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Installation of parts and appliances released without an EASA Form 1 or equivalent

Peter wrote:

Not many parts from Aircraft Spruce will be dual-release. In fact I wonder: if you buy say a Honeywell part from Spruce USA, do you get a dual-release 8130 with it?

If you specify on your purchase order that the part must be supplied with a dual-release 8130-3 then they may be able to oblige. It depends on whether the repair station they use for the overhaul also holds EASA approval on the back of their FAR145. Many US-based shops now do have EASA approval – far more than European shops having FAA approvals.

Avionics geek.
Somewhere remote in Devon, UK.

Peter wrote:

fuel filters at €200-300 each (mandatory lifed under Part M, every 2 years IIRC

Every year or 300h as per MM chapter 05……

LFPE
We got the same type of extremely fine wire mesh fuel filter on the Yak. That never gets replaced but ultra sonic cleaned in 50 to 100 hour intervals/ once a year. After cleaning I take an air gun and blow from inside out. I just cannot see much sense in replacing as the wire appears to be stainless steel. Vic
vic
EDME

Yes I agree with you Vic.
I don’t understand why Socata puts such a life limit on this kind of filter.

LFPE

To make money, presumably, and that in turn supports their dealer network because they buy the parts at list minus 25% or so

But this is not applicable to a Part 91 N-reg.

Administrator
Shoreham EGKA, United Kingdom

Just got this from EASA

Administrator
Shoreham EGKA, United Kingdom

The fitment of new ‘8130-3’ replacement parts is permitted under the terms of the EU/US bilateral agreement (BASA):

“Acceptance of NEW engine/components (and rebuilt engines) is governed by the Technical Implementation Procedure (TIP). The general principle is to accept such engine/components when released new on FAA Form 8130-3 using the blocks 13a to 13e (left side).” [EASA website]

It seems likely that this will no longer be possible after Brexit, even if the UK remains a member of EASA. Again, from the EASA website:

“Article 12 of the EU-US BASA defines that the Agreement applies to “[…] the European Community civil aviation regulatory system as applied in the territories in which the Treaty establishing the European Community is applied […]”. Therefore the Agreement does not apply to Norway, Iceland, Switzerland and Liechtenstein, which are EASA Member States and Members of the EASA Management Board, but are not Member States of the European Union.”

So after Brexit presumably the UK will be, at best, in the same boat as the four non-EU states referred to. How do these states currently manage new spare parts that come with an FAA-only 8130-3? Or do they only have the option to use EASA Form 1 or 8130-3 Dual Release parts?

Old dog learning new tricks

For many years, there have been treaties between the USA and various countries – see here.

When JAA came along, they proclaimed these to be dead. In 2005 I was at a presentation by a former JAA director who explained this. However that wasn’t quite the case in reality (the treaties continued to be operated) until EASA came along with a bigger hammer the full authority of the EU and now the above website says

So the UK could revert to whatever was agreed previously. AFAIK, 8130-3 would be accepted for new parts, like at present, except that way back what the CAA called Class 1 parts (engines and props) required a Form 1, or they would accept them with an 8130-3 with an Export CofA (a form signed by a US DAR which a US based DAR signs for a few hundred $). Also there have been companies which would take in say a prop with an 8130-3 and generate a Form 1 for it, via something like this. I was offered one such “conversion” in 2002, for £600, by a then well known UK engine shop (I believe it involved an inspection, a sheet of clean A4 and some laser printer toner which came with a Form 1 ).

I am sure a way will be found, because if a Form 1 (or a dual release 8130-3) was the only way, aviation (not just light GA) in Europe would collapse.

How e.g. Switzerland does it may be found at the above link. They are free to negotiate directly with the USA.

Another thing is that the UK CAA does want to remain in EASA for airworthiness (maintenance and parts) and licensing stuff, so how this will pan out remains to be seen.

Administrator
Shoreham EGKA, United Kingdom

Thanks for the link to the FAA bilaterals page. I can see that the non-EU EASA states have similar arrangements (though I haven’t checked the details).

I hope the Brexit team have the reinstatement of the US-UK bilateral on their to-do list, and get it done within the next 12 months (but I won’t hold my breath!).

Old dog learning new tricks

Once the UK is not in the EU, it will be free to sort out whatever treaty it wants, between the UK CAA and the FAA, directly. So the brexit team won’t need to be involved. And a working treaty is already up there…

I suspect however the CAA will have bigger fish to fry, like dealing with (my recollection of) Barnier’s threat that UK pilot licenses may not be recognised. Obviously he is playing hardball as instructed but there is a certain % of people on the continent (and a few on EuroGA) who would like the UK to burn in hell for daring to upset the cart, so the final landscape cannot be predicted from this far back

My positive outlook is based on, like I said, aviation collapsing if there was no way to accept the 8130-3, FAA-PMA parts, etc. Only a small % of US firms have EASA145 approval and can issue dual-release 8130-3 forms.

There are other angles e.g. will present UK EASA145 companies be able to continue issuing EASA-1 forms? Obviously they would want that, and along with that will have to be UK’s recognition of these. If the EU was to expel the UK from EASA, this authority would cease and the UK would have to create a new Form 1. This would cause havoc in Europe and elsewhere, so I think it is unlikely, although (as with the rest of the brexit stuff) any deal is not likely before the 11th hour. There is no precedent for this stuff…

Administrator
Shoreham EGKA, United Kingdom
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