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
A

ahypnoz

Pre-takeoff checklist
Joined
Feb 22, 2015
Messages
137
Location
oklahoma city
Display Name
Display name:
ahypnoz
It is my understanding that an A&P can install, remove, and reinstall any instrument or piece of avionics. But only a properly FAA-certified instrument/radio repair station or FCC-licensed technician (as applicable) can go inside the box/instrument itself.
 
ADS-B out boxes need two 337s. One for the install and another for testing. An IA can submit and sign those.
 
ahypnoz said:
It is my understanding that an A&P can install, remove, and reinstall any instrument or piece of avionics.
Click to expand...
Yes. But some transponder work may require re-certification by a repair station.
ahypnoz said:
can go inside the box/instrument itself.
Click to expand...
Define "go inside." An A&P can not alter/repair certain instruments/avionics but there is no restriction in opening up the equipment.
 
From the memo.
"After initial approval, can applicable ADS-B OUT systems be installed on aircraft notcovered by that approval?

Yes, ADS-BOUT systems that have previously received FAA approval and meet all of the following conditions may be installed and returned to service on other aircraft without further data approval:"

and then

"Note: Some elements of an ADS-B OUT installation may not meet the definition of a minor alteration. such as the installation of antenna(s) that penetrate a pressure vessel. Such installation elements may require additional data from the aircraft manufacturer or other FAA approved data. Reference Attachment 1 of this memorandum, ADS-BOUTAlteration Flow chart or guidance on determining the eligibility of ADS-BOUT installations covered by this policy."

my opinion? it depends upon what you do to the aircraft. still following the FAR 43-A
 
Checkout_my_Six said:
I’m not seeing anywhere in that memo where the installation and pairing is not a major requiring the 337.

There is at least one 337 with this install...the flight test documents performance compliance.
Click to expand...

Have already installed at least 50 ADS-B systems on transport category aircraft for 135 and 135+ operators, not one of the STC approved EMI or GTP required a flight test. All tested can be done on the ground with standard (MRO) equipment.

Same goes for the one I installed in the 177 via field approval.

Flight testing was for GA rebate validation.
 
You question is incomplete. Yes, an A&P can install the Skybeacon but it still requires (as do all ADS-B out solutions) a 337, which requires an A&P with IA signature. Once installed and flown, you can retrieve a performance report (PAPR) from the FAA that will let you know if the system is functioning properly. The FAA recommends retrieving a report every month or two.
 
I thought if the aircraft was covered by the skyBeacon AML STC that you did not need to get a 337. Only if it was not one of the 272 aircraft listed on the AML that you would need to get a 337.
 
ahypnoz said:
I thought if the aircraft was covered by the skyBeacon AML STC that you did not need to get a 337. Only if it was not one of the 272 aircraft listed on the AML that you would need to get a 337.
Click to expand...
So...you’re saying an AML is a minor alteration and not an addition to the TC?...and no 337 is required...just a logbook entry?
 
ahypnoz said:
I thought if the aircraft was covered by the skyBeacon AML STC that you did not need to get a 337. Only if it was not one of the 272 aircraft listed on the AML that you would need to get a 337.
Click to expand...
You thought wrong :)
 
ahypnoz said:
It is my understanding that an A&P can install, remove, and reinstall any instrument or piece of avionics. But only a properly FAA-certified instrument/radio repair station or FCC-licensed technician (as applicable) can go inside the box/instrument itself.
Click to expand...

From the website:
https://uavionix.com/products/skybeacon/#faqs


Can I install skyBeacon as the owner of the aircraft?


Experimental Aircraft: Yes

Light Sport Aircraft: With manufacturer approval.

Certified Aircraft: You cannot install skyBeacon unless you have Inspection Authority for your aircraft. We recommend you contact an avionics installation facility or your regular Inspection Authorization (IA). Most IAs, aircraft maintenance facilities, and/or repair stations are also qualified to install skyBeacon. Please note that the installation must be tested to verify proper configuration and operation.
 
AC 43-6D.

Subject: Altitude Reporting Equipment and Transponder System Maintenance
and Inspection Practices
Advisory Circular
Date: 2/15/17 AC No: 43-6D Initiated by: AFS-300 Change:


INSTALLATION. Any appropriately rated person (as specified in § 43.3) may perform an aircraft alteration that consists of installing or reinstalling equipment (following maintenance). The equipment may consist of an encoding or non-encoding altimeter, air data system components, remote encoding devices (blind encoder), or transponders. ADS-B equipment includes an ADS-B transponder or UAT and the associated source system’s components to broadcast the aircraft’s identity, altitude, velocity, and other information. Only after the performance of the suitable functional check to determine that the altered system will perform its intended functions can an appropriately rated person grant approval of the aircraft for return to service. Additionally, if applicable, test and inspections requirements described in §§ 91.411 and 91.413 and part 43 appendices E and F must be satisfied.

Static Pressure System Test. Performance of this test on all instruments that rely on connected static air will ensure component leak integrity and that no leaks occurred while making connections to the encoding altimeter, blind encoder, or other instruments. This procedure is one method of demonstrating compliance with the requirements within
§ 91.411(a)(2). Section 91.411(b) lists the persons authorized to perform this test. While static systems contained within an article that the authorized person did not open or close during article installation do not require post installation testing in accordance with
§ 91.411(a)(2), the FAA recommends completion of the items in paragraphs 9.1.1 and 9.1.2.
 
Clip4 said:
AC 43-6D.
Click to expand...

This advisory circular (AC) provides information concerning acceptable methods of testing altimeters, static systems, altitude encoders, and air traffic control (ATC) transponder systems (ATCTS). This guidance also applies to the above articles, but does not include all requirements for testing the article, when part of 1090 megahertz (MHz) Extended Squitter (ES) or Universal Access Transceiver (UAT) Automatic Dependent Surveillance-Broadcast (ADS-B) systems. Like all advisory material, this AC is not in itself mandatory and does not constitute a regulation. It provides a means, but not the only means, of testing at the time of original installation, after performing repairs, or during scheduled recertification. Where indicated, this AC ensures compliance with regulatory requirements. Operators may elect to follow an alternative method that the Federal Aviation Administration (FAA) has found acceptable.

This AC only applies to the testing portion of the equipment.. has nothing to do with the installation or requirements for a 337
 
Any STC requires a 337. The 337 form is for any major repair or alteration. If there is no STC, then a 337 field approval is required. If there is an STC, then a 337 is required with no Faa approval beyond the STC. An A&P can install, but an IA must sign to return to service. This all applies to a certified plane.

There is an FAA letter that allows for a “follow on to an STC” for ADS-B systems in planes that are not on an AML.
 
Tom-D said:
This advisory circular (AC) provides information concerning acceptable methods of testing altimeters, static systems, altitude encoders, and air traffic control (ATC) transponder systems (ATCTS). This guidance also applies to the above articles, but does not include all requirements for testing the article, when part of 1090 megahertz (MHz) Extended Squitter (ES) or Universal Access Transceiver (UAT) Automatic Dependent Surveillance-Broadcast (ADS-B) systems. Like all advisory material, this AC is not in itself mandatory and does not constitute a regulation. It provides a means, but not the only means, of testing at the time of original installation, after performing repairs, or during scheduled recertification. Where indicated, this AC ensures compliance with regulatory requirements. Operators may elect to follow an alternative method that the Federal Aviation Administration (FAA) has found acceptable.

This AC only applies to the testing portion of the equipment.. has nothing to do with the installation or requirements for a 337
Click to expand...

The original question was can an AP install a sky beacon. This AC says they can.
 
Clip4 said:
This AC says they can.
Click to expand...
Show me where. ?

it actually says"
This advisory circular (AC) provides information concerning acceptable methods of testing altimeters, static systems, altitude encoders, and air traffic control (ATC) transponder systems (ATCTS).
 
Tom-D said:
Show me where. ?

it actually says"
This advisory circular (AC) provides information concerning acceptable methods of testing altimeters, static systems, altitude encoders, and air traffic control (ATC) transponder systems (ATCTS).
Click to expand...

INSTALLATION. Any appropriately rated person (as specified in § 43.3) may perform an aircraft alteration that consists of installing or reinstalling equipment (following maintenance). The equipment may consist of an encoding or non-encoding altimeter, air data system components, remote encoding devices (blind encoder), or transponders. ADS-B equipment includes an ADS-B transponder or UAT and the associated source system’s components to broadcast the aircraft’s identity, altitude, velocity, and other information. Only after the performance of the suitable functional check to determine that the altered system will perform its intended functions can an appropriately rated person grant approval of the aircraft for return to service. Additionally, if applicable, test and inspections requirements described in §§ 91.411 and 91.413 and part 43 appendices E and F must be satisfied.
 
Clip4 said:
INSTALLATION. Any appropriately rated person (as specified in § 43.3) may perform an aircraft alteration that consists of installing or reinstalling equipment (following maintenance). The equipment may consist of an encoding or non-encoding altimeter, air data system components, remote encoding devices (blind encoder), or transponders. ADS-B equipment includes an ADS-B transponder or UAT and the associated source system’s components to broadcast the aircraft’s identity, altitude, velocity, and other information. Only after the performance of the suitable functional check to determine that the altered system will perform its intended functions can an appropriately rated person grant approval of the aircraft for return to service. Additionally, if applicable, test and inspections requirements described in §§ 91.411 and 91.413 and part 43 appendices E and F must be satisfied.
Click to expand...
43.3 Persons authorized to perform maintenance, preventive maintenance, rebuilding, and alterations.
(a) Except as provided in this section and §43.17, no person may maintain, rebuild, alter, or perform preventive maintenance on an aircraft, airframe, aircraft engine, propeller, appliance, or component part to which this part applies. Those items, the performance of which is a major alteration, a major repair, or preventive maintenance, are listed in appendix A.

Who decides what is a major repair?
Again, see what I posted in Post #6.
 
I don't think any holes have to be drilled if you have standard wingtip lights. The Skybeacon mounts on the same mounting plate using the nutplates already in place. Modifications are only necessary if the beacon will not fit due to your wingtip design, but they tried to design it so many wings will need no modification.
 
Checkout_my_Six said:
I’m not seeing anywhere in that memo where the installation and pairing is not a major
Click to expand...
As quoted:
"Yes, ADS-B OUT systems that have previously received FAA approval and meet all of the following conditions may be installed and returned to service on other aircraft without further data approval."
 
Jesse Saint said:
Any STC requires a 337.
Click to expand...
Not quite. An STC is simply a design approval given under Part 21. What triggers a 337 is how the STC alters the aircraft which is determined by the installer under Part 43. If a major then 337 needed. If a minor then no 337 needed.
 
This is from the Garmin GTX 335 with GPS installation manual.

Install the panel mount GTX 335 with GPS as a minor alteration in accordance with FAA Memorandum
Installation Approval for ADS-B OUT Systems or FAA Notice 8900.362 Policy for Installation of
ADS-B OUT Systems using the data in this installation guidance manual. Installation in accordance with
the FAA Policy Memo only pertains to the GTX 335 with GPS and limited interfaces contained herein.
 
Considering that the Installation involves using the existing 3 screw holes, no new holes and then the A&P attaches the two wires.

So if you plane is on the AML you can use the STC (SA04362CH)

“From the FAA approved flight manuel supplement for the Uavionix SkyBeacon as installed in the make (your make) and model number (your model) per the AML. This supplement must be attached to the FAA approved airplane flight manual when the SkyBeacon is installed in accordance with Approved Model List (AML) supplemental type certificate SA04362CH”

On Page 11 section 6 of the STC:

Performance “No Change”

Weight and Balance “No Change” (100 grams)

I still think that this seems like this would be a minor alteration and an A&P can install it.

I guess the second part of the question is is do you need an AI to sign off to return to service or can any appropriately rated person (as specified in § 43.3) return the aircraft to service?
 
A
Bell206 said:
Not quite. An STC is simply a design approval given under Part 21. What triggers a 337 is how the STC alters the aircraft which is determined by the installer under Part 43. If a major then 337 needed. If a minor then no 337 needed.
Click to expand...
An STC is major. That requires a 337 form. A minor alteration would not require an STC, just a TSO or PMA.

“The most common source of approved data for performing major alterations is a supplemental type certificate (STC).“ Mike Busch

“If the alteration is minor, the approval can be done by any licensed A&P mechanic. However, if the alteration is deemed to be major, it requires a mechanic with an Inspection Authorization (IA), in order to sign the approval block on the 337 form and submit it to the FAA. Any STC is, by definition, a major alteration and also requires a 337 form.” AOPA
 
ahypnoz said:
Considering that the Installation involves using the existing 3 screw holes, no new holes and then the A&P attaches the two wires.

So if you plane is on the AML you can use the STC (SA04362CH)

“From the FAA approved flight manuel supplement for the Uavionix SkyBeacon as installed in the make (your make) and model number (your model) per the AML. This supplement must be attached to the FAA approved airplane flight manual when the SkyBeacon is installed in accordance with Approved Model List (AML) supplemental type certificate SA04362CH”

On Page 11 section 6 of the STC:

Performance “No Change”

Weight and Balance “No Change” (100 grams)

I still think that this seems like this would be a minor alteration and an A&P can install it.

I guess the second part of the question is is do you need an AI to sign off to return to service or can any appropriately rated person (as specified in § 43.3) return the aircraft to service?
Click to expand...
Let us assume that your aircraft is on the Sky beacon AML. Plus it fits in place with no modification of your A/C.
With that in mind the application of a STC (SA04362CH) still needs a 337 to apply it to the aircraft.
Thus, the A&P-IA must inspect the installation and return it to service by signing block 7 of the 337.
SO.... as asked in post one the simple answer is, NO because the application requires a 337
 
Technically the question of the OP is whether an A&P can install. The answer is yes. However, an IA is required to inspect and return to service.
 
Jesse Saint said:
Technically the question of the OP is whether an A&P can install. The answer is yes. However, an IA is required to inspect and return to service.
Click to expand...
I think we are picking a nit.. Cya

actually any one can install, under the supervision of :)
 
Tom-D said:
You say "Installing this isn’t no means a major alteration."
and then say, "field approval is one option". Field approvals are for major alterations too, they are to gain approval for data that isn't already.
Click to expand...

??????????? Field approvals are for minor changes too. They are for approvals for many different types of changes. For ex I can install an asp4a which isn’t certified in model x for autopilot altitude preselect and get field approval since it’s not covered under an STC. This is not major, requires no 337, and field approval is fine.
 
Jesse Saint said:
An STC is major.
Click to expand...
FYI: major/minor alterations are determined by the installer under Part 43, not by the part producer under Part 21. The FARs are quite clear on this topic. So as an A&P if you determine every STC is a major that is your prerogative under 43. But that determination is not supported by FAA guidance. There are various references on this. Here’s one:
https://www.faa.gov/about/office_org/headquarters_offices/agc/practice_areas/regulations/interpretations/data/interps/2016/bowers - (2016) legal interpretation.pdf

The high points:
“… altering an aircraft in accordance with certain STCs would require completion of FAA Form 337.”

“Therefore, an alteration done in accordance with a STC would constitute a major alteration if it "might appreciably affect weight, balance, structural strength, performance, powerplant operation, flight characteristics, or other qualities affecting airwmihiness" or "is not done according to accepted practices or cannot be done by elementary operations." 14 C.F.R. § 1.1. Any such alteration would require the completion of FAA Form 337.”

The key words are “certain,” “if,” and “any such.” If your definition was correct then these words would be replaced by “all” plus STC would be listed in Part 43 Appendix (A) under Major Alterations.

There are actually several versions of STCs that are used for different purposes which follow different rules. Not all STCs are equal in that respect. For example, a standard STC is different from an STC-AML.
 
Last edited:
GLMS_NC said:
This is not major, requires no 337, and field approval is fine.
Click to expand...
Curious. So where would the FSDO ASI physically sign-off on your “field-approval” without a 337?
 
Bell206 said:
FYI: major/minor alterations are determined by the installer under Part 43, not by the part producer under Part 21. The FARs are quite clear on this topic. So as an A&P if you determine every STC is a major that is your prerogative under 43. But that determination is not supported by FAA guidance. There are various references on this. Here’s one:
https://www.faa.gov/about/office_org/headquarters_offices/agc/practice_areas/regulations/interpretations/data/interps/2016/bowers - (2016) legal interpretation.pdf

The high points:
“… altering an aircraft in accordance with certain STCs would require completion of FAA Form 337.”

“Therefore, an alteration done in accordance with a STC would constitute a major alteration if it "might appreciably affect weight, balance, structural strength, performance, powerplant operation, flight characteristics, or other qualities affecting airwmihiness" or "is not done according to accepted practices or cannot be done by elementary operations." 14 C.F.R. § 1.1. Any such alteration would require the completion of FAA Form 337.”

The key words are “certain,” “if,” and “any such.” If your definition was correct then these words would be replaced by “all” plus STC would be listed in Part 43 Appendix (A) under Major Alterations.

There are actually several versions of STCs that are used for different purposes which follow different rules. Not all STCs are equal in that respect. For example, a standard STC is different from an STC-AML.
Click to expand...
So...which “certain” STC does not require a 337?
 
Checkout_my_Six said:
So...which “certain” STC does not require a 337?
Click to expand...
It's mostly items approved under a AML-STC where the STC data is used as design approval for a part like a PMA but can be other types of STCs also. For example, certain aircraft battery installs or certain accessories like certain Rosen Shades have STCs attached but their installs do not meet the requirements of a major alteration. However, no 337 still requires compliance with 91.403(d) which leads some vendors to include the STC doc free or charge a small fee for it.
 
I have installed many dozen STC’s, and every single one has a filed 337. This includes batteries and Rosen Visors.
 
You must log in or register to reply here.
Back
Top