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Radionavigation equipment replacement and airworthiness

Hello every EASA airworthiness and maintenance regulation experts…

I have questions about the installation of an overhaul exchanged ADF receiver KR87 on a French Reg IFR aircraft.
1/ As the replacement is just a slide in, could you please confirm it could be made and signed by a B1 mechanic?
2/ What kind of tests must be done after such a replacement (same P/N) under French/EASA radionavigation equipements regulation?
3/ Does this replacement must be declared to the authorities in relation with the french Aircraft Station Licence ( I am not sure this licence deals about receiving only devices)?

I tried to sort this out from the regulations (Part M, Part 66, Part 21….) , but not so easy for me….
Could you give me the regulations that deal about this kind of operation?

Thank you for your help.
Thomas

Last Edited by TomTom at 19 Nov 11:05
LFPE

Thomas

The KR87 should have an EASA form 1.

The installation of the KR87 is permitted under pilot-owner maintenance. See Appendix VIII of Part M. I assume therefore that any licensed engineer could do it, too.

However, if the pilot-owner slots it in, a “suitably licensed engineer” has to release the aircraft to service before it is used for IFR operations.

I don’t know exactly what this means. I suspect that a radio engineer would need to release the aircraft to service and would do a functional test. I don’t know if the rules mean that the whole aircraft is prohibited from IFR operations until the radio engineer has done this or if only the ADF is in quarantine.

Most people just slide the new unit in…

The problem is that the S/N won’t match what is in the logbooks, so the Q is whether anybody will check that. I have been told the German (D-reg) “annual IFR check” does pull everything out and collects and checks all the serial numbers, but I don’t think any other country does that.

An alternative procedure, popular with avionics bought from US Ebay, is to use a hair dryer to transfer the S/N label.

Obviously I have never heard of anybody doing any of the above. I am writing this only as a hypothetical illustration of what is technically feasible, and it would be illegal on an ICAO certified aircraft

Administrator
Shoreham EGKA, United Kingdom

Peter wrote:

I have been told the German (D-reg) “annual IFR check” does pull everything out and collects and checks all the serial numbers, but I don’t think any other country does that.

No, that is not done. However, the avionics check certificate usually lists the serial numbers of the devices.

German pilots have told me everything is extracted to read the labels.

In reality you may have to, to get the numbers, because if the equipment is old, the records are not likely to even exist.

Administrator
Shoreham EGKA, United Kingdom

Thank you for your replies.
Yes I was looking for the legal way of doing it….;)
In France we have a french specific whole avionics test every 2 years for IFR : “Tests globaux”. I don’t know if changing the unit would require a new test….
I’ll keep advised if I know more about this.
Thomas

LFPE

Why would you keep the ADF at all?

LFPT, LFPN

For legal flying of NDB approaches, where no GPS approach is published?

Europe does not have a US-style GPS substitution concession.

Obviously one flies NDB approaches using GPS guidance but that’s a different matter.

I have never seen a reg explicitly saying this but a common interpretation is that you need to carry the specified equipment. It would be interesting if that interpretation was actually unenforceable, and it would for sure explain why none of the hundreds of e.g. SR22s flying IFR around Europe with no DME/ADF has ever been busted.

Administrator
Shoreham EGKA, United Kingdom

Peter wrote:

For legal flying of NDB approaches, where no GPS approach is published?

Where do you have that in France ? :-) Except maybe Avignon?

Does TomTom regularly fly into airfields where NDB is required and no RNAV available?

Are there really that many NDB approaches around in western Europe?

LFPT, LFPN

If I was flying only in France (or actually only within any one country in Europe) I would not bother with all the hassle of doing an IR. Especially as enroute VFR in IMC cannot be detected. Especially since if only flying within France you get reasonable VFR CAS transits – necessary since much of their airspace cannot be worked out by looking on the map

There are loads of NDB approaches in e.g. Croatia or Greece. These places aren’t going to spend ~30k per runway end to get GPS approaches.

Whether you actually need the IAP on the day, on a typical nice-wx GA trip, is another matter.

But my view would be that if you file an IFR flight plan to such an airport and you aren’t carrying the required kit, your insurance is in the trash before your wheels leave the ground. Whether the loss assessor or loss adjuster is smart enough to notice is another matter It’s the same old debate as e.g. flying a homebuilt to a country which requires a permit and you haven’t got one. People who didn’t get a payout or had a reduced payout aren’t going to post about it on a forum…

Administrator
Shoreham EGKA, United Kingdom
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