You could install your Radio yourself, if you like to. You just need a Part66 CFS to sign the release / supervise your work.
You could’ve done the same with tve G5 if you wish.
You just need a Part66 CFS to sign the release / supervise your work.
You could’ve done the same with tve G5 if you wish.
Does that cover ELA2 also (up to 2000kg)?
Aviation is such a strange business. Not only does the equipment have to be certified with the FAA, then you have to have another level, an STC, for your particular airframe! In no other business except perhaps the medical business, are you so monopolized and over a barrell.
Peter wrote:
Does that cover ELA2 also (up to 2000kg)?
1. The modification, repair or replacement by riveting, bonding, laminating, or welding of any of the following airframe parts:
(a) a box beam;
(b) a wing stringer or chord member;
(c) a spar;
(d) a spar flange;
(e) a member of a truss-type beam;
(f) the web of a beam;
(g) a keel or chine member of a flying boat hull or a float;
(h) a corrugated sheet compression member in a wing or tail surface;
(i) a wing main rib;
(j) a wing or tail surface brace strut;
(k) an engine mount;
(l) a fuselage longeron or frame;
(m) a member of a side truss, horizontal truss or bulkhead;
(n) a seat support brace or bracket;
(o) a seat rail replacement;
(p) a landing gear strut or brace strut;
(q) an axle;
(r) a wheel; and
(s) a ski or ski pedestal, excluding the replacement of a low-friction coating.
2. The modification or repair of any of the following parts:
(a) aircraft skin, or the skin of an aircraft float, if the work requires the use of a support, jig or fixture;
(b) aircraft skin that is subject to pressurization loads, if the damage to the skin measures more than 15 cm (6 inches) in any direction;
(c) a load-bearing part of a control system, including a control column, pedal, shaft, quadrant, bell crank, torque tube, control horn and forged or cast bracket, but excluding
(i) the swaging of a repair splice or cable fitting, and
(ii) the replacement of a push-pull tube end fitting that is attached by riveting; and
(d) any other structure, not listed in (1), that a manufacturer has identified as primary structure in its maintenance manual, structural repair manual or instructions for continuing airworthiness.
3. The performance of the following maintenance on a piston engine:
(a) dismantling and subsequent reassembling of a piston engine other than (i) to obtain access to the piston/cylinder assemblies; or (ii) to remove the rear accessory cover to inspect and/or replace oil pump assemblies, where such work does not involve the removal and re-fitment of internal gears;
(b) dismantling and subsequent reassembling of reduction gears;
(c) welding and brazing of joints, other than minor weld repairs to exhaust units carried out by a suitably approved or authorised welder but excluding component replacement;
(d) the disturbing of individual parts of units which are supplied as bench tested units, except for the replacement or adjustment of items normally replaceable or adjustable in service.
4. The balancing of a propeller, except:
(a) for the certification of static balancing where required by the maintenance manual;
(b) dynamic balancing on installed propellers using electronic balancing equipment where permitted by the maintenance manual or other approved airworthiness data;
5. Any additional task that requires:
(a) specialized tooling, equipment or facilities; or
(b) significant coordination procedures because of the extensive duration of the tasks and the involvement of several persons.
I don’t think installing a G5 require any of those tasks.
So you don’t need a maintenance organization.
With the expected Part-M light adoption later this year, independent certifying staff will be able to release any tasks within it’s Part 66 licence privilege.
AdamFrisch wrote:
Aviation is such a strange business. Not only does the equipment have to be certified with the FAA, then you have to have another level, an STC, for your particular airframe!
The installation has to be based on approved data, including existing FAA publications etc, unless it is a minor modification in which case it requires only a mechanic’s logbook entry. An STC is only one kind of approved data, and many installations are actually minor mods, but companies like Garmin (and they in particular) commercially manipulate their customers into ‘manditorily’ using an STC that they often provide only for dealer use. The restriction to dealer use and the restriction on not using other types of approved data for installation is not the intent of the FAA process. Very little in my plane has been installed using an STC because the model is not generally covered. With just a few exceptions everything has been done via a field approval.
When replacing a radio with another that draws the same current etc, and installs without structural changes, per FAA requirements it is a minor modification requiring nothing but an A&P logbook entry. You will find a lot of shops who deny that and file a 337 and approved data anyway. I think this has become kind of a disease, encouraged by the likes of Garmin… 
It doesn’t help when FAA itself issues special guidance on installing an ADS-B OUT system (specifically) that describes the installation as a minor modification in most cases… and then requires IA signoff and filing a 337 anyway!
I think the 337 stuff is often done “backwards”.
A mod is either Minor or Major.
If Major then a 337 is only a part of the job. One thread is here. Merely writing out a 337 form is not the correct process. The 337 is the endpoint of a Major Alteration process, and apart from the DER8110 route (or an STC, or a rarely done TC-based route) it cannot be done without FSDO approval.
I’ve seen jobs where a company looked at something, frowned, and said “we will need to write out a 337 for that” and they did so, and usually (not always ) filed a copy to the FAA. Such a 337 is basically worthless unless it details the process.
That’s unless a mod done IAW the AC-whatever standard repairs manual can be regarded as Major and yet disposed of by saying it was done IAW ACxxx-xxx on a 337… is that possible? I thought all such work (usually airframe work) was Minor.
using an STC that they often provide only for dealer use
This is often said but on inspection of the STC turns out to not be true. It would probably be illegal in the EU, if not in the US also. Are Garmin STCs dealer-restricted?
Peter wrote:
That’s unless a mod done IAW the AC-whatever standard repairs manual can be regarded as Major and yet disposed of by saying it was done IAW ACxxx-xxx on a 337… is that possible? I thought all such work (usually airframe work) was Minor.
AC 43.13, where applicable, is as much approved data as an STC (or DER report) and therefore equally valid as the technical basis for a 337.
My aircraft has also for example had 337s written and approved based on combinations of approved data not all in one document… for example a CS propeller approved by LBA for the airframe (not FAA by the way), using hydraulic control but not electric control, fitted to an N-registered aircraft with electric control that is STC’d for different planes by FAA. For a Field Approval what really matters is that one FSDO official likes the argument put forth for the data presented…
Peter wrote:
Are Garmin STCs dealer-restricted?
Yes, that is my understanding of Garmin policy for much of their product line. For some products they make an ‘exception’ to ‘allow’ A&P installation.
There was another thread on this one but I can’t find it so I will post it here. It is to do with the age of King autopilots.
Looking at the installation / maintenance manuals (I have a big collection) I see this
KFC300 1979 Pilot guide
KAP200 1984 Pilot guide
KFC200 1984
KFC250 1990 Pilot guide
KAP100 1990 IM
KAP150 1990
KFC150 1990 IM
KAP140 1998 Line IM IM
KFC225 2001 IM/MM
After about 2003 just about everybody with any competence left Honeywell / Bendix / King (HBK).
I wonder if it’s a coincidence that Garmin ended up in Olathe, KS – where Bendix-King already was….
