Teledyne landing lights - under EASA and FAA
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Teledyne landing lights - under EASA and FAA
I am looking at these
On N-reg, they are routinely fitted as a minor mod.
On G-reg, what would be the process?
There is an additional variable, on aircraft which use the lamp current to energise a reed relay which operates a cockpit indicator light, so the light does not come on if the lamp filament is blown. This is a little silly since you can see the lights from the cockpit! Does the subsequent non-functioning of the cockpit indicator light affect the paperwork?
On N-reg, they are routinely fitted as a minor mod.
On G-reg, what would be the process?
There is an additional variable, on aircraft which use the lamp current to energise a reed relay which operates a cockpit indicator light, so the light does not come on if the lamp filament is blown. This is a little silly since you can see the lights from the cockpit! Does the subsequent non-functioning of the cockpit indicator light affect the paperwork?
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I would just fit them, make an entry in the logbook and be done with it. If anyone ever raises a stink about it, then switch back to the old filament one until they've left the field and swap it again!
It's not like you've installed a new structural member or re-riveted the elevator....
It's not like you've installed a new structural member or re-riveted the elevator....
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Actually I have replaced all the standard rivets on my TB20 with flush ones, which is why it goes 20kt faster
I get your drift, of course, but that wasn't my question
I get your drift, of course, but that wasn't my question
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On G-reg, what would be the process?
But with someone like you (IO540) and your obvious technical ability, I would think that you would be able to put forward a reasonable case for fitting these lights e.g c/b rating, current consumption, compatibility with existing lamp holder etc. Of course there's a fee to pay but you would be able share this with other users. I don't think you have to be a design authority to do this.
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I take it there is no such thing as an EASA minor mod which is just a logbook entry, is it? Legally speaking, I mean. Even a minor mod needs to go to EASA and back.
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In Europe, N-reg, there are some other angles on this...
A minor mod (logbook entry) is easy.
A major mod (337, etc) could be more tricky because the only FSDO that supposedly supports 337 processing for non-US users is the NY IFU and this has washed its hands of this US taxpayer funded responsibility. There is a way around this but it can be costly. So avoiding a 337 is a good idea. Personally I think that no way is this a major mod on the FAA definition of a major mod which is a "basic change" to the electrical system.
I see the PMA angle is just a replacement, which is a great option.
For EASA, the official lack of acceptance of a US PMA is a major problem which the industry sidesteps otherwise European GA would grind to a halt. I suspect that this is just a moneyspinner for companies able to generate an EASA-1 form...
My original Q was not rhetorical but I did know a part of the answer, but I still wanted some input from people who have actually done it (if any).
A minor mod (logbook entry) is easy.
A major mod (337, etc) could be more tricky because the only FSDO that supposedly supports 337 processing for non-US users is the NY IFU and this has washed its hands of this US taxpayer funded responsibility. There is a way around this but it can be costly. So avoiding a 337 is a good idea. Personally I think that no way is this a major mod on the FAA definition of a major mod which is a "basic change" to the electrical system.
I see the PMA angle is just a replacement, which is a great option.
For EASA, the official lack of acceptance of a US PMA is a major problem which the industry sidesteps otherwise European GA would grind to a halt. I suspect that this is just a moneyspinner for companies able to generate an EASA-1 form...
My original Q was not rhetorical but I did know a part of the answer, but I still wanted some input from people who have actually done it (if any).
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IO540 - I do know someone who has obtained an EASA Minor Mod, but I am reluctant to disclose the nature of this. The person concerned put together a professional package containing all the technical information and submitted it along with the appropriate paperwork. The item concerned was not even a previous aircraft part. I too was amazed at how easy the process was.
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what happens to parts when they arrive with an EASA-1 form but no 8130-3
I do know someone who has obtained an EASA Minor Mod, but I am reluctant to disclose the nature of this. The person concerned put together a professional package containing all the technical information and submitted it along with the appropriate paperwork. The item concerned was not even a previous aircraft part. I too was amazed at how easy the process was.
If you billed your time at say £60/hr preparing the paperwork for a mod application, it would be a grand or two immediately. I did an FAA 337 application a short while ago, which a US FSDO (not the NY IFU) approved, and while it was easy, and the FAA itself charged nothing, if I counted my total time on it it would have been charged out to a (nonexistent in this case) client at 4 figures.
The one big EASA issue seems to be that if you want to get an EASA STC, you need the support of the manufacturer, which is generally a U.S. company and many of those are not interested in providing the data for what they perceive is a tiny market. Even Garmin have on occassion totally washed their hands of supporting a potential installation.
Last edited by IO540; 11th May 2011 at 07:05.
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I researched this a while ago and found that neither the FAA nor the UK CAA requires any specific form for a normal component.
The CAA required an EASA-1 form for Class 1 parts (engines or props), or an FAA Export CofA (8130-4). I gather the FAA no longer does the 8130-4 and apparently the CAA now accepts an 8130-3 for these items too.
What is required is evidence of traceability, back to the manufacturer. An 8130-3 or EASA-1 form is just that. But other documents are just as good.
I think EASA is trying to modify this and insist on an EASA-1 form for everything but that has to be widely ignored, because buying every item from (or via) an EASA145 company just inflates costs everywhere, and the generation of the EASA-1 form is a sham anyway in most cases.
Once the part is installed, the traceability document should be filed into the work pack, which is the property of the aircraft owner. In practice people don't bother to do this with trivia like the four screws, washers and nuts which hold an altimeter in the panel. This is a huge grey area which is widely tolerated otherwise aviation would disappear up its back orifice
The CAA required an EASA-1 form for Class 1 parts (engines or props), or an FAA Export CofA (8130-4). I gather the FAA no longer does the 8130-4 and apparently the CAA now accepts an 8130-3 for these items too.
What is required is evidence of traceability, back to the manufacturer. An 8130-3 or EASA-1 form is just that. But other documents are just as good.
I think EASA is trying to modify this and insist on an EASA-1 form for everything but that has to be widely ignored, because buying every item from (or via) an EASA145 company just inflates costs everywhere, and the generation of the EASA-1 form is a sham anyway in most cases.
Once the part is installed, the traceability document should be filed into the work pack, which is the property of the aircraft owner. In practice people don't bother to do this with trivia like the four screws, washers and nuts which hold an altimeter in the panel. This is a huge grey area which is widely tolerated otherwise aviation would disappear up its back orifice
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As I understand the new EASA rules a Part M organisation is responsible for every item when they come to issuing the ARC. So for instance, if they spot a repair which was made and signed for by a previous company and it doesn't comply with SRM then they have the responsibility to remedy it.
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What would happen is that the work would continue, logbook entries wouldn't occur, and its better for all as-is.
The $64M Q is: where would you draw the line? I know for a fact that there are engine shops which would re-use conrod bolts.
As I understand the new EASA rules a Part M organisation is responsible for every item when they come to issuing the ARC. So for instance, if they spot a repair which was made and signed for by a previous company and it doesn't comply with SRM then they have the responsibility to remedy it.
But in all other cases you are entitled to rely on the previous maintainer's signoff, otherwise two things will happen:
1) Every time you service a plane which others have worked on, you will need to go back to square 1, which would cause GA to collapse
2) Every cowboy and conman (of which there are loads in maintenance) would have a field day, discovering the issue when the plane is unairworthy and thus having the customer over a barrel
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A proposed new EASA head needs to be crooked enough to go on TV and say with a straight face to a load of (mostly admittedly only marginally more honest) Euro MPs that 14 ATPL exams and many hours of logbook stuffing with an FTO instructor is a "little test".
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I agree on the cost basis - there isn't one. But one could get more brightness out of these. On the TB20 especially, with the lights being only on the LH wing, taxiing at night is very hard (if you need to make a right turn) and also if you have a wide angle (taxi) lamp of the LED type, you can leave it on the whole time, for conspicuity.
Actually that LED lamp I linked is sold as a combined landing+taxi but the beam is much too narrow for a taxi lamp.
Actually that LED lamp I linked is sold as a combined landing+taxi but the beam is much too narrow for a taxi lamp.
