EMAG P Model as minor alteration

[Drew M20E]

I know I am going to get abused for even starting this thread but here is goes. I am getting ready to replace my left bendix magneto and shower of sparks system, 1966 E model. I know the STC routes that I can take but after reviewing my model specific TCDS and lycomings newest service Service Instruction SI1569B, has anyone looked into the possibility of installing the EMAG P Model as a minor alteration under IA approval? Before anyone asks why, I believe having a built in alternator is a huge advantage over battery backup for EIS. Please be gentle.

[cctsurf]

Just a brief examination of the SI shows this:

At the engine level, an EIS may be installed replacing one or both of the engine’s traditional magnetos as a
minor alteration documented with an engine logbook entry. Current FAA guidance is that the required
airframe electrical system alterations needed for a single EIS installation may be accomplished by either minor
or major alteration. The installer can decide which type of alteration is best for their application. Lycoming
is providing the following recommendations based on this guidance:
1. If the installer considers the airframe alteration a minor alteration, this Service Instruction, FAA Advisory
Circular 43.13-1B and 2B, and other Advisory Circulars or applicable information can be referenced in
the airframe logbook as acceptable data.
2. If the installer considers the airframe alteration a major alteration requiring an FAA Form 337, this Service
Instruction, specific sections, chapters, and paragraphs used from FAA Advisory Circular 43.13-1B and
2B, and other approved instructions can be referenced in Block 8 of the Form 337 as approved data along
with the appropriate airframe logbook entry. If the installer does not have sufficient approved data to
substantiate the alteration, they should obtain approval of their acceptable data by an Aviation Safety
Inspector (field approval) or appropriately rated Designated Engineering Representative

https://www.lycoming.com/sites/default/files/SI1569B-Installation_Operation_and_Maintenance_of_Lycoming_EIS.pdf

I would like to see chapter and verse from the FAA, not from Lycoming...  But from what they are saying, it sounds like they believe it could be done... 

I just completed my Surefly installation paperwork and they didn't mention this possibility in their installation documentation...  We filed the 337.  I would have LOVED the E-Mag!

[jetdriven]

No

[1964-M20E]

Interesting maybe the approach will work, I agree I like the E-mag better than any other EIS.  The service bulletin is written for the Lycoming EIS.  The issue withe the E-mag is they use automotive style spark plugs.  Maybe that will get into the major alteration class.  I really wish E0-mag would have used a standard Bendix or slick harness and standard plugs approvals wold probably be faster and easier. 

[jetdriven]

I can see how installing an EIS may be considered a minor alteration but an experimental electronic ignition system isnt going to be so easy, it might as well be something home made, or a MSD-6AL racecar system from the speed shop. Its not a type-certificated or STC'd part.

A Weber carburetor surely would run smoother and better than a MA4A Marvel carb, but its the same thing.

Edited November 27, 2021 by jetdriven

[takair]

I read the SB as being very specific to the Lycoming EIS. Any reference within the document is implied to be the Lycoming EIS, not a generic EIS. I think they had to bring this out because they don’t have the same STC package out there that Surefly has, and many IAs have been installing those with the dual airframe and power plant STC. I don’t think they intended this for other peoples systems. I’m sure a call to Lycoming could help clear it up. I think any other system would need pedigree to get approved. Just the fact that a specific flight manual and ICA would need to be approved, would likely make it a major alteration and likely need an STC. If those are somehow available for the P Mag, then that might change things. 

[EricJ]

2 hours ago, takair said:

I read the SB as being very specific to the Lycoming EIS. Any reference within the document is implied to be the Lycoming EIS, not a generic EIS. I think they had to bring this out because they don’t have the same STC package out there that Surefly has, and many IAs have been installing those with the dual airframe and power plant STC. I don’t think thy intended this for other peoples systems. I’m sure a call to Lycoming could help clear it up. I think any other system would need pedigree to get approved. Just the fact that a specific flight manual and ICA would need to be approved, would likely make it a major alteration and likely need an STC. If those are somehow bailable for the P Mag, then that might change things. 

Actually the definition of major alterations makes it a major alteration.    FAR 43 Appendix A (a)(2)(iii) Installation of an accessory which is not approved for the engine.

That's a major alteration.

[carusoam]

Drew,

It looks like you are attracting heat for the system type you have selected…

Are you familiar with the experimental nature vs. the other similar devices that have STCs already?

Plenty of the STC’d variety being installed…

Mostly of one brand, vs. any other…

Even the re-badged version of the same manufacturer aren’t getting much play… for real reasons…

 

Too much effort to get something reliable, when on the bleeding edge…

 

Go ahead and supply your logic for going down this path… the more you support your own idea, the more support you can get from others thinking the same thing…

PP thoughts only, not a mechanic or web guy…

Best regards,

-a-

[DXB]

I've always wondered why the Surefly folks went for ship's battery as the power source and not the internal alternator of the E-mag, which seems like a much more elegant solution, assuming it's durable and reliable. Now Surefly is supposedly close to a second mag replacement, but that one will use the ship's backup 2nd battery if it has one, or require install of a separate battery pack. That makes the dual replacement system seem FAR inferior to the E-mag.  Now, I suspect the Surefly designers are very smart, capable folks.  Does that imply that there are inherent flaws and/or high regulatory barriers to an STC for such an electronic ignition system? Or maybe E-mag's patent protections for the internal alternator simply too restrictive? Given Surefly's incredible success, perhaps they could just buy E-mag to overcome such barriers?

[Drew M20E]

When I posted this, the intent was not to ruffle feathers or begin arguments. It was to see what information could be ascertained from a large group of knowable people.  I fully comprehend the differences between certified and experimental.  The lycoming SI does pertain to their version of Surefly, I get that, it was the fact that they suggest a minor alteration for it is what got my attention.  My specific TCDS does not specify ignition type and along with the FAA AC 23-27 for vintage aircraft I was not sure if there was room for a possible IA decision instead of the field approval route.  As far as the park plug issue, I would have looked into New Horizons to see if one could be fabricated to accept aircraft plugs. I do appreciate everyone's feedback.

[EricJ]

53 minutes ago, Drew M20E said:

When I posted this, the intent was not to ruffle feathers or begin arguments. It was to see what information could be ascertained from a large group of knowable people.  I fully comprehend the differences between certified and experimental.  The lycoming SI does pertain to their version of Surefly, I get that, it was the fact that they suggest a minor alteration for it is what got my attention.  My specific TCDS does not specify ignition type and along with the FAA AC 23-27 for vintage aircraft I was not sure if there was room for a possible IA decision instead of the field approval route.  As far as the park plug issue, I would have looked into New Horizons to see if one could be fabricated to accept aircraft plugs. I do appreciate everyone's feedback.

The TCDS for your engine (1E10, see Note 7) will specify the approved ignition systems for that engine.   Lycoming can approve, and has, additional ignition systems, so you can install any "approved" accessory via the engine TCDS, approvals from Lycoming, or accessories specifically STC'ed for that engine, which also provides "approval".   Naturally the only electronic ignition Lycoming has approved, to my knowledge, is the EIS.   Anything else without approval will be a major alteration.    Sometimes even "approved" items are treated as major alterations (e.g., many STC's are treated as major alterations), but the STC provides the "approved data" for the alteration which makes the 337 form pretty straightfoward.    Without such approved data a major alteration would require sufficient independent data, e.g., from a DER, to support a field approval via a 337.

AC 23-27 doesn't really provide an easy means to circumvent that process for major alterations.

Edit:   BTW, I don't think you've ruffled any feathers.   It's a good question and I think sometimes people give up on exploring such possibilities too easily.  

Edited November 29, 2021 by EricJ

[N201MKTurbo]

If it was as simple as you suggest, there would be many already installed. I’m sure EMAG would be advertising it.

[carusoam]

New Horizons is around here somewhere… @HoJo87

Their Maggie  ignition wire harness is widely accepted around here…

It got placed on many new SureFly installs, for people looking for a new half harness…

 

The SureFly gained a ton of traction… there were a few install issues that only pertained to a random handful of some engines…

A single gear attribute that was important to SureFly ops, was not important to existing mag ops….  Some of the gears in the field needed to be swapped for a different gear to get proper timing…

 

Just when you think it can’t get easier than installing a standard device… on a 50yr old machine…. You may find there are a lot of changes over the 50yrs… adding to the challenges…

 

We have found lately… many things start in the experimental category… and then move to the certified world when ready…

The experimental world allows for experimentation and updates at a rapid pace…

 

Soooo….

If you find something working really well in the experimental world… it is possible for it to move towards the certified world…

There is plenty of manufacturing control rules that are required on top of the proof of design work we are more familiar with…

 

It helps to have patience if waiting for a new technology is in the plan… 

If your plane is a forever-plane… expect to see a few interesting opportunities in your ownership time line…

 

Share the details that you like and dislike about this device…

When you look back a decade from now… (use the search…). You may be surprised…. At what has occurred, and how your thinking may have changed….  

 

Fun times ahead…

-a-