This is an interesting development 
I see no issue with selling an EASA paperwork package by mail order (after all some EASA STC holders have been selling them to other installers for years) but what value is there in a Minor Mod approval?
Surely a Minor mod can be done by any installer, with a logbook entry by an EASA66 person?
Also how can somebody own a Minor mod approval in the first place?
You have to pay money to EASA for a minor mod approval and you have to supply documents which might take time to create. That company has done that and allows you to use their approval for a fee. I don’t see anything strange about that.
Surely a minor mod approval is a perversion of the system.
The fact a mod is “minor” means no certification authority approval is required. The mod can be done in the field, signed off by an appropriate person.
In FAA-land this would be laughed at.
Not in EASA land, you are supposed to file all minor mods with the agency. Does anyone do that? Well…
My “knowledge” was that the only way to be sure a mod is Minor or Major is to ask EASA.
Which, to be absolutely precise, is also the case under FAA – if you want an absolutely gold plated guarantee (underwritten by the US gold reserves) that your proposed mod is Minor. Being illiterate enough to be unable to read FAR Part 43 Appendix A, etc would also help…
But once a mod has been determined, by the ultimate authority (FAA or EASA), to be Minor, no installation approval should be required. A logbook signoff only.
Otherwise, the Major Mod regime is perverted… because there isn’t one anymore.
Is there really zero decision authority in the field?
Peter, we are talking EASA here, not FAA. The procedure for EASA is as it is — you have to file minor changes with the agency. Minor mod in EASA land does not mean you can perform it without paperwork. You can find guidelines on the CAA web site.
On a quick read, that is a Major mod process i.e. a nice job creation scheme.
Also it looks like a Part 21 firm can do the decision in-house, according to some criteria specified elsewhere no doubt.
Part 21 / DOA is also very expensive option. I do apply for all EASA minor changes myself. As Achimha writes it requires quite a lot of work, as you will have to write your own reports to receive an EASA minor change approval.
One has to pay a fee to EASA for this “service”, and the applicant has work for it. Customers could pay less than the EASA fee if an approval is wider and could be re-used, making it possible to share to cost between others.
You are not allowed to use the minor change approval without permission of approval holder.
Obvouse, a lot of approvals are very similair as most will aply for the same approvals, there might be hundreds of approval for building a GTX-330 in a Cessna 172 for example.
Some manufacturers also offer some approvals free of charge (Trig did that with their TT-31) for most GA aircraft, and so did we for our voltage warning light.
This is an outrageous job creation scheme – unsurprising given that EASA recruited heavily from what are now EASA 21 companies and from the mod approval departments of the national CAAs.
I recall correspondence with one of these – an ex Brit – whose best argument for some bizzare requirement was “times have changed”.
No wonder people operate on the N-reg.
The EU machinery is set up to ignore overt commercial pressure and lobbying (take the famous Swatch and lead-free soldering case) but then they throw the game away by stuffing themselves with the gravy train riders from the very industry they are trying to regulate.
You are not allowed to use the minor change approval without permission of approval holder.
How can the holder claim copyright when his submission is the same as everybody else’s, and in any case is straight out of the Garmin IM?
Actually this is a wider issue with all STCs, most of which are straight out of the IM…
How can the holder claim copyright when his submission is the same as everybody else’s, and in any case is straight out of the Garmin IM?
EASA allows the holder of a minor mod approval to grant permission to use it. If you perform that mod, you have to document on which base you have done it and that would be a reference to the approval holder which requires his permission. That’s more an EASA thing rather than a copyright thing.
