We have done this point a number of times but always without any clear conclusion posted by anyone, IIRC.
It turns out there is a document called Major Alteration Job Aid. You can google for it. Curiously I had one listed in my SN3500 installation writeup (funny how one has been up the same road before) but a more current version is here
In the absence of an STC, the category you want your proposed mod to be in is EVL and that qualifies for a Field Approval.
Peter wrote:
In the absence of an STC, the category you want your proposed mod to be in is EVL and that qualifies for a Field Approval.
Not so fast. It reads “may be eligible” , NOT “is eligible” .
Whilst the list does cover a few more specific examples, there remains vast grey areas, so a definitive “clear conclusion” will not always be .
It reads “may be eligible” , NOT “is eligible” .
Well, a Field Approval is, ahem, field approved by the FAA, so if they don’t want to approve it then, ahem, they won’t approve it.
Then you have to revise the application based on the FSDO inspector feedback. I have done two of these so I know how it works, and I am not even an A&P myself!
The reason I posted this is that this document is a very useful guidance. If your proposed mod qualifies as a Major Alteration based on the main decision chain, this document should offer guidance on whether a Field Approval is possible – if it goes under EVL.
I know the FAA reads EuroGA (and so does every European CAA) but that does not prevent having an informative discussion. After all, the FAA wrote that document.
If the FAA sign off on a Field Approval, there is no grey area. The mod is 100.00% legal. It is a very safe procedure to use.
If they don’t then you revise the application until they do, or follow one of the other routes i.e. an STC or the DER route. Most people won’t bother then because they cost money. A Field Approval is free from FAA charges.
You’re missing the point: It’s about the DATA that’s supplied for the Field Approval, NOT the Field Approval itself.
AFS-300 MAJOR REPAIR/ALTERATION DATA APPROVAL
Mike Bush had a write up about just this topic in April 2017 CPA magazine. Some things are obvious but the take away is left most of the times in grey areas to the mechanic according to Bush.
From my experience he is right and it also depends on the FSDO some are much easier than others. So its worth some research as the which ones are more consumer friendly.
If you can get the article its worth a look. Or just wait for the upcoming webinar.
This is now off-topic for STCs and is discussing the general issue of the FAA Major v. Minor Alteration decision flow.
There are sure grey areas there but the biggest issue is that the vast majority of mechanics (FAA and EASA) can’t / won’t read the regs, and will refuse to do the work unless they treat it as a Major i.e. TC (factory approved) / STC / Field Approval / DER 8110. It is just the way the industry is. Those good with spanners are mostly not good with reading or writing.
In the EASA system these people have an easier life because they don’t have to make any decisions like this, most of the time. No STC = no-go.
Are you referring to Mechanic here in Europe or in the US? Cause I have found no problem in the US with my 30+ years of experience there.
Both.
In the USA however there is a choice of FSDOs and you can do “FSDO shopping” so if you get a difficult inspector in one, you can try another. Here in Europe we have been under the responsibility of the totally dysfunctional NY IFU (a rogue FAA outpost which does what it likes without any oversight by the FAA) and e.g. avionics shops over here have bypassed them by using the DER 8110 route (337 etc filed direct to Oklahoma; no contact with the FAA). The problem with that is that the client gets billed an extra 2k or so for the DER package…. A Minor route is another good solution, of course.
So get an FAA mechanic who interprets the regs the correct way since there can be such a grey area. But then I guess the others who loose work to them will jump all over them and complain to the FAA.
Its cheaper to fly in an FAA A&P for 1 or 2 jobs where the costs are shared than go through the DER nonsense. Usually a guy retired and wanting to see the world would be a good way to go.
Yes I had heard that the FSDO in Munich was difficult for certain things.
I think its a function of top down policy since the FAA employees have a lot of good people and some real jerks who make headline news. It dosent take to many of them to grab everyones attention.
