Numerous threads have identified that acquiring a field approval is near impossible with the current climate in regulation. It didn't used to be this way in the past, especially when a modification was backed up by frequent or repetitive application on many aircraft.

My question is, when did the denial of most all 337's begin and what caused that shift in that level of denial?

The new Field Approval guidance started in 2016, I believe
From the painful process we went through...we were involved from late 2015 until August 2016.
More time was spent trying to locate our paperwork as it crawled through the system that people actually reviewing the submission.

I can only draw the conclusion that "liability" was the reason for the change.

(We were given a "NO" answer...no details. Our data was submitted with DER data and previously approved 337s)
We decided to not pursue it any further at that time due to complete lack of communication with FSDO, ACO as to what information/documentation was needed for approval.)

Is it possible that the reorganization of the FSDO's was an influence in this? Since some FSDO's were more practical about 337's while others had a reputation for denying everything, this disparity between offices could have brought about the reorganization. So as a result, all sense of practicality has been eliminated and the door is closed to any technical innovation that wasn't on the original TCDS. It would be interesting to see if any of the aviation advocacy efforts are focused to this issue.

Or worse yet, maybe this is just another nail in the coffin for GA that paves the way for pilotless drone replacements...

Opinion only....having been around the 'government system' since the late 70's , what I have noticed is a trend for people in any position of authority, to become almost dictator like. More control and 'do it my way or else' type of attitude. It's very hard to get much accomplished when we have this authoritarian attitude. Then the minions under these figureheads, interpret the rules however they feel fit with little to no leeway. There is the occasional one that will help or work with you, but it seems to be getting to be the rarity rather than normalcy.
A few years ago, when I owned a Champ, I piece together better brakes for the plane. Those old Van Sickle's were nearly worthless. After approaching several different IA's about it, they all replied that since the rules have changed, it was nearly impossible to do the conversion except for getting the insanely over priced STC'd kit from WagAero. I wasn't about to spend $5K+ just for better brakes on a plane that was worth mid $20K. I will say, that the FAA guys up in my area do seem to be a little more helpful than other places I have lived. Maybe it's because the area is still pretty much rural and they have some common sense.

I am slowly getting away from the certified segment of aviation and delving into the experimental side. Much less of a headache when ever I want to improve or modify something. Wanted more HP on my RANS, easy, ordered a set of Zipper cylinders from Hal. They come in a box, I upack them and go about installing them. No need to worry about every nut and bolt's tractability, or if all the i's dotted and t's crossed. No worry about whether or not the local FSDO will approve it after month's of back and forth paper shuffling. I just fill out the log books and go flying.

Am I a conspiracy theorist that thinks it is all about control? No, just tired of over controlling people with a 'title' that what to rule every aspect of our lives.

I too have noticed what WW Hunter stated above. I think that most new bureaucrats just want to show up for work, make no waves, put in their time then collect a pension. To really serve their employer, us, is not a high priority.

Tim

Wow. Well said. Thank you. It's a crying shame. Isn't it? How can the employer (us) have a say in this?

Jim

Here in Siskiyou County there is an empty hanger at KSIY that used to have a mechanic and it was the FBO. It is really run down at this point and has been vacant for over four years. I local mechanic has been trying to lease it for that long. Seems like everybody at the county level is walking around in 90 SAE gear lube. We have been trying to get electricity to the hangers in Weed (O46) for over 15 years. We even volunteered to do the work as one of the hanger owners is an electrical contractor and I have a backhoe. Pathetic

Tim

This is what I'm talking about:

Gunny: "The local FSDO basically wanted me to complete an STC application with testing and all sorts of stuff. I was never totally convinced that I wanted GY26's and the prospect of spending all that money/time only to see if they met my mission was a hill to great to climb for me"

The fact is there is literally hundreds of this type of aircraft out there using that size tire on a field approval and his FSDO is imposing this amount of bureaucratic resistance. Where is the logic in this?

Here is something from Boy's Life 1920 that may help explain it. Oh and Boy's Life is a magazine from Boy Scouts of America

"The Boy Who Can't"

Hey, fellows, come closer, let each of us name
The worst kind of nuisance – we'll call it a game.
"I vote for the fellow who's never on time!"
"The fellow who always would borrow a dime!"
"The chap who takes pleasure in starting a fight!"
"The geezer, while camping, who snickers all night!"
Yes, those pests are terribly trying, I grant,
But I'll cast my vote for the fellow who "can't."
He can't rig a fish-pole, he can't take a hike,
He can't cook a flapjack or tinker his bike,
He can't learn to signal, he can't do first aid,
Can't do without candy or pink lemonade,
Can't follow a trail and can't lace up his shoe,
Can't do a blamed thing that you want him to do!
Oh, boy, I'd be happy if I could but plant
A swift kick on the rear of the fellow who can't!
He can't get his grammar or spelling or math,
Can't split his kindling, he can't take a bath,
He can't help his mother, he can't use his head;
Can't rise in the morning and can't go to bed,
He can't find his collar, he can't tie his tie –
He never knows what he could do if he'd try –
But repeats all day long his monotonous chant:
"Oh, Mamma; oh, Teacher; oh, Mister, I can't."
There's great need in the world for the confident man
Who tackles his work with a hearty "I can!"
So, if you would succeed and find living a joy,
Just learn how to do things while you are a boy;
For the boy who refuses to work when he SHOULD,
Loses the power to work when he WOULD.
Weakness and softness his talents supplant,
And he finds at the test that he REALLY CAN'T.
From Boy's Life, c. 1920
By F. J. P.

Bet the guy you are talking to was never a Boy Scout or the Military

Tim

FYI, there has for years been internecine pissing contests between the Flight Standards Division of FAA and the Engineering Division.

For years, Flight Standards saw the difficulty, or rather the impossibility of getting the Engineering Division to approve ANYthing. And, there is no question.....it is the Engineering Division’s responsibility to approve modifications to airplanes, NOT the Flight Standards Division.

So, at some point, Flight Standards Inspectors and managers got fed up with the inaction on seemingly reasonable proposals for modifications. At about the same time, in Alaska at least, Flight Standards realized that there were a lot of illegally modified airplanes out there, and many if not most of these mods were not necessarily bad mods. Just no paperwork to make them “legal”.

The Flight Standards Division started a program to get as many of these planes “Legal” as possible, by using the field approval system, which, by the way, was never intended to be used as a regular means of approving modifications.

So, the FSDO’s managed to develop a good working relationship with Aircraft owners, and perhaps more importantly, with mechanics, by routinely approving many modifications, both minor and major. And, since it was so easy to get field approvals, Flight Standards encouraged mechanics to field approve EVERY mod, even “minor” mods, which should have been simply approved with a logbook entry. Hence mechanics who are scared or at least reluctant to sign off even the simplest mods with a logbook entry. Our mechanics became FAA trained. And threatened.

But, at some point, the Engineering Division sees Flight Standards approving all these modifications, via field approvals....and they know field approvals were never intended for this. So, they start raising Cain within the organization. Effectively, Flight Standards had taken over Engineering’s responsibility, using a system (field approvals) never intended for this purpose. Never mind that Engineering wasn’t DOING it’s job in any case.

So, Flight Standards got spanked by the boss, and told to back off field approvals for “major” mods. But that also opened a door for Flight Standards Inspectors who were becoming more concerned about personal liability........like what happens if I field approve a mod, and someone is killed in that Plane? Will they sue me because I’m not an Engineer, yet I approved a modification?

And, that is essentially the “perfect storm” that field approvals are now in.

MTV

When we had our inspection on our homebuilt Rans in 2015, I was talking with the inspector (FAA) about this very thing and he said that Juneau still had the stones to do field approvals. Not sure what the case is today.