Since many aftermarket products are certified under AML STC (thats blanket approval for a large number of aircraft models), the demand for FAA field approvals has lessened over recent years, but the process is complex. Field approvals require sizable amounts of paperwork and coordination on the part of the installer, while the aircraft owner absorbs the cost and downtime. Shops we talked with are frustrated with the process.
The FAA Flight Standards division declined our request for an interview, but agreed to respond to a written query about what the FAA is doing to ease the process of obtaining field certification, why some approval requests on the FSDO level are being passed off to ACOs and what its doing to ensure across-the-board standardization.
Weve noticed that an increasing number of approval requests cant be accomplished at the FSDO level. The FAA developed the Major Repairs and Alterations Job Aid to help walk inspectors through these issues. Interestingly, Some systems have new and novel features that will need additional analysis until the policy and guidance has been developed to allow broader installation approvals, we were told. Presumably, that policy and guidance will be in the new Part 23 and parallel regs. Its not uncommon for a FSDO or ACO to request engineering data (through a DER), system integration analysis and operational impact analysis. Thats fair enough, but these requirements can vary between districts and even among inspectors in the same office. The FAA said its addressing this by developing specialized focus teams to help provide technical support and guidance for installations.
With the FAA chomping at the bit to get the fleet ADS-B-compliant by 2020, Peter Ring at ADS-B manufacturer FreeFlight Systems told us field approvals for its systems that dont yet have AML approval are generally being FSDO-approved without difficulty. Perhaps the new approach is working. The FAA established an ADS-B focus team that provides a dedicated point of contact that has detailed technical and policy knowledge which field inspectors can use to ease the evaluation and approval.
Shops and owners can help streamline any approval by commencing the approval process early, perhaps before the aircraft even hits the maintenance floor; this way it doesnt become a hangar queen while the shop waits for approval. The installer should submit as much manufacturers data as possible, plus examples of other approvals and TSO or PMA data appropriate and applicable to the installation.
When the field approval requires the services of a DER for engineering analysis, get ready to pay. Approved engineering data for installing something as simple as an antenna could cost nearly $3000. Since many shops dont have a DER on staff, ask about additional certification costs and the potential for delays before committing to a project. Better yet, select equipment thats approved by an AML. That keeps the sign-off simple.