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?
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.
Does EASA publish guidance on how to make a decision in the field as to whether a proposed mod is Major or Minor?
It’s a Q I have asked and apparently there isn’t any guidance i.e. it is EASA who is the final arbiter and every mod must be referred to it for a judgement.
One EASA Part 21 (a design authority) shop owner told me they get some latitude to make that decision in-house.
I think that is bad because if you lay down rules you have a responsibility to publish them in a form which the average person (one that is required to apply them) is able to understand.
In practice the decision is often made in the field using common sense and if necessary the work is done “off the books”.
In the FAA system, there is clear guidance which covers most non-electronics areas, in Part 43 Appendix A (see e.g. “Certification” notes here). An old copy is here – see page 20+. The system is far from perfect and there are various bits elsewhere which cover the other stuff e.g. autopilot installations and subsequent interconnections. But it is clear enough for most jobs and the issue is in practice limited mostly by adult illiteracy issues because many people working on aircraft can’t read these docs.
Apply for a minor change can be done yourself, however you should be willing to spend time to find out the process and what they want to see. I sometimes do minor changes for other companies as well as they get stuck in the process and give up.
highflyer,
minor change approval is a fact of life and needs to be done. Otherwise the costs are going to be much higher if you are found illegal at a ramp check or at your next avionic check. Just get it done and then forget about it.
In Europe, you have exactly 2 choices. Either do what EASA tells you or stop flying.
You could do the minor change paper work all by your self and save lot’s of money. As mentioned earlier most of your money will end up as VAT or someones income tax.
/Sam
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 ?
A minor change approval is just required by law. They where once free of charge, nowadays EASA charges around 300 Euro for the approval process to the applicant. The applicant have to create a “design” and prove that it meets the requirements. (For example, installation of a KX-155 to replace a KX-175 would be a no no, as this KX-155 does not meet the 8.33 kHz separation and is a replacement for a 25 kHz radio. Therefore doesn’t comply, and wouldn’t be approved). Make this data cost time. 500 Euro including VAT (and the 300 EASA fee) Most of it would be VAT and EASA fee.
You should contact Jesse (on this forum). He does seem to have the LBA approval and his rates are definitely lower than those of most german Prüfers (who tend to charge “by the unit”…)
For D-reg the avionics checker needs to have LBA approval. So the answer is more or less no.
