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MRAs and when they are required


Anticept

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Hi All!

It would seem that the MRA system has changed a bit from a year ago. I just got off the phone with Dave at FD USA. FD Germany has advised FD USA that MRAs are required in the case of all alterations where equipment and parts are installed that is different from what shipped with the aircraft.

This means anything from changing the prop or wheel system, to even changing to a different tire size, needs an MRA. There are some very minor things that we can do as mechanics without an MRA, but it puts the burden on the mechanic to prove it is safe.

This is due to the method of compliance with the ASTM and EASA, which FD Germany is finding out is not as simple as previously believed.

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COOL!!!

 

Maybe we should get an MRA for each oil change, and to put air in the tires too.  After all, it's only $150 and we ARE changing something.  Maybe an MRA for each flight too, since we are changing the number of hours on the engine and airframe.

 

 

 

I'd be interested in seeing if the other LSA manufacturers require this...that will tell the tale if this is really an ASTM compliance issue.  Not saying FD is going overboard, but I'd be interested...

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I'd be interested in seeing if the other LSA manufacturers require this...that will tell the tale if this is really an ASTM compliance issue.  Not saying FD is going overboard, but I'd be interested...

 

I don't know if it's FD Germany, or if it's the way that EASA works. Regulation in Europe regarding aviation is super strict, whereas the USA is one of the few developed countries in the world where we are relatively unregulated. For that matter, this is about the only country in the developed world where "Night VFR" is such a thing.

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I don't know if it's FD Germany, or if it's the way that EASA works. Regulation in Europe regarding aviation is super strict, whereas the USA is one of the few developed countries in the world where we are relatively unregulated. For that matter, this is about the only country in the developed world where "Night VFR" is such a thing.

 

But why apply German rules to US owners?  I would think a manufacturer would be happy to have less regulation, even if only in part of its market.

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But why apply German rules to US owners?  I would think a manufacturer would be happy to have less regulation, even if only in part of its market.

 

Because the US regulations say we have to follow the manufacturer's recommendations. The manufacturer certifies our aircraft to ASTM standards in accordance with EASA regulations, therefore they are bound to EASA rules. It isn't recertified by the FAA due to the bilateral trade agreements.

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Because the US regulations say we have to follow the manufacturer's recommendations. The manufacturer certifies our aircraft to ASTM standards in accordance with EASA regulations, therefore they are bound to EASA rules. It isn't recertified by the FAA due to the bilateral trade agreements.

 

That makes some sense.  I'm still not getting an MRA for an oil change.  :D

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When I heard this my impression was that the money has to do with the ongoing record keeping that LS manufacturers are required to have in case they should go under. $150 seems a bit much actually.

 

This is also partially correct. Anytime an MRA is done, it has to go through each department of FD Germany, who have to review your airplane records to make sure an equipment incompatibility has not come up.

 

In addition, major MRAs that require engineering get expensive, but FD does allow the engineering data to be made by a third party as long as it conforms to standards.

 

Finally, FD Germany has been getting so many MRA requests, that it was taking up the engineer's time considerably, and so they started charging for MRAs to pay for their time.

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Let me throw this our for general comment. Would these require an MRA for an SLSA? And will MRAs be a point in liability lawsuits? And will they be an issue in ramp checks? And can one claim that if a part was changed in a subsequent build or even subsequent different model, that one can use it without an MRA?

Different tire than came on the airplane

Different battery

Leaving wheel fairings off

Different lights

Adding internal spring to hoses or tubing

Rerouting hoses or tubing

Using different tire air pressure than is in POH or other FD documentation for that airplane

 

Yeah, OK, my tongue is in my cheek.

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Many of the above concerns were addressed many years ago before many of you came to the CT family. Several have fleet LOA's.

 

An MRA is only to inform the MFG you made a change to your specific plane and to show the FAA there has been a change to a specific aircraft. If it was something that has already been addressed then the MRA only goes into your file. If you put something new in or made something new never addressed by the MFG or a fleet LOA you might get charged the $150 for FD's certification and or testing of that change to a CT.

 

You can't go wrong by sending in an MRA about a change. If it isn't needed it probably just goes into your file. If it has already been covered by FD it just goes in your file and if it is something brand new then it gets additional work to make sure you are legally covered.

 

Although many have adopted the military version of an MRA.

 

"Don't ask, Don't tell"  :)

 

Things like hose routing aren't covered by MRA's. Even FD hasn't been exact on each hose route over the years. Tire pressures aren't covered with MRA's. There are fleet approvals for this and isn't a design part of the plane, but a service item. MRA's usually cover design or parts change issues.

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An MRA is only to inform the MFG you made a change to your specific plane and to show the FAA there has been a change to a specific aircraft. If it was something that has already been addressed then the MRA only goes into your file. If you put something new in or made something new never addressed by the MFG or a fleet LOA you might get charged the $150 for FD's certification and or testing of that change to a CT.

 

 

Unfortunately this is not entirely the case anymore. Even fleetwide LOAs require an MRA, and you will still be charged.

 

I have been told though that once an MRA is done, you can go back and forth between old and new equipment without putting in an MRA, as an MRA is basically an approval process for installing new equipment. The old stuff is still approved.

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Unfortunately this is not entirely the case anymore. Even fleetwide LOAs require an MRA, and you will still be charged.

 

I have been told though that once an MRA is done, you can go back and forth between old and new equipment without putting in an MRA.

 

"As a bonus, once you make an expensive upgrade, you can go back to your crappy old equipment...at no charge!"   Sounds like infomercial marketing, lol!

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Unfortunately this is not entirely the case anymore. Even fleetwide LOAs require an MRA, and you will still be charged.

 

I have been told though that once an MRA is done, you can go back and forth between old and new equipment without putting in an MRA, as an MRA is basically an approval process for installing new equipment. The old stuff is still approved.

Appropriate log entries and weight and balance as indicated, I would assume?
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Hi All!

 

It would seem that the MRA system has changed a bit from a year ago. I just got off the phone with Dave at FD USA. FD Germany has advised FD USA that MRAs are required in the case of all alterations.

Corey,

Has FD USA or anyone sent out official documentation on this issue, since it is at variance with common practice over the past decade or so?

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Just trying to understand this.  "Even fleetwide LOAs require an MRA, and you will still be charged"

 

So, if an S-LSA owner removes the main gear wheel pants (for which there is a fleetwide LOA), the owner must still submit a MRA for that "alternation"?

 

Fred

2006 CTsw

E-LSA

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Just trying to understand this.  "Even fleetwide LOAs require an MRA, and you will still be charged"

 

So, if an S-LSA owner removes the main gear wheel pants (for which there is a fleetwide LOA), the owner must still submit a MRA for that "alternation"?

 

Fred

2006 CTsw

E-LSA

 

Removing the pants is not an alteration in the MRA sense. Installing a different size wheel pants, would be. MRAs are about approvals of installation of equipment and parts which are different than what originally shipped with the aircraft. I'm sure there's also an exception for manufacturer supplied parts when the old part is not available anymore either, such as the old vs new style fuel filters in the pod/mushroom (the old style is not sold anymore). If I have to fill out an MRA for a new part because the old ones can't be purchased anymore, I will tell FD to shove the $150 up their ass :-).

 

I've edited my first post to clarify "all" alterations.

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My understanding is:

 

Deviations from the design and equipment information for your particular serial number aircraft specified by your manufacturer requires a Letter of Authorization (LOA) from the manufacturer.

 

If you do maintenance or modifications that are not supported by your Maintenance Manual or procedures issued by the manufacturer, then you need an LOA.

 

Interfacing with the FAA on configuration management, design or equipment changes is the manufacturers responsibility.

 

Or am I missing something??

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The FAA supports acceptable methods and practices when maintaining LSAs as long as it is not contrary to the maintenance manuals. If they didn't, you would need an LOA for everything anyways because the flight design maintenance manuals leave a lot to be desired.

 

As for what "acceptable methods and practices" means, that's one of those judgement calls. The kind where the wrong one can get you in deep :).

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The FAA supports acceptable methods and practices when maintaining LSAs as long as it is not contrary to the maintenance manuals. If they didn't, you would need an LOA for everything anyways because the flight design maintenance manuals leave a lot to be desired.

 

As for what "acceptable methods and practices" means, that's one of those judgement calls. The kind where the wrong one can get you in deep :).

That's what it says in the regulations, but according to the Light Sport Branch there are no other means that are accepted other than the manufacturer.

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From the LSA FAQ put out by FAA. Looks like it confirms what Tom says, at least for SBs.

 

http://www.faa.gov/aircraft/gen_av/light_sport/media/LtSptAircraftFAQs.pdf

 

 

"8) I own a light sport airplane. The manufacturer issued a safety directive. Do I need to comply with the directive?

Yes, you must comply with the directive, but you have three ways to comply. One,

comply with the directive as written. Two, use an alternative method of compliance,

provided the person issuing the directive approves the action. Three, obtain a waiver

from the FAA. The FAA will only grant a waiver if the directive does not follow the

applicable consensus standard. (Reference: 14 CFR § 91.327)"

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