About a decade ago, the FAA began changing their policies on Field Approvals. Certain types of approvals for airplane upgrades suddenly came to a screeching halt. Many major repairs and alterations that were previously eligible for field approval were designated as only possible through the STC process. First introduced as an individual Job Aid, the "new" requirement eventually made their way into the FAA Order 8900.1 Vol. 4, Ch.9. This Order, known as the FSIMS Order is a huge deal. It is the "gospel" by which all FSDO personnel must operate. Reading this whole document would be like trying to absorb the entire text of Obamacare. It is enormous. You really have to use the index to find exactly what pertains to your issue and focus on the related section, otherwise, you will get LOST in a sea of legal jargon.
I believe the FAA powers who wrote this material really did not intend to stifle industry the way it has. But the fact is, the Order has stopped field approvals for many things that were previously considered routine field approvals. For example... BRAKES. A lot of good equipment is available for improving wheels and brakes on old airplanes. Many old airplanes were converted to modern brakes via field approval back in the days before the FSIMS Job Aid. As the STC requirement came down, many would-be applicants for such modifications were "priced" out of the ability to obtain FAA approval. The STC process is just simply too costly for most small airplane owners.
This week, I set out to request an exemption for this and have had a surprisingly good experience in dealing with the FAA. To make a long story short... the FAA shared some good news in the works for revisions to the FAA Order 8900.1 that will bring relief to applicants on Brake System changes and other repairs and modifications. I learned that Order 8900.1 is being revised to lighten up the approval process from "STC" back to the "field approval" side for several types of changes that have been stymied for the past few years. It seems that the FAA has acknowledged the adverse impact to the GA fleet and are serious about fixing it. Though not everything will be back to normal, we will see some positive changes really soon. Thanks FAA for applying the "brakes" on the FSIMS Order.
Click on the images below to view letter.