If a DAH AFM offered and lists e.g. a KMA26 as available equipment (in the equipment list) and hence this equipment was approved for the type overall, but an individual aircraft doesn’t have a KMA26 (e.g. anymore), can one be installed without it being a modification?
The answer is generally Yes but there is dissent within the industry. As with the general topic of this thread, you may have difficulty finding an avionics business willing to do this.
The work still has to be documented, and AFMSs etc generated (or purchased!) as appropriate.
So eg in 1970 Cessna offered the C172 without ADF. In 2021 a 1970 C172 doesn‘t have an ADF. Can an ADF be installed without mod approval based on the DAH originally offering the same combination in 1970?
More to the point, if you installed an ADF (or replaced a part off the books) who on earth would know?
I had a really comprehensive pre-buy where they checked out all of the important stuff, corrosion, engine, prop, life limited items. Unless somebody pays for 40-100 hours of work trawling through every item I doubt they would spot an “extra” ADF. They definitely won’t be able to spot a good second hand part from a “chop shop”
What all these regulations do is make things more dangerous as it forces maintenance prices up, stops “sensible” repairs (like changing an Electrolytic capacitor) and often prevents good second hand parts being used.
You are absolutely right, however, I want to get to the root of this and find out how it is correctly done according to the regulations, leaving aside if it is sensible or not.
Thanks!
Wow a real bunch of information here. So as far as I’ve come now, you can actually pick an autopilot, say, even from ebay dot com (to stay with the example from here ) – but better from an EASA-reg aircraft – and put it in your plane, more or less without paperwork. The only thing you really need is to find the right person who’s willing to sign a Release to Service for this.
So let’s see, goal would be to have an S-tec 55 (or similar) installed preferably for less than 10k. Achievable?
Hi Udo,
Not life-limited, nor part of the primary structure, nor part of the flight controls
Autopilot → Flight Controls?
Could be an issue.
If the equipment is FAA STCd for your plane, ask the OEM for the STC and validate it for your plane with EASA (200€).
I’d always get the paperwork out of the way first before buying hardware.
I wonder if there has ever been a ruling on whether autopilot parts are “critical”. Let me ask around…
UPDATE:
I posted it on an obscure EASA forum and got this reply:
Q: Has the phrase “Not life-limited, nor part of the primary structure, nor part of the flight controls” been clarified as to exact scope?
Hermann Spring • 2 minutes ago
If you are technical competent, you know what to do.
Technical competent, means, that you know the design and you are able to judge the failure modes, as well as the condition.
Missing competence calls for delegation of the responsibility and the judgment to a regulation.
Personal I propose NEVER to regulate such details, th ends in hughe dicuments, which are not assiting the technicians, but the lawyers if something happens.
Study the technical information instead of.
Use all effort, that it never happened
The respondent has a title of “Head of Training – Motorfluggruppe Pilatus”, so not actually EASA-internal but probably well connected.
I got a further reply:
1. Life-limited means that it has an airworthiness limitation (e.g. hours, calendar or cycles) as set per approved maintenance data (e.g. maintenance manual) or ADs. This would be the case for most engine components, for example.
2. Part of the primary structure means a load-bearing element, in the sense that a removed or damaged component would decrease the “strength”, hence safety, of the aircraft. This typically means any part of the structure of the airframe, including the skin.
3. Flight controls mean the collection of mechanical parts, such as rods, cables, pulleys, and sometimes chains to transmit the forces of the flight deck controls to the control surfaces. The controls and the surfaces, being primary (elevator, ailerons, rudder) or secondary (flaps, spoilers, trim tabs) are also included here.
which to me suggests that servos are not a part of the flight controls – because they don’t transmit the forces of the flight deck controls. The respondent (who is not in EASA; EASA people almost never participate on forums) also pointed to this 2013 document local copy which might clarify it. It seems to be one of the earliest documents on this topic! This PDF has been posted previously and has been “around” a lot but I don’t think it is helpful in clarifying this point.
Peter wrote:
Life-limited means that it has an airworthiness limitation (e.g. hours, calendar or cycles) as set per approved maintenance data (e.g. maintenance manual) or ADs. This would be the case for most engine components, for example.
I don’t think so…
+1 I don’t think so.
A rough guesstimate on the accuracy of information I have received from
- club presidents
- pilots
- owner pilots
- maintenance organisations/personnel
- ato nominated persons
(that claim to be in the know) is
50% was completely wrong,35% was partially wrong and useless,
10% was partially wrong but at least pointed me in the right direction and
5% turned out to be accurate.
Regarding EASA, you’d think they could set up a team to answer questions from the public (email ticket system or some other direct channel). Instead, inquiries that include “my competent authority is telling me to ask EASA” get answered with “please consult your competent authority” ;)
