Throughout your ownership of an aircraft, you will likely need to modify your plane at some point. This could be refurbishing the interior, installing new avionics to meet new requirements, or upgrading the communications system and entertainment. These are fairly common items that occur throughout an ownership cycle, but we caution clients that modifications to your jet can have an expensive impact on your future resale if not done properly.
An aircraft being airworthy in one jurisdiction, such as EASA, does not mean it is legally airworthy in another, such as the FAA. As you modify parts or the configuration of your jet, it is important to ensure that it is modified to be accepted by the FAA and EASA. If the modifications are not completed in accordance with both standards, these modifications can prevent an aircraft being accepted by another jurisdiction in the event of an export/import at resale.
We have recently seen particular problems with seatbelt installation paperwork. The FAA is taking issue with some seatbelts installed by certain facilities under EASA jurisdiction and are refusing to accept them under the FAA jurisdiction. In the worst case scenario, this can mean the purchase of all new seat belts – a time consuming and expensive endeavour.
The best thing you can do is to get a “dual release” for any modifications done. A dual release is the ability for a maintenance shop to certify parts and modifications to FAA and EASA standards. This will limit your choice of maintenance facilities and may not be the lowest price, but it will save you heartache and money when you try to resell and export your jet (changing parts or modifications at exportation will be very costly).
Pay attention to interior paperwork such as burn certificates for materials used in your cabin as well. The requirements and standards are the same in FAA and EASA, but you have to have documentation to prove it was done to both standards.
Whenever you make a modification to your aircraft, EASA usually mandates you get a Part 21-approved engineering company to create a formal modification package, which is typically accepted by the FAA and EASA. However, some European maintenance facilities still (improperly) do work without a Part 21 modification which becomes very problematic when discovered, as it could require the modification to be redone with a Part 21 design paperwork attached. The Part 21 is fairly new and many owners still go to these places that do not offer the correct package because they are cheaper and the Part 21 approvals are relatively unknown outside of aviation experts.
Speak candidly with your operator and CAMO and tell them to ensure that your modifications are done appropriately and that you have the proper paperwork to prove it. Your future self will thank you for it.
Blogs are written from real world experience by Colibri Aircraft’s individuals. If you have any questions or comments about the topic of this blog, please feel free to contact us at enquiries@colibriaircraft.com
