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chanik

Position light and battery upgrades and fixes

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Well, my argument was more that part 21 doesn't read to the responsibilities of owners or mechanics but basically, I agree.

To be fair, I'll paraphrase Edsel's precise response though: 14CFR21.190 c2 The OEM must "State that the aircraft meets the provisions of the identified consensus standard"

He didn't say but to identify it, they would have to refer to 8130.2G, http://www.faa.gov/regulations_policies/orders_notices/index.cfm/go/document.information/documentID/324850

That points them to ASTM F2483 and section 05 in particular says parts should only be supplied through the OEM (according to Edsel. I haven't bought that document so have not read it myself).

It is a thin line of legal argument but in any case, the debate would be about whether FD has acted properly. If there is a violation in there it would be theirs.

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Chanik,

I do have a copy of the ASTM F2483-12. It requires that the aircraft maintenance manual include sources to purchase parts, ref. ASTM F2483-12 (5.1.1.2). I cannot find any other reference in this standard that speaks to requirements on where to purchase parts. All this not withstanding, even if the relevant ASTM did have an expressed requirement on where to purchase parts, and the aircraft mfg. included it in their maintenance manual (as they are required to do via the 21.190 rule), it would still not be regulatory for us in the field.

The reason I continue to push this issue, is because this line of reasoning is the same one that the FAA tried to take on the Rotax training requirement. They basically said that because 21.190 requires the mfg. to create maintenance and inspection procedures IAW ASTM F2483, and this standard includes task specific training requirements, that these requirements become regulatory. This obviously not the case. That was the beginning of the debate that eventually led to the Carol Carpenter chief counsel opinion letter. Unfortunately, that opinion fell short of the mark, by only addressing the specific training issue. The broader scope is that while ASTM are FAA accepted, only the specific parts of the standards referenced by FAR, are regulatory. Since ASTM is not referenced anywhere in part 43, maintenance is not held to it. ATSM is of course referenced in part 91, but as far as I can tell, these references relate to design issues only.

I agree with you, that if FD omits any of the required items within ASTM F2483 from their maintenance and inspection procedures manual ( including sources for parts), they are in violation of 21.190. Maybe I have misunderstood the general opinion in this discussion, and Ford's answer to you. If he is saying that we must buy parts from the mfg. and is using the 21.190 rule as the basis for this requirement, he is wrong.

 

Also, I tried to contact Rebecca MacPherson (FAA chief counsel's office) about two months ago on an unrelated issue. They told me (I don't remember who I talked to) that she is no longer with the FAA. Ed Averman (ed.averman@faa.gov) is someone I have used in the past. He helped me during the whole Rotax training requirement saga.

 

Doug Hereford

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Doug, just to clarify, does that mean that we can substitute parts from another manufacturer?

For instance, the seal on the access for our fuel tanks calls for Hylomar Blue. There is no part number related to this, but I believe Permatex (they no longer have a Hylomar product) makes something similar. Common sense tells me not to use it, but am I legally bound to use what the OEM specifies? Or, can I substitute better position lights than those that are specified?

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Doug,

My opinion is that you are legally bound to use what P/N the manufacturer specifies. I assume you are SLSA. The examples given earlier, I completely agree with. If the mfg. calls out a certain P/N seal, but the gives ref. to standard seal material, you could use any P/N that meets the identified standard. If the mfg. calls out a certain P/N position light (assy.) or lamp, but then references a standard P/N, then you could use any lamp or assy that meets that standard. However, if the mfg. only gives their specific P/N, that part must be used (unless you get permission from them to alter the product by using another part).

The previous example given about hose (DIN something or other) said it much better than I just did.

As for where you choose to procure the subject parts, that is your choice. Someone may argue traceability. Like I said before, the burden of proof and liability falls on the mechanic. If I say that I used FD P/N: XYZ, but bought it from Joe-Blow's airplane salvage, I need to be in a position to prove that it is an approved part.

 

In your specific example of position lights, my opinion is that no matter how minor you feel the change is, or how much better you think they are, do not install them without approval from the mfg. You as the mechanic/repairman may not be breaking any rules by installing them (assuming you use accepted methods, techniques, and practices) however, I believe that you put the operator in a position to break 91.327 each time he/she flys the plane.

 

Doug Hereford

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Edsel did start by claiming the aforementioned legal requirement but he ended up being fairly doubtful of that initial position by the end of our discussion. Now, it would not surprise me to find that the ASTMs conflict with themselves in different parts.

 

Doug, you cannot make substantive part changes because part 43.7 and elsewhere, the manufacturer must approve any changes. So an LOA would be needed.

 

I would tend to defend FD even further though and say that FAA violating them based on F2483.05 would be a dubious legal proposition. There are two flaws in that argument, one serious and one fatal.

The serious one is that 21.190 c2 is both overly vague and overly broad. As you mentioned, there is no specific path to the requirement, just 'the consensus standard' And there is a ton of ASTM stuff to read so making them strictly answer to all of it is unreasonable and impractical and regulations do get voided for that reason in court.

The fatal flaw is that Edsel's argument is an example of the exact problem with the MacMillan interp that blows a hole in the SD process and Carol's interp., and the rotax mandatory training legal decision: All of these fall to the illegal delegation of rulemaking authority away from the govt entity (the FAA). ASTMs are living documents outside of FAA direct review or approval. They therefore may not add, modify or restrict ANY regulations. 14CFR 21.190 c2 would not survive a legal challenge. But since the FAA has admitted to not going after anyone on it, it is likely never to face one.

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I agree with you both, I just wanted to clarify. I am an LSRM but I only work on my own plane, never-the-less, I do not change things without clear approval. Eventually I may go ELSA. If I do it will be for safety reasons - such as the position lights. My hope is that FD will find a way to approve better ones. I have seen what the CTLSi uses and they are a marked improvement.

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I got an MRA from FD today, but only for my aircraft.  If anyone else wants to upgrade, pretty much follow the instructions I posted.  Use solderless connectors. Document what you did, and submit a form and $120.

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I have looked into the most recent position/strobe lights from AVEO.  They now sell an updated ESeries LSA position light.  I would like to upgrade my CTSW factory position lights with lights that include a strong strobe and think these AVEO lights would be a good choice.  As with the other AVEO lights discussed here, these too appear to have a really low amperage draw and the factory wiring should be capable of supply the needed current.  Any comments on this would be appreciated.

http://www.21stcentury-usa.com/aveo/aveoflash/positionlights/

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This is why I recently went ELSA, I can change common sense items such as lighting without begging for permission. I can also modify things in accordance with acceptable methods used on certified aircraft such as rewiring the center panel switches that are wired incorrectly, at least on the CTSW. Switches take A+ from buss bar and send it to the circuit breaker, then to the appliance. If the switch shorts the wire burns or the entire electrical system fails. What were they thinking.

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Madhatter, if I read my wiring diagram correctly for my CTSW, it shows A+ first going to 30A breaker, then from there power splits and goes to starter relay, to the capacitor and to the instrument panel 25A breaker.  From the 25A power goes to ign. switch and to breakers for instrument panel.  After the IP breakers, the power goes to switches.  It appears that the IP breakers would trip, should a switch short out.  Am I reading this wrong?

Roger, I'll give you a call next week to discuss position lighting.

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It seems the Aveo lighting prices have come down a bit.  The link Dick posted shows $795, IIRC they were about $950 a couple of years ago.  This is definitely on my short list of upgrades, the factory lighting on the CTSW is pretty dismal. 

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My CTSW switches take A+ from the off side of the switch from a daisy chained wire buss then to the circuit breaker then to the appliance being run. If the schematic shows otherwise, then someone did not follow it. My circuit breaker wires are a rats nest of spade connector wiring. I am going to replace all circuit breakers with Klixon breakers and a real buss bar split for avionics master just as I have done in a lot of aircraft. I am also going to add a ground buss instead on two bolts with 30 ground wires on them. I'm sure the original is all fine for day vfr but I intend to do light IFR and night flying. I don't need electrical surprises at night. I have worked on certified aircraft for 45 yrs and it is hard to change to Ace Hardware quality (no offense to Ace Hardware)

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It wouldn't surprise me. The CTSW seems to be seriously haphazardly wired, very inconsistent with the wiring diagram. I have one that I work on that is the same way.

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4 hours ago, FlyingMonkey said:

. . . the factory lighting on the CTSW is pretty dismal. 

Concur, especially for the CTSW.

I would really like to see a good LED landing light alteration for the SW. Probably not likely though, as serious cowl work would probably be required.

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Hi Dick,

In 2013 I installed Aveo POWER BURST position/nav/strobe LED lights and received the MRA approval in 2014. I really like them, they are an unbelievable improvement  over the original units. If you or your mechanic ( forgot his name but went to LSA repairman school with him) decide to make the change give me a call. There are two things I learned the hard way that I would like to share with you in hopes you wont also learn the hard way. My cell is 218-343-5877

al meyer

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Madhatter, neat landing light installation.  Very creative and must work really well.  I figure you already have the circuit diagram for the standard CTSW and don't even want to bother looking at it but if you do, I've got the PDF of it.  My 2006 CTSW is all steam and pretty simple.  The diagram is simple for my plane and I'm sure that the A+ first goes to breakers then to switches if my CT is wired in accordance with the diagram!.  You are totally right about the general layout of wiring.   I'd like to take the wiring out and start over but it ain't broke (for the time being) so I'm not fixin'.

Al Meyer, I do recall your name.  Would it be Paul Plumley who attended the LSRM classes with you?  Thanks for the offer for information.  I'll give you a call.

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Basic wiring of circuits for aircraft are all the same for the usual appliances whether a C150 or C340. It is pretty straight foreward . It is very important to make sure there is as short as possible distance from A+ buss to the circuit breaker so there is less chance of short in- between which will take out the main breaker or burn the wire. I suppose it seems easy to me because I have done this so long. The hardest part is lying under instrument panels for hours, (Cessna 340's are horrible.)

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Most cessnas are horrible though.

As are piper and mooney panels (older models)

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