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The point John makes is a good one, though it takes some background to
understand.
 * "Major repairs and major modifications are defined in Part 43,
appendix A."  This lists what "Major" is, and says everything else is
"Minor."  Thus, Major and Minor is subject to interpretation, and can
only be understood via A&P school and finding out what your FSDO will
accept.
 * There is also the discussion about "Airworthy."  To wit:
"Unlike Seaworthy, airworthiness has two aspects; one of which is 'save
to fly.'  The other, 'conforms to the type certificate as issued and/or
as amended' is where people get tripped up."
           Percy 

-----Original Message-----
From: John Cooper [mailto:[EMAIL PROTECTED] 
Sent: Friday, June 30, 2006 9:46 AM
To: [EMAIL PROTECTED]; Tech
Subject: Re: [COUPERS-TECH] C-75 to C-85 upgrade.

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At 11:25 AM 6/30/2006, [EMAIL PROTECTED] wrote:
>an engine upgrade does not require a 337 (I am glad it doesn't), but 
>installing shoulder harnesses, strobes, and a 20 amp generator do...
>
>I guess I am still too new to aviation to understand how FAA
regulations work.


Not trying to defend the FAA, but, this one's not that hard to
understand.

Continental has published procedures for changing from a C75 to a C85.
No major components are involved, hence it qualifies as a minor
modification.

Erco never published anything addressing shoulder harness and it
involves potentially structural modifications to the airframe, hence it
is a major modification.  Similar logic is applied to the electrical
system.

My experience is that many 337's are filed that are not required.  On
the other hand, many modifications that require 337's don't get them...

Major repairs and major modifications are defined in Part 43, appendix
A.  Anything that is not a major repair or modification is by definition
a minor one.

John Cooper, A&P
Skyport Services
PO Box 249
4996 Delaware Tnpk
Rensselaerville, NY 12147
518 797-3064
Fax 518 797-3865
www.skyportservices.net 

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