ADSB Transponder Installation - EO Required?
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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 ?
Sarcasm aside, there is an element of truth in it. I am sure for big jobs, an engineer must be involved, when modifying an airplane beyond the imagination of the manufacturer. But I can hardly see the 'cost' in pointless EO's.
I have looked at 3 EO's for transponders (garmins) for 3 different airframes, and they are word for word a copy of what is put out by garmin themselves? You can't tell me that deleting the previous rego/serial and typing in the new one, clicking print and posting it is worth anywhere from $660 to $1500?
What we have now is not a prescriptive system, but an oppressive and costly one, that provides no benefit for I would guess, 80% of GA modifications.
I am not an engineer, but I would consider myself reasonably educated, but I cannot for the life of me see how the current EO system makes my aircraft any safer.
If you want further proof of the ridiculous nature of EO's, in this current environment, an EO is required for commercial, off the shelf, iPad/GPS clamps, that mount and remove in a matter of seconds, are not permanent parts of the aircraft and don't fix to anything structural. That word is from a CASA FOI.
I am sure they are trying to eliminate risk, but the odds of any given pilot misreading a digit on the altimeter and being involved in a CFIT incident would have to be orders of magnitude higher than a pilot having clamped a small iPad to the seat rest and having that cause an accident. By the logic of EO's we should stop all flying activities, based on what is more probable.
You can't, and shouldn't, legislate against every possibility ever, or we just end up with... Hmmm... Well, we end up with the regulatory f&@kfight we have now...
I don't know about GA aeroplanes these days, but I know of one airliner where the systems are so integrated that the inter relationship between systems that at first (and second, third and fourth) glance appear totally unrelated are in fact intrinsically entwined to make simple mods almost impossible.
Clock signals control which computer is primary on a given date when the aeroplane wakes up in the morning, weight on wheels messages on the data bus drive changes to pressurisation controllers, resetting a clock can make the flaps fail....
A quick and dirty assessment may be a big mistake, particularly if someone else installing an earlier mod has taken a required input from somewhere unexpected because it was convenient.
Probably less of an issue in a "classic" aeroplane like an old Cessna or piper, but newer machines with glass instruments or ones with post delivery installations of gps etc might fall into the danger zone....
I am not an engineer but I would think that any sort of installation/approval would require a detailed look at the history of the particular airframe to make sure that they aren't opening Pandora's box
Clock signals control which computer is primary on a given date when the aeroplane wakes up in the morning, weight on wheels messages on the data bus drive changes to pressurisation controllers, resetting a clock can make the flaps fail....
A quick and dirty assessment may be a big mistake, particularly if someone else installing an earlier mod has taken a required input from somewhere unexpected because it was convenient.
Probably less of an issue in a "classic" aeroplane like an old Cessna or piper, but newer machines with glass instruments or ones with post delivery installations of gps etc might fall into the danger zone....
I am not an engineer but I would think that any sort of installation/approval would require a detailed look at the history of the particular airframe to make sure that they aren't opening Pandora's box
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Integrated airliners, yes! Who knows what's connected to what and how in that case, but charging someone with a mid 80's 182 or Lance, $1000 for what is blindingly obvious, is unwarranted.
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I am not an engineer but I would think that any sort of installation/approval would require a detailed look at the history of the particular airframe to make sure that they aren't opening Pandora's box
EO's for the vast majority are plain and simple BS, except for the very very few.
RatsoreA seems to be on the money here.
And CASA have confirmed this in writing to owners….just the industry pretends they have not and perhaps some out there would rather only the few who push the point get off, the rest they charge
.I hope that is not the case, but the data says otherwise so far.
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Well, the Americans have managed it fine... I think they call them STC's!
I don't claim expertise in the minutiae of the US system but we do have a few DARs/DERs on the site. Hopefully, we might get some input from them.
However, the same requirement exists - someone has to make the compatibility determination and I guess it is the A&P and/or DER in much the same way as happens in Oz.
Or, as Degas observed
Painting is easy when you don't know how, but very difficult when you do.
I have looked at 3 EO's for transponders (garmins) for 3 different airframes, and they are word for word a copy of what is put out by garmin themselves?
May I respectfully suggest that you might be missing the point. You are paying the EO for the compatibility assessment .. the EO words come along as part of the deal.
If you want further proof of the ridiculous nature of EO's, in this current environment, an EO is required for commercial, off the shelf, iPad/GPS clamps, that mount and remove in a matter of seconds, are not permanent parts of the aircraft and don't fix to anything structural
Correct but, again, the need is for the behind the scenes assessment, not the shopfront to and fro. The fee should reflect the reasonable cost for doing the work etc.
I am sure they are trying to eliminate risk
An impossibility, I'm afraid .. managing risk is another animal altogether.
would have to be orders of magnitude higher than a pilot having clamped a small iPad to the seat rest and having that cause an accident
Perhaps .. but largely irrelevant to the topic
but I know of one airliner where the systems are so integrated that the inter relationship between systems that at first (and second, third and fourth) glance appear totally unrelated are in fact intrinsically entwined to make simple mods almost impossible
that's it in a nutshell and exactly the same for my work and my mate's.
CASA have confirmed this in writing to owners
you pays your money and you takes your chances. Having known a few LAMEs who have been taken to the cleaners in Court by disgruntled owners .. were I a LAME, I wouldn't touch the assessment thing with a 20ft (sorry, 6m) bargepole. Far better to let the delegate/AP carry that can ..
I don't claim expertise in the minutiae of the US system but we do have a few DARs/DERs on the site. Hopefully, we might get some input from them.
However, the same requirement exists - someone has to make the compatibility determination and I guess it is the A&P and/or DER in much the same way as happens in Oz.
Or, as Degas observed
Painting is easy when you don't know how, but very difficult when you do.
I have looked at 3 EO's for transponders (garmins) for 3 different airframes, and they are word for word a copy of what is put out by garmin themselves?
May I respectfully suggest that you might be missing the point. You are paying the EO for the compatibility assessment .. the EO words come along as part of the deal.
If you want further proof of the ridiculous nature of EO's, in this current environment, an EO is required for commercial, off the shelf, iPad/GPS clamps, that mount and remove in a matter of seconds, are not permanent parts of the aircraft and don't fix to anything structural
Correct but, again, the need is for the behind the scenes assessment, not the shopfront to and fro. The fee should reflect the reasonable cost for doing the work etc.
I am sure they are trying to eliminate risk
An impossibility, I'm afraid .. managing risk is another animal altogether.
would have to be orders of magnitude higher than a pilot having clamped a small iPad to the seat rest and having that cause an accident
Perhaps .. but largely irrelevant to the topic
but I know of one airliner where the systems are so integrated that the inter relationship between systems that at first (and second, third and fourth) glance appear totally unrelated are in fact intrinsically entwined to make simple mods almost impossible
that's it in a nutshell and exactly the same for my work and my mate's.
CASA have confirmed this in writing to owners
you pays your money and you takes your chances. Having known a few LAMEs who have been taken to the cleaners in Court by disgruntled owners .. were I a LAME, I wouldn't touch the assessment thing with a 20ft (sorry, 6m) bargepole. Far better to let the delegate/AP carry that can ..
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John,
No, not missing the point, I understand that they want to do a compatibility assessment, what I am implying is, they aren't doing them, and are just rubber stamping them, printing the same one as last time, with the relevant aircraft details changed, and charging several hundred dollars for the privilege.
AND, I am also implying that in 90% of the Pipers/Cessnas/Beechcraft getting around, it is not needed, not relevant and an unfair burden to be borne.
If I has having major structural changes to my wing, I would happily pay for an engineer and the subsequent EO, because I might be in it when the glue comes undone! But for the vast majority of mods, it's a pointless expense.
May I respectfully suggest that you might be missing the point. You are paying the EO for the compatibility assessment .. the EO words come along as part of the deal.
AND, I am also implying that in 90% of the Pipers/Cessnas/Beechcraft getting around, it is not needed, not relevant and an unfair burden to be borne.
If I has having major structural changes to my wing, I would happily pay for an engineer and the subsequent EO, because I might be in it when the glue comes undone! But for the vast majority of mods, it's a pointless expense.
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Getting back to Jaba's original post.
Can we all agree that EO's are being unnecessarily requested/paid for/issued for a simple change such as a slide in txpr replacement.
Can we all agree that EO's are being unnecessarily requested/paid for/issued for a simple change such as a slide in txpr replacement.
There is no correct answer to this debate. For example newish aircraft delivered with G1000 avionics are certified as part of the type certificate, not a STC by garmin.
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For example newish aircraft delivered with G1000 avionics are certified as part of the type certificate, not a STC by garmin.
How about a G1000 equipped C182 or G36 with a GTX33 transponder. You want to upgrade to a 33ES for ADSB, a simple upgrade path (if or when it exists) will be provided by probably a similar blind box, an extra wire for the GPS in, some firmware updates perhaps.
All this will be in the instructions and an STC to cover it, one would expect.
How is it this would need an EO, when all the USA folk will do is instal and make an entry in the log book?
In the US, A&P mechanics (LAME's) can sign off minor modifications. The pedants at CASA have not allowed this. Therefore we require EO's for a wide range of things that mechanics simply sign off as OK in the US.
Safe skies are empty skies.
Safe skies are empty skies.
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An stc can be used when all conditions of that stc are meet. If there is any change to the stc it can't be used in it's entirity. If you change your engine for another for example to another for an upgrade and you buy it as a kit. It will come with every thing you require to do the change. How ever avionics are complety different. Even though it has an stc for that aircraft if you have any changes in your avionics it may not be covered. Then you require an EO for a electrical load and that the integration of the new avionics are comparable with the rest of the pannel and the airframe. Thing are not as clear cut as Jaba would like to think they quite are. I don't know of anyone that's ever to to have a lend of a costumer on this note. Another point here is if it's in the ipc you don't have to have an EO it may be fitted iaw the aircraft M/M
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Cheers
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Yr,
I do.
And if you look at the associated paperwork with Garmin transponders, extra installed avionics are catered for in the STC.
I don't know of anyone that's ever to to have a lend of a costumer on this note.
And if you look at the associated paperwork with Garmin transponders, extra installed avionics are catered for in the STC.
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You can't make a blanket call on this. Every aircraft has to be taken on it's own merits.
And while an EO is an additional cost to the owner it dose give protection to both them and the installer if something dose go wrong.
And the way casa is behaving at the moment to cover ones arse not only is an EO but puts a full stop to an Awi trying to have go. So if I'm installing anything wit an STC if I'm in doubt we get an EO saves a fine on myself and any black marks on the org. If the costumer can't afford that we'll he has the option to go else where.
The problem with avionics is the interaction with every thing else in the panel. And before you all say anything are you willing to pay any fines or court cases if I or someone else signs it out under an stc and it shouldn't have been. I'll will answer it no you won't. Hence we have to cover our selfs.
As Sol said. Oils Arnt oils.
And while an EO is an additional cost to the owner it dose give protection to both them and the installer if something dose go wrong.
And the way casa is behaving at the moment to cover ones arse not only is an EO but puts a full stop to an Awi trying to have go. So if I'm installing anything wit an STC if I'm in doubt we get an EO saves a fine on myself and any black marks on the org. If the costumer can't afford that we'll he has the option to go else where.
The problem with avionics is the interaction with every thing else in the panel. And before you all say anything are you willing to pay any fines or court cases if I or someone else signs it out under an stc and it shouldn't have been. I'll will answer it no you won't. Hence we have to cover our selfs.
As Sol said. Oils Arnt oils.
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Yr right,
You cannot be serious. The STC to install xxx modification says it is applicable to yyy model. It comes with appropriate instructions and is installed by a qualified person.
That's it, the i's are dotted and the t's are crossed.
You are the sort of LAME that creates problems like this, and frankly, I am surprised you are still in business, because if I was a customer of yours, and you were charging me for superfluous s#!t I don't need, I would go elsewhere and then recommend to everyone that would listen to do the same.
If there is an STC issued, then it is legally covered. You wasting my money on something that isn't needed is bordering on committing some sort of fraudulent act yourself.
It doesn't matter if the owner can or can't afford it, they shouldn't have to pay for it if they don't have to. Next time you go out to eat, and the waiter brings you the bill at the end of the night, and it has 5 extra items you never ordered, wanted or needed, but the waiter put them on there because he felt they would be beneficial, would you be happy with that?
And frankly, as long as I'm on a late night rant, there are many threads about how pilots that can't spell wouldn't be hired, I wouldn't trust you to work on my aircraft as you seem to lack basic literacy skills, something that I would say is very important as a LAME, especially as you are applying legal constraints to people's aircraft with no real idea of what that means.
You cannot be serious. The STC to install xxx modification says it is applicable to yyy model. It comes with appropriate instructions and is installed by a qualified person.
That's it, the i's are dotted and the t's are crossed.
You are the sort of LAME that creates problems like this, and frankly, I am surprised you are still in business, because if I was a customer of yours, and you were charging me for superfluous s#!t I don't need, I would go elsewhere and then recommend to everyone that would listen to do the same.
If there is an STC issued, then it is legally covered. You wasting my money on something that isn't needed is bordering on committing some sort of fraudulent act yourself.
It doesn't matter if the owner can or can't afford it, they shouldn't have to pay for it if they don't have to. Next time you go out to eat, and the waiter brings you the bill at the end of the night, and it has 5 extra items you never ordered, wanted or needed, but the waiter put them on there because he felt they would be beneficial, would you be happy with that?
And frankly, as long as I'm on a late night rant, there are many threads about how pilots that can't spell wouldn't be hired, I wouldn't trust you to work on my aircraft as you seem to lack basic literacy skills, something that I would say is very important as a LAME, especially as you are applying legal constraints to people's aircraft with no real idea of what that means.
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Let's get a couple of things straight. The lame and the Maint org don't make anything out of an EO. An stc is a legal document and MUST be followed to the letter. If the aircraft dose not meet the requirements in the the document then a EO is required as per the regs.
That's not up to me or you it's the regs that set that.
When installing any PART or modification it must meet the aircraft type cert and must be certified for the use as described. Just because it has an stc for that application DOSE NOT mean it can be fitted. The stc May or may not be comparable with what is already installed on the aircraft.
Btw spelling is a nothing. I can read that's the important bit and understand.
Cheers
That's not up to me or you it's the regs that set that.
When installing any PART or modification it must meet the aircraft type cert and must be certified for the use as described. Just because it has an stc for that application DOSE NOT mean it can be fitted. The stc May or may not be comparable with what is already installed on the aircraft.
Btw spelling is a nothing. I can read that's the important bit and understand.
Cheers
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Further more when you know of people that have been pinged for not writing in the M/R that they washed there aircraft and didn't put it in the part 2 on the M/R. You see washing the aircraft is in the M/M and as such is a maintenance action and had to be recorded or the aircraft that was grounded because it had leading edge tape on the wings and had no EO to cover it. Then you start to realize why we have to put up with now and at every part and why Maint org now try and cover the bums as much as possible. It's easy for you arm chair experts to sit back and point your fingers. Like I've said if it's so easy you go and do it.
Btw I stand by my record and really never had a problem with costumers
at all
Btw I stand by my record and really never had a problem with costumers
at all
When you live....
costumers
Having some work done now and EOs a plenty for improving safety...
1. Use spare annunciator to indicate pitot heat not on = EO (not to mention needing a release certificate for the label for the decal!)
2. Wire baggage door open switch in parallel with main door unsafe =EO
I accept installers need to CYA but really - a LAME and licensed avionics guy can't do the paperwork - crazy.
UTR
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Paper work absolutely nothing to do with us. The regs state it and we have to comply with that. They trying to get ride of Car30 guys. What they going to replace that with god only knows.
Won't to take an instrument out of your panel and send it for repair. Mmm guess what an EO is required if you don't have a spare to replace the missing instrument.
Welcome to our night mare
Won't to take an instrument out of your panel and send it for repair. Mmm guess what an EO is required if you don't have a spare to replace the missing instrument.
Welcome to our night mare
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First, some housekeeping -
dose
[dohs]
noun
1. A quantity of medicine prescribed to be taken at one time.
2. A substance, situation, or quantity of anything analogous to medicine, especially of something disagreeable: "Failing the exam was a hard dose to swallow".
does
[duhz]
verb
1. A 3rd person singular present indicative of do.
With that out of the way -
Actually, it does. That is the whole point of an STC. In most cases a bunch of engineers much smarter than you or I have designed a product, taken the time to have it certified (reviewed by a different bunch of engineers) and have an STC issued.
If I have Part X, an STC for Part X and the STC says that it is applicable to aircraft Model Z, and that is my aircraft model, then everything is covered. Any particular LAME's ignorance of that basic principle is inexcusable. Getting an EO, "just to cover our bases" is pointless.
If the solder-jockey that installed a bit of electrical equipment made a hash of it, and it caught fire mid flight, do you really think an EO would have made squat of a difference? Is it going to help the pilot put the fire out? As I said, not once has the issuer of an EO even been on the same airfield as my airplane, let alone checked to see if the solder-jockey has done the job correctly.
You need to educate yourself (I am not referring to literacy here) that just "because we've always done it like that" doesn't mean you have been doing a said action correctly, lawfully, efficiently or in a cost effective manner. As a business, you should be trying to get the best deal for your customer, or, they won't be your customer any more.
dose
[dohs]
noun
1. A quantity of medicine prescribed to be taken at one time.
2. A substance, situation, or quantity of anything analogous to medicine, especially of something disagreeable: "Failing the exam was a hard dose to swallow".
does
[duhz]
verb
1. A 3rd person singular present indicative of do.
With that out of the way -
Just because it has an stc for that application DOSE NOT mean it can be fitted
If I have Part X, an STC for Part X and the STC says that it is applicable to aircraft Model Z, and that is my aircraft model, then everything is covered. Any particular LAME's ignorance of that basic principle is inexcusable. Getting an EO, "just to cover our bases" is pointless.
If the solder-jockey that installed a bit of electrical equipment made a hash of it, and it caught fire mid flight, do you really think an EO would have made squat of a difference? Is it going to help the pilot put the fire out? As I said, not once has the issuer of an EO even been on the same airfield as my airplane, let alone checked to see if the solder-jockey has done the job correctly.
You need to educate yourself (I am not referring to literacy here) that just "because we've always done it like that" doesn't mean you have been doing a said action correctly, lawfully, efficiently or in a cost effective manner. As a business, you should be trying to get the best deal for your customer, or, they won't be your customer any more.