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Homebuilt panel (also Dynon EFIS-D10A)

Peter wrote:

My understanding of the current (or previous) treaty was that if you got a DER 8110 design package, you could use that to apply for an EASA STC.

It’s one thing to be allowed to install it, another thing to be allowed to use it as primary attitude indicator. I don’t think a DER could help them with the second bit, that’s IMHO where FAA stepped in.

And I think Dynon may have used the DER route to get their STC.

AIUI it was EAA who did it and it’s their STC. D10A was simply the first product to go, there will be more and from other manufacturers as well.

One possibility is that their software was not designed IAW the requirements for a TSOd EFIS box.

It does meet ASTM 3153-15, but none of the traditional TSO/ DO. And reportedly Dynon played a significant role in development of that ASTM standard. I guess it’s not that cheap, especially if they don’t intend to stop with attitude indicators.

Peter wrote:

My understanding of the current (or previous) treaty was that if you got a DER 8110 design package, you could use that to apply for an EASA STC.

There are two different issues.

- The product certicification, normaly FAA Form 8130-3 or EASA Form one for new products other then standard parts

- The product into aircraft certification, for example STC.

Items that are certified only with a minor change, such as many custom made solution, or some small aviation products for non esstial stuff are approved by an EASA minor change. One item one could think of is a car stereo, or a marine radio, I-Pad etc. Then there is only a minor change approval, and no EASA Form 1 with the products (and these products could never get an EASA Form 1 either). These kind of products are not covered under the bilateral agreement, as they don’t have an EASA Form 1.

I guess that this would be the same with the Dynon box, it is produced without paperwork, and is clearly not a standard part. Lacking paperwork it seems that the part itself, doesn’t fall under the bilateral agreement.

From the bilater agreement:

This is basically as wigglyamp said.

I did found the following remarkable the first time I did read this document a long time ago.

An EASA company with an FAA validation can never issue an FAA Form 8130-3, and an FAA company with EASA validation can never issue an EASA Form 1. They always will have to issue their own form.

Yet it is possible for example when repairing a component, that a used (overhauled) part is used which comes with an FAA 8130-3, then final releas by an EASA company becomes a Form 1 stating the it is only acceptable for N (Reg), as such, this EASA Form 1 is not a dual release, as it is not applicable for EASA aircraft.
This is important, as, a Form 1 always need to be inspected for this before accepting parts (important when buying parts). Else it would be possible that you buy an part with EASA Form 1 which can not be installed on an EASA aircraft, even while the P/N is acceptable for that aircraft.

The other way is the same.

JP-Avionics
EHMZ

Reference for traceability of standard parts is in EASA MA501c and AMC501c(3).

Avionics geek.
Somewhere remote in Devon, UK.

only require a certificate of conformity from the original manufacturer (not from a stockist)

Is there a reference for this? (not from a stockist)

One of the purposes of organisational approvals (ISO9000 etc) for distributors is to avoid this requirement.

Administrator
Shoreham EGKA, United Kingdom

OK- wasn’t totally clear. Standard parts (nuts, bolts etc produced to a recognised specification in the public domain such as MS, NAS etc) only require a certificate of conformity from the original manufacturer (not from a stockist). All other parts require a Form 1 or 8130-3.

Avionics geek.
Somewhere remote in Devon, UK.

Under our FAA repair station approval which is on the back of our EASA part 145, we can only fit parts onto N reg aircraft that come with an 8130-3 or a new EASA Form 1

Is that literally true?

For every last nut and bolt and washer?

That would be an unusually restrictive way of working.

One should have evidence of traceability for parts fitted to a certified aircraft, and while an 8130-3 etc is sufficient for that, is it necessary?

Administrator
Shoreham EGKA, United Kingdom

“They (Dynon) don’t have PMA nor DOA/POA equivalent as far as I am aware, so they can’t issue a Form 8130-3 with the unit?”

Under our FAA repair station approval which is on the back of our EASA part 145, we can only fit parts onto N reg aircraft that come with an 8130-3 or a new EASA Form 1. Therefore we couldn’t install a Dynon on a N-reg type covered by the STC. What parts release is required when installing new items to certified aircraft in the U.S.?

Avionics geek.
Somewhere remote in Devon, UK.

My understanding of the current (or previous) treaty was that if you got a DER 8110 design package, you could use that to apply for an EASA STC.

The 8110 package can be used standalone on an N-reg, to support a 337 (Major Alteration). That’s a Field Approval. This is a popular route for European N-reg owners, but can add a lot of cost.

And I think Dynon may have used the DER route to get their STC.

But who knows?

There must be a reason why they didn’t go for a TSO. It would be very interesting to know why. They can’t be short of money. Certification of “simple” avionics boxes is expensive only if you don’t know how to work the system.

One possibility is that their software was not designed IAW the requirements for a TSOd EFIS box. Honeywell had to abandon the original KSN770 design because of that, I was told by one of their reps. IMHO, having seen so many uncertified EFIS products, from 1-man companies, exhibited at EDNY over the years, they are developed by buying-in an AHRS box which outputs the data via some serial stream, and you buy a processor board, a big LCD, and use standard graphics libraries to implement things like round gauges, bar graphs, tapes, etc. I got someone to write some stuff in Borland Delphi c. 1996 and he did all of this, way back then. The learning curve is not a problem once you are “into” it. That panel above would have been a great fun project, taking 1-2 man-years.

Administrator
Shoreham EGKA, United Kingdom

wigglyamp wrote:

I wonder if they’ll try and get EASA validation under the recently approved bi-lateral? I can see loads of resistance from this side of the pond to having uncertified primary instruments being installed.

Isn’t the bilateral only valid for items which are produced with EASA Form 1 / FAA Form 8130-3? For parts acceptance, this was the issue in under the old bilateral.

They (Dynon) don’t have PMA nor DOA/POA equivalent as far as I am aware, so they can’t issue a Form 8130-3 with the unit?

JP-Avionics
EHMZ

I wonder if they’ll try and get EASA validation under the recently approved bi-lateral? I can see loads of resistance from this side of the pond to having uncertified primary instruments being installed.

Avionics geek.
Somewhere remote in Devon, UK.
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