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Minor change approval

I have installed a new KX165 A which is very easy to exchange since it has the same rack as the KX155A. No wiring has to be done. The radio works perfect and the avionic shop has confirmed that everything is ok. But he can not certify the aircraft for IFR since I do not have a minor change approval which I have to buy from a well known shop in southern Germany for 500 Euro. Isn`t it stupid ? What can I do ? Flying IFR in a VFR certified plane ? Any recommendations ? Does G- Register help ?

Berlin, Germany

That is really stupid.

On a G-reg it would just be plugged in and forgotten. Nobody would even notice the change. Can you go to another company for the IFR certificate and just turn up with it? Or do the German firms pull out all avionics and check the serial numbers?

Administrator
Shoreham EGKA, United Kingdom

Which type of aircraft are you talking about and where is the plane registered?

Early last year I had the KX155 exchanged against a KX165A in my plane by exactly that well known company in Southern Germany. They just plugged it in without further comment and continued with the annual avionics check. I would recommend to call the shop in Straubing directly and to talk to Heinz Eckert oder Martin Scheifl to ask for their opinion.

RXH
EDML - Landshut, Munich / Bavaria

Well, the guy is right of course. During the avionics check, the previous avionics check will be looked at and if there are differences in devices, questions will be asked. There should be no problem finding somebody that will “accidentally” overlook the change. That well known company in Bavaria is not going to be the one.

On a G-reg it would just be plugged in and forgotten. Nobody would even notice the change.

Equally wrong as doing it under D-reg. A G-reg needs the same minor change approval. The only difference is that it will be noticed in Germany on the next avionics check and in a G-reg at some point in the future when you expect it least. Like when you just bought the aircraft and find out that half of the avionics were improperly installed.

Last Edited by achimha at 02 Apr 15:06

Like when you just bought the aircraft and find out that half of the avionics were improperly installed.

How would that happen on a G-reg?

Radio changes like this would be a Minor mod and would just be a logbook entry, but even if you suspect the radio was changed (and why should you?) there is no way of knowing when it was changed, so there is no way of knowing how far back in the logbooks the entry would be, so there is no way to check it because no plane has a perfect paper record.

Also most avionics work is done as logbook inserts, given to the customer, who can choose whether to glue it into the airframe logbook, or not. I know a guy who had his autopilot servos changed about 10-20 times, with all work done by a “top shop” under the autopilot mfg’s extended warranty, yet his plane was sold with no record of any problems…

If you buy a plane with a KX165A then you have the very best radio possible, and nobody is going to question it.

I am just being practical about this. The German IFR Certificate system is a perfect extraction system for €uros.

Administrator
Shoreham EGKA, United Kingdom

Radio changes like this would be a Minor mod and would just be a logbook entry,

That is not according to the rules for EASA registrations. You have to get a minor mod approval from EASA otherwise you’re breaking the rules. The UK does — because it is required to — perform random inspections on aircraft and then your 20 years of unapproved mods will come back like a boomerang.

Of course it’s stupid but that’s the current law.

I know a guy who had his autopilot servos changed about 10-20 times, with all work done by a “top shop” under the autopilot mfg’s extended warranty, yet his plane was sold with no record of any problems…

That is no issue because the same servo type will be in the airplane before and after. Nobody can object to that and there is no requirement to keep records of the original serial number.

Last Edited by achimha at 02 Apr 17:21

The UK does — because it is required to — perform random inspections on aircraft

As somebody who lives in the UK I can tell you that the reality is very different

Nobody can object to that and there is no requirement to keep records of the original serial number.

There is – if you change an item you are required to make a logbook entry, saying XYZ P/N xxxxx S/N yyyy removed P/N zzzzz S/N bbbbb installed, etc.

Administrator
Shoreham EGKA, United Kingdom

As somebody who lives in the UK I can tell you that the reality is very different

The UK never struck me as a country that would ignore EU law. EU directive 2042/2003 introduced ACAM (Aircraft Continuous Airworthiness Monitoring) which requires each CAA to perform a certain number of random aircraft inspections. These are very thorough.

There is – if you change an item you are required to make a logbook entry, saying XYZ P/N xxxxx S/N yyyy removed P/N zzzzz S/N bbbbb installed, etc.

What I tried to say is that there is no requirement to keep the serial number of the original part. Therefore it is not possible to say that a part was replaced. These parts can be bought for less money without EASA Form 1

Ok, let me give some answers:
Yes Peter, the avionics pull out the radio and check the reg. number. My avionic man recommended to call the shop in Bavaria.
The plane is a Cessna 182 with D-registration. And I did made a call to the avionics shop in southern Germany. Mr. H.E. told me on the phone that his company charge 500 Euro incl. VAT plus 1 hour for installation and paper work.
I do not want to follow these stupid regulations. The plane fulfils all demands for an IFR registration since the year of construction.
I am illegal from now on, that`s quite enough .

Berlin, Germany

The fact of the matter is that EASA know that these regulations and a lot of other stuff within the part M regulations are totaly inapropriate to small private aircraft, the history of EASA is that it was set up by the EU largely by consultants who did not have the first idea of how to regulate aviation and probably did not even know GA existed.

The EU put the recommendations of these consultants into law with catastrophic results and that is what both the EASA and the GA industry is stuck with until the laws can be changed. There has been much talk of “part M light” and this will arrive within two years, it is as much in the interest of EASA as it is the GA industry to get this done as a lot of people in EASA will find themselfs with nothing to regulate and out of a job if the regulatory burden is not lifted.

The sooner we see part M light the better and we need to do all that we can to encourage its progress so as to get most of the current stupidity stopped.

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