So, it sounds like there is zero experience in the GA industry of this concession?
Is there some disincentive for the avionics installation business to follow this route?
I thought it was intended for importing aircraft in the EU from the US, and not for installation of equipment that was not there before.
However looking at the EASA documentation I do not find that limitation, only that “The scope is limited to second hand aircraft and installed engines, if applicable, in the following categories: [small airplanes]”
I am not sure what ‘second hand aircraft’ means in the context of, for example an aircraft that I have owned for one year since new and that I decide to install a certain STC on…is that second hand? I believe the definition is meant to apply at the time of the aircraft changing hands?
Best case it just means it cannot be used to import a new aircraft from the US with an unvalidated mod installed.
Worst case it can only be applied upon import of a used aircratf from the US into the EU.
I do not see in the application form any restriction like such worst case.
If we are in the best case, I dont see why an avionics installer would be disincentivated to follow this route…it just opens his market! Why would you think so?
Well, to paraphrase my hero
there are two types of avionics shops: the ones with the capability to generate certification, and the ones without 
The former like complicated paperwork because they can charge 4 figures for it, and often they sell the (customer financed) paperwork package on to the others later. Often, a DER 8110 package (paid for by an N-reg customer) can be used to obtain an EASA STC which can be sold on, etc. That is the environment that STCs create, especially in Europe.
The latter would prefer a simple route with minimal paperwork. Nowadays they stick to AML STC products which make life very simple. They don’t like paying the other group 1k-2k for an STC, either.
As regards aircraft import, is it true that if you import an N-reg, every mod on it has to be EASA-recertified? I believe a recent treaty allows Field Approval and STC acceptance but only at registry transfer. What about FAA Minor Alterations? Surely they need to be EASA 21J recertified? That discussion is really for the aforementioned thread though.
On the topic name, real-world examples of “basic” would be really useful.
I am not sure I know how to use the quote system in this forum…let me give it a try…
Well, to paraphrase my hero
there are two types of avionics shops: the ones with the capability to generate certification, and the ones without .The former like complicated paperwork because they can charge 4 figures for it, and often they sell the (customer financed) paperwork package on to the others later. Often, a DER 8110 package (paid for by an N-reg customer) can be used to obtain an EASA STC which can be sold on, etc. That is the environment that STCs create, especially in Europe.
I believe the market for the former is relatively small compared to potential customers (fleet size) , which has been strangling the EU retrofit market compared to the US.
The latter would prefer a simple route with minimal paperwork. Nowadays they stick to AML STC products which make life very simple. They don’t like paying the other group 1k-2k for an STC, either.
AML STC’s and even minor mods were mostly forbidden in EUrope until a few years ago. This really opened retrofit installs of AML-supported and validated STC’s (ie GTN750 (EASA AML) vs GNS530 (originally non-EASA AML, well known case here)…)
As regards aircraft import, is it true that if you import an N-reg, every mod on it has to be EASA-recertified?
No
I believe a recent treaty allows Field Approval and STC acceptance but only at registry transfer. What about FAA Minor Alterations?
All of the above except STC’s with installs supported by an FAA form 337 (which is usually the case) and except mods affecting “critical” parts (rarely the case)
Surely they need to be EASA 21J recertified?
Only for STC’s inst’d with 337’s
That discussion is really for the aforementioned thread though. On the topic name, real-world examples of “basic” would be really useful.
In practice almost eveything that does not mess up with noise certification, TCDS-specified life-limited parts, or TCDS-specified mandatory maintenance/OH intervals should be good.
Also, where FAA part-23 requirements would differ from EASA CS-23, with published differences listed as Significant Standard Differences ( I am aware of such listing for part-25 large aircraft, but not for part-23 small aircraft) an analysis would have to be performed. This analysis is the tedious (typically DER-) work: identifying which CS’s are affected and then justifying for each one why this validation is no issue.
Also, if the specific subject has been identified as a Validation Item (VI) by the auhorities then it is non-basic. Again there is a published list of VI’s for large aircraft but I am not aware of such for small aircraft.
I can give you examples on large aircraft but not on small ones. My experience would be with changes involving cabin management avionics, in flight entertainment video and wifi equipment, cabin layout incl lavatory and galley removal and installation, all of them basic.
For small aircraft I dont see why any non-integrated (ie non-G-1000) single avionics install would be a problem. With dual installs (ie GTN750+GTN650) the Agency has always been more scheptical, but I still do not see why they would be non-basic. I will try to confirm if such SSD and VI lists exist for small aircraft.
Also on topic: this should open up the market for install of multiple FAA-approved mods (not only avionics) that used to be non-economical for the reasons you stated above. IN summary: only the engineering part of those former avionics shop may suffer, but overall the market should benefit.
Again there are two kinds of business minds: those that think that opening up the market will ultimately benefit them, and those that would like to keep a market, if minimal, all to themselves, even if that policy itself damages the market overall.
One famous case in aviation was GE vs RR: GE would allow any third-party to access their maintenance data and overhaul their jet engines, whereas RR used to be very jealous and careful rarely allowing any third-party to do maintenance on their engines…Guess who owned the market until RR changed their policy…
Antonio
Antonio wrote:
I will try to confirm if such SSD and VI lists exist for small aircraft.
I now have confirmation from EASA: they do not exist for small aircraft, automatically rendering most STC’s as BASIC.
Antonio
This is very interesting and many thanks for your posts @Antonio
Does this finally open up a dual GNS installation? It would be ironic if it did, after that product has reached the end of its practical life for new installs…
I find it amazing that there is practically no knowledge of this process on the ground. As you say, there are winners and there are losers.
Picking up your last-1 post, where you replied to my reference to Minor Alterations, I had some questions on a bit of a tangent and have started a new thread here.
Coming back to this: when I found the original FAA STC, where exactly can I then find out whether it’s considered basic or not.
Basic seems to be anything that’s not non-basic, but where can I compare a specific STC to a set of criteria. Maybe it’s just me being to dumb to find it… :)
Like I said earlier, what we need is some examples where somebody used this route.
I was too lazy to search for 14 CFR 21.101 (b) and EASA Part 21A.101 (b). No time for paperchase.
Example: would a baffle kit that cools certain cylinders a little better be considered “basic” ? I would assume so, right ?
Doesn’t affect performance, noise, flight safety,…
?
