It is very difficult to get decent information on this, but I have been hearing rumours that under the FAA-EASA treaty the FAA is no longer doing field approvals for any European based aircraft.
I have heard it from two different people (both IAs).
If true that would mean Major mods are not practically doable unless supported by an airframe specific STC.
One "name" mentioned is an FAA EASA TIP which when googled turns up this 2011 treaty. Local copy: https://www.euroga.org/system/1/user_files/files/000/037/800/37800/81fc4d905/original/GermanyIPA.pdf
A google on the above turns up a whole load of other stuff. But it doesn't actually say (that I can see) field approvals have been stopped.
One thing it does suggest is that EASA officials will be able to verify mods on N-reg planes. Presumably all they will be able to do is verify they were done IAW Part 91 i.e. the usual Minor v. Major decision chart stuff, and whether a Major mod was correctly implemented.
Obviously field approvals continue in the USA so if you can get a field approval processed at a US FSDO that will still be good. And the alternative - an 8110-3 generated by an FAA DER - should still be a workable process, if potentially expensive.
This drives business towards Garmin or Garmin, of course.
I came across this when looking for a way to get a field approval for the B&C backup alternator mod.
Before you assume that field approvals are not supported in Europe, ask the FSDO in Germany directly (I think they are in Frankfurt).
I spoke with Frankfurt IFO only a few months ago (so after the TIP was published) and they confirmed they. CAA have already taken on oversight of FAA Repair Stations in the UK so there is a potential grey area of responsibility. I would do everything possible to keep CAA away from an N reg aircraft. I think your aux alternator would still be approved through Frankfurt but it might take some time (given the geographical area they are responsible for and the number of staff). A DER might be a better, if more expensive bet, if your requirement is time-critical.
Seems I lost a bit of the previous post. I meant to say "I spoke with Frankfurt IFO only a few months ago (so after the TIP was published) and they confirmed they would accept a 337 for field approval at that office."
I’m currently upgrading my avionics, and believe that I’ll likely need an FSDO or DER to support an upgrade from a Sandel SN3308 to an SN3500.
I and my aircraft are based in Switzerland. My current avionics installation (N-reg Cessna R172K) was done in 2003 and consists of a Sandel SN3308 with a variety of connections: Garmin 430, Stec 30 A/P, Stec GPSS, KMT-112/KG-102A compass system, WX-500 Stormscope, KX-155 (appears as RMI on 3308). The 3308 does NOT contain the upgrade to support GPS/WAAS approaches. The aircraft is N-reg and the installation was done as a Major Alteration via a DER as a field approval with 337. The DER work took a long time.
I’m now replacing the KX-155 with an Avidyne IFD540 (STC’d) and the SN3308 with a Sandel SN3500 to get full GPS/WAAS approach capability. Although I’m still trying to get confirmation that the Sandel replacement can’t be done as a Minor Alteration, I’m trying in parallel to set up for an additional field approval. There have been a lot of changes since 2003, including the loss of the FAA NY FSDO support for international field approvals.
Theoretically, any FAA FSDO can do a field approval. Does anyone know of a US domestic FSDO that will accept 337 & field approval requests from facilities and A&P/AI in international locations? Any suggestions for a DER that could process this quite quickly? While the EHSI cabling will be new to match the different SN3500 pin layout, the functionality change from an EHSI perspective is essentially only addition of the the IFD540.
Vince
The NY IFU has not been any good for field approvals for many more years than I know about.
IMHO this is a Minor Alteration anyway, but it may depend on autopilot connections.
Otherwise, there are various DERs around and even Sandel have an in-house one, but that is a fairly pricey route. If you can find some kind A&P/IA in the USA who can sit across a desk with an FSDO inspector and get it approved there and then, that would be the most cost effective route. The actual location of the aircraft is irrelevant and probably of no interest to the FAA.
That last suggestion would be a great solution. I’ve queried my local A&P & he’s trying to locate an A&P near an FSDO that would be prepared to help that way.
If anyone reading this forum knows of such a US A&P, I would much appreciate hearing from them.
An update on this old thread.
I have just got my third FAA Field Approval done.
The previous ones were this and this and those were processed by two guys in the USA (the first was an FAA inspector and the second is a pilot). Both were kindly done for free.
The third was for the B&C backup alternator. It was started by a US avionics guy a couple of years ago but he got busy and abandoned it. I paid him for the work done, but it was not sufficient to be usable. It was finally done by a freelance certification consultant, for $1k, after I posted a “$1k reward” on a US site. There are various STCs but none for the TB20, even though the installation is simple and virtually identical to some STCd aircraft types. It turned out to be a gold plated job as field approvals are apparently becoming these days, with an ACO having to separately inspect the AFMS.
Anyway, this last US guy is really competent, communicates well, understands the topic (he owns an IFR tourer himself) and is willing to do more of these for European based aircraft, so if anyone needs this, drop me an email and I can put you in touch.
There is the obvious limitation that the job needs to be fairly simple, self contained and well documented, because no US FSDO inspector will be able to inspect the aircraft.
The alternative route for Major Alterations is the DER 8110 one which is favoured by avionics shops over here because it doesn’t involve the FAA approving anything, but it is expensive, with the client paying 2k and upwards, and the shop can then use the resulting data to obtain an EASA STC which they can sell to other installers.
Obviously I have no financial interest in this recommendation.
Peter wrote:
The alternative route for Major Alterations is the DER 8110 one which is favoured by avionics shops over here because it doesn’t involve the FAA approving anything, but it is expensive, with the client paying 2k and upwards, and the shop can then use the resulting data to obtain an EASA STC which they can sell to other installers.
I was just going through the records of a light twin on FAA reg that was based in the S of UK. About 10 years ago a large UK avionics shop installed a GNS530 using a DER endorsed 8110.
Despite the DER 8110, the installation is placarded and filed in the 337 as “VFR Only” .
This raises two questions : First, why pay a DER when a “VFR only” GPS installation is a simple log-book sign-off and secondly why would they not file it for IFR use ?
When my plane was new, 2002, and going onto the G-reg (it came from France as a temporary F-reg) the UK CAA inspector demanded it is placarded VFR only because, he said, the KLN94 is a VFR only GPS! The agent, Air Touring, of course duly complied (adding the other CAA-specified items like EXIT stickers on the 2 doors) but it was trivial to change the config afterwards.
A GNS box has no “VFR/IFR” config, so this is doubly bizzare. I suspect the reason was a subtle one, along the lines of the issue here. Did the installer do the DER package design, used a US based DER, or did they buy the DER 8110 from another shop? I wonder if @wigglyamp could shine some light on what the reason might have been?
I don’t think (N-reg) a panel mount GPS is a Minor Alteration if it is “VFR”. My recollection is that what makes it Minor is a lack of connection to an autopilot (and some other conditions). A device used for “monitoring only” is Minor if
That allows you to install a ton of “monitoring” stuff as Minor, on an N-reg.
