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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 :-)). |
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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. |
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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).
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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 |
#5
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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. |
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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 |
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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. |
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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 |
#9
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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... |
#10
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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 |
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