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Installation Certification by AD 3
- Thread starter kontiki99
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- Thread starter
- #21
All,
Sorry not to have been back for a while. There have been other pressing matters.
I haven't had time to read through the responses.
Here is a link to the NPRM ->
TCAS is installed on most of our fleets by 3rd party STC. I say 3rd party because they are not the operator or airframe OEM. The equipment OEM holds the STC in most cases, but maybe not all. I believe we may have one STC in the mix thats owned by a (Designated Alteration Station) we contracted with.
I'd like to obviate STC approval, revision, amendment, change, process, if possible, because it can take so much time. Working out agreements and getting them through legal can add almost a year to even the simplest project. We're looking at an accomplishment time of 48 months.
Thanks,
Sorry not to have been back for a while. There have been other pressing matters.
I haven't had time to read through the responses.
Here is a link to the NPRM ->
TCAS is installed on most of our fleets by 3rd party STC. I say 3rd party because they are not the operator or airframe OEM. The equipment OEM holds the STC in most cases, but maybe not all. I believe we may have one STC in the mix thats owned by a (Designated Alteration Station) we contracted with.
I'd like to obviate STC approval, revision, amendment, change, process, if possible, because it can take so much time. Working out agreements and getting them through legal can add almost a year to even the simplest project. We're looking at an accomplishment time of 48 months.
Thanks,
Ok, now it makes more sense. You have TCAS units that were installed as part of an STC. The STC calls for the TCAS unit by part number. The AD requires SB compliance on the unit that will roll the part number to one not listed on the STC. A repair station authorized to perform the AD/SB does the work and returns the unit to you with an 8130-3 return to servicee. Since the part number no longer matches the STC, you have no authorization to install the new part number unit.
First thing, have you made comments to the Federal Register with your concerns yet? You have until 2/11/2011 to make comments. FAA will have to answer those comments prior to issuing the AD, and there is where you will get your final answer.
When you make your comments, be sure to be clear and concise on your discription of the problem. Identify additional costs that are not in the NPRM that will be required to comply. They only used 2 hours @ $85 an hour. As I see it, you have to remove the unit, ship it to the facility that can make the repairs, recieve it back into your quality system, then re-install it in the aircraft at a minimum. f additional engineering is required for the STC, there are more costs associated with that. You also have down time and lost revenue.
Another concern I have is that the NPRM states "Traffic Alert and Collision Avoidance System (TCAS) units with the part numbers (P/Ns) specified in the ACSS service bulletins identified in Table 1 of this AD". I've never seen an AD that references a vendor document to identify the units that are impacted by the AD. This makes no sense, unless the aircraft operator has the SB, he won't know that the AD impacts him. The AD should identify by part number exactly what units are impacted by the AD.
All in all, this is one of the worst proposed ADs in terms of understanding the requirements.
BY ALL MEANS, SUBMITT COMMENTS TO THIS NPRM!!!!
First thing, have you made comments to the Federal Register with your concerns yet? You have until 2/11/2011 to make comments. FAA will have to answer those comments prior to issuing the AD, and there is where you will get your final answer.
When you make your comments, be sure to be clear and concise on your discription of the problem. Identify additional costs that are not in the NPRM that will be required to comply. They only used 2 hours @ $85 an hour. As I see it, you have to remove the unit, ship it to the facility that can make the repairs, recieve it back into your quality system, then re-install it in the aircraft at a minimum. f additional engineering is required for the STC, there are more costs associated with that. You also have down time and lost revenue.
Another concern I have is that the NPRM states "Traffic Alert and Collision Avoidance System (TCAS) units with the part numbers (P/Ns) specified in the ACSS service bulletins identified in Table 1 of this AD". I've never seen an AD that references a vendor document to identify the units that are impacted by the AD. This makes no sense, unless the aircraft operator has the SB, he won't know that the AD impacts him. The AD should identify by part number exactly what units are impacted by the AD.
All in all, this is one of the worst proposed ADs in terms of understanding the requirements.
BY ALL MEANS, SUBMITT COMMENTS TO THIS NPRM!!!!
- Thread starter
- #23
thruthefence
I don't understand how an AMOC would help in our case. I read through your hilarous vignett and do see where you are coming from. It's very interesting to me personally because I have recently been wondering if there was any merit to starting a company like Peckerwood. That question is probably best left to another thread entirely.
If I had to deal with that situation, I don't know exactly how I'd approach it. It's always difficult dig out the underlying facts in hypothetical situations.
I'm an avionics engineer for the 121 world, that's just about to get my instruments rating and I'm insanely driven to buy an airplane this year. It's obvious that a lot of small operators need help in these areas, but I wouldn't want a hobby pastime I truly love to become legal hell.
I don't think there is any money in starting another marginal me-to 3rd party avionics company either. There might be something in helping the Peckerwood customers, but! They might have made marginally uninformed decisions hoping to luck out on something too good to be true, and might be hard to collect from if even if you do excellent work for them on a bail out.
Does Peckerwood go on to surrender their STC to the FAA? What they might do to support the matter?
berkshire
I am going go back to the OEM holder and in the cases where they hold the STC, see if they plan to update the STC. Good advice, thanks. I need to get it done early in time to eval what they say and comment.
dgapilot
I really don't like the way the AD is written either. Listing SBs instead of explicitly listing specific part numbers will create problems going forward. I do a lot of AD research for aquisitions on older airplanes. In 20 years it will be impossible to determine if that AD has been complied with on a purchased aircraft, if it's not changed.
Those SBs may very well not be publicly available 20 years from now. I've already obtained a set and three have already been revised since the AD was drafted. Some are SBs written for military product lines.
I do plan to recommend that we comment on the AD. I'm still researching our own particular situation to understand what kind of obstacles we're facing, before I draft anything.
I don't understand how an AMOC would help in our case. I read through your hilarous vignett and do see where you are coming from. It's very interesting to me personally because I have recently been wondering if there was any merit to starting a company like Peckerwood. That question is probably best left to another thread entirely.
If I had to deal with that situation, I don't know exactly how I'd approach it. It's always difficult dig out the underlying facts in hypothetical situations.
I'm an avionics engineer for the 121 world, that's just about to get my instruments rating and I'm insanely driven to buy an airplane this year. It's obvious that a lot of small operators need help in these areas, but I wouldn't want a hobby pastime I truly love to become legal hell.
I don't think there is any money in starting another marginal me-to 3rd party avionics company either. There might be something in helping the Peckerwood customers, but! They might have made marginally uninformed decisions hoping to luck out on something too good to be true, and might be hard to collect from if even if you do excellent work for them on a bail out.
Does Peckerwood go on to surrender their STC to the FAA? What they might do to support the matter?
berkshire
I am going go back to the OEM holder and in the cases where they hold the STC, see if they plan to update the STC. Good advice, thanks. I need to get it done early in time to eval what they say and comment.
dgapilot
I really don't like the way the AD is written either. Listing SBs instead of explicitly listing specific part numbers will create problems going forward. I do a lot of AD research for aquisitions on older airplanes. In 20 years it will be impossible to determine if that AD has been complied with on a purchased aircraft, if it's not changed.
Those SBs may very well not be publicly available 20 years from now. I've already obtained a set and three have already been revised since the AD was drafted. Some are SBs written for military product lines.
I do plan to recommend that we comment on the AD. I'm still researching our own particular situation to understand what kind of obstacles we're facing, before I draft anything.
thruthefence
Aerospace
And sometimes, SB's are revised, often for no other reason then to correct punctuational. If the AD note doesn't say "or latest revision" for it's compliance. You may be stuck again at some later date.
now i'm confused (situation normal ?) ... is there an AD or are you anticipating something coming from the NPRM ?
won't the AD reference a particular a/c configuration or component ? it sounds to me as though you have an affected a/c but you've changed the config (with a 3rd party STC), and so aren't affected by the AD ??
now if your 3rd STC isn't compliant with the NPRM, that's a different question ... if the 3rd party won't fix it, then someone else has to.
won't the AD reference a particular a/c configuration or component ? it sounds to me as though you have an affected a/c but you've changed the config (with a 3rd party STC), and so aren't affected by the AD ??
now if your 3rd STC isn't compliant with the NPRM, that's a different question ... if the 3rd party won't fix it, then someone else has to.
Another thought, as written in the NPRM, it wouldn't comply with the Adminsitrative Procedures Act, as the vendor (L3 in this case) could revise the SB to include additional products and since the AD NPRM now only lists the SB and not the specific products, the requirement to modify the additional products listed in a revised SB would not have the benifit of going through the public comment and cost analysis required. The guy that wrote this NPRM is really screwed up!
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