Experimental parts on certified aircraft

This forum has been developed to discuss aviation related topics.

Moderators: ahramin, sky's the limit, sepia, Sulako, lilfssister, North Shore, I WAS Birddog

Post Reply
flyguy73
Rank 1
Rank 1
Posts: 37
Joined: Tue Nov 03, 2009 7:10 pm

Experimental parts on certified aircraft

Post by flyguy73 » Mon Dec 30, 2019 9:14 am

I recently installed a certified uAvionix SkyBeacon ADSB-out on my PA-28 that includes ADSB-out, red LED nav light and strobe. I would like to install the matching green light and strobe for the right side. uAvionix does offer a matching certified LED light for the right side or for an extra $200, an LED + ADSB-in. However, the LED+ADSB-in is for experimental aircraft only. In the US, it is apparently possible to install this unit as a "minor alteration" on the PA28 with an inspection authorization and appropriate logbook entry. Can anyone comment on doing a similar installation in Canada? According to the CARS, I don't believe this would meet the requirements of a "Major Modification".
---------- ADS -----------
  

User avatar
AirFrame
Rank 10
Rank 10
Posts: 2020
Joined: Sun Oct 11, 2009 10:27 pm
Location: Sidney, BC
Contact:

Re: Experimental parts on certified aircraft

Post by AirFrame » Mon Dec 30, 2019 9:26 am

Nor would it affect structure, airworthiness, or performance. Nor is it likely that anyone would ever ask you about it if you just installed it and flew on.
---------- ADS -----------
  

Mapleflt
Rank 6
Rank 6
Posts: 472
Joined: Sat Jun 20, 2009 6:13 pm

Re: Experimental parts on certified aircraft

Post by Mapleflt » Mon Dec 30, 2019 10:03 am

You may also want to keep in mind that while Canada has yet to fully define the Canadian ADSB requirements it's unlikely the unit you are looking at will be compliant.
---------- ADS -----------
  

flyguy73
Rank 1
Rank 1
Posts: 37
Joined: Tue Nov 03, 2009 7:10 pm

Re: Experimental parts on certified aircraft

Post by flyguy73 » Mon Dec 30, 2019 10:17 am

Mapleflt wrote:
Mon Dec 30, 2019 10:03 am
You may also want to keep in mind that while Canada has yet to fully define the Canadian ADSB requirements it's unlikely the unit you are looking at will be compliant.
I understand this, but given that I fly to the US now, I couldn't wait until we get a requirement in Canada. I am ADS-B compliant for the US now after installing the SkyBeacon this summer. When we finally get requirements for Canada, then I will worry about what to do then to meet them. But if I waited to find out what NavCanada will be requiring, then I wouldn't be compliant in the US.

At any rate, I wasn't questioning the ADS-B implementation anyway. I'm interested in the use of the experimental LED. I think AirFrame has the most sensible answer, but I would ideally like to do something that meets TC approval as well.
---------- ADS -----------
  

photofly
Top Poster
Top Poster
Posts: 7493
Joined: Tue Jan 18, 2011 4:47 pm
Location: Making aviation exhausting, everywhere

Re: Experimental parts on certified aircraft

Post by photofly » Mon Dec 30, 2019 2:23 pm

flyguy73 wrote:
Mon Dec 30, 2019 9:14 am
I recently installed a certified uAvionix SkyBeacon ADSB-out on my PA-28 that includes ADSB-out, red LED nav light and strobe. I would like to install the matching green light and strobe for the right side. uAvionix does offer a matching certified LED light for the right side or for an extra $200, an LED + ADSB-in. However, the LED+ADSB-in is for experimental aircraft only. In the US, it is apparently possible to install this unit as a "minor alteration" on the PA28 with an inspection authorization and appropriate logbook entry. Can anyone comment on doing a similar installation in Canada? According to the CARS, I don't believe this would meet the requirements of a "Major Modification".
FIrstly, for a private aircraft, nobody is going to audit what parts you install.

However, since you ask, you are caught by 571.07(1):
571.07 (1) No person shall install a new part on an aeronautical product unless the part meets the standards of airworthiness applicable to the installation of new parts...
Your light doesn't meet the definition of a "standard part" or a "commercial part", it's not produced subject to an FAA PMA, or "manufactured in conformity with a part design approval issued by the Minister" therefore it's not eligible for installation.

It's not the modification that's the problem, it's the part itself.

To be honest, even if it were a standard part (it quite clearly isn't, but just suppose) then it (arguably) wouldn't pass the test for a part "whose failure does not adversely affect the continued safe flight and take-off and landing of the aircraft".
---------- ADS -----------
  
Kirk: This is a dangerous mission. Likely, one of us will die. The landing party will be me, Spock, McCoy, and Ensign Ricky.
Ensign Ricky: Aw, crap.

Heliian
Rank (9)
Rank (9)
Posts: 1581
Joined: Wed Apr 29, 2009 2:14 pm

Re: Experimental parts on certified aircraft

Post by Heliian » Mon Dec 30, 2019 3:46 pm

Why would someone produce or even install a kit that only has one led position light?

Now you left a paper trail, should have just done it.
---------- ADS -----------
  

User avatar
AirFrame
Rank 10
Rank 10
Posts: 2020
Joined: Sun Oct 11, 2009 10:27 pm
Location: Sidney, BC
Contact:

Re: Experimental parts on certified aircraft

Post by AirFrame » Tue Dec 31, 2019 9:38 am

flyguy73 wrote:
Mon Dec 30, 2019 10:17 am
At any rate, I wasn't questioning the ADS-B implementation anyway. I'm interested in the use of the experimental LED. I think AirFrame has the most sensible answer, but I would ideally like to do something that meets TC approval as well.
Unfortunately, as photofly points out, there is no option that would meet TC approval (short of certifying it yourself, which would be cost prohibitive).

What's the worst that could happen if it were installed? It could stop working, and you'd have no lights on that wingtip. No worse than a conventional bulb burning out. It could fall off, hang by it's wiring, and beat the crap out of your wingtip. Maybe mount it with spade terminals so it would simply depart the airplane if that happened. But if you're mounting it to the same points as the existing light, with equivalent hardware, even that is so vanishingly unlikely that I wouldn't worry about it.
---------- ADS -----------
  

corethatthermal
Rank 5
Rank 5
Posts: 324
Joined: Tue Feb 12, 2019 7:27 pm

Re: Experimental parts on certified aircraft

Post by corethatthermal » Tue Dec 31, 2019 10:02 am

NOT 1 post suggested talking to your AME ! Sure, go ahead, put unapproved parts on an A/C but don't expect your AME to do the next annual. Expect him to lock the doors when you come around !
---------- ADS -----------
  

User avatar
PilotDAR
Rank 11
Rank 11
Posts: 3069
Joined: Sun Sep 30, 2012 6:46 pm
Location: Near CNJ4 Orillia, Ontario

Re: Experimental parts on certified aircraft

Post by PilotDAR » Tue Dec 31, 2019 10:43 am

Just as a reminder, the person signing on the installation must have approved data which is the evidence that design compliance has been shown. I know that it's troublesome that approved data is required, but that's the cost to operate a certified plane. Some product manufacturers prefer to not submit their intended aviation products for approval, and that is certainly their choice. Whether a product is "approved" or not, is not a reflection on its quality of compliance, simply whether it has been evaluated and approved.

In the case of nav lights, a TSO is a part of the approval, and thereafter, an STC or similar approval. (No, the fact that a product has a TSO does not automatically confer approval for installation, and STC or airframe manufacturer's acceptance is still required.)

The design requirements for airplanes have specific requirements for nav lights; colour, angle of view, and function and reliability being the most important. F&R will include an evaluation for electro magnetic interference of the other airplane systems (which I have found with some LED systems). Again, the product could be fine, and have the required characteristics, but without the approval for the intended installation, there is no way to demonstrate this.

I have approved TSO'd nav lights on certain airplanes by STC, but no, it is not worth the cost to do it for just one plane. That's why the TSO'd and STC'd products are more costly, they have been tested and approved. LED lights are the way of the future. I have installed them on several planes, and been entirely happy. Be sure to choose a TSO'd product, approved by STC or PMA for your type. There is no approval mechanism in Canada to allow a "major" mod below this threshold. TC would like to investigate more simple approvals, as the FAA already allows, but alas, there does not seem to be the momentum from GA (I've tried), so it's not on the horizon. LED lights would be a perfect starting point, but no one is making an approach to TC for anything other than STC approval.
---------- ADS -----------
  

flyguy73
Rank 1
Rank 1
Posts: 37
Joined: Tue Nov 03, 2009 7:10 pm

Re: Experimental parts on certified aircraft

Post by flyguy73 » Tue Dec 31, 2019 8:39 pm

PilotDAR wrote:
Tue Dec 31, 2019 10:43 am
Just as a reminder, the person signing on the installation must have approved data which is the evidence that design compliance has been shown. I know that it's troublesome that approved data is required, but that's the cost to operate a certified plane. Some product manufacturers prefer to not submit their intended aviation products for approval, and that is certainly their choice. Whether a product is "approved" or not, is not a reflection on its quality of compliance, simply whether it has been evaluated and approved.

In the case of nav lights, a TSO is a part of the approval, and thereafter, an STC or similar approval. (No, the fact that a product has a TSO does not automatically confer approval for installation, and STC or airframe manufacturer's acceptance is still required.)

The design requirements for airplanes have specific requirements for nav lights; colour, angle of view, and function and reliability being the most important. F&R will include an evaluation for electro magnetic interference of the other airplane systems (which I have found with some LED systems). Again, the product could be fine, and have the required characteristics, but without the approval for the intended installation, there is no way to demonstrate this.

I have approved TSO'd nav lights on certain airplanes by STC, but no, it is not worth the cost to do it for just one plane. That's why the TSO'd and STC'd products are more costly, they have been tested and approved. LED lights are the way of the future. I have installed them on several planes, and been entirely happy. Be sure to choose a TSO'd product, approved by STC or PMA for your type. There is no approval mechanism in Canada to allow a "major" mod below this threshold. TC would like to investigate more simple approvals, as the FAA already allows, but alas, there does not seem to be the momentum from GA (I've tried), so it's not on the horizon. LED lights would be a perfect starting point, but no one is making an approach to TC for anything other than STC approval.
This isn't necessarily the answer that I wanted to hear, but it was the answer I expected to hear. It does seem like TC may be overly strict in their requirements for some simple items such as LED lights, especially in light of the fact that the FAA may have more lax requirements, but it is the system we have. Perhaps this is something COPA and it's members can help fight for?
---------- ADS -----------
  

ahramin
Rank Moderator
Rank Moderator
Posts: 5855
Joined: Tue Feb 17, 2004 5:21 pm
Location: Vancouver

Re: Experimental parts on certified aircraft

Post by ahramin » Tue Dec 31, 2019 8:57 pm

The FAA is actively working on getting new technologies into old airplanes. I think someone did the math on safety benefits of new stuff versus safety risk of unapproved stuff.

Transport Canada had a wide open consultation in 2018 about what changes people wanted to see in the CARs. They didn't get much interest from GA (It's amazing how few GA owners know the basic rules of aircraft ownership and operation but maybe not so amazing since flight schools don't own private aircraft). One quick outcome was the change in the ELT recert rules which is already out. My guess is that for the analysis required for sweeping rule changes like that being done in the US there simply isn't the funding even if the will was there.
---------- ADS -----------
  

User avatar
PilotDAR
Rank 11
Rank 11
Posts: 3069
Joined: Sun Sep 30, 2012 6:46 pm
Location: Near CNJ4 Orillia, Ontario

Re: Experimental parts on certified aircraft

Post by PilotDAR » Wed Jan 01, 2020 10:01 am

It does seem like TC may be overly strict in their requirements for some simple items such as LED lights, especially in light of the fact that the FAA may have more lax requirements, but it is the system we have. Perhaps this is something COPA and it's members can help fight for?
It's not that TC is overly strict, it's jut that that's what the present regulations say. Even Engineers at TC whom I deal with on a weekly basis say that these rules are too strict, and need updating, but it costs money to consult and update rules. It's free to leave them as is.

I had lunch with two very senior TC Aircraft Certification staff a few years back, and told them that the GA industry would be much better off, if Delegates were permitted to just consider the mod, stick our thumb in the air to prove we can find that it complies, sign an approval, and send a bill for an hour of our time. This, instead of the minimum of twenty plus pages I must generate to document even the most simple mod for approval. The two TC staff did not disagree with me, but there is no path for this, unless an investment is made it time to pave one. No one private airplane owner is going to invest in this, it's going to take a group

I have spent hours on the phone with COPA in support of getting the ball rolling on this, no ball so far. And I really don't worry about this, as I can issue an approval to modify my two certified planes. My OM plane nicely sidesteps these requirements. I tried recently to move my C 150M into OM, to free it of the regulatory burden, but not yet, still too many of them operated commercially! So it's new nav lights will the the TSO'd, STC'd versions.
---------- ADS -----------
  

flyguy73
Rank 1
Rank 1
Posts: 37
Joined: Tue Nov 03, 2009 7:10 pm

Re: Experimental parts on certified aircraft

Post by flyguy73 » Wed Jan 01, 2020 10:29 am

PilotDAR wrote:
Wed Jan 01, 2020 10:01 am
It does seem like TC may be overly strict in their requirements for some simple items such as LED lights, especially in light of the fact that the FAA may have more lax requirements, but it is the system we have. Perhaps this is something COPA and it's members can help fight for?
It's not that TC is overly strict, it's jut that that's what the present regulations say. Even Engineers at TC whom I deal with on a weekly basis say that these rules are too strict, and need updating, but it costs money to consult and update rules. It's free to leave them as is.

I had lunch with two very senior TC Aircraft Certification staff a few years back, and told them that the GA industry would be much better off, if Delegates were permitted to just consider the mod, stick our thumb in the air to prove we can find that it complies, sign an approval, and send a bill for an hour of our time. This, instead of the minimum of twenty plus pages I must generate to document even the most simple mod for approval. The two TC staff did not disagree with me, but there is no path for this, unless an investment is made it time to pave one. No one private airplane owner is going to invest in this, it's going to take a group

I have spent hours on the phone with COPA in support of getting the ball rolling on this, no ball so far. And I really don't worry about this, as I can issue an approval to modify my two certified planes. My OM plane nicely sidesteps these requirements. I tried recently to move my C 150M into OM, to free it of the regulatory burden, but not yet, still too many of them operated commercially! So it's new nav lights will the the TSO'd, STC'd versions.
Right, I probably shouldn't have said overly strict, perhaps more conservative. While the FAA may be more willing to consider minor issues like this, given the recent Boeing 737 Max debacle and the apparent lax FAA oversight, perhaps conservatism is not necessarily a bad thing. However, there is probably room for compromise, especially on items like LED's or some avionics that would not appear to cause a significant airworthiness issue but would result in greatly enhanced safety or situational awareness.

Certainly an OM plane would get around this issue, but introduces issues of it's own. In this case, it would limit the ability to fly into the US, which was exactly the reason for installing the SkyBeacon ADS-B and matching LED nav light in the first place.
---------- ADS -----------
  

User avatar
AirFrame
Rank 10
Rank 10
Posts: 2020
Joined: Sun Oct 11, 2009 10:27 pm
Location: Sidney, BC
Contact:

Re: Experimental parts on certified aircraft

Post by AirFrame » Wed Jan 01, 2020 10:37 am

corethatthermal wrote:
Tue Dec 31, 2019 10:02 am
NOT 1 post suggested talking to your AME ! Sure, go ahead, put unapproved parts on an A/C but don't expect your AME to do the next annual. Expect him to lock the doors when you come around !
When it's obvious that putting the desired part on the plane flies in the face of regulations, why would anyone suggest talking to your AME about it? If you put the question to them, they have to say "no". If you've already got a relationship with your AME that is good enough that he would let a Nav Light slide past unmentioned, then you're probably not going to ask these questions in a written, public, forum.
---------- ADS -----------
  

photofly
Top Poster
Top Poster
Posts: 7493
Joined: Tue Jan 18, 2011 4:47 pm
Location: Making aviation exhausting, everywhere

Re: Experimental parts on certified aircraft

Post by photofly » Wed Jan 01, 2020 10:44 am

It’s not an AME’s responsibility to opine on what you may or may not have done to your airplane: an AME is responsible for doing the work YOU ask them to, including the inspections required by CAR625 appendices B & C, if that’s what you ask them to do, in a manner consistent with the regulations. YOU make the decision about airworthiness, not an AME.
---------- ADS -----------
  
Kirk: This is a dangerous mission. Likely, one of us will die. The landing party will be me, Spock, McCoy, and Ensign Ricky.
Ensign Ricky: Aw, crap.

corethatthermal
Rank 5
Rank 5
Posts: 324
Joined: Tue Feb 12, 2019 7:27 pm

Re: Experimental parts on certified aircraft

Post by corethatthermal » Wed Jan 01, 2020 12:56 pm

If you've already got a relationship with your AME that is good enough that he would let a Nav Light slide past unmentioned, then you're probably not going to ask these questions in a written, public, forum.
Foolish and disrespectful towards your AME ! You ignorantly put your AME into a corner. Either he/she has to look the other way OR enter the discrepancy ( unapproved part ) into the log book, thereby rendering the A/C as unairworthy and perhaps invalidating the insurance AND possibly resulting in a fine if TC finds out you have been installing unapproved parts ! Either way, you are pissing in the AME s cornflakes !!!
It’s not an AME’s responsibility to opine on what you may or may not have done to your airplane: an AME is responsible for doing the work YOU ask them to,
IF an AME comes across YOUR unapproved installation , look at my answer above !!! NO respect for AME s
---------- ADS -----------
  

CpnCrunch
Rank 10
Rank 10
Posts: 2984
Joined: Mon Feb 08, 2010 9:38 am

Re: Experimental parts on certified aircraft

Post by CpnCrunch » Wed Jan 01, 2020 1:19 pm

Also creates a problem if you ever want to sell your plane, when the prospective buyer asks where the documentation is for the mod.
---------- ADS -----------
  

boeingboy
Rank (9)
Rank (9)
Posts: 1110
Joined: Wed Mar 03, 2004 2:57 pm
Location: West coast

Re: Experimental parts on certified aircraft

Post by boeingboy » Wed Jan 01, 2020 4:56 pm

Foolish and disrespectful towards your AME ! You ignorantly put your AME into a corner. Either he/she has to look the other way OR enter the discrepancy ( unapproved part ) into the log book, thereby rendering the A/C as unairworthy and perhaps invalidating the insurance AND possibly resulting in a fine if TC finds out you have been installing unapproved parts ! Either way, you are pissing in the AME s cornflakes !!!

Really?
Just like your big red warning light....right?? :rolleyes:
Looking at my newly acquired project c-150 , I looked around and couldn't find the low oil pressure warning light !! Damn, twins and larger A/C have "dummy" lights for everything including smoking on the pot, so WHY has no one come up with a low oil press. light STC so the pilot can immediately look at the gauge to confirm and maybe save a life or 2? HMM, I am installing a light from the hobbs txdcr, to hell with the regs !!!
---------- ADS -----------
  

photofly
Top Poster
Top Poster
Posts: 7493
Joined: Tue Jan 18, 2011 4:47 pm
Location: Making aviation exhausting, everywhere

Re: Experimental parts on certified aircraft

Post by photofly » Wed Jan 01, 2020 5:13 pm

That would actually be permissible. It would be a minor modification using standard parts.
---------- ADS -----------
  
Kirk: This is a dangerous mission. Likely, one of us will die. The landing party will be me, Spock, McCoy, and Ensign Ricky.
Ensign Ricky: Aw, crap.

boeingboy
Rank (9)
Rank (9)
Posts: 1110
Joined: Wed Mar 03, 2004 2:57 pm
Location: West coast

Re: Experimental parts on certified aircraft

Post by boeingboy » Wed Jan 01, 2020 5:29 pm

I didn't say it couldn't be done.

I was referring to some owner, willy-nilly throwing a couple of wires on some switch already installed.....To hell with regs!
---------- ADS -----------
  

corethatthermal
Rank 5
Rank 5
Posts: 324
Joined: Tue Feb 12, 2019 7:27 pm

Re: Experimental parts on certified aircraft

Post by corethatthermal » Wed Jan 01, 2020 5:52 pm

Instead of the pressure switch operating a hobbs meter, it operates a light ! It is MY A/C , not a customer and it shall be documented in the logbooks. I am the one who shoulders the responsibility/ verification of its legality as I am the one signing it off
---------- ADS -----------
  

photofly
Top Poster
Top Poster
Posts: 7493
Joined: Tue Jan 18, 2011 4:47 pm
Location: Making aviation exhausting, everywhere

Re: Experimental parts on certified aircraft

Post by photofly » Wed Jan 01, 2020 5:59 pm

boeingboy wrote:
Wed Jan 01, 2020 5:29 pm
I didn't say it couldn't be done.

I was referring to some owner, willy-nilly throwing a couple of wires on some switch already installed.....To hell with regs!
Isn't he an AME?
---------- ADS -----------
  
Kirk: This is a dangerous mission. Likely, one of us will die. The landing party will be me, Spock, McCoy, and Ensign Ricky.
Ensign Ricky: Aw, crap.

User avatar
AirFrame
Rank 10
Rank 10
Posts: 2020
Joined: Sun Oct 11, 2009 10:27 pm
Location: Sidney, BC
Contact:

Re: Experimental parts on certified aircraft

Post by AirFrame » Thu Jan 02, 2020 7:42 am

photofly wrote:
Wed Jan 01, 2020 5:59 pm
Isn't he an AME?
An AME is allowed to sign off mods to his own aircraft?

The quote above says there's "no STC" to add the light, and "to hell with the regs," he's doing it anyway. Which suggests that if he's an AME, he knows it's against the regs somehow. And yet, he's doing it anyway. But hey, I guess he can piss in his own cornflakes... :P
---------- ADS -----------
  

photofly
Top Poster
Top Poster
Posts: 7493
Joined: Tue Jan 18, 2011 4:47 pm
Location: Making aviation exhausting, everywhere

Re: Experimental parts on certified aircraft

Post by photofly » Thu Jan 02, 2020 5:31 pm

AirFrame wrote:
Thu Jan 02, 2020 7:42 am
photofly wrote:
Wed Jan 01, 2020 5:59 pm
Isn't he an AME?
An AME is allowed to sign off mods to his own aircraft?
An AME can issue a release for work performed on their own aircraft, sure.

The decision as to whether a modification is minor or major doesn't have to be made by anyone with a particular qualification. An AME might be better placed to make that decision, but at root it's a question of fact and not opinion, like airworthiness. If the modification meets the criteria in CAR571 Appendix A it's minor, and can be supported with "acceptable data". If not, it needs either "approved data" or "specified data". If coreatthermal can find acceptable data (like a similar installation as part of another type certified aircraft) uses standard parts like LED's or bulbs and holders, and performs the work in a standard way like by following the guildelines in AC43.13, then he's good to go.
---------- ADS -----------
  
Kirk: This is a dangerous mission. Likely, one of us will die. The landing party will be me, Spock, McCoy, and Ensign Ricky.
Ensign Ricky: Aw, crap.

Post Reply

Return to “General Comments”