ADSB Transponder Installation - EO Required?
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In correct.
An stc is not a blanket right to fit any product to an aircraft. It is the right that that product may be fitted if it meets all requirements for fitment. Some stc are not compatible with others.
An stc is not a blanket right to fit any product to an aircraft. It is the right that that product may be fitted if it meets all requirements for fitment. Some stc are not compatible with others.
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Yr Right and RatsoreA are probably closer to furious agreement than posts show.
Civil Aviation Safety Authority - Home
My view if an existing STC exists Australian or foreign and you are installing with STC owners approval you have an already approved modification. All you need to do is ensure it is compatible with other mods to the aircraft. It then looks a bit grey as to whether a LAME can do that or whether a CAR35 is needed. What is clear is a unique mod is not required to cover where an STC exists. The approved STC may help resale too.
Civil Aviation Safety Authority - Home
Conflict with other Modifications
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.
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.
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If in this instance the unit is a racked item. Meaning in and out the stc would cover it. If the unit rack has to be removed and or reinstalled in a different place and is NOT covered in the stc for relocation and or installation of the rack or a wiring diagram is not provided then an EO is required.
We live in Australia our rules are different to that of the FAA which means not all things are not always covered.
Avionics are the hardest thing to cover as just about every aircraft is different even in the same model group.
Where as if you install a vortex generator kit you not changing the wing between aircraft and it is provided in the kit from the start to the finish. Avionics Arnt like that.
The rules are quite clear in that a modification can not be done with out an EO and at the end of the day it's not the lame responsabity to not do the job with out it.
Things are not always black and white or clear cut.
Cheers
We live in Australia our rules are different to that of the FAA which means not all things are not always covered.
Avionics are the hardest thing to cover as just about every aircraft is different even in the same model group.
Where as if you install a vortex generator kit you not changing the wing between aircraft and it is provided in the kit from the start to the finish. Avionics Arnt like that.
The rules are quite clear in that a modification can not be done with out an EO and at the end of the day it's not the lame responsabity to not do the job with out it.
Things are not always black and white or clear cut.
Cheers
Unexpected modification....?
How can something be "unexpected" if it had been through the process yr right is so enamored with? Is it just me or is the CASA giving cart blanche to the engineering community to let rip with no recourse. What defines "unexpected"?
How can something be "unexpected" if it had been through the process yr right is so enamored with? Is it just me or is the CASA giving cart blanche to the engineering community to let rip with no recourse. What defines "unexpected"?
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What if a stc has already been done. It's not in th M/M that the next stc has gone off. Hence unexpected. Have a look in a ipc p# Abc unless an ()& has been done the p# XYZ is to be used. Nothing is a given in aviation absolutely nothing. Hence why we have lame and approvals
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When the stc is done they reference the ipc illustrated parts catalogue and the the m\m maintenance manual. They have know idea if the aircraft their stc is going into a modified aircraft. Hence the personal installing the stc needs to make sure that the stc is ok to use.
The point yr right is trying to make is this:
An STC is based on an aircraft that meets the original type design and, in some cases, specified modifications that are already the subject of other STCs.
Almost all GA aircraft that have been around for a decade or more will almost certainly be the subject of numerous avionics modifications that have been approved outside the STC process. For example, pull up the current TCDS for e.g. a Bonanza V35 and you won’t find anything in there for an intercom or two VHFs or a GPS or an EDM 700 etc etc. All of those modifications can affect electrical load, W&B, environmental considerations like ventilation and cooling etc etc. Some of those modifications may be the subject of an STC, but the holder of the STC for e.g. an EDM 700 cannot possibly anticipate all of the other modifications that might already have been made to the aircraft to which it can be fitted.
If an aircraft has e.g. a transponder and there’s an STC for the rack-mounted box to be replaced with another box, of a different part number, that nonetheless: (1) slots into the same rack as the previous box; (2) weighs substantially the same as the previous box; (3) consumes the same or less power than the previous box; (4) does not have any different ventilation/clearance/environmental requirements than the previous box; (4) does not have any different antenna cable and antenna characteristics than the existing system, there’s almost certainly no need for an EO.
However, very few avionics ‘upgrades’ are a simple black box ‘swap and play’.
An STC is based on an aircraft that meets the original type design and, in some cases, specified modifications that are already the subject of other STCs.
Almost all GA aircraft that have been around for a decade or more will almost certainly be the subject of numerous avionics modifications that have been approved outside the STC process. For example, pull up the current TCDS for e.g. a Bonanza V35 and you won’t find anything in there for an intercom or two VHFs or a GPS or an EDM 700 etc etc. All of those modifications can affect electrical load, W&B, environmental considerations like ventilation and cooling etc etc. Some of those modifications may be the subject of an STC, but the holder of the STC for e.g. an EDM 700 cannot possibly anticipate all of the other modifications that might already have been made to the aircraft to which it can be fitted.
If an aircraft has e.g. a transponder and there’s an STC for the rack-mounted box to be replaced with another box, of a different part number, that nonetheless: (1) slots into the same rack as the previous box; (2) weighs substantially the same as the previous box; (3) consumes the same or less power than the previous box; (4) does not have any different ventilation/clearance/environmental requirements than the previous box; (4) does not have any different antenna cable and antenna characteristics than the existing system, there’s almost certainly no need for an EO.
However, very few avionics ‘upgrades’ are a simple black box ‘swap and play’.
Last edited by Creampuff; 25th Aug 2014 at 05:24.
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I prefer when yr right's apprentice posts for him 
but when he's charging him out at 120 bucks an hour we should just spend a few minutes extra interpreting yr right's post 
but when he's charging him out at 120 bucks an hour we should just spend a few minutes extra interpreting yr right's post
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Why would you argue so hard to charge your customers for something that they don't need (I know they don't need it, I have the response from casa), rather than invest that time and effort into looking after them?
If you received a clear answer from CASA, Rat, that would be a rare thing worth framing.
What, precisely, was your question, and what, precisely, was the answer?
What, precisely, was your question, and what, precisely, was the answer?
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Creamie,
Well, after going to 5 different avionics installers/shops, and getting quotes for installation, and all of them charging me a range of prices for an EO, I was displeased.
My question was, "I have a Garmin transponder with an STC, and my aircraft is on the approved model list, am I required to get an engineering order?"
The answer was, "The STC and AML are more than satisfactory and you don't require an EO"
He also quoted a bunch of regs and reg numbers saying why. This was from the head avionics guy in Canberra.
It took me 15 minutes to save myself anywhere from $660 to $1540, and I was disappointed that LAMESs/avionics techs can't be bothered trying to save their customers a substantial amount of money, that could be better spent.
Well, after going to 5 different avionics installers/shops, and getting quotes for installation, and all of them charging me a range of prices for an EO, I was displeased.
My question was, "I have a Garmin transponder with an STC, and my aircraft is on the approved model list, am I required to get an engineering order?"
The answer was, "The STC and AML are more than satisfactory and you don't require an EO"
He also quoted a bunch of regs and reg numbers saying why. This was from the head avionics guy in Canberra.
It took me 15 minutes to save myself anywhere from $660 to $1540, and I was disappointed that LAMESs/avionics techs can't be bothered trying to save their customers a substantial amount of money, that could be better spent.
That's an unusually broad and categorical statement from someone from CASA. As I say, I'd frame that, with a note as to time, date and name of the CASA person.
So let's assume, purely hypothetically, that you're going to fit your transponder to one of the aircraft on the STC and AML, but the avionics buss on your specific aircraft is already loaded to its maximum rating due to other systems already connected to it (also under STC and AML).
How's that going to work?
So let's assume, purely hypothetically, that you're going to fit your transponder to one of the aircraft on the STC and AML, but the avionics buss on your specific aircraft is already loaded to its maximum rating due to other systems already connected to it (also under STC and AML).
How's that going to work?
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Yes, it is, and I am happy to forward you a copy, if you want! I have already sent it to a bunch of people.
Whilst I do love a good hypothetical, the one you have proposed isn't grounded in the real world.
I have a basic understanding of electricity, and I don't think it takes an engineer to work out that replacing an old, high current draw box, with a new, modern box with lower current draw and lower heat production, won't overload a bus.
If you're taking one out, and putting one back, I fail to see how that would occur. I know it's mostly marketing pap, but they even say in the brochure, less current, less heat, no warm up, solid state digital and no cavity tube!
I think a little application of common sense can go a long way!
Whilst I do love a good hypothetical, the one you have proposed isn't grounded in the real world.
I have a basic understanding of electricity, and I don't think it takes an engineer to work out that replacing an old, high current draw box, with a new, modern box with lower current draw and lower heat production, won't overload a bus.
If you're taking one out, and putting one back, I fail to see how that would occur. I know it's mostly marketing pap, but they even say in the brochure, less current, less heat, no warm up, solid state digital and no cavity tube!
I think a little application of common sense can go a long way!
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Further, both transponders put out 250w.
Watts are a function of voltage and amperage, so a 14 volt DC system in most aircraft, to make 250w require roughly 17.85 amps. Doesn't matter what box is doing it. Newer ones might be more efficient in other areas of current draw, but for the actual Tx, it mattes not what box is installed.
Watts are a function of voltage and amperage, so a 14 volt DC system in most aircraft, to make 250w require roughly 17.85 amps. Doesn't matter what box is doing it. Newer ones might be more efficient in other areas of current draw, but for the actual Tx, it mattes not what box is installed.
Good for you.
Therefore there will be no safety or regulatory problem.
Obviously the change makes no substantial difference to W&B.
Question: Can I remove the (older) Garmin 327 from the rack in my aircraft and insert and use a (newer) Garmin 330 in its place? Each is the subject of an STC and AML for my aircraft.
Therefore there will be no safety or regulatory problem.
Obviously the change makes no substantial difference to W&B.
Question: Can I remove the (older) Garmin 327 from the rack in my aircraft and insert and use a (newer) Garmin 330 in its place? Each is the subject of an STC and AML for my aircraft.
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I see where you are going with this.
If by 'I', I assume you mean your appropriately qualified solder jockey?!
Whilst the 327 only has 200w of transmitting power, versus the 250w from the 330 (ES as well) a quick electrical load analysis could be performed, should you be worried about the the 3 extra amps that the new box will draw.
Getting an electrical load analysis is not an EO. They might perform a "paper" load analysis when doing an EO, but that is not an EO.
But, as you pointed out, the regulatory requirement is satisfied. If you have been following the thread, I am not anti something that would improve safety. I am spending myself out of house and home putting good, safety enhancing things in my airplane. What I am anti, is spending money on something that gives me no benefit.
Also, in the 330 paperwork, I recall seeing something with regards to other equipment installed in the aircraft, and it's respective loads, but I'm not 100% sure! and I don't have it to hand.
Out of curiosity, are you trying to argue in favour of imposing EO's on things that don't need it? I think any regulatory burden that can be reduced across the industry is a good thing? Or do you disagree with that?
If by 'I', I assume you mean your appropriately qualified solder jockey?!
Whilst the 327 only has 200w of transmitting power, versus the 250w from the 330 (ES as well) a quick electrical load analysis could be performed, should you be worried about the the 3 extra amps that the new box will draw.
Getting an electrical load analysis is not an EO. They might perform a "paper" load analysis when doing an EO, but that is not an EO.
But, as you pointed out, the regulatory requirement is satisfied. If you have been following the thread, I am not anti something that would improve safety. I am spending myself out of house and home putting good, safety enhancing things in my airplane. What I am anti, is spending money on something that gives me no benefit.
Also, in the 330 paperwork, I recall seeing something with regards to other equipment installed in the aircraft, and it's respective loads, but I'm not 100% sure! and I don't have it to hand.
Out of curiosity, are you trying to argue in favour of imposing EO's on things that don't need it? I think any regulatory burden that can be reduced across the industry is a good thing? Or do you disagree with that?
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Unfortunately common sense dose not come into it at all. If the unit you have has to be modified in any way and it's not in the stc package then you require an eo. It's not up to the lame to take it upon his self to break the law to make you feel better. Next you are sure it's stc and not pma.
Next you hit the biggest bug bear of aviation. What one casa office advise will be different to the next.
If you have an accident and even if your equipment was not to blame there is a good chance that your insurance will be null and void.
But then you no doubt you be ringing your lawyer to sue the arse of the installer. So this leaves us with two options now.
1st is you sound like most you can't afford to own an aircraft.
2nd get the EO and stop whining. Go get a lic and for it yourself as it's easy to do.
😁
Next you hit the biggest bug bear of aviation. What one casa office advise will be different to the next.
If you have an accident and even if your equipment was not to blame there is a good chance that your insurance will be null and void.
But then you no doubt you be ringing your lawyer to sue the arse of the installer. So this leaves us with two options now.
1st is you sound like most you can't afford to own an aircraft.
2nd get the EO and stop whining. Go get a lic and for it yourself as it's easy to do.
😁