The AV-30 can be wired up to the Area 660 or 760 handheld to drive the HSI. That is a lot of bang for the buck. Though the 760 is obscenely overpriced.Some of these new things don’t work without additional expensive boxes that talk to them. The old hand-helds are really nice for precise navigation, not very expensive, and easy to set up.
I believe this FAA interpretation says ”the 30 item list” is representative only and is not meant to cover everything the owner is allowed to do.One of the things I dislike is the overly restrictive interpretation of "preventive maintenance in the regulations.
Preventive maintenance is defined by the FAA as "simple or minor preservation operations and the replacement of small standard parts not involving complex assembly operations." That's pretty broad and I think reflected the statutory intent. I also think that when the law was written it did not foresee the development of entirely new lighting technologies - but I also don't think that would have changed the original intent.
However in Appendix A of Part 43 the FAA went way past the statutory intent and spelled it out in regulation with "limited to" language in sub section (c):
(c) Preventive maintenance. Preventive maintenance is limited to the following work, provided it does not involve complex assembly operations:
(1) Removal, installation, and repair of landing gear tires.
(2) Replacing elastic shock absorber cords on landing gear.
(3) Servicing landing gear shock struts by adding oil, air, or both.
(4) Servicing landing gear wheel bearings, such as cleaning and greasing.
(5) Replacing defective safety wiring or cotter keys.
(6) Lubrication not requiring disassembly other than removal of nonstructural items such as cover plates, cowlings, and fairings.
(7) Making simple fabric patches not requiring rib stitching or the removal of structural parts or control surfaces. In the case of balloons, the making of small fabric repairs to envelopes (as defined in, and in accordance with, the balloon manufacturers' instructions) not requiring load tape repair or replacement.
(8) Replenishing hydraulic fluid in the hydraulic reservoir.
(9) Refinishing decorative coating of fuselage, balloon baskets, wings tail group surfaces (excluding balanced control surfaces), fairings, cowlings, landing gear, cabin, or cockpit interior when removal or disassembly of any primary structure or operating system is not required.
(10) Applying preservative or protective material to components where no disassembly of any primary structure or operating system is involved and where such coating is not prohibited or is not contrary to good practices.
(11) Repairing upholstery and decorative furnishings of the cabin, cockpit, or balloon basket interior when the repairing does not require disassembly of any primary structure or operating system or interfere with an operating system or affect the primary structure of the aircraft.
(12) Making small simple repairs to fairings, nonstructural cover plates, cowlings, and small patches and reinforcements not changing the contour so as to interfere with proper air flow.
(13) Replacing side windows where that work does not interfere with the structure or any operating system such as controls, electrical equipment, etc.
(14) Replacing safety belts.
(15) Replacing seats or seat parts with replacement parts approved for the aircraft, not involving disassembly of any primary structure or operating system.
(16) Trouble shooting and repairing broken circuits in landing light wiring circuits.
(17) Replacing bulbs, reflectors, and lenses of position and landing lights.
(18) Replacing wheels and skis where no weight and balance computation is involved.
(19) Replacing any cowling not requiring removal of the propeller or disconnection of flight controls.
(20) Replacing or cleaning spark plugs and setting of spark plug gap clearance.
(21) Replacing any hose connection except hydraulic connections.
(22) Replacing prefabricated fuel lines.
(23) Cleaning or replacing fuel and oil strainers or filter elements.
(24) Replacing and servicing batteries.
(25) Cleaning of balloon burner pilot and main nozzles in accordance with the balloon manufacturer's instructions.
(26) Replacement or adjustment of nonstructural standard fasteners incidental to operations.
(27) The interchange of balloon baskets and burners on envelopes when the basket or burner is designated as interchangeable in the balloon type certificate data and the baskets and burners are specifically designed for quick removal and installation.
(28) The installations of anti-misfueling devices to reduce the diameter of fuel tank filler openings provided the specific device has been made a part of the aircraft type certificiate data by the aircraft manufacturer, the aircraft manufacturer has provided FAA-approved instructions for installation of the specific device, and installation does not involve the disassembly of the existing tank filler opening.
(29) Removing, checking, and replacing magnetic chip detectors.
(30) The inspection and maintenance tasks prescribed and specifically identified as preventive maintenance in a primary category aircraft type certificate or supplemental type certificate holder's approved special inspection and preventive maintenance program when accomplished on a primary category aircraft provided:
(i) They are performed by the holder of at least a private pilot certificate issued under part 61 who is the registered owner (including co-owners) of the affected aircraft and who holds a certificate of competency for the affected aircraft (1) issued by a school approved under § 147.21(e) of this chapter; (2) issued by the holder of the production certificate for that primary category aircraft that has a special training program approved under § 21.24 of this subchapter; or (3) issued by another entity that has a course approved by the Administrator; and
(ii) The inspections and maintenance tasks are performed in accordance with instructions contained by the special inspection and preventive maintenance program approved as part of the aircraft's type design or supplemental type design.
(31) Removing and replacing self-contained, front instrument panel-mounted navigation and communication devices that employ tray-mounted connectors that connect the unit when the unit is installed into the instrument panel, (excluding automatic flight control systems, transponders, and microwave frequency distance measuring equipment (DME)). The approved unit must be designed to be readily and repeatedly removed and replaced, and pertinent instructions must be provided. Prior to the unit's intended use, and operational check must be performed in accordance with the applicable sections of part 91 of this chapter.
In a perfect world and given the two items in red above, you *could* interpret what you intend to do as simply "Replacing bulbs, reflectors, and lenses of position and landing lights" and "Trouble shooting and repairing broken circuits in landing light wiring circuits". That would pretty much cover the new LED lighting unit as well as the wiring. Just be sure the wiring is "broken" when you "start". And I think it would fall under the original statutory intent.
The problem with that interpretation is the STC. You can't submit the STC with the 337 form as an owner/pilot, nor can you call a change requiring an STC to be "preventative maintenance". It would also be disqualified if the new unit results in any weight and balance change. As Bob says its a "minor alteration" at most, but the FAA is really pushing for STCs when ever possible, and in fact won't approve a 337 if it's using the same basis for approval as an existing 337. They want to protect the financial interests of whoever offers the STC. That's a result of Owners and A&Ps using the information in the STC to do the alteration, but then not paying the holder of the STC.
Still, I'm not real clear why LED light installations require an STC or even a minor alteration, rather than just meeting a TSO standard. For example, you can replace your tires with different TSO approved tires listed on the TCDS, provided there isn't a weight and balance change. Why doesn't the same logic apply to an "approved" landing light?
Red arc means don't fly like that. Potential severe vibration with the engine/prop combination. Even at 2400 the vibration can be noticeable and uncomfortable at higher MP settings.I don't understand the red arc. I've seen yellow arcs as "avoid operation blah, blah" but anytime I dig into it that yellow arc is usually associated with specific propeller installations. My own tach has a yellow arc but I just looked at a picture and it is between 2600 and 2700.