As a Part 145 one can never issue an EASA Form 1 for parts that orginally where not with an EASA Form 1
Many thanks Jesse for the great explanation. However – I am as damn sure as I can be that aircraft parts distributors (such as e.g. Adams) are buying US parts, with
and they resell them with an EASA-1 form, in the same way as above.
Are you saying Adams are a Part 21 (for this purpose)?
Obviously if doing this “properly” if somebody buys 10 screws, you issue an EASA-1 form for those 10 screws but back at the office you keep a traceability log which links the EASA-1 form you generated to the 8130-3 form under which you got the 1000 screws. In reality if you bought 1000 screws under a Form X, and you need 10 for some avionics work, you just stick your hand in the box and grab 10 screws and write down nothing (but that’s not “proper”)
This DOA/POA nonsense was the reason Cessna stopped marketing the Skycatcher around here
What happened?
They required Cessna to become a DOA/POA in order to obtain CSA-LSA approval.
Cessna, in a typical American way, said “sod off”, deciding it wouldn’t be worthwhile (they probably already knew at that point that it would never sell in big numbers).
Peter wrote:
I am as damn sure as I can be that aircraft parts distributors (such as e.g. Adams) are buying US parts, withan 8130-3 form with each part, OR
an 8130-3 form covering say a bag of 1000 screws
and they resell them with an EASA-1 form, in the same way as above.
Why would they do that, it doesn’t make sense. New parts are in 99% acceptable to EASA, so no reason to do that. Haven’t seen any forms from them as well. As I understand from the Adams website is that they have become Part 145 for ELT’s only.
As Part-145 you can issue an EASA Form 1 marked with INSPECTED/TEST, REPAIRED or OVERHAULED. There are no other options. You can not do these without the maintenance documenation. Therefore it would be impossible to inspect for example most screws (standard parts – no form needed anyway)
For example on an 8130-3 for batteries, you will typically find a whole lot of S/N’s, while you get only one of them. They just make 100 copies of the form, and send a copy to every buyer with a battery in that S/N range.
For Europe it would be better to have more aviation companies. an FAA like PMA system would be good for European aviation industrie. As that is a light form of POA/DOA for a single product, therefore less overhead.
Talk of cost in this segment always seems funny to me when I look around. Look at Guimbal Cabri G2 and XtremeAir XA41/ 42. One is a piston helicopter certified to CS-27, the other one is a piston aerobatic aeroplane certified to CS-23. Both are clean sheet, state of the art (the latest and greatest in their segments) designs from new companies. XA4x is a niche product and Guimbal quoted much lower number than roughly 80 million USD (I have in vague memory about 5 million €) for the Cabri project, I think he financed it from his pocket and he used to be an engineer with Eurocopter (and others before that), IIRC, not an entrepreneur. Guimbals are made in France, XtremeAirs in Germany. The major difference is, that I can see, they are not loaded with avionics. Otherwise it beats me where four seat SEPs get so expensive (other than they just can slap such a price tag on them).
Otherwise it beats me where four seat SEPs get so expensive (other than they just can slap such a price tag on them).
Indeed – a frequent rant of mine 
It is hugely non-obvious how there could be any truth in e.g. Cessna saying they cannot do a “new C152” because it would cost them $200M (or whatever) to get it certified.
So I think most of these figures are just bollox.
I think we have had multiple threads on this but it’s not hard to do a rough costing on a SEP, based on fairly easily guessed OEM pricing of major parts like the engine and a G1000 kit. It is impossible to make it add up to anywhere near the list price of a fully loaded SR22 for example… even allowing for a 15% dealer margin and likely warranty costs.
What we are probably seeing is a combination of very poor productivity (I think Socata’s one was exceptionally bad; I almost never saw anybody in their factory doing much work), overloaded fixed costs (including a huge advertising budget in some cases), a way overstated provision for product liability (good for depressing taxable profits but that is going to bite you eventually because you can’t keep doing that for ever), and a fat return to investors who are keeping some businesses afloat (they are not charities).
A new 152 would probably fall under VLA (quite a few companies managed to get planes certified under that), especially if they could get an exception like Diamond or the proposed changes materialized. Diamond is selling Rotax powered DA20 for what? About 125-130k? Aquila A 211 should be similarly priced.
Well, Cessna is an old company, probably not very efficient, not a small team of enthusiasts chasing a dream. So they could very well eat through a 100 million or whatever USD. I just wouldn’t expect much of it to fall on certification since they should know what they are doing. I read somewhere how much EASA charges, forgot the numbers, but they were peanuts compared to these sums (you obviously have to add salaries of people involved in the certification effort and other expenses like fuel, etc.).
Martin wrote:
Otherwise it beats me where four seat SEPs get so expensive (other than they just can slap such a price tag on them).
That actually is what I believe one of the major reasons why GA declines. If you take cars as an example, all that is left on the market are airplanes equivalent to hand made oddities such as Lamborhinis and Morgans(if they are still made) which naturally cost a lot of money because each and every one of them is practically hand made and uses low volume specialized electronics like out avionics. That would NEVER work in the car industry, where cost is massively driven downwards by automated methods and the sheer quantity. If 200 Cirrus are sold over a year then the full overhead of that factory, the certification cost e.t.c. lasts on these 200 airframes. That is a darn sight different than a car plant which produces a couple of million cars per year.
Peter wrote:
Cessna saying they cannot do a “new C152” because it would cost them $200M (or whatever) to get it certified.
Well, they did try with the Skycatcher didn’t they. And failed.
But there is a point to that. I’ve recently followed some discussions at Mooney. They are doing exactly that, a brand new, white sheet airframe. And they estimate that the cost will be horrendous to get it certified but they do it anyway because they know that they have to break out of the confines of the M20 type certificate. And that trap is where most of todays manufacturers are in.
Cessna could make a new series but it would cost them loads more than hanging on to the type certificates they do have and modify those. That is basically what all legacy manufacturers do, even Cirrus is doing exactly that, the GX5 is the 5th incarnation of the same type certified plane. And the first certification of that plane almost killed them! Columbia? Taken over by Cessna because they could never recover the cost of the certification.
In fact, todays new companies very often follow a similar path: They come up with a great new design, certify it, go bancrupt and thereafter sell the new type certificate (or the whole company) in order to actually produce it. Cirrus, Columbia, Eclipse, the list goes on.
Why won’t Lycoming or Continental finally develop engines which would correspond to today’s technical level? Same reason, even they can not afford to do it without risiking the whole company on the costs. So some manufacturers arise and make uncertified stuff and sell like mad. Now that can not be the idea, if certification is such a problem and the uncertified stuff works just as well but is simply politically hassled, then what is the purpose of such elaborate certification?
So yes, Certification is today one of the biggest hurdle and one which makes planes so expensive. Even if the actual certification cost may be less, with the numbers produced, it is no wonder that a plane which in terms of parts and components would cost maybe 50k as a luxury car costs 800k as an airplane.
Look at avionics. They never get finished. IFD440/540? King? They spend millions into developing a box which will sell a few thousand exemplars. No wonder that one has the value of a new Prius, and that is just the Radio for heaven’s sake. At the same time, we get a lot of boxes and even apps for 200$ ipads which have more features, work better and cost next to nothing.
How many airplane manufacturers never got past certification but ran bancrupt before? How many avionics makers? It is not supposed to be that way. Certification means to assure that the certified appliance corresponds to set standards, not an unsurmountable barrier.
So if not certification, then what?
For me, the devils circle is that. High prices will mean low volume, low volume means high overhead per airframe, high overhead is amongst other things caused by high certification costs. The fact that these costs are so high also does one more thing: It monopolizes airplanes, avionics and engines to a few companies who again manufacture low volume / high cost articles.
What is needed would be a “Volkswagen” concept of airplane, much as the German original concept, or the French 2CV. Affordable, mass produced, standardizes and with today’s manufacturing techniques and certified at a cost which makes it worthwile. Somehow I can’t really see that happen in today’s environment however.
Mooney_Driver wrote:
That is basically what all legacy manufacturers do, even Cirrus is doing exactly that, the GX5 is the 5th incarnation of the same type certified plane.
The TBM900 is also actually under the TBM700 TC ISTR.
A new 152 would probably fall under VLA (quite a few companies managed to get planes certified under that), especially if they could get an exception like Diamond or the proposed changes materialized.
VLA is a dead end road as it doesn’t include IFR certification.
Diamond is selling Rotax powered DA20 for what? About 125-130k? Aquila A 211 should be similarly priced.
Diamond hasn’t built any new Rotax powered DA20s in almost 20 years.
A new 211 costs 180-200k once it’s in your hands. VFR-only.
