ADSB Transponder Installation - EO Required?
 

Here is a bit of good news for the likes of Akro etc.:E

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.

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.

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!

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:ok:

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 seem to remember making points like this, mmmmmm

Wish I'd known this a couple of months ago - might have challenged the requirement for the EO for the avionics upgrade on the club PA28 :sad:

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.

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.

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 :ok:

"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 ?

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?

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 ..

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.

On the email this morning.....:ugh:

Did that just disappear today? Does anyone still have an archive copy? I wonder what it means...?

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! :ok:

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 ...

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 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.

Well, the Americans have managed it fine... I think they call them STC's!

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

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.

Is it true that Australian eo's are not recognised overseas?
If so, it would make it a tad difficult to sell your airplane offshore.

Yes….if they were that complex. Many engine upgrade, prop changes or other relatively common modifications are far more complex with interaction with other systems than exchanging a GTX327 with a GTX330ES.

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. :ok:

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.

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 ..

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.

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.:ugh:

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.

But what has that got to do with it?:confused:

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? :ugh:

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.

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

Cheers

Yr,

I do.

And if you look at the associated paperwork with Garmin transponders, extra installed avionics are catered for in the STC.

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.

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.

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

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

I can't help feel that this isn't an accidental spelling mistake! ;)

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

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

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.