AOPA Turbine Pilot Magazine - June 2020 - 14

LETTERS

LETTERS FROM OUR APRIL 2020 ISSUE

Quest for perfection
Readers reflect on the 310
I was delighted to read Mike
Collins' article in the April 2020
AOPA Pilot about "Building
the Perfect Twin." It struck a
familiar note because I had a
310 for many years. I bought
mine in 1974 and its number
was N62GS. That, after having
owned a Piper Cherokee Six for
many years whose number was
N622GS. We were a family of six
so we needed a six-seater, and
never mind the Piper Seneca
I had in between, which is the
only twin I had that came with
counterrotating props.
The airplanes I owned,
including of course the 310, took
my family on many trips domestically, to Canada, and to the
Bahamas. Happy to say that all
were free of significant incidents,
as indeed were all my flights-
day, night, VFR, IFR, so I must
have done something right.
I wish all the best to Cynthia
and John Bowman and may
they continue to enjoy their 310.
The article says that John is a
mere 70, which makes him just
a decade older than my oldest
kids (I am 91). I hope John does,
as he wishes, keep flying until he
is 95 and then some! I last took
my flight review in a glider, for
which I am rated, and the check
pilot was my son, a doctor, who
is also a flight instructor and I
passed with, ahem, flying colors.
George H. Spencer
AOPA 122610
McLean, Virginia

I cannot be the only one to have
thoroughly enjoyed the article
and the photography on John
Bowman's 310.
14 | AOPA PILOT June 2020

P&E

SAVVY MAINTENANCE

FINALLY!

Savvy Maintenance coverage
sponsored by AIRCRAFT SPRUCE

OPINION

Hot seat
Is it legal to install uncertified
equipment in a certificated aircraft?
BY MIKE BUSCH

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I RECEIVE AND ANSWER hundreds of emails
each week from aircraft owners, pilots, and
mechanics who have maintenance-related
questions. One I received several weeks ago
seems worth sharing:
Mike, I need your help. I am a member of
a flying club, and during the recent annual of
our club Skyhawk someone got the bright idea
to install automotive seat heaters in the plane
without an STC or Form 337. This seems like
it might be a violation of the regulations. Is it?
Why would our club's A&P participate
in the installation of uncertified equipment
and then sign off the aircraft as airworthy?
Should I question all the other work this
A&P performed? Should I report him to the
local FSDO?
This pilot's strong reaction was clearly
predicated on his understanding that all
equipment in a certificated aircraft must be
FAA-approved. Lots of aircraft owners and
mechanics believe the same thing. I've even
heard flight standards district office inspectors
say this. But this common misconception is
simply wrong.

IS IT INSTALLED?

Did you ever bring a suitcase along in your
aircraft? Did you ever use an iPad or portable GPS or handheld VHF transceiver in the
cockpit? Since none of these items are FAAapproved, did you violate any regulations by
doing so? Of course not. But why not?
The answer is that the FAA's rules about
certification of equipment apply only to
items that are "installed in or attached to
the aircraft." The uncertified suitcase you
stowed in the baggage compartment is
not installed in or attached to the aircraft.
Neither is a handheld radio or smartphone.
What about the iPad in its suction-cup
window mount, or the handheld GPS that
is clamped onto the control yoke? The FAA
has traditionally interpreted "installed
in or attached to the aircraft" as meaning
attached to the aircraft with a structural fastener. Suction cups, Velcro, elastic straps,
and wingnut clamps don't count.
This FAA interpretation has been
a blessing for pilots and aircraft owners. It's what allows us to use all sorts of

100 | AOPA PILOT April 2020

uncertified high-tech equipment aboard
our aircraft so long as it isn't screwed,
glued, or riveted to the airframe. That's a
truly wonderful thing.
So, what about a seat heater? A bit
of Googling revealed that there are two
kinds of aftermarket automotive seat
heaters available: external heating pads
that attach to the seats with elastic straps,
and internal heating pads that are inserted
between the upholstery and the foam padding (with some seat disassembly required)
and secured with adhesive strips.
The external kind, which is easily removable without tools, doesn't
qualify as being "installed in or attached to."
Therefore, it doesn't need to be certified. It
doesn't require an A&P's involvement. A
pilot can simply strap it onto the seat, plug it
into the cigar lighter socket, and fly off into
the sunset with warm buttocks and no concern about violating any regs.
During an annual inspection of the
aircraft, the external seat heater attached
with elastic straps would not be considered as an airworthiness item any more
than would an iPad or a handheld transceiver or a suitcase that happened to
be left in the aircraft while it was being
inspected. If it's not "installed in or
attached to" the aircraft, then the IA
doesn't need to inspect it.
But what about a seat heater that uses
internal heating pads mounted beneath
the upholstery and secured to the underlying foam with adhesive? That's a bit
more complicated.

IS IT A MAJOR ALTERATION?

By any reasonable interpretation, a seat
heater that uses internal heating pads is
"installed in or attached to" the aircraft.
This means that the seat heater installation
would qualify as an alteration to the aircraft's type design.
However, just because it's an alteration
doesn't mean that an STC or field approval
would necessarily be required, or that a
Form 337 would have to be submitted to
the FAA. Those things are only required
for major alterations; a minor alteration
requires just a simple logbook entry signed
by an A&P mechanic.
What's the difference between a major
alteration and a minor alteration? The regulatory definitions of those terms appear in
FAR 1.1 (Definitions) as follows:
"Major alteration means an alteration
not listed in the aircraft, aircraft engine, or
propeller specifications-
"That might appreciably affect weight
[limits], balance [limits], structural strength,
performance, powerplant operation, flight
characteristics, or other qualities affecting
airworthiness; or
"That is not done according to accepted
practices or cannot be done by elementary
operations.
"Minor alteration means an alteration
other than a major alteration."
In addition, FAR Part 43 Appendix A
paragraph (a) provides a list of the kinds of
alterations that the FAA considers airframe
major alterations: alterations of wings; tail
surfaces; fuselage; engine mounts; control
system; landing gear; hull or floats; elements

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AN INTERNAL SEAT HEATER could be
considered an alteration, but not a major
alteration, so no STC or Form 337 would be
required. It would need to be signed
off by an A&P with a simple logbook entry.

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aopa.org/pilot AOPA PILOT | 101

Just a quick note about Mike Busch's article
"Savvy Maintenance: Hot Seat." I thought it was
outstanding. I've been wondering about those
questions (related to installation of accessories) for a while and his explanation was very
well written. It was also a great opportunity
to address those kinds of wackos who would
report to the FSDO on something like this.
Good work!
Stephen Ratzlaff
AOPA 5496829
Seattle, Washington

It truly epitomizes the values so many of us share to see
so much love lavished on a
"lowly" 310, and the pride of
ownership and challenge to
perfection are inspirational.
The paint job, too, is a thing
of beauty, subtly suggesting
the tireless effort that went
into developing it. I certainly

hope we will see a follow-up
picture of the panel, with the
G500TXi, which I further hope
is going in the second stack,
replacing the Stormscope and
ADF, and not in the primary
position, replacing the beautiful six-pack.
Greg Faris
AOPA 3205929
Kissimmee, Florida

Fatal distractions

Great article ("Safety Spotlight:
Lessons from a Tragedy"). I am
a 26,000-hour pilot with airline
and helicopter/instrument, CFI,
CFII SEL, MEL. My gut is that
if you look at the timeline in
the pilot's entering the left turn
from the climb, I get the feeling
that his attention was not on the
instruments, but head-down in
automation/kneeboard.
I always teach "Get the dog
in the cage"-autopilot on HDG,
V/S-before allowing distraction to the automation. Too
many times I have found that
hand-flying in IMC only takes
a distraction for two seconds to
lead to a rollover event. It's like
texting while driving.
Robert Posey
AOPA 10003206
Newport Beach, California

Taking heat

What a sad state we are in when
a person's first reaction is to run
to the FSDO instead of asking
for a simple explanation from
the A&P ("Savvy Maintenance:
Hot Seat"). I can understand
the concern, but come on, let's
not kill the fly with a shotgun. I
have been flying for more than
54 years and owned and operated over a dozen airplanes.
When I had a question my first
stop was the mechanic, not the
feds to try to put a black mark
on a man's livelihood. It's unfortunate that in this tech age we
live in, we have lost the ability to
communicate with one another,
but I digress.
Don Trizzino
AOPA 3190233
Canton, Ohio

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AOPA Turbine Pilot Magazine - June 2020

Table of Contents for the Digital Edition of AOPA Turbine Pilot Magazine - June 2020