Or worse. One of the many time-consuming nags that tag along with major and even minor maintenance is preparing the supporting regulatory paperwork. It’s one issue that sends some of us flocking to the experimental world and it’s easy to see why. For the maintenance troops, filling out paperwork is a huge time and money burner (padded on to your maintenance invoice), but good logs make an aircraft stronger at resale. Maintenance releases, FAA 8130-3s, log entries and weight and balance reports is the standard for return to service by a Part 145 repair station or an IA. On the other end of the spectrum, there’s paperwork-intensive STCs or FAA field approvals. If you’ve bought an FAA approval, you know the value of the FAA signature that says your wings are legal. Rule-benders fly the aircraft (not airworthy, officially) while they wait for approval, and some have snatched their airplanes from the shop because they got tired of waiting. These days smart shops know not to start the project without the approval already in place. Modify it first and risk getting stuck with a hangar queen.
That was the trouble for a guy who called looking for advice because a shop tagged his twin unairworthy during a prebuy. At some point, an autopilot was installed, but there was no paperwork chase. It wasn’t even in the weight and balance. It was presumably installed during a major avionics installation. It gets worse. The autopilot wasn’t STC’d for the plane, and the GPS that was installed wasn’t approved (via its STC) with the autopilot. But, someone installed it anyway and let it go. Fortunately for the potential buyer (and unfortunately for the current owner), the tech doing the inspection understood the mod needed at least some paperwork. One thing led to another and when he couldn’t find a flight manual supplement for the IFR GPS navigator (another requirement), he dug deeper into the paperwork. When he couldn’t find the flight manual supplement for the autopilot (critically important to the pilot operating the aircraft), it was time to make some calls.
Since the mechanic doing the inspection wasn’t an avionics tech, and in an effort to save some paperwork costs (this is billed at typical shop labor rates, or higher), he tasked the aircraft owner to chase down the STC. Of course a call to the autopilot maker revealed that the aircraft wasn’t even on the AML (approved model list) STC for this autopilot. At this point the deposit-paying buyer was seeing red flags. If someone installed a major system like an autopilot without an STC (or even a signoff), what else is lurking under the aircraft’s skin? He walked away from the deal, while the owner was left standing next to an unairworthy cabin-class twin. They were doing the prebuy during the expired annual inspection, so it was stuck. We’ve all seen these hangar queens. You know, what could be good airplanes, but held ransom by FAA signatures and shop costs.
My advice was to get the FAA FSDO involved for a field approval. Yes, an inspector will come look at the airplane. Autopilots are tough. This one was approved for other twins in class, but not this rare model. Maybe with a good inspection of the installation and the right documentation (including previously approved data from a similar installation), the shop could build a solid field approval package and submit it for signoff as a one-time STC. The other option, of course, was to remove the autopilot and install one that was approved. There were few in the aftermarket that were approved, plus that wasn’t an option for the owner who was bailing out of the airplane after losing his medical. I lost track of the story, but I heard someone ended up buying the airplane on the cheap as it sat. Maybe they worked with an autopilot OEM for an STC.
As it’s been for a while, autopilot and flight control approvals generally aren’t handled at the local FSDO, but instead at the region’s governing ACO (aircraft certification office). The approvals I have been involved with haven’t gone well. One engineering package (commenced before the system was installed, smartly) sat at an ACO for over a year and was eventually declined, even though the paperwork was prepared exactly as a principal avionics inspector had suggested. The owner ran out of money and dropped the idea, but paid big for the effort.
Just keep up with the paperwork. Factor it into maintenance costs. This includes all logbook entries (including pitot/static and transponder inspections) and keeping all up-to-date flight manual supplements in the aircraft because they are an extension of the aircraft’s flight manual. And resist leaving the logbooks in the the airplane or with a shop. They have been lost, stolen and destroyed in hangar fires and hurricanes, never recreated as the originals. —Larry Anglisano
