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#51
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Glide computer in certified glider
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 |
#52
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Glide computer in certified glider
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/#!to...lt/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 a * 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 |
#53
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Glide computer in certified glider
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/#!to...lt/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 a * 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 |
#54
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Glide computer in certified glider
"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. |
#55
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Glide computer in certified glider
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 |
#56
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Glide computer in certified glider
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 |
#57
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Glide computer in certified glider
SO you CAPITALISE and shout when you lose eh?
What a dip**** you are 2G. |
#58
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Glide computer in certified glider
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. |
#59
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Glide computer in certified glider
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 |
#60
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Glide computer in certified glider
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 |
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