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Is the FAA accepting EASA modifications directly?

This document has been emailed to me, with a suggestion that it does.

I can’t really get my head around it (150 pages) but does anybody know?

The FAA-EASA treaty, concluded maybe a year ago, allows for mutual acceptance of the data submitted to get an STC, but that is of course totally different from accepting the STC itself.

OTOH an EASA Minor Mod, approved by Cologne, might be acceptable to the FAA…

But looking at the bilateral aspect of this, an FAA Minor Mod is not approved by the FAA so it has no bilateral standing, so how would this work?

Administrator
Shoreham EGKA, United Kingdom

rather prefer it the other way : that EASA accepts FAA STCs…. but that was anounced to come – one day….

EDRT

Normally this issue goes the FAA STC to EASA way, but for the TRX-1500A, which is European made and only has the EASA minor mod approval, how would one get the approval to install on a N-reg’ed aircraft?

Garrecht says it is possible according to the document mentioned by Peter above, but has anybody tried it out?
Does it require a Field Approval, or is installing such “accessories” considered so minor, that a simple logbook entry referring to the bilateral agreement above is enough??

spirit49
LOIH

Garrecht says it is possible according to the document mentioned by Peter above, but has anybody tried it out?

I have tried it with one of our own custom made avionics systems. This was certified the same way as Garrechts TRX-1500A (Standard part) instead of full certification. This way is possible for some avionics and less expensive certification methode. FAA would not accept this.

Unfortunatly for European companies EASA doesn’t have a PMA system like FAA’s PMA. PMA certification is also less expensive than “full” certification.
PMA is widely accepted in EASA, EASA’s alternative with standard parts is not accepted by the FAA.

JP-Avionics
EHMZ

Well. Garrecht says in an email earlier today:

we only have an EASA Minor Change Approval, however its possible to use it for FAA aircraft as well via bilateral agreements, please look at 3.2.7.2 in the attached document. This should however by clarified with the FAA examiner of your aircraft first.

Attached document being the paper Peter is referring to above.

SO, if Garrecht is trying to sell a product they have an EASA approval on, and referring to the bilateral agreement, while you Jesse (on the sharp end of this business) say its impossible, somebody have gotten it wrong.

I can just imagine the nightmare you have if buying a product like this, then not being able to install it.

However, WHAT is this bilateral agreement about then. Last time I checked the word bi-lateral, it meant 2-ways……

Last Edited by spirit49 at 16 Feb 20:32
spirit49
LOIH

I think it has to do with interpretation. I think Garrecht is right, as they accept minor changes. As it is considerd as a standard part (just like the product I tried) you won’t have an EASA Form 1 with the part. This is where things go wrong I suspect. It is more a less like a PMA part, in which production, part and installation have been certified in one go, instead of certification of the part, and installation as two seperate certifications (full certification with EASA Form 1)

FAA quote on my question based on this document :" I confirmed with my EASA counterpart that it would have to be produced under a POA. And all parts exported from a POA must be shipped with an EASA Form 1."

With this standard part you don’t use the expensive POA / DOA route, therefore no EASA Form 1. This was back in 2012, so it might have changed for positive.

The best thing for European aviation companies would be a EASA/FAA PMA. Getting an FAA PMA as European company is not possible :-(

JP-Avionics
EHMZ

That means that the TRX-1500A could be installed in a N-reg? Right?

Leads me to 2 new questions:

1. Is the EASA Minor Mod paperwork required for a N-reg?
2. Is a logbook entry enough for such an installation, refereeing to the EASA Minor Mod document and the bilateral agreement?

spirit49
LOIH

Not according the FAA in a similair case. They do accept EASA minor changes, but don’t accept the part itself because it doesn’t come with a EASA Form 1.

They only seem to accept a minor change IF the actual parts are produced by a certified production facility (POA) and comes with EASA Form 1.

For your other questions, ask you A&P / IA. @Michael on this forum, might be able to answer this part of your question.

Last Edited by Jesse at 16 Feb 21:05
JP-Avionics
EHMZ

Damn this is complicated…….. :I

For your other questions, ask you A&P / IA. @Michael on this forum, might be able to answer this part of your question.

Michael is my A&P so I was hoping to do the grunt research on this installation before I show up on his steps with a shinny brand new yellow box for him to install.

My thoughts on installing the TRX-1500A is that it is a MASSIVE step in avoiding other traffic. And sending out/receiving FLARM I will do my part in the local airspace I operate. However it seems to me that increasing safety margins isn’t so easy after all.

spirit49
LOIH

Jesse pretty much nailed it : There’s the installation and there’s the device, both need “approved data”.

The installing FAA A&P determines whether it’s a Minor or Major, and the EASA Minor Mod document is worthless in this case, but one could assume that if it is considered “Minor” by EASA, then there’s a good chance the installing A&P would too.

The box would need it’s own “approved data”, typically in the form of a FAA TSO, PMA or STC.

FAA A&P/IA
LFPN
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