Glide computer in certified glider

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/...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..

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?

"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.

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

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

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.

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