Fitting "non certified" avionics as secondary instruments

[englishal]

I was wondering whether it is possible to fit some of these non-certified avionics found in may permit aircraft to a CofA aeroplane as a "standby instrument"? For example one can pick up a pretty funky Dynon Skyview system for under 3000 GBP from Harry M's, which is cheaper than a certified MFD. If you could fit one of these in the P2 position as a "secondary" instrument, would this be legal. I'm thinking G reg and N reg here.

Some amazing pieces of kit out there a tenth the price of a G500, so it would make sense to have these as "backup" instruments while retaining the old instruments. I assume that as long as it didn't interfere with the certified avionics then it should be ok?

Ok, if it is NOT ok, then why can't one get an STC to fit one as a standby instrument, exactly the same was as JPI do with their range of EDM secondary engine monitors? I imagine if this was done under the FAA then the costs would be relatively low and fairly easy....??

[cambioso]

Why not fit them anyway (as a standby system of course!), and then placard them, in nice big letters, "inop" or "not for aviation use"?
Remove them when it's annual check time, and replace them after........ then everyone is happy!!!!

Tin Hat on, standing by for "Incoming" !!!

I'm reading Geoffrey De Havilland's autobiography at the moment (Sky Fever). He describes the situation when they had devised an aero engine with a new dual ignition system (all engines up to then had single ignitions). The Ministry wallas got involved and decreed that, for safety(?!) reasons, the dual ignition had to be disabled to a single ignition (by removing a plug lead I guess) for all flights further than 3 miles from the airfield. The system could be used inside the 3 mile limit??!! This was in the early 1920s...............Kind of comforting to think that after 80+ years, things haven't changed eh?

Jez

[IO540]

It is very difficult to get an authoritative view on this kind of thing, and of course it varies between states of registry anyway.

My understanding is as follows, for N-regs:

In general to do a mod on an ICAO CofA plane you need Approved Data for the item in question.

Approved Data can be a Type Certificate (so if the item was on the original type certificate, for the right airframe S/N range, you can just install it at any later date, with just a logbook entry), a Supplementary Type Certificate (you need to apply for approval for this e.g. an FAA 337 but this almost invariably won't be refused), a design done by an FAA DER (comment as previous), a TSO or PMA approval of the item (this is more tricky because the TSO/PMA is unlikely to specify the whole installation environment), etc.

Or you can go through FAR Part 43 Appendix A (the list of Major Mods), and all the various guidance notes, and if it is not in there then by definition (**) you can install it as a Minor Mod, with just a logbook entry.

It is completely standard and in accordance with proper US/FAA practice, to do Minor Mods using TSOd items, with just a logbook entry and appropriate documentation in the work pack (load analysis, W&B). I think you could install a genuine backup instrument, using TSOd parts, in this way, anytime, and any A&P/IA (who can read Part 43 Appendix A) will sign it off. And example would be a backup oil pressure gauge system made up of TSOd parts (sensor and indicator); this is one area I have researched in detail.

The fact that something is a Minor Mod does not do away with the need for component traceability so everything needs to come with a suitable document, which can be an EASA1, 8130-3, or any other bit of paper which provides traceability information (***). You can't just buy something from B&Q, although if you got the exact same item with a TSO/PMA and a Certificate of Conformity showing a batch # then you could.

Obviously there are grey areas around the corners of what is a Minor Mod, and these move according to who is trying to make money out of who. One long standing one was the installation of the superior Concorde solid-gel batteries in place of the old liquid acid Gill ones. To deal with the widespread installer illiteracy and for marketing reasons, Concorde got various (trivial) STCs, but eventually the FAA ruled that the swap can be done with just a logbook entry and that is now the US practice (which is great news). But these batteries are properly aviation-approved so you do have that bit of Approved Data; you could not fit a car battery from Halfords.

A bit of homebuilt-category avionics like a Dynon is a problem because it has not even a TSO or PMA approval (AIUI). You would need to pay a DER to generate Approved Data. I have never heard of anybody doing that; I guess it would be nontrivial. I have researched a fixed satellite phone installation and that was what I found; Iridium have the market sewn up, with several "approved" products.

If the Dynon had TSO or PMA then it can do it, with proper documentation etc. I do think there are issues otherwise everybody would be doing it. A TSO does not mean much, and certainly no GA aviation approval means anything w.r.t. reliability or design quality, but it does cost money. I looked at getting a PMA approval for something I was going to manufacture and it was very hard for a non-US business to get, largely due to the need to host a load of American officials for a while, while they inspect your factory.

The way to avoid all this crap is to make the item "temporarily" mounted e.g. velcro. The FAA did try recently to stop more "obviously permanent" GPS installations which use e.g. a yoke mounting bracket but they backed off under the sh*tstorm which ensued as that would have killed most of the portable aviation GPS market :)

(**) It is customary for the big UK avionics shops, and the less "educated" US avionics shops who can't read the regs, to disregard this and treat everything they do as a Major Mod, pay a DER, send off a 337, etc. This obviously increases the cost substantially. The FAA has said in various seminars they don't like this, and the other day one US avionics installer told me they have had 337s returned by the FAA on grounds of triviality. But the practice continues, and going to a DER is a "safe" CYA procedure which cost a few hundred bucks per signature (a DER won't return an application on grounds of trivia because he makes a living that way).

(***) This is a ripe area for disinformation and revenue generation, with items "requiring" and EASA1 form selling for 2x as much ;) and this is true for both FAA and EASA rules.

[jez d]

englishal

If it's for a G reg aircraft then suggest you contact the Yakovlevs: The Yakovlevs Aerobatic Display Team 2009 (http://www.yakovlevs.com/)

Their aircraft are fitted with Dynons following a minor mod approval from the CAA.

[englishal]

Thanks Jez, Interesting...

[Fuji Abound]

It is not OK on a UK reg. and obtaining a minor mod. will almost certainly prove expensive and time consuming. I have been there.

I am not saying it cant be done and depending on the installation the hassle may diminish but it is not to be taken on lightly.

If you find someone to just "do it", you risk more problems when the annual is due.

Even "removable" equipment can be an issue unless of course you remove it before the annual!

I wish it were otherwise but better to tell you how I found it.

[A and C]

If I find an unapproved bit of kit at maintenance check I am bound by law to remove it before the aircraft can be released for service.

I suspect but cant prove that some kit gets removed from aircraft before I see the aircraft for a maintenance check and then refitted after the aircraft has gone back to the owner. This is of course not leagal but I cant the aircraft under survalance 24 hours a day!

[IO540]

If the kit is removable then it is not illegal, however ;)

A piece of panel mounted avionics is not likely to be removed for the Annual, because it would leave a big hole in the panel, plus the cable connector.

And if a bit of kit is removable then it should not be illegal to do the Annual with it present... no?

Historically, in a typical 30 year old spamcan, a lot of items would have been installed without the right paperwork, years ago. A MO is entitled to assume that they went in legally even if the logbooks all the way back to 1980 don't exist. Presumably, A&C, you are referring to some really obvious installation of say a Garmin 296 screwed into the panel?

[Fuji Abound]

If the kit is removable then it is not illegal


I would not be so certain.

I suspect if you leave it in place you may still have issues at the annual depending how it is installed.

[Halfbaked_Boy]

I would not be so certain.

I suspect if you leave it in place you may still have issues at the annual depending how it is installed.

So the Garmin, FlyAngel etc GPSs we use aint legal?

But they are installed - you have to plug 'em in!

[Pilot DAR]

Using the case of a type certified aircraft in North America, operating under the flight authority of a standard C of A, the following requirements must be met: (my words)

A pilot may not attempt to fly an aircraft which does not conform to it's type design. It is either the original C of A, or the revalidation of that C of A by qualified inspection which confirms the conformance to it's type design at the required intervals.

When the plane leaves the factory, only approved and certified (as conforming to their type design, and thus being worthy), "pieces of kit" will be installed. There after, only similarly certified "pieces of kit" which are approved on that aircraft, may be installed, or you are invalidating the measure of "conform to type design", and thus the C of A.

The fact that something is certified as airworthy, TSO'd etc. does not automatically qualify it for installation in any aircraft. A Gramin 430 is "certified" and obviously commonly approved for installation in lots of aircraft types - but not helicopters after they leave the factory, other than by special approval. A tire will be TSO'd, and thus certified, and it might be the right size to fit your aircraft, but that does not make it's installation legal (conforming). It might be the wrong ply rating. The TSO'd tire, battery etc. still must be approved as a part of the type design.

Generally any change to the aircraft which has "other than a negligible effect" (those are government words, not mine) requires an approval.

If you're attaching your hand held GPS to the gawd awful transformer robot mount that grips the control column tube, and you do it right, and check everything moves as it should/shouldn't, you're probably okay, though do remind yourself that the instructions will say in there somewhere, that you must assure that you have not affected the safety of flight. If you don't think of something, and have an accident, you the installer pilot will suddenly be repsonsible for flying an unairworthy aircraft. In turbulance, could the GPS flip back, and jam full nose down control? Might the "temporary" GPS installation block the normal view of a gear unsafe light? I have seen many pilot/owner installed mods which definately would not be considered "minor", and would certainly require an approval or certification to be "airworthy".

The rule of thumb used by Transport Canada locally is that if a tool is required to perform the installation, or it wires into other than the cigarette lighter socket, it probably requires an approval.

There are lots of very worthwhile "things" which might be installed in an aircraft, which no one has yet approved. It does not make them not worthwhile, they are just not proven as conforming to the required type design yet.

[englishal]

We have a garmin Aera 550 as VFR GPS (as a backup to the 430). This is wired into the aircraft power through a CB and has a hull mounted antenna. It is mounted on the Garmin aviation mount which is screwed to the throttle quadrant behind the levers and the wires are routed behind the plastics and carpets to it is a nice installation. To remove the Aera you pop it from the backet and take it home. However the bracket is permanently mounted to the throttle quadrant plastics with the wires permanently routed. There is also a data port mounted in the dash to connect to a Zaon as well as USB.

This is signed off by an FAA IA on a 337 so I guess should be legal? (it was installed by an avionics engineer and our maintenace co. so don't worry about fouling levers with the wires, it was done properly).

[IO540]

or it wires into other than the cigarette lighter socket

However, one can do a certified power connector installation, and then what goes into that is a separate issue. Maybe all power connectors in aircraft are illegal, but it would suprise me if that was so.

I agree re doing it properly which is why I would never use a traditional yoke mount. The awful yoke mount which comes with a Garmin 496 is OK for a Russian combine harvester and that's about it. However, doing a job properly is not the same as it being legal...

other than a negligible effect

That's a huge subject though, isn't it?

Taken literally (which is more or less the EASA line) this is the same as saying that an A&P or an IA is dumb, cannot read, has no idea how a plane works, and has no authority to sign off any mod other than a Type Certificated add-on accompanied by full drawings for that specific serial number range airframe. Yet, the foregoing text is simply not the actual practice in FAA-land.

[wigglyamp]

On EASA aircraft, all components fitted to the aircraft other than standard parts (mil-spec hardware etc) must be released on an EASA Form 1 or equivalent - regulation 21A.307. Therefore installation of non-approved kit into a certified aircraft is a non-starter - and doing so voids the C of A and insurance. Look out if you have a non-approved modifcation in your aircraft and try to make a claim following an accident!
There are methods for non-ETSO equipment to be used, but this will be when the equipment normally has an FAA TSO and comes with an FAA 8130-3, and the equipment will then be approved via an EASA Part 21J DOA or directly by an EASA minor change. Other totally un-approved parts can also be got onto an aircraft but then it's via an EASA STC ( and for the hassle involved, it's not worth attempting).
In the case mentioned of the Dynon in Yaks, the YAK52 is an Annex 2 aircraft - it's on a CAA permit and not an EASA C of A, so 21A.307 doesn't apply, in exactly the same way as for ex-UK military aircraft. The Dynon isn't fufilling any mandatory requirement as the aircraft is Day VFR so carriage of an artificail horizon is not required.

On N reg aircraft and the comment by IO-540 about un-necessary Form 337s when the change could be classified as Minor and done as a logbook entry. Most A/Ps & IAs that I know won't clear a mod as a minor change unless the work is a direct form/fit/function swap of one box for another, such as changing a King KT76A transponder for a Trig Mode S unit or a like-for like upgrade of an ELT from 121.5 to 406. Beyond this, they expect changes to be covered on a Form 337 as a Major alteration. A 337 requires approved data, and this can be either from a DER on an 8110-3 (this is how we typically work), an FAA STC or by having the FAA FSDO sign the 337, which I don't believe happens outside the US. Therefore, the additonal costs incurred for a DER approval, whilst not always desireable, are in many cases the only method to get the mod signed off.

[englishal]

Could you get a DAR to sign off a Dynon system as "secondary instrumentation" though? If a DAR costs 1000 quid (being generous here!) and the Dynon 3500 quid then you could end up with a neat secondary instrument package relatively cheaply (in aviation terms)....? This would give stdby AI, DI, MFD all in one hit.

Some of the non-approved MFDs are half the price of an "approved" one, yet probably contain much the same electronics.

In the case of our Aera, it is only the power supply and antenna installation which needs a sign off, which is a pretty standard thing to sign off (antenna location and mounting, power supply and CB choice).

[wigglyamp]

Fitting any form of EFIS in an FAA-certified aircraft will be based on FAA AC23-1311-1B. An EFIS attitude indicator is automatically an STC just as it is with EASA, so a DER isn't going to sign it off. The equipment must have a hardware and software Design Assurance Level C as defined in AC23-1309-1D, so there is no way to put un-certified EFIS which has none of the required equipment qualification in a certified platform - sorry!.

[Pilot DAR]

Taken literally (which is more or less the EASA line) this is the same as saying that an A&P or an IA is dumb, cannot read, has no idea how a plane works, and has no authority to sign off any mod other than a Type Certificated add-on accompanied by full drawings for that specific serial number range airframe.

I have never thought of the people of the maintenance world "mechanics" to generalize (though I know there are many types) in this context. Many of the modifications I am asked to approve originate with "mechanics", and are excellently thought out, and very workable. I nearly always approve them with little change.

That said, every type certificate contains a section called "certification basis". This defines what is the minimum design standard applicable to that type, and that becomes the minimum standard to which any mod must also qualify, and demonstrate compliance. Though I agree that "mechanics" are very skilled, it is possible that they are not a conversant with the design standards, and how they are to be interpreted, and applied. That's where the FAA "DER" or TC "DAR" (very similar roles) come in.

Added to this, you will see a statement at the bottom of STC's requiring the installer to assure that the installation of that mod, does not create an unsafe condition in the context of the other mods which may already be installed on the aircraft. This is because the original type design showed compliance, and the first STC did also, but it is very possible that the second STC was not assessed for design compliance in the context of the aircraft with the first STC installed, the permutations would be very numerous!

An example of this would be; could you install a Horton STOL kit on a Cessna 185, which already has a Robertson STOL kit installed? Surprisingly, in some cases, yes! In an other case, I specifically approved such an installation.

Another much less comfortable example is the installation of an STC apporved TCM 550 engine to on a Cessna 180, in place of the O-470. The 550 has a much greater fuel flow, but the 180 airframe has demonstrated that it can provide that fuel, so compliance with the fuel flow requirement was found. However, the "least favourable attitude for fuel flow" used was probably not the higher pitch attitude attainable with a STOL kit, or VG kit. Yet there are many examples of aircraft with combined mods. I can tell you from personal experience, that in at least two Cessna 180's so modded, it is possible to fly the aircraft at full power at a pitch attitude so high (and much higher that the original) that fuel flow for the larger engine cannon be maintained, and it quits. 'Been there, done it! This is exactly the situation which could exist with a pilot straining the plane over the trees on takeoff - and then it quits!

The installer of the second STC, had not considered the iner-relationship of the second STC, with the first, and an unsafe, and non compliant aircraft was the result.

I realize that this is a far extreme situation from that presented in the original poster, but it is important to conssider that a DER/DAR is the person who's job it is to establish that ALL applicable design requirements for a mod have been considered, and met. "Mechanics" perhaps can do this, DER/DAR must!

[IO540]

I suspect that if wigglyamp's reply correctly ties the Dynon product to the FAA EFIS (337 needed, etc) requirement, then that is the end of that... no practical way to do it.

Otherwise, loads of "backup" instruments are installed in the USA as a minor mod. You can install a backup altimeter (TSOd obviously) in that way. Backup engine instruments, likewise.

The thing which catches out a lot of people is that a lot of engine instruments are not certified as "primary" so the original gauge has to stay - even if it is useless. In my TB20, the EDM700 is certified as primary so no other CHT/EGT gauge is present, but on the TB21 the original CHT/EGT gauge has to stay...

In practice, there are holes in all this, potentially. I know of Skytec starter motors with an STC for aircraft X but which draw about 3x more current than the relay(s) can carry, and they get welded...

[wigglyamp]

The following is an extract from FAA AC23-1311-1B. You can see that the FAA anticipated applicants wanting to install EFIS-type displays as secondary instruments without going through the STC process and have cut that out immediately.
8.1
b. There have been applications to install equipment, such as flight and navigation displays, as non-required. These applications request approval for these installations as Situation Awareness (SA) only. It is not acceptable to label an instrument as "SA-Only" and assume that its failure condition is acceptable. Installing compelling displays that provide Primary Flight Information (PFI), but do not meet the appropriate operational and airworthiness requirements, and labeling them as "Supplemental" or "SA-Only" is not acceptable. Section 13.6 provides more guidance.

c. The basis for certification has been that the equipment should perform its intended function and not present a hazard. Instruments that aid situation awareness should be certified under the part 23 requirements, including § 23.1301 and § 23.1309. These displays could provide hazardous misleading information. PFI is essential for safe operation. An instrument that provides PFI should meet the minimum standards of applicable TSOs or an equivalent standard. It also should meet the guidance in AC 23.1309-1C, AC 23-17B, and the guidance in this AC.

[IO540]

No wonder the Dynon stuff is so much cheaper :)

[Papa Whisky Alpha]

I have read this thread with interest. I have just returned from the Flying Show at the NEC where my wife bought me an "Aware" as a Christmas present. Am I invalidating my ARC and / or C of A if I fit this device in my a/c ? I note on the blurb that the CAA has commended it.

PWA

[IO540]

Wigglyamp raises an interesting point about the NY IFO not processing 337s anymore.

I found this too, when i tried to get a GPS approach approval for my plane. They gave the avionics shop (the last of the three that tried this) a right run-around, clearly not wanting to do it.

The DER route to get around this is a good one but is a lot more expensive...

Isn't there one other option which is to fill in a 337 (which needs an IA, etc) and send it off, wait for X months, and if one hears nothing, one can install it as proposed? That way, the NY IFO not co-operating would not matter.

[Fuji Abound]

My experience comes form some years back wanting to fit a moving map GPS. There wasnt a convenient space in the panel so I explored various other options.

It is attractive to think that the installation would be straight forward, however in the design assessment it is clear there is much to consider, including the ability to read and operate the instrument, the instruments impact if any on cockpit visibility, electrical safety and integrity of the fitting. In reality none of that is unreasonable.

I am most certainly not one for over regulation and the costs involved and hassle in mod approvals of this sort maybe out of proportion, however, I think the principle is sound - which is that if you fly a certified aricraft the C of A provides some comfort professional expertise has been applied to the selection and installation of the equipment fitted.

You may believe you can do as good a job in making this assessment as an approved shop (and doubtless some can) but some equally cant.

[maxred]

I have just been asked to remove, not only the Garmin hand held unit, but the temporary mount on the dash due to 'not on the original equipment list'.

I have been told that anything, not covered by an STC, or incorporated by a certified original equipment list, cannot remain at time of certification, and for subsequent inspections. - N REG:=

[englishal]

Can't it be signed off on a 337 ?

Don't 337's go to Heathrow these days?

[maxred]

Not sure where the form goes, but my understanding is that the 337 is for Major Repair/Alteration.Almost like a new STC application, which as IO poiints out could take months.

I capitulated in the case of the GPS, by temporarily removing it for an easier life.

These issues, (normally) crop up when you fall foul of the regs, as in the case of certification (new), or major sign off work.

The situation is of course correct, in that the equipment, if altered since manufacture, where it was certified, to be replaced by anything 'non certified', must be removed for sign off. A fair enough point I think.

[Pilot DAR]

Being a Canadian guy, eh, I will not claim to know all the ins and outs of the FAA 337 form system. What I do believe, however, is that "approvals" for modifications by "337" are being issued by the FSDO (flight standards distric office), as opposed to the ACO (aircraft cerification office). As I mentioned earlier, the possible absence of the aircraft certification perspective in the "approval" process, may result in an oversight of a certification consideration. That is not to say that the "mechanic's" perspective is not very valuable, and appropriate, it just might not be complete from a "showing of design compliance" perspective.

I hold this opinion, because there is history of 337 "approved" modifications not being accepted by Transport Canada, when an American aircraft is imported into Canada. I have had to issue new STC approvals to cover a mod found to be on the aircraft by 337, which the purchaser could not, or was unwilling to, remove.

Of course things get carried away, and I can say that 5% of inquiries I receive about approving a mod, I send away with advice (sometimes a letter) as to why my evaluation says it's not even a mojar mod, and does not require a formal approval. The measure I use (with some caution for interpretaion differences) is found here:

Okay... I'll put it up later, it seems Transport Canada's website is down right now.

[wigglyamp]

There seems to be some confusion on when/how the 337 is used. In the US, most 337s are used as part of a 'Field Approval'. In this way, the FAA FSDO inspector approves the data that is used for the modification (this could be a follow-on from an existing STC that isn't directly applicable to the subject aircraft), or it could be the manufacturer's installation manual. The FSDO inspector will make a statement in box 3 confirming approval of the data. One the installation has been carried out, the repair station or IA will make the box 7 approval for return to service after the A&P or repair station has cleared box 6 for conformity of the modification to the apprpoved data, which will be listed on the back page of the 337.
In the alternative case, the installation data will already be approved by an STC (this may be an AML STC with hundreds of aircraft listed such as for the JPI EDM700), or it could be data approved by a DER on an 8110-3. In this situation, the IA or repair station will just sign the box 7 and there will be no FAA entry in box 3. Once the aircraft is released to service via the 337, the completed form is sent to FAA in Oklahoma, not to the FSDO.
Therefore, in all cases, the 337 must be completed and signed with approved data of some form BEFORE the aircraft can fly. You can't submit an un-approved form to a FSDO or ACO and believe that you can fly whilst waiting for it to be signed off.
For a minor change, the 337 is not used. A minor change just requires a logbook entry.

[IO540]

I have been told that anything, not covered by an STC, or incorporated by a certified original equipment list, cannot remain at time of certification, and for subsequent inspections. - N REGYou have been told bollox, like so many others..... who told you this? Email me if you prefer. Whoever told you this cannot spell

mike
india
november
oscar
romeo

mike
oscar
delta

:)

Don't 337's go to Heathrow these days? AIUI, 337s go to your local FSDO, and "your local FSDO" in Europe is the NY IFO.

the 337 is for Major Repair/AlterationExactly right. Add "only" after that, too :)

I capitulated in the case of the GPS, by temporarily removing it for an easier life.That is fair. But you could have installed a power connector in the dash, and got that signed off. It would need its own CB otherwise it cannot be signed off (meaninfully).

there is history of 337 "approved" modifications not being accepted by Transport Canada, when an American aircraft is imported into Canada. I have had to issue new STC approvals to cover a mod found to be on the aircraft by 337, which the purchaser could not, or was unwilling to, remove.EASA do that all the time, to FAA certification.

They like to quote famous accidents which involved bodged work. This is a ripe area for digging out examples - just like the Private Eye has a very easy time nowadays with so many of today's politicians being crooked :) What they ignore is that a lot of work done by EASA shops is also crap, and a lot of potential safety enhancing equipment is not installed in Europe because the paperwork is prohibitive and/or it is so difficult to find an avionics shop which understands the regs. I have heard some appalling stories from Germany, on a friend's plane, where EASA caved in only when the owner told the avionics shop to abandon the project, and they would have lost their approval fees.

On an N-reg, there is a theoretical route which uses a US-based (inland) FSDO. This is possible because the aircraft is anyway owned by a US citizen/company, and if the address is in the USA, the FSDO will have no way of knowing the aircraft is actually living outside the USA. This is difficult because one needs to assemble gold plated paperwork that enables the package to be presented by a US based IA who probably has not seen the aircraft. It can be done in some cases where sight of the aircraft is not necessary; for example this is the case with EASA GPS approach approved flight manual supplements which is just a paperwork purchase.

In the alternative case, the installation data will already be approved by an STC (this may be an AML STC with hundreds of aircraft listed such as for the JPI EDM700), or it could be data approved by a DER on an 8110-3. In this situation, the IA or repair station will just sign the box 7 and there will be no FAA entry in box 3. Once the aircraft is released to service via the 337, the completed form is sent to FAA in Oklahoma, not to the FSDO.Is the above "send in the STC and wait for no reply procedure" usable only with an STC for that airframe S/N range (or an AML STC)?

[wigglyamp]

There is no 'Send in the STC and wait for no-reply procedure'. The aircraft cannot fly once modified via a Major change or STC until a Form 337 is fully completed and signed off with correct data. The submission to FAA in Oklahoma is for record keeping and not for approval.

[IO540]

There is no 'Send in the STC and wait for no-reply procedure'. The aircraft cannot fly once modified via a Major change or STC until a Form 337 is fully completed and signed off with correct data. The submission to FAA in Oklahoma is for record keeping and not for approval.

I meant doing the 337 before the work is done.

AIUI, one is entitled to seek an FAA ruling on a proposed mod, and if they don't object, you can do it. Is this absolutely not true? It appears to be a standard US procedure.

[wigglyamp]

Yoy are correct in that for a field-approval, you should seek the agreement of the FSDO and get them to sign box 3 before the work is done, so that immediately on completion of the mod, the IA or repair station can return the aircraft to service using Box 7. However, if the FAA don't reply, this is not an acceptance, and unless the 337 is correctly filled out and approved, the aircrat still can't fly.

[IO540]

OK, so one can send a 337 to Oklahoma, and one has to wait to get it back.

That's fair enough.

That is surely a useful option for cases where the NY IFO is not playing ball.

Has anybody tried this?

Of course if Oklahoma simply says "this is foreign" and passes it to the NY IFO which then bins it....

[wigglyamp]

Sorry - you're missing my point. Oklahoma just record the completed 337 - they don't approve it. It you want to get a field-approval on a 337, you have to go through your FSDO. In 20 years of doing small aircraft, I've never managed to get a 337 field-approved in UK, so always use the DER-approved 8110-3 route.

[Pilot DAR]

Okay, TC's website seems to be working again. This document is the "test" for your proposed mod being "major" or not. It is guidance, not the last word, but it get's you close for knoiwng which route to follow, minor mod logbook entry, or STC approval...

Part V - Standard 571 Appendix A - Criteria for the Classification of Modifications and Repairs - Transport Canada (http://www.tc.gc.ca/eng/civilaviation/regserv/cars/part5-standards-a571sa-1893.htm)

[IO540]

Some interesting wording in there...

(8) reduce the storage capacity of the primary battery?
(9) affect a communication system required by the approved type design?
(10) affect instruments, or indicators that are installed as part of a system required by the approved type design?

:)
Any addition whatsoever will potentially do (8) so any electrical equipment is a major mod.
Any navigational equipment whatsoever will potentially do (9) so any radio equipment is a major mod.

Likewise for (10).

In 20 years of doing small aircraft, I've never managed to get a 337 field-approved in UK, so always use the DER-approved 8110-3 route.

Have you tried?

You know me :) I have investigated various potential avionics work, via various UK shops (because I like to get my ducks in a row at the outset, to avoid the situations and downtime which some pilots end up stuck in) and I think you are more or less alone in using the DER route. The others seem to be trying to push stuff through the NY IFO, but last time I tried it (for the GPS FM supplement; happy to email you the details) this route did not appear to work [anymore].

[wigglyamp]

Thanks for the TC modification definitions. It's very similar to EASA's table in AMC21A91. The significant difference between TC/FAA and EASA is that under EASA, a Minor change still requires approved data and is not just a logbook certification. In reality, our EASA Minor change is the same as an FAA Major alteration, and STCs are directly equivalent.

[wigglyamp]

IO-540.
I talked to the current FAA avionics field inspector from LHR during a recent repair station audit at your home airfield and he advised that they have no obligation to undertake field-approvals outside the US, and that he didn't have the time to deal with them. His predecessor did clear a couple of flight manual supplements for me for BRNav and TAWS-B but wouldn't consider field approvals.

[IO540]

That explains quite a lot then :ok:

So the only options for a UK based N-reg are

- DER
- a Minor Mod

I believe all DERs are in the USA. This one (http://www.derassociates.com/) is used by some European firms; their website is really informative ;)

[wigglyamp]

The third option for UK N-reg operators is to install something that already has an FAA STC covering the specific aircraft type - then all that is needed is an FAA IA or repair station to sign the 337. Aspen EFD1000 or Garmin G500 no hassle, but want a Sandel 3500 ? - you need a DER!

[IO540]

Just read today that Sandel 3500s go in as a minor mod in the USA, apparently - if replacing an existing HSI.

The EFD1000 is having a lot of QA issues. A friend is on his 3rd one in a year. The last one failed totally in IMC.

The G500 is a nice product but £40k or so, by the time one has done all the rest.

[wigglyamp]

Suggest you look at section 3 of the following FAA document. An EHSI should be a Major alteration.

http://www.faa.gov/other_visit/aviation_industry/airline_operators/airline_safety/info/all_infos/media/2008/FSAW95-09E.pdf

[smarthawke]

Regarding the fitting of 'handheld' GPS etc in certified aircraft, the CAA explained it (as most of us thought) at an engineer's seminar that if the piece of kit or its mount is permanently attached to the aircraft by screws or rivets then that isn't allowed.

Attaching it by Velcro or suction mount is okay as that is deemed as pilot fitted equipment. If the aircraft is in for maintenance then it can't be released with anything fitted that shouldn't be there.

Obviously any power or other wiring (aerials etc) to supply such equipment have to be an approved mod if fitted to (hard-wired to) the aircraft.

Part of the argument is the lack of crashworthiness testing of the mounts. Personally, I think yoke mounts (which are legal) are potentially dangerous but mounts like the AirGizmo ones are great (but illegal). Funny old world.

[IO540]

Wigglyamp - I have just heard from the USA that that 8300-10 document is outdated and has been cancelled.

Currently looking.

The current stuff is supposed to be here (http://fsims.faa.gov/PICResults.aspx?mode=EBookContents)

A lot depends, apparently, on whether an AFMS is required.

Probably getting too far off topic here, however.

[englishal]

Part of the argument is the lack of crashworthiness testing of the mounts. Personally, I think yoke mounts (which are legal) are potentially dangerous but mounts like the AirGizmo ones are great (but illegal). Funny old world.
Yea it is madness! In one of out aeroplanes we have an Airgizmo's mount. It fits into a hole in the panel which was empty. The GPS is properly hard wired to the power supply and external hull mounted antenna, and it is a really nice, clean, convienient setup. It is safer than having a bulky GPS around the place which would act like a hammer flying around in the event of a crash...

So my question is, why are the CAA so pigheaded not to allow mounts like this through a simple field sign off? If anything it makes EVERYTHING safer - less cluttered cockpit, reliable navigation, and I can't see any reason not to allow this?

Maybe someone from the CAA (who read these boards) would care to explain?

(we remove it before each annual. Takes 10 seconds).

[IO540]

I won't defend the system for a moment but it is the price we pay for being able to jump into our planes and - using our ICAO CofAs, ICAO licenses, ICAO IRs, etc - we can fly 800nm to some god forsaken (but warmer!) hellhole where you have to bribe somebody to sell you avgas, without anybody questioning our right to do so.

Without ICAO, private flying would have been banned in all countries where personal liberty is not a major population / public issue i.e. most of Europe, especially southern Europe.

One can't have one's cake and eat it.

EASA could introduce a sub-ICAO certification regime, usable for flying in the EU only (i.e. not Croatia and other nice places, unless they explicitly accepted it) but that would trash the livelihoods of the countless chimps that work in there on gold plating certification (like disregarding AML STCs), not to mention damaging the business of the big European EASA Part 21 shops who make serious money on the paperwork associated with mods.

It is also easy for them to point to hazards like the dodgy yoke mounts which so many people fly with. These can have serious control obstruction potential.

One can do quite a lot by getting a "certified" signal and power connector brought out somewhere, and then having the required equipment attached "temporarily". You can do satellite phones that way (lots of planes have rooftop Iridium/Thuraya antennae for internet weather; voice is harder due to the required intercom connections), obviously GPSs, even TCAS boxes (this (http://www.lxavionics.co.uk/traffic-monitor.htm) is interesting).

[wigglyamp]

I appreciate the issue of not being able to legally use an AirGizmo mount in a certified aircraft but please remember that it's not a CAA issue - they have no control over dsign approvals on EASA aircraft. The rule in 21A307 about all parts having to have an EASA Form 1 or equivalnet has killed off what the CAA used to accept as 'No Hazard' equipment. And in EASA-land, there is no simple 'Field sign-off', whilst may of us, even those of us who make our living from EASA design work, would like to see.

[IO540]

The rule in 21A307 about all parts having to have an EASA Form 1 or equivalnet

If taken literally, all GA would grind to a halt if an EASA-1 was needed for everything.

I researched this about 2 years ago and any documentation which carries batch traceability was acceptable, both under EASA/CAA and FAA regimes.

Secondhand parts could not be fitted to a G-reg unless it had an EASA-1 form, which controls the market for parts salvaged from wreckage (basically it means the ex-wreck part needed to be "inspected" and "recertified" (gosh one is supposed to be impressed) by an EASA145 company) but new parts were OK with any suitable papers as mentioned above.

And this remains the practice in GA maintenance today.

Speak privately to anybody doing it and he will tell you that loads of parts are not available with an EASA1 ... screws, etc loads of small parts. New instruments bought from the USA come with an 8130-3 anyway.

An EASA1 form means nothing about performance. It just one means of compliance for batch traceability, and it keeps the EASA145 regime in business.

Class 1 parts (engines and props) were different and needed either an EASA1 or an 8130-4 (FAA Export CofA) but I heard this changed recently since the FAA stopped doing the 8130-4 so the Eurocrats now have to accept an 8130-3 for Class 1 parts also.

Where is the above incorrect?

[vee-tail-1]

To echo some posts above. My Robin ATL is an EASA aircraft so I have to remove quite a lot of non approved equipment before each annual /ARC. It has been an interesting technical challenge to make the power connectors, aerial leads, instrument panel fittings, easily removable but mechanically and electrically secure. Fortunately Robin provided a number of c/b protected spare connectors behind the panel. Also I have been able to find GPS and transponder equipment designed to fit in the instrument panel holes. But perhaps the greatest satisfaction for me is intentionally doing something 'illegal' and giving two fingers to the nutters who make the rules.:*