Finding a shop to install non-TSO equip.

dmspilot

dmspilot

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It's been discussed at length here that most equipment (e.g., comm radios, etc.) for aircraft used in Part 91 don't really need to be TSO'd. However I haven't had any luck finding someone willing to install and sign off on such equipment. Anyone else?
 
Find an independant A&P, be upfront about what you want to do, show him/her (if necessary) the various publications documenting the legality of performing the installation you propose, and offer to assist. Shouldn't be too difficult. A commercial shop would be much less likely to be interested in doing anything other than the most obviously accepted installations.
 
MuseChaser said:
Find an independant A&P, be upfront about what you want to do, show him/her (if necessary) the various publications documenting the legality of performing the installation you propose, and offer to assist. Shouldn't be too difficult. A commercial shop would be much less likely to be interested in doing anything other than the most obviously accepted installations.
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Bingo. You'll find it nearly impossible to find any repair station (avionics shops are almost always repair stations) willing to do it. They've got too many policies, procedures, manuals, etc. that make it difficult for them. You need a smaller shop or independent A&P/IA that is both open-minded about the regs and the discretion the FAA gives the A&P/IA and who is sufficiently familiar with avionics to get the job done. They do, in fact, exist.
 
dmspilot said:
It's been discussed at length here that most equipment (e.g., comm radios, etc.) for aircraft used in Part 91 don't really need to be TSO'd. However I haven't had any luck finding someone willing to install and sign off on such equipment. Anyone else?
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good luck!
 
dmspilot said:
However I haven't had any luck finding someone willing to install and sign off on such equipment.
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Who does your annuals, they won't install it? Keep in mind, if your IA isn't on board also they might just write it up at the next annual. Unfortunately, there are APIAs who prefer not stray even though it's perfectly legal. Perhaps the equipment vendor may have a list of people who will install their equipment in your area? I've signed off a number of non-TSO equipment over the years, but sometimes it just takes a little more effort to find an AP in your area. I used to have people from a wide area call up especially when I was installing a number of marine radios. All that business was by word of mouth as social media wasn't the thing back then.

As for shops, a FAA CRS usually wont' unless that specific process is written into their 145 manual. So it usually is tough to find a shop to do it.
 
Bell206 said:
Keep in mind, if your IA isn't on board also they might just write it up at the next annual.
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This is an excellent point that I should have raised. Any time you're thinking about doing anything that toes up to the line of legal, talk about it with the IA that signs off your annuals. In theory, if another A&P has blessed it, the IA shouldn't really override it, even if he disagrees, as that A&P's signature on the alternation makes it legal, but not all IA's will see that fine legal distinction and may refuse to sign off an annual. That said, many IA's pay virtually no attention to avionics. Biggest risk is having a CRS (Certified Repair Station) do a subsequent annual; they'll ding you.
 
From FAA order 8300.16A:

8-10. Commercial Off-the-Shelf (COTS) and Other Articles not Produced under 14 CFR Part 21, § 21.9.

a. COTS Articles. COTS refers to an article that has been developed for sale to the general public. For the purposes of this order, both COTS and articles not produced under § 21.9 are addressed in the same manner. Installation of such articles can be approved but requires an evaluation based on their intended functions and failure modes and effects. In addition, such articles installed for “situational awareness” or as a supplemental system may be acceptable provided they do not interfere with or displace required equipment, or otherwise interfere with the safe operation and airworthiness of the aircraft.

b. Installation of COTS Articles. Section 21.9 was not intended to restrict an owner or operator or their repair and maintenance facility or person from installing “commercially available” articles on their products.

c. Determining Suitability of an Alteration. A commercially available article (part) does not have to be approved in order for an alteration including that article to be accomplished in accordance with part 43. The installer must determine the suitability of the alteration as follows:

(1) For major alterations, the installation of an article must be performed with approved technical data.

(2) For minor alterations, the installation of an article must be performed with acceptable data.

(3) The approved or acceptable data must show that an article meets the airworthiness requirements and is suitable for its intended purpose.
 
It establishes FAA policy on alterations... what needs FAA approval, and what does not.
 
rotormatic1 said:
It establishes FAA policy on alterations... what needs FAA approval, and what does not.
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"This order defines the process for the approval of technical data for major repairs and major alterations."

How is installation of a radio a major alteration? How does your post answer the question?
 
If it’s required equipment, the article needs to be approved. As far as the installer determining the alteration is major or minor, the installer would refer to the definition in 14 CFR 1, and appendix A of 14 CFR 43. Most certificate holders determine the installation of a radio is not a major alteration. The answer shows the equipment installed must be approved if it is required equipment, not that the installation itself needs to be approved as a major alteration.
 
rotormatic1 said:
If it’s required equipment, the article needs to be approved. As far as the installer determining the alteration is major or minor, the installer would refer to the definition in 14 CFR 1, and appendix A of 14 CFR 43. Most certificate holders determine the installation of a radio is not a major alteration. The answer shows the equipment installed must be approved if it is required equipment, not that the installation itself needs to be approved as a major alteration.
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Where did I ask about approvals for required equipment, and where in your passage does it state required equipment must be approved, and what kind of approval is necessary?
 
rotormatic1 said:
It establishes FAA policy on alterations... what needs FAA approval, and what does not.
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Not quite. It establishes the process to approve the data for a major alteration. Since you're a new member perhaps search PoA for the numerous threads on the topic of non-TSO part installation. Who knows, maybe you will become enlightened.;)

And FYI: all "required equipment" does not need to be "approved." It must only "meet the performance and environmental requirements" of that specific approval. Try 91.215(a) for an example.
 
You asked about installing a non TSO approved radio.

A radio is required equipment, as referenced in 14 CFR 91.205(d)(2) (IFR):

(d) Instrument flight rules. For IFR flight, the following instruments and equipment are required:

(2) Two-way radio communication and navigation equipment suitable for the route to be flown.

The passage states the non approved equipment cannot displace approved equipment.

VFR only? Need to show it is installed in accordance with standard practices and performs it’s intended function, however, don’t forget about FCC requirements...
 
rotormatic1 said:
You asked about installing a non TSO approved radio.

A radio is required equipment, as referenced in 14 CFR 91.205(d)(2) (IFR):

(d) Instrument flight rules. For IFR flight, the following instruments and equipment are required:

(2) Two-way radio communication and navigation equipment suitable for the route to be flown.

The passage states the non approved equipment cannot displace approved equipment.

VFR only? Need to show it is installed in accordance with standard practices and performs it’s intended function, however, don’t forget about FCC requirements...
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Maybe you did not read my original question correctly. I was not looking for legal advice on whether a non TSOd radio was legal. Nor did I desire to debate such a topic. Your opinions are both incorrect and unwarranted.
 
Not opinion or or advice. Just showing established policy.
 
dmspilot said:
It's been discussed at length here that most equipment (e.g., comm radios, etc.) for aircraft used in Part 91 don't really need to be TSO'd. However I haven't had any luck finding someone willing to install and sign off on such equipment. Anyone else?
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So what is it for? A comm radio? Is this supposed to be a primary or standby?

Not that it matters but even the "approved" equipment you see these days contain features that are not approved.

If we are being honest about it, often seeking a field approval may be cost prohibitive unless it can be done on your own time.
 
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rotormatic1 said:
Not opinion or or advice. Just showing established policy.
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Y'know, a lot of us have been debating this issue and mostly we don't come on after being a member for a week or so spewing stuff that just isn't true. You might want to research some old posts on this topic in other threads before making your pronouncements. Or quoting your credentials. Lot of experience in this group.

Supreme Court Justice Hand went home to Kentucky during Prohibition and went to what was his favorite saloon. He asked the bartender if they kept the law or whiskey. The bartender said, "Judge, we got the law. But if you want the whiskey, we got that too.

So, we got the regs. You want field experience? We got that too.

Jim
 
46 years in GA Maintenance, just trying to help.
 
FAA has granted STC approval for the installation of the non-certificated Dynon EFIS-D10A primary attitude indicator to replace the antique, failure-prone and obsolete mechanical attitude instruments in the panels of Cessna 150, 152 and 172 and Piper PA-28 and PA-38 models.
 
And by recent FAA policy in the ADSB arena, those approvals can be extrapolated as approved data on a simple 337 to every single engine land aircraft in the fleet.

Jim
 
Doug Reid said:
What do you want to install ...make and model of equipment ?
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Some examples that prompted the question are a KN64 and a non-TSO'd comm radio (I could use a backup and a jump plane at the airport is currently using a handheld...)
 
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