Peter wrote:
all without any of the equipment being supported by an STC or some other data (e.g. Installation Manuals), as a Minor mod? How much did the clients pay for your design work, submitted to EASA?
It depends on the project, see below. My clients don’t pay separate for design, it is included in the installation pricing, as I can not install those without approval. The have to pay the EASA fee’s, which I charge on a 1 to 1 basis.
- Installation of brake light (for an instructor which wanted to know when his students where applying brakes in the air).
This one was one of my firest own design, further standard practices AC-43.13. I though it was funny when he came in asking if I could install a brake light in his aircraft. Though can be quite usefull on some aircraft I guess.
- Installation of stormscope systems
- Installation of different traffic systems including antennas
Done in according manufacturer installation manual and AC-43.13
- Installation of a WX radar in a different pod using the POD which was already certified.
This one was an mix of installation manual for WX radard, own design, and excisting installation further standard practices AC-43.13
- Installation of multiple 100 Watt HF systems, including tuner and antenna on unpressurised aircraft
These were HAM amateur radio HF transceivers which where modified to work on clients own frequency, this included testing emissions as well, as it required modification to frequency and filters. As such this equipment didn’t come with installations other then for amateur use. The same for the tuner. The antenna was designed for aviation use, though not for this specific aircraft. So own design, which also included EMC testing and functional in air testing.
- Installation of very high resolution 3D camera systems (looking downward) on multiple unpressurised aircraft
This where specialised camera system, delivered as a complete product. aircraft allready had a very large hole. Installation was for the camera system, including mounting and processing (50 Amp current consumption for the complete system). Installation own design with AC-43.13 as guideline.This also required EMC testing.
- Installation of our own air data computer
Own design software and hardware and installation instructions, required EMC testing as well.
- Installation of our own datalogger
Own design software and hardware and installation instructions, required EMC testing as well.
- Installation of multiple maritime VHF radios including antennas
Installation of standard maritime VHF radio, tuning of VHF aviation antenna. Own design based on maritime installation instructions and AC-43.13.
- Installation of relaying equipment including antennas
Installation of custom made equipment (equipment build by thirdth party), Own design for installation, required EMC testing, also included tuning of antenna’s.
- Installation ELT system on the bottom of the fuselage including antenna
This was for a fixed gear SEP, with first ELT on top to meet requirements. Secondary ELT was instralled on bottom. Installation instructions based on ELT installation manual, with a deviation for the antenna installation.
As you can see quite some items can be done using minor change. It typically requires a long time though for these specials.
Yes – Form 32 application to EASA and use the data from the equipment installation manuals. No different to any other minor change.
Peter wrote:
What level of approved data (what amount of work and what needs to be generated) is needed for that? What is the EASA process?
Their should be a engineering report to show that compliances with all regulations and all work to be done, ICA procedures, test procedures etc. I would guess this is the same to the FAA process (when I perform avionics works on FAA aircraft, the A&P/IA useally takes care of this)
Peter wrote:
Can the aircraft owner do this himself (using a freelance avionics installer) and apply to EASA himself?
An owner can do this himself, though I guess it can be pretty though. The avionics installer should be cable of doing this as well. I have done many changes also for others. I have people asking for complete applications all the time. As I spend a lot of time on those, and that it is included in my pricing when I install equipment, I don’t hand out this applications. Sure enough the approval itself is included and installer / owner document, not the part that goes too EASA. I guess other companies do the same. One doesn’t give away hours of labour.
Getting the approval sorted can be quite time consuming as well. I have customers asking for EASA contact details, which I never give. I have to work with this organisation on a regular basis. I can not afford have customers interfere with this process.
Jesse – Peter doesn’t believe in paying for approval paperwork, whether an 8110-3 or god forbid an EASA minor change.
I think I am beginning to understand how this works…
One does a Minor mod allright but pays a few k for it 
Peter doesn’t believe in paying for approval paperwork, whether an 8110-3 or god forbid an EASA minor change.
A somewhat disingenuous statement, but you know you can count on me not disclosing private communication supporting my position 
Peter wrote:
One does a Minor mod allright but pays a few k for it
Peter, it is the same as asking you to publish your schematics including sourcecode firmware, stating that it is only worth 50 Euro on parts, while you sell the equipment for more. Sure you have to make a living, so do we.
The margin on equipment is nowhere near a few k, especially if you think of it that design is included.
If you want to do it yourself, you will be free to do so. On ELT’s this is good example, where someone finds a lower price ELT then quoted, then it is USA pricing, shipping as dangerous good, programmed incorrectly, no design data. Then they apply for minor change themselfs, only to find out it will be rejected a couple of times. End result is that pricing is far more expensive then when they have bought from a capable avionics shop.
I jest Peter, but you do like to knock the EASA mod system and praise the FAA approach when in fact they’re not that different anymore (excluding Agency fees).
CS-STAN has brought an approach very similar to the FAA minor change – acceptable data only, not approved data, and certified just with a logbook entry.
FAA Major alteration equivalent to EASA Minor change – both require approved data.
FAA Major change to type design equivalent to an EASA Major change – both require approved data and are finally approved by the appropriate agency.
The days of the EASA Part 21J doing mods for GA is rapidly diminishing as equipment OEM’s get more AML STCs approved, so it’s only the unusual or specialised tasks that will be done by the design organisation. CS-STAN is going through an amendment at present which is going to provide a much a greater scope including replacement of primary instruments including the addition of electronic versions provided they meet the relevant TSO.
Thanks for the clarification.
you do like to knock the EASA mod system and praise the FAA approach when in fact they’re not that different anymore (excluding Agency fees).
I ask straight questions and they can be answered with a straight answer.
Some people think I am trying to make points. Sometimes I am, but subtlety is not my forte, and much more often (and in this case) I just happen to know a bit about the topic and am just structuring the question carefully to elicit an answer which reveals something that I think isn’t being revealed
And I do sense that there is a certain amount being left out, which would confuse the hell out of most people who don’t know much about this.
In FAA-land, a “minor mod” usually means an A&P/IA looks at it and decides it is a minor mod, and it goes in with a logbook entry. The FAA provides a fairly easy flow chart for this (yes I know there are various subtleties e.g. EFIS needs an STC). The paperwork costs the customer peanuts. Well, maybe a few hundred $ for some hours of somebody’s time, but this is unlikely because the “business” is done face to face and doesn’t involve an external agency and providing you pick TSOd products you don’t need to do anything special in documentation.
In the EASA-land “minor mod” scenarios described here, the customer pays thousands. So to call it a “minor mod” is not exactly accurate – especially if the poster then goes on to suggest that the EASA route is much better than the FAA route (a Major mod would be needed in most of the FAA cases)!
Take this “minor mod” from Jesse above
- Installation of multiple 100 Watt HF systems, including tuner and antenna on unpressurised aircraft
These were HAM amateur radio HF transceivers which where modified to work on clients own frequency, this included testing emissions as well, as it required modification to frequency and filters. As such this equipment didn’t come with installations other then for amateur use. The same for the tuner. The antenna was designed for aviation use, though not for this specific aircraft. So own design, which also included EMC testing and functional in air testing.
I happen to have spent enough days in EMC labs getting my electronic designs tested and I would have to be a complete idiot to think that particular “minor change” cost the customer less than thousands just in the design paperwork that goes to EASA to support the application!
So IMHO the EASA “minor change” route is meaningless for comparing with the FAA “minor alteration” route – because a customer will judge this according to how much it cost him.
To argue otherwise is to argue e.g. that I could install a PT6 engine in my TB20. The process is completely straightforward. It’s been done before… PA46s, Bonanzas, Cessnas, you name it. Really completely straightforward. Just throw a pile of money at it… (sarcasm doesn’t work on the internet but I am sure you get my drift).
What I am getting at is that EASA doesn’t seem to have a real “minor mod” process at all. Whichever way you do it, either you have to deal with EASA (and they decide) or you deal with an EASA 21 company (and they decide, within the limits of their authorisation to do minor mods). The former route can be quite cheap (a few hundred, IIRC) if you do the paperwork yourself (most customers can’t). The latter route might be, or not, but based on what I have seen it will be way more than a few hundred especially in the cases given as previous examples.
The days of the EASA Part 21J doing mods for GA is rapidly diminishing as equipment OEM’s get more AML STCs approved
That is indeed true but this is a long-ongoing process which benefits users equally under both systems, because most AML STCs (well, the ones from the big avionics names) are done for both regimes, for new products.
CS-STAN is going through an amendment at present which is going to provide a much a greater scope including replacement of primary instruments including the addition of electronic versions provided they meet the relevant TSO.
That would be highly relevant, if it means one could replace a primary instrument with a different (functionally same i.e. an encoding altimeter with a different presentation but which has the same gray code output) type, even though the aircraft TC specifically calls out the original. In FAA-land you need an STC for that, specifying “primary replacement”, AIUI. I spoke to one UK shop today and they said the same – an EASA STC is currently needed for such a substitution.
Peter wrote:
That would be highly relevant, if it means one could replace a primary instrument with a different (functionally same i.e. an encoding altimeter with a different presentation but which has the same gray code output) type, even though the aircraft TC specifically calls out the original. In FAA-land you need an STC for that, specifying “primary replacement”
Did you read CS-STAN? Under EASA you can often use CS-STAN, in other cases a minor change is enough.
You don’t seem to understand, that if you want to change anything from the TC or and applicable STC, it isn’t always a major change, as you seem to suggest all the time. The change can be minor of major. Cases like these a minor changes.
Peter wrote:
I spoke to one UK shop today and they said the same – an EASA STC is currently needed
You always spoke with a shop which doesn’t seem to understand any regulations as all. IMHO you just seem to be bashing EASA, installers or shops, all the time. Many of us have proved over and over again that you statements don’t make sense at all.
wigglyamp wrote:
but you do like to knock the EASA mod system and praise the FAA approach when in fact they’re not that different anymore
I agree with this, and really can not understand why you have related ALL of EASA, mechanics etc… You keep on this over and over and over.
Peter wrote:
I would have to be a complete idiot to think that particular “minor change” cost the customer less than thousands just in the design paperwork that goes to EASA to support the application!
Ok then I don’t charge enough I guess. Then if I would you would likely argue that monkeys are charging $$$ for a simple design. For a minor change it is never near 1K at my, which includes the 290 Euro EASA fee.
For example, the Golze WX solutions, can be issued with a minor change. Does these cost thousands on minor change? No
Another example, Garrecht TRX can be issued with a minor change. Does these cost thousands? No
Flarm products could be bought with a minor change, Did these cost thousands? No (no covered in CS-STAN)
Using the GNS-WAAS STC Wigglyamp worked on. Does this cost thousends? No, not even close
Trig TT-31 installation, minor change free of charge.
JP Avionics voltwage warning light. Does this cost thousands? No
The altimeter minor changes I did, did these cost thousands? No
The altimeter minor changes Wiggly amp did? I wouldn’t think it would be thousands.
You wanting a PT-6 engine on your TB-20 without excisting STC, would this be major? Yes, would this be thousands? Yes you wouldn’t come near it with paperwork for that for a few thousand.
Peter wrote:
In the EASA-land “minor mod” scenarios described here, the customer pays thousands. So to call it a “minor mod” is not exactly accurate – especially if the poster then goes on to suggest that the EASA route is much better than the FAA route (a Major mod would be needed in most of the FAA cases)!
Ok, so I showed you it doesn’t cost thousands. Why doesn’t understand EASA the term minor mod? I think it is very logical. Calling an altimer check, or as you describe anything that is on an TC or STC, so basically changing anything from orginal as a major, that wouldn’t make sense IMHO.
I can not comment on the FAA requirements, maybe @Wigglyamp can. I think they are much more similair then you pretend them to be. And if the FAA actually requires an STC for changing an altimeter, then I would suppose it would be fair to say the EASA system, on this point, is clearly more suiteable for GA.
