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FAR 145 Repair Station mandatory for any autopilot adjustments?

Any work on the plane regardless of cause has to be done by FAA certificated mechanics – that’s a stand alone requirement. In relation to transponder and static checks you have to comply with any rules of the country/airspace, but those rules have nothing to do with FARs that apply only to specific types of US domestic airspace. So the FAA repair station requirement in those specific FARs does not apply. Seems logical to me.

Personally I would challenge that interpretation…..it’s not that hard to get the checks done at a repair station in the UK…so I’m not going to trust a single DAR’s opinion on it….As far as difficulty in establishing foreign Repair Stations goes, the FAA recently (this year) have apparently started granting certificates again…

YPJT, United Arab Emirates

Any work on the plane regardless of cause has to be done by FAA certificated mechanics

Or anybody else (qualified or not) working under A&P supervision.

Same in EASA-land… otherwise nobody could train on the job.

Administrator
Shoreham EGKA, United Kingdom

“Done by” means signed off by

Peter,

Although an A&P may not sign off a 91.411 altimeter test, they may sign off a static pressure system test which checks for leaks in the static system.

(b) The tests required by paragraph (a) of this section must be conducted by—
(1) The manufacturer of the airplane, or helicopter, on which the tests and inspections are to be performed;
(2) A certificated repair station properly equipped to perform those functions and holding—
(i) An instrument rating, Class I;
(ii) A limited instrument rating appropriate to the make and model of appliance to be tested;
(iii) A limited rating appropriate to the test to be performed;
(iv) An airframe rating appropriate to the airplane, or helicopter, to be tested; or
(v) deleted
(3) A certificated mechanic with an airframe rating (static pressure system tests and inspections only).
KUZA, United States

Although FAR Part 91 applies primarily to US airspace, some sections apply to US registered aircraft outside of the US.

Subpart E—Maintenance, Preventive Maintenance, and Alterations

Sec. 91.401 Applicability.

(a) This subpart prescribes rules governing the maintenance, preventive maintenance, and alterations of U.S.-registered civil aircraft operating within or outside of the United States.

Sec. 91.411 “Altimeter system and altitude reporting equipment tests and inspections”. and Sec. 91.413 “ATC transponder tests and inspections.” both fall under Subpart E and apply outside of the US,

FAR Part 43 applies to all US registered aircraft.

Sec. 43.1 Applicability.

(a) Except as provided in paragraphs (b) and (d) of this section, this part prescribes rules governing the maintenance, preventive maintenance, rebuilding, and alteration of any-
(1) Aircraft having a U.S. airworthiness certificate;
(2) Foreign-registered civil aircraft used in common carriage or carriage of mail under the provisions of Part 121, or 135 of this chapter; and
(3) Airframe, aircraft engines, propellers, appliances, and component parts of such aircraft.
[(b) This part does not apply to—
(1) Any aircraft for which the FAA has issued an experimental certificate, unless the FAA has previously issued a different kind of airworthiness certificate for that aircraft; or
(2) Any aircraft for which the FAA has issued an experimental certificate under the provisions of Sec. 21.191 (i)(3) of this chapter, and the aircraft was previously issued a special airworthiness certificate in the light-sport category under the provisions of Sec.
21.190 of this chapter.]
(c ) This part applies to all life-limited parts that are removed from a type certificated product, segregated, or controlled as provided in Sec. 43.10.
(d) This part applies to any aircraft issued a special airworthiness certificate in the light-sport category except:
(1) The repair or alteration form specified in §§43.5 (b) and 43.9 (d) is not required to be completed for products not produced under an FAA approval;
(2) Major repairs and major alterations for products not produced under an FAA approval are not required to be recorded in accordance with appendix B of this part; and
(3) The listing of major alterations and major repairs specified in paragraphs (a) and (b) of appendix A of this part is not applicable to products not produced under an FAA approval.

So, although the requirement to have Appendix E—Altimeter System Test and/or Appendix F—ATC Transponder Tests and Inspections accomplished may or may not apply to a given country airspace, it the work is performed, it must be performed by a repair station or other authorized party as spelled out in 91.411

KUZA, United States

Thanks for the clarification – not being familiar with European airspace requirements it’d be interesting to learn what kind of airspace and where requires transponder and static system checks, and on what frequency, regardless of who does them on an N-registry plane. Those specifics are still driven by the airspace owner, the FAA doesn’t care.

Or in other words, a lot of N-registered aircraft operating within the US don’t require any such transponder or static system checks because they don’t operate in the relevant US airspace. What’s the legality of those aircraft if they suddenly appear in European airspace? And what if there is a mismatch between the specific FAA test requirements and the airspace owner test requirements?

Last Edited by Silvaire at 11 Jul 02:48

Most (all?) N-registered airplanes based in Europe are used for IFR flight…so the static checks are done. Transponders are required for controlled airspace so the checks are done….I would say most (all?) n-reg owners will comply with Parts 91.411 & 91.413….whether or not there is some argument to say it is not technically required (although I would say most are unaware of any debate on the issue).. If for no other reason it doesn’t make sense to somehow been seen to shirk the already considered lax (by certain factions over here) FAA requirements….

YPJT, United Arab Emirates

OK – so it’s clear one needs an FAA Repair Station even outside the USA. That DAR opinion appears to be incorrect.

I don’t think anybody is suggesting not doing those checks. After all, the aircraft is clearly not legal to fly IFR without them. It is merely the requirement to use a Repair Station which is in question – because there aren’t many around especially in some parts of Europe, and they do charge a lot of money. I used to pay GBP 350 if I flew there (which itself was about GBP 200 in flying costs plus GBP 60 for landing+ILS) or GBP 500 if they drove down (100 miles). Now I am lucky because I am hangared in one!

Administrator
Shoreham EGKA, United Kingdom

I don’t think anybody is suggesting not doing those checks

No, the point would be to understand exactly what is actually required in a fairly complicated regulatory situation, so as not to spend money unnecessarily, or to fall victim to predatory rules enforcement.

My last Mode C check was $80, done in my hangar. I need another one in a few months, time sure flies.

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