wHEN IS A 337 NEEDED VS AN STC

[n3437d]

DOES ONE NEED A 337 OR STC IF A NEW PANEL (AIVION INSTRUMENTS) IS ADDED TO REPLACE OLD?

[Bruce Fenstermacher]

You will need some basis of approval for the modification. I'm not formiliar with AIVION INSTRUMENTS. Is this a company that offers an instrument panel for a 170. If so perhaps they went through the process of having there panel approved for installation in all 170s and more than likely received an STC for it. If so that would be you basis of approval. Assuming of course that AIVION INSTRUMENTS gives you permission to use there STC and presumably they would if they sold or sell you there product.

On the other hand if AIVION INSTRUMENTS is just a company that will custom build you a panel then you will need to have that approved for your aircraft. The form used for the approval process is a form 337.

If there is a STC involved the form 337 would also be used to submit the STC information and modification to the FAA for the aircraft records. It just wouldn't have to be approved be cause it was previously by the STC process.

Got all of that

[GAHorn]

FAR 43, Appdx. A, defines "Major Alteration" and major alterations require Form 337's with block 3 approval (field approval.) An STC is an alteration/modification that has already obtained approval.
Manufacturing a new instrument panel will fall under the definition of major alteration. Replacing an existing approved panel with an identical panel is a repair. It will also probably require a Form 337, but will not require block 3 approval or STC.
Avion is a company that makes replacement panels, and they are best in a position to advise you as to whether or not you will need additional approval to install their product in your airplane. Good luck. Take pictures. Write an article, and send it to headquarters@cessna170.org

[mit]

DOES ONE NEED A 337 OR STC IF A NEW PANEL (AIVION INSTRUMENTS) IS ADDED TO REPLACE OLD?

I Installed their panel in the mid 90's when the FAA was doing Field approvals. They did at least 3 counting mine, here. I don't understand why they have not got the STC approved by now!

[c170b53]

IMHO run from that part supplier. In the beginning they were stating in their ads that they were seeking an STC for the 170. Never happened, that famous STC pending B.S. Yes you can get a field approval and there is lots of them out there. A.R. do have an STC for the 172 and there's no difference other then where the little wheel goes but there's going to be paperwork issues. The panel from Del-air is not as cute but has the STC. Therefore its a slam dunk. Call Harry to see how much leeway you have to make the new panel resemble a glass cockpit. Sorry George if I've done a bad thing in this reply, I'll understand if I'm sanctioned.

[johneeb]

IMHO run from that part supplier. In the beginning they were stating in their ads that they were seeking an STC for the 170. Never happened, that famous STC pending B.S. Yes you can get a field approval and there is lots of them out there. A.R. do have an STC for the 172 and there's no difference other then where the little wheel goes but there's going to be paperwork issues. The panel from Del-air is not as cute but has the STC. Therefore its a slam dunk. Call Harry to see how much leeway you have to make the new panel resemble a glass cockpit. Sorry George if I've done a bad thing in this reply, I'll understand if I'm sanctioned.

Stay away from Avion Research and Trevor Hoy. During the restoration of my 170, Trevor Hoy was the only bad actor I dealt with out many suppliers. He makes promisses that he cannot and does not intent to keep, and you are left with a commitment to modify your aircraft with very important parts missing to say nothing of no approval paperwork.

[GAHorn]

IMHO run from that part supplier. In the beginning they were stating in their ads that they were seeking an STC for the 170. Never happened, that famous STC pending B.S. Yes you can get a field approval and there is lots of them out there. A.R. do have an STC for the 172 and there's no difference other then where the little wheel goes but there's going to be paperwork issues. The panel from Del-air is not as cute but has the STC. Therefore its a slam dunk. Call Harry to see how much leeway you have to make the new panel resemble a glass cockpit. Sorry George if I've done a bad thing in this reply, I'll understand if I'm sanctioned.

Sanctioned? Sanctioned? No such thing for good folks that are here for the right reasons, such as yourself. Now, Ol' Gar is walkin' a thin line, I admit..., but you? Pshawww!
Thanks for the help!

[n3437d]

I never expected to get "6" replies to this question. I only wished that I had thought to ask it 5 years ago while making the purchase. This truly makes me wonder about legal ramifications, not only with the FAA but through an Insurance Carrier.

How squeeky clean does one have to be when they get into a bind? I think I know the answer to that one?

[cessna170bdriver]

This truly makes me wonder about legal ramifications, not only with the FAA but through an Insurance Carrier.

How squeeky clean does one have to be when they get into a bind? I think I know the answer to that one?

Being just a private pilot and not depending on flying for my living (just my sanity ), the thought of an insurance (especially liability) claim being denied scares me more than an FAA sanction. However if you at least attempt to keep your airplane "legal" then the chance of denial of coverage is more remote.

We had the Aviation Safety Program Manager for Airworthiness from the Van Nuys FSDO give his spiel on the PACE (Pilot And Courtesy Evaluation) program ( http://www.faa.gov/fsdo/cae/safety/pace1st.htm ) to our local pilots’ group last night. One of the “what ifs” he gave us was that if you substantially damage your airplane, say due to a blown tire, and the investigation reveals that your Brackett air filter isn’t properly documented, many insurance companies would deny a claim based on the fact that technically the airplane was not airworthy. He added that while any fair judge would make them pay anyway since an air filter can’t cause a blown tire, the appeal process could take years, and in the meantime you’re without an airplane, and you’re paying the legal fees.

According to the presentation we received last night, the PACE program is an opportunity to have an FAA inspector come out without cost or fear of FAA sanction, and evaluate your airplane, records, and, if your airplane is determined to be “legal”, your piloting ability. If discrepancies are discovered (and this guy indirectly assured us that there would be) the inspector will provide a list to the owner to resolve however and whenever the owner chooses. Supposedly, the list provided is not an official record and the FAA will NOT follow up to ensure compliance.

This all sounds good, and if it’s executed like it’s written, it’s a good program. However, I’d like to say that I did not come away from this particular presentation with a “warm fuzzy” that continued airworthiness of our older planes is of much concern, at least in this district. Case in point: The subject of service manuals came up several times. He told us that any time any maintenance is done on the airplane, it must be logged as being “in accordance with the type certificate data sheet and service manual”. He told us to run away from any shop that did not have a TCDS and a service manual for our airplanes because that would be the only way it could properly maintain an airplane. He gave us several examples of airplanes he had grounded due to maintenance not performed in accordance with its service manual. About the third time service manuals came up, I raised my hand and asked him what data we should reference if an airplane was old enough to have been built before service manuals were required to be written. His response, and I quote, was “Sell it to the Smithsonian.” Ignoring his joke (sort of), in as calm a voice as I could muster, I told him I had a 1955 Cessna 170B, and the Smithsonian isn’t likely to be interested . His response to that was that I should save the money from cheating on my income taxes and buy a new airplane. When no one laughed at that “joke” either, he muttered something about “best practices” and went on to the next subject. While he did have a lot of good information to offer and chanted the “we are here to help you” mantra, I think he compromised his credibility with his flippant remarks. When he asked for “volunteers” for the PACE program, he didn’t get any takers from our group.

Miles

[GAHorn]

It's unfortunate that your FAA representative was so cavalier in his remarks. It undermines not only his credibility, but it also serves to MIS-inform the flying public....which is the EXACT OPPOSITE of the purpose of his FSDO having sent him to make the presentation.

It is commonly heard that the insurance companies are the real threat to owners who operate airplanes with known defects, but that is rarely the case. I have an airplane that is missing it's baggage limitation placard. It's been missing the entire time I've owned it. I keep thinking I need to take care of that.
If I loan my airplane out and the pilot overloads the baggage and stalls/spins in on takeoff the insurance company is most likely going to pay me for my loss (assuming the pilot met my insurance requirements or was named on the policy.) There is little likelihood of any further action by the ins. co. other than to lay claim to the wreckage for sale to a salvage yard.
If they ended up in a huge lawsuit from the survivors of the fatally injured in that wreck, perhaps they'd look into it more deeply. Perhaps they'd notice the NTSB report that told about the outboard motor and the 100 lbs of fishing weights in the baggage compartment that caused the airplane to be out of balance. In such case, would they come to me to get their money back? Would they refuse to defend the case in court? Not likely. They'd probably pay the claims up to the policy limit, then go after the mechanic/inspector who'd been signing off my annuals for the last 6 years, and the guy before him who restored the airplane, deliberately left the placard off, and returned it to service. IF....IF...they felt they could prove the dead pilot had overloaded the compartment because of his ignorance of the limitation because of the missing placard.
Any opposing attorney worth his salt would quickly point out that the aircraft should never have passed it's annual and never been issued an airworthiness certificate without that placard, which is required by the type certificate.

The reason our airplanes go thru annual inspections is to determine their continued airworthiness. The primary goal in that inspection is to determine that they meet their design type certificates....or if they don't...then they must meet an "approved alternative certification basis" (such as a field approval or STC.)
In other words, it's the annual inspection that confirms an airplane is airworthy. It's the ONLY inspection that is comprehensive in that regard.
Unless an owner can be proven to have knowingly altered his aircraft in such a manner that it's airworthiness is affected...then an insurance company would have a difficult time denying coverage on such a basis. They would more likely pay the owner, and then if the claim was sizeable, go after the mechanic/inspector who last annualed it and signed it off. (No wonder inspectors are sometimes picky. The FAA is not the real threat....it's the loss of income and personal liability that is threatening to a mechanic/inspector.)

[zero.one.victor]

So George, why not replace the missing baggage limitation placard? By rights, the airplane IS unairworthy without it,as it is required per TCDS. Easy enough to replace, too: just xerox that part of the TCDS, clip out the placard, and scotch-tape it in the baggage area,preferably where it can't be seen without sticking your head behind the rear seat- like up close to the bottom of the hat shelf. I was missing the placard that says: "this aircraft must be operated.....". I did the xerox trick & taped it to the panel where it is "in front of & visible to the pilot" (per TCDS requirements) yet unobtrusive.

Eric

[GAHorn]

Actually, I've had the placard reproduced for some time now. I just haven't installed it. Too many projects...not enough time...and whenever I remember it...I'm nowhere near the plane.

[n3437d]

For those that might be interested in how my question got started. I had posted my plane for sale last month. I received a lot of interest but decided not to sell. I had one VERY interested party (cash in hand). He asked about the STC's and 337 as there has been extensive work done on the plane. Where is the STC for the panel? There was none to be found. All work had been done "in accordance" and entered and signed off in the A/C logs. I decided to contact Avion yesterday http://www.avion.com. Contact was made mainly due to some of the posts to my original question. Well "blow me over" when I arrived at my office this morning at 7am, there was a message on my phone from Avion. A "bloke" by the name of Trevor had left a message. His tone left a bit to be desired, such as "how come you waited 6 years to contact us?" "We NEVER promised STC's for our panels." I will keep you all informed as he left his phone number 408-732-2027 (Sunnyvale,CA).

The long and the short - "money in hand" walked as the paperwork was incomplete. Should I offer my "worthless steed to the Smithsonian or should I "take the money that I have been holding from the IRS" (just kidding) and buy a 310

[n3437d]

More thinking on this topic...I have this situation where a prior owner did work, new Avion panel. Now there is no STC and Avion will not step up to plate and furnish one, stating that "No STC was ever promised." Now we have an aircraft that is not in compliance. Are the choices #1 remove existing "upgraded panel" with one that is STC'd, #2 Attempt to have Avion get their panels STC'd, #3 Attempt to get field approval? What should the responsibility be of companies that provide aircraft components?
I really never thought much about this until the world turned complicated.

[zero.one.victor]

IMHO any verbal promise Avion may have made in the past (especially to someone other than yourself) is worth the paper it's printed on-- nothing! They are under no obligation to pursue/obtain an STC just because you want them to. From what I've heard about obtaining regular (multi-use) STC's, I don't blame them for not wanting to go thru it.
I would say that per your options, you can #1 remove upgraded panel (what a waste) and install an STC'd panel, or #3 attempt to get a field approval.
Or an option you did not list: leave well enough alone. Evidently someone (or maybe several someones) was satisfied enough with whatever documentation has been done for the panel mod to sign off on the annual for six years now. If a 337 has been filled out and filed with someone (IA,DER/DAR,FAA rep) signing it off as "installed in accordance with usual practices" etc I'd leave well enough alone. Even if it was just a logbook entry. Is your IA satisfied? That's what counts. If your potential buyer(s) are not, they can just walk away.
If you're now planning on keeping the airplane (which I recommend! ) let sleeping dogs lie, and don't sweat it.

Eric