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But what we've been able to avoid (with one exception—the Maple Leaf/RS Designs tailcone) are regular trips to the FAA for field approvals. How have we made that happen? By using a neat tool called a DER.

Your own engineer
A DER, or designated engineering representative, does a lot of heavy lifting these days. We interviewed David Chadwick, of DC Aerospace who is serving as DER for our essential bus installation, about the process by which a DER achieves that designation, and how they provide the engineering data and support to ensure modifications to an airplane are safe, cogent, and follow best practices.

"A DER is a person—having been found to have the necessary knowledge, skill, experience, interest, and impartial judgment to merit special public responsibility—delegated by the FAA as a Designated Engineering Representative (DER)," says Chadwick. "Delegations can be granted for Systems and Equipment, Mechanical, Structures, Powerplant, Radios, Propeller, Flight Analyst, Flight Test Pilots, and Acoustical. Special delegations are also given for Administrative, Major Repairs and Alterations, PMA Identicality, and other special authorizations."

A DER can approve engineering technical data within the limits of his or her authority though the FAA form 8110-3, officially called a "Statement of Compliance." A DER appointment runs annually, and the DER must show activity in his or her assigned delegations each year in order for renewal, along with required attendance at recurrent seminars every two years.

There are four FAA Aircraft Certification Directorates: Transport Airplane Certification Directorate (Large Aircraft, within CAR 4 and FAR Part 25), Small Airplane Certification Directorate (Small Aircraft, within CAR 3 and FAR Part 23), Rotorcraft Certification Directorate (FAR Part 27 and Part 29), and Engine and Propeller Certification Directorate. Each directorate has certification offices within their geographic area, and a DER gets assigned to the Aircraft Certification Office (ACO) in the geographic area that he or she resides.

Chadwick continues, "However, this does not limit the DER from working or approving data outside their geographic area. In fact, DERs can approve data for any U.S. type-certificated product located anywhere in the world, within their delegation.

"For instance, let's say you want to accomplish a modification on your aircraft, but you do not have any approved data, [such as a] supplemental type certificate (STC), manufacturer's FAA-approved service bulletin, or installation manual. You have a couple of choices: You can pursue the field approval process via FAA Form 337, or you can contact a DER. The first choice is free; the latter choice will cost you some money, but may save you some valuable time," adds Chadwick. "Oh, did I forget to mention that DERs do charge for their services?

"Normally you would gather up some draft sketches or pictures showing just what you have in mind for your modification, then meet with your Flight Standards or General Aviation FAA inspector. The object here is for the FAA inspector to sign off block 13 of FAA Form 337, then bingo...you have field approval for the data.

"But as you may have noticed lately, the FAA is giving [fewer] field approvals; in fact, big aircraft operators like FAR 121 operators [such as airlines] no longer are granted field approvals by the Flight Standards District Office (FSDO). The FSDO is looking more and more to help from the DER community in the area of data approvals in support of FAA Form 337s. FAA Order 8300-10, Chapter 1, "Field Approval of Major Repairs and Major Alterations," gives guidance to the FSDOs as to what they can and cannot approve. Check it out, it's a very good reference when planning major work where you might be seeking field approval," suggests Chadwick.

An easier way
Yes, it does cost money, but the time savings and lack of uncertainty is immense. Because the DER works with you on the process, there seem to be fewer surprises, at least in our experience.

As we wrap up the project, and time is once again of the essence, this service-oriented process is proving invaluable to making sure your Cardinal is ready to go to the winner in early 2008.

E-mail the author at julie.boatman@aopa.org.

Navico Group was created in September 2006 to extend Lowrance's global reach, with Jens-Thomas Pietralla as chief operating officer, and CEO-elect for when Darrell Lowrance, Carl's son, would step down from heading the company in January 2007. Aviation sales manager Grant Farrell is an active pilot with a new-to-him Yakovlev 52 warbird. With products like the 600c we're giving away in the Cardinal, plus the large-format 2000c, Lowrance continues to offer a value solution for pilots that they can also use on land or sea. Contact Lowrance by calling 800/324-4740, or by visiting the Web site.