Non-TSO for Certified Aircraft

Capt. Geoffrey Thorpe said:
Which is why an A&P would never use a zip tie or safety wire in place of a hose clamp on an air box.
Click to expand...

Of COURSE not, that's why the IA is given the latitude to toss stupidity like this out. (S)he is also given the latitude to use hex head stainless steel hose clamps from the aviation department of the National Aviation Parts Association (NAPA) Parts Store instead of the "aviation quality" stuff from Spruce or Waggyaero.

Jim
 
bnt83 said:
Who wants to pay a mechanic shop rate labor to play phone tag with the FAA because the owner wants to install a mod that holds NO prior approval? That time alone would probably pay for the difference in cost.

Ok, lets say they just installed it without the FAA consult, now the FAA somehow caught wind of it and the mechanic is forced to play the phone tag game because his kids gotta eat. Now he's probably gotta spend even more time defending his position, which may or may not be a successful outcome, and not got getting paid for the effort.
Click to expand...

I suspect that a reasonably savvy owner should be able to do much of the legwork, and just keep the A&P/IA in the loop. However, mechanics have to eat, and support their families too...
 
thomasdr72 said:
I suspect that a reasonably savvy owner should be able to do much of the legwork, and just keep the A&P/IA in the loop. However, mechanics have to eat, and support their families too...
Click to expand...

I've been trying this myself with mixed success. From what I can tell, FSDO inspectors aren't really keen on talking to non-A&P owners about this kind of stuff. Seems you can get some surface-level information, but I've struggled to get much past that. In other words, FSDO will talk to you in really broad terms about your project, but won't really discuss a) whether they'll seriosuly consider an approval or b) what it'll take to get them to consider an approval. It's mostly been "that sounds like a nice project, have your A&P call me..." And in my experience, most A&Ps and shops just aren't interested in dancing with the FAA for a field approval.

Funny thing, I had a conversation with a senior engineer at the FAA today (not in the FSDO) and he was bemoaning the fact that the FAA gives a lot of individuals a lot of discretion (A&Ps, FSDO inspectors, etc.), but they're all terrified to use it. One of his points was that there is absolutely nothing in the regs that requires airplane parts to be TSOd, and that a TSO is simply one way for an A&P to determine that a part is suitable to be installed on an airplane. But that most A&Ps refuse to install non-TSOd stuff because they don't want to have to actually make an airworthiness decision. Same goes for FSDO inspectors who don't want to grant field approvals because they'd have to actually exercise discretion and make a determination. Easier to just leave that to the manufacturer and the ACO (STC process).
 
bnt83 said:
Who wants to pay a mechanic shop rate labor to play phone tag with the FAA because the owner wants to install a mod that holds NO prior approval? That time alone would probably pay for the difference in cost.

Ok, lets say they just installed it without the FAA consult, now the FAA somehow caught wind of it and the mechanic is forced to play the phone tag game because his kids gotta eat. Now he's probably gotta spend even more time defending his position, which may or may not be a successful outcome, and not got getting paid for the effort.
Click to expand...

You've just described why every industry NEEDS a few old folks around who really don't need the job. The need for a paycheck quite often leads to the wrong outcome.

It's okay to need the paycheck. Just find the old guy or gal and sic them on the stupidity. They'll know if it's worth the battle. :)

Jim knows the TSO thing is worth the battle. He's outnumbered by those who need the paycheck but he'll keep shooting. Helps all of us.
 
denverpilot said:
Jim knows the TSO thing is worth the battle. He's outnumbered by those who need the paycheck but he'll keep shooting. Helps all of us.
Click to expand...

There's an old story about the screech owl and the scrooch owl. The screech owl swoops down on the henhouse, grabs the first hen he sees, raises hell screeching and drags the hen out of the house yelling like hell. If he's lucky he'll make it out of the henyard before the farmer has a chance to grab his shotgun and make it one less screech owl in the world. The scrooch owl climbs the henhouse fence carefully, tiptoes into the henhouse, scrooches over to the fattest hen in the house, nuzzles up to her, tells her how pretty she is, and soon their ain't no hen.

Moral, tiptoe into the henhouse, scrooch around carefully, you'll get what you want, and you won't get shot. Raise hell, bother the FSDO with a ton of questions, screech your head off and they'll take a paperwork shotgun to you.

Softly, softly catchee monkey.

Jim
 
Last edited:
bradg33 said:
I've been trying this myself with mixed success. From what I can tell, FSDO inspectors aren't really keen on talking to non-A&P owners about this kind of stuff. Seems you can get some surface-level information, but I've struggled to get much past that. In other words, FSDO will talk to you in really broad terms about your project, but won't really discuss a) whether they'll seriosuly consider an approval or b) what it'll take to get them to consider an approval. It's mostly been "that sounds like a nice project, have your A&P call me..." And in my experience, most A&Ps and shops just aren't interested in dancing with the FAA for a field approval.

Funny thing, I had a conversation with a senior engineer at the FAA today (not in the FSDO) and he was bemoaning the fact that the FAA gives a lot of individuals a lot of discretion (A&Ps, FSDO inspectors, etc.), but they're all terrified to use it. One of his points was that there is absolutely nothing in the regs that requires airplane parts to be TSOd, and that a TSO is simply one way for an A&P to determine that a part is suitable to be installed on an airplane. But that most A&Ps refuse to install non-TSOd stuff because they don't want to have to actually make an airworthiness decision. Same goes for FSDO inspectors who don't want to grant field approvals because they'd have to actually exercise discretion and make a determination. Easier to just leave that to the manufacturer and the ACO (STC process).
Click to expand...

Don't forget that transponders and IFR GPS do need to meet TSO and maybe one or two other odd items. Other than that, I agree totally.

Maintainers are given the leeway to make decisions, but aren't being trained and shown how. Then you get owners who want what they think is right and you have to try and educate them. And then the regulator comes along, adding more confusion and non-answers. Not a great situation. But if it was easy, everyone would be doing it! :)
 
JAWS said:
Don't forget that transponders and IFR GPS do need to meet TSO and maybe one or two other odd items.

Altitude encoders.

and you have to try and educate them.

Educate only so far. Then you simply say, "sorry, I don't do that. Joe down the taxiway might be able to help you."

Jim
Click to expand...
 
LOL Pretty much! LOL
 
Thank you so much for posting this clarification on installing non-TSO avionics. Makes perfect sense to me.

weirdjim said:
Well, I can only speak from experience as an avionics engineer for over 50 years, an avionics manufacturer for forty-three years, and an A&P IA for thirty years. Hardly any experience at all, and ALL of it in General Aviation.

I started a business 43 years ago making KIT avionics. That's right, folks, Heathkits for Airplanes. And I didn't distinguish between experimentals and factory builts. After a year of this foolishness, the bigwigs from the FAA Western Region headquarters came down to give me a Stern Talking To. They said without STC,TSO,or PMA I couldn't build my stuff and sell it. I asked them to show me the STC/TSO/PMA for the Narco Superhomer/Mark III through Mark XII or the King STC/TSO/PMA for the KX 120/150/170.

The answer was "Well, harumph, those are big companies and harrumph we think they make a good product and harrumph they don't or they haven't or they shouldn't or they won't ... well, anyway, we'll be getting back to you when we think this through."

That was 42 years ago, the team leader for that group went on to become the Director of Airworthiness back in DC, and neither he nor any of his minions have been back to see me. My non TSO's/STC'd/PMA'd stuff have been installed in over TEN THOUSAND aircraft of all makes and models. Audio panels, marker receivers, 760 channel navcoms, lamp dimmers, intercoms ... the whole array of avionics. As yet, not a peep from the Friendly Aviation Agency.

Now, would somebody that can speak from knowledge and experience like to debate me over what can and cannot be installed into standard (as opposed to experimental) certificated aircraft?

Jim
Click to expand...
 
One of the services government provides to industry is protection from competition through onerous and confusing regulations.

The FAA is particularly adept at providing “good service”.
 
I'm probably taking this too far, so let me test it.

Are you saying I can install a G3X or a non-certified G5 in my Mooney without a field approval as long as my A&P is ok with it. This does NOT mean I can use it as primary for instruments noted in the TC (IE: I can't remove the original altimeter), but I can install it if I choose to without a regulatory issue.

Did I get it right?
 
Clip4 said:
Not all Gizmos require a TSO, but they all require an STC or an FAA field approval for installation in certified aircraft.
Click to expand...
Nope, that's not true either. STCs and Field Approvals are only necessary for major modifications.
 
Salty said:
Are you saying I can install a G3X or a non-certified G5 in my Mooney without a field approval as long as my A&P is ok with it
Click to expand...
Yes. But it's easier to look at it this way. You determine what goes in your aircraft. Not a vendor. In general, anything you install will fall under one of two catagories: replacement or alteration. Since you want to alter your panel with the G3X you look to Part 43 App A to see if install falls under a major or minor. If minor then logbook entry by you mechanic if he agrees.

On the other hand say you need to cut primary structure to install the G3X which makes the install a major alteration, but only for the hole to be cut. Not the G3X. Using AC43.13 or a an SRM for approved data, you make the hole and complete the 337. Then install the G3 as a minor alteration.

Its only when you replace existing items with different items that the paperwork and authorizations come into play.
 
Bell206 said:
Yes. But it's easier to look at it this way. You determine what goes in your aircraft. Not a vendor. In general, anything you install will fall under one of two catagories: replacement or alteration. Since you want to alter your panel with the G3X you look to Part 43 App A to see if install falls under a major or minor. If minor then logbook entry by you mechanic if he agrees.

On the other hand say you need to cut primary structure to install the G3X which makes the install a major alteration, but only for the hole to be cut. Not the G3X. Using AC43.13 or a an SRM for approved data, you make the hole and complete the 337. Then install the G3 as a minor alteration.

Its only when you replace existing items with different items that the paperwork and authorizations come into play.
Click to expand...
I think this is also confirming my intuition that removing the altimeter, AI, DG, etc and replacing them with a g3x is a different conversation.
 
Salty said:
I think this is also confirming my intuition that removing the altimeter, AI, DG, etc and replacing them with a g3x is a different conversation.
Click to expand...
Yes. But i think if you keep the altimeter out of the mix and if you're replacing vacuum indicators you might have a path. Read over this and discuss with your mechanic. It's not directed at field level but it is FAA policy. There's another document on this but cant seem to locate it.
http://download.aopa.org/advocacy/PS-ACE-23-08.pdf?_ga=1.128165836.1569058260.1436975544
 
Salty said:
I'm probably taking this too far, so let me test it.

Are you saying I can install a G3X or a non-certified G5 in my Mooney without a field approval as long as my A&P is ok with it. This does NOT mean I can use it as primary for instruments noted in the TC (IE: I can't remove the original altimeter), but I can install it if I choose to without a regulatory issue.

Did I get it right?
Click to expand...
Not entirely, simply think of it this way, any equipment that must integrate with other equipment or systems just have a standard, that is known as a TSO.
Your A&P may be OK with you doing something, But at annual time the A&P-IA may have a different opinion, he's the guy you should be gaining permission from.
 
Tom-D said:
Not entirely, simply think of it this way, any equipment that must integrate with other equipment or systems just have a standard, that is known as a TSO.
Your A&P may be OK with you doing something, But at annual time the A&P-IA may have a different opinion, he's the guy you should be gaining permission from.
Click to expand...
Since he’s the same guy he’ll probably be ok too.
 
Tom-D said:
You could do it the way your A&P wants it done, then do it over for your IA..

Want to do it once or twice?
Click to expand...
Your reading comprehension could use some help.
 
Last edited:
Installing an IO-540 in my Slo-rrow via 337 would be pretty pimp.

So basically when it comes to major alteration is it fair to say we're at the whims of pension-frightened derelicts? IOW, the field approval process is effectively dead when nobody is willing to sign off a damned thing. STC process and its economic obfuscation is now the price of entry. How convenient. So to recap, we know they ain't approving ---t Monday thru Friday, my question for the FSDO then is...
giphy.gif


Maybe asking for forgiveness is better than asking for permission after all :D.
 
hindsight2020 said:
IOW, the field approval process is effectively dead when nobody is willing to sign off a damned thing.
Click to expand...
The Field approval system is alive and well, you just have to use it properly.
A&Ps simply believe it isn't worth their time, because owners believe paper work is not worth paying for.
a Field approval package ready to send to FSDO usually requires a full 2 days, @ $50 per. Add $400 to a bill see what the owner says.
 
Tom-D said:
The Field approval system is alive and well, you just have to use it properly.
A&Ps simply believe it isn't worth their time, because owners believe paper work is not worth paying for.
a Field approval package ready to send to FSDO usually requires a full 2 days, @ $50 per. Add $400 to a bill see what the owner says.
Click to expand...

$400? On what would amount to a 25AMU installation opportunity cost for the "STC approved" solutions by Garmin? I don't see that being the reason why field approvals don't have traction with owners. The reason people don't do it is because the AP feels, or the owner has a reasonable expectation that the FSDO is gonna stonewall the whole thing; who the hell wants to get ripped off by these pension-chasers over a hobby anyways? That's why people get steered to the DER route and the economically non-starter STC one off. So I don't understand what you mean by "using it properly" when these obfuscation dynamics are clear as day at the FSDO.

And let's talk about those STCs. How much you think it would run for me to get a DER to get me approval data signed to the satisfaction of the gatekeepers, to get a Dakota engine swap on an arrow III approved (identical airframe and wings/stabilator, and the engineering data all but writes itself especially if you keep the max gross weight at the original HP certification like the PPonk mods in the 182), or slap Arrow III fuel tanks on my Arrow II (no change in CG arm and minor cut and rivet work on a stone simple cherokee wing)? Cuz I'm sure 400 bucks and my AP's concurrence via field approval ain't gonna cut it with the derelicts at the FSDO. I'd love to sponsor creative ways to use the tools you suggest are available to us; I think it's just a disingenuous argument to suggest we have them available in earnest, and these are one of many examples to illustrate that lack of access. But hey if you could point me at a friendly FSDO and a right-priced DER let's do it! I'd love nothing more to be a pioneer in this hobby for once. :D
 
hindsight2020 said:
$400? On what would amount to a 25AMU installation opportunity cost for the "STC approved" solutions by Garmin? I don't see that being the reason why field approvals don't have traction with owners. The reason people don't do it is because the AP feels, or the owner has a reasonable expectation that the FSDO is gonna stonewall the whole thing; who the hell wants to get ripped off by these pension-chasers over a hobby anyways? That's why people get steered to the DER route and the economically non-starter STC one off. So I don't understand what you mean by "using it properly" when these obfuscation dynamics are clear as day at the FSDO.

And let's talk about those STCs. How much you think it would run for me to get a DER to get me approval data signed to the satisfaction of the gatekeepers, to get a Dakota engine swap on an arrow III approved (identical airframe and wings/stabilator, and the engineering data all but writes itself especially if you keep the max gross weight at the original HP certification like the PPonk mods in the 182), or slap Arrow III fuel tanks on my Arrow II (no change in CG arm and minor cut and rivet work on a stone simple cherokee wing)? Cuz I'm sure 400 bucks and my AP's concurrence via field approval ain't gonna cut it with the derelicts at the FSDO. I'd love to sponsor creative ways to use the tools you suggest are available to us; I think it's just a disingenuous argument to suggest we have them available in earnest, and these are one of many examples to illustrate that lack of access. But hey if you could point me at a friendly FSDO and a right-priced DER let's do it! I'd love nothing more to be a pioneer in this hobby for once. :D
Click to expand...
I'm talking field approvals, and you talk STC.. do you know the difference?
 
Tom-D said:
I'm talking field approvals, and you talk STC.. do you know the difference?
Click to expand...
I do. I'm saying field approvals ain't happening the way you suggest they're readily available, and it ain't because owners want to save 400 bucks on a 30AMU installation.
 
hindsight2020 said:
I don't see that being the reason why field approvals don't have traction with owners
Click to expand...
One of the reasons field approvals lost traction a bit was 20+ years ago the feds redefined the field approval process. The big change was removing alterations considered a "major change to TC" from the field approve (FSDO) process to the STC (ACO) process. Not saying your proposed swap would fit the lower level, but there are still engine swaps that could be done at the FSDO level with existing data.
 
hindsight2020 said:
I do. I'm saying field approvals ain't happening the way you suggest they're readily available, and it ain't because owners want to save 400 bucks on a 30AMU installation.
Click to expand...
Do you really believe that the approval package for your project including the engineering to be approved will require two days and cost $400.00?

Some field approval packages require weeks to develop, blue prints to buy, and all that.

400.is about as cheap as I've seen.
 
Bell206 said:
One of the reasons field approvals lost traction a bit was 20+ years ago the feds redefined the field approval process. The big change was removing alterations considered a "major change to TC" from the field approve (FSDO) process to the STC (ACO) process. Not saying your proposed swap would fit the lower level, but there are still engine swaps that could be done at the FSDO level with existing data.
Click to expand...
I guess that is why AC43,210 was written. (because we can't do this any more )
 
hindsight2020 said:
$400? On what would amount to a 25AMU installation opportunity cost for the "STC approved" solutions by Garmin? I don't see that being the reason why field approvals don't have traction with owners. The reason people don't do it is because the AP feels, or the owner has a reasonable expectation that the FSDO is gonna stonewall the whole thing; who the hell wants to get ripped off by these pension-chasers over a hobby anyways? That's why people get steered to the DER route and the economically non-starter STC one off. So I don't understand what you mean by "using it properly" when these obfuscation dynamics are clear as day at the FSDO.

And let's talk about those STCs. How much you think it would run for me to get a DER to get me approval data signed to the satisfaction of the gatekeepers, to get a Dakota engine swap on an arrow III approved (identical airframe and wings/stabilator, and the engineering data all but writes itself especially if you keep the max gross weight at the original HP certification like the PPonk mods in the 182), or slap Arrow III fuel tanks on my Arrow II (no change in CG arm and minor cut and rivet work on a stone simple cherokee wing)? Cuz I'm sure 400 bucks and my AP's concurrence via field approval ain't gonna cut it with the derelicts at the FSDO. I'd love to sponsor creative ways to use the tools you suggest are available to us; I think it's just a disingenuous argument to suggest we have them available in earnest, and these are one of many examples to illustrate that lack of access. But hey if you could point me at a friendly FSDO and a right-priced DER let's do it! I'd love nothing more to be a pioneer in this hobby for once. :D
Click to expand...
I think that this whole rant is based upon a wrong preconceived idea of what FSDO does.
You come at FSDO with the attitude shown here you certainly are't getting what you want.
 
bradg33 said:
From what I can tell, FSDO inspectors aren't really keen on talking to non-A&P owners about this kind of stuff. Seems you can get some surface-level information, but I've struggled to get much past that. In other words, FSDO will talk to you in really broad terms about your project, but won't really discuss a) whether they'll seriosuly consider an approval or b) what it'll take to get them to consider an approval.
Click to expand...

I think you reach that point, because you haven't submitted a draft 337 to the FSDO. The FSDO can't approve handwaves, they have to approve concrete proposals. Nothing says the 337 has to be prepared by an A&P (though certainly you'll want to consult with yours). Draft the 337, send it over to your FSDO inspector, and the quality of your conversation will improve by an order of magnitude.
 
I have a 1947 Stinson108-3 with a TC under CAR, not Part 91 (or any other part). I have concluded I can save a few hundred dollars by installing a non TSO radio (such as an “experimental” approved radio like a Garmin 200) with no problem from the FAA, but that I need an A&P/IA to “sign off” on the installation? Correct so far? What type of “sign off” do I need? A simple logbook entry that the radio was installed according to the manufacuter’s installation instructions (but ignoring the part where the manufacturer states the radio is not for certified aircraft)? Is the installation of the radio a “replacement” or a minor alteration? Do I need any type of “sign off”?

It appears that everyone participating in this thread agrees that a transponder and GPS must be TSO; but where do you find the FAR or Order or other FAA written statement that TSO is required for this type of equipment?

What about ADS-B out? Specifically, I could save at least $1,000 if I installed a product from uAvion called “ECHO” or $500 if I used its “non-certified” SkyBeacon as opposed to its soon to be “certified” model. However, it appears I will need a TSO product and an STC , or with my Stinson being on the Approved Model List (if uAvion requests approval for the Stinson). Is this correct? Stated differently, can I legally install a non certified skyBeacon on my Stinson with just a logbook entry from my A&P/IA?

Thanks for your input.
 
I think you meant part CAR 3 vs 23 and not 91. 91 is an operating rule that applies for today.
 
Bob Brown said:
I have a 1947 Stinson108-3 with a TC under CAR, not Part 91 (or any other part). I have concluded I can save a few hundred dollars by installing a non TSO radio (such as an “experimental” approved radio like a Garmin 200) with no problem from the FAA, but that I need an A&P/IA to “sign off” on the installation? Correct so far? What type of “sign off” do I need? A simple logbook entry that the radio was installed according to the manufacuter’s installation instructions (but ignoring the part where the manufacturer states the radio is not for certified aircraft)? Is the installation of the radio a “replacement” or a minor alteration? Do I need any type of “sign off”?

It appears that everyone participating in this thread agrees that a transponder and GPS must be TSO; but where do you find the FAR or Order or other FAA written statement that TSO is required for this type of equipment?

What about ADS-B out? Specifically, I could save at least $1,000 if I installed a product from uAvion called “ECHO” or $500 if I used its “non-certified” SkyBeacon as opposed to its soon to be “certified” model. However, it appears I will need a TSO product and an STC , or with my Stinson being on the Approved Model List (if uAvion requests approval for the Stinson). Is this correct? Stated differently, can I legally install a non certified skyBeacon on my Stinson with just a logbook entry from my A&P/IA?

Thanks for your input.
Click to expand...
As long as your radio meets the aviation standards as far as frequency rules it does not need a TSO.
ADS-b I'm not so sure because it must interface with the national system. I do not understand how the national system can tell if your signal came from a TSOed transmitter.
 
You must log in or register to reply here.
Back
Top