Piper Arrow (PA-28r 201) Type Certificate

[tmccaghren17]

Hey guys, Im preparing for a Checkride here soon and was looking over all the info over the plane again. I went looking for the Type day Certificate because i know that an inoperative equipment question will be asked. Basically I was reading over it and could really decipher it. What I got out of it was there is nothing really special with the type certificate and just to follow 91.205, Kinds of Op, and ADs. Any of you guys agree, or am I wrong?

 

[mshunter]

Don't forget about 91.213(start there, not at .205 because .213 refers you to .205), and look over AC91-67(I think that's the one).

 

[n57flyguy]

I would agree, I am learning there are many aspects of airworthiness that are often looked over. Mshunter is correct, start with 91.213, then go on to 91.205. You probably won't find an MEL, if that is what you are looking for. Here is 91.67, which does a good job pointing you in the direction of what you need to know (91.405, Parts 43, 91.213):

http://rgl.faa.gov/Regulatory_and_G...yCircular.nsf/list/AC 91-67/$FILE/Chap1-2.pdf

 

[MidlifeFlyer]

Third vote for 91.213 as the place to start. Chances are to MEL but that just means you start with 91.213(d).

 

[thevideographer]

Lets say you go look at the plane and it has a 3 bladed Sensenich prop on it, but the type certificate lists a 2 bladed Hartzell. Unless the owner has an STC or a lot of paperwork, that airplane is unairworthy. I know it's far fetched, but that's why you have to refer to the type certificate.

 

[RedBaron2000]

Lets say you go look at the plane and it has a 3 bladed Sensenich prop on it, but the type certificate lists a 2 bladed Hartzell. Unless the owner has an STC or a lot of paperwork, that airplane is unairworthy. I know it's far fetched, but that's why you have to refer to the type certificate.

...which is why it's called a Supplemental Type Certificate. It's not far fetched at all, and not all that complicated. There is the original TC, and then if you want to install something else you need to have a supplemental TC. It's really all the same thing.

 

[n57flyguy]

Lets say you go look at the plane and it has a 3 bladed Sensenich prop on it, but the type certificate lists a 2 bladed Hartzell. Unless the owner has an STC or a lot of paperwork, that airplane is unairworthy. I know it's far fetched, but that's why you have to refer to the type certificate.

An STC or an STC, not 'a lot' of paper work. Good point though on checking up that the required paper work/endorsements (?) for STC's is identified. I am not well versed on that area, I will research that more.

 

[thevideographer]

I said an STC or a lot of paperwork.​

 

[n57flyguy]

I said an STC or a lot of paperwork.​

Aware, what I want to know is what "a lot of paper work" means. Seems to vauge and indefinite,, and I'm almost sure its not just an 8130. Does any FAR mention "Make sure there is a lot of paper work?" What does it show compliance with? Why is applicable?

 

[thevideographer]

Adding a 3 bladed prop that isn't listed in the original type design or a supplemental type certificate requires more than an 8130 form. I can't for the life of me find the faa guidelines on how to get a modification approved, but it isn't easy.

 

[MidlifeFlyer]

Adding a 3 bladed prop that isn't listed in the original type design or a supplemental type certificate requires more than an 8130 form. I can't for the life of me find the faa guidelines on how to get a modification approved, but it isn't easy.

Are you perhaps referring to field approval (Form 337)? AC 43-210 (one of, I think, 4 ACs that deal with the subject) discusses the process. Yep, by any definition I would think field approval of a propeller that is not already STC'd would involve "a lot of paperwork" and you create design specs and prove the resulting installation will be airworthy and and not affect other systems. OTHO, if it's a well-known design with STCs for other aircraft, much of the paperwork has already been done.

 

[rframe]

An existing STC is very little paperwork. You basically buy the rights to use the STC, do the work, write the work up in the logs, and submit the 337 stating the change was made. There is no approval, as the STC is already approved.

Field approvals used to be the way to get simple one-off things done. You'd write up the proposal, if it seemed common sense you got it approved, often by simply showing that other people has made the same change by providing copies of their 337's. Now days, field approvals are frowned upon and in some areas they seem almost impossible to get.

The Feds want all sorts of engineering data, where each data item can seem to be of arbitrarily assigned value by the individual processing it, for even the simplest of changes that make many things simply impractical. Consider something as simple as changing an incandescent bulb for an LED bulb...you'll face a pile of work and possibly months of approval back and forth work, if there's not an existing STC.

Also there are two types of STC's... a one time (a much more involved process, but with similar end results, to the the field approval), where you provide sufficient engineering data to satisfy the individual and a reproducible STC which is almost like an FAA patent for a modification which you can sell the rights of use to.

If there is an existing STC that is somewhat similar to what you want to do, then they'll tell you to just go use that and will deny you at the outset.

 

[Roger Roger]

Consider something as simple as changing an incandescent bulb for an LED bulb...you'll face a pile of work and possibly months of approval back and forth work, if there's not an existing STC.

You should not. According to the FAA's own regulations a change of type of bulb is not a major alteration and can therefore be done in accordance with AC43.13 with just a logbook entry. That's not the way a lot of people seem to treat it.

 

[rframe]

You should not. According to the FAA's own regulations a change of type of bulb is not a major alteration and can therefore be done in accordance with AC43.13 with just a logbook entry. That's not the way a lot of people seem to treat it.

Are you referring to AC 20-62E, where it talks about discrete electronic components?

​

Electrical and electronic parts, such as resistors, capacitors, diodes, and transistors, if not specifically marked by the equipment manufacturer’s part number or marking scheme, may be substituted or used as replacement parts,​

provided that such parts are tested or it is determined that they meet their published performance specifications and do not adversely affect the performance of the equipment or article into or onto which they are installed. The performance of such equipment or article must be equal to its original or properly altered or repaired condition.​

​

If so, I'd agree... but many people dont (maybe they like making more work for themselves?), and I've seen the LED light issue before and people have tried to get a field approval or one time STC and it's a damn mess.

By the way there's a Cessna rheostat that costs $1,500 that you can buy for $30 and this AC is the lifesaver!

 

[Roger Roger]

Are you referring to AC 20-62E, where it talks about discrete electronic components?

Electrical and electronic parts, such as resistors, capacitors, diodes, and transistors, if not specifically marked by the equipment manufacturer’s part number or marking scheme, may be substituted or used as replacement parts,​

provided that such parts are tested or it is determined that they meet their published performance specifications and do not adversely affect the performance of the equipment or article into or onto which they are installed. The performance of such equipment or article must be equal to its original or properly altered or repaired condition.​

​

If so, I'd agree... but many people dont (maybe they like making more work for themselves?), and I've seen the LED light issue before and people have tried to get a field approval or one time STC and it's a damn mess.

By the way there's a Cessna rheostat that costs $1,500 that you can buy for $30 and this AC is the lifesaver!

That's not what I'm referring to, though that AC is a great one. It comes from 14 CFR 43 Appendix A, where it enumerates what is considered a major alteration. Nowhere on that list is "replacing a light with a different type". Unless you consider that a "change to the basic design of the electrical system" which from everything I've gotten talking to MX inspectors it is not. So, since the bulb swap is not a major alteration, it does not require a 337, and therefore does not require Approved Data (such as an STC). As long as the wiring meets AC43.13 standards for the current draw of the bulb and the circuit breaker is sized appropriately to protect the wire, and there are no modifications to primary structure made to accomodate the bulb, you're good to go with a logbook entry. What sometimes gets people in trouble is stuff like nav lights. A nav light, to be a legal for night flying nav light, has to have certain brightnesses through certain viewing angles and so to be legal for night flight you'd have to prove that your installation met that criteria, and by far the easiest way to do that is to use a certificated assembly, which often comes with an STC even though it may not be a major alteration. But for something like an indicator light? No big deal.

Edit to add: while the above is my (And therefore the correct) interpretation based on a literal reading of the regulations, and in line with what my local FSDO mx folks have told me, we all know how consistent interpretations of even simple rules can be from FSDO to FSDO so before anyone takes this as gospel and dumps a bunch of money into non-STC parts from Spruce, check with your A&P/IA/FSDO as applicable. Also worth remembering are some words that a FSDO inspector would never admit to having said, but that are nonetheless true: "Y'know how often we look at logbooks of a 91 plane? Whenever someone balls it up."

Another edit:
The use of the 337 form and what is and is not a major alteration or repair is one of the most misunderstood concepts in the maintenance world, on par with 91.205 vs. 91.213 for required equipment in the ops world. Lots of guys, even IAs, will file 337s for stuff that's not a major alteration ( like, for example, changing radios or installing an intercom) while simply making logbook entries for stuff that should be major (put a doubler on an aileron spar? Replace a rudder skin? Major!). Even when guys do get this right, referencing the proper data can be another trip-up, to the point of triggering a visit from the local FSDO when they see a a 337 come across their desk (which they do, at least if you're working on 135 birds) that they don't like.

trafficinsight might be a good one to weigh in on this as well as he has significantly more IA experience than I do, and might be able to offer another FSDO's view of things.

 

[n57flyguy]

Excellent write up RR, thanks.

 

[mshunter]

The use of the 337 form and what is and is not a major alteration or repair is one of the most misunderstood concepts in the maintenance world,

I would disagree with that. IMO, it's more of a CYA measure, because of how inconsistent the damn FAA is from one FSDO to another.

 

[MidlifeFlyer]

I would disagree with that. IMO, it's more of a CYA measure, because of how inconsistent the damn FAA is from one FSDO to another.

My favorite example of a useless 337 CYA is a set of replacement sun visors for Piper Comanches. Complete and clean replacement - even use the existing mounting hardware. It was "invented" by an optometrist for his own use and he took the step of getting field approval.

He sells them. Sort of. For $10 he sells is a copy of the plans and the 337 paperwork for the owner-manufactured part. For an additional $197 deposit, he also sends you a completed set to use as a "sample" for making your own. If you sent back the "sample" within 15 days, you get your $197 back.

Obviously a CYA for the good doctor to avoid accusations that he's selling uncertified aircraft parts. I've always wondered whether anyone has ever sent the "sample" back or submitted the 337 paperwork.

 

[rframe]

My favorite example of a useless 337 CYA is a set of replacement sun visors for Piper Comanches. Complete and clean replacement - even use the existing mounting hardware. It was "invented" by an optometrist for his own use and he took the step of getting field approval.

He sells them. Sort of. For $10 he sells is a copy of the plans and the 337 paperwork for the owner-manufactured part. For an additional $197 deposit, he also sends you a completed set to use as a "sample" for making your own. If you sent back the "sample" within 15 days, you get your $197 back.

Obviously a CYA for the good doctor to avoid accusations that he's selling certified aircraft parts. I've always wondered whether anyone has ever sent the "sample" back

I personally know someone who was denied a checkride and had a maintenance follow up by the FAA because he had unapproved sun visors installed without an STC/approval.

 

[MidlifeFlyer]

I personally know someone who was denied a checkride and had a maintenance follow up by the FAA because he had unapproved sun visors installed without an STC/approval.

Not a bit surprised. Good example of inconsistent understanding and enforcement of maintenance stuff can be.

Good esample is that incandescent/LED replacement discussed earlier. Does that replacement fall into Appendix A light bulb and wiring categories for preventive maintenance (if you can replace the bulb and you can fix the wiring, why can't you also replace the fixture that connects the wiring to the bulb)?

Even the Chief Counsel, which is generally pretty conservative in it's reading of the regs is a bit looser on this one:

==============================
Many preventive maintenance tasks are listed in 14 C.F.R. part 43, appendix A, paragraph (c). The paragraph sets forth in 32 numbered subparagraphs items the FAA has determined to be preventive maintenance. Even though the introductory text of subparagraph (c) states that "[p]reventive maintenance is limited to the following work .... " (emphasis added), in view of the broader definition of preventive maintenance in section 1.1, we believe that such limitation is not controlling. *** As with the other paragraphs of Appendix A (i.e., on major repairs and major alterations), the lists are better viewed as examples of the tasks in each category-they cannot be considered all inclusive. There are, no doubt, many "simple or minor preservation operations [tasks]" and many "replacement of small standard parts not involving complex assembly operations" performed daily, especially on small general aviation aircraft, that the agency would consider to be preventive maintenance, though they are not included in the 32 listed items.
==============================

But you never know how Inspector Twelve from the FAA will react to a given repair/replacement.