Missing 337s - When Opinions Collide

RotorAndWing said:
:rolleyes2:
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Okay, roll your eyes at the IG report I noted. Or the NTSB report mentioned. Or Bob Hoover. Many others like these that never make it to an NTSB judge.

Again, the FAA is like the IRS. The best possible outcome for a pilot dealing with them is... nothing. Worst case? Not so hot. Anyone who goes into a FSDO thinking they are there to help them is naive.
 
Blackhawk said:
Okay, roll your eyes at the IG report I noted. Or the NTSB report mentioned. Or Bob Hoover. Many others like these that never make it to an NTSB judge.

Again, the FAA is like the IRS. The best possible outcome for a pilot dealing with them is... nothing. Worst case? Not so hot. Anyone who goes into a FSDO thinking they are there to help them is naive.
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weirdjim said:
I cited chapter and verse of the regs, part 43/A. Cite your reference for the difference between an STC and the work necessary to accomplish it.
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14 CFR Part 43, sections 43.5 and 43.9.
THe STC itself gives the installation instructions, and if followed, the approval has already been done. Minor modification.
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Approval of the data and approval of the completed work are two different issues. Read the regs, including 14 CFR 43.13.

Ya know, Levy, I don't see IA after your name, nor even A&P. When you get them, then come back and tell us all about it.
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I don't need either to know what the rules are. But if you don't accept my word for it, ask any licensed mechanic, or any FAA Airworthiness Inspector, and I'm sure you'll get the same answer. Most importantly, if you ask the FAA Chief Counsel, I'm sure they'll tell you the same, and while none of them hold mechanic certificates, they are the ones who get to decide what the regulations mean.
 
bnt83 said:
I challenged everyone to find the FAA definition of modification.
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They don't use that term. The term in question is "alteration", not "modification". While I cannot find a specific definition of "alteration" in the FAR's, Appendix A to 14 CFR Part 43 does tell us what constitutes a "major alteration", and that's what we're discussing here.

Note to weirdjim: The existence or absence of previously approved data is not a part of the Part 43 definition of what constitutes a major alteration, only how you go about the approval and documentation process. See 43.5, 43.9, and 43.13 for details.
 
I was talking to some Roswell based pilots. They said most FSDO personnel have been replaced by alien mimics. They are using every means to ground pilots and aircraft to avoid having their ships discovered from the air. Comments on this thread seem to confirm this is the truth. :hairraise:
 
weirdjim said:
We blew our wad this year sending her to France to take a graduate course in 15th century French cathedral organs.
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That sounds like a quote from a bad movie. :lol:

At first I thought you were BSing me, but then I did this search: https://www.google.com/?gws_rd=ssl#q=15th+century+french+cathedral+organs

Amazingly, there are quite a few of them. Who knew?

So, let me get this straight -- a multi-thousand dollar trip to France for her is equivalent to a week of camping in the North 40 for you? Methinks you're getting the short end of this deal, Jim! :yikes:
 
Blackhawk said:
Wait... so Bob Hoover did not happen? This did not happen? Or do the Pilot Counsel folks at AOPA wear tin hats?
http://www.aopa.org/News-and-Video/All-News/1994/May/1/Pilot-Counsel-(4).aspx

Or this? Are you saying the DOT IG people wear tin hats?

http://books.google.com/books?id=zX...kansas city fsdo cited in ntsb report&f=false
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And according to you, someone gets out of line then the whole should be damned. So accordingly the hundreds upon hundreds that give satisfactory service should be admonished by the actions of a few?

Ever hear of a dishonest cop? Ever hear of a dishonest lawyer? Ever hear of a dishonest judge? Ever hear of a dishonest (......)............

Go back to living in fear in your cave, you'll be safe there. :rolleyes:
 
RotorAndWing said:
And according to you, someone gets out of line then the whole should be damned. So accordingly the hundreds upon hundreds that give satisfactory service should be admonished by the actions of a few?

Ever hear of a dishonest cop? Ever hear of a dishonest lawyer? Ever hear of a dishonest judge? Ever hear of a dishonest (......)............

Go back to living in fear in your cave, you'll be safe there. :rolleyes:
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Yes I've heard of dishonest lawyers and cops. The problem with people at the Federal Level who get out of line is that they are very hard and expensive to fight. It matters little to them if they spend hundreds or thousands of hours on a minor case that will cost you dearly. Look at the current, ongoing fiasco with the IRS where we are now learning that they "lost" their emails when their hard drive "crashed".
In my instance- doing a right hand pattern with a sick pax at a non-towered airport with no other traffic- even with AOPA legal I spent over $1000 just getting to the point where we would see a judge. From that point forward it would all be out of my pocket and even if we did not go all the way to an NTSB judge we were talking thousands of dollars. The FAA lawyer knew it too and used many nice tactics to delay and run up my bill. Lawyers are not cheap- north of $400/hour in NY.
Oh, and that 15 day suspension that I paid my lawyer to reduce it down to? Yeah, well the FAA kind of "lost" my certificate and could not find it for 45 days... the original suspension they proposed. Ooops. So sorry. That extra month of no work? Oh well.
So spare me the crap about the FAA being there to help. I will reiterate again to anyone following this. Treat the FAA like the IRS. Be very careful what you say to them.
 
What is with all the fear? If an Inspection Authorization can't be creative enought to sign off a 337 for work that has been previously done Id go to a different one. How can an aircraft get imported with non-FAA approved repairs and alterations?

Hint: FAA approval is obtained, 337 and log entries written and work signed off as previosly installed and conformed to FAA approved data.

I've seen several autogas STCs never officially installed but the owner held the entire data package, just no log entry & 337 filed, easy $ for any IA.
 
Blackhawk said:
Yes I've heard of dishonest lawyers and cops. The problem with people at the Federal Level who get out of line is that they are very hard and expensive to fight. It matters little to them if they spend hundreds or thousands of hours on a minor case that will cost you dearly. Look at the current, ongoing fiasco with the IRS where we are now learning that they "lost" their emails when their hard drive "crashed".
In my instance- doing a right hand pattern with a sick pax at a non-towered airport with no other traffic- even with AOPA legal I spent over $1000 just getting to the point where we would see a judge. From that point forward it would all be out of my pocket and even if we did not go all the way to an NTSB judge we were talking thousands of dollars. The FAA lawyer knew it too and used many nice tactics to delay and run up my bill. Lawyers are not cheap- north of $400/hour in NY.
Oh, and that 15 day suspension that I paid my lawyer to reduce it down to? Yeah, well the FAA kind of "lost" my certificate and could not find it for 45 days... the original suspension they proposed. Ooops. So sorry. That extra month of no work? Oh well.
So spare me the crap about the FAA being there to help. I will reiterate again to anyone following this. Treat the FAA like the IRS. Be very careful what you say to them.
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One thing I learned many, many years ago is there is always 2 sides to every story. Maybe it's just me but I sense there is more to your story than you are alluding too.

Anyway, it's a useless argument. Go forward and live in fear.:rolleyes:
 
Jay Honeck said:
Amazingly, there are quite a few of them. Who knew?

She did, and has for about a dozen years. She is part of the PhD program at the U of Kansas in liturgical music and every OTHER year they take a trip to Europe to play the same instruments that Bach, Beethoven, Brahms, (etc.) played in their heyday. So far she has been to Germany, Italy, and now France plus a couple more that I didn't know about before re-meeting her.
So, let me get this straight -- a multi-thousand dollar trip to France for her is equivalent to a week of camping in the North 40 for you? Methinks you're getting the short end of this deal, Jim! :yikes:

Well, since SHE paid for it out of HER savings and retirement that she had before we joined up, I figure she can do with it as she damned well pleases. Besides, if you do the math, a trip to Oshkosh in the 182 sucks the gasoline hell out of 2 AMUs. Plus camping. Plus meals. Plus motels on the way.
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.....

Jim
 
Jay Honeck said:
But in the FAA's world, they are completely comparable, and of equal importance. We all know that the only real difference between the two scenarios is which piece of paper must be obtained, and from which bureaucrat. But, of course, since paperwork is all the FAA actually produces, obtaining retroactive "approval" is a big deal in their world.

In the OP's case, it should be a simple paperwork issue to resolve -- but you really never know. In my case, it was not, and I paid dearly. As a new owner in 1998 it was my baptism by fire into the bizarro world of the FAA.

And that, in a nutshell, is what drove me into the wonderful world of experimental aiircraft. I am SO glad that I will never, ever have to deal with that bureaucratic Bravo Sierra again. YMMV.
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Why do you think it should have been possible to get "retroactive approval" for a modification to your aircraft which was not legal? How does the passage of fifteen years change the fact that the installation was not permitted by the FARs?

As someone else already stated, the two situations are completely unrelated. The Sensenich propeller STC was an FAA approved modification to the OP's aircraft. Performing the modification required a Form 337 to be generated. The 337 certifies the installation was done in accordance with the STC. The form must be signed off by an IA and sent to the FAA. These two separate actions make the modification legal. All he needs to do is generate the 337 and provide it to the FAA.

Your situation was that a modification for which an STC had not been issued was done to a certificated aircraft. That's not legal. It wasn't legal the day it was done, and it wasn't legal when the situation was discovered fifteen years later.

No amount of begging, cajoling, or complaining was going to change that. Yet for some reason you think the FAA treated you unfairly. You complain because the FAA "allowed" you to reuse the wiring as if that was some inexplicable bureaucratic decision. The answer is much more simple. The wiring conformed to the materials and methods in the Whelan STC, or else you would have been directed to remove it.

There's nothing unusual or unfair with regards to how the FAA handled the situation. Your aircraft had modification which did not comply with the FARs, and you were directed to bring it into compliance. As far as I know the FAA won't issue a piece of paper which allows an illegal modification to remain on a certificated aircraft, no matter how long it's been that way.

For you to think they should have made an exception reflects poorly on you, not the FAA.
 
bnt83 said:
What is with all the fear? If an Inspection Authorization can't be creative enought to sign off a 337 for work that has been previously done Id go to a different one.
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While a second opinion in such a case might be warranted, keep in mind that the reason an IA wouldn't "sign off a 337 for work that has been previously done" might be that it was not done properly.
 
3393RP said:
Why do you think it should have been possible to get "retroactive approval" for a modification to your aircraft which was not legal? How does the passage of fifteen years change the fact that the installation was not permitted by the FARs?

As someone else already stated, the two situations are completely unrelated. The Sensenich propeller STC was an FAA approved modification to the OP's aircraft. Performing the modification required a Form 337 to be generated. The 337 certifies the installation was done in accordance with the STC. The form must be signed off by an IA and sent to the FAA. These two separate actions make the modification legal. All he needs to do is generate the 337 and provide it to the FAA.

Your situation was that a modification for which an STC had not been issued was done to a certificated aircraft. That's not legal. It wasn't legal the day it was done, and it wasn't legal when the situation was discovered fifteen years later.

No amount of begging, cajoling, or complaining was going to change that. Yet for some reason you think the FAA treated you unfairly. You complain because the FAA "allowed" you to reuse the wiring as if that was some inexplicable bureaucratic decision. The answer is much more simple. The wiring conformed to the materials and methods in the Whelan STC, or else you would have been directed to remove it.

There's nothing unusual or unfair with regards to how the FAA handled the situation. Your aircraft had modification which did not comply with the FARs, and you were directed to bring it into compliance. As far as I know the FAA won't issue a piece of paper which allows an illegal modification to remain on a certificated aircraft, no matter how long it's been that way.

For you to think they should have made an exception reflects poorly on you, not the FAA.
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Wow! An Orwellian post, if I've ever seen one.

You're right, of course. As were the drones who forced me to pay to have a perfectly-functioning, 15 year old strobe system removed from a perfectly-functioning airplane.

Not one of them could allow common sense to intrude on their world. Not one of them could stand up and say "Wait a minute! This guy is right! This IS Bravo Sierra!"

I actually felt sympathy for them, at the end, as I usually do when dealing with government employees. Although I was the one paying for it, I simply could not imagine working and living in a paradigm so rigid as to allow no room for common sense. It must be awful.
 
Jay Honeck said:
Wow! An Orwellian post, if I've ever seen one.

You're right, of course. As were the drones who forced me to pay to have a perfectly-functioning, 15 year old strobe system removed from a perfectly-functioning airplane.

Not one of them could allow common sense to intrude on their world. Not one of them could stand up and say "Wait a minute! This guy is right! This IS Bravo Sierra!"

I actually felt sympathy for them, at the end, as I usually do when dealing with government employees. Although I was the one paying for it, I simply could not imagine working and living in a paradigm so rigid as to allow no room for common sense. It must be awful.
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If you wanted to keep the strobes, why didn't you pursue a field approval rather than remove them? :dunno:
 
mondtster said:
If you wanted to keep the strobes, why didn't you pursue a field approval rather than remove them? :dunno:
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They like to have the 337 all filled out, reviewed, and approved before you do the mod. You could alternatively ask for Exp R&D airworthiness in order to develop the information for the 337 and field approval I guess.:dunno:
 
mondtster said:
If you wanted to keep the strobes, why didn't you pursue a field approval rather than remove them? :dunno:
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I was advised (again, by the shop that was fleecing me, as a new owner in 1998) that a field approval would cost more than new Whelan strobes.

To this day, I don't know: Were they right?
 
Jay Honeck said:
I was advised (again, by the shop that was fleecing me, as a new owner in 1998) that a field approval would cost more than new Whelan strobes.

To this day, I don't know: Were they right?
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Depends on what they were going to charge you for the paperwork, and what it was going to cost to get the data for approval. For sure you were in the air legally faster because your plane was technically grounded until the field approval came through, and that would take 60-120 days after they have the complete package quite likely.
 
weirdjim said:
Let's give this a little thought. What does the top of the 337 say ... MAJOR Repair or MAJOR modification. Back in the stone ages when most of us were in liquid form, the Feds got a little bitchy about hanging a Model T engine on a J3 and flying it about, so they ginned up a list of what is major (FAR Part 43 Appendix A). Most of us are pretty rigid when it comes to the stuff that is enumerated in this list, but let's take the propeller in question.

In the parlance of the FAA, the propeller is an "accessory" to an engine. The FAR is quite specific that a major alteration is, "(iii) Installation of an accessory which is not approved for the engine."

So the question begs itself, what does "approved" mean? I believe the answer is quite simple ... when an STC is issued specific to an engine or engine/airframe combination, that in and of itself bears FAA signatures for "approval". As such, the installation of an STC'd propeller on an engine for which approval is granted by the STC documentation becomes a MINOR modification and as such a logbook entry by an A&P (not necessarily an IA) is all that is required.

/Asbestos suit on/

Jim
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I think the FAA just needs to know what the certificated design of each aircraft is. When I say the certificated design I refer to the original type certificate along with any supplemental type certificates.

In a forensic investigation, knowing what significant changes were made lets them follow up with corrective inspections and ADs. It also saves them from combing through years of maintenance records to find what significant changes were incorporated.
 
Jay Honeck said:
Jim is opinionated as hell (that's why we all like him) -- but I've never known him to take a cheap shot.
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And a mere four posts later:

weirdjim said:
Ya know, Levy, I don't see IA after your name, nor even A&P. When you get them, then come back and tell us all about it.
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Proved you wrong pretty quickly, eh Jay?

Threads like this are always fun. Many of us just sit back, pop a beer, and wonder with a grin:

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(And then you wait for the spelling and grammar dicks to start wagging)
 
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timwinters said:
And a mere four posts later:



Proved you wrong pretty quickly, eh Jay?

Threads like this are always fun. Many of us just sit back, pop a beer, and wonder with a grin:

44752956.jpg


(And then you wait for the spelling and grammar dicks to start wagging)

You forgot a period or exclamation point at the end of that sentence.
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.....
 
Well, I was a little stymied when the local IA didn't sign the missing 337. I went back through prev owner registration records and searched for A&P that signed the log book in that city. The name showed up in a Bonanza magazine ad. I called and left a message; he called me Wed and will just write up the missing 337 himself.

Lotta nice folks everywhere.
 
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