Vintage Aircraft Replacement & Modification Article

Steve Pierce

Administrator
Staff member
Graham, Texas, United States
Vintage Aircraft Replacement & Modification Article (VARMA)

I can see several items this process might work on. Alternators, regulators on VFR airplanes. Brakes, tailwheels and more.
 

Attachments

Says a case by case basis. I have been good at documenting things like this with data using other aircraft type certificates and parts manuals. To quote my old PMI (FAA Primary Maintenance Inspector) " you aren't reinventing the wheel, just building a better mouse trap". I miss him every time I deal with the local FSDO.
 
This is good news. Was reading through the article posted by Jim. It has a link concerning a similar type of approval for Dyson EFIS for an experimental aircraft that was STC'd to be installed in a vintage aircraft. Article mentions that further approvals and companies were pending. Am I wrong in the way I read the article? Does anyone have any visibility on where this went? May be barking up the wrong tree, but it would seem to me, that avionics for experimental aircraft, installed in our aircraft, would be a logical path of progression. Besides, who wouldn't want to save the money for the same piece of glass in the cockpit without paying such a huge differential?
 
I’m all for it also but the EAA example was to submit a 337 for installation of an off the shelf starter solenoid. This would mean it’s viewed as a major alteration which means it needs approved data. This has always been tougher because of the higher threshold. As an IA with an O-290 can I use this to install pistons from combustion technologies ?
 
I think the point of all this is a way to substitute parts and pieces that already meet some sort of FAA approval on an aircraft that it is not approved on. Example would be wheels and brakes, alternators and regulators, shimmy dampener etc.
 

Attachments

Last edited:
Good question. It seems like AC 23-27 and field approvals already get you there. I think what we really need is a pathway around field approvals and one time STCs as they are becoming to difficult for many people
 
I agree with Scott. Getting a field approval via my local FSDO is non existent. I don’t see them being any responsive to a VARMA letter.
Be nice if they would give a little more authority to the IA and let him make the determination. I find it annoying how they don’t want responsibility yet are reluctant to relinquish authority.
 
I think this is going to be approved by the group in Chicago not the local FSDO.
 
That’s what it looks like to me also. I guess we will have to wait and see how things move through their office.
 
I think this is going to be approved by the group in Chicago not the local FSDO.

Scott Forhman is the guy behind all of this. He came to the WI IA seminar this spring and explained the process. I just submitted my first request for a LOA.

Replace the old nav light/cockpit flood with the new solid state Seaton engineering SWP microdim. Let you know how it goes.
 

Attachments

Last edited:
I agree with Scott. Getting a field approval via my local FSDO is non existent. I don’t see them being any responsive to a VARMA letter.
Be nice if they would give a little more authority to the IA and let him make the determination. I find it annoying how they don’t want responsibility yet are reluctant to relinquish authority.

Field Approvals from the FSDO are likely a thing of the past for most FSDOs. Getting them from DARs will be the way of the future. It will take a little more work as DARs have to document all Field Approvals as shown in AC43-210A Not really hard, just takes some time. I do quite a few and unfortunately I get backed up and don't get them out as fast as I like.
 
Scott Forhman is the guy behind all of this. He came to the WI IA seminar this spring and explained the process. I just submitted my first request for a LOA.

Replace the old nav light/cockpit flood with the new solid state Seaton engineering SWP microdim. Let you know how it goes.

I look forward to hearing how it goes. That is a way better dimmer.
 
Scott Forhman is the guy behind all of this. He came to the WI IA seminar this spring and explained the process. I just submitted my first request for a LOA.

Replace the old nav light/cockpit flood with the new solid state Seaton engineering SWP microdim. Let you know how it goes
.
attachment.php

Looks like most of the eastern USA is under water... what map is that?
 
Nothing yet. It took 3 months to get my DME application returned because I missed checking a box. Once I checked the box it took another 9 months to approve it.

Todd
 
Just forget getting field approvals from the FSDO. Go with a DAR for your field approvals. Just remember they have to follow the AFS-300 job aid as far as what is capable of being field approved. Granted, A DAR isn’t free, but will likely get what you need. That said AC23-27 has to be one of the most confusing ACs. In one place it says it is approved data, in another it says the data can be used to obtain a field approval!
 
So is VARMA just as bad as the field approval process ? It sounds like it. The DAR is likely the only effective route in this day and age I guess. I was very hopeful for the VARMA pathway.
 
I have gotten a few field approvals in the last few years but it takes due diligence and a good PMI (Primary Maintenance Inspector).
 
I should have considered the responses to my comment on the time it takes for Government to work. The EAA has been lobbying the FAA for years to streamline the process for replacement of obsolete parts on vintage aircraft. The FAA responded with VARMA. No comments about how long it took the FAA to respond....

VARMA is noting new, its not an Regulation or Order, its simply a way to increase the A&P community knowledge and confidence in substituting obsolete parts and materials in vintage aircraft using the Advisory Circulars.

The Advisory Circulars already exists, AC 23-27, 20-62 and 43-18. The problem is that the ACO (Engineers) don't speak Mechanic and Mechanics don't speak Engineer. ACO's and DAR'S work to strict procedures, Field Approvals, STC's, PMA approval, but there is no procedures for an A&P or Owner trying to use the AC to replace an obsolete part on a vintage aircraft.

VARMA is the ACO's official review of the rationale a A&P or Owner is intending to use to comply with the AC. A document (Permission or Denial letter) is then issued by the ACO to the A&P or Owner with the FAA findings. That is what I am waiting on. I don't mind waiting a long time if it works. With acceptance of my rationale, I can pass it on to other owners and mechanics to use in their projects.

Todd
 
I should have considered the responses to my comment on the time it takes for Government to work. The EAA has been lobbying the FAA for years to streamline the process for replacement of obsolete parts on vintage aircraft. The FAA responded with VARMA. No comments about how long it took the FAA to respond....

VARMA is noting new, its not an Regulation or Order, its simply a way to increase the A&P community knowledge and confidence in substituting obsolete parts and materials in vintage aircraft using the Advisory Circulars.

The Advisory Circulars already exists, AC 23-27, 20-62 and 43-18. The problem is that the ACO (Engineers) don't speak Mechanic and Mechanics don't speak Engineer. ACO's and DAR'S work to strict procedures, Field Approvals, STC's, PMA approval, but there is no procedures for an A&P or Owner trying to use the AC to replace an obsolete part on a vintage aircraft.

VARMA is the ACO's official review of the rationale a A&P or Owner is intending to use to comply with the AC. A document (Permission or Denial letter) is then issued by the ACO to the A&P or Owner with the FAA findings. That is what I am waiting on. I don't mind waiting a long time if it works. With acceptance of my rationale, I can pass it on to other owners and mechanics to use in their projects.

Todd

While FAA is talking VARMA and various ACs there is still a lot of unknowns. That said, AC43-18 doesn't even apply to an A&P, it only applies to 145 Repair Stations that have a quality System. A&Ps have been permitted to fabricate parts for as long as there have been airplanes! The guys that wrote AC43-18 have no idea about aviation maintenance other than air carrier stuff. Unfortunately so many A&Ps don't understand the certification process. AC43-210A covers how to process Field Approvals and the AFS-300 job aid provides guidance on what is able to be Field Approved. A field Approval is nothing more than a mini STC and needs to be regarded the same way. You need to define what the alteration is, identify what applicable regulations are being impacted and show how the alteration satisfies the intent of the regulation. I've done a lot of IA seminars on this very issue knowing that the A&Ps and IAs are short on this knowledge.
 
Last edited:
Ok, stupid question time … it seems like the OME dimmer switch is unavailable. The Seaton microdim switches are not FAA/PMA certified, but they are “RTCA/DO-160G Section 21 RFE qualified.”

According to AC 23-27, a replacement part has to be “in complete compliance with an established industry … specification.” The FAA has an entire AC dealing with RTCA/DO-160, so sounds like that’s an acceptable standard.

Sounds like a minor alteration … ?

Chris
 
Last edited:
Back
Top