Replacing parts on a factory built aircraft (RA)

[dodo]

If I have an RA 24- registered aircraft, and I want to replace the radio, does it have to be with the same make and model as the manufacturer supplies, or is it OK as long as it is basically the same functional item the same (a radio), and doesn't require changes elsewhere to the aircraft (i.e. same antenna, same location on dash)?

 

dodo

 

 

[Mriya]

The short answer is that approval is required for any mods to a factory built aircraft.

 

The longer and more involved answer of what that approval looks like and how it is obtained will depend upon the type of design certification that applies. Is it a factory certified LSA? Does it have a full CASA approved Type Certificate? Is there an STC approved for the mod? Maybe an EO has been prepared for the change? There are probably a few more options to be considered before answering your question, however these are a good start to help establish what type of approval you will require.

 

Regards,

 

Justin.

 

 

[dodo]

Type Certificated - and I am assuming that the factory provided exactly one radio type/model, and no STC...

 

...but your reply implies an engineering change or factory approval would be required for the simplest change, even if it is just unbolt/bolt in a different make of radio?

 

dodo

 

 

[Downunder]

They (manufacturers & govt bodies) seem to be cracking down on modded 24 aircraft these days.

 

Best bet I recon, would be to get a instument tech to do the job and get him to contact the manufacturer for prior approval.

 

Intended use as a private, owner maintained or school, hire and reward may affect the manufacturers decision.

 

Obviously they are worried about a bodgy job causing an incident/accident and damaging the "brand".

 

As a "24" owner myself, it's unfortunate readily available improvements and changes are difficult to implement by those people that DO know what they are doing..

 

(edited before Dazza found out....)

 

 

[Guest ozzie]

Whatever happened to the Avionics guy fitting whatever the owner wanted in the avionics rack and do the paperwork/ signoff himself or is that just the GA world.

 

 

[biggles]

They (manufacturers & govt bodies) seem to be cracking down on modded 24 aircraft these days.Best bet I recon, would be to get a instument tech to do the job and get him to contact the manufacturer for prior approval.

Intended use as a private, owner maintained or school, hire and reward may affect the manufacturers decision.

 

Obviously they are worried about a bodgy job causing an incident/accident and damaging the "brand".

 

As a "24" owner myself, it's unfortunate readily available improvements and changes are difficult to implement by those people that DO know what they are doing..

 

(edited before Dazza found out....)

Instument ??

 

 

[Mriya]

Whatever happened to the Avionics guy fitting whatever the owner wanted in the avionics rack and do the paperwork/ signoff himself or is that just the GA world.

Not sure whether you are joking or serious with that comment. Certainly isn't how things are supposed to be done. However, wouldn't surprise me if it has happened like that out in GA land somewhere.

Going back to the original question. I'd start with a question to the factory to see whether your desired change is (or can be) approved by them. If they can't help and it is an aircraft with full Type Certification issued by a NAA (not LSA factory certification) then it will require a trip to your nearest Aeronautical Engineer for an EO.

 

Unfortunately within RAAus and possibly GA, short cutting the system has almost been 'normalised' resulting in question marks about the legal Airworthiness of many aircraft out there.

 

 

[Guest ozzie]

Bloody serious. How many crapped out radios and navs have been replaced in Cessnas and other GA aircraft over the years. Take aircraft to the Avionics shop say rip out and replace with say all new Fancy Stuff. Throw big wad of cash at The Man. Avionics shop does job signs off job updates aircraft logs. what's problem?

 

 

[Mriya]

Bloody serious. How many crapped out radios and navs have been replaced in Cessnas and other GA aircraft over the years. Take aircraft to the Avionics shop say rip out and replace with say all new Fancy Stuff. Throw big wad of cash at The Man. Avionics shop does job signs off job updates aircraft logs. what's problem?

A few possibilities with your scenario...

1. The big wad of cash covers organising the EO also. That is the way our Radio LAME works it if an EO is required.

 

2. Depending on the equipment changes some upgrades may come with valid STC's allowing the upgrade.

 

3. Or possibly the LAME was taking paperwork shortcuts which by default mean the aircraft is no longer technically airworthy as it no longer complies with the original TC and there is no supporting documentation that authorises the modification away from the approved design.

 

I realise all this can sound a little 'petty', but please don't shoot the messenger. I didn't make the rules, but am simply trying to explain them from CASA's point of view. Bottom line as they see it is ALL repairs and mods must be documented and conform with approved data. This provides assurance that the aircraft continues to meet Airworthiness standards and has not been compromised by sub-standard repairs or alterations.

 

The experimental category exists for people who want to 'tinker' with aircraft, but once you are in that category other restrictions start to apply to provide a level of protection to the general public in the event that an 'experiment' fails.

 

 

[pmccarthy]

When I replaced my tyres the Australian agent for my LSA sold me 10 ply to replace the 6 ply that had worn out. Can I assume this conforms? How would I (the customer) find out? It has been a big improvement, where does common sense fit in?

 

 

[Guest ozzie]

A few possibilities with your scenario...1. The big wad of cash covers organising the EO also. That is the way our Radio LAME works it if an EO is required.

2. Depending on the equipment changes some upgrades may come with valid STC's allowing the upgrade.

 

3. Or possibly the LAME was taking paperwork shortcuts which by default mean the aircraft is no longer technically airworthy as it no longer complies with the original TC and there is no supporting documentation that authorises the modification away from the approved design.

 

I realise all this can sound a little 'petty', but please don't shoot the messenger. I didn't make the rules, but am simply trying to explain them from CASA's point of view. Bottom line as they see it is ALL repairs and mods must be documented and conform with approved data. This provides assurance that the aircraft continues to meet Airworthiness standards and has not been compromised by sub-standard repairs or alterations.

 

The experimental category exists for people who want to 'tinker' with aircraft, but once you are in that category other restrictions start to apply to provide a level of protection to the general public in the event that an 'experiment' fails.

I part owned a maintenance facility back in the eighties. Well aware how the system works even though it has now become a lot more crazier. I employed several LAMES, one i used as the signatory. No shortcuts, work is always done 'in accordance with..' If the products have an STC then there should be no problem fitting them to a customers aircraft. We did no radio work, it went to an approved Avionics workshop. Easier to farm it out.

 

So point is: If a 24 aircraft requires new radios etc then it should not be limited to what the factory supplied or is it?

 

If i buy a 24 regoed parrot and I don't like what is fitted in the panel am i stuck with it or fit it out with my favourite KING radios as long as the work is done by approved people.

 

KISS.

 

 

[Guest Andys@coffs]

ELSA anyone........benefits and disadvantages.......I think it could be easy to go from LSA to ELSA how one returns is a real question!

 

If the aircraft is online (income producing) then ignore the question.....

 

Disadvantages of other than income producing? I cant think of too many...resale?

 

I wonder for a radio replacement what possible benefit an engineer could bring to the question that a good experienced tech couldn't? but as said the rules is the rules........

 

Andy

 

 

[Downunder]

Extract from Foxbat newsletter August 2013 http://www.foxbat.com.au/public/editor_images/2013 August final_web.pdf

 

(Bold by me)

 

2. As a Light Sport Aircraft (LSA).

 

All A22LS Foxbats fall into this category. In many respects,

 

LSA standards are more stringent than some ultralight Type Certificates. Whereas a Type

 

Certificate covers all aircraft of that Type, every individual LSA Aircraft has to have its own

 

Certificate of Airworthiness based on its Statement of Compliance to indicate that the aircraft

 

complies with the required standards – in the case of USA and Australia, those of ASTM

 

International (known until 2001 as the American Society for Testing and Materials).

 

In the USA, LSAs were originally intended to bridge the gap

 

between traditional GA aircraft and ultralights and require a

 

Light Sport Pilot’s License to fly them. In Australia, this clarity

 

of purpose was muddied somewhat by local organisations.

 

As a result, in Australia, LSAs can be registered VH- with

 

CASA or 24- with RA-Aus. The aircraft are identical, it is only

 

the paperwork (and pilot license) which is different.

 

Either way, only the LSA manufacturer can approve a

 

modification to their aircraft – even a Part 21/CAR 35 engineer

 

cannot approve modifications to LSAs. This means any

 

change from the delivered specification must have an LOA

 

(Letter Of Approval) from the manufacturer.

 

So if you later want to add a UHF radio, install a fuel flow

 

meter or a mustering siren, add any extra instruments or even

 

change the type of tyres on the aircraft, you should have an

 

LOA to make it legal. However minor a modification may

 

seem, if you do not have an LOA, your insurance is likely to be invalid and CASA/RA-Aus may

 

order a change to ‘experimental’ status for your aircraft – meaning it cannot be used for trainingor hire.

 

The only exceptions to LOA’s are removable/portable accessories like headsets and GPS

 

equipment which are not permanently fixed to the aircraft.

 

Whether Type Certified or LSA, if you do not have the necessary approvals for a modification,

 

you are technically flying illegally. As a result, your insurance may be invalid and you could in

 

theory be open to prosecution by CASA. The message is simple – do not modify your aircraft

 

unless you have the necessary approvals!

 

 

[djpacro]

These may answer some questions:

 

http://www.casa.gov.au/scripts/nc.dll?WCMS:PWA::pc=PC_102010

 

• Draft AC 21-46 v3.0 - Airworthiness approval of avionics equipment
   
   
  

 

 

http://www.casa.gov.au/wcmswr/_assets/main/newrules/parts/021/download/draft-ac21-12.pdf Classification of design changes

 

 

[Guest ozzie]

the next person that tells me this is recreational aviation gets a poke in the eye.

 

 

[Dafydd Llewellyn]

Type Certificated - and I am assuming that the factory provided exactly one radio type/model, and no STC......but your reply implies an engineering change or factory approval would be required for the simplest change, even if it is just unbolt/bolt in a different make of radio?

dodo

The radio installation is not normally part of the Type certificate; it would presumably need to be approved as complying with CAO 103.24, and the installation under CASR 21 subpart M. However it may be covered in the aircraft's maintenance manual.

 

 

[dodo]

Thanks for the advice, and it has given me a lot of options. The hardest thing was to know where to start reading.

 

Dodo