ADSB Transponder Installation - EO Required?
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ADSB Transponder Installation - EO Required?
Here is a bit of good news for the likes of Akro etc.
Sadly it comes on the back of much bad and very disappointing news.
It seems that the avionics industry in Australia has been either price gouging / deliberately misleading, or been seriously misguided by their own lack of interest in researching the facts.
An STC (Supplimental Type Certificate) and an associated AML (Approved Model List) is the universally accepted method of upgrading all manner of things from various manufacturers of either engines, props avionics or anything in-between.
What does this mean to you the Transponder (read or anything else) upgrade customer?
Simply that the installer does not need an EO (Engineering Order) at your great expense just to simply remove an old radio/gps/transponder and install a new unit so long as the new unit has an STC and your aircraft model is on the AML.
There is scope for a minor exception for some kinds of STC's where maybe a combination of STC's may not be a "good combination" and they may need further analysis, but in the simple GA Avionics arena I am struggling to think of this being an issue.
So to all of you who have been charged for an EO already …..I am sorry this is going to be sad to read. For those of you who are about to embark on a Transponder upgrade soon, make sure you are very specific in evaluating who is doing what and for how much.
How did I come across this? Fortunately I am not as limited with my own operation, but I assumed that those in the industry knew how STC / AML's worked so it was never apparent to me that people were being stung this way until someone I know went to do an upgrade which involved the EO cost. To his credit he insisted the avionics installation company do some proper research with CASA and to CASA's credit they asked the right questions, sought the documentation and then responded with confirmation that this was an acceptable STC/AML installation and no need for an EO.
The take away from this story is it has come to our collective attention that the vast majority if not all avionics installers are of this same misbelief, either through deliberate action or by not understanding and blindly following what all their industry colleagues are doing. Possibly through some fear caused by scare tactics of someone in the distant past.
When next you are faced with a situation like this it would be prudent to follow this bit of advice sent to me last night by someone who really does understand the topic better than most.
I hope this thread is of some benefit to all who read it. GA in Australia is hampered enough by excessive regulatory and knock on effect cost, so this kind of impost needs to be stopped and many others like it if the entire industry is to survive.
If anyone knows how to get this filtered out through the bulk of industry…please do it.
Sadly it comes on the back of much bad and very disappointing news.
It seems that the avionics industry in Australia has been either price gouging / deliberately misleading, or been seriously misguided by their own lack of interest in researching the facts.
An STC (Supplimental Type Certificate) and an associated AML (Approved Model List) is the universally accepted method of upgrading all manner of things from various manufacturers of either engines, props avionics or anything in-between.
What does this mean to you the Transponder (read or anything else) upgrade customer?
Simply that the installer does not need an EO (Engineering Order) at your great expense just to simply remove an old radio/gps/transponder and install a new unit so long as the new unit has an STC and your aircraft model is on the AML.
There is scope for a minor exception for some kinds of STC's where maybe a combination of STC's may not be a "good combination" and they may need further analysis, but in the simple GA Avionics arena I am struggling to think of this being an issue.
So to all of you who have been charged for an EO already …..I am sorry this is going to be sad to read. For those of you who are about to embark on a Transponder upgrade soon, make sure you are very specific in evaluating who is doing what and for how much.
How did I come across this? Fortunately I am not as limited with my own operation, but I assumed that those in the industry knew how STC / AML's worked so it was never apparent to me that people were being stung this way until someone I know went to do an upgrade which involved the EO cost. To his credit he insisted the avionics installation company do some proper research with CASA and to CASA's credit they asked the right questions, sought the documentation and then responded with confirmation that this was an acceptable STC/AML installation and no need for an EO.
The take away from this story is it has come to our collective attention that the vast majority if not all avionics installers are of this same misbelief, either through deliberate action or by not understanding and blindly following what all their industry colleagues are doing. Possibly through some fear caused by scare tactics of someone in the distant past.
When next you are faced with a situation like this it would be prudent to follow this bit of advice sent to me last night by someone who really does understand the topic better than most.
I STRONGLY recommend that your correspondent go back to XXXXX Aviation and ask them to explain exactly what the legislative basis of their need for an EO actually is.
"We usually..." "It's much easier if..." "To avoid problems later.." (Exactly what problems?) should not be acceptable.
"We usually..." "It's much easier if..." "To avoid problems later.." (Exactly what problems?) should not be acceptable.
If anyone knows how to get this filtered out through the bulk of industry…please do it.
Agree, but (there's always a but!).
I think, however, where it comes from is the incidental work that may be required.
For example, if you follow the AML installation instructions to the letter, without 'drawing outside the lines.' Then, no problem.
However, where mod work is required, then an EO will probably be required.
A good example of this is adding a long and 'heavy' box to a '60's style rack (think EX600 in a baron panel, old cessna, PA31 etc) if the rack rails are the result of 40 years of Swiss cheesing, you will either need to replace them, or insert a brace.
I don't know about you but if I were the signatory responsible (given our 'user-friendly' mod laws) I would need to see an EO.
In a PA31, the back of those racks are less than 15mm from the chain that connects the two control columns. Were the rack to 'sag' it would very likely jam - bad ju-ju.
I'm not arguing that it's right, but I have seen many examples of where an EO has effectively been required.
Again, for the avoidance of any doubt, I'm not advocating the necessity of our friends' CASA's laws; merely the compliance thereby.
I think, however, where it comes from is the incidental work that may be required.
For example, if you follow the AML installation instructions to the letter, without 'drawing outside the lines.' Then, no problem.
However, where mod work is required, then an EO will probably be required.
A good example of this is adding a long and 'heavy' box to a '60's style rack (think EX600 in a baron panel, old cessna, PA31 etc) if the rack rails are the result of 40 years of Swiss cheesing, you will either need to replace them, or insert a brace.
I don't know about you but if I were the signatory responsible (given our 'user-friendly' mod laws) I would need to see an EO.
In a PA31, the back of those racks are less than 15mm from the chain that connects the two control columns. Were the rack to 'sag' it would very likely jam - bad ju-ju.
I'm not arguing that it's right, but I have seen many examples of where an EO has effectively been required.
Again, for the avoidance of any doubt, I'm not advocating the necessity of our friends' CASA's laws; merely the compliance thereby.
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A 'but'?
I think this is one of the things wrong with GA.
Here is word from CASA that EO's aren't required for a specific thing, but, no, the STC isn't good enough, lets try and find a way where we can still charge the owner money for no benefit.
I have paid for a bunch of EO's in my time, and not once has the guy issuing the EO even been in the same state as the aircraft when it was being modified, let alone examined it himself.
EO's are a huge WOFTAM, and don't, in my opinion, do anything to promote safety. They do help the bottom line of some engineering companies though.
I am sure there are circumstances where an EO is warrented, like major modification of airframe, corrosion repairs, etc, but for something this routine, and for every LAME/Avionics shop I've spoke to, none had even had any thought other than an EO was required.
I am disappointed to think that places don't want to try to save their customers money, time and effort by even looking to see if an STC was available. There was another thread running about complaining that upgrades/maintenance by LAME's was costing more and value for money wasn't being achieved, and both sides made some good points, but why would anyone pay $600 to $1500 more for any given job, if they don't have to. Some of the posts made reference to the cost of jobs, and mentioned EO's. A lot of those posts/complaints/jobs have an STC. So why are we just accepting it, rather than challenging it?
It reminds me very much of the 5 gorillas in a cage with a ladder and a bunch of bananas story. Google it if you haven't heard it!
I think this is one of the things wrong with GA.
Here is word from CASA that EO's aren't required for a specific thing, but, no, the STC isn't good enough, lets try and find a way where we can still charge the owner money for no benefit.
I have paid for a bunch of EO's in my time, and not once has the guy issuing the EO even been in the same state as the aircraft when it was being modified, let alone examined it himself.
EO's are a huge WOFTAM, and don't, in my opinion, do anything to promote safety. They do help the bottom line of some engineering companies though.
I am sure there are circumstances where an EO is warrented, like major modification of airframe, corrosion repairs, etc, but for something this routine, and for every LAME/Avionics shop I've spoke to, none had even had any thought other than an EO was required.
I am disappointed to think that places don't want to try to save their customers money, time and effort by even looking to see if an STC was available. There was another thread running about complaining that upgrades/maintenance by LAME's was costing more and value for money wasn't being achieved, and both sides made some good points, but why would anyone pay $600 to $1500 more for any given job, if they don't have to. Some of the posts made reference to the cost of jobs, and mentioned EO's. A lot of those posts/complaints/jobs have an STC. So why are we just accepting it, rather than challenging it?
It reminds me very much of the 5 gorillas in a cage with a ladder and a bunch of bananas story. Google it if you haven't heard it!
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Interesting Jaba.
I have been reliably informed recently that to replace a KT76A TXPR with a TSO Trig (or new King jobbie) that slides into the same rack and weighs about the same, and consumes no more power - requires an EO to fit, at about extra $600.
Your post implies that common sense could possibly apply..........how novel
I have been reliably informed recently that to replace a KT76A TXPR with a TSO Trig (or new King jobbie) that slides into the same rack and weighs about the same, and consumes no more power - requires an EO to fit, at about extra $600.
Your post implies that common sense could possibly apply..........how novel
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Chairman,
I don't know about the new Kings or Trigs, but the Garmin line of transponders all come with STC's and a very long and comprehensive list of aircraft on the appropriate AML. So in that case, common sense (which these days is more of a super power than X-ray vision!) prevailed.
But be careful, it's very difficult to charge for common sense, so expect resistance when trying to apply it.
I don't know about the new Kings or Trigs, but the Garmin line of transponders all come with STC's and a very long and comprehensive list of aircraft on the appropriate AML. So in that case, common sense (which these days is more of a super power than X-ray vision!) prevailed.
But be careful, it's very difficult to charge for common sense, so expect resistance when trying to apply it.
Approval of foreign STC's
As a LAME I can say there is a common lack of knowledge about this in the industry, although there are people out there who apply the rule (myself included).
The relevant information is contained in paragraph 5 of the following doc:
http://www.casa.gov.au/wcmswr/_asset...worth/35_7.pdf
Note: that only STC's form an approved country count although this does cover FAA and EASA.
CASA have actually expanded this in 2010 as prior to that only STC's from the type certificate holders country were automatically accepted. Who says the department only takes away! (Just mostly)
For those who need to argue this this regulation works alongside the CAR30 reg which says "modifications must be approved by CASA" by stating "a modification is taken to be approved by CASA if:"
I do not blame most LAME's for not knowing this, CAAP 35-7 is an obscure doc that mostly applies to design organizations (The people who do EO's!). Unfortunately due to the complexity of the regs LAME's simply do not have time to troll through them all (took me 20mins and I knew where to find it!) in the hope they will save a few dollars.
Owners are always grateful when $$$ are saved but are rarely willing to pay for research time that does not pay off so LAME's are left making judgement calls of when to do more research.
This is when having a good knowledgeable LAME is worth paying extra for. BIG $$$$$$$ can be saved by knowing what mods are out there. Especially as some STC's are cheaper than the genuine parts they replace.
The relevant information is contained in paragraph 5 of the following doc:
http://www.casa.gov.au/wcmswr/_asset...worth/35_7.pdf
Note: that only STC's form an approved country count although this does cover FAA and EASA.
CASA have actually expanded this in 2010 as prior to that only STC's from the type certificate holders country were automatically accepted. Who says the department only takes away! (Just mostly)
For those who need to argue this this regulation works alongside the CAR30 reg which says "modifications must be approved by CASA" by stating "a modification is taken to be approved by CASA if:"
I do not blame most LAME's for not knowing this, CAAP 35-7 is an obscure doc that mostly applies to design organizations (The people who do EO's!). Unfortunately due to the complexity of the regs LAME's simply do not have time to troll through them all (took me 20mins and I knew where to find it!) in the hope they will save a few dollars.
Owners are always grateful when $$$ are saved but are rarely willing to pay for research time that does not pay off so LAME's are left making judgement calls of when to do more research.
This is when having a good knowledgeable LAME is worth paying extra for. BIG $$$$$$$ can be saved by knowing what mods are out there. Especially as some STC's are cheaper than the genuine parts they replace.
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In addition to what Progressive has posted here is the link to acceptance of foreign STC's.
Civil Aviation Safety Authority - AWB 00-16 - Acceptance of Foreign Supplemental Type Certificates (STCs)
"AWB 00-16 Issue 1, 17 January 2005
Effectivity
To all owners, operators and maintainers intending to incorporate an STC issued by a foreign country.
Background
CASR 21.114 Foreign STCs states: A certificate (however described) for an aircraft, aircraft engine or propeller that is issued by or for the NAA of a recognised country and is equivalent to a STC that could have been issued by CASA (a foreign STC) is taken to have been issued by CASA for these regulations. CASR 21.114 provides the Australian aviation industry with ready access to certain modifications that have been approved by recognised overseas authorities. This Bulletin clarifies some issues relating to this regulation, to assist the consistent use of foreign STCs."
A number of people getting together to have an STC drawn up where one does not exist rather than individual EO's could make sense. Or asking the stc holder to amend by adding additional types.
Civil Aviation Safety Authority - AWB 00-16 - Acceptance of Foreign Supplemental Type Certificates (STCs)
"AWB 00-16 Issue 1, 17 January 2005
Effectivity
To all owners, operators and maintainers intending to incorporate an STC issued by a foreign country.
Background
CASR 21.114 Foreign STCs states: A certificate (however described) for an aircraft, aircraft engine or propeller that is issued by or for the NAA of a recognised country and is equivalent to a STC that could have been issued by CASA (a foreign STC) is taken to have been issued by CASA for these regulations. CASR 21.114 provides the Australian aviation industry with ready access to certain modifications that have been approved by recognised overseas authorities. This Bulletin clarifies some issues relating to this regulation, to assist the consistent use of foreign STCs."
A number of people getting together to have an STC drawn up where one does not exist rather than individual EO's could make sense. Or asking the stc holder to amend by adding additional types.
Last edited by halfmanhalfbiscuit; 21st Aug 2014 at 15:37. Reason: More info
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Progressive,
Excellent post! And you are correct, many LAME's would not know. Is that their fault for not educating themselves? Which under the burden of everything else is easy to understand. Or is it the regulator who should be more proactive in educating industry and owners?
I think more the latter.
The issue about paying for the research…..well an avionics shop should be able to do the vast majority of the research in 15 minutes or less. Why? because they know the system (or should) and as you point out when you know where to look, it is far easier.
Straight forward installation of any avionics with an STC/AML is in most cases a monkey see monkey do process, the same as the last one, the same as the next one. At $110/hr that cost is max $30 not $700.
A more proactive approach to this and many other things in GA from both the regulator and the maintenance orgs would possibly make life in GA more affordable and thus create more work, not less.
I am sure Leadsled will have something to say on this when he gets around to it. Something like….look at how the biggest GA community in the world do this work.
BTW…hope the world is treating you well over there
Excellent post! And you are correct, many LAME's would not know. Is that their fault for not educating themselves? Which under the burden of everything else is easy to understand. Or is it the regulator who should be more proactive in educating industry and owners?
I think more the latter.
The issue about paying for the research…..well an avionics shop should be able to do the vast majority of the research in 15 minutes or less. Why? because they know the system (or should) and as you point out when you know where to look, it is far easier.
Straight forward installation of any avionics with an STC/AML is in most cases a monkey see monkey do process, the same as the last one, the same as the next one. At $110/hr that cost is max $30 not $700.
A more proactive approach to this and many other things in GA from both the regulator and the maintenance orgs would possibly make life in GA more affordable and thus create more work, not less.
I am sure Leadsled will have something to say on this when he gets around to it. Something like….look at how the biggest GA community in the world do this work.
BTW…hope the world is treating you well over there
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"Danger, Will Robinson".
Now having disclosed my age bracket, may I offer a few comments ? A couple of posters, whose identities I haven't figured out (Progressive and halfmanhalfbiscuit) appear to have some background in the design discipline so my comments should be read as being additional to theirs.
(a) although I have been out of the design delegate side of things for a decade or so, previously I had around 30 years as a CAR 22/35/36 and, earlier, ANR 21/40/41 Authorised Person and, for my sins, produced the occasional STC. (Hopefully my memory is correct with the Reg numbers).
(b) when it comes to STCs, a basic and underpinning consideration is that the STC is applicable ONLY to the configurations implicit in the STC S/N applicability range. That is to say, the STC folk are saying that their mod is OK to install on a bog standard aircraft (as defined by the applicability so it may not be OEM bog standard) - but if it has had any OTHER mods then all bets are off.
(c) the hyperlinked documents are well worth reading - in detail rather than superficially. CAAP 35-7(0), in particular, is the sort of document I would have loved to have had access to in my previous lives.
(d) from the CAAP at §8 -
8.1 It is the responsibility of the installer, not the registered operator, to ensure that the modification or repair is approved and can be installed in accordance with the supplied instructions.
Holders of modification or repair approvals should provide their clients or customers with a copy of the approval document. The installer must take into consideration that the particular aircraft may have other modifications or repairs that impact upon the incorporation of the modification or repair.
8.2 If the modification or repair cannot be incorporated in accordance with the supplier’s instructions, or there is a compatibility problem with other modifications and repairs, then an assessment of the modification or repair or the aircraft or both by CASA or a CAR 35 IoA holder is required. The basis for compliance with the airworthiness requirements is not always obvious and it cannot be assumed that a small change is trivial.
(e) and the AWB
The STC is normally approved based on a specific aircraft configuration. As additional modifications are installed, the interface and interaction with those unexpected modifications can be significant. The person installing the modification is required to review the STC and the aircraft being modified and ensure there are no unexpected modifications in the aircraft being modified that will conflict with the STC. The interaction with any such modifications must be evaluated. For complex interactions, specialist technical advice should be sought to ensure there are no adverse consequences. Installation of significant avionic equipment into an aircraft with a FADEC, is one example. Any change to the STC to ensure necessary compatibility must be separately approved.
(f) Now, I have had many years' involvement with LAMEs of all disciplines and hold them in high regard. However, the Industry long ago evolved to a point where no one individual has all the smarts. In general, the LAME is not well placed to make a determination in respect of incompatibility ESPECIALLY with anything to do with electonics. Trust me, that is the fact of the matter. In reality aircraft work now is a multidisciplinary activity and needs input from a bunch of people to make things work properly.
(g) by all means, the LAME can make the call but then he/she carries the can. Not having any legal competence, I don't know where this leaves the CofR holder or, indeed, the PIC, if the LAME got it wrong and the smoking hole in the ground were able to be linked to that mistake.
well an avionics shop should be able to do the vast majority of the research in 15 minutes or less
That may well be the case for some matters. Consider though, that one of my (very highly qualified and experienced on Type) guys, in just the past week or so, spent four (4) days before he was able to track down an autopilot fault in a very electric system. The problem ended up being a widget inside another widget .. etc ... and he had access to the entire WDM data as well as the aircraft.
Food for thought, I hope ?
Now having disclosed my age bracket, may I offer a few comments ? A couple of posters, whose identities I haven't figured out (Progressive and halfmanhalfbiscuit) appear to have some background in the design discipline so my comments should be read as being additional to theirs.
(a) although I have been out of the design delegate side of things for a decade or so, previously I had around 30 years as a CAR 22/35/36 and, earlier, ANR 21/40/41 Authorised Person and, for my sins, produced the occasional STC. (Hopefully my memory is correct with the Reg numbers).
(b) when it comes to STCs, a basic and underpinning consideration is that the STC is applicable ONLY to the configurations implicit in the STC S/N applicability range. That is to say, the STC folk are saying that their mod is OK to install on a bog standard aircraft (as defined by the applicability so it may not be OEM bog standard) - but if it has had any OTHER mods then all bets are off.
(c) the hyperlinked documents are well worth reading - in detail rather than superficially. CAAP 35-7(0), in particular, is the sort of document I would have loved to have had access to in my previous lives.
(d) from the CAAP at §8 -
8.1 It is the responsibility of the installer, not the registered operator, to ensure that the modification or repair is approved and can be installed in accordance with the supplied instructions.
Holders of modification or repair approvals should provide their clients or customers with a copy of the approval document. The installer must take into consideration that the particular aircraft may have other modifications or repairs that impact upon the incorporation of the modification or repair.
8.2 If the modification or repair cannot be incorporated in accordance with the supplier’s instructions, or there is a compatibility problem with other modifications and repairs, then an assessment of the modification or repair or the aircraft or both by CASA or a CAR 35 IoA holder is required. The basis for compliance with the airworthiness requirements is not always obvious and it cannot be assumed that a small change is trivial.
(e) and the AWB
The STC is normally approved based on a specific aircraft configuration. As additional modifications are installed, the interface and interaction with those unexpected modifications can be significant. The person installing the modification is required to review the STC and the aircraft being modified and ensure there are no unexpected modifications in the aircraft being modified that will conflict with the STC. The interaction with any such modifications must be evaluated. For complex interactions, specialist technical advice should be sought to ensure there are no adverse consequences. Installation of significant avionic equipment into an aircraft with a FADEC, is one example. Any change to the STC to ensure necessary compatibility must be separately approved.
(f) Now, I have had many years' involvement with LAMEs of all disciplines and hold them in high regard. However, the Industry long ago evolved to a point where no one individual has all the smarts. In general, the LAME is not well placed to make a determination in respect of incompatibility ESPECIALLY with anything to do with electonics. Trust me, that is the fact of the matter. In reality aircraft work now is a multidisciplinary activity and needs input from a bunch of people to make things work properly.
(g) by all means, the LAME can make the call but then he/she carries the can. Not having any legal competence, I don't know where this leaves the CofR holder or, indeed, the PIC, if the LAME got it wrong and the smoking hole in the ground were able to be linked to that mistake.
well an avionics shop should be able to do the vast majority of the research in 15 minutes or less
That may well be the case for some matters. Consider though, that one of my (very highly qualified and experienced on Type) guys, in just the past week or so, spent four (4) days before he was able to track down an autopilot fault in a very electric system. The problem ended up being a widget inside another widget .. etc ... and he had access to the entire WDM data as well as the aircraft.
Food for thought, I hope ?
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John,
Your post, whilst well thought out, is what I think is another problem with over regulation in GA. Are you saying that if I have an STC for a modified passenger door, then the aircraft is no longer 'bog standard' and that any other STC for any other after market modification, no matter to what systems it applies to, no longer applies?
Have I read your comments correctly?
So, my door mod renders my aircraft non-standard, and therefore I must get an EO for my transponder, rather than use the STC? That is what I understand you to be saying?
Your post, whilst well thought out, is what I think is another problem with over regulation in GA. Are you saying that if I have an STC for a modified passenger door, then the aircraft is no longer 'bog standard' and that any other STC for any other after market modification, no matter to what systems it applies to, no longer applies?
Have I read your comments correctly?
So, my door mod renders my aircraft non-standard, and therefore I must get an EO for my transponder, rather than use the STC? That is what I understand you to be saying?
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Not quite.
The need and requirement is for a (technically and certification)competent assessment of compatibility to be made as the STC holder, patently, can't do that for individual birds.
Clearly, there will be many installations for which this may be straightforward and the installing LAME can do it just fine.
However, and particularly as we see increasingly electronic birds, it just doesn't work across the board.
For instance, a mate runs a fleet of highly modified, fitted out with more kit than you could poke a stick at, aircraft ... which regularly drive the whitehanders and design engineering support guys to distraction with the innovative gremlins which pop their heads out regularly.
The LAME who allows him/herself to be browbeaten by a customer into doing a down and dirty assessment when such is inappropriate .. puts his/her neck into the noose whilst hanging the fundamentals out into a cold, cold breeze ...
Hard facts of life, I'm afraid.
Same thing applies the other way around - the designer of a one-off mod intended for a particular tail number has to ensure that it is compatible with both the OEM bog standard aircraft configuration plus all the other existing mods, including STCs, which might be present in the aircraft. Sometimes there are hidden things there which can bite everyone and even the experts goof off on occasion following which there is a serving of embarrassment all around ..
The need and requirement is for a (technically and certification)competent assessment of compatibility to be made as the STC holder, patently, can't do that for individual birds.
Clearly, there will be many installations for which this may be straightforward and the installing LAME can do it just fine.
However, and particularly as we see increasingly electronic birds, it just doesn't work across the board.
For instance, a mate runs a fleet of highly modified, fitted out with more kit than you could poke a stick at, aircraft ... which regularly drive the whitehanders and design engineering support guys to distraction with the innovative gremlins which pop their heads out regularly.
The LAME who allows him/herself to be browbeaten by a customer into doing a down and dirty assessment when such is inappropriate .. puts his/her neck into the noose whilst hanging the fundamentals out into a cold, cold breeze ...
Hard facts of life, I'm afraid.
Same thing applies the other way around - the designer of a one-off mod intended for a particular tail number has to ensure that it is compatible with both the OEM bog standard aircraft configuration plus all the other existing mods, including STCs, which might be present in the aircraft. Sometimes there are hidden things there which can bite everyone and even the experts goof off on occasion following which there is a serving of embarrassment all around ..
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All excellent points, but, ultimately, pointless.
Can you explain to me 'not quite' and still align it with your previous quote above?
I am yet to have an EO done on my aircraft that the person issuing and signing the EO is even to clap eyes on my aircraft.
He gets some paperwork from the guy fitting it, rubber stamps it, sends it back with a ridiculous bill and an AFM supplement that has been put together with the cut/paste function from the documentation put out by the manufacturer of the whatever component is being installed.
And, speaking with other owners, they report very similar, if not identical stories.
Complying with a lot of these regulations has very little to do with actual airborne safety. I am sure that there are plenty that do, but more than a fair share are just pointless paper chasing exercises designed to liberate money from owners pockets.
(b) when it comes to STCs, a basic and underpinning consideration is that the STC is applicable ONLY to the configurations implicit in the STC S/N applicability range. That is to say, the STC folk are saying that their mod is OK to install on a bog standard aircraft (as defined by the applicability so it may not be OEM bog standard) - but if it has had any OTHER mods then all bets are off.
I am yet to have an EO done on my aircraft that the person issuing and signing the EO is even to clap eyes on my aircraft.
He gets some paperwork from the guy fitting it, rubber stamps it, sends it back with a ridiculous bill and an AFM supplement that has been put together with the cut/paste function from the documentation put out by the manufacturer of the whatever component is being installed.
And, speaking with other owners, they report very similar, if not identical stories.
Complying with a lot of these regulations has very little to do with actual airborne safety. I am sure that there are plenty that do, but more than a fair share are just pointless paper chasing exercises designed to liberate money from owners pockets.
Last edited by RatsoreA; 22nd Aug 2014 at 01:17.
When you live....
CASA wishes to advise that CAAP 35-7(0) – Design approval of modifications and repairs has been cancelled/removed from the CASA Website.
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JT
QUOTE]Clearly, there will be many installations for which this may be straightforward and the installing LAME can do it just fine.[/QUOTE]
With due respect, at all times in this thread I have been targeting this as the majority of cases, which fall into the description you outline above.
This should be the focus here.
It seems to me many have just said rather than be proactive here, lets just slug an EO in for good measure. This gets you pinned against a wall starring at the point end of a gun if you do it in the USA…….so to speak!
Cheers!
QUOTE]Clearly, there will be many installations for which this may be straightforward and the installing LAME can do it just fine.[/QUOTE]
With due respect, at all times in this thread I have been targeting this as the majority of cases, which fall into the description you outline above.
This should be the focus here.
It seems to me many have just said rather than be proactive here, lets just slug an EO in for good measure. This gets you pinned against a wall starring at the point end of a gun if you do it in the USA…….so to speak!
Cheers!
Moderator
Can you explain to me 'not quite' and still align it with your previous quote above?
Are you saying that if I have an STC for a modified passenger door, then the aircraft is no longer 'bog standard'
Correct.
.. any other STC for any other after market modification, no matter to what systems it applies to, no longer applies?
No. Each STC embodiment requires an evaluation of its appropriateness with respect to the particular pre-mod aircraft - that can only be assessed on a one off basis unless you are looking at a small identical fleet. In particular, the next STC mod proposed to be incorporated needs to be considered in terms of the whole aircraft as it exists, including extant embodied STCs. It may well be that an existing, incorporated STC mod creates an incompatibility - the present STC OEM made no allowance for whatever mods your bird may have had incorporated previously (unless such is specified in the present STC paperwork).
How could a trivial door mod be a problem you might ask ?
First thing comes to mind is PEC if the static source is aft of the door, for instance.
I am reminded of a B52 program (if my recollection is correct) wherein a relatively minor skin profile change way out in front of the static resulted in an abort on the first test profile takeoff when the "wind in the wires" didn't match the TP's expectations compared to the ASI .. back to the drawing board.
If the door has an emergency release facility, does the door mod affect the inflight separation characteristics ? Not much good if the original mod had the door clearing the tail but the new mod results in the tail departing with the door in close formation .. ?
The list goes on .. all that means is that I've made, or seen, or heard of, or read of, a great bunch of stuff ups made by supposed experts who just happened to overlook something.
The Challenger disaster is a leading example of this philosophical concern.
So, my door mod renders my aircraft non-standard, and therefore I must get an EO for my transponder, rather than use the STC?
Not necessarily, but perhaps. Someone MUST make a determination that the door mod is compatible with the intended radio mod. That determination may be easy or it may be complex .. either way it must be made and by competent person(s). If the end result is a stuff up in concert with a mishap, then stand by and watch the lawyers circling the carcass.
I am yet to have an EO done on my aircraft that the person issuing and signing the EO is even to clap eyes on my aircraft.
That may well happen and, in some situations, may be quite reasonable. However, I would have thought that the fee charged should reflect the real cost - but keep in mind that the time at the aircraft, especially for a small job, may reflect only a small proportion of the actual and accountable costs. ie small jobs cost more in overheads to the consultant than large jobs
In my own practice, for instance, the only job I can recall approving without either having attended personally or by collegiate proxy was for an airline F28 and that was appropriate, considering the circumstances and the particular job. Most, if not all, of the remainder involved much clambering over, in, and under various aeroplanes, helicopters, and other strange forms of aeronautical conveyances.
Complying with a lot of these regulations has very little to do with actual airborne safety.
I empathise with your concern. However, keep in mind that a lot of certification involves stuff which may not at all be obvious. The direct link to safety may seem to be tenuous at times but that is the nature of the beast.
Did that just disappear today?
Had to smile. Just about immediately after making the previous post, in comes the email handout from CASA with the cancellation advice .. The obselete document should remain on the site for a little while until the system catches up with it. Just rechecked now (1330EST) and it is still there.
Does anyone still have an archive copy?
Sure do if anyone wants a copy after the CASA site deletes it.
I wonder what it means...?
That's easy .. the document is obsolescent/obsolete - take your pick.
If you look here you will note that the discussion paper infers that the process reflects a move from the old stuff to the new.
I note that the next email in this morning notified changes to CAR 30 so it appears that things may be moving ...
Are you saying that if I have an STC for a modified passenger door, then the aircraft is no longer 'bog standard'
Correct.
.. any other STC for any other after market modification, no matter to what systems it applies to, no longer applies?
No. Each STC embodiment requires an evaluation of its appropriateness with respect to the particular pre-mod aircraft - that can only be assessed on a one off basis unless you are looking at a small identical fleet. In particular, the next STC mod proposed to be incorporated needs to be considered in terms of the whole aircraft as it exists, including extant embodied STCs. It may well be that an existing, incorporated STC mod creates an incompatibility - the present STC OEM made no allowance for whatever mods your bird may have had incorporated previously (unless such is specified in the present STC paperwork).
How could a trivial door mod be a problem you might ask ?
First thing comes to mind is PEC if the static source is aft of the door, for instance.
I am reminded of a B52 program (if my recollection is correct) wherein a relatively minor skin profile change way out in front of the static resulted in an abort on the first test profile takeoff when the "wind in the wires" didn't match the TP's expectations compared to the ASI .. back to the drawing board.
If the door has an emergency release facility, does the door mod affect the inflight separation characteristics ? Not much good if the original mod had the door clearing the tail but the new mod results in the tail departing with the door in close formation .. ?
The list goes on .. all that means is that I've made, or seen, or heard of, or read of, a great bunch of stuff ups made by supposed experts who just happened to overlook something.
The Challenger disaster is a leading example of this philosophical concern.
So, my door mod renders my aircraft non-standard, and therefore I must get an EO for my transponder, rather than use the STC?
Not necessarily, but perhaps. Someone MUST make a determination that the door mod is compatible with the intended radio mod. That determination may be easy or it may be complex .. either way it must be made and by competent person(s). If the end result is a stuff up in concert with a mishap, then stand by and watch the lawyers circling the carcass.
I am yet to have an EO done on my aircraft that the person issuing and signing the EO is even to clap eyes on my aircraft.
That may well happen and, in some situations, may be quite reasonable. However, I would have thought that the fee charged should reflect the real cost - but keep in mind that the time at the aircraft, especially for a small job, may reflect only a small proportion of the actual and accountable costs. ie small jobs cost more in overheads to the consultant than large jobs
In my own practice, for instance, the only job I can recall approving without either having attended personally or by collegiate proxy was for an airline F28 and that was appropriate, considering the circumstances and the particular job. Most, if not all, of the remainder involved much clambering over, in, and under various aeroplanes, helicopters, and other strange forms of aeronautical conveyances.
Complying with a lot of these regulations has very little to do with actual airborne safety.
I empathise with your concern. However, keep in mind that a lot of certification involves stuff which may not at all be obvious. The direct link to safety may seem to be tenuous at times but that is the nature of the beast.
Did that just disappear today?
Had to smile. Just about immediately after making the previous post, in comes the email handout from CASA with the cancellation advice .. The obselete document should remain on the site for a little while until the system catches up with it. Just rechecked now (1330EST) and it is still there.
Does anyone still have an archive copy?
Sure do if anyone wants a copy after the CASA site deletes it.
I wonder what it means...?
That's easy .. the document is obsolescent/obsolete - take your pick.
If you look here you will note that the discussion paper infers that the process reflects a move from the old stuff to the new.
I note that the next email in this morning notified changes to CAR 30 so it appears that things may be moving ...
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John,
It's not the triviality of the door mod, it's what relation does that mod have to with the replacement of a small box in the panel with another almost identical small box?
And the need for an aeronautical engineer to give me a bunch of paper work (the cost of which was a little over DOUBLE what it cost me for the guy with the soldering iron to actually put it in there!) that doesn't tell me, or anyone else operating the aircraft, something that they already know?
I suspect that you would be in the minority that feel the fee should reflect the work involved, as I have been quoted from $660 to $1500 for JUST the EO for a transponder. And in ALL cases, the place issuing it, won't have looked at the aircraft. It cost me 3 hours labour to have the actual unit fitted.
It's cost like these, which can be anywhere from 2-5 hours of equivalent flight revenue, is killing GA, and they don't do ANYTHING.
If you can draw the direct link to safety for these, I am only to happy to see it, but from my point of view, it's just a way to bleed owners a little further.
It's not the triviality of the door mod, it's what relation does that mod have to with the replacement of a small box in the panel with another almost identical small box?
And the need for an aeronautical engineer to give me a bunch of paper work (the cost of which was a little over DOUBLE what it cost me for the guy with the soldering iron to actually put it in there!) that doesn't tell me, or anyone else operating the aircraft, something that they already know?
I suspect that you would be in the minority that feel the fee should reflect the work involved, as I have been quoted from $660 to $1500 for JUST the EO for a transponder. And in ALL cases, the place issuing it, won't have looked at the aircraft. It cost me 3 hours labour to have the actual unit fitted.
It's cost like these, which can be anywhere from 2-5 hours of equivalent flight revenue, is killing GA, and they don't do ANYTHING.
If you can draw the direct link to safety for these, I am only to happy to see it, but from my point of view, it's just a way to bleed owners a little further.
Moderator
it's what relation does that mod have to with the replacement of a small box in the panel with another almost identical small box?
Problem is, how to set up a prescriptive system with sufficient information to allow folk to determine in advance of a determination that the situation is as simple and unrelated as you infer ?
I agree, wholeheartedly, that a significant proportion of (GA) mods (in particular) are trivial and easy peasy for the incompatibility assessment. One still needs to cover the complex animals and a way of not trivialising the categorisation of each.
I can't give you the answer but, having been there on both sides of the table, I can detail the problem. (One of the few times, I guess, that an engineer has a problem but not the solution .. usually engineers are characterised by having a solution looking for a problem).
the fee should reflect the work involved
but that needs to be done on a rational basis with all costs, including the hidden on-costs, included. Unless the job is on a mates' rates foreigner deal (and, even then, the delegate or AP carries the liability cost), it is going to cost some real dollars .. only the quantum is to be determined.
is killing GA
tell me about it .. I get fiscally raped regularly by the design folk I use. Sometimes they are worth their weight in gold .. for simple jobs the overheads get up my nose. Gets a lot worse the further up the formality chain you go, I'm afraid.
but from my point of view
appreciate your frustration but do consider it from the LAME's, owner's and pilot's position of liability. While I can't speak to the two last, the LAME who does a down and dirty assessment can find him/herself way, way out on a limb and penniless after the mishap and subsequent sequence of legal fun and games.
Problem is, how to set up a prescriptive system with sufficient information to allow folk to determine in advance of a determination that the situation is as simple and unrelated as you infer ?
I agree, wholeheartedly, that a significant proportion of (GA) mods (in particular) are trivial and easy peasy for the incompatibility assessment. One still needs to cover the complex animals and a way of not trivialising the categorisation of each.
I can't give you the answer but, having been there on both sides of the table, I can detail the problem. (One of the few times, I guess, that an engineer has a problem but not the solution .. usually engineers are characterised by having a solution looking for a problem).
the fee should reflect the work involved
but that needs to be done on a rational basis with all costs, including the hidden on-costs, included. Unless the job is on a mates' rates foreigner deal (and, even then, the delegate or AP carries the liability cost), it is going to cost some real dollars .. only the quantum is to be determined.
is killing GA
tell me about it .. I get fiscally raped regularly by the design folk I use. Sometimes they are worth their weight in gold .. for simple jobs the overheads get up my nose. Gets a lot worse the further up the formality chain you go, I'm afraid.
but from my point of view
appreciate your frustration but do consider it from the LAME's, owner's and pilot's position of liability. While I can't speak to the two last, the LAME who does a down and dirty assessment can find him/herself way, way out on a limb and penniless after the mishap and subsequent sequence of legal fun and games.