Solid State Backup AI

"Dan Truesdell" wrote in message ...
I had an interesting conversation with out local FSDO today. He
basically reported the FAA party line that anything that is "physically
attached" to a production aircraft must have an STC/337/what-ever to be
legal.

This argument is not supported by the regulation (depending on what you
mean by "what-ever"). A 337 is filed persuant to major modification.
The rule defining major modification doesn't say "anything attacdhed to
an aircraft." This is a figment of the FAA field organizaiton.

"Ron Natalie" wrote in message
m...

"Dan Truesdell" wrote in message
...
I had an interesting conversation with out local FSDO today. He
basically reported the FAA party line that anything that is "physically
attached" to a production aircraft must have an STC/337/what-ever to be
legal.

This argument is not supported by the regulation (depending on what you
mean by "what-ever"). A 337 is filed persuant to major modification.

There are three signature levels for a 337, but it is required for the
airplane to return to service, after a change.

The rule defining major modification doesn't say "anything attacdhed to
an aircraft." This is a figment of the FAA field organizaiton.

"Tarver Engineering" wrote in message ...

"Ron Natalie" wrote in message
m...

"Dan Truesdell" wrote in message
...
I had an interesting conversation with out local FSDO today. He
basically reported the FAA party line that anything that is "physically
attached" to a production aircraft must have an STC/337/what-ever to be
legal.

This argument is not supported by the regulation (depending on what you
mean by "what-ever"). A 337 is filed persuant to major modification.

There are three signature levels for a 337, but it is required for the
airplane to return to service, after a change.

So, how many signatures is required isn't an issue. If it's not a major
alteration, you don't have to deal with it at all.

"Ron Natalie" wrote in message
m...

"Tarver Engineering" wrote in message
...

"Ron Natalie" wrote in message
m...

"Dan Truesdell" wrote in message
...
I had an interesting conversation with out local FSDO today. He
basically reported the FAA party line that anything that is
"physically
attached" to a production aircraft must have an STC/337/what-ever to
be
legal.

This argument is not supported by the regulation (depending on what
you
mean by "what-ever"). A 337 is filed persuant to major
modification.

There are three signature levels for a 337, but it is required for the
airplane to return to service, after a change.

So, how many signatures is required isn't an issue. If it's not a major
alteration, you don't have to deal with it at all.

Doesn't your mechanic sign off 337s for you?

If you mean that an owner operator can pretty much do whatever they want to,
of course.

"Tarver Engineering" wrote in message
...

"Ron Natalie" wrote in message
m...

snip
There are three signature levels for a 337, but it is required for the
airplane to return to service, after a change.

So, how many signatures is required isn't an issue. If it's not a
major
alteration, you don't have to deal with it at all.

Doesn't your mechanic sign off 337s for you?

If you mean that an owner operator can pretty much do whatever they want
to,
of course.

Let me add to this, that the owner operator can even certify the part,
through the MIDO, if the manufacturer holds any PMA, or TSOA; for any part.
There is even a MIDO form the owner operator can fill out and file, that
makes it all legal. Our MIDO inspector flys an old Commander and he wanted
us to know that it was a real deal, as he has trouble getting parts for his
airplane, at times.

"Tarver Engineering" wrote in message ...
= So, how many signatures is required isn't an issue. If it's not a major
alteration, you don't have to deal with it at all.

Doesn't your mechanic sign off 337s for you?

If you mean that an owner operator can pretty much do whatever they want to,
of course.

No, it means that if it's not a major repair or alteration the FAA doesn't want to
hear about it on a 337. Does your mechanic file a 337 everytime maintenance
is performed on your aircraft? A major modification involves something that
changes the design of the aircraft as spelled out in Part 43. As long as I'm
playing along with the type certificate, my mechanic doesn't need any permission
from the FAA to perform work. It's not even the magnitude of the work that's
an issue. You can swap out entire engines for example, as long as it's part of
the approved design.

"Ron Natalie" wrote in message
m...

"Tarver Engineering" wrote in message
...
= So, how many signatures is required isn't an issue. If it's not a
major
alteration, you don't have to deal with it at all.

Doesn't your mechanic sign off 337s for you?

If you mean that an owner operator can pretty much do whatever they want
to,
of course.

No, it means that if it's not a major repair or alteration the FAA doesn't
want to
hear about it on a 337.

The FAA only signs one block of the three signature blocks of the 337.

The lack of a major modification in no way relieves the requirement for a
337 to return to flight.

Does your mechanic file a 337 everytime maintenance
is performed on your aircraft?

The 337 is part of the airplane's records.

A major modification involves something that
changes the design of the aircraft as spelled out in Part 43. As long
as I'm
playing along with the type certificate, my mechanic doesn't need any
permission
from the FAA to perform work. It's not even the magnitude of the work
that's
an issue. You can swap out entire engines for example, as long as it's
part of
the approved design.

There are three signature levels on the FAA form 337:

A&P
IA
FSDO

Some changes are perfectly fine for an A&P to sign off and FAA never needs
to know about it.

The lack of a major modification in no way relieves the requirement for a
337 to return to flight.

There's a reason why the title of Form 337
(http://av-info.faa.gov/afsforms/337.pdf) is "MAJOR REPAIR AND ALTERATION".
The requirement to file a 337 is given in Part 43, Appendix B, Recording of
Major Repairs and Major Alterations:

(a) Except as provided in paragraphs (b), (c), and (d) of this appendix, each
person performing a major repair or major alteration shall --

(1) Execute FAA Form 337 at least in duplicate; ...

Barry

"Barry" wrote in message
...
The lack of a major modification in no way relieves the requirement for
a
337 to return to flight.

There's a reason why the title of Form 337
(http://av-info.faa.gov/afsforms/337.pdf) is "MAJOR REPAIR AND
ALTERATION".
The requirement to file a 337 is given in Part 43, Appendix B, Recording
of
Major Repairs and Major Alterations:

(a) Except as provided in paragraphs (b), (c), and (d) of this appendix,
each
person performing a major repair or major alteration shall --

(1) Execute FAA Form 337 at least in duplicate; ...

Sure, but non-sequitur.

Tarver Engineering wrote:


The FAA only signs one block of the three signature blocks of the 337.

Irrelavant.



The lack of a major modification in no way relieves the requirement for a
337 to return to flight.


Does your mechanic file a 337 everytime maintenance
is performed on your aircraft?


The 337 is part of the airplane's records.

Yes, but again irrelavant for this discussion. The point is most
maintenence on the plane does not require a 337 to be filed.