I will try to explain again my previous question. There are 3 different process with certificates (attached).
1. Process for using of part with acceptable certificates for installation on same aircraft depends on aircraft registration I have explain in Appendix 05
2. Process of issuing certificate for part removed as serviceable from aircraft (ROBBERY PROCESS) I have explain in Appendix 03 (Under EASA A rating)
3. Process of issuing certificate for part that was maintained in the shop I have explain in Appendix 04 (Under EASA B,C,D ratings)
My Question was related to item 2 – Can anybody know the way for part removed as serviceable from aircraft (Robbery process) registered in EASA to be issued :
- Normally and in according to EASA regulation – EASA F1 (and i.a.w Appendix 03 (attached)
- Customer required FAA 8130-3 to be issued also, but I cannot find the FAA regulation how to be issued 8130-3 for part removedfrom EASA registered aircraft during robbery proces.
Appendix_03_Instruction_for_Issuing_Component_Certificate_of_Release_to_Service_during_aircraft_maintenance_pdf
Appendix_04_Instruction_for_Issuing_Component_Certificate_of_Release_to_Service_i_a_w_DOC_2_pdf
Appendix_05_Acceptable_certificates_for_installation_of_an_article_pdf
This is interesting (and a huge amount of work has gone into those tables) but looks quite complicated.
Are you asking for what is legal for private flying, or is this for AOC operations?
Let me take just one line in the first PDF (appendix 3):
That is not correct, for private (Part 91) operations, because an FAA A&P has the authority to inspect a part and declare it airworthy (or not). The part does not need an 8130-3. If it did, that would imply a mandatory inspection by a FAA 145 company, which is obviously wrong.
The EASA version of the above is much more complicated – see e.g. here.
Then you have various concessions under Part M Light / CS-STAN. Very few people understand these, and there isn’t a lot of support in the maintenance business (because the ability to use parts without EASA-1 etc reduces the shop revenue) but you can read e.g. this.
Recent EuroGA contributors who may know more about the EASA side are @antonio and @ultranomad.
NikolaSRB wrote:
Customer required FAA 8130-3 to be issued also, but I cannot find the FAA regulation how to be issued 8130-3 for part removedfrom EASA registered aircraft during robbery proces.
Check the FAA MAG (mx annex guidance). If the 145 shop is faa approved they can issue 8130. Issueing easa form 1 and acceptance by FAA could also work:
More requirements are in the US/FAA <> EU/EASA BASA (Bilateral Aviation Safety Agreement) TIP (technical implementation procedures) and FAA MAG (mx annex guidance).
You don’t need an 8130-3 for the part. You need an A&P with an eyeball or two 
NikolaSRB wrote:
Customer required FAA 8130-3 to be issued also, but I cannot find the FAA regulation how to be issued 8130-3 for part removed from EASA registered aircraft
I too wonder why the customer requires an 8130-3?
The only parts for which I’ve needed an 8130 for legal installation on my FAA regulated aircraft have been overhauled propellers and overhauled instruments, because work performed on those must be performed by a repair station to be legal, and accordingly repair stations issue paperwork to document their involvement. Otherwise there is no requirement for 8130 or any other paperwork to install a part on a privately operated (FAR Part 91) aircraft, whether the part is new or used. As Peter says the mechanics logbook entry is all that’s needed, essentially as follows: “removed widget and installed used serviceable widget. Checked for satisfactory operation, OK. John Smith A&P 123456” The registry of the aircraft the part came from is not relevant.
A German guy at my US base imports non-airworthy EU registered aircraft in containers as a business and parts them out, selling the parts for use on certified N-registered aircraft in the US, without paperwork.
Additional information/explanation:
Customer leased Landing Gear for use on EASA registered B737NG aircraft (at the moment on the maintenance in our Co) and now need FAA 8130-3 and EASA Form 1 as a process for lease return, but there are two possibilities:
1. Landing Gear can be sent to the shop with EASA & FAA capabilities and after maintenance can be issued EASA F1 and 8130-3 separately due to we (Serbia) is not part of EU, but our Co have FAA and EASA approval for shop maintenance (EASA C rating) can be – Customer not accepted this option – too expensive. (see Appendix 3 from my previous message)
2. Landing Gear can be certified threw Robbery process (EASA A rating) for used part removed serviceable from EASA registered aircraft, but threw this process can be issued EASA F1 (EASA 145 A 50) and cannot be issued 8130-3 (as I know). Customer accept this option, but during certification process defined in the EASA 145 A 50, customer required 8130-3 also. That is my PROBLEM. I need clear answer YES or NO. Somewhere shall be noted/wrote which certificate can be issued during robbery process depends on A/C registration -in my case EASA registered aircraft. (see Appendix 4 from my previous message)
Additional question for you is: Where is define process (what maintenance action have to be done) LEASE RETURN?
Thanks everybody for help.
Are you telling me someone in the business of leasing airliner landing gears is expecting an answer from amateur pilot forums?
These issues are far more complex than private non commercial topics and the amount of money involved easily covers (and warrants) to pay consulting fees to experts.
Well, I guess the B737 BBJ could be considered a GA aircraft!… I had a feeling this 8130 question might be in relation to aircraft operating outside of FAA Part 91, for which I imagine there is little maintenance paperwork expertise on EuroGA.
All sorts of stuff goes on out there… I recall reading about a 737 which was written off (totalled, in US-speak) because somebody installed replacement landing gear without the right paperwork, and the value of an old 737, minus the cost of buying a set of landing gear with “paperwork”, was below the cost of scrapping it.
For those who find this hard to believe, I posted this a while ago
