[Chasnaisflyer]

Hello Robl and all who contributed to my request.
I have purchased a full replacement ignition kit which includes two Slick 6364 Magneto's and which are a direct replacement for the old 664s. These are PMA parts and there is an STC which affairms the suitability of the 6364 in place of the ,664, with the instructions for fitting.,( In fact it is a specific replacement as can be seen from the part numbering system)
I am in USA right now where I have purchased these parts.
My aircraft is based in France where it is maintained by a qualified engineer and signed off by a French CAMO. I trust my engineer absolutely, but I am aware that he spent his whole life in commercial aviation. He thinks big plane when it comes to paperwork and is frightening me to death with CAA, EASA Forms 32 and the rest of it. All of these things sing money for bureaucracy.
From others I have spoken to, including on this forum, it would seem that only a log book entry is required. My French built ,172h is privately operated.
It was suggested I contact aerofurb for an opinion, which I have failed to do because I do not know how to make the contact.
If aerofurb or anybody can help me with a persuasive argument for my engineer, I would really appreciate it.
As a footnote I would like to tell you that Champion/Slick have been excellent in support of my questions but they cannot help with. EASAland issues.

[aerofurb]

My view is as with you and Rob - the 664 magneto has been replaced by a 6364. I think there is enough evidence to show that this is the case including the Slick application guide.

Champion Slick Magneto Application Guide

Page 0-2 Para 0.2.1 says that:

Current production magnetos have four digits in the part number and that the current part number for 6 cylinder engines is 63xx, ie the 6300 Series.

Page 4-9 says the O-300-D magnetos are 6364 or 664

The TCDS will always lag behind.

I'm sure your engineer should be able to suss from that it's a simple model designation change - all Slick magnetos go thought this.

Another example is the C152 O-235 magnetos - the TCDS quotes a 4281 magneto but if you ring a part supplier, it is 4381 that is the current part number.

If you use the O-300-D parts catalog, I'm sure it will specify the 664 mag. Contact a part supplier and they will tell you the current part number is a 6364. No different to part number changes for Cessna or Piper (or any other airframe manufacturer for that matter) airframe parts. Parts catalogs rarely have the current part numbers.

I can't really advise you on how to convince your engineer apart from applying common sense after reading the manufacturer's application data.

Good luck!

PS I rarely venture onto the Tech part of the forum these days as most of the time after you spend a fair bit of time providing answers to questions posed, you never get a response from the OP. So they obviously weren't that interested in getting advice or are just plain ignorant....

[Chasnaisflyer]

Thank you aerofurb and everybody else who contributed.
Ron

[wigglyamp]

Interesting certification question.

PMA's come in a couple of varieties - one as a straight replacement, automatically acceptable to EASA where the specific airframe or engine is listed on the PMA certificate and the parts isn't classified as CRITICAL, and one used to approve parts under a modification. The EASA guidance is here: https://www.easa.europa.eu/document-lib ... n-2007003c
Here's an example of a the first sort of FAA PMA, for a replacement LED landing lamp: http://rgl.faa.gov/Regulatory_and_Guida ... 08004EE7E4

In the second case, the PMA is just the means of approving the manufactured part, and the installation approval is via an FAA STC (just as used with all S-Tec autopilots etc). In these cases where the PMA forms part of a modification and not just a replacement, the STC requires EASA validation before the parts can be installed.

In the case of the Slick magneto, the particular PMA in question is here: http://rgl.faa.gov/Regulatory_and_Guida ... ick%206364. There is no attached airframe/engine list and PMA states that the basis of approval is an FAA STC SE1220GL. If you then look at the STC, it then contains the approved model list of engines: http://www.airweb.faa.gov/Regulatory_an ... t=se1220gl

If we follow the EU/US bi-lateral : https://www.easa.europa.eu/document-lib ... nts/eu-usa , then according to the TIP section 2.8.2 (a) the PMA part can be accepted if the part is not critical, OR it's made under a licensing agreement, OR the PMA holder is the holder of an EASA STC which incorporates the PMA part.
In this case, the there doesn't appear to be an EASA validation of the STC and I've looked at the UK, German LBA and Swedish CAA lists as these are all I have access to and can't find any such approval. However, if the part isn't classed as CRITICAL per the TIP, then it should be acceptable in any case as a replacement, so as long as the FAA 8130-3 states: 'This PMA part is not a critical component' in Block 13, in which case it's good to go with just a logbook entry. However, if it is shown as a critical part then the FAA STC would require EASA validation per TIP 2.8.2 (b) (3) before the parts can be accepted.

[Kemble Pitts]

Your engineer might come over as pedantic but he is right.

If a Regulator asks him "what document did you change that magneto in accordance with"? he needs to be able to point to approved design data that tells him he can do it (on that aircraft type) and how to do it.

If he can't then he's liable to lose his licence/approval.

Wigglyamp has made a very good input but I suspect you'd have a task on your hands to claim that magnetos were not 'critical' items.

[Chasnaisflyer]

Thank you to everybody that contributed to this discussion which had helped me resolve everything in a good way.
R.T.

[skydriller]

While investigating a possible magneto issue for a french pilot friend, I came across this from the CAA about magneto problems. Having also just read through this thread as part of that search I remembered it and thought it might be relevant.

At the bottom it specifically mentions replacement of slick magnetos 6xx with 6xxx etc. so it would appear to be OK to do so, considering they are suggesting you do so!!

[url]http://caa.gov.il/index.php?option=com_docman&view=download&category_slug=2014&alias=4762-magneto-defects-1&Itemid=669&lang=he
[/url]

Regards, SD..