Can an A&P install the new Skybeacon in a certified airplane?

Can an A&P install the Skybeacon?

  • Yes

    Votes: 17 81.0%

  • No

    Votes: 4 19.0%
  • Total voters
    21
Jesse Saint said:
I have installed many dozen STC’s, and every single one has a filed 337. This includes batteries and Rosen Visors.
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The reason you did a 337 is simple, Rosen Visors are not an authorized replacement part. They have a STC that makes them usable.
 
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Bell206 said:
Curious. In your opinion, what portion of a Rosen visor install on a pre-1980 Cessna 172 falls under the definition of a major alteration per Part 1 and Part 43 Appendix A(a) requiring a 337?

Here is the data package:
http://www.rosenvisor.com/componentpdfs/RCS-300-1.pdf
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Modification of the type design is not required to meet 43-A's requirements.
Rosen visors do not alter the airframe, but they are not an authorized replacement part either.
So the STC makes them usable (legally)

Read the first sentence in the "condition and limitation" para of your link.
 
Tom-D said:
Modification of the type design is not required to meet 43-A's requirements.
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Interesting. But if 43-A is N/A, then how do you as an installer determine if the type design modification is a major or minor alteration to the aircraft?
Tom-D said:
Read the first sentence in the "condition and limitation" para of your link.
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If talking about the STC C and L section---I don’t see any mention it is a major alteration or require a 337.
Tom-D said:
but they are not an authorized replacement part either. So the STC makes them usable (legally)
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No and yes. All “legal” replacement parts are required to have a design approval and a production approval. An STC is simply one type of design approval so the visor is an “authorized” replacement via the AML:
“Design approval means a type certificate (including amended and supplemental type certificates) or the approved design under a PMA, TSO authorization, letter of TSO design approval, or other approved design” [21.1(b)(4)]

So, if we follow your track, and 43 App A(a) is not applicable to design changes, why don’t all FAA-PMA or TSO parts require a 337 since they are included as “design approvals” with STCs as listed above?
 
Bell206 said:
Interesting. But if 43-A is N/A, then how do you as an installer determine if the type design modification is a major or minor alteration to the aircraft?

If talking about the STC C and L section---I don’t see any mention it is a major alteration or require a 337.
There is no mention in this STC as to major or minot, But the L&C section does say it is a change to the type design.

No and yes. All “legal” replacement parts are required to have a design approval and a production approval. An STC is simply one type of design approval so the visor is an “authorized” replacement via the AML:
Exactly..
“Design approval means a type certificate (including amended and supplemental type certificates) or the approved design under a PMA, TSO authorization, letter of TSO design approval, or other approved design” [21.1(b)(4)]

So, if we follow your track, and 43 App A(a) is not applicable to design changes, why don’t all FAA-PMA or TSO parts require a 337 since they are included as “design approvals” with STCs as listed above?
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Simple, because the change to the design may not require any modification of the aircraft.
your Rosen visor STC proves that, there are no instructions for modifying the airframe, they simply bolt in. Thus they do not meet the requirement of 43-A which covers what modifications meet the requirements of a major alteration.
But to be clear to your question of why not all parts? many small parts that are subtitled are done so as a minor alteration and simply logged as that in the aircraft's maintenance records.
 
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thanks for proving my point.

1-1. Purpose of this Order. This order provides guidance applicable to the data approval process for major repairs and alterations including field approvals.

1-4. Scope.

a. This order defines the process for the approval of technical data for major repairs and major alterations. This order does not provide guidance for making decisions on major or minor changes in type design.

c. Minor alterations or repairs do not require FAA approved data and therefore must not receive field approval.

d. Repairs and alterations that have all the necessary approved data also do not require field approval.
 
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So...if it’s a minor...why does an STC exsist?

The PMA is there for replacement parts.
 
Tom-D said:
your Rosen visor STC proves that, there are no instructions for modifying the airframe, they simply bolt in. Thus they do not meet the requirement of 43-A which covers what modifications meet the requirements of a major alteration.
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Exactly. No major alteration, no 337 needed. Design changes are handled by Part 21 and alterations are handled by Part 43. Simple.:)
 
Checkout_my_Six said:
So...if it’s a minor...why does an STC exsist?
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It’s the other way around. Months/years before the part hits the market the vendor determines which design/production approval they will use to certify their parts/installation per Part 21. Once it hits the market and you buy it, then the installer figures out if it’s a major or minor alteration.
Checkout_my_Six said:
The PMA is there for replacement parts.
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A PMA is simply a combination design/production approval. Any Part 21 approval process can be used for replacement parts. An STC is a design approval only. You would need to get either a Production Certificate (PC), a TSO, or a PMA approval to produce a part design approved under an STC. Most vendors use a PMA. To confuse matters, some vendors use an AML-STC to approve the design process for a FAA-PMA part. Look at a Concorde applicability chart and you’ll find STCs, PMAs, and TSOs listed together. Who decides which one to use?
 
8110.4C gives guidance when to issue an STC. It needs to be a major change to issue.
 
Bell206 said:
Exactly. No major alteration, no 337 needed. Design changes are handled by Part 21 and alterations are handled by Part 43. Simple.:)
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So we have paper in the box for those who need it.
 
Checkout_my_Six said:
ADS-B out boxes need two 337s. One for the install and another for testing. An IA can submit and sign those.
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This is true if you need/want to do the verification via a test flight. If you have the required test equipment to verify system performance on the ground (as most avionics shops would), then you can do the return to service/system verification all on one 337.

C.
 
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