Change in CAA attitude to small mods?

[IO540]

A couple of years ago, fitting gas landing lights (the sort modern cars have) would have been a design exercise requiring a CAA L2 approved company - about £2000 in paperwork before actually doing anything. The lights draw LESS current and give out LESS heat so there should be no issue if properly done.

I've just heard that somebody got them fitted without problems.

Has there been a change in the CAA approach to this, or is this a slip-up? I know the latter is very possible as not every LAME knows the rules and I know of several cases of trivial but technically illegal work.

If the CAA permitted trivial mods like this, especially ones that are routinely done in the USA under a 337, it would leave the FAA IR as the only reason to go N-reg. Now, they couldn't be THAT smart could they be??? :O

[dirkdj]

IO540,

EASA is now in charge, not the CAA. If the STC was accepted previously anywhere in EASAland, it is accepted in all member states.

[IO540]

That still means (doesn't it?) that if the item has not been fitted in the EU previously, we are still back to the CAA approving it.

There is a treaty between the CAA and the FAA for mutual recognition of approvals (90+ pages of it) but AIUI the CAA has still got to approve it, in the form of issuing an AAN.

[Genghis the Engineer]

Nope, we have to apply to EASA. More to the point, the overseas STC holder has to apply to EASA, you can't do it yourself.

Any UK/FAA agreements are now dead. Also, nobody issues AAN's any more except for Annex II aircraft, it's an EASA STC.

UK CAA *may* do the work, but as contractors to EASA, not in their own right.

That does however apply to major mods, a change of light bulb is likely to be a minor mod, I'm not sure what the new rules are there - anybody?

G

[IO540]

GTE

That's astonishing and not what the CAA man told me last week when I was checking out if he had an STC for something and had issued an AAN.

Getting a US company (the STC holder) to get off their backside for a one-off sale is going to be very hard!

Do you have a reference for the FAA-CAA treaty being dead?

I am not doubting this but as I say it is hard to believe.

I've also noticed that the CAA appears to have replaced the loss of the star annual fee with a £9000 charge on every JAR145 maintenance outfit. If the work isn't there, why don't they do what every other outfit would do and simply make staff redundant? They have just clobbered most self employed LAMEs.

As with a few other things, the letter "N" seems to be the way to go........

[WorkingHard]

IO540 -
"I've also noticed that the CAA appears to have replaced the loss of the star annual fee "
Would you be so kind as to explain a little more please. You seem to be indicating no more CofA renewals. Is that so?

[ACX]

I believe that changes to minor mods will come in when the EASA scheme of charges comes into force. These charges are expected to be introduced during the summer at which point it will be illegal for the CAA to charge for the parts of the EASA regulations that EASA are directly responsible for, i.e. design and certification tasks. C of A issue, etc stays with the CAA as this is delegated to the competent authority.

It is still a bit sketchy, but I believe the basis process is that minor mods for aircraft over 2000kg will be done directly by EASA (no CAA involvement) and we will have to pay EASA directly. For aircraft under 2000kg these will be done by the CAA at NO CHARGE!

As has been said all approvals of STC's must be made by the holder directly to EASA/National Authority responsible for the type. This is basically because the FAA deems an STC to be a major mod.

ACX

[Genghis the Engineer]

IO540, no I don't have a reference and am not all that certain that one exists. I speak to the folks at Gatwick quite a lot, and sit on a few fairly important committees, so that's my understanding of the latest position from there. It does however seems to be in a constant state of flux.

Best advice I can offer at the moment is that if you have a specific mod in mind, phone the nearest CAA regional office and ask to speak to a "surveyor" for a chat about it.

G

[ACX]

Speak to your local CAA regional office and get their advice. However, i beleive that it will be a major mod.
Ask the STC holder if they have sold any kits to another operator in Europe. If the answer is YES you should be able to check with that local authority that the STC is approved. Them just fit it.

The LBA have a very good section on their website listing all the STC's they have approved.

Best of luck
ACX