That, Alan, is dynamite…
Above link is to an EASA presentation on the topic and within the presentation is a link to the certification memorandum
I wonder what
identified for installation in the specific aircraft;
not complex motor-powered
mean…
If the second one refers to the “EASA complex” term (i.e. 5700kg+ 19+ seats etc) that’s OK. But if it refers to “complex” in the traditional way (i.e. CS prop, retractable) that makes this worth a lot less.
I have saved a local copy here.
“Identified for installation etc” means there is a log saying that a part without Form 1 has been installed on G-ABCD
“Complex” as defined by EASA means as you say, plus no more than one turbine and no jets at all and not requiring two crew. TBM850 is not complex. My Twin Comanche is an ELA 2 as it has piston engines.
Back on the topic of ELA 1 maintenance, there has been an opinion published recommending that the maintenance programme for an ELA 1 can be declared by the owner without any involvement of an NAA. Associated with this in the same opinion is the recommendation to publish a MIP (minimum inspection programme) to use as a starting point for the design of such a maintenance programme.
Due out Q4 2014
Complex with CS Prop, retractable etc is an FAA concept I understand and as Alan quiet rightly points out, it means genuinely complex in European definitions.
So… where are the opportunities here?
This regulation is in for a while. I don’t see many advantage for a Thielert engine for example.
where are the opportunities here?
The implication is that you can reduce the maintenance costs substantially – in certain areas – by purchasing parts from industrial outlets such as (for electrical parts) RS Components, Farnell, Digikey, Mouser, etc, etc.
For example (this is a TB20 but that’s not the point) you have a landing gear squat switch. From Socata this might be €1500. From a standard aviation parts supplier it might be €700 (albeit without the crappy AMP connector fitted, which costs €3 from e.g. mouser.com). From an industrial switch distributor it might be €200 (again without the connector) and the only trick there will be to get the CofC.
What you will have difficulty with is proving (even if it is obvious by inspection and industry knowledge) is that all three are the same. The Socata one will have more mysterious inspection stamps on it… You don’t know that e.g. they don’t test it over some extended temp range. For example RS sell a €20 Crouzet microswitch (used to illuminate the gear status indicator lamps) which is absolutely identical to a Socata €100 one, but the latter has a suffix on its P/N which Crouzet do not include in their data sheet.
But that difficulty will always be present (because Socata are hardly going to reveal the exact process which they apply to the switch on its way into the plastic bag with the Socata tag inside) so this EASA regulation cannot require such a high burden of proof otherwise it would be always be completely useless.
You won’t save money on airframe structural parts (brackets, etc) because they come from the airframe manufacturer only. And the cost of such parts is why owning a long-neglected/abused plane is usually expensive.
But an aircraft manufacturer makes only the airframe and the wiring harness. All other bits are bought in, off the shelf.
The Socata heater hoses can be bought from the manufacturer Spiragaine (just make sure you don’t ask for the hose by the Socata P/N else Spiragaine will tell you to piss off) at a fraction of the price. Or an identical spec hose can be bought from a high end motor racing parts supplier and cut to length.
Trelleborg (or standard American AN) O-rings… €2 instead of €20; the trick there is to group together with enough others to buy a few dozen.
Stabilus gas struts for doors. On all aircraft you find stull like PTT switches costing €200 (or €2 for a crappy one, or €30 for a milspec one). The famous TB avionics relay board which costs €700 but contains four socketed car relays costing €4 each.
The list is long. The only limit is how much effort you want to put in finding the OEM parts and as I say finding others to share a larger purchase.
For example I am now trying to buy a small quantity of the Le Bozec fuel filter. It is about €200 from Socata and about half that from the (predictably) French manufacturer, and there are two sources of what is a fairly generic part.
I don’t see many advantage for a Thielert engine for example.
Not for a Thielert because that is an engine so loads of “critical” parts.
Probably not for a Diamond airframe anyway because a Diamond is full of special parts not used on any other aircraft and, to make things worse, it’s full of special European parts. A Diamond owner is probably over a barrel more than anybody else, when it comes to alternate sourcing. Worse than Socata, most likely, because at least Socatas used American engines.
However if Diamond do what Socata do which is to buy in bits from firms in the homebuilt aircraft industry (e.g. brake master cylinders) then sourcing the exact parts from the actual manufacturer should be easy, and you can save thousands that way because those bits are always expensive.
I am not sure why many parts of a Thielert engine would not qualify under this rule. Where does it say that critical engine parts are a no-no?
In the presentation I see a picture of hoses for instance that qualify, I’d say that this is a critical part.
would it not make a lot of sense for a Thielert engine? Case in point: The starter motor. Thielert rips you off for 1.000 euros for what I suspect is a standard Mercedes component that you can buy for 200 or so. More of such stuff on the engine..
i am going to talk to my service center and see what he says.
My view, yet to be put to the test, is that this legislation also allows the owner to authorise the fitment of used parts and also US-overhauled parts, both without Form 1.
The original NPA is worth seeking out as I believe it represents the intention of this ruling. There was some interesting stuff about copying and making minor parts like brackets. Some of the preamble spoke about needing to relax control over certain areas, so I expect that issues of burden of proof will be unlikely.
Peter – I don’t see anything that requires a CofC
(As an aside, UK law is very much of the form “if it doesn’t say you can’t, you can”)
