Usually that is the rule, but AC43 Appendix A (N-reg) doesn't appear to actually say that.
Under EASA it is probably even more likely to be the case, but they now accept the AFMS for a GPS to fly GPS/RNAV (not LPV) approaches as a Minor mod.
Looking at Part-21 an AFMS is a major…
But then again looking at CS everything needs to be documented…. So whats the way to go?
I would say that we need an AFMS for every modification (avionic or equipment not repair ie sheet metall)
So a new AFM Supplement may be minor. (There are soooo many variants so we need to look at your particular case)
/Sam
I would say that we need an AFMS for every modification (avionic or equipment not repair ie sheet metall)
That means an AFMS for every switch for every cabin light, etc.
Of course the aircraft should come with a “user manual” describing all the stuff in the cabin, but an “AFMS” has a strict legal meaning and the regulatory people go berserk when anybody proposes anything that might need a new AFMS or a change to an existing one.
For example changing or expanding the sources for the autopilot (which could be any change to the NAV radio config) needs an AFMS and changing an autopilot AFMS is bordering on the impossible. Nothing is going to make EASA or FAA go more wild than changing anything to do with an autopilot.
In some countries they have a document that state what manuals are applicable for this particular aircraft.
So if you have a Garmin GMA340 audiopanel this document shall state this by refering to the GMA340 pilots guide with p/n and revision.
However looking at
AEROPLANE FLIGHT MANUAL
CS 2X.1581 General
(2) Other information that is necessary for safe operation because of design, operating or handling characteristics
There is no good EASA guidance regarding airplance flight manual supplements but FAA AC25.1581-1 cover this a little bit.
h. Appendices and Supplements. Additions to the AFM that may or may not supersede existing AFM material.
(1) Appendix. An addition to the AFM to cover the installation of optional equipment or specific operations (engine inoperative ferry, reduced power or thrust takeoff, configuration deviation list (CDL), etc.).
(2) Supplement. Information that supersedes or is in addition to the basic AFM resulting from the issuance of a supplemental type certificate (STC), or from approved changes to AFM limitations, procedures, or performance information without an STC.
Next step is to study each word and meaning in detail. For example.. a COM radio installatoin is not optional, it’s required equipment.
An Appendix or a Supplement… the important thig is to make sure that the crew will somehow be aware of what has been installed, how to operate it and were to find additional information (ie an AFMS that refers to a user manual for that particular equipment).
The whole question of Major vs Minor Alteration seems quite confused to me. If you read FAR Part 43, Appendix A (Link) it would be difficult to describe an OAT/CHT/EGT unit or even a Fuel Flow computer as a Major Alteration. In the discussions on MooneySpace it seems (in the US at least) most of these things are considered Minor and do not require a form 337, but there are certain IAs who consider otherwise… In my case the JPI FS-450 includes an AFMS but the EI EAC-1 does not. I called Electronics International and they said: “Because of the nature of digital instruments and the era that the EAC-1 was certified, it does not have or require an AFM. Please let me know if you need any additional assistance”…..
The next issue is the FAA form 8130-3….This is not in general use in the US…it was originally devised as a form to go with exported parts to confirm compliance with FAA airworthiness for the benfit of foreign CAAs….it is not required by the FARs….and yet some IAs over here seem to treat it as mandatory…In fact the IA does need to be sure that the part is genuine and airworthy, and the 8130-3 achieves this, but equally a Certificate of Conformance should also suffice…
I agree 200%, Anthony.
The only thing which might possibly move an EDM to a Major mod is the drilling of the holes in the exhaust system.
But even the UK CAA did a generic approval for the EDM700 because they got fed up with approving so many requests. That was about 10 years ago. That will be grandfathered to all of EASA-land.
Nobody actually requires an 8130-3. It is a sufficient but not necessary document for the part traceability requirement.
The 8130-4 (an Export CofA) was required for what the CAA used to call Class 1 components (engines and props) if they were done by a US non-EASA145 company. So you paid $300 to a DAR to sign that form. I last heard that the FAA stopped the Export CofA system but I am not up to date on it.
