FIELD APPROVAL FOR PA28-235 HEATED PITOT

[akoprivnik]

https://www.faa.gov/documentLibrary/media/Order/Order_8300.16A.pdf

yes. This order is the bible for the ASI to determine responsibilities he/she would use when presented with a field approval. I reference it extensively before submitting a field approval package to the FSDO and ACO. It further goes into details how to determine what validates a field approval. it also gives clear direction to the ASI for the steps and data needed to approve a field approval. But, the reference to use to determine major/minor is 14CFR Part 1 and Part 43 appendix A. The installing technician would use this as the determination.

I think all on this thread would benefit by reading order 8300.16A.

 

[philiplane]

"Major alteration means an alteration not listed in the aircraft, aircraft engine, or propeller specifications that: ( 1) Significantly affects weight, balance, structural strength, performance, powerplant operation, flight characteristics, or other qualities affecting airworthiness; or (2) Is not done according to accepted practices and cannot be done by elementary operations."

There are two elements: the alteration is not listed in the specifications, AND, the alteration affects the properties noted. So by definition, most alterations will be minor. Installing an IFR GPS in a CAR3 airplane for example is a Major Alteration not because of the equipment itself, but because it changes the type of operation to IFR under GPS, which requires a Flight Manual Supplement. The FMS itself requires either a Field Approval, or an STC if available. IFR GPS did not exist under CAR3 rules, so the FMS is the Major Alteration, not the GPS unit itself.

For some very long boring reading on Major Alteration definitions and the FAA working group that updated the AC's, see this:

https://www.faa.gov/regulations_pol...ittees/documents/media/AGAMcmmT1-01051994.pdf

 

[akoprivnik]

Years ago when getting regulatory information required a paid subscription and a microfiche reader, or a trip to the FSDO, confusion to what the regs actually said was understandable. Now where the answer is no further than the smartphone in your pocket taking literally a minute or two, what is the excuse for continuing to cite "regs" that don't exist? The definition of a major alteration isn't complicated, and it even states that alterations or repairs the don't meet the definition of major, are thereby minor. Pretty simple, yet some claiming to be card carrying AMT's for decades still struggle to figure it out.

A good example of this is the repeated claim that any change is major because it changed the original type certificate. Have these folks never actually read a type certificate for something like a cherokee? Apparently not, if they had they would have noticed stuff like switches, door stewards, battery cables, or in this case pitot heat, are not even mentioned. How are you changing something that didn't exist in the first place?

I remember a conversation years ago long before I was a card carrying AMT, when one of the old mechanics told me that basically any modification required a 337. I had to ask the obvious, if this is true why is the form clearly titled "MAJOR REPAIR AND ALTERATION". if it was for any alteration or repair, why does it say "Major" right there in the title? No answer...

Then there is repeated claim without any factual basis to back it up that in the event of an accident your insurance will be null and void when they discover your illicit led dome light bulb, or Napa alternator belt... Funny enough that this is entirely made up, but more puzzling, at least to me, is why some people care? Navigating the minefield of regulations and the exorbitant costs associated with airplane ownership is bad enough, without making stuff up to make it even more burdensome than it already is.

Jeff

Let's be clear. The FAA TC specs are a general summary of basic requirements for continued airworthiness reference when conducting inspection and verifying airworthiness for return to service. The type certification I am referring to are the documents to certify the aircraft configuration when new. It is obvious the FAA TC specs are not used to certify the aircraft. The manufacture certifying process involves conformity to approved data and drawings. This information specifies every nut, bolt and component installed on that specific aircraft. Every aircraft coming off the line may have numerous minor deviations that makes it unique to that aircraft.
The point for this long dissertation is the aircraft topping this discussion was designed, conformed and certified at "Birth" without a heated pitot tube. FAA TC specs have nothing to do with this issue. Piper confirmed there are no paths currently published to install a heated pitot tube on this serial number range of aircraft. But obviously, there are aircraft that have been modified. I included how my aircraft was modified in 1971. This can be used to give some guidance on size wire, CB, switch and amperage draw and can be used as a bases for signing off and returning to service. The argument is if this is a major or minor modification. It really comes down to the installing technician to make that call. Reference 14CFR Part 1 and Part 43 Appendix A. I would also confide in the IA you use for your annuals to make sure he/she doesn't shoot you down at the annual.
Good luck and fly safe.

 

[philiplane]

Let's be clear. The FAA TC specs are a general summary of basic requirements for continued airworthiness reference when conducting inspection and verifying airworthiness for return to service. The type certification I am referring to are the documents to certify the aircraft configuration when new. It is obvious the FAA TC specs are not used to certify the aircraft. The manufacture certifying process involves conformity to approved data and drawings. This information specifies every nut, bolt and component installed on that specific aircraft. Every aircraft coming off the line may have numerous minor deviations that makes it unique to that aircraft.

Actually, the FAA does not certify every nut bolt and detail of each plane and how it is manufactured. They only certify that the manufacturer complied with applicable rules for the plane and its' intended use for Kinds Of Operation. The FAA does not "certify" maintenance or parts manuals as part of the Type Certificate of the plane either. They accept them. That's it. That's why those manuals can be revised without Piper having to re-submit a new TCDS application when they change the part number of the alternator drive belt. But the FAA does use those TCDS specs when certifying the aircraft model, which covers weight & balance, performance, day/night VFR, IFR, and passenger seating. They just don't care what radios you have, what color paint there is, or whether or not your pitot tube is heated. The heated pitot is a Part 91 operating requirement for IFR operations. Not a TCDS requirement to manufacture the plane.

Asking Piper for blessing is also a dead end. They want to sell you a new plane. They have little interest in helping you modify a 60 year old product.

Always remember- MPSAWTD... Most People Suck At What They Do. You can ask for help from the "experts" and get less help than if you did the work yourself.

So the fact that a plane left the factory without a heated pitot tube does not doom it to never having one legally installed. The process is simple, and within the reach of your everyday A&P. He doesn't need Piper's blessing, or FAA approval, to perform this minor alteration. He needs a TSO approved AN5812-12 pitot tube, or the Piper blade style tube, some wire, a circuit breaker, a switch, and the ability to write a log entry detailing the installation.

 

[akoprivnik]

Actually, the FAA does not certify every nut bolt and detail of each plane and how it is manufactured. They only certify that the manufacturer complied with applicable rules for the plane and its' intended use for Kinds Of Operation. The FAA does not "certify" maintenance or parts manuals as part of the Type Certificate of the plane either. They accept them. That's it. That's why those manuals can be revised without Piper having to re-submit a new TCDS application when they change the part number of the alternator drive belt. But the FAA does use those TCDS specs when certifying the aircraft model, which covers weight & balance, performance, day/night VFR, IFR, and passenger seating. They just don't care what radios you have, what color paint there is, or whether or not your pitot tube is heated. The heated pitot is a Part 91 operating requirement for IFR operations. Not a TCDS requirement to manufacture the plane.

Asking Piper for blessing is also a dead end. They want to sell you a new plane. They have little interest in helping you modify a 60 year old product.

Always remember- MPSAWTD... Most People Suck At What They Do. You can ask for help from the "experts" and get less help than if you did the work yourself.

So the fact that a plane left the factory without a heated pitot tube does not doom it to never having one legally installed. The process is simple, and within the reach of your everyday A&P. He doesn't need Piper's blessing, or FAA approval, to perform this minor alteration. He needs a TSO approved AN5812-12 pitot tube, or the Piper blade style tube, some wire, a circuit breaker, a switch, and the ability to write a log entry detailing the installation.

How do you think aircraft get certified? Why do you think it takes years to get the FAA to certify a new design or new model that is added to the same model TC number. Of course the FAA certifies the design and data the manufacture presents to them. The TC specs are developed based on that data and are added to the existing TC number or a new number is issued. I never said the "FAA" certifies every nut, bolt and component. The manufacture develops and designs the aircraft. All drawings and data document the material specs for all parts and hardware. All data is presented to the FAA to review and to "CERTIFY" the design and documents. The FAA develops the TC specs. and issues a production certificate. Now the manufacture can produce (production) the aircraft and sell it to the public. Each aircraft must go through a conformity process to the "CERTIFIED" data, overseen by the FAA before the FAA issues an Airworthiness Certificate.
We really went off the main subject. Which is installing a heated pitot tube in an aircraft that does not have clear guidelines for installation due to serial number effectivity. Of course it can be done by an A&P. If it was done previously on a similar aircraft configuration, and it was blessed by the manufacture and the FAA, why not use it? You have all the information to include wire size, breaker size, pitot tube PN and a letter from Piper. The log entry just needs to state work performed and a statement of airworthiness and return to service. If you don't want to use the data I provided, install the system based on the AMM, IPC and AC43.13 using the serial number aircraft effectivity that the manuals cover for the heated pitot tube.

 

[Ray93J]

I thought running the wire inside of the wing was the toughest part of this job. Nope, it is the paper work.

 

[akoprivnik]

Yep. It ain't airworthy until the weight of the paperwork matches the weight of the aircraft.

 

[NorthernAviation]

Always remember- MPSAWTD... Most People Suck At What They Do. You can ask for help from the "experts" and get less help than if you did the work yourself.

This would be even funnier if it wasn't so true! It's actually why I decided to become an A&P/IA many years ago, I simply tired of dealing with mechanics wearing their ignorance like a badge of honor: I'm not signing off (insert your plane here) unless you (insert unnecessary expense here)... It became much easier when I could simply say, that's ok, do the work I asked and I'll sign it off myself...

Some of the more memorable exchanges with MPSAWTD folks:

Top the engine in a C182 because it was "weak". When I asked how the "weakness" determination was made I was told, during the runup it wouldn't drag the tires with the brakes locked. As I recall that "weak" engine delivered another decade of service before overhaul.

Overhaul the props simply because they were 6 years old. When I explanted the aircraft was operated pt91, I was told it didn't matter because it was a ME turbine. When pushed to show the relevant reg, it was shown a passage relating to ME helicopters... This one was with the FAA!

Replace the co-pilot side windshield at a cost of around $50,000 (heated glass) due to some delamination at the bottom even though it was well within the specs from both the manufacture of the windshield and the airframe. I was told the "inspector" didn't like it.

Replace 5K worth of batteries because it was "shop policy" due to the shop not having the required ($1,500) test equipment.

Most were just stupid claims we all have seen. I remember being told Rapco products could only be used on "home builts". This one came from a shop that wanted to buy brake discs from the airframe manufacture at over 10x the price as Spruce. Another time I was told I needed new wheels at $10K, this was years ago so I bet it would be probably $40K now. When I asked to be shown what the problem was I was shown one slightly oversize bearing seat on one half. When asked what was the problem with the other three, I was told it would be "illegal" to not change all four... Once again I offered to use my pen to return the plane to service; the shop changed only the defective part at 1/4 the cost.

This of course is nothing new, or only found in aviation. Last winter when I was gone my wife called to tell me we needed a new dryer because the control board was bad the the service tech said a replacement was unobtainable due to the inability to determine the correct model. I told her to open the door and look for a sticker in the jamb. A moment later a photo of the appropriate sticker appeared on my phone, a quick google search returned dozens of sources for a replacement. But without a doubt the best was when my wife's car, a Mercury Mountaineer developed a water leak. I hate fixing cars, so she took it to the local Midas. They told her the engine was "bad" and would cost more to replace then the car was worth. The mechanic then offered to "save" her the cost of towing if she would sign the title over to him instead. She obviously declined and had the car towed to my hanager. The knothead had rounded off the bolts resulting in his inability to remove the pump. I cut the heads off with a cutoff wheel, removed the pump, welded nuts to the studs to facilitate removal and replaced the defective pump. The most expensive part? Midas had put all the parts they removed in the back, but managed to lose the serpentine belt. The belt from the local Napa store cost more than the new water pump from Amazon! You can't makes stuff like this up.

It's difficult to not conclude events such as these are the result of folks simply being crooks. However, over the years I have decided malice and stupidity often look the same. The sad part is the dumber the technician, the more resistant they are to learning.

Jeff

 

[skitheo]

One of Piper's problems was that they made a lot of changes on the fly, and the paperwork did not catch up for some time later. The parts catalogs are great examples of that. You'll find planes with factory installed equipment, which was installed before the parts book shows eligibility. Or the plane left the factory without it, and the selling dealer installed it before customer delivery. In the 1960's Piper cranked out lots of basic planes and sent them to dealers. Where the final features would be installed, like radios, autopilots, heated pitot's, wheel fairings, etc. That's why you see that extensive list of Optional Equipment Kits in the back of the parts manuals. And nothing shows in the weight and balance & equipment lists because the dealer forgot to revise them. This is why you see so many crazy high useful loads in older weight and balances. They left the factory pretty bare, then the dealer installed 40 to 60 pounds, or more, of options into the plane. In an Aztec for example, the Lear L2B autopilot alone weighed 52 pounds, and the radio package another 40 to 70 pounds.

This is very common on any Piper built from 1960 through 1970, and even more so in the Cherokee line. In later years they did better.

Thanks for that explanation. It becomes very clear reading through my plane's log books. It's a '64 235, SN in the mid 400's. It was built with a fixed pitch prop, a 40-amp generator, only the light in the nose for a landing light and a bent tube for a pitot. Before it left Vero Beach, a constant speed prop was installed. Before it was delivered, Lane Air Service in Anniston, AL, installed a radio. A couple of years later the Cessna-style leading edge dual landing light was installed with a field approval. Somewhere along the way it was upgraded to a 60-amp alternator. In 2016 when I was going to move to Oregon, I had a heated blade pitot installed, including running the wire, adding the CB and switch, log book entry only. Dual static ports in the empennage retained. Also installed at the same time was an IFD-540 and NGT-9000, with 337's filed for each.

When I had it weighed for the first time after the TT/AC100 & Aspens were installed in December 2019, it magically gained about 80 lbs.

 

[partsguy210]

Please open attachment containing the 337 and data reference used to modify my aircraft back in 1971. You can use the 337 and letter from piper along with the paperwork from kit 757-004 and piper drawing 69046 to modify your aircraft.

Thank You!