Looking for a little help please with my D Reg (1967) Mooney. Im new to this since its my first stint at (certified) aircraft ownership. It has for most of its existence been maintained at FWM in Hangelar near Bonn. Ive been its owner for two or three years now. When I took ownership, I discovered differences in ways that German reg aircraft differ from the UK for example (not that Im an expert on either) – Like the IFR certificate, different weight and balance schedule, a unified Bordbuch rather than engine, prop and airframe logbooks and various other items.
I have mountains of paperwork and maintenance records (going back to 1967) including the original POH from 1967- which is stamped with the Aircraft Reg number but nothing that i can see that resembles a POH or flight manual Supplement in which would reside pilot instructions for kit that has been installed since it was new- like the KFC 200 Autopilot and the GNS430 (not W).
Heres the question. Im doing my IR flight training in it and the flight training organisation are a bit shocked that there is no POH supplement – ‘what !! its a legal requirement/ how can it not have one / every aircraft weve seen has’ etc etc. Apart form the ‘legal requirement’ to carry such a thing on board, the CAMO ought to check its up to date every annual and they want a copy for their records etc.
Now i do take the point- with no real updates to the POH since 1967 how’s a pilot to know how the GNS430 works (and that its IFR certified and for what exactly) or the KFC 200 in this particular installation. Of course I have operating handbooks for each of these things and probably the installation maintenance records amongst many files…
SO… should I have a POH supplement with ‘Key’ (whatever that is) items listed- including their operation and limitations listed – but i havent got one following the purchase (or havent found one amongst the paperwork!!) – Or isnt a specific POH supplement (of ‘flight manual supplement’) with such items mandatory in Germany?
thanks particularly to those of you with D reg machines who will know the answer!
Justin
Justin,
Have a look in your docs. I just came across a German registered “C” Model the other day and found that it had a normal Mooney issued POH everyone was using to fly it (so do I in my Swiss registered one) and then there was a German translated version which had the supplements you are looking for hidden away in the on board docs, clearly not opened for a long time.
In theory, the “legal” Operating manual which has to be carried on board should have the basic supplements for the additional STC’d equipment such as the AP and the Avionics. What I have seen also is that this usually is a large A4 type folder which then in plastic pockets includes the manuals for the addons.
What Mooney type are you flying? Mine is a 1965 “C”. I am curious as you mention a KFC200 in a 1967 model, which I am told I can’t have in my airplane.
Ok I will have a good rummage through the docs. Its an F. Id be surprised if any type certificate for the KFC200 didnt group the vintage mooneys together (ie if its in my F it should go in your C) kind of thing. If i discover anything useful in my docs on that front Ill let you know.
j
Hi Justin, rather than meet on various forums we ought to meet up in the UK over a beer and compare paperwork on our M20Fs!
Mine as you know is also a 1967 M20F but Danish registered.
As mentioned above by Mooney Driver, I have a Danish CAA stamped copy of the original 1967 flight manual (30 or so pages, much smaller than subsequent POHs on any aircraft) plus stamped photocopies of the STEC autopilot and Garmin GPS155xl as well as the KNS80 Pilot Guides, all in a neat (or not so neat after a few years) plastic folder, so I guess that counts as ‘approved POH’ for me. With a KFC200 and a 430 you have a much higher tech installation than mine , so I would gladly swap! Mind you, there is even a copy of the intercom manual in there.
I guess the training organisation is being a bit fussy but personally I would not lose too much sleep about that kind of paperwork, my own point of view is if the aircraft has a valid ARC, if is a legal documented installation (i.e. for CofA purposes) and it works in real life, whether or not I have the exactly right kind of paper or stamp won’t stop me from flying. I think the state of confusion under EASA is such that you will get a variety of different opinions on what paper is needed here or there, especially when people tend to gold plate it and add previous historic national regulations, and you will loose the will to fly, so I’d rather just fly…
What I suggest is ask you last avionics shop or the one who installed it to find or re-issue the correct paperwork if they can, failing that try the European Mooney Association members (empoa.eu), mostly German Mooney owners on there and the KFC200/430 is a pretty standard combo on M20Js and Ks. I was missing a page from the installation report on my Garmin from 1998 by a previous owner, I called up Scandinavian Avionics and they emailed me the pdf two days later free of charge… Credit to them! Maybe you could just print a PDF of the Garmin and King manuals and get your avionics shop to stamp it.
ps: lunch is on me if we ever meet and you happen to find in your paperwork who re-arranged your panel to a modern configuration and what paperwork the LBA produced. I am thinking of having mine redone soon and would avoid the dreaded minor/major mod charade if I have a documented proof it has been done before under EASA. Of course in the case of a ‘N’ it would be a simple logbook entry and the owner can do it himself! So yes, it can be a pretty decent lunch!
Patrick
Justin, this is not an issue specific to D-regs. Many STCs contain an AFMS (authorized flight manual supplement) and your aircraft is not airworthy unless that AFMS is present on board. In real life, people tend to be sloppy about it. I have never heard that anyone had trouble because of this.
Sometimes it leads to interesting questions. I had an S-TEC 60-2 installed for which an AFMS was provided. Then I changed to the Avidyne DFC-90 for which another AFMS was supplied. The Avidyne STC requires an S-TEC autopilot because it uses the servos. Does this mean I have to keep the S-TEC AFMS in my POH or can I remove it?
Of course in the case of a ‘N’ it would be a simple logbook entry and the owner can do it himself!
I don’t think so 
It can be a minor mod but the owner can’t do it himself.
your aircraft is not airworthy unless that AFMS is present on board.
That’s technically true under any reg but loads of avionics boxes have been installed without this having been complied with. You would ground half the GA fleet if you enforced this. I know a gue who has installed maybe a hundred GNS430 boxes and never did any of this stuff. I have even had a well known UK shop quote me for a GNS530W on a “customer responsible for paperwork” basis.
Under N regs the vintage Mooney panel has been updated by quite a few owners, under a Form 337 and then signed off by an Ai. OK nowadays getting a 337 signoff is apparently more difficult than in the past, quite a few examples on Mooneyspace.there was a how to guide somewhere in the Web, one guy did it in a day! what changes is just a single layer that sits on the panel, just a frame that sits on a few bolts in the Mooney, a flat piece with a few holes, not the complete structure so nothing structural.
anyway apologies for the digression, completely academic for me as I am not N reg and completely incapable of doing it myself, but frustrating to see that done in the US when most avionics shops here say it is an insane job involving tons of expensive paperwork.
See jonathanpaul.org/pdf/NewPanel.pdf
I don’t think the “337 and signed by an IA” route actually exists – unless the 337 is backed up by either (a) an STC, or (b) an 8110-3 from a DER.
Sure it has been done (I’ve seen it) but I don’t think it is legal in any way. The resulting 337 is bogus. If somebody does an FAA database 337 search, they will find a 337 in your records but they won’t find it in the FAA records. You will then have an awful lot of “fun” either selling the plane or doing a registry transfer. On the latter, the plane will just sit there grounded, with you over a barrel, for ever, or until you can dig out a DER or a DAR who is willing to sort it out, and European DARs are about €1500/day. You won’t be able to fly it out because it doesn’t exist (no CofA).
Apart from the above two routes, a major alteration (which always requires a 337 unless the work is covered by a Type Certificate) can only be done as a Field Approval and that is the route which is now hard to do if you are in Europe (due to the lack of FSDOs). Those avionics installers who want a gold plated paperwork package for a non-STC job, and who therefore face either the field approval or the DER route, go for the DER route because (like the STC route) it doesn’t involve any FAA approval. The 337 is still sent to the FAA but only for filing in the aircraft records. I know just one UK shop that uses the DER route (there may be others) and they charge for it – €2000 or so. And that is the price an N-reg owner pays for wanting to install a box which doesn’t have an STC
The above is my best understanding to date and if anyone knows otherwise I would be glad to hear it. I do have someone in the USA who is just about able to submit a field approval on my behalf (I’ve done it twice – one two) but he is very busy.
Merely re-laying out an instrument panel is normally a minor mod (N-reg and EASA-reg) – unless you are moving something out of the pilot’s defined field of view in contravention of the STC or whatever approval it went in under. For example I vaguely recall there is/was an EASA ruling which requires a vacuum AI to be located right next to any Aspex EFD-1000, aligned with the AI on the Aspen. One pilot I know was refused an Aspen installation over this, so in disgust he told the shop to rip out the Aspen and revert it back to the way it was, and EASA bent over and let him do it. I guess it was an EASA 21 company doing the work 
Similarly re-laying out the RHS panel is almost always going to be a minor mod. Again, unless you are doing something with mandatory instruments / annunciators and then you need to be careful. Any avionics on the RHS, or any newly installed avionics anywhere, must not have any autopilot connections, otherwise the autopilot AFMS needs rewriting and you very definitely do not want to go there
I had a look at that PDF. You definitely want to involve whoever is going to sign it off before you start and that applies to any Major mod. And if it is a Minor mod then you need to be 100% sure of your ground (with an N-reg I would ask a couple of DERs and maybe one DAR for an informal view, plus of course your IA) because a Minor mod can always be argued about if somebody is out to get you.
As always, you guys are a great help! I’ll have a look through the mountains of paperwork at home to see if I can find something that resembles a supplement relating at least to the autopilot and 430 installation. Failing that, I’ll try Herr Birkmann and the maintenance shop in Hangelar (installers) and failing that, I’ll try to get something together to have my current shop to sign off. Achim- when I wade through mountains of (German) maintenance records what am I looking for which tells me that it’s a POH supplement type document- any particular phrases? Point taken though Patrick about gold plating of yesteryear’s installations requiring a paperwork trail suited to today. As for lunch- anytime! Likely haunts for me are- North of England (but can travel) or fairly regularly hauling (in the mooney) to Leipzig / area.
Justin
Not all aircraft manufactured prior to 1979 have a POH. FAR 21.5 determines what aircraft require an AFM.
Sec. 21.5 Airplane or Rotorcraft Flight Manual.
(a)With each airplane or rotorcraft not type certificated with an Airplane or Rotorcraft Flight Manual and having no flight time before March 1, 1979, the holder of a type certificate (including amended or supplemental type certificates) or the licensee of a type certificate
must make available to the owner at the time of delivery of the aircraft a current approved Airplane or Rotorcraft Flight Manual.
(b) The Airplane or Rotorcraft Flight Manual required by paragraph (a) of this section must contain the following information:
(1) The operating limitations and information required to be furnished in an Airplane or Rotorcraft Flight Manual or in manual material, markings, and placards, by the applicable regulations under which the airplane or rotorcraft was type certificated.
Section 91.9 describes what is required and in the case of an aircraft that doesn’t have a POH, it must have placards to prescribe any operating limitations. Of course these regulations only apply to N numbered aircraft.
Sec. 91.9 Civil aircraft flight manual, marking, and placard requirements.
(a) Except as provided in paragraph (d) of this section, no person may operate a civil aircraft without complying with the operating limitations specified in the approved Airplane or Rotorcraft Flight Manual, markings, and placards, or as otherwise prescribed by the certificating authority of the country of registry.
(b) No person may operate a U.S.-registered civil aircraft—
(1) For which an Airplane or Rotorcraft Flight Manual is required by Sec. 21.5 of this chapter unless there is available in the aircraft a current, approved Airplane or Rotorcraft Flight Manual or the manual provided for in Sec. 121.141(b); and
(2) For which an Airplane or Rotorcraft Flight Manual is not required by Sec. 21.5 of this chapter, unless there is available in the aircraft a current approved Airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, or any combination thereof.
Some manufacturers, repair stations or IA would interpret that an aircraft had to have the latest version of the POH in the aircraft. However, this was determined by the following FAA General Counsel opinion that this was not correct. See the text below:
This is in response to your letter requesting an interpretation of 14 C.F.R. § 91.9(b)(1). In your letter, you asked whether the Rotorcraft Flight Manual (RFM) which was provided at the time that an aircraft was purchased would be considered the “current” RFM for the purposes of § 91.9(b)(1) or whether the operator would need to have the latest revision of this RFM in order to legally operate the aircraft. You also asked whether this interpretation would remain the same for a part 135 operator.
Section 91.9(b)(1) prohibits operation of an aircraft for which an RFM is required if that aircraft does not contain a copy of the “current” approved RFM. The FAA first addressed the meaning of “current” in an interpretation that was issued in 1998. The 1998 interpretation stated that the word “current”, as used in an operational regulation, imposed an ongoing obligation to keep the latest copy of the RFM in the aircraft.
However, the 1998 interpretation did not address the issue of whether this position complied with the Administrative Procedure Act (APA) The FAA resolved this issue in a 2008 interpretation, which addressed the word “current” in the context of manufacturers’ inspection programs.’ In that interpretation, the FAA found that construing the word “current” to encompass “subsequently issued changes to maintenance manuals or inspection programs” would violate the APA. This is because certain regulations require the regulated parties to comply with the current maintenance manuals and inspection programs." If the word “current” in those regulations is construed to encompass subsequent changes that a third party makes to a maintenance manual or inspection program, then by making those changes the third party would be able to impose significant additional regulatory burdens without first going through the notice and comment process required by the APA. Thus, in order to comply with the APA, the 2008 interpretation construed the word “current” more narrowly so that this *word did not impose an ongoing obligation, but rather, in the context of the regulation at issue, applied only to a manufacturer’s inspection program that was in place at the time that it was adopted by the owner or operator.
However, an RFM that was provided with the aircraft at the time the aircraft was purchased may subsequently be amended by an Airworthiness Directive (AD). The RPM, as modified by the AD, would be considered a “current, approved” RFM for purposes of § 91.9(b)(1). This is because an AD is issued pursuant to the procedures specified in the APA usually through notice and comment rulemaking. As such, construing the word “current” in the regulations to encompass obligations imposed by an AD would not violate the APA.
Applying the above discussion to this case, the word “current”, as it is used in § 91. 9(b)( I), refers to the version of the RFM that was in place at the time that the aircraft in question was purchased and includes any subsequent AD-mandated changes that were made to the RFM. The word “current” does not encompass any subsequent changes that were made to the RFM that were not mandated by an AD or other rulemaking because those changes did not go through the notice and comment rulemaking process.
For some time, a VFR GPS has not required an AFMS, but an IFR installation does. The AFMS has to be approved by the FAA. Prior to the WAAS GPS units, the manufacturer provided a sample AFMS that the installer edited to reflect the installation. To get it FAA approved, it had to be sent to an FAA FSDO with a field approval 337. Typical processing was a few weeks. Now with STC’s covering the installation, this is not necessary as the STC comes with an approved AFMS with the installation. Autopilots always require an AFMS. Since these are installed under an STC, the AFMS should be provided at the time of installation. Some vendors will provide a free copy while others require your first born.
So if an STC or an AD required a AFMS, then it was required, otherwise not.
