Comm out for repair
 

Would anyone know the answer to the following. Our aircraft which is fitted with 2 comms needs one of them repaired. At our location there is no radio repairer so it has to go interstate for repair. The LAME that is removing the faulty unit tells me that once he removes it, this gets entered into the MR and we are grounded until it gets back? This doesn't sound correct to me. For IFR ops and even NVFR for certain flights to PAL operating airfields certainly, but day VFR? Why would this be as I have flown many VFR aircraft with only 1 comm fitted over the years. Anyone know the truth of the matter and where I can find this in the regs?

Day VFR equipment | Civil Aviation Safety Authority

The flight and navigational instruments required for flights under visual flight rules are:

• an airspeed indicating system
• an altimeter, with a readily adjustable pressure datum setting scale graduated in millibars
  one of the following
  • a direct reading magnetic compass or
  • a remote indicating compass and a standby direct reading magnetic compass; and
• an accurate timepiece (clock or watch) indicating the time in hours, minutes and seconds.

CAO 20.18
Other aircraft in private, aerial work or charter operations
3.4 Subject to paragraph 3A.3, an aircraft:
(a) engaged in a private, aerial work or charter operation; and
(b) not mentioned in paragraphs 3.1 to 3.3;
may only be operated under the V.F.R. if it is equipped with the following:
(c) the instruments specified in Appendix I;
(d) any other instruments and indicators specified in the aircraft’s flight manual.

So what does your Flight Manual say? If it says you require 2 then that would be why, also, is the remaining Radio properly certified for use? Wouldn't be the first time one has been installed and certified with a cheaper backup that wasn't.

Many LAMEs think that, the moment an entry is made in the MR, the aircraft is grounded until that entry is "cleared". This is not true, and I will find the CAR references tomorrow, if you wish.

The regs are very clear that only a "major defect" can cause the MR to "cease to be in force" (i.e. aircraft is grounded), and examples are given of what constitutes "major defects". A removed radio is certainly not a major defect and does not even come close to being one.

FGD - while I agree with you, it seems CASA's (current) interpretation is that any MR entry renders the aircraft unairworthy. This is in contradiction to various CARs but follows on from others $^@%%!!! Never look for consistency.

A workaround might be to remove the radio and placard the associated bits U/S. (Because the pilot might inadvertently attempt to use the blank gap in the panel :ugh: )

Thanks, drpixie.

So, if my seat has developed the occasional little squeak, or the armrest has gotten a little wobbly, and I record that on the MR, then my aircraft is grounded?

An entry only effects a flight where that entry would effect that particular next flight, unless as mentioned the M/R is endorsed "Aircraft unserviceable" or words to that effect. EG: Clock in control column (Beech A36, B200 Etc) U/S does NOT ground the A/C as long as you carry a time piece!

Your Flight Manual will list all your equipment in that aircraft.

Yours should list the two comms - if you get ramped and they only find one, you will certainly be grounded.

An EO can be applied for to remove the unit for x amount of time and some conditions/limitations be made, like blanking the hole, placards and pulling and securing the CB.

In short having one of your two comms U/S is not breaching operations of the 20.18 requirements, but removing the unit is a completely different thing.

If you have an aircraft that has two turn and bank indicators and one is broken (stuck) you can not just remove the U/S one and keep flying around. It could be feeding information to other systems like the AP so now you start to get multiple failures or part failures. That's why you need an EO.

According to current CASA "thinking" - absolutely yes - anything on the MR grounds it. (Excepting MEL items, which are closed by the reporting pilot and turned into scheduled items!)

The days of using the MR as a useful "to do" list are over. If you record the nav light u/s, you must send the aircraft to maintenance - can't even use it for day vfr. Does this encourage us to leave things of the MR? To keep a separate squawks list? Absolutely. Counter-productive? Absolutely. Degrades PIC responsibility? Yup.

CAAP 43-01 v2.0 covers it quite well. Section 4.2

https://www.casa.gov.au/sites/defaul...ce-release.pdf

As far as the original post - 1 of 2 Coms U/S - that would probably be fine if so endorsed as not a major defect and not required for VFR .

1 Com Removed - needs an EO.

That placard would be "do not store your mobile phone in here - it will get hot and catch fire"

Aren't we looking at two problems here?

One: The U/S Radio, which if not removed, could probably allow the A/C to continue flying albeit with some restrictions till repaired. Either an MEL or AFM Sup might help?
Two: Removing the U/S Radio. If it's removed, you've effectively now modified the A/C which will render it grounded, unless you get an approval (Engineering Order).

Is it possible for you to fly the A/C to facility capable of repairing the defect?

I found the best option was a loan unit, this can often be supplied from the shop doing the repair at a small fee + freight.

I once heard a bloke that knew a bloke say that "loan units can often be found on eBay. You install them and they test "fine" and get signed off in the Log Book (not MR)- next attempt for some reason it goes U/S. The faces all look the same and an AWI is not going to remove your radio's to check S/N's - Thats the ATSB's job.

Flying to a facility will cost ferry hrs and down time. Not often they will jump straight onto your com - needs to be left a few days to adjust to the workshop room temperature before it can be touched by the Bench Tech's bare hands. There is only one problem, and that is once the unit is removed the aircraft is grounded until a) the com is replaced, b) An EO is granted, c) A permit is granted by CASA - gave up on that many years ago.

CAR 42Z Removable items of radiocommunications equipment in VFR aircraft—exemption from certification requirements:
can this apply???

A com is not a removable item of radio communications equipment (normally).

That would be more a hand mic or a headset or even a ELT listed in the Flight Manual.

42Z is an exemption of a certification for a "replacement" part, not an exemption to fly with item removed.

Update on our aircraft. Firstly thankyou all those who responded to my inquiry. After finding that the responses were split about 50/50 as to if my LAME was correct or not I decided I would contact CASA direct and spoke to an Airworthiness Inspector.
The result of which was that he was correct. Apparently it is more to do with weight and balance effects than the fact that 1 comm is u/s. The mere fact that the radio probably weighs about 1kg and is pretty well right on the datum line makes no difference. Them is the rules and CASA loves rules. So unless my LAME can source a loan unit we are grounded until ours gets back. However we can ask a CASA delegate for a permit/engineering order to allow us to continue flying while it is out. Depending on the cost of this apposed to the time to getting the repair done will decide which way we go. Our aircraft is only private category so no business pressures there.
So well done to those who said our LAME was correct and to us others who thought he was wrong we have learnt something today. I still think it is regulation gone mad but who cares what I think.
Thanks again
MT

Thanks for the feed back.

Ask another AWI you will get a different reason why it is grounded, you might even get one that says it not grounded (but I doubt that these years).

What type of com is it?

Removal of any part of an aircraft is a modification not a repair.

All modifications major and minor require approval.

While a draft, CAAP 35-1(0) explains what needs to be done/considered for approval.

Re - 'Apparently it is more to do with weight and balance effects'...…

BUT - "However we can ask a CASA delegate for a permit/engineering order to allow us to continue flying while it is out. "

WOT...??
And risk either burying the aircraft nose in to the ground, or falling backwards like a falling leaf...….C of G is "OUT" you know...…

But just pay us (permit / engineering order...) and all will be well...… BUT the C of G will STILL be "out"...….

And, If you believe 'that', you will believe anything..!!!

No Cheers....NOPE....None at all...……….