New radio

EASA is taking ages to get things approved. It should take about 6 weeks, but they will rarely make it that “quickly” it rather takes months.

Your probem is not likely to with the certification status of the trigg radio……… It is likely to be with the administrative mess of the so called European Air Safety Agency.

When your radio technician applies for an EASA minor change ( at three times the cost for UK CAA annex 2 aircraft ) they put the oversight out to one of the EASA national authorities. If you are lucky the job ends up on the desk of Northern European authority worker who is conversant with light aircraft, if you are unlucky it ends up on the desk of a Southern European who has never approved a minor change on anything smaller than a Boeing 747 and over applies the regulations and does this very slowly because he is on a big learning curve at your expence.

My guess is that you are the victim of a typical bit of EASA over regulation.

I would advise you to call around the gliding clubs in Germany and the UK and see if any of the DR400 glider tugs have the TY91 fitted, if they do offer them a few € and may be they will sell you the modification package that they used. That way you will bypass EASA.

Or email Trig, they my know if anyone has fitted the unit to a DR400.

I would advise you to call around the gliding clubs in Germany and the UK and see if any of the DR400 glider tugs have the TY91 fitted, if they do offer them a few € and may be they will sell you the modification package that they used. That way you will bypass EASA.

I don’t think this is feasible, because the DR300 and DR400 series aircraft share one TCDS. So an STC would cover both, DR400 and DR300 series. Just the DR200 series has own TCDS (unfortunately).

German glider clubs would tend to use the KTR2, I guess. Especially the tugs don’t need frequency changes that often and the bad operation qualities of the KTR2 aren’t that bad in comparison to the low price.

In spring I fitted a Trig in a Yak 18 T and that had no papers for this radio. You don´t need to deal with EASA for this business, rather a “developper” for avionics like the Straubing company. They will do all paper work, at a cost. The Trig has a EASA form 1 certainly so a minor change by a developper will do. Vic

Vic, that is the very nub of the problem, if you deal with a design organization you pay for them to do the whole thing, this is usually quite expensive.

For a simple Instalation you can get an avionics guy to do it for you and submit it to EASA who if you are lucky turn it around quickly, but if it lands on the wrong desk you are in for a lot of trouble.

In all my dealings with EASA I find them obstructive, expensive, lacking knowlage of the GA sector, uninterested in safety and very slow to act.

About twelve years back the late Gwyneth Dunwoody MP chairperson of the UK parlamentry select committee for transport discribed EASA as " unfit for purpose and an accident waiting to happen ". Over a decade later I still have no reason to disagree with her words.

Most of the delegates at the EASA GA conference held in Rome a few weeks back reflected some very unfavouable views of the standard of Oversight provided by EASA. It is high time we started fireing the EASA management as they clearly have not after twelve years of serouse criticism from inside the industry and very high ranking and moderate political body have failed to improve their act.

How the Instalation of a small VHF comms radio that has an ETSO in a small wooden box ( DR400 ) can run to this much trouble is simply beyond the comprihention of most right thinking people, but apparently the veiw from EASA is quite the opposite !

To be precise, EASA call them design organisations that will do any installations of certified equipment. You could do a lot of the basic or all of the work yourself but someone of the DO will have a check of correct execution and will have to provide EASA the detailed installation scheme. Vic

You could do a lot of the basic or all of the work yourself but someone of the DO will have a check of correct execution and will have to provide EASA the detailed installation scheme. Vic

This is incorrect. You can use a Design Organisation (DOA / Part 21) to do the design. This is often quite expensive for minor changes. They often charge 10 – 25x as much as EASA, as they would have to make a design, and get audited on this as well. The normal route would be to get a minor change from EASA. A Part 21 company CAN have the capability to make a design, and approve this design. Not all Part 21 companies can do avionics changes. A design organisation can not execute the minor change.

The actual installation has to be carried out by an Part 66 B2 engineer (avionics) which is rated for your aircraft. Or by a Part 145 maintenance organisation which has avionics capability and is rated for your company. If the aircraft is under a CAMO contract you typically would like to use the Part 145 and not Part 66 as you will have to stay in a controlled envoirement.
A Part 66 engineer of Part 145 maintenance organisation can do the execution, they can apply for a minor change at an EASA. They can not approve the minor change themselfs like a Part 21 DOA can.

As an addition, some Part 21 DOA’s can design major changes (STC) depending on their capabilities. A Part 66 or Part 145 can NOT design major changes (STC), they will always have to use a Part 21 DOA organisation for that. The installation of a this radio and transponder is considered a minor change.

Have your avionics engineer pushing EASA

So you say I was only lucky with Straubing Avionik accepting my efforts ? Fact is they charged me € 700.- for the installation check and testing. Minor change fee would have been € 500.- only, if it had been a Dittel, for that they had all documents at hand after numerous installations – but not in Yak, that is. Instead I preferred the Trig, for looks and ergonomics. And in this case – they had not done yet a change in a certified aircraft with this Trig – they quoted € 1200.- total for the extra documentation work, plus of course the said € 700.- testing. They got many photos and an idea of the wiring from me for their records. All approvals are to be found here:

http://www.avionik.de/en/about-us/approvals.html
We had to wait several weeks for the inspection to be done ar our airfield, 50 km from Straubing, as the plane was still grounded before full unlimited D-reg . After this it only took max. 2 weeks to get the papers from them to forward to our LBA. So we had no reason to deal with EASA. In fact, EASA are not very helpful in most cases versus the NAAs as I believe they have no formal legal power as a safety agency. It is the NAAs that press safety proposals into law !!
All costs should depend on the complexity of the job and in this thread it is only a wiring of a new radio into an existing harness, with some possible trouble regarding intercom connections. It is a very different kind of fish with avionics dealing with autopilot etc. .

Vic

So you say I was only lucky with Straubing Avionik accepting my efforts ?

Actually yes. This is outside the owner maintenance scope, so you are lucky the want to sign of for you work. I would think most shops would install this for 750-1000 Euro without any involvement from you. They might have inspected your work very closely, which I can understand. One wouldn’t be willing to sign off blind.

Typically owner assisted work takes more time, and would therefore be more expensive than what is often thought. Owner assistance is IMHO only usefull to gain knowledge, not to save money.

I think the Part 21 route is expensive. Avionik straubing is both Part 145 and Part 21 so they can do both the design under Part 21 and the installation under Part 145 or Part 66.

Now you have gone the Part 21 route you paid 1200 + 700 Euro + equipment is 1900 Euro excluding equipment. Going the minor change route AND have the equipment installed would be around 290 + 1000 Euro = 1290 Euro excluding equipment. The advantage is the Part 21 route is that it is faster. The minor change route saves you money. There is no bad way, as both end up in the same approval and installation, it’s a time versus money consideration.

When installing more complex equipment this difference will be even larger.

Another thing to consider is what the shop does when a second customer comes for the same change. Will he also pay 1200 Euro, or will the only pay 500 Euro as you paid for the design allready. Both wouldn’t be fair IMHO.

I always charge my customer with the 290 Euro EASA fee, I don’t charge for the design and creating the minor change paperwork. Sometimes I can reuse an approval and sell it multiple times for 290 Euro. Sometimes with exotic aircraft or equipment I can use / sell the approval only once. This averages so I can earn some money to do the paperwork as well AND being able to give my customers a low fixed pricing on a minor change, even in the case of exotic equipment.