STC.
> > > >
> > > > Tom
> > >
> > >
> > > No, this is not correct and is misinformation that can create problems for other glider owners.
> > >
> > > Show us one regulation or FAA policy that states an ADS-B Out install is necessarily a major modification....
> > >
> > > ADS-B Out installs can "require an STC?" yes, in a very specific way, as one (the most common) way to justify the pairing of a specific ADS-B transmitter and GPS Source. That use of an STC is special and does *not* automatically make the install a major alteration, but that seems to be confusing Tom here.
> > >
> > > ---
> > >
> > > So people do not cause themselves problems by believing this wrong information here is more explanation: (or just remember this is here and point your A&P at it if needed).
> > >
> > > Wether an ADS-B Out install is a major or minor modification in a certified aircraft has the same tests applied to it as any other modification. That's because there is *no* FAA regulation or policy saying an ADS-B Out install is a major modification, so the normal rules apply.
> > >
> > > Once upon a time an ADS-B Out install in a type certified aircraft was more complex, it's simpler now. So be careful about looking at old information.
> > >
> > > For the last few years the FAA policy uses an STC as (the most common) basis for pairing the transponder and GPS source, and requires the installer to follow the relevant STC documentation for pairing those devices. That STC is not necessarily used there as the basis for the approval of a major modification (and since there are no glider-specific STCs for any of these installs, or even a basic transponder install, those STC likely do not cover enough for an install in a glider to do so). The FAA was being very pragmatic here about avoiding problems with pairing different devices and wanted to know that devices paired in actual installs had been proven to work well together and documented in a prior STC.
> > >
> > > The key FAA policy document guiding all this is N 8900.362 https://www.faa.gov/regulations_policies/orders_notices/index.cfm/go/document.information/documentID/1029526 (People wanting more technical info can also read AC 20-165B https://www.faa.gov/regulations_policies/advisory_circulars/index..cfm/go/document.information/documentID/1028666). And yes this policy document is past its expiration date, but is still the reference doc being used by FSDOs and others (the expiration date issue has been explained a lot elsewhere, Google for it if curious). Section 6 in that policy describes the requirements for "subsequent installs" using an STC to justify the pairing, and is pretty straightforward.
> > >
> > > That policy requires filing an "notification only" (the term commonly used to refer to doing that, but the policy does not use that exact term) 337 with FAA HQ in Oklahoma, not with the FSDO. That does *not* make that installation automatically a major change, and does not anywhere require filing that 337 with the FSDO for major modification approval. If the A&P IA determines the change is a major modification (separate from anything to do with that is is "ADS-B") then they could would file a 337 for approval with the FSDO as normal for a major modification.
> > >
> > > Some folks have unfortunately read that the policy and see mention of 337s and are not reading clearly what it says and assume they *have* to file the 337 with the FSDO, the FSDO may see an inbound 337 and assumes the A&P is seeking approval for a major change... and that might start a pile of unnecessary work. Read the policy document carefully and follow it, it's really that simple.
> > >
> > > Owners may want to talk to their A&P IA before they do an ADS-B Out install and ask them what paperwork they plan to file/where/why if it's different than what I'm outlining here it may be a good to check they are familiar with that FAA policy N 8900.362.
> > >
> > > ---
> > >
> > > Other general things to help A&Ps and glider owners:
> > >
> > > There is no paperwork/notice only 337 to file for any ADS-B Out or TABS install in any experimental aircraft.
> > >
> > > For 2020 Complaint installs in a type certified glider: you need to use a Trig TT22 transponder and TN70 GPS Source (since its actual TSO-C145c approved). All the glider community Trig dealers know how to get the TT22+TN70 STC paperwork from Peregrine (Trig's STC development partner). Your A&P will want to get that paperwork, even though again its not being used to support a major alteration approval.
> > >
> > > Do NOT do a SIL-3/"2020 Compliant" install in a type certified aircraft using a non-TSO-C145c or similar actual TSO approved GPS source. And the FAA could easily spot that something is up as there won't be that notification only 337 filed for your aircraft in their database. The TN72 CAN be used to do TABS SIL=1 in a type certified glider, but not 2020 Compliant ADS-B Out. There is no paperwork to file anywhere for a TABS install. Double check any such install to make sure you are transmitting SIL=1 not SIL-3.
> > >
> > > Since the TN72 is a "meets performance requirements..." but not actual TSO-C145c or similar GPS source, you can do a 2020 Compliant SIL-3 install with a TN72 and TT22 in a *experimental* glider (but not a type certificated glider) again, there is no FAA paperwork to file for a TABS install, just a maintenance log book entry.
> > >
> > > Pull an FAA ADS-B flight report for all installs, ideally the first few flights, for both 2020 Compliant ADS-B Out or TABS. https://adsbperformance.faa.gov/PAPRRequest.aspx I'm happy to help people look at the reports and make sure they look OK.
> >
> > The FAA regulation is the fore-mentioned 14 CFR 21.93. Not convinced - check this out:
> > https://www.trig-avionics.com/support/u-s-ads-b-stc-program/
> >
> > I quote from this link:
> >
> > "The FAA also requires that a certified ADS-B installation is completed in accordance with an FAA STC approval (Supplementary Type Certificate)."
> >
>
> How dense are you? I've just explained why you are wrong about the specific ADS-B Out use of STCs *not* meaning its a major alteration, and how STCs are used to establish pairing for an install, and pointed to the exact FAA policy documents.
>
> And you link to stuff from Trig saying. "The FAA also requires that a certified ADS-B installation is completed in accordance with an FAA STC approval (Supplementary Type Certificate)." Yes you numbat, as in exactly what I'm saying above. None of which makes an ADS-B Out install a major alteration..
>
> Again, show us one regulation or FAA policy that states an ADS-B Out install is necessarily a major modification.... we are waiting...
>
> I really hope it's so obvious you have no idea what you are talking about that people know to ignore you.
>
> ---
>
> And for folks who bother to read that Trig link, one thing that is different than stated on that page is several of us have worked with the great folks at Trig and Peregrine to make sure that the TT22+TN72 STC is available to glider industry A&Ps to do installs that are not necessarily normal authorized Trig dealers. Because of the specialized nature of the glider A&P/service market. But of course I don't know what I'm talking about...

How dense? Dense enough to seek FAA guidance, unlike you. Tell you what - let's make a bet, say $1,000 to the charity of the winner's choice. I say it IS a major change. I will contact the Spokane FSDO tomorrow and get a determination. Are you on?

Tom

[2G]

On Sunday, May 20, 2018 at 6:39:58 PM UTC-7, Darryl Ramm wrote:
> On Sunday, May 20, 2018 at 6:07:04 PM UTC-7, 2G wrote:
> > On Sunday, May 20, 2018 at 5:19:22 PM UTC-7, Darryl Ramm wrote:
> > > On Sunday, May 20, 2018 at 9:06:11 AM UTC-7, 2G wrote:
> > > > On Saturday, May 19, 2018 at 9:52:05 AM UTC-7, jfitch wrote:
> > > > > On Saturday, May 19, 2018 at 8:51:12 AM UTC-7, 2G wrote:
> > > > > > On Saturday, May 19, 2018 at 7:23:32 AM UTC-7, jfitch wrote:
> > > > > > > On Saturday, May 12, 2018 at 3:10:57 PM UTC-7, 2G wrote:
> > > > > > > > On Thursday, May 10, 2018 at 11:35:08 PM UTC-7, Bob Kuykendall wrote:
> > > > > > > > > On Thursday, May 10, 2018 at 7:48:12 PM UTC-7, 2G wrote:
> > > > > > > > > > So, you think I am full of ****...
> > > > > > > > >
> > > > > > > > > I wouldn't have put it in so few words.
> > > > > > > >
> > > > > > > > If you do call the FAA for guidance, they will likely refer you Advisory Circular AC 43-210A (https://www.faa.gov/documentLibrary/media/Advisory_Circular/AC_43-210A.pdf) “Standardized Procedures for Obtaining Approval of Data Used in the Performance of Major Repairs and Major Alterations.” This covers what constitutes a minor repair:
> > > > > > > >
> > > > > > > > “3.2.2 Determine the Repair or Alteration Classification. Determine if the repair/alteration is a minor change in type design (as defined in 14 CFR part 21, § 21.93) to the product’s type design; and if so, is it a major or a minor repair/alteration. To determine if a repair/alteration is major or minor, refer to part 43 appendix A. Figure 3-2, Determination of Major or Minor Alteration or Repair, is a flowchart of the field approval evaluation process based on part 43 appendix A.”
> > > > > > > >
> > > > > > > > The regulation referenced, 14 CFR part 21, § 21.93, explicitly defines what constitutes a minor repair (https://www.law.cornell..edu/cfr/text/14/21.93):
> > > > > > > >
> > > > > > > > "(a) In addition to changes in type design specified in paragraph (b) of this section, changes in type design are classified as minor and major. 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)."
> > > > > > > >
> > > > > > > > The addition of instrument not required for certification constitutes a minor alteration (unless it affects the performance of required instrumentation) and meets the above criteria. An FAA airframe inspector are available to answer any questions concerning these regulations. My experience with FAA inspectors is they are really trying to make compliance as easy as possible and are not trying to make your life miserable.
> > > > > > > >
> > > > > > > > Tom
> > > > > > >
> > > > > > > That definition of minor change leaves very wide latitude for minor changes. Also great latitude for judgement about what is considered a minor change.
> > > > > >
> > > > > > I totally disagree. 14 CFR 21.93 clearly states:
> > > > > >
> > > > > > 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.
> > > > > >
> > > > > > If ANY of these conditions are met, it is a major change requiring the attendant paperwork. You don't make this judgment, your A&P does. And I would consult with an IA who is authorized to sign off on major changes.
> > > > > >
> > > > > > Tom
> > > > >
> > > > > There is very little you can do to the panel that would affect any of those things. As long as the required instruments stayed in place, you could replace the entire panel with a homebuilt one made from crumb board from Home Depot, complete with a lawn sprinkler controller and a hair dryer.. Weight, balance, structural strength, reliability, operational or other characteristics? No appreciable affect, hence minor change. Yeah the A&P would need to sign. He's the one with the great latitude for judgement.
> > > >
> > > > Now you are being silly. Adding ADS-B Out to a standard category aircraft, for example, IS NOT a "minor" change, requiring an STC.
> > > >
> > > > Tom
> > >
> > >
> > > No, this is not correct and is misinformation that can create problems for other glider owners.
> > >
> > > Show us one regulation or FAA policy that states an ADS-B Out install is necessarily a major modification....
> > >
> > > ADS-B Out installs can "require an STC?" yes, in a very specific way, as one (the most common) way to justify the pairing of a specific ADS-B transmitter and GPS Source. That use of an STC is special and does *not* automatically make the install a major alteration, but that seems to be confusing Tom here.
> > >
> > > ---
> > >
> > > So people do not cause themselves problems by believing this wrong information here is more explanation: (or just remember this is here and point your A&P at it if needed).
> > >
> > > Wether an ADS-B Out install is a major or minor modification in a certified aircraft has the same tests applied to it as any other modification. That's because there is *no* FAA regulation or policy saying an ADS-B Out install is a major modification, so the normal rules apply.
> > >
> > > Once upon a time an ADS-B Out install in a type certified aircraft was more complex, it's simpler now. So be careful about looking at old information.
> > >
> > > For the last few years the FAA policy uses an STC as (the most common) basis for pairing the transponder and GPS source, and requires the installer to follow the relevant STC documentation for pairing those devices. That STC is not necessarily used there as the basis for the approval of a major modification (and since there are no glider-specific STCs for any of these installs, or even a basic transponder install, those STC likely do not cover enough for an install in a glider to do so). The FAA was being very pragmatic here about avoiding problems with pairing different devices and wanted to know that devices paired in actual installs had been proven to work well together and documented in a prior STC.
> > >
> > > The key FAA policy document guiding all this is N 8900.362 https://www.faa.gov/regulations_policies/orders_notices/index.cfm/go/document.information/documentID/1029526 (People wanting more technical info can also read AC 20-165B https://www.faa.gov/regulations_policies/advisory_circulars/index..cfm/go/document.information/documentID/1028666). And yes this policy document is past its expiration date, but is still the reference doc being used by FSDOs and others (the expiration date issue has been explained a lot elsewhere, Google for it if curious). Section 6 in that policy describes the requirements for "subsequent installs" using an STC to justify the pairing, and is pretty straightforward.
> > >
> > > That policy requires filing an "notification only" (the term commonly used to refer to doing that, but the policy does not use that exact term) 337 with FAA HQ in Oklahoma, not with the FSDO. That does *not* make that installation automatically a major change, and does not anywhere require filing that 337 with the FSDO for major modification approval. If the A&P IA determines the change is a major modification (separate from anything to do with that is is "ADS-B") then they could would file a 337 for approval with the FSDO as normal for a major modification.
> > >
> > > Some folks have unfortunately read that the policy and see mention of 337s and are not reading clearly what it says and assume they *have* to file the 337 with the FSDO, the FSDO may see an inbound 337 and assumes the A&P is seeking approval for a major change... and that might start a pile of unnecessary work. Read the policy document carefully and follow it, it's really that simple.
> > >
> > > Owners may want to talk to their A&P IA before they do an ADS-B Out install and ask them what paperwork they plan to file/where/why if it's different than what I'm outlining here it may be a good to check they are familiar with that FAA policy N 8900.362.
> > >
> > > ---
> > >
> > > Other general things to help A&Ps and glider owners:
> > >
> > > There is no paperwork/notice only 337 to file for any ADS-B Out or TABS install in any experimental aircraft.
> > >
> > > For 2020 Complaint installs in a type certified glider: you need to use a Trig TT22 transponder and TN70 GPS Source (since its actual TSO-C145c approved). All the glider community Trig dealers know how to get the TT22+TN70 STC paperwork from Peregrine (Trig's STC development partner). Your A&P will want to get that paperwork, even though again its not being used to support a major alteration approval.
> > >
> > > Do NOT do a SIL-3/"2020 Compliant" install in a type certified aircraft using a non-TSO-C145c or similar actual TSO approved GPS source. And the FAA could easily spot that something is up as there won't be that notification only 337 filed for your aircraft in their database. The TN72 CAN be used to do TABS SIL=1 in a type certified glider, but not 2020 Compliant ADS-B Out. There is no paperwork to file anywhere for a TABS install. Double check any such install to make sure you are transmitting SIL=1 not SIL-3.
> > >
> > > Since the TN72 is a "meets performance requirements..." but not actual TSO-C145c or similar GPS source, you can do a 2020 Compliant SIL-3 install with a TN72 and TT22 in a *experimental* glider (but not a type certificated glider) again, there is no FAA paperwork to file for a TABS install, just a maintenance log book entry.
> > >
> > > Pull an FAA ADS-B flight report for all installs, ideally the first few flights, for both 2020 Compliant ADS-B Out or TABS. https://adsbperformance.faa.gov/PAPRRequest.aspx I'm happy to help people look at the reports and make sure they look OK.
> >
> > If you had bothered to contact the FAA (but you can't be bothered and consider them to be a nuisance), they could have provided you with this resource:
> > https://www.faa.gov/nextgen/equipadsb/resources/media/ADS-B_Out-In_Installation_Tech_Paper(9-25-17).pdf
> >
> > I quote:
> >
> > "The purpose of this Technical Paper is to explain the Federal Aviation Administration’s (FAA) policy regarding alterations to aircraft for the installation of Automatic Dependent Surveillance-Broadcast (ADS-B) equipment. This policy applies to aircraft certificated under Title 14, Code of Federal Regulations (14 CFR) § 23, 25, 27, 29, and their predecessor regulations. This Technical Paper provides policy pursuant to compliance with 14 CFR § 91.225 and § 91.227. "
>
> Bzzzt wrong again. yet again, pointing back to the exact same stuff I just mentioned. Do you actually bother to read anything carefully?
>
> That paper restates the exact same policy I have explained above in #3. "After initial equipment pairing approval, can applicable ADS-B OUT systems be installed on aircraft not covered by that approval? "
>
> Again, nobody here ever said an ADS-B Out Install is not going to use an STC (to justify pairing). You said something very different, that it was necessarily a major alteration.
>
> Again, show us one regulation or FAA policy that states an ADS-B Out install is necessarily a major alteration....
>
> And just to get in ahead of yet more confusion. Things saying stuff like "may be used for field approval" etc. are not saying an install *is* a major alteration. Its saying if it is then that data may be used to justify that alteration. So again a very simple question, where is exact wording anywhere in FAA regulations or policy documents saying that an ADS-B Out installation in any certificated aircraft is necessarily a major modification?

PS The charity must be an approved 501(C)(3) nonprofit - you don't qualify.

Tom

[[email protected]]

As dense as they come, still in hole, still digging. Do you like to be thought of as a pratt?

[Darryl Ramm]

I don't want to be part of anybody going to a FSDO half assed with information and potentially creating problems for themselves or other glider owners or pilots. And I don't even trust you could get into a detailed/accurate discussion with people. Oh well if it causes issues, everybody will at least know who to blame. Hang onto your seats owners and pilots in the Seattle area. Other folks have tried to warn you your ideas on r.a.s. before, but you can't seem to listen to anybody else about anything.

[JS[_5_]]

Do people have nothing else to do but argue about routine stuff that has been done thousands of times before?
Amazing.
Jim

[2G]

On Sunday, May 20, 2018 at 7:59:14 PM UTC-7, Darryl Ramm wrote:
> I don't want to be part of anybody going to a FSDO half assed with information and potentially creating problems for themselves or other glider owners or pilots. And I don't even trust you could get into a detailed/accurate discussion with people. Oh well if it causes issues, everybody will at least know who to blame. Hang onto your seats owners and pilots in the Seattle area. Other folks have tried to warn you your ideas on r.a.s. before, but you can't seem to listen to anybody else about anything.

So, you DON'T want to put your MONEY where your MOUTH is. That tells me EVERYTHING about you!

Tom

[Jonathan St. Cloud]

Hey Tom, Darryl, his knowledge and time freely given, are gifts to the soaring world. Why not just stop, please. This conversation has run it's course, went off the road, through a ditch and hit a tree.

Let's just move on to something more fruitful, like the dreaded downwind turn :)

On Sunday, May 20, 2018 at 9:43:18 PM UTC-7, 2G wrote:
> On Sunday, May 20, 2018 at 7:59:14 PM UTC-7, Darryl Ramm wrote:
> > I don't want to be part of anybody going to a FSDO half assed with information and potentially creating problems for themselves or other glider owners or pilots. And I don't even trust you could get into a detailed/accurate discussion with people. Oh well if it causes issues, everybody will at least know who to blame. Hang onto your seats owners and pilots in the Seattle area. Other folks have tried to warn you your ideas on r.a.s. before, but you can't seem to listen to anybody else about anything.
>
> So, you DON'T want to put your MONEY where your MOUTH is. That tells me EVERYTHING about you!
>
> Tom

[Paul Agnew]

It's a suckers bet. I have no doubt that you can find someone at a FSDO that will agree with you. I also have no doubt that Darryl can find many more FAA Inspectors that will agree with him.

As a side job to my airline position, I work closely with the FAA on Master Minimum Equipment List policy and the default answer to any question the FAA is unprepared to answer is always skewed to more paperwork and regulation. In essence, it's easier to say, "no" than to do the research and say, "yes". I can recount many instances where the FAA stance was negative until the regulations, advisory circulars, institutional preactices, and legal interpretations were presented. Still, we still run into POIs and PMIs that are stubborn about their pet opinions and will not accept anything that is outside of their comfort zone without a mandate from above. The same holds for IAs/AIs who have chosen to interpret the guidance to suit their opinions. I've heard some really creative, but solid logic on repairs and rebuilding from IAs around the hangar over the years.

I have a lot of respect for the experts at the FAA, but they cannot know everything and will often default to "you can't do that" when pressed for an opinion without time to research the issue. Darryl has clearly presented a strong case that would hold up to FAA scrutiny.

The continued bickering is juvenile and embarrassing.

Enough talking...Let's Fly!

Paul A.
Jupiter, FL

[Paul Agnew]

Fuel for the fire. I found this letter from the FAA Milwaukee FSDO in response to an inordinate number of Form 337s being filed for radio installations. It may be old, but I don't know of any change in policy since the date of the letter regarding 337s.

https://groups.google.com/forum/#!topic/rec.aviation.homebuilt/qodHhczVS1Y

>>>>>>

U.S. Department of Transportation
Federal Aviation Administration
Flight Standards District Office
4915 South Howell Avenue
Milwaukee, WI 53207

DATE: June 5, 1995

SUBJECT: Major Alterations

TO: Certified Repair Stations and Inspection
Authorization (IA's)

This office is frequently confronted with questions regarding
what constitutes a major alteration, especially when
installation or removal of avionics and other similar
equipment is involved. The following information is provided
to help mechanics and repair stations understand this
sometimes complicated matter. The regulatory definitions of
major alterations are found in Federal Aviation Regulations
(FAR) 1 and 43, Appendix A (a). These regulations are often
interpreted too conservatively resulting in minor alterations
being treated as major alterations.

Simple alterations that do not affect the structural
integrity of the aircraft, alterations that are made by the
same method as the aircraft manufacturer has used or
installation of equipment listed by the aircraft manufacturer
as "Optional Equipment" may be considered minor alterations.
A simple equipment installation that is made in an aircraft
with units mounted on factory provided racks may be
considered as minor alterations. The certificated person
installing the equipment is responsible to use the
information provided by the equipment manufacturer, and that
information in Advisory Circular (AC) 43.13-1 and 43.13-2
regarding wire size, circuit protection, wire support,
antenna installation, etc. They are also responsible to
record the alteration in the aircraft records in accordance
with FAR 43.9 (logbook entry) and update the weight and
balance and equipment list.

We do not wish to imply that field approvals of equipment
installation is never required. Examples of installations
that would require field approval are:

* Alterations that involve the construction of a radio rack
or shelf.

* An installation made in an instrument panel that is a
structural part of the aircraft and requiring an opening
to be cut in areas other than that specified by the
aircraft manufacturer.

* Special FAA policy sometimes requires field approval on
installation of new types of equipment such as the current
requirement for GPS.

If you have any questions regarding this memo, or are in
doubt as to whether a 337 is required, please do no
hesitate to contact this office.


Sincerely,

Thomas L. Lind
Supervisor, Airworthiness
Certificate Management Unit

[Craig Funston[_3_]]

On Monday, May 21, 2018 at 9:50:09 AM UTC-7, Paul Agnew wrote:
> Fuel for the fire. I found this letter from the FAA Milwaukee FSDO in response to an inordinate number of Form 337s being filed for radio installations. It may be old, but I don't know of any change in policy since the date of the letter regarding 337s.
>
> https://groups.google.com/forum/#!topic/rec.aviation.homebuilt/qodHhczVS1Y
>
> >>>>>>
>
> U.S. Department of Transportation
> Federal Aviation Administration
> Flight Standards District Office
> 4915 South Howell Avenue
> Milwaukee, WI 53207
>
> DATE: June 5, 1995
>
> SUBJECT: Major Alterations
>
> TO: Certified Repair Stations and Inspection
> Authorization (IA's)
>
> This office is frequently confronted with questions regarding
> what constitutes a major alteration, especially when
> installation or removal of avionics and other similar
> equipment is involved. The following information is provided
> to help mechanics and repair stations understand this
> sometimes complicated matter. The regulatory definitions of
> major alterations are found in Federal Aviation Regulations
> (FAR) 1 and 43, Appendix A (a). These regulations are often
> interpreted too conservatively resulting in minor alterations
> being treated as major alterations.
>
> Simple alterations that do not affect the structural
> integrity of the aircraft, alterations that are made by the
> same method as the aircraft manufacturer has used or
> installation of equipment listed by the aircraft manufacturer
> as "Optional Equipment" may be considered minor alterations.
> A simple equipment installation that is made in an aircraft
> with units mounted on factory provided racks may be
> considered as minor alterations. The certificated person
> installing the equipment is responsible to use the
> information provided by the equipment manufacturer, and that
> information in Advisory Circular (AC) 43.13-1 and 43.13-2
> regarding wire size, circuit protection, wire support,
> antenna installation, etc. They are also responsible to
> record the alteration in the aircraft records in accordance
> with FAR 43.9 (logbook entry) and update the weight and
> balance and equipment list.
>
> We do not wish to imply that field approvals of equipment
> installation is never required. Examples of installations
> that would require field approval are:
>
> * Alterations that involve the construction of a radio rack
> or shelf.
>
> * An installation made in an instrument panel that is a
> structural part of the aircraft and requiring an opening
> to be cut in areas other than that specified by the
> aircraft manufacturer.
>
> * Special FAA policy sometimes requires field approval on
> installation of new types of equipment such as the current
> requirement for GPS.
>
> If you have any questions regarding this memo, or are in
> doubt as to whether a 337 is required, please do no
> hesitate to contact this office.
>
>
> Sincerely,
>
> Thomas L. Lind
> Supervisor, Airworthiness
> Certificate Management Unit

The FAA has done a reasonably good job of outlining what's required, but they have thrown in a few head scratchers.

It's referenced in their 2016 Memorandum regarding Installation Approval for ADS-B Out Systems. The memo's available from this FAA webpage https://www..faa.gov/nextgen/equipadsb/installation/ Click on the link to AFS-360_2016-03-02.pdf

Reader's digest version:

- Pairings of transmitters / GPS source must be approved. Pairings are not specific to any particular aircraft. "Once the performance of the initial pairing has been established, the FAA considers follow-on installations of the same pairing to be approved". This means in any aircraft. Gliders are aircraft and nothing glider specific is required or desired.

- This is a minor alteration unless installation of antennas penetrating pressure vessels is required, etc. There's a good flow-chart outlining this on the last page of the PDF.

The FAA asks that ADS-B Out installations on CERTIFIED aircraft be documented with an advisory 337 submitted directly to OK City (NOT the local FSDO). This confuses folks since the 337 title says "Major Repair and Alteration", but we're not doing a major alteration. Cognitive dissonance anyone.. Anyways, just go with it. The FAA had to figure out a way to track who's installing ADS-B and that's what they chose. It's NOT a major alteration for any glider that I can think of. The feds even give you the specific language to enter on the 337. Again, just go with it.

Let's stay with the specific guidance the FAA has provided regarding ADS-B Out installations and not get wrapped around the axle of what we believe are conflicting regs. As with any bureaucracy there will be lack of clarity at times and cases where regs conflict. Let's not make it worse by running it through the RAS mill.

Cheers,
Craig

[[email protected]]

"I have no doubt that you can find someone at a FSDO that will agree with you. I also have no doubt that Darryl can find many more FAA Inspectors that will agree with him."

Airshow pilots, who deal with different FSDOs every weekend during the airshow season are fond of saying, "The FAA has about 90 FSDOs. Each independently owned and operated."

Some FSDO inspectors are great and know their stuff. Some are not so great and make stuff up all the time. Gotta watch out for that, as the tendency in the bureaucracy is to circle the wagons and back up erroneous directives and advice to avoid having to admit to a mistake.

[2G]

On Monday, May 21, 2018 at 11:40:20 AM UTC-7, wrote:
> "I have no doubt that you can find someone at a FSDO that will agree with you. I also have no doubt that Darryl can find many more FAA Inspectors that will agree with him."
>
> Airshow pilots, who deal with different FSDOs every weekend during the airshow season are fond of saying, "The FAA has about 90 FSDOs. Each independently owned and operated."
>
> Some FSDO inspectors are great and know their stuff. Some are not so great and make stuff up all the time. Gotta watch out for that, as the tendency in the bureaucracy is to circle the wagons and back up erroneous directives and advice to avoid having to admit to a mistake.

I spoke with Dave Hartson at the Spokane FSDO (509-532-2360) and, when asked if an ADS-B Out install in a standard category aircraft was a minor or major alteration, his reply was "It depends." What it depends upon is the complexity of the installation. If it can be accomplished with simple hand tools, it was probably minor. But if it involved "drilling holes and using pop rivets" it was probably a major. They are very willing to give guidance on this issue if drawings, photos, sketches, etc. of the proposed install is sent to them. He also said that experimental aircraft only require a logbook entry signed off by an A&P.

Tom

[Craig Funston[_3_]]

On Monday, May 21, 2018 at 2:57:36 PM UTC-7, 2G wrote:
> On Monday, May 21, 2018 at 11:40:20 AM UTC-7, wrote:
> > "I have no doubt that you can find someone at a FSDO that will agree with you. I also have no doubt that Darryl can find many more FAA Inspectors that will agree with him."
> >
> > Airshow pilots, who deal with different FSDOs every weekend during the airshow season are fond of saying, "The FAA has about 90 FSDOs. Each independently owned and operated."
> >
> > Some FSDO inspectors are great and know their stuff. Some are not so great and make stuff up all the time. Gotta watch out for that, as the tendency in the bureaucracy is to circle the wagons and back up erroneous directives and advice to avoid having to admit to a mistake.
>
> I spoke with Dave Hartson at the Spokane FSDO (509-532-2360) and, when asked if an ADS-B Out install in a standard category aircraft was a minor or major alteration, his reply was "It depends." What it depends upon is the complexity of the installation. If it can be accomplished with simple hand tools, it was probably minor. But if it involved "drilling holes and using pop rivets" it was probably a major. They are very willing to give guidance on this issue if drawings, photos, sketches, etc. of the proposed install is sent to them. He also said that experimental aircraft only require a logbook entry signed off by an A&P.
>
> Tom

Thanks for checking Tom.

Oklahoma City has already provided guidance in this memo (link below) that very clearly says what is and isn't major.

http://rgl.faa.gov/Regulatory_and_Guidance_Library/rgPolicy.nsf/0/1fdea629cd029a7c86257f7900601653/$FILE/AFS-360_2016-03-02.pdf

The guidance document is in agreement with your FSDO that experimental aircraft only need a logbook entry and do not require reporting.

Install reporting for certificated aircraft with approved pairings is direct to Oklahoma City and is not supposed to go through any of the FSDOs.

It's nice that Spokane FSDO has an opinion and is willing to help, but guidance from OK City supersedes any of the FSDOs & we want to avoid getting a large diversity of opinions from different regions. I'm sure that's why the Feds published an overarching guidance document.

Spend some time going over the document. The process is surprisingly straightforward.

Thanks again,
Craig

[[email protected]]

SO you CAPITALISE and shout when you lose eh?
What a dip**** you are 2G.

[jfitch]

On Monday, May 21, 2018 at 2:57:36 PM UTC-7, 2G wrote:
> On Monday, May 21, 2018 at 11:40:20 AM UTC-7, wrote:
> > "I have no doubt that you can find someone at a FSDO that will agree with you. I also have no doubt that Darryl can find many more FAA Inspectors that will agree with him."
> >
> > Airshow pilots, who deal with different FSDOs every weekend during the airshow season are fond of saying, "The FAA has about 90 FSDOs. Each independently owned and operated."
> >
> > Some FSDO inspectors are great and know their stuff. Some are not so great and make stuff up all the time. Gotta watch out for that, as the tendency in the bureaucracy is to circle the wagons and back up erroneous directives and advice to avoid having to admit to a mistake.
>
> I spoke with Dave Hartson at the Spokane FSDO (509-532-2360) and, when asked if an ADS-B Out install in a standard category aircraft was a minor or major alteration, his reply was "It depends." What it depends upon is the complexity of the installation. If it can be accomplished with simple hand tools, it was probably minor. But if it involved "drilling holes and using pop rivets" it was probably a major. They are very willing to give guidance on this issue if drawings, photos, sketches, etc. of the proposed install is sent to them. He also said that experimental aircraft only require a logbook entry signed off by an A&P.
>
> Tom

A drill and pop rivet puller are simple hand tools. Not sure what is simpler - maybe a hammer. I'd go by the official FAA document, which someone put some thought into.

[2G]

On Monday, May 21, 2018 at 6:55:09 PM UTC-7, jfitch wrote:
> On Monday, May 21, 2018 at 2:57:36 PM UTC-7, 2G wrote:
> > On Monday, May 21, 2018 at 11:40:20 AM UTC-7, wrote:
> > > "I have no doubt that you can find someone at a FSDO that will agree with you. I also have no doubt that Darryl can find many more FAA Inspectors that will agree with him."
> > >
> > > Airshow pilots, who deal with different FSDOs every weekend during the airshow season are fond of saying, "The FAA has about 90 FSDOs. Each independently owned and operated."
> > >
> > > Some FSDO inspectors are great and know their stuff. Some are not so great and make stuff up all the time. Gotta watch out for that, as the tendency in the bureaucracy is to circle the wagons and back up erroneous directives and advice to avoid having to admit to a mistake.
> >
> > I spoke with Dave Hartson at the Spokane FSDO (509-532-2360) and, when asked if an ADS-B Out install in a standard category aircraft was a minor or major alteration, his reply was "It depends." What it depends upon is the complexity of the installation. If it can be accomplished with simple hand tools, it was probably minor. But if it involved "drilling holes and using pop rivets" it was probably a major. They are very willing to give guidance on this issue if drawings, photos, sketches, etc. of the proposed install is sent to them. He also said that experimental aircraft only require a logbook entry signed off by an A&P.
> >
> > Tom
>
> A drill and pop rivet puller are simple hand tools. Not sure what is simpler - maybe a hammer. I'd go by the official FAA document, which someone put some thought into.

You are welcome to take a jackhammer to your glider for all I care.

Tom

[2G]

On Monday, May 21, 2018 at 6:05:23 PM UTC-7, wrote:
> SO you CAPITALISE and shout when you lose eh?
> What a dip**** you are 2G.

Maybe, just maybe, someday you will make an intelligent post, but I seriously doubt it.

Tom

[[email protected]]

Exactly what I though about all your posts so far.

[Haven]

On Tuesday, May 22, 2018 at 2:48:42 AM UTC-7, wrote:
> Exactly what I though about all your posts so far.

Geez, who/what do I listen to now, Alexa or Siri? I'm reminded of a junior high school food fight. Wonder if FSDO people are following this as entertainment?

[Charlie M. (UH & 002 owner/pilot)]

This, and other threads, are "no win" in my book.

My feeling, the less you deal with the government, the better.
I would trust on the "local guy" (a&p in this case) plus whatever you can show upfront. It is HIS neck that gets chopped if the upper group disagree after he signs off.
Maybe direct him/her to a relevant thread on here with linked FAA documents (or other documents for other locations).
I agree, this could have been easy, typical government (in the US) makes it harder.

Apologies to any local guys here. No, I am not looking to hang any of you, so, chill.......

[2G]

On Tuesday, May 22, 2018 at 9:53:59 AM UTC-7, Charlie M. (UH & 002 owner/pilot) wrote:
> This, and other threads, are "no win" in my book.
>
> My feeling, the less you deal with the government, the better.
> I would trust on the "local guy" (a&p in this case) plus whatever you can show upfront. It is HIS neck that gets chopped if the upper group disagree after he signs off.
> Maybe direct him/her to a relevant thread on here with linked FAA documents (or other documents for other locations).
> I agree, this could have been easy, typical government (in the US) makes it harder.
>
> Apologies to any local guys here. No, I am not looking to hang any of you, so, chill.......

I think your A&P should be the first place you start. But, remember, it is YOUR glider that is being modified, not the A&P's. Issues may arise when it's time to sell your glider and the prospective buyer's A&P reviews your logbook and finds discrepancies.

It is unfortunate that there are trolls out there that have nothing informative to say, but only throw around childish insults (which only reflects on them).

Tom

[Charlie M. (UH & 002 owner/pilot)]

Hey, do me a favor, don't drag me into this "discussion". I was only stating to start with your local guy and show him linked documents on this forum.

If you and others want to "discuss" things, fine.

I don't know, I am staying out of it.

[2G]

On Tuesday, May 22, 2018 at 5:36:24 PM UTC-7, Charlie M. (UH & 002 owner/pilot) wrote:
> Hey, do me a favor, don't drag me into this "discussion". I was only stating to start with your local guy and show him linked documents on this forum.
>
> If you and others want to "discuss" things, fine.
>
> I don't know, I am staying out of it.

Nobody put a gun to your head to write your post.

Tom