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beware of "warranty" R&R labor costs



 
 
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  #1  
Old August 21st 03, 12:19 AM
Michael
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"Roger Tracy" wrote
So let me get this straight. If I own a Century autopilot (which I do) then
I have to pay some AH a royalty to use it? I think not.


Well, that depends on how you plan to use it.

If the autopilot is already installed and has paperwork, then no.

If you are planning to install it, then maybe. Specifically, it
depends on HOW you are going to install it.

Autopilot installation is considered a major alteration by every FSDO
out there. That means you need a 337, and you need to do it based on
acceptable data. Basically, you have three ways to make that data
happen.

If the autopilot was optional equipment for that make and model
airplane, then the airplane manufacturer will have approved drawings
for the installation. All you need to do is get a copy of the
drawings, follow them, and refer to them (Installed Autopilot123 in
accordance with AirplaneManufacturer drawing #123-456-789). You don't
have to pay a royalty, and pretty much any FSDO will accept that as
valid.

You could in theory get a field approval. Also no royalty. In
practice, field approvals are not being granted for autopilot
installations, period. Unless you've got something on someone at the
FSDO, they will tell you to get an STC or go home.

That brings us to the STC - the most popular way to install an
autopilot. The autopilot manufacturer is going to own the STC. These
guys have been pushing FSDO's to verify that you have permission to
use the STC. You want permission - you pay a royalty. Or you can
keep the autopilot on the shelf. Your call.

Basically, here is what's happening. There are effectively no new
airplanes being built. In order to make money, the autopilot
manufacturers have to sell new autopilots into old airplanes. That
means they need the old autopilots to go away. That's why they're
throwing up every possible roadblock to the installation of old
autopilots, and when that's not possible trying to make extra money
off them.

Michael
  #2  
Old August 21st 03, 05:30 AM
Justin Case
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Good explanation, but unless I see it in writing where the
manufacturer has the authority to do this, I consider it a rumor. And
if the FSDO's (I don't care how many) are bowing to this, and it's not
in writing, they're violating the law. Can ANYONE cite the statute?

On 20 Aug 2003 15:19:12 -0700, (Michael) wrote:

"Roger Tracy" wrote
So let me get this straight. If I own a Century autopilot (which I do) then
I have to pay some AH a royalty to use it? I think not.


Well, that depends on how you plan to use it.

If the autopilot is already installed and has paperwork, then no.

If you are planning to install it, then maybe. Specifically, it
depends on HOW you are going to install it.

Autopilot installation is considered a major alteration by every FSDO
out there. That means you need a 337, and you need to do it based on
acceptable data. Basically, you have three ways to make that data
happen.

If the autopilot was optional equipment for that make and model
airplane, then the airplane manufacturer will have approved drawings
for the installation. All you need to do is get a copy of the
drawings, follow them, and refer to them (Installed Autopilot123 in
accordance with AirplaneManufacturer drawing #123-456-789). You don't
have to pay a royalty, and pretty much any FSDO will accept that as
valid.

You could in theory get a field approval. Also no royalty. In
practice, field approvals are not being granted for autopilot
installations, period. Unless you've got something on someone at the
FSDO, they will tell you to get an STC or go home.

That brings us to the STC - the most popular way to install an
autopilot. The autopilot manufacturer is going to own the STC. These
guys have been pushing FSDO's to verify that you have permission to
use the STC. You want permission - you pay a royalty. Or you can
keep the autopilot on the shelf. Your call.

Basically, here is what's happening. There are effectively no new
airplanes being built. In order to make money, the autopilot
manufacturers have to sell new autopilots into old airplanes. That
means they need the old autopilots to go away. That's why they're
throwing up every possible roadblock to the installation of old
autopilots, and when that's not possible trying to make extra money
off them.

Michael


  #3  
Old August 21st 03, 05:07 PM
Ron Natalie
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"Justin Case" wrote in message ...
Good explanation, but unless I see it in writing where the
manufacturer has the authority to do this, I consider it a rumor. And
if the FSDO's (I don't care how many) are bowing to this, and it's not
in writing, they're violating the law. Can ANYONE cite the statute?


43.5 says that you have to execute a 337 in a matter prescribed by
the administrator. Since Marion doesn't have time to deal with these
issues personally, she delegates it to the FSDOs. Believe me, unless
you got the STC paperwork with your serial number on it, it ain't acceptable
to the administrator. The only way to legitimately get the paperwork is
to get it from the certificate holder and if they want to charge for it,
there isn't anything you're going to do.


  #4  
Old August 21st 03, 11:47 PM
Justin Case
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Show me! Show me! Show me! Don't quote numbers that appear to make
up your argument. Although your "43.5" may or may not say that, how
do you know your interpretation is correct. Now where does it say
that the "administrator" has the right to disregard other laws when
not in time of emergency. Show me the numbers so that I can see it
for myself. Help me out here, otherwise I'll think you're saying the
"administrator" may decide that there's too much air in everyone's
tires.


On Thu, 21 Aug 2003 11:07:45 -0400, "Ron Natalie"
wrote:


"Justin Case" wrote in message ...
Good explanation, but unless I see it in writing where the
manufacturer has the authority to do this, I consider it a rumor. And
if the FSDO's (I don't care how many) are bowing to this, and it's not
in writing, they're violating the law. Can ANYONE cite the statute?


43.5 says that you have to execute a 337 in a matter prescribed by
the administrator. Since Marion doesn't have time to deal with these
issues personally, she delegates it to the FSDOs. Believe me, unless
you got the STC paperwork with your serial number on it, it ain't acceptable
to the administrator. The only way to legitimately get the paperwork is
to get it from the certificate holder and if they want to charge for it,
there isn't anything you're going to do.


  #5  
Old August 21st 03, 11:58 PM
Ron Natalie
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"Justin Case" wrote in message ...
Show me! Show me! Show me! Don't quote numbers that appear to make
up your argument. Although your "43.5" may or may not say that, how
do you know your interpretation is correct.


Do you have a copy of the FAR's? Read 43.5 and come back and we
can have an intelligent discussion. They are available he
http://www.airweb.faa.gov/Regulatory...e?OpenFrameSet
How does anybody know anything is correct. I read what it says. It
says that for a major modification you have to file the paperwork to
the satisfaction of the administrator.

So you first have to agree or disagree with me on that.

Now note that the things left to the discretion of the administrator are a big
can of worms in the FAA. It pretty much means that they don't even have
to write down what they mean by that. They can approve or disapprove
things at whim.

Now it has been my experience and the experience of others here that an
STC is by default acceptable provided you have the appropriate STC paperwork.

Now where does it say
that the "administrator" has the right to disregard other laws when
not in time of emergency.


What laws are you talking about? I can't make any intelligent comment
if you're going to be so vague?

Show me the numbers so that I can see it
for myself. Help me out here, otherwise I'll think you're saying the
"administrator" may decide that there's too much air in everyone's
tires.


No, I am saying the administrator can determine whether a modification has
been done in accordance with her self-adopted standards. And anybody
who doesn't believe that hasn't worked with the FAA field system.


  #6  
Old August 22nd 03, 03:37 AM
Justin Case
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Unfortunately I'll agree with you that the feds are pretty screwed up.
I'd like to see where it says that her highness can put the interests
of certain individuals in front of others.

The law I'm looking for is the one that seems to be referred to when
everyone says that permission is needed by the STC holder to install
one of his products. I need to drill down and see exactly what it
states so that I may make my case. Doesn't seem to be anyone that can
steer me in the direction of this legendary federal law. If the feds
are going to refer to it, I need to see it, or assume it doesn't
exist.

And as I figured, your 43.5 doesn't do it for me, and I'm not
satisfied with your interpretation. Neither does the referring
paragraphs of 43.9 or 43.11. If your reading of this were actual, it
would then be prudent to see the rules governing the actions of the
administrator. I will not blindly be led by the short hairs into
believing that an appointed individual can alter the laws of this
land. If the administrator is not allowing certain alterations, there
needs to be legitimate reason why, not just a "Duh, okay!".

And when you feel you're up to some real research and interpretation,
then respond with a good argument, not with the silly FAR's.


On Thu, 21 Aug 2003 17:58:07 -0400, "Ron Natalie"
wrote:


"Justin Case" wrote in message ...
Show me! Show me! Show me! Don't quote numbers that appear to make
up your argument. Although your "43.5" may or may not say that, how
do you know your interpretation is correct.


Do you have a copy of the FAR's? Read 43.5 and come back and we
can have an intelligent discussion. They are available he
http://www.airweb.faa.gov/Regulatory...e?OpenFrameSet
How does anybody know anything is correct. I read what it says. It
says that for a major modification you have to file the paperwork to
the satisfaction of the administrator.

So you first have to agree or disagree with me on that.

Now note that the things left to the discretion of the administrator are a big
can of worms in the FAA. It pretty much means that they don't even have
to write down what they mean by that. They can approve or disapprove
things at whim.

Now it has been my experience and the experience of others here that an
STC is by default acceptable provided you have the appropriate STC paperwork.

Now where does it say
that the "administrator" has the right to disregard other laws when
not in time of emergency.


What laws are you talking about? I can't make any intelligent comment
if you're going to be so vague?

Show me the numbers so that I can see it
for myself. Help me out here, otherwise I'll think you're saying the
"administrator" may decide that there's too much air in everyone's
tires.


No, I am saying the administrator can determine whether a modification has
been done in accordance with her self-adopted standards. And anybody
who doesn't believe that hasn't worked with the FAA field system.


  #7  
Old August 21st 03, 05:00 PM
Ron Natalie
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Posts: n/a
Default


"Michael" wrote in message om...

If the autopilot was optional equipment for that make and model
airplane, then the airplane manufacturer will have approved drawings
for the installation. All you need to do is get a copy of the
drawings, follow them, and refer to them (Installed Autopilot123 in
accordance with AirplaneManufacturer drawing #123-456-789). You don't
have to pay a royalty, and pretty much any FSDO will accept that as
valid.


If it was approved on the type certificate, you don't even need a 337. Changes
in accordance with the aircraft specifications as certificated are not major
atlerations as far as far as part 43 is concerned.



  #8  
Old August 22nd 03, 02:58 AM
G.R. Patterson III
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Ron Natalie wrote:

If it was approved on the type certificate, you don't even need a 337.


Which can be a trip. When I bought my Maule, I added a few things as money
permitted. One item was a clock. Chief Aircraft had a model that was on the
optional equipment list. No STC required.

When it arrived, I discovered that they had sent a new model. This one had
internal lighting, which was the only difference. That meant that a 337 had to
be filed, a local FBO had to handle the paperwork (which costs), and the local
FSDO required a field inspection.

All for a stinking clock.

George Patterson
Brute force has an elegance all its own.
 




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