New auto pilots becoming available, but........

[dgapilot]

91.319 says that for Experimental aircraft they can only be used for “the purpose” for which they are certified. In the case of Experimental Exhibition, the purpose is to exhibit the aircraft to the public. They can also be used for proficiency flying. The Op Limits issued are boiler plate from Order 8130.2J. The main thing there is the requirement to file an annual Program Letter outlining where you will be exhibiting the aircraft and what other flying you intend to do with it, where it will be based and who will be maintaining it. You might also want to read 43.1, any aircraft in the Experimental category is exempt from Part 43 maintenance requirements EXCEPT aircraft that previously had a different type of certificate. Since all Short Wings previously had Standard Certificates based on 43.1, they still need to comply with all Part 43 requirements. Only certified mechanics can perform maintenance and major repairs and major alterations still need to have 337s to document what was done to the aircraft. Unless the alterations are explicitly to support the Experimental Purpose of the aircraft they still need FAA Approved Data. It isn’t as easy as “just going Experimental”.

David Schober
A&P, IA, DAR, DER


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[Keith Turner]

Since all Short Wings previously had Standard Certificates based on 43.1, they still need to comply with all Part 43 requirements. Only certified mechanics can perform maintenance and major repairs and major alterations still need to have 337s to document what was done to the aircraft. Unless the alterations are explicitly to support the Experimental Purpose of the aircraft they still need FAA Approved Data. It isn’t as easy as “just going Experimental”.

David Schober
A&P, IA, DAR, DER


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There is an interesting thread on the EAA forum regarding CAM 3 vintage aircraft being put in the EE category, what it entails and the written and practical limitations.
It seems that the program letter from the DAR can have some variation based on the particular modifications and the DAR that signs off on the program letter and that is what I want to explore. I don’t see the limitation of having to have a A&P sign off on the modifications and a A&P/IA sign off on the inspections as being a big problem. I would expect to have that level of oversight and control. In the end I may just choose to make minimal modifications that keep the airplane in the certified category.

I do find it frustrating that I cannot change out a 75 year old electrical switch that is well past its use by date with a new industrial grade unit that meets IP 87 (e.g. NKK “S” series) but have to use a MIL SPEC switch that is 5 times the price. If this were a high performance high flight level aircraft I could understand it- for a day VFR 75 year old puddle jumper it is massive overkill.

[Keith Turner]

This post may hijack the thread so maybe it needs a new thread - but here goes.
With MOSAIC just around the corner it’s pretty clear that the PA22-150 will meet all of the expected new rules for LSA aircraft. Reading through the changes in regulation it’s not clear ( to me at least) if it would be possible to move the PA22-150 from type certificated to E-LSA. If this were possible it would be the best of both worlds and a big advantage from moving to Experimental Exhibition. Having the freedom to make modifications without STC’s or field approval and the aircraft owner being able to get maintenance and inspection approval after having taken the two week course. Limitations about for hire use, flight instruction of non owners etc. all likely to remain. The big question is in the ability to move the airplane category into E-LSA. I need to spend more time reading the MOSAIC doc to see if it covers that category change.
Anyone that has the answers please speak up

[dgapilot]

There is an interesting thread on the EAA forum regarding CAM 3 vintage aircraft being put in the EE category, what it entails and the written and practical limitations.
It seems that the program letter from the DAR can have some variation based on the particular modifications and the DAR that signs off on the program letter and that is what I want to explore. I don’t see the limitation of having to have a A&P sign off on the modifications and a A&P/IA sign off on the inspections as being a big problem. I would expect to have that level of oversight and control. In the end I may just choose to make minimal modifications that keep the airplane in the certified category.

I do find it frustrating that I cannot change out a 75 year old electrical switch that is well past its use by date with a new industrial grade unit that meets IP 87 (e.g. NKK “S” series) but have to use a MIL SPEC switch that is 5 times the price. If this were a high performance high flight level aircraft I could understand it- for a day VFR 75 year old puddle jumper it is massive overkill.

The DAR has nothing to do with the program letter other than to review the initial one to see that it meets the intent of Order 8130.2J Appendix C and 14 CFR 21.193 (a) thru (d). The applicant writes the Program Letter, not the DAR. A DAR does not sign it either, the DAR simply issues the Certificate.

As for replacing parts, that can already be done under the existing regulations as a Standard Certificated aircraft. Read AC23-27, it provides guidance on a lot of that. Old airplanes used a lot of automotive parts and there is no reason you can't use replacements for what was there originally.

[Keith Turner]

The DAR has nothing to do with the program letter other than to review the initial one to see that it meets the intent of Order 8130.2J Appendix C and 14 CFR 21.193 (a) thru (d). The applicant writes the Program Letter, not the DAR. A DAR does not sign it either, the DAR simply issues the Certificate.

As for replacing parts, that can already be done under the existing regulations as a Standard Certificated aircraft. Read AC23-27, it provides guidance on a lot of that. Old airplanes used a lot of automotive parts and there is no reason you can't use replacements for what was there originally.

Thanks for the reply and reference. It does indeed provide a pathway for using “equivalent or better than” components that are neither TSO’d or PMA.
Also I saw wording for electronic equipment that says “ meets the requirements of the TSO without actually having a TSO” and “functionally equivalent of the TSO’d product”. So in the example of radio transceivers - the Garmin GTR 200 unit is not TSO’d but meets the performance requirements of the TSO. So within the scope of comparison with pre 1980 TSO’d transceivers the GTR200 is superior in every respect functionally and performance wise. Does this provide a pathway for replacing the existing VAL 360 TSO unit with a GTR200?
I suspect that since ADSB was not required in 1980 there is no grandfather rule for ADSB equipment. If there were then the UavioniX echo which is not TSO’d but according to UavionX meets the relevant TSO so could be installed in a pre 1980 certified GA aircraft with only a logbook entry by an A&P/IA.
As an extension of that thought a non certified HDX, ADAHRS, EMS 200 and associated sensors could be installed in a new panel provided the basic minimum required steam gages were also there as a “One Off” or “No-Hazard” STC.

[dgapilot]

Kieth, you need to look at the definitions of Major Alteration and also the definition of Major Change in Type Design along with the AFS300 job aid for major alterations. It makes no difference what the certification basis is (CAR4, CAR3, Part23) when determining major alterations, the only difference is what regulation you need to show compliance to. For any Major Alteration you need approved data. For any Major Change in Type Design you need an STC. Additional references would be AC43-210A.

Installation of a com radio can be shown to be a minor alteration, so no approved data is required. For whatever reason FAA has determined that installation of ADSB out equipment is a change in type design and requires an STC. There is a great flow chart in AC43-210A that can drive one to the determination of minor alteration or major alteration. The AFS300 job aid helps determine if an STC would be required once you determine that you are dealing with a major alteration. It also indicates if you don’t have approved data if it can be field approved or if you need DER approved data.

Hope this helps.


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[Gilbert Pierce]

https://www.faa.gov/documentLibrary/...210A_CHG_1.pdf

Job aid on page 14 & 15.

[dgapilot]

The AFS300 Job Aid can be found on the DRS under “other documents, reporting systems and job aids, job aids and it is the third document down.


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[Subsonic]

So, getting back to the OP topic re: "New autopilots"...I'm wondering if any shortwing owners with heritage analog/vacuum/electric driven autopilots would be willing to share their experience using them? Good, or any issues? Still working? Keeping them serviced and operating difficulties?

I'm thinking of trying to put SOMETHING in my plane to help me on my lonely cross country adventures. I'd be interested in a good condition used and serviceable heritage system. Maybe Lear, or Brittain, or whatever is on the TCDS or STC'd for my '56 PA22.

At some point in the future, it may be that replacing a vaccum servo with an electric servo can be justified if you can show the new part loads the system with the same inch-pound control limits, or that the digital navigator replacing a vac. DG with heading bug is reasonable and tunable to mimic the original system.

Just a thought, but it might be more palatable for a DER to approve. Maybe?