Whats all This MAJOR vs. MINOR Stuff Anynow?

>At 06:46 PM 11/8/99 -0800, Stephen wrote:
>>I recently purchased an RST-564 audio panel kit and the RST-522 remote
>>mounted marker beacon receiver kit RST's position is that the 
>>installation shouldn't be considered a "Major alteration or repair" 
>>and so shouldn't technically require a form 337.  

Stuart replies:

>RST is correct.  Those who, like sheep, follow the FAA suggestions to sent
>in 337's 'just to be on the safe side' serve to reinforce the notion that
>such crap is required.  The FAA, like any union, likes to stay overworked
>and understaffed.  Then they can cry for more money and the union dues keep
>increasing.  That way the union bosses can borrow from the pension fund and
>get the mafia funded so that your children can get drugs and prostitutes.
>Please read the definitions of major repairs and major alterations found in
>FAR part 43.  If you do not have it handy, think of all the fun you will
>have looking it up.

  Last time I got into an arm wrestling match with a bureaucrat
  on major versus minor, he dug out the following:

  ----- the government official opened The Word and he sayeth:

  Sec. 21.93  Classification of changes in type design.

    (a) In addition to changes in type design specified in paragraph (b) of
  this section, changes in type design are classified as minor and major. A
  "minor change" is one that has no appreciable effect on the weight, balance,
  structural strength, reliability, operational characteristics, or other
  characteristics affecting the airworthiness of the product. All other changes
  are "major changes" (except as provided in paragraph (b) of this section).

  ----- here endeth the reading of The Word------

  He allowed as how I was adding hardware that changed "weight and balance".
  I allowed that every time a pilot climbs aboard along with passengers
  fuel and baggage, that the weight and balance of the airplane was
  changed . . . and that 21.93 was refering to the "weight and balance
  envelope" as published in the POH. I pointed out that many changes
  to aircraft over time can alter the manner in which the airplane may
  be loaded in the future (add a/c equipment in the back makes it difficult
  to fly with more than children in back seat) but that the performance
  charateristics of the airplane were unaltered. It was up to PIC to
  calculate w/b for every proposed flight and make sure he stays inside
  the envelope. It mattered not whether changes to empty w/b were from
  adding passengers, fuel and baggage or adding a radio to the panel.
  He counters with "if the rule meant weight and balance envelope, it
  would have SAID weight and balance envelope. All it says is weight
  and balance . . . period. Ergo, fill out the 337 you ignorant and
  insolent  . . . ." Well, he didn't say it exactly that way but
  his tone of voice and demeanor made his thoughts very clear.

  How about a petition to the FAA for an change to 21.93 to say "weight
  and balance envelope?"  But the next hassle will arrise over operating
  characteristics . . . obviously an airplane with a radio "operates"
  differently than one without . . . and here we go again . . .

  Another sticking point has been found in FAR43 as follows:

  ----- the government official opened The Word and he sayeth:

  Appendix A--Major Alterations, Major Repairs, and Preventive Maintenance

    (a) Major alterations--(1) Airframe major alterations. Alterations of the
  following parts and alterations of the following types, when not listed in
  the aircraft specifications issued by the FAA, are airframe major
    (i) Wings.
    (ii) Tail surfaces.
    (iii) Fuselage.
    (iv) Engine mounts.
    (v) Control system.
    (vi) Landing gear.
    (vii) Hull or floats.
    (viii) Elements of an airframe including spars, ribs, fittings, shock
        absorbers, bracing, cowling, fairings, and balance weights.
    (ix) Hydraulic and electrical actuating system of components.
    (x) Rotor blades.
    (xi) Changes to the empty weight or empty balance which result in an
        increase in the maximum certificated weight or center of gravity
        limits of the aircraft.
    (xii) Changes to the basic design of the fuel, oil, cooling, heating, cabin
         pressurization, electrical, hydraulic, de-icing, or exhaust systems.

  ----- here endeth the reading of The Word------

  Paragraph 43(A)(a)(xi) supports the notion I posed on the interpretation
  of 21.93 but in paragraph (xii) we see the words "Changes to basic design." 
  Again, we have vague wording that allows the uneducated to assert that
  any alteration is a "change to basic design" . . . I've proposed to several
  FAA types that the addition of an essential bus to a light aircraft requires
  only a re-arragnement of the breaker panel using hardware already on the
  airplane's TC, the addition of a switch already on the TC, the use of
  wire already on the TC and the addition of a diode (the most rudimentary
  of semiconductor devices with no unknown or questionable characteristics).
  That the addition of said bus creates no new hazards to flight and offers
  demonstrable enhancements to safety and should be allowed at owner discretion
  as a minor change to the aircraft. I was informed that the change was
  not only a "major" change to "basic design," that I would be guilty of
  blasphemy should I suggest that large numbers of airplanes get this change
  on a 337 . . . an airframe by airframe STC was called for (which would
  also require filling out a 337 when the STC was installed). I would also
  be changing "operating characteristics" which requires a POH revision.
  One guy even suggested that some time with a flight instructor might be
  called for . . .to check out the pilot on new "emergency procedures."

  It's obvious to me that the only way we'll see a clear pathway 
  to modernization and improved safety in light aircraft is to press 
  for the de-certification program being evaluated in Canada.
  Until we get the FAA out of our hip pockets, GA light aircraft will
  continue on the present, inexorable slide to antiquity and small
  notations in history books. "Yes my grandson, there was a time when
  peope flew their own airplanes! Can you imagine that? Ordinary people
  could get into a machine and experience the ultimate freedom . . .
  but that was ages ago, now EVERBODY flys all SAFELY in the loving
  and caring arms of GOVERNMENT and those horrible little machines of 
  yesteryear are but a dim memory . . .Would you like to go visit the
  museum? Grandpa can show you one. . . ."

  Fly comfortably.

  Bob  . . .