If you how exactly where to push, and bookworm does 
Indeed – and it’s an impressive achievement. I wouldn’t know where to start.
@bookworm – Any chance of sharing the letter from the CAA to the maintainers, redacted as necessary? I’m sure it would prove useful to other owners.
Ah yes, new vs overhauled. I enjoyed presenting this at GA COM:
The ship wherein Theseus and the youth of Athens returned from Crete had thirty oars, and was preserved by the Athenians down even to the time of Demetrius Phalereus, for they took away the old planks as they decayed, putting in new and stronger timber in their place, in so much that this ship became a standing example among the philosophers, for the logical question of things that grow; one side holding that the ship remained the same, and the other contending that it was not the same.
—Plutarch, Theseus
It would be absurd to permit an overhauled unit, containing a plethora of good components and a few bad ones, to be reinstalled only on the condition that the good components, as well as the bad components, had been replaced by new components.
The text of the letter was as follows, but unfortunately it does leave the new vs used issue open. To the best of my knowledge, the “generally applicable process” has never been developed and docimented.
Does that mean that if buy, say, a GTN with FAA form (kind of confirmation it is in working condition) on ebay, I can install it into an EASA aircraft without form 1?
arj1 wrote:
Does that mean that if buy, say, a GTN with FAA form (kind of confirmation it is in working condition) on ebay, I can install it into an EASA aircraft without form 1?
Yes, that’s my understanding. It shouldn’t matter if is is an audio panel (as it is in my case) or a GTN.
Of course, if the GTN is new, then the FAA 8130-3 is equivalent to an EASA form 1 anyway.
This is why this concession is basically dynamite.
No wonder almost anybody in the industry runs away from it at 140kt
I’ve used this provision for new parts such as Guardian iPad mounts and also some avionics where I knew the history of the component.
The person certifying the installation also has to take into account M.A.504 in order to ensure parts recovered from accident/incident aircraft don’t enter the supply chain, so it’s not just a case of accepting a part at face value:
This is an interesting add-on. However, there is a general rule in rulemaking that the party who seeks the benefit of the restriction (in this case, the national CAA) has to give the benefit of the doubt of any ambiguity to the target.
So, taking the above
1) if there is no service life limit, there is no issue
2) if there is no evidence of AD noncompliance, there is no issue
3) if there is an STC or some other certification route, there is no issue
4) if the thing works, or worked when removed from the previous plane, there is no issue
5) if you are unaware of it having been in a crash, there is no issue
This means that if you buy a used item and some paperwork with it says “working when removed”, you should be good to go. You are not required to assume that the used GNS430 is a chinese fake
And if the regulation does not state that a used item is excluded, then it is included
This is big. Really big. It means you can transplant all sorts of parts removed from a parted-out plane, straight into yours. This has been an area fraught with difficulties. It drives a bus through this, notwithstanding that SR22 seats (mentioned there) probably don’t qualify because they are likely a “critical” part.
Reading the guidance above the only issue is involvement of the aircraft in an accident that is “likely to affect the serviceability” of the particular part being used. Since most accidents don’t affect most parts, this is not as written a major issue.
Obviously out in the real world there are companies and facilities that part out and sell aircraft as their primary business, and acres of used airframe parts for sale on e.g. Barnstormers. Many or most of them have been removed from crashed aircraft, most have no damage as a result, and if damaged (like the ground looped wing I have hanging on my hangar wall) many can be repaired before reuse.
We recently had a very interesting Zoom discussion on this topic, and specifically this ‘dynamite’ concession posted by @alan_south which arrived some years ago without anyone noticing.
It really seems to be real… It literally means that if say your KX165A radio packs up, you can buy one on US Ebay, no paperwork, and get it plugged in. Or get the said radio installed as a new installation.
This is serious convergence with the N-reg scene.
The main challenge is revenue/political; specifically maintenance industry acceptance.
And as wigglyamp says above this concession is possibly not available to owners who are using a 145 company, working under its 145 authority, to maintain their planes.
