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Latest on 8.33 requirements (merged)

Yes, the market of used/refurbished KX 165A is empty. This is what I have experianced from six month ago, a dealer of used avionics near NY was unable to find one, although they are listed. Therefore I decided for a brand new one for 5050 USD. And I would not buy a second one even the regulations demand two 8,33.

Berlin, Germany

One of the issues with that is that you have to set up the whole QA charade, including hosting a delegation of FAA employees.

Well this is one of thing what makes it expensive, I think it could be slightly better under FAA then under EASA. FAA will is some cases require you to produce in America. They are quite protective for their own market. As shame EASA isn’t.

Don’t get me wrong here, An America avionics design company will have a little easer life then then European one.

One can see why companies like Dynon go after the non-CofA market. You don’t even need ISO9000 (another €€€€ charade, traditionally discharged by throwing in a QA “consultant” for a few weeks).

I don’t see why you would need to be ISO9000?

A KX165A is about 1 man-year, if you are competent in analog and RF and are not “leveraging” (a word I dislike) an existing product.

That could be possible, for an uncertified project. The certification will make it much more, and therefor also more expensive. Apart from that, it takes ages before your receive feedback on all your report, this alone could take more then one year for all reviews combined.

JP-Avionics
EHMZ

My GTX330 was unreadable in daylight and had to be swapped for another one. There was a problem with it, but it isn’t very good and IMHO works because one rarely looks at it.

I don’t say that their aren’t problems with it, I just have never seen them, and have seen them a lot with the KX displays. As it still goes wrong on KX A versions it shows that it is a poor quality / design problem.

I don’t like that manufacturers change their display for different products, which they all seem to do for different products. I just look ugly. If you would have KY-197, KR-86, GNC-255 and GTX-330 you would have four different display colors from two manufactures. Crazy!

JP-Avionics
EHMZ

Jesse

I take your point about the cleaning of the display contacts in King radios if you don’t think ahead, but with a little pre planning you can get this done as part of an annual check rather than wait for things to go wrong as King radio display problems show up long before the display becomes unusable.

True,

Both most clubs try to save some money and don’t want "unnecessary maintenance. It happens most often by flying clubs, with aircraft outside, most private owners have their aircraft hangared on the airfields I work. Then they don’t have any problems.

No need to say that having in aircraft in a hangar is always better from a maintenance and cosmetic point of view.

JP-Avionics
EHMZ

I don’t see why you would need to be ISO9000?

A while ago I looked at making a PMA product.

It would have been hard to do in Europe. There is the “FAA delegation” issue, and they want to see a certain type of QA system, and ISO9000 would have been a starting point for ticking that box. I suspect it is impossible unless you have a certain number of employees so they can be appointed to the various QA posts – a bit like an EASA CAMO but bigger.

Then if you want to be able to generate 8130-3 forms you need to be an FAA 145 company which is a huge job – see here

I am not sure the Americans are specifically protective of their home market, but their “world” is certainly slanted to work for them, which it does very well, but it makes it hard for outsiders to get into.

The bottom line is that there are a number of old players who already have the technology for just about anything you might want, so any newcomer is very vulnerable. The business case hangs totally on the old players remaining nicely asleep, and not having a single person left who can even switch on the PC on which the KX165A PCBs were laid out – which is probably a good approach with King but as I say it is a risk because a clever new manager could wake up the old giant.

Years ago, during the Mode S “wars” in N Europe, there was much talk of a low cost Mode S transponder coming out. Of course it never did – because no existing player wants to bomb to market price, and with it bomb the value of the ~25% dealer discount (a sure way to a commercial death, in certified avionics). And any newcomer would be obviously vulnerable to say Garmin (who makes the GTX330 for about $200 in parts and direct labour) just dropping the price and killing him (or buying him, recruiting the 1 or 2 smart engineers he has, and shutting him down, which is the modern way of doing this).

Also a massive advantage is in personal relationships with the cert authorities. Firms like Garmin and King are on first name terms with the real players in the FAA, and Garmin are evidently on better than first name terms with EASA (how else to get an “over our dead body” AML STC?). How do you even start building that?

cleaning of the display contacts in King radios

How about coating them in conformal coating?

Last Edited by Peter at 19 Jan 12:58
Administrator
Shoreham EGKA, United Kingdom

Peter, the QA system issues for being an FAA PMA manufacturer are apparently solvable by the usual methods – a friend of mine makes PMA and TSO’d stuff now, with a small number of employees. His company was well established in the experimental market first. ISO certification is not part of his approach.

The same guy/company also sells to OEM airframe manufacturers, and doesn’t need a PMA to do that – it’s covered by the aircraft TC. On one occasion recently he needed one of his own parts for local use, upgrading an older airframe, and sent the part to the customer so they could release it with an 8130 and send it back to him!

Other than local contacts who make non-electronic airframe and propulsion components, there is another group I don’t know well who does autopilots including both the electronics and servos etc. They have not yet done approved systems AFAIK – presumably the experimental business is strong enough. Regardless, it seems to me that being in the experimental parts business beforehand is helpful prior to moving into FAA PMA parts. By that I mean manufacturing and selling to homebuilders, warbirds or whomever and developing product, cash flow and reputation with FAA. How that would work out outside of the US, selling internationally including the US, I’m not so sure.

Last Edited by Silvaire at 19 Jan 13:53

Being able to produce under an FAA PMA in Europa would be interesting, as far as I know this is not possible.

PMA is much more suiteable, and affordable for some non critical equipment. Even Magneto’s are manufactured as PMA parts !?!?

Unfortunatly EASA accepts FAA PMA parts, while it their is no similair EASA PMA regulation :-(

Don’t get me wrong, I think PMA is a good thing, only EASA runes the European market by accepting the less expensive PMA, while demanding the far more expensive full design and production approvals in most similair cases for European companies. Just not a level playfield.

JP-Avionics
EHMZ

Unfortunatly EASA accepts FAA PMA parts,

They have to – otherwise most of aviation would end at the next service.

“Half” the bits we fly with are PMA parts.

Administrator
Shoreham EGKA, United Kingdom

They have to – otherwise most of aviation would end at the next service. “Half” the bits we fly with are PMA parts.

Yes! So they (EASA) should make a FAA-PMA like regulation for European manufacturers. Would be good for European aviation industry and give consumers more equipment to choose from combined with better pricing.

JP-Avionics
EHMZ
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