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Doing FAA Field Approvals in Europe / FSDO or DER to support FAA Field Approval?

If that was taken literally, it would mean an Installation Manual cannot be used as data either, which would pretty well put an end to the Field Approval route, not just because most of the authors are (a) dead (b) uncontactable (c) unwilling to assist. Everything any human writes is automatically copyright, for some x years after the author’s death. So clearly it is more complicated. In aviation certification, most of the data is clearly intended to be placed into the public domain. And with STCs is gets more ambiguous when you get onto the illegal restraint of trade implicit in restricting an STC to just a [manufacturer’s] dealer which is a fairly standard clause in new STCs which otherwise permit its free use for an installation.

Administrator
Shoreham EGKA, United Kingdom

Peter wrote:

The contents of an STC (not the STC number) can be used as data to support a field approval.

I would be very careful with that. The FAA has ruled that the “approval data” found in STCs and Field Approval 337 forms is Proprietary Information and thus copying of such is a Copyright AND Intellectual infringement.
I hasten to add that I’m NOT a lawyer, just saying …

Last Edited by Michael at 22 Jul 05:38
FAA A&P/IA
LFPN

The contents of an STC (not the STC number) can be used as data to support a field approval. That’s what I did with the Sandel SN3500 – used a C421 STC. That STC was drawn up for me by a retired senior FSDO inspector.

Administrator
Shoreham EGKA, United Kingdom

Interesting thread, I’m looking to put non-standard tyres and rims on my PA32 – it’s FG, so identical to a Cherry Six – for which an STC and other FA exist.

Unsure as to whether this will make the process easy, normal or impossible!

I agree but to be fair, in 2001, RNAV as a legal concept didn’t exist, the then trendy job creation scheme was probably PRNAV which almost nobody understood, GPS approaches didn’t exist in Europe…

This customer, like most, would have done what the installer (who is not on EuroGA, BTW, although they do read it because they once threatened legal action over some post) told him he needs, and got his cheque book out. I know the company and in my involvement with them found them having only a very basic capability and that was more than a decade after this job.

A Field Approval would have been the other option but, as I say above, probably as hard then as today. The FSDO business was handled by the NY IFO which has never been supporting these services to GA. Accordingly the DER 8110 route came into common use by avionics shops because it is predictable: the shop does the basic design, liases with a US based DER who signs it off at a rate of (according to one report) $300 per page, and the package is sent off with the 337 to Oklahoma for filing. The customer gets a bill which IME starts at 2k. Nowadays the 8110 data can be used to apply for an EASA STC which is a bonus for the shop which can sell on that STC to other (less clued-up) shops.

The Field Approval route – IF you can get it to work – is great for the proactive aircraft owner who wants to install something and has a good guy/team which can do it.

Administrator
Shoreham EGKA, United Kingdom

Peter wrote:

It was the state of the art box then; no W version.

Yes, that I know, but seems rather silly to spend all that money and not be able to use it for what it was made for: RNAV !

FAA A&P/IA
LFPN

It was the state of the art box then; no W version.

Administrator
Shoreham EGKA, United Kingdom

Peter wrote:

What year was that GNS530 installed?

You were correct: 2001

Why ?

FAA A&P/IA
LFPN

What year was that GNS530 installed?

Administrator
Shoreham EGKA, United Kingdom

wigglyamp wrote:

If you go through an EASA Part 145 maintenance organisation that also has FAA approval then they can raise the 337 without having access to an IA. With the increased access to AML STCs, we don’t often need to get data approved

Correct on both counts and why trying to install a used, non-WAAS GNS unit is a waste of time – much easier/better just go with the AML !

Me thinks that the “VFR only” placard on the DER/8110-3 install I’m looking at is do to lack of AFMS and a proper Flight test, both of which are easily corrected.

Last Edited by Michael at 08 Mar 06:59
FAA A&P/IA
LFPN
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