VARMA

[hindsight2020]

Apologies if already posted, saw from another board. VARMA rollout. Nice to see the EAA take the lead on matters AOPA should be spearheading for us fac-built hell captives.

I don't see it being transformative, since right from the jump it limits the actual parts of consequence to the mothballing of these orphaned antiques, but I gotta give EAA their due in being just so darn glass half full.

So far they've got a couple softball items through, though the means-testing is already apparent and is a sign of a nothingburger neutered implementation (alternators VFR only, unreal). Perhaps one day it will lead to primary non-commercial being finally allowed and this whole kabuki can be dispensed with. Not that I'm sticking around to find out, 'what has posterity done for me lately' and all that jazz.

Tempted to contact that ACO and throw a couple parts requests by them that would really help things along for my lawmower.

 

[Daleandee]

Good info! Thanks for the heads up. We'll share this at our next EAA chapter meeting ...

Dale (former AOPA member) Andee

 

[Shepherd]

Well dang!
Too much good sense here.
Round up the usual suspects and execute them.

 

[GeorgeC]

Made before 1980 is vintage? Thanks for that...

 

[schmookeeg]

Sigh... I'm vintage.

 

[Bell206]

Interesting. While there is already existing guidance for installing similar parts via AC 23-27, COTS, etc. it does add a unique process for “replacement” parts to that mix. This could be huge in certain situations. However, the lack of aircraft installation “acceptance” within that document will still require the same Part 43 final steps as the existing guidance.

This new process seems more like an expansion of owner-produced parts to include off-the-shelf items than an addition to the PMA or TSO processes. Regardless, I would wait till there is a VARMA doc under the FAA letterhead to ensure the process context remains the same. The current EAA version is actually a bit more restrictive than the existing AC process, but it is definitely a move in the right direction.

 

[wheaties]

The door handles on my plane are car parts. For 35x the price of the same serial number product i can get an FAA approved piece. Now I can get the part from the auto store. It's about time.

I just spent several hundred dollars on a part for my seat that shouldn't cost half that. Rock on EAA.

 

[SoonerAviator]

One more reason to support EAA vs AOPA (not wanting to start a "drag AOPA through the mud" thread). It just blows my mind how doing simple stuff like this could lead to legitimate change for the little guys but AOPA and their giant coffers of money won't lift a finger.

 

[Sundancer]

I think we need AOPA, but they appear to be be FAA lapdogs to a great extent. There are ways to be constructively confrontational, to disagree professionally without burning bridges. I'm not there, I don't know the nature of their personal relationships with their FAA counterparts, of course, but AOPA doesn't leave the impression of pushing very hard. FAA has their own pressures, from the clowns on Capital hill, and their own 1960's bureaucracy - the place is a pyramid of management levels and super-diluted accountability. My old squadron commander was a big noise there and he likened it to wrestling the giant Stay Puft marshmallow man from Ghost Busters. NOTAMS, III Class medicals, generic FARS, wildly inconsistent FSDO opinions, etc., worthy of agressive AOPA pursuit - again, maybe I'm just not aware. . .

 

[Racerx]

One more reason to support EAA vs AOPA (not wanting to start a "drag AOPA through the mud" thread). It just blows my mind how doing simple stuff like this could lead to legitimate change for the little guys but AOPA and their giant coffers of money won't lift a finger.

I became an EAA member after I heard how they were helping Dynon get FAA approval.

 

[Pinecone]

It is NOT manufactured before 1980, it is that the Type Certificate is pre-1980, but includes all follow ons on the same TC. So the Mooney M20 TC is 1955, all other M20s are follow on/add ons to the original TC. So pretty much all Cessnas, most Beech and Pipers are covered.

 

[Domenick]

A VERY important clarification. Thanks.

 

[Ventucky Red]

Could be a start..

FAA CREATES ‘OFF-THE-SHELF’ REPLACEMENT PARTS PROGRAM FOR LEGACY AIRCRAFT
Posted by Cessna Owner Organization | Apr 12, 2023 | FAA Announcements & Certifications, News

Finding replacement parts for legacy aircraft has become increasingly difficult over the years, but owners can now breathe a sigh of relief. The FAA has approved a new program called the Vintage Aircraft Replacement and Modification Article program (VARMA), which will allow the use of certain off-the-shelf parts in type-certificated aircraft. The new rules apply to non-safety-critical parts used in planes weighing less than 12,500 pounds built before 1980.

Currently, parts must pass rigorous FAA engineering approvals and standards to be legally installed, even though safe, functional parts already exist outside the system. The new program has been adopted to reduce barriers to maintaining and repairing vintage planes, recognizing that a whole generation of planes are at risk of permanent grounding to unavailability of parts.

VARNA relies on existing FAA policies to create a streamlined process that requires no new regulations, orders, or advisory circulars. According to EAA, which worked with the FAA to develop the program, it “allows ordinary maintenance personnel to validate that certain low-risk replacement parts are suitable for installation on aircraft, without the need for extensive engineering analysis or complex and time-consuming design and production approvals from the FAA.

“The program applies to parts whose failure would not ‘prevent continued safe flight and landing.’ While this means that safety-critical components are not subject to this program, there are plenty of hard-to-find parts that meet VARMA’s criteria.”

As part of the testing for VARMA, EAA applied for permission to use an off-the-shelf starter solenoid in a Cessna 150, as the part is considered non-safety critical. The solenoid successfully passed the review process within several weeks using a Form 337 approval. Since then, EAA has also gained approval for alternators and voltage regulators in VFR aircraft.

 

[Ed Haywood]

So help me out here. Is this a change to the parts eligiblity process, the installation approval process, or both?

The examples cited required a 337. That means they were major alterations, which require approved data or a field approval. So this sounds like the FAA is adjusting its internal field approval process to not require engineering and production studies for non-safety-critical parts on vintage aircraft. Right?

But isn't there already a process that covers non-safety-critical parts ... called "minor alteration"? And can't you already determine that a part for a minor alteration meets TSO by referencing the understanding technical standards, like Val did for radios?

Using the test case, quality starter solenoids probably are built to an SAE standard, and the same standard is probably referenced by the TSO. So could not an intrepid A&P reach the same end result without having to go to a field approval?

Regardless, anything that provides more paths to success, I am a fan of. An I have been an EAA member for 25 years, but never an AOPA member, so this kinda validates my feelings there.

 

[Mongoose Aviator]

So help me out here. Is this a change to the parts eligiblity process, the installation approval process, or both?
The examples cited required a 337. That means they were major alterations, which require approved data or a field approval. So this sounds like the FAA is adjusting its internal field approval process to not require engineering and production studies for non-safety-critical parts on vintage aircraft. Right?

An applicant should submit a request for a letter of acceptance (LOA) to the Aircraft Certification Office (ACO) for Vintage Aircraft Replacement & Modification Article (VARMA) program. Before submittal, the applicant should discuss their intention to seek an acceptance for a specific article with the geographic ACO (preferably during the early stages), so the FAA and applicant can determine the required documentation for replacement or modification. An applicant's data submittal should contain sufficient detail and substantiating data to describe the design and demonstrate that it complies with the proposed standards and provisions of Advisory Circular 23-27, (Parts And Materials Substitution For Vintage Aircraft), AC20-62E (Eligibility, Quality, and Identification of Aeronautical Replacement Parts) or later revision.

 

[WDD]

I have a feeling that getting permission to replace a door handle with one from Auto Zone will require an application process similar to getting a 3rd class medical for a person who once took Adderall when he was 12 prescribed by an over zealous PCP. A year, lots of paperwork, and 50% chance of success.

 

[Bell206]

I have a feeling that getting permission to replace a door handle with one from Auto Zone

FYI: You can do that now but through an alteration process. However if what they're pushing through the VARMA process is true you can get that door handle labeled as a replacement part which is big. If so selecting parts that already are produced under an industry standard like SAE the VARMA process will be more a paperwork exercise than a true "approval" process similar to standard parts and COTS.

What will be interesting is how VARMA will be accepted on a global front via ICAO member nations. A lot of non-aviation parts are produced under various international standards in this day and age so this move, at least from my standpoint, could have a larger impact than an owner maintained aircraft category in the long run. Time will tell once the FAA releases the official policy.

 

[WDD]

Each time a part breaks I have to do VARMA paperwork and a few months time to get my plane fixed? Or just get the certified part and go flying. I guess if a plane is orphaned and no replacement parts are made any more this would work.

Now - if this allows me to use experimental avionics like a G3 it would indeed be significant.

 

[Bell206]

Each time a part breaks I have to do VARMA paperwork and a few months time to get my plane fixed?

No clue. But my guess given the context of the EAA article it would be a one time "acceptance" per part. But don't know where or how such a database base would be kept. As mentioned, need for the FAA doc to be released to answer those questions.

I guess if a plane is orphaned and no replacement parts are made any more this would work.

There are already processes for this. The big change in VARMA is "replacement" parts for a majority of the existing private GA fixed wing fleet. There's a difference.

if this allows me to use experimental avionics like a G3 it would indeed be significant.

You can do that now. Just depends on your mechanic and his personal limitations. Now VFR vs IFR ops and other specialize ops do have some requirements where a non-approved part may not work. But keep in mind, there is no regulatory classification of "experimental" parts. That is a vendor label only.

 

[Fracpilot]

Now if I could only put a G3 touchscreen and GFC 500 in my 310 under VARMA