The bottom line is that KX155A to KX165A is a change the requires a minor change and that has always been the case, what is now different is the amount of paperwork that EASA generates for such a minor change.
The problem is that the people running the regulatory system are so far removed from any sort of reality that what makes perfect sense from an office in Cologne is utter nonsense when applied to practical reality.
The UK CAA is slowly getting rid of its Technical staff, I have seen one department get the chop right in the middle of doing a job for us…….. Result much delay. The result of this change in oversight is that aircraft maintenance is less and less being overseen by people with a practical knowlage of the industry but by professional administrators who only know how to shuffle paper and how to charge a lot of money for adding less than nothing to flight safety.
If you install a GPS with a minor mod, don’t forget to disable SBAS. So the conclusion basically is, it’s always a major change.
OK – I have seen that before. But that is for avionics, and for specified categories of avionics. It’s not a general doc like the FAA do.
Also I think most of it is a job creation sham for EASA 21 companies. For example why is a dual GPS install, or a new transponder antenna install, a Major mod?