FAA Requires 337 for Modification Removal

Mods, approval, 337's, STC's, fun with the Feds.
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Hottshot
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Post by Hottshot »

As long as you have it in writing from said FED I say go for it! lol

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Vtaildriver
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Post by Vtaildriver »

Hi Andy,

Try and get a "letter of concurrence" from your local FSDO. I am waiting for my local FSDO to issue me a letter to install the 26" GoodYear's via logbook only (taken only 6 months). Whats funny is that I submitted a 337 with three supporting 337's showing 26's on Maules, my PMI told me that a 337 was not needed yet I still insisted that I wanted a paper trail from the FAA. He told me that the office will issue me a letter of concurrence stating that they "concur" that the tire install can be performed via log book only.

Submit a letter to your PMI stating that "you" believe that the tire install does not require a 337 and can be performed via logbook only. If they "concur" they will issue a letter back. It allows you to put something in your logbook and have some backup if SHTF and you end up trying to defend yourself. If you get no where just fill out a 337 and data package and submit.

Chris

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Andy Young
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Post by Andy Young »

The Anchorage FSDO said "not sure where that guy (Denver FSDO) is getting his info, but 337 is required". Also, reading yhe STC reveals that IT references submitting a 337, so there you go...

Anchorage FSDO did concur with putting a statement on the 337 about all future swaps between this and previous comfiguration being done by log book entry only. So I'll just do that and presumably be done with it.

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Vtaildriver
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Post by Vtaildriver »

I re-read your original post, I must have overlooked the STC part that you had listed. :shock: . You definitely should file a 337 since an STC in the eyes of the FAA is considered a major change in type design requiring a 337.

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Wyflyer
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Post by Wyflyer »

Andy please keep us informed how this goes. Also any W/B changes. I'm ordering a set of brakes and wheels too, and plan to swap them on and off with my 8.50's, depending on the mission
we allow darwins law to take its course. -chris erasmus

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Andy Young
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Post by Andy Young »

Wyflyer wrote:Andy please keep us informed how this goes. Also any W/B changes. I'm ordering a set of brakes and wheels too, and plan to swap them on and off with my 8.50's, depending on the mission
I ended up submitting a 337, and did put a statement in there about doing the ongoing swaps between the 31s and 8.50s with a log book entry. I'll let you know if I hear anything back from the FAA on that, but I don't expect to.

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andy
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Post by andy »

Andy Y., the reading that I got from my IA is that the 337 is required when installing the bushwheels since there's an STC involved. When you swap the 8.50x6.00 tires back, only a logbook entry and weight & balance change sheet are required. I didn't check this out with the Charlotte FSDO so it doesn't really answer your question. Sounds like a good idea to put the swap language into the original 337, though.

As far as the FAA knowing the aircraft's current configuration, around here most of them want to see copies of the 337s in the aircraft in case of a ramp check. I keep mine in the back of the POH along with the STCs and supplements.
Andy
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aero101
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Post by aero101 »

337's, STC's, nor logbooks are required for a ramp check, these are all part of aircraft records... Part 91 very specific (ARROW) on what must be carried in the aircraft. The only exception I know of for having 337 onboard are when you have ferry tanks installed, or carrying external loads, (these 2 items require issuance of temp AW Certificate) and these are specified in original 337 before it will be approved. I also believe this is all specified in the inspectors handbook. If he got questions, he can certainly request to see the logbooks at your convenience. If you specify on 337 that an installation will be removed or reinstalled at owners preference or depending upon season, such as ski's, tires, floats, etc that is perfectly legal. If not specified, technically you need to do a new 337 every time you remove something that was installed on 337, although this really isn't enforced to speak of most locations...
Jim
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