A GULFSTREAM 2 WAS DENIED A CERTIFICATE TO OPERATE IN PART 135 OP DUE TO FAA INSPECTOR REQUIREMENT FOR A FIELD INSPECTION OF A POTABLE WATER REPAIR.

Narrative

FEB/MON/98; I SIGNED AN FAA FORM 337 WHICH AMENDED A PERVIOUS FAA 337; DATED JUL/TUE/73; WHICH CONVERTED A GRAVITY TYPE WATER SYS TO A PRESSURIZED SYS. THE AMENDED 337 WAS NEEDED TO REPAIR A FAULTY REGULATOR AND CHK VALVE; IN WHICH NEEDED TO BE REPLACED. THE PARTS HAD TO BE REPLACED; AND THE MANUFACTURER OF THESE PARTS WAS OUT OF BUSINESS. NEW PARTS WERE PROCURED FROM A WELL ESTABLISHED VENDOR WHO ROUTINELY INSTALLS WATER SYS ON THESE CALIBER OF ACFT THAT ARE PART OF AN STC (SUPPLEMENTAL TYPE CERTIFICATE) PACKAGE. THE PARTS REMOVED WERE NOT PMA/TSO (PARTS MANUFACTURER APPROVAL/TECHNICAL STANDARD ORDER) PARTS AND THE PARTS INSTALLED WERE NOT PMA/TSO EITHER BUT WERE USED IN CURRENT SYS. PARTS ALSO WERE SAME FORM FIT AND FUNCTION. I DEEMED THE SYS AS AIRWORTHY AND STILL CONSIDER IT AS SUCH. ON OCT/FRI/99; IT WAS BROUGHT TO MY ATTN; AN FAA AIRWORTHINESS INSPECTOR WOULD NOT GRANT THIS ACFT A 135 CERTIFICATE DUE TO THE FAA 337 NOT BEING FIELD APPROVED. I BELIEVE THIS IS TECHNICALLY CORRECT AS THE PARTS ARE NOT PMA/TSO; BUT CONSIDERING THE ENTIRE SYS WAS NOT INSTALLED WITHOUT A FIELD APPROVAL (IT WAS INSTALLED AND APPROVED BY AN AIRWORTHINESS INSPECTOR). A FIELD APPROVAL WAS NOT REQUIRED. I SHOULD HAVE SOUGHT A FIELD APPROVAL TECHNICALLY; BUT STILL BELIEVE IS NOT APPROPRIATE FOR THIS APPLICATION. THE 337 WAS USED AS A MEANS OF PROPERLY ALTERING THE ORIGINAL ALTERATION DUE TO LIKE PARTS BEING INSTALLED. CALLBACK CONVERSATION WITH RPTR REVEALED THE FOLLOWING INFO: THE RPTR STATED THE ACFT WAS SOLD AND THE WATER SYS APPROVAL AND FIELD INSPECTION PROBS WERE NEVER RESOLVED. THE RPTR SAID THE PARTS USED IN THE REPAIR WERE THE SAME PARTS USED WHEN THE WATER SYS WAS MODIFIED FROM GRAVITY TO PRESSURE FLOW WITH SUPPLEMENTAL TYPE CERTIFICATE PARTS AND APPROVED BY SUBMITTING A FORM 337. THE RPTR SAID WHEN WORKING WITH AGING ACFT THE PAPERWORK TRAIL IS MASSIVE.