Avionics News July 2013 - 15

alteration), then by regulation (14 CFR Part1), the alteration
is a minor alteration.
In fact, the FAA Advisory Circular 43-210 lists 21 sources of
approved data, while FAA order 8900.1, volume 4, chapter 9,
lists 22 sources. Since AC 43-210 is actually a little more than
nine years old, you must combine the two documents to actually identify all of the usable sources of approved data. The five
most often used sources of approved data are STCs and field
approvals plus data approved by a designee (DER or ODA),
approved service bulletins and, finally, AC 43.13-1/2 series.
Assuming the data package is complete – that is, the data
package covers the entire alteration – each source is equal to
the others. No one source is preferred over another. A field
approval is not preferred over DER approved data, and an STC
is not preferred to an approved service bulletin. If complete,

than seven figures, or $1 million; they are not ideal for any
aircraft worth more than $1 million. And third, it takes a huge
amount of resources for the AEA membership to keep up on
the rapid pace of technology advances, resources the FAA
simply doesn’t have. Your inspector may not be familiar and
comfortable with the advanced technologies, and certainly
not the interfaces of these technologies. When the technology
exceeds their comfort level, this is the ideal project to contract
with an FAA designee.
Let’s get back to the scenario where you asked for your
inspector’s advice before you did your homework. Under no
circumstances should you ask your aviation safety inspector
a question and then disregard the answer without having a
conversation with your inspector, explaining your research
and your conclusion. This is probably one of the most
difficult discussions an avionics shop
can have with its inspector. You asked
So if you are not in compliance, you not only need to
for their advice, didn’t like the answer,
and then asked around until someone
know that you are not in compliance, but you absolutely
gave you the answer you wanted. You
need to know ‘why’ you are not in compliance, as
then chose to follow the “better” advice,
well. If you do not know ‘why’ your actions are not in
while the inspector who has oversight
for your operations believes the advice
compliance with the regulations, you cannot amend
he or she first gave you. At this point,
your business practices to be in compliance.
human nature believes you are cheating
the system. You were told the alteration
all sources are equal. The one limitation, as well as an area of
was major, and you chose to treat it like it was minor; you’re
confusion, is the approval of flight manual supplements. With
cheating the system.
a few exceptions, most flight manual supplements will need
A better answer is to do your homework first, then evaluate
to be either approved by the local Flight Standards District
the alteration and determine the correct approach. Then, and
Office (if it has been delegated the authority for this particular
only then, have the discussion with your inspector. If he or
technology), or they are forwarded to the responsible ACO.
she doesn’t agree with your proposed level of alteration, then
In these cases, the data can be approved via one source even
the question becomes a technical one: where is the analythough the FMS is processed as a field approval.
sis wrong? You can show why “your” alteration is minor;
So, if an ASI is uncomfortable offering a field approval
your inspector can either agree or show where your analybecause their unique knowledge skills or experience doesn’t
sis is flawed and why “this” particular alteration is major.
qualify them, simply turn to a qualified designee. The AEA
Remember, with few exceptions, the determination of major
has a listing of designee members in its members-only section
or minor is unique to your alteration, your specific project, not
of the website.
a generic statement of technology.
If you have attended any of my major/minor alteration
Also remember, it is your right to understand the governpresentations in the past decade, you know my feeling about
ment mandates – it is “right to question your government”
field approvals. First, they are a good tool for recreational airwhether it is about repair station operations, evaluating an
craft; they are not ideal for business aircraft. Second, they are
alteration or a specific maintenance task. If you don’t undera good tool for nonbusiness aircraft with a hull value of less
stand, ask. q
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Avionics News July 2013

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