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englishal
17th Oct 2009, 09:26
I've posted on this subject before but am still not that clear on what one can and can't install in an aeroplane (at reasonable cost that is!).

For example, this has an FAA STC for installation in our aeroplane assuming it was N reg:

http://www.buy-ei.com/Pictures/reflect_MVP-50P.jpg

How does this translate to the G reg? I have read about CAA AANs but don't fully understand the process yet.

If there is an FAA STC on an item, does this make the process of fitting the item to a G reg relatively straight forward and more of a paperwork exercise than anything else? Or do the FAA STCs not count for much?

I'd like to fit some decent engine monitoring gear to our plane, but searching the AANs there are limited options compared to the FAA.

Thanks.

IO540
17th Oct 2009, 10:19
AIUI, the UK CAA issued an AAN in various circumstances, one of them being to cover an install of something that had an FAA STC.

There is an FAA-CAA mutual STC recognition treaty but it does not provide for automatic FAA STC acceptance. (I believe Australia does automatic FAA STC acceptance).

Many European countries have such treaties with the FAA but EASA (I wrote to them a while ago) pretends they don't exist. You can find a list of them on the FAA website...

AIUI, the CAA stopped issuing AANs when EASA took over certification.

If an item can be found in the AAN database, then it can be installed in a G-reg and by extension in any EASA-reg plane.

However many G-reg installs do not have an AAN, because they were done under the mistaken but widespread belief that FAA STCs can be installed directly, due to the FAA-CAA treaty.

I would not install an item in a UK based N-reg which has no chance of being EASA approved. This is not because I believe that EASA will kick out N-reg planes (I am sure they won't, and neither will they be able to subject them to EASA maintenance regimes because in many cases that would ground them) but because the resale value of a SE piston plane will be impacted if it cannot be transferred to a European registry.

If yours is a G-reg then you have to get EASA approval (unless there is an install done elsewhere in Europe - EI might be able to tell you if they sold any to European non-N-reg people, and you start the search that way). I've got some contacts who can give you a frank and honest input :) One would hope the FAA STC would be useful as Approved Data in this case and I am sure that is true, but EASA is European and Europe is morally and intellectually superior to the USA and this must be absolutely respected :)

englishal
17th Oct 2009, 10:34
Thanks Peter...

There are lots of good bits of kit out there which would aid flight safety which the FAA have STC'd for that particular aeroplane. It seems nuts that one cannot then buy this piece of equipment and just have it fitted.

Probably the ones to ask are the avionics installers but I'd like to get it clear in my mind before because there is an awful lot of teeth sucking and "can't do that"'s that I hear!

For example EDM800 looks pretty good, and there is an STC that covers it for the aircraft. So how exactly to I know if I can fit it or not? where do I start? It is all a bit of a minefield!

Cheers

IO540
17th Oct 2009, 15:47
A suprising amount of stuff is EASA approved (either directly under EASA or by a previous Euro CAA). If you stick to this, that's the simplest way by far. This is true of much of the JPI range.

Anything else is going to rely on avionics shop teeth sucking and their interpretations of regs which are, shall we say, somewhat variable :ugh: If you feel lucky, try getting a PRNAV approval while you are at it :ugh: Actually I am not kidding - don't put in any fancy avionics today unless it is PRNAV approval capable (basically that means having to use a GNS430/530 and preferably the W versions.

englishal
17th Oct 2009, 16:49
Is there any way to search the EASA STC's or do I really have to wade through all 2107 pages of the PDF STC list! :eek:

IO540
17th Oct 2009, 18:05
I think that's it. It is listed in some sort of order though, IIRC.

However this will show only approvals done by EASA. All teh pre-EASA ones, which are automatically grandfathered into EASA, are on databases spread around Europe, most of which are not accessible :)

wigglyamp
17th Oct 2009, 21:07
The three main sources of FAA STCs that have been validated in Europe and that can easily be searched are the German LBA, UK CAA and EASA itself (for all those approved since September 2003).

To check the CAA list, go to Airworthiness Approval Notes Database Search | Airworthiness | Safety Regulation (http://www.caa.co.uk/application.aspx?catid=340&pagetype=65&appid=10)
Enter the FAA STC number in to the search table and you should find any associated CAA approvals.

For the EASA list, download the .pdf list then using the FIND fucntion in Acrobat, enter the FAA STC number and hopefully it'll turn up.

I don't know if you can still access the LBA list, but I have the final version so if you have a specific FAA STC you need checking, I'd be happy to look it up.

IO-540 always like to remind us that European avionic shops are far less capable/reliable than those in the US and that with 90% of the aviation market, the American approval system must always be right. Some of us work under both approval systems and do know how to use the EASA certification system and make it work effectively. In many cases, EASA design approvals provide significantly better certification data than provided in equivalent FAA STCs!

englishal
18th Oct 2009, 06:58
Thanks.

So if I find the STC in FAA land, and it lists my aeroplane, then I search the EASA doc or the CAA website and find an EASA STC or CAA AAN relating to this bit of kit, then I can buy the kit in the USA, give it to my avionics installer and pay him to install it?

wigglyamp
19th Oct 2009, 21:48
Yes that's pretty much the may it works. All of the JP Instruments systems - EDM760, FS450 etc are installed under this route.
In the past, the person who owned the AAN (the original applicant who paid the fee) gave permission for someone else to use the AAN, in a similar way to the method the FAA currently dictate. This is where the FAA STC holder must give written permission for someone to embody the modification. In reality, if you find the validated FAA STC in EASA, CAA or LBA lists you can pretty much just get on with it, provided you have the full STC data package.

The one area which can catch people out is if the AAN or other validation calls up any limitations or a particular AFM supplement which may vary from the original FAA document. It's important, therefore, to obtain not just the AAN approval number, but also the actual AAN document so you can check on limitations and applicability.

IO540
20th Oct 2009, 08:31
IO-540 always like to remind us that European avionic shops are far less capable/reliable than those in the US and that with 90% of the aviation market, the American approval system must always be right. Some of us work under both approval systems and do know how to use the EASA certification system and make it work effectively. In many cases, EASA design approvals provide significantly better certification data than provided in equivalent FAA STCs!

Wigglyamp, can you post an actual example where the superior EASA approach has improved safety?

If unable to, I will accept an example which is purely theoretical so long as full detail of the failure mode is supplied.

:)

wigglyamp
20th Oct 2009, 21:22
IO-540. I specifically mentioned 'significantly better certification data' as opposed directly to imnproved safety, but the two are directly related. Here is a recent example (which we have made subject to a formal investigation so I'll keep details a bit vague):

Aircraft (no, not the KingAir you mentioned in another post!) had dual GNS units installed to FAA AML data with interface to a dual EFIS display. The installer did not create/provide any wiring diagrams of what they'd done. On test as part of import, it was found that each EHSI would annunciate 'LOC' when the associated GNS was tuned to ILS - so far so good, but L-R deviation was actually being driven by GPS XTK deviation. Potentially lethal as Nav flag was clearing from ILS but wrong deviation source, so pilot could consider himself on centreline whilst possibly flying into a mountain! There were other related problems in cross-side switching, autopilot coupling and RMI pointer operation. I've no idea of how the installer could have certified the completed installation as functionally correct.

A European STC requires specific design data including wiring diagrams for the particular airframe and avionic interface. If this had been done, the designer should have been able to work out that the generic AML drawings were seriously wrong! We suspect other similar installations based on this data are out there and have already identified at least one more aircraft with similar issues.

This is probably the extreme end of what I find wrong with FAA AMLs, and I agree that EASA may well go over the top with some of it's requirements. This incident shows that relying on generic installation data as contained in most AMLs leaves potentially dangerous situations open which may never be reviewed by another design/certification engineer. At least in forcing the applicant to produce a full design package, EASA provide an additional layer of checking manufacturer-produced installation data as well as producing specific test schedules hich should identify post-installation issues.

IO540
20th Oct 2009, 22:18
Wigglyamp

The installations you describe were done by an idiot.

Now, I accept that most avionics shops are just wiremen, following diagrams with little functional understanding and close to zero signal-level understanding.

So, where does that leave us?

If you say that EASA exists to enable an idiot (who can squeeze a crimp tool) to carry out the installation, that is one line of debate we could explore.

If you say that EASA supplements a competent installer, that is IMHO a much harder line to argue.

The whole process dates back, I presume, decades to ICAO practices which mean little today. Just think about this: what does it mean to say a GNS430 is approved for a Cirrus SR22? A 430 could be installed in a C150 or in a modern King Air. Introducing the airframe or other equipment into the 430 approval is like certifying a steering wheel for a 1976 Viva, S/N 223367 to 223450 only, when actually it can (obviously) be used on any car with the right splined shaft etc. But no certification can cope with the huge variety of possible configurations with interconnected equipment - unless one assumes the installer is an idiot in which case every installation is a Major Mod.

The whole thing needs a drastic overhaul, but the widespread lack of competence in the avionics business is playing into EASA's hands.

wigglyamp
20th Oct 2009, 22:42
The installation in question was done by an allegedly competent avionic shop and I quite agree with your comment about it being done by an idiot - no proper testing, or some of the issues would have been found. However, they had wired to an FAA approved AML which did not reflect the aircraft interface and which was which was ultimately incorrect!

I'm sure every avionic installer in the UK and US who can operate a crimp tool will be delighted to know you think of them as idiots. Whilst they may not be highly knowledgeable about component level design, there is nevertheless a decent level of skill required to produce an accurate, functional, reliable and airworthy installation of today's complex avionics. I assume you'll never want to go near any European shop to have work done?

I consider this discussion over.

IO540
21st Oct 2009, 06:54
I'm sure every avionic installer in the UK and US who can operate a crimp tool will be delighted to know you think of them as idiots. Whilst they may not be highly knowledgeable about component level design, there is nevertheless a decent level of skill required to produce an accurate, functional, reliable and airworthy installation of today's complex avionics. I assume you'll never want to go near any European shop to have work done?

I didn't say there were no idiots in the US avionics scene. I think they are probably similar to those over here; the only real difference being that they do a lot more work, or a lot more varied work, so they have more experience. I do business with America regularly and their % of picnics shoft of a sandwich is just as interesting as over here in the UK.

What I am disputing is the validity of the EASA approach, treating everything as a mod which they must approve. Assuming a competent installer, this approach is no more valid than the AML approach which is basically meaningless (see my steering wheel example) in terms of telling the installer which wires go where.