09 May 2025, 14:58 [ UTC - 5; DST ]
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Post subject: Re: Legacy Citation vs Turboprop Posted: 05 Dec 2023, 01:54 |
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Joined: 12/03/14 Posts: 19978 Post Likes: +25037 Company: Ciholas, Inc Location: KEHR
Aircraft: C560V
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Username Protected wrote: I think you might want to check your facts, if you want to put M2 armrest in your 560, it’s going to require an STC. Substantiate your claim with references. What would be required in your scenario is a mechanic sign off that the alteration was minor and acceptable. Reference: https://www.faa.gov/documentlibrary/med ... 3-210a.pdfIn particular: Title 14 of the Code of Federal Regulations (14 CFR) part 43, § 43.7 specifies persons authorized to approve an aircraft or aircraft component for return to service after maintenance, preventative maintenance, rebuilding, or alteration. For major repairs or major alterations the work must be done in accordance with technical data approved by the Administrator.
Title 14 CFR part 1, § 1.1 defines major repairs and major alterations. In addition, part 43 appendix A, paragraph (a) further defines what constitutes a major alteration. In a similar manner, part 43 appendix A, paragraph (b) further defines what constitutes a major repair. A minor alteration is an alteration that is not major.
Minor alterations/repairs do not require approved data.Major alterations require FAA approval. Interior fittings are not major per Part 43 Appendix A. Minor alterations only require a mechanic (or other person indicated in Part 43.7) to return the aircraft to service. Mike C.
_________________ Email mikec (at) ciholas.com
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Post subject: Re: Legacy Citation vs Turboprop Posted: 05 Dec 2023, 07:27 |
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Joined: 05/23/13 Posts: 7838 Post Likes: +10204 Company: Jet Acquisitions Location: Franklin, TN 615-739-9091 chip@jetacq.com
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Username Protected wrote: I think you might want to check your facts, if you want to put M2 armrest in your 560, it’s going to require an STC. Substantiate your claim with references. What would be required in your scenario is a mechanic sign off that the alteration was minor and acceptable. Reference: https://www.faa.gov/documentlibrary/med ... 3-210a.pdfIn particular: Title 14 of the Code of Federal Regulations (14 CFR) part 43, § 43.7 specifies persons authorized to approve an aircraft or aircraft component for return to service after maintenance, preventative maintenance, rebuilding, or alteration. For major repairs or major alterations the work must be done in accordance with technical data approved by the Administrator.
Title 14 CFR part 1, § 1.1 defines major repairs and major alterations. In addition, part 43 appendix A, paragraph (a) further defines what constitutes a major alteration. In a similar manner, part 43 appendix A, paragraph (b) further defines what constitutes a major repair. A minor alteration is an alteration that is not major.
Minor alterations/repairs do not require approved data.Major alterations require FAA approval. Interior fittings are not major per Part 43 Appendix A. Minor alterations only require a mechanic (or other person indicated in Part 43.7) to return the aircraft to service. Mike C.
Are we talking modifying the interior from a standard 560 to a CJ3+ style interior where the armrest disappear into the seat back, including replacing the drink rails and tray tables with new ones like exist in the late model aircraft?
Because I sure thought that was what we were talking about.
Now you are saying “interior fittings”? What does that mean?
I’ll be glad to substantiate anything you like, but first, you are going to agree on what we are talking about so that you can’t weasel out of this one with semantics.
To be abundantly clear, our discussion was between the interiors of a Citation V and a CJ3+, and what you are saying is that you can modify the V to be like the 3+ with out needing an STC? Is that correct?
This conversion will require; 1. Modifying the seats with hidden armrest and a narrower base. 2. Replacing the drink rails and tray tables with new drink rails and tray tables with a structural design similar to those in a CJ3+
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Post subject: Re: Legacy Citation vs Turboprop Posted: 05 Dec 2023, 11:29 |
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Joined: 05/23/13 Posts: 7838 Post Likes: +10204 Company: Jet Acquisitions Location: Franklin, TN 615-739-9091 chip@jetacq.com
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Username Protected wrote: here's my specific question:
1) let's say i want to get rid of all the wood (rails, galley, etc), and replace with the newer-styles I see, that include gray composites and carbon fiber.
2) recovering all the seats, but using new foam and materials to give them a new shape.
i assume these are all minor alterations. My understanding is that #1 would require an STC, assuming these are new parts. #2 you can do as long as you adhere to the original seat design, in other words you can rebuild the foam, make the surfaces tighter to the frame, and change the pattern of lines, creases, folds, etc.
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Post subject: Re: Legacy Citation vs Turboprop Posted: 05 Dec 2023, 11:47 |
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Joined: 11/08/12 Posts: 7291 Post Likes: +4787 Location: Live in San Carlos, CA - based Hayward, CA KHWD
Aircraft: Piaggio Avanti
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Username Protected wrote: here's my specific question:
1) let's say i want to get rid of all the wood (rails, galley, etc), and replace with the newer-styles I see, that include gray composites and carbon fiber.
2) recovering all the seats, but using new foam and materials to give them a new shape.
i assume these are all minor alterations. I would assume so. The controlling opinion is that of the installing mechanic (with likely heavy influence from what he believes he can get away with at his FSDO). I would think #1 would be minor as long as the change doesn’t affect anything like passenger access to safety equipment (O2 masks) or egress (emergency exit). Or structural attach points. #2 should be fine as long as seat structure and safety features aren’t affected (seat belts, attach points, frame).
_________________ -Jon C.
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Post subject: Re: Legacy Citation vs Turboprop Posted: 05 Dec 2023, 14:11 |
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Joined: 08/24/13 Posts: 9632 Post Likes: +4478 Company: Aviation Tools / CCX Location: KSMQ New Jersey
Aircraft: TBM700C2
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Username Protected wrote: #2 you can do as long as you adhere to the original seat design, in other words you can rebuild the foam, make the surfaces tighter to the frame, and change the pattern of lines, creases, folds, etc. Some seemingly simple changes to foam can invalidate the G rating of the seat, so even foam changes can be major
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Post subject: Re: Legacy Citation vs Turboprop Posted: 05 Dec 2023, 14:53 |
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Joined: 05/23/13 Posts: 7838 Post Likes: +10204 Company: Jet Acquisitions Location: Franklin, TN 615-739-9091 chip@jetacq.com
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Username Protected wrote: #2 you can do as long as you adhere to the original seat design, in other words you can rebuild the foam, make the surfaces tighter to the frame, and change the pattern of lines, creases, folds, etc. Some seemingly simple changes to foam can invalidate the G rating of the seat, so even foam changes can be major
Yes, very good point, they have to be substantially the same, including type / density of foam.
Do you have any insight to drink rails and tray tables, I've always been told that anything that changes the interior is sticky because of safety.
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Post subject: Re: Legacy Citation vs Turboprop Posted: 05 Dec 2023, 18:17 |
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Joined: 08/24/13 Posts: 9632 Post Likes: +4478 Company: Aviation Tools / CCX Location: KSMQ New Jersey
Aircraft: TBM700C2
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Username Protected wrote: Some seemingly simple changes to foam can invalidate the G rating of the seat, so even foam changes can be major
Yes, very good point, they have to be substantially the same, including type / density of foam. Do you have any insight to drink rails and tray tables, I've always been told that anything that changes the interior is sticky because of safety.
My past experience with cabin mods were that anything that changed mounting points, moved seats or added cabinets were STCd or at least DER approved. Mainly due to emergency egress.
Something like a drink rail would not necessarily trigger an STC but might still need DER approval. I haven't really been in that side of the business for a few years though, so things may have changed. In the avionics world a lot more is called Minor than there used to be
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Post subject: Re: Legacy Citation vs Turboprop Posted: 06 Dec 2023, 00:04 |
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Joined: 12/03/14 Posts: 19978 Post Likes: +25037 Company: Ciholas, Inc Location: KEHR
Aircraft: C560V
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Username Protected wrote: i assume these are all minor alterations. Generally, yes, they are. Anything that is not listed in FAR 43 Appendix A part (a) is a minor alteration. As long as you don't change structure, you are good. That doesn't mean there are no requirements on the mods, you still have to do it compliant to standards such as burn rating, good materials, etc. Mike C.
_________________ Email mikec (at) ciholas.com
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Post subject: Re: Legacy Citation vs Turboprop Posted: 07 Dec 2023, 08:36 |
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Joined: 05/23/13 Posts: 7838 Post Likes: +10204 Company: Jet Acquisitions Location: Franklin, TN 615-739-9091 chip@jetacq.com
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Username Protected wrote: i assume these are all minor alterations. Generally, yes, they are. Anything that is not listed in FAR 43 Appendix A part (a) is a minor alteration. As long as you don't change structure, you are good.That doesn't mean there are no requirements on the mods, you still have to do it compliant to standards such as burn rating, good materials, etc. Mike C.
How are you going to make any of the changes to a V that would make it like a new CJ3 without modifications that are anything but minor?
Changing the entire drink rail and tray table to make it slimmer isn’t a minor change.
That nice little armrest that folds into the seat back? That’s not only a major change it has safety implications.
You might get away with having a small shop make some of these changes and get a FSDO / DER sign off, but they’re not touching anything safety related, and I suspect that includes the drink rails, but the real test of something like this is does the aircraft still meet part 135 conformity?
You have taken a position that you refuse to surrender, and now you are attempting to maneuver out of it without admitting you were wrong.
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Post subject: Re: Legacy Citation vs Turboprop Posted: 07 Dec 2023, 09:07 |
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Joined: 12/03/14 Posts: 19978 Post Likes: +25037 Company: Ciholas, Inc Location: KEHR
Aircraft: C560V
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Username Protected wrote: Changing the entire drink rail and tray table to make it slimmer isn’t a minor change. "Drink rail" is not structural, therefore it is a minor change. Mike C.
_________________ Email mikec (at) ciholas.com
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Post subject: Re: Legacy Citation vs Turboprop Posted: 08 Dec 2023, 00:15 |
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Joined: 05/23/13 Posts: 7838 Post Likes: +10204 Company: Jet Acquisitions Location: Franklin, TN 615-739-9091 chip@jetacq.com
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Username Protected wrote: Changing the entire drink rail and tray table to make it slimmer isn’t a minor change. "Drink rail" is not structural, therefore it is a minor change. Mike C.
So now you’re trying to steer this down to but one of three separate items in hopes to find something that you weren’t wrong about?
FWIW I suspect you’re wrong about this one as well.
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