Airplane With No Paperwork On the Avionics

[Unregistered]

I have had an airplane for the past 6 years that I've flown hundreds of hours and done lots of IFR flying. It's been totally solid avionics wise. Well, I started poking around in the logs a few days ago and noticed that there are no 337's, STC's or logbook entries for the GPS or a couple of the other avionics. I have a 430 as well as a panel mount, IFR approved MFD. I took the logs to my A&P and he confirmed that indeed, there is no paperwork at all on the avionics or their install. So it appears that I've been flying an airplane that is "unairworthy" from an FAA viewpoint due to the lack of paperwork. My A&P wasn't sure what the best way to handle and fix the problem would be, so he advised I call the FSDO and speak to an inspector without giving any personal info. He said the FSDO here has always been reasonable and helpful. So, I called the local FSDO with my blocked number and asked to speak to an inspector. Both times I called it went to voicemail and I didn't want to leave a msg. I'm going to call Monday, but I thought that maybe somebody on here would have some suggestions or may have handled this in the past. I emailed the previous owner and he admitted that he installed the stuff himself. I have to say, it was a very professional looking install and I haven't had any issues whatsoever. I'm still very upset he didn't disclose it when it bought it and upset that the shop that did the pre-buy didn't catch this. I'm not worried that someone wouldn't sign off on the install. My mechanic said it looks good. I'm worried about not having any STC's, if they're even needed.

Also, do I need to file an NASA report to cover my butt? I just found out and haven't flown since, but I still don't want to get burned by the FAA. Any suggestions would be appreciated!!

 

[Blackhawk]

I have had an airplane for the past 6 years that I've flown hundreds of hours and done lots of IFR flying. It's been totally solid avionics wise. Well, I started poking around in the logs a few days ago and noticed that there are no 337's, STC's or logbook entries for the GPS or a couple of the other avionics. I have a 430 as well as a panel mount, IFR approved MFD. I took the logs to my A&P and he confirmed that indeed, there is no paperwork at all on the avionics or their install. So it appears that I've been flying an airplane that is "unairworthy" from an FAA viewpoint due to the lack of paperwork. My A&P wasn't sure what the best way to handle and fix the problem would be, so he advised I call the FSDO and speak to an inspector without giving any personal info. He said the FSDO here has always been reasonable and helpful. So, I called the local FSDO with my blocked number and asked to speak to an inspector. Both times I called it went to voicemail and I didn't want to leave a msg. I'm going to call Monday, but I thought that maybe somebody on here would have some suggestions or may have handled this in the past. I emailed the previous owner and he admitted that he installed the stuff himself. I have to say, it was a very professional looking install and I haven't had any issues whatsoever. I'm still very upset he didn't disclose it when it bought it and upset that the shop that did the pre-buy didn't catch this. I'm not worried that someone wouldn't sign off on the install. My mechanic said it looks good. I'm worried about not having any STC's, if they're even needed.

Also, do I need to file an NASA report to cover my butt? I just found out and haven't flown since, but I still don't want to get burned by the FAA. Any suggestions would be appreciated!!

Yikes.
Do not discuss this in any manner with the FSDO where they will know who you are. You mentioned the blocked number- good idea.
I would be worried about the sign off. May/may not be an issue. Some avionics are for specific tail numbers. If they can use everything the avionics shop may need to pull the entire installation, inspect it, then reinstall it minus any unapproved pieces.
In addition if the previous owner purchased the avionics used and did not use an avionics shop the avionics may be hot. If so expect to lose the items.
Did you have a pre-buy done??

 

[Unregistered]

I have had an airplane for the past 6 years that I've flown hundreds of hours and done lots of IFR flying. It's been totally solid avionics wise. Well, I started poking around in the logs a few days ago and noticed that there are no 337's, STC's or logbook entries for the GPS or a couple of the other avionics. I have a 430 as well as a panel mount, IFR approved MFD. I took the logs to my A&P and he confirmed that indeed, there is no paperwork at all on the avionics or their install. So it appears that I've been flying an airplane that is "unairworthy" from an FAA viewpoint due to the lack of paperwork. My A&P wasn't sure what the best way to handle and fix the problem would be, so he advised I call the FSDO and speak to an inspector without giving any personal info. He said the FSDO here has always been reasonable and helpful. So, I called the local FSDO with my blocked number and asked to speak to an inspector. Both times I called it went to voicemail and I didn't want to leave a msg. I'm going to call Monday, but I thought that maybe somebody on here would have some suggestions or may have handled this in the past. I emailed the previous owner and he admitted that he installed the stuff himself. I have to say, it was a very professional looking install and I haven't had any issues whatsoever. I'm still very upset he didn't disclose it when it bought it and upset that the shop that did the pre-buy didn't catch this. I'm not worried that someone wouldn't sign off on the install. My mechanic said it looks good. I'm worried about not having any STC's, if they're even needed.

Also, do I need to file an NASA report to cover my butt? I just found out and haven't flown since, but I still don't want to get burned by the FAA. Any suggestions would be appreciated!!

The shop that did the pre buy could be liable if they explicitly stated the paperwork for the avionics was in good order. Call them up, or show up, and explain the scenario. Maybe they can remove/inspect for you at no cost or pay to send it to a shop that can?

 

[poadeleted20]

What you'll need is for an avionics shop to do a "conformity inspection" on the installation, including all the ground and flight tests required by the regulations, FAA guidance, and relevant installation manuals. That's not going to be cheap, but it's what you need to do. If you don't, you face a couple of possibilities, including:
You take the plane for annual, and the inspecting mechanic sees all this and writes it up, declining to certify it as airworthy.
You can't sell the plane because nobody who does a proper maintenance records check will touch it.
You somehow come to the FAA's attention, and they burn you for flying an unairworthy airplane.

What to do now?

Well, you can contact an aviation attorney and see if you have legal recourse against the shop that did the pre-purchase inspection. You might be able to get them to pay for the conformity inspection and any work needed to fix any problems discovered. Of course, that attorney is going to take a chunk of the proceeds (like 30-40%), but 65% of something is better than nothing. You could also just bite the bullet and eat this, and put it down to a learning experience about buying and owning airplanes. Or you could just keep flying, realizing you face the potential consequences listed above.

As for the FAA, now that you know the problem, if you ground the plane, get the work and documentation cleaned up, and submit the necessary 337's, the FSDO is most unlikely to go after you for your past sins of flying this plane while it wasn't legal. They really are in the safety business, and if they see you are trying to make it right, they're not going to punish you for that. My guess is the worst that happens if you do this and the first they hear about it is when you submit the 337's, is that you get a Letter of Correction telling you to fix it all up before further flight -- a letter which disappears from your record after two years.

 

[poadeleted20]

The shop that did the pre buy could be liable if they explicitly stated the paperwork for the avionics was in good order. Call them up, or show up, and explain the scenario. Maybe they can remove/inspect for you at no cost or pay to send it to a shop that can?

Get an attorney to do that -- you probably don't know the relevant law (Federal aviation law as well as state business and contract law) well enough to win that argument. At least spend a few bucks (or no bucks if you have the AOPA Legal Services Plan) to get some legal advice before contacting the shop so you know where you stand legally.

 

[RotorAndWing]

What you'll need is for an avionics shop to do a "conformity inspection" on the installation, including all the ground and flight tests required by the regulations, FAA guidance, and relevant installation manuals. That's not going to be cheap, but it's what you need to do. If you don't, you face a couple of possibilities, including:
You take the plane for annual, and the inspecting mechanic sees all this and writes it up, declining to certify it as airworthy.
You can't sell the plane because nobody who does a proper maintenance records check will touch it.
You somehow come to the FAA's attention, and they burn you for flying an unairworthy airplane.

What to do now?

Well, you can contact an aviation attorney and see if you have legal recourse against the shop that did the pre-purchase inspection. You might be able to get them to pay for the conformity inspection and any work needed to fix any problems discovered. Of course, that attorney is going to take a chunk of the proceeds (like 30-40%), but 65% of something is better than nothing. You could also just bite the bullet and eat this, and put it down to a learning experience about buying and owning airplanes. Or you could just keep flying, realizing you face the potential consequences listed above.

As for the FAA, now that you know the problem, if you ground the plane, get the work and documentation cleaned up, and submit the necessary 337's, the FSDO is most unlikely to go after you for your past sins of flying this plane while it wasn't legal. They really are in the safety business, and if they see you are trying to make it right, they're not going to punish you for that. My guess is the worst that happens if you do this and the first they hear about it is when you submit the 337's, is that you get a Letter of Correction telling you to fix it all up before further flight -- a letter which disappears from your record after two years.

Just have an avionics shop inspect and file the correct logbook entries and 337's. 337's are sent directly to OKC and not reviewed by AW ASI's (years ago 337's were reviewed by FSDO Inspectors, no more).

No letter of correction to worry about.

 

[poadeleted20]

Just have an avionics shop inspect and file the correct logbook entries and 337's. 337's are sent directly to OKC and not reviewed by AW ASI's (years ago 337's were reviewed by FSDO Inspectors, no more).

No letter of correction to worry about.

As I said...

...the FSDO is most unlikely to go after you for your past sins of flying this plane while it wasn't legal. They really are in the safety business, and if they see you are trying to make it right, they're not going to punish you for that.

...and I thought a letter would be the very worst the FSDO would do (and that's not a very big deal even if it were to happen). Just getting the paperwork right was and remains my first suggestion. Only problem will be cost, and that's where competent legal advice comes in.

 

[JHW]

Op, your local ia can make you legal to fly immedtately just by sending a 337 and making a log entry stating "found previuosly installed equipment xx and yy, installed per blah blah, revised w&b blah blah"

What he can't do is make you legal for /g ifr. You need an avionics shop and a flight manual supplement fot that.

 

[Blackhawk]

As for the FAA, now that you know the problem, if you ground the plane, get the work and documentation cleaned up, and submit the necessary 337's, the FSDO is most unlikely to go after you for your past sins of flying this plane while it wasn't legal. They really are in the safety business, and if they see you are trying to make it right, they're not going to punish you for that. My guess is the worst that happens if you do this and the first they hear about it is when you submit the 337's, is that you get a Letter of Correction telling you to fix it all up before further flight -- a letter which disappears from your record after two years.

Again, I would be very, very careful with that thought process from first hand experience. Some safety inspectors do feel violation are the best form of improving safety.

 

[murphey]

1. get an aviation lawyer
2. listen to the lawyer and do as recommended
3. do not call FAA or FSDO that's the job of the lawyer.


curious...you've had the airplane for 6 years and no one has noticed the paperwork problem thru 6 annual inspections?

 

[poadeleted20]

Again, I would be very, very careful with that thought process from first hand experience. Some safety inspectors do feel violation are the best form of improving safety.

I know you believe that, but I also know that "some" is an extreme exaggeration. I also know HQ Flight Standards doesn't want it that way. But I also know that arguing with you about that is not going to be productive.

 

[dtuuri]

curious...you've had the airplane for 6 years and no one has noticed the paperwork problem thru 6 annual inspections?

My initial reaction too! Also, why the heck didn't the OP check the paperwork when buying the plane in the first place? This kind of stuff really irks me. I had an AI go over a Twin Comanche for me (I'm an A&P myself, but not a Comanche expert). He found an unauthorized panel mod where structural aluminum was hacksawed out of the way to make a nice "T" stack, automotive wire connectors and wiring for illegally installed radios, and corrosion where paint stripper ran down the belly. Cost me just $150 to walk away from it. Beautiful airplane though.

dtuuri

 

[jsnapp]

Do you have a 430 or 430w? what are the other avionics. If it is a 430w, there is an STC and many IAs could simply write up the 337 after verifying it was installed and configured per the STC. He will just need the appropriate manuals and docs. A garmin dealer would have the needed paperwork and could do it fairly quickly, If it was a 430 then it has to be done through a field approval. This is best done by an avionics shop and not just any IA. still not more difficult though. Most radios can simply be installed with a log book entry (different A&P/I a have different opinions here) if they are replacing a previous similar function radio ( nav/com for a nav/com).





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