I know in the FAA world an A&P’s privilege includes avionics, because avionics is “airframe”. In reality most avionics work in the US is done by 145 shops but that’s because it is easy to get a 145 over there. So the aircraft owner can do the work and if his A&P is happy, everybody is happy and it is 100% legal. If the installation involves e.g. an STC then you need an A&P/IA to conform and sign off on the 337 etc.
What are the corresponding requirements in EASA-world? Can a freelance EASA66 mechanic similarly check and sign off avionics work done by an aircraft owner? Assume it is a Minor mod, or under some concession like the stuff in Part-ML. That ought to cover stuff like installing an EDM700. And what if it isn’t a Minor mod e.g. you want to install a GTN750 under an AML STC.
The motivation is
Getting someone to do the paperwork properly on any job/modification is one of the biggest hurdles I come across regardless of registration.
Someone good working in GA Tech records who can do 337’s, Equipment Lists, W&B Sheets, AD reports, Log Book Entries, Log Book Surveys, etc could earn 2x what a mechanic could earn if they wanted to do freelance work. I am surprised nobody has made a decent business out of offering the services remotely. Any freelance avionics or mechanics I know simply have minimal time to spend on paperwork.
When I remember right, a minor change requires an MRO.
Peter wrote:
And what if it isn’t a Minor mod e.g. you want to install a GTN750 under an AML STC.
This is a minor change
Peter wrote:
That ought to cover stuff like installing an EDM700
This is not a minor change but a standard change, can be done under CS-TAN and does not require an MRO.
A freelancer with category B2 in the Part-66 license can, according to 66.A.20 (a)(3)(i),
issue certificates of release to service and to act as B2 support staff for following:
— maintenance performed on avionic and electrical systems, and
— electrical and avionics tasks within powerplant and mechanical systems, requiring only simple tests to prove their serviceability;
So, in more complex cases, a category B1 or C may be needed in addition. Other than that, no problem so long as the aircraft is non-complex and in non-commercial operation (otherwise, no freelancers at all). As to the work done by the aircraft owner, it’s down to the Part-66 license holder’s judgment to inspect and accept the work.
Someone good working in GA Tech records who can do 337’s, Equipment Lists, W&B Sheets, AD reports, Log Book Entries, Log Book Surveys, etc could earn 2x what a mechanic could earn if they wanted to do freelance work. I am surprised nobody has made a decent business out of offering the services remotely. Any freelance avionics or mechanics I know simply have minimal time to spend on paperwork.
One fairly basic issue is that only a fool will generate paperwork without doing a physical inspection, and that complicates the job. In the FAA scene that is highly risky because it takes only 1 or 2 reports from a subsequent owner of a dodgy signoff and the FAA will just strip your IA (and eventually your A&P also) qualification. It is a lot safer in the EASA scene but there are far fewer freelancers to start with.
Also a 337 isn’t a standalone thing. We sort of did that before. It is a “cover sheet” for a Major Alteration, and that job needs other supporting stuff e.g. a Field Approval (hard to do in Europe; I’ve done a few using US based contacts), an STC, a DER 8110 form (usually not cheap), or a TC.
IME most people who do the work don’t understand the approval routes, or they offer routes which are overpriced for the job (partly the same thing).
And what if it isn’t a Minor mod e.g. you want to install a GTN750 under an AML STC.
This is a minor change
I don’t think so. Anything under an STC is a Major – unless it is a “bogus/marketing STC” like e.g. the ones intended for mechanics who want to cover their backside for installing a Concorde battery in place of a Gill. But the STC delivers the supporting data, plus any AFMS, which is why it is such a great route.
A freelancer with category B2 in the Part-66 license can
That’s great.
What is involved in getting a B2? Is that the same as what used to be a UK CAA B2? That wasn’t common.
I would guess that EASA66+B2 is not all that common because I have known a bunch of avionics installers who always worked under “somebody’s hangar approval”. Or of course off the books. They could not sign off a job.
So let’s say I want to install a new audio panel in my own airplane, which ought to be a pretty simple wiring job. How do I know whether this is 1) possible, and 2) who would need to sign it off?
Peter wrote:
One fairly basic issue is that only a fool will generate paperwork without doing a physical inspection, and that complicates the job
They would only need to generate a good draft version of everything for the freelancer who did the work with the signing authority, to look over match up to the job. This would be the same as a big workshop, the guys making the paperwork have clean hands. The guys doing the spanner work would rarely be involved in the paperwork.
Peter wrote:
What is involved in getting a B2? Is that the same as what used to be a UK CAA B2? That wasn’t common.I would guess that EASA66+B2 is not all that common because I have known a bunch of avionics installers who always worked under “somebody’s hangar approval”. Or of course off the books. They could not sign off a job.
Even if an avionics guy works under a Part-145 or Part-MF organisation officially, he still needs a B2 to sign off. Getting a B2 is generally the same as getting a B1 except a different scope of theory tests and practical experience. I sat all the 17 theory modules, so I have a B1.2 and B2 now but can get B1.1/1.3/1.4 once I gain sufficient practical experience. However, in addition to category, one should also have a relevant type or group rating. I have group 3, which is non-complex piston aeroplanes.
As to B2 being less common than B1, the demand for them in terms of man-hours is lower anyway. Also, fewer people have a talent for electronics than for mechanics. One more reason behind the shortage of avionics freelancers may be a relatively high cost of their tools.
dutch_flyer wrote:
So let’s say I want to install a new audio panel in my own airplane, which ought to be a pretty simple wiring job. How do I know whether this is 1) possible, and 2) who would need to sign it off?
Audio panel installation is a standard change under CS-STAN, but it can’t be released by a pilot-owner, so you need a B2 holder (freelance or organisation). The prerequisites are as follows:
— the equipment is authorised in accordance with ETSO-C50c or ETSO-C139a, or later amendments, or the equivalent;
— the equipment has at least the audio functionality of the previously installed equipment, and is compatible with the existing installation;
— the equipment is compatible with the connections to the existing communication and navigation systems;
— the equipment is qualified for the environmental conditions to be expected during normal operation; and
— the instructions and tests defined by the equipment manufacturer are followed.
As to the simplicity of the wiring job, it isn’t very complex but there are some techniques to be observed and some pitfalls to be aware of. Shielding and grounding are two important aspects – if you do them improperly, you can create an installation that works perfectly on the ground with an engine off but gives you trouble in flight.
WilliamF wrote:
This would be the same as a big workshop, the guys making the paperwork have clean hands. The guys doing the spanner work would rarely be involved in the paperwork.
Avionics guys also have reasonably clean hands 
This is great because it enables an aircraft owner to do a lot of his own wiring and get a freelance signoff.
Maybe @Ultranomad should set up a training course for B2
Ultranomad wrote:
Shielding and grounding are two important aspects – if you do them improperly, you can create an installation that works perfectly on the ground with an engine off but gives you trouble in flight.
This was a big problem with our old radio installation – not so much when the engine was running, but the audio cables were picking up the radio’s own RF emissions, and causing feedback squeal when keying the mic. When we replaced the old Narco radio, the intercom and radio wiring I removed was hideous. It had been like that for a while.
