Yes sorry you are correct..( brain fade).LAA MOD2 is the intial proposal..then specific MOD 3…MOD7 or whatever specific MOD you are doing.
I lost the will to live over my Autopilot MOD taking so long although others I know have taken longer than 8months!…..
alanr wrote:
A MOD3 is only the initial proposal from which the LAA target is to give you a reply within one month. Once the MOD3’s are approved you will then have to submit the specific MOD, chapter and verse in every minute detail, depending on what it is you are installing/changing….Expect then another few months to get the specific MOD application ok’d, this will be dependant on how many questions they ask or queries that arise.
Actually I submitted MOD 2 forms for the initial agreement on what was proposed and the MOD 3 is the whole package. I do hope it doesn’t take 8 months as that’s even longer than an EASA STC administered and investigated from Cologne!
A MOD3 is only the initial proposal from which the LAA target is to give you a reply within one month. Once the MOD3’s are approved you will then have to submit the specific MOD, chapter and verse in every minute detail, depending on what it is you are installing/changing….Expect then another few months to get the specific MOD application ok’d, this will be dependant on how many questions they ask or queries that arise.
It took me 8months from start to finish to get a full Autopilot MOD approval.
Did they give a reason for the refusal, @wigglyamp?
To me this like so many aspects of life, where people will try to safeguard their jobs and positions, right up to the point where the wheels are coming off the whole operation.
I am also told there are conflicts within the system e.g. between the grass roots flyers and those who have more money available. Probably this maps onto the same communities as the 450kg v. 600kg UL debate.
jwoolard wrote:
That’s fair, there’s probably a gap in the market there. In theory, anybody (well, any organisation) can go out and get A8-26 approval if they can persuade the CAA they’re up to the job. The LAA and BMAA already have some overlap, and the BGA do a similar job.
I asked the LAA if we could use our CAA A8-21 approval (same extensive coverage as our EASA 21J) to address mods on LAA aircraft (thinking of my RV12 in particular) and was politely told that it wouldn’t be possible. I’m now writing LAA MOD 3 applications for various changes such as the Garmin G3X, undercarriage fairings etc. I haven’t seen any problems in their approach and the level of data they require, but allowing others with suitable authorisations to directly approve mods would be beneficial and help off-load some of the work from the small engineering team at the LAA.
It’s no surprise that the LAA “Inspectors” vary, there are about 350, and coded to what they can do i.e. Metal airframe, Composites, Engines some with knowledge of specific types, Final Inspection before first flight, Night/IFR and it goes on. Some are licenced engineers and charge commercial rates others do it for nothing or petrol money. It’s the builder’s responsibility to find and appoint an Inspector and ensure they have the appropriate codes. It could sound shambolic but works remarkably well.
If anyone is interested in building, and not sure, the LAA run an excellent (Warning – I am one of the instructors) ‘Working in Aluminium’ course. It is a full day where you will build a toolbox, you will learn enough to start building an RV. We’ve had some, who successfully completed the toolbox, thanked us, and said it’s not for them, saving them a lot of money buying the tools and kit.
That’s fair, there’s probably a gap in the market there. In theory, anybody (well, any organisation) can go out and get A8-26 approval if they can persuade the CAA they’re up to the job. The LAA and BMAA already have some overlap, and the BGA do a similar job.
You could probably persuade the CAA that an oversight regime which used any EASA or FAA licensed engineer to sign off maintenance, and any DER or equivalent to produce mod packages, was sufficient. I suspect you’d still need an inspector system for new builds. I think you’d have very few takers as DERs have little experience with the homebuilt stuff, and a lot of the kit used explicitly doesn’t meet the requirements of the certified equipment.
Peter wrote:
Why does the LAA retain the examination+decision power even when they are so overloaded, and when there are well-established routes for mod approval which are good enough even for the certified route?
I suspect their answer is something along the lines of “but the certified DERs don’t know the LAA requirements”, which is true – but there’s no reason there couldn’t be a group of people who are trained/trusted to know the LAA setup. Maybe they could be called “LAA inspectors”…
Actually, I agree with you – I think there is a place for a more trusted subset of inspectors to approve minor mods. The LAA would need to get the CAA to agree to it though.
For your relatively trivial mod, there is absolutely no reason you need a DER or anyone else to generate the data, and nobody at the LAA is going to spend days looking at it – a similarly simple one of ours was looked at and [in principle, as we’re still building] approved in a few weeks. My guess is it took less than an hour of someone’s time.
My earlier Q about using a DER/EASA21 to generate design data was about shorting the LAA queue.
Surely, in any other technical sphere, generating the data in the right format should help and could even enable approval immediately if it is done by a sufficient “authority”. The FAA accepts DER data directly without examination, for a Major Alteration (non STC, at least), and this is one method to sidestep a Field Approval especially from Europe. If the FAA accepts such a package, why would the LAA not accept it? Even the EASA process is not too bad if you throw enough money at a 21 company. (A DER is not cheap either – the design package for say an alternator might be 1k-2k depending on your contacts).
Why does the LAA retain the examination+decision power even when they are so overloaded, and when there are well established routes for mod approval which are good enough even for the certified route?
While homebuilts have traditionally offered a route to a lower cost of ownership, there are very evidently plenty of LAA owners who are paying as much or more than people pay in the certified world. For example, any good RV goes for the price of a 2002 TB20GT and, from one indication I have seen, a built and well equipped RV10 would cost almost 2x as much. Look at the €150k+ Rotax machines at AERO EDNY every year. Nobody can call that a “low cost route to flying” anymore (well you do get some more kt per fuel flow, so the pure DOC is better, but the purchase+build cost trumps that, over the average remaining ownership time) and there should be a better certification path for those who can pay what are such relatively trivial amounts.
One has to ask why the LAA is so successful. Obviously, a large part of it is because it offers a way forward to those who cannot get the Class 2 medical. Most of the NPPL success is due to this (around 2/3 in its first few years), after all. The LAA is going to get really busy after April 2018 if the mad Brussells-driven killing-off of the ability to fly a certified aircraft on the NPPL in UK airspace is enforced (the CAA would really be negligent if they implement that, in the face of Brexit) as that will drive many hundreds of UK pilots to looking for a homebuilt. Of course the prices of ready built homebuilts of reasonable quality and capability will go up. Most of these pilots don’t read forums and aren’t yet aware… And most of them won’t be interested in building anything, with the vast number of hours involved.
I wonder if @Genghis_the_Engineer is still out there? He had some involvement in this, IIRC, though it may have been on the UL scene.
Peter wrote:
e.g. you could install a bigger alternator (or a second alternator) even though it was never approved for that engine. I wonder how much such an approval would take?
That sounds like a pretty simple mod in LAA land – especially if the new alternator is designed for aviation use. Standard disclaimers apply (I’m not the LAA, or an inspector), but I expect they would want to see:
You should also expect to have the new installation signed off by an LAA inspector and then to fly a short test sortie.
Barely 30 minutes of paperwork if you have circuit diagrammes ready for your existing setup.
Sadly the LAA are victims of their own success, and you may have to wait a while for approval.
It is up to the applicant to provide sufficient data such that the LAA’s in house engineers are satisfied, much the same as if you’d designed a whole new aeroplane.
