A&P with IA is not just a lot less income, it often means no business and no income. The IA on top of the A&P rating is not particularly hard to get, but in the US you can’t likely run any kind of shop or service without it, and you would need to do some fancy footwork to keep going if you lost it.
By my observation a non-IA A&P is more often held by somebody who does something else for their primary income, and who doesn’t get the IA because maintaining it generally means doing a certain number of inspections (more than one or two) every year. I think all the non-IA A&Ps I know personally work only on their own planes, sign off their Annuals as a 100 hr, then get an IA friend to do a quick physical inspection and additional logbook entry when completed.
A Form 337 is mainly used only as the certification that a given major alteration or repair has been inspected for conformance with approved data. As such the inspection can be performed by an A&P mechanic with an IA (IA = Inspection Authorization) who after signing the 337 mails it to FAA to be added to the aircraft records they have on file. No additional FAA approval is required if pre-existing approved data was used, it just gets filed.
The approved data itself comes from a variety of sources: AC 41.13 (the large books of pre-approved practices published by FAA), an applicable pre-approved STC, and an FAA Designated Engineering Representative (DER) review/report are three of the most common sources of approved data. A field approval is when the FAA itself directly approves the data for a major repair or modification, on one aircraft. When that occurs the FAA approval is also noted on the 337, prior to the work being done, prior to the IA inspection sign-off and prior to the 337 being mailed for filing in the aircraft records. Nowadays the FAA does not have the engineering capability to do many field approvals and so they mostly want a DER involved if other forms of approved data are not available. Changing from one engine variant to another that isn’t of the TC when they almost exactly the same might be the kind of thing that gets an FAA field approval nowadays.
My individual aircraft has an FAA field approval for Auto Fuel, with the 337 filed about 40 years ago. No other aircraft of the type has similar FAA fuel authorization. The owner at that time was a very senior engineer for a major auto manufacturer, and I can’t think of any other factor that would have led FAA to field approve it, even then. Which field office (FSDO) is involved and what people are doing the work does seem to matter.
Another arcane source of approved data is a 337 that was approved for another aircraft (based on any kind of approved data) prior to some date a very long time ago.
I appreciate your time to explain this to me in depth, Peter.
My goal is to understand if indeed there is a way for an instance involving a 337 form to be arranged WITHOUT engaging the FAA in any way, shape or form. I understand this is not possible.
So, starting out, we had this
wigglyamp wrote:
An EASA (or UK CAA) Part 145 with FAA authorisation can sign off all maintenance work and 337s without needing any involvement from FAA AP or IA.
It merely means an FAA approved European/or UK 145 shop can skip the FAA AP IA.
Then Savvy Aviation saying this
There are four principal sources of such approved data:- a supplementary type certificate (STC) obtained by the developer of the alteration and approved by the FAA;
- an airworthiness directive issued by the FAA;
- a field approval obtained by the aircraft owner and approved by the FAA;
- and data approved by a designated engi- neering representative (DER) hired by the aircraft owner.
A major alteration must also be inspected and approved by an IA, whose job it is to verify that the alteration was indeed made in accordance with the approved data. (Note that the IA does not have the authority to approve the data— such approval must come from an FAA employee or designee.)
Finally, a major alteration must be docu- mented on an FAA Form 337 signed of by the mechanic who performed the alteration and by the IA who inspected and approved it. (The two are often the same person.) The Form 337 must incorporate or identify the approved data used to make the alteration. If the approved data is not an STC or AD, then the form must also be signed by the FAA inspector or DER who approved the data.
[Snoopy’s understanding is the next sentence applies to all 337 instances?! →]Once all the necessary signatures have been obtained, the form must be sent within 48 hours to the FAA Aircraft Records Branch in Oklahoma City, where it becomes a part of the aircraft’s permanent file.
And then this
Peter wrote:
Only a Field Approval needs an FAA signoff.
making it sound like a field approval is the only instance requiring FAA involvement. I think I am incorrectly understanding what you mean by “sign off”. So let’s simplify it and just call it “any FAA involvement whatsoever” in regards to major alterations/repairs/STCs→ FORM337 activities."
Peter wrote:
Not unless it has FAA approval i.e. de facto is an FAA 145 shop. I actually didn’t know until just now these existed.
It is still an EASA 145 shop, but one accepted / approved under FAR 145 as well.
Next topic:
Basically, some APIAs never touch your plane. An EASA shop does the work and you pay the APIA for his „pencil power“ to get you your annual.
Peter wrote:
Not legal.
Any IA who does not physically inspect the plane (I mean turn up, all inspection covers left removed, and checks everything) is an idiot. I know this has happened but all it takes is for the plane to end up in the hands of an unhappy owner (e.g. post sale, or after a dispute with the shop) and the IA gets reported for a “mail order signature” and after 1-2 such complaints gets struck off by the FAA. I know of such personally. Then the guy is just an A&P (= a lot lower income). 1-2 more such complaints and no A&P either. EASA66 is much more “sticky”; one guy I know was doing this and got totally banned by the FAA but is still doing EASA66 work.
I have recently been involved with a couple of N-regs, and I can personally attest that this payment for pencil power really seems to happen. Given the atrocious shape some planes I’ve looked at are in, it seems that the competent authority being on another continent isn’t exactly fruitful.
Step 1: A “convenient” 145 shop correctly accomplishes the annual inspection.
Step 2: Owner needs FAA AP IA to sign off the work.
Step 3: FAA AP IA gets 1500-2000€ and completes the paperwork.
So here I am, looking at the aircraft after studying the paperwork, that is, legally on paper, all in order. And what I see in reality is ridiculous. E.g., elevator trim not working/stuck, can kill you easily. Or operational capabilities not reflecting aircraft documentation accurately. One aircraft supposedly has a MOGAS STC, however, the engine was changed (to one with more HP), which would require alterations of the fuel system / adding an additional fuelpump etc to conform to the STC. The airplane is powered exclusively by MOGAS (as is evident by the brown leak spots that have eaten the paint everywhere) without said modifications. Who in their right mind would, as a natural person (not LTD/LLC) sign of an annual inspection on an airplane that has the wrong fuel in its tanks at present, and has been used like that for some time before as well? Risk of fuel hoses degrading etc.? I cannot imagine such an airplane was waiting patiently, wasting shop floor real estate, with all inspection panels removed, for its undeserved annual sign off. It’s my understanding that the AP IA is accountable to verify AD / STC compliance, but maybe I’m wrong about this.
And so someone curious might think: “Hmmm, so there’s a 1500+ KM distance between the aircraft’s location and the AP IA’s address, let’s utter a shy request to at least see airline ticket/travel invoices. Maybe the AP IA was really there after all?” Guess how that would go down…
Yes, there are also plenty of respectable people out there who do things correctly. But pencil whipped annuals are a fact. Caveat emptor!
You’re welcome.
As I explained relatively few 337s are created by or signed off by anybody but an FAA A&P IA, because the work is much more often done based on existing approved data. Given that situation there is no FAA involvement other than filing the IA-signed 337 in the aircraft records, and yes, the IA needs to mail the signed 337 to FAA within 48 hrs of the work being completed.
Obviously an IA reviews AD compliance and inspects for TC compliance issues as part of every annual inspection.
Interesting that local mechanics in Europe would do poor work just because they aren’t signing it off. Also interesting to believe that an IA would send Annual sign off stickers through the mail without seeing the plane. I’ve never personally met an IA who would do anything remotely like that – being caught doing it would not be a happy thing. All this sounds a bit far fetched to me.
My goal is to understand if indeed there is a way for an instance involving a 337 form to be arranged WITHOUT engaging the FAA in any way, shape or form. I understand this is not possible.
A 337 has to be sent off to Oklahoma, for filing. There is no inspection of it. This part cannot be avoided, but it is just €1 for airmail 
The following Major Alteration methods avoid any FAA “inspection” or “approval”:
The only method which needs an FAA “approval” is a Field Approval and this is hard to get done in Europe because there are no FSDOs here that you can pop into. You need a contact in the US. I have done a number of these myself, via a contact e.g. this this and this. But very few people in Europe do these because they haven’t got the contacts. And if you are a shop then you simply tell your customers to ignore everything without an STC! That’s how Garmin came to own the universe. The more imaginative shops, for non STC mods, use the DER route and bill the cost to the client; I’ve seen DER prices from a few hundred $ (for signing a 1 page drawing prepared by the European shop) to $10k (for a complete set of wiring diagrams for an EHSI).
I have recently been involved with a couple of N-regs, and I can personally attest that this payment for pencil power really seems to happen.
Sure; there are idiots around. I wrote this above. They eventually get kicked off and go back to working in an EASA shop 
because they got EASA66 on the back of their A&P work experience, and with some written exams
Given the atrocious shape some planes I’ve looked at are in, it seems that the competent authority being on another continent isn’t exactly fruitful.
There is no “competent authority” in aviation. The system hangs together like any QA system hangs together:
But pencil whipped annuals are a fact.
There is/was an engine shop, EASA145, in central Europe, which did engine overhauls with this
Pretty well impossible to prove.
Welcome to GA
An IA is required to do an annual inspection. The typical sequence is the IA signs off the annual after the inspection and discrepancies/servicing is accomplished, but this is not necessary. The inspection process itself determines the discrepancies, it does not include the return to service after repairs and servicing. Once the annual inspection is complete, the IA signs off the inspection as either airworthy or unairworthy. In either case, the annual requirement is met. If the aircraft is signed off as unairworthy, the IA is required by regulation to provide the owner/operator with a discrepancy list and it is up to the owner to handle them. The list of discrepancies are not included in the logbooks, but they must be resolved by a competent person, usually an A&P. If the competent person performs maintenance, they must make a logbook entry for any maintenance to return the aircraft to service. Often more than half of the work accomplished during an annual is maintenance and servicing. Also, many shops and some IA have determined discrepancies that are not required by the FAA, for example performing service bulletins that are not an AD, replacing or overhauling engines, propellers, and parts based solely on time in service. I have had several annuals signed off as unairworthy and arranged for repairs on my own. In some this was due to disagreements with the IA as to what constituted an airworthiness discrepancy. This usually occurred when an annual was accomplished as part of a pre-purchase inspection where the seller wanted to use their own mechanic to resolve discrepancies. In one case, the IA at my shop was about to go on vacation for two weeks, so I had him sign off the annual after he completed the inspection as unairworthy and provide the owner with a list of discrepancies and then the other A&P in the shop could return the aircraft to service in his absence. One other case on my own Bonanza, occurred when I hired an out of town IA (4 hour one way drive) who I respected and some of the discrepancies were going to take a week for parts to arrive. It did not make sense to have him come back when the parts arrived (I had to pay for his travel expenses and hotel) when I could have a local A&P install them and return the aircraft to service.
Unfortunately almost no Europe based A&P or A&P/IA knows about the above
Getting briefly back to mods, you can see why N-regs based in Europe limit themselves almost totally to STC mods. Almost no shop knows about the DER route, practically zero can get a Field Approval done, the TC route is rarely available (it might be e.g. replacing a KLN94+KMD550 in a TB20 with 2×GNS430 which were on the original Socata TC, so maybe you could “install” those and “immediately” pull them out and install 2×IFD440), and that’s about it.
Mind you, non-STC EASA Major Mods are very expensive unless you know how to work the system.
Getting briefly back to mods, you can see why N-regs based in Europe limit themselves almost totally to STC mods. Almost no shop knows about the DER route, practically zero can get a Field Approval done, the TC route is rarely available
Presumably they would also utilize AC 41.13-2B Link as approved data? Extract from the cover letter:
This data generally pertains to minor alterations; however, the alteration data herein may be used as approved data for major alterations when the AC chapter, page, and paragraph are listed in block 8 of FAA form 337 when the user has determined that it is:
a. Appropriate to the product being altered,
b. Directly applicable to the alteration being made, and
c. Not contrary to manufacturer’s data
The restriction to note the chapter, page and paragraph on the 337 is important as it makes much clearer whether the data is directly applicable to the work, with little opportunity for sweeping statements of applicability. It is none the less a terrific resource because no FAA interaction or major mod. approval is required other than IA sign off and submission of the Form 337, just like an STC.
Hmmm – didn’t know you could do that.
