Who owns STCs?

[soay]

I want to install a piece of electronic equipment in my SEP aircraft. The aircraft manufacturer has obtained an STC for this product that's valid in EASA land. I've lined up an electronics shop to do the work, but they cannot proceed until they have the technical details documented in the STC. The aircraft manufacturer has ignored all requests for information about the STC. If they refuse to play ball, is the only solution to start again from scratch?

Thanks

[forget]

http://www.airweb.faa.gov/Regulatory_and_Guidance_Library/rgstc.nsf/MainFrame?OpenFrameSet

[Pilot DAR]

If the FAA database does not easily yield your answer, I might be able to be of some help, but would need more information. You are welcomed to PM me.

Pilot DAR

[IO540]

There are two issues here, AIUI.

The STC constitutes "approved data" for the item, and you may need a copy of it to get the full installation instructions (unless it is trivial like e.g. a battery, or it comes with an installation manual anyway).

The STC is also supposedly the intellectual property of the STC holder and you are not allowed to install the item in accordance with the STC without the STC holder's permission. Normally, a purchase of the item is said to be good enough for this purpose..... Some STC holders get a bit funny about this stuff though, even though a lot of STCs contain no intellectual property because they are based on widespread prior art (avionics installations in particular are usually no more than collections of wiring diagram segments compiled from the various installation manuals). This applies to a lot of EASA avionics STCs which exist only because EASA has created a commercial opportunity for re-packaging product documentation which is used straight off in the USA without question ;)

[soay]

Thanks for the responses so far.

There is an FAA STC, but I've been informed that it doesn't help much as its use would still fall into the Major Modification category for EASA approval. I understand that the complications arise due to the composite airframe, but the FAA vs. EASA difference just seems to be red tape to me.

The product is made by Avidyne, who hold the FAA STC and have been as helpful as they can, but the sticking point is getting the EASA STC out of the aircraft manufacturer. They have quoted for the work, but at a much higher price than the UK avionics shop, plus the cost of the 12 hours return flying time to their factory. There ought to be a European law against that!

[IO540]

If you have no EASA STC then all bets are off re the cost.

I think one UK avionics shop which generates EASA STCs is Lees Avionics.

The cost can be vast - I know somebody who spent £8000 on an EASA STC for one (non-avionics but otherwise trivial) item, before apparently giving up.

The American company may or may not co-operate. It is hardly in their interest to do so, with the vast uniform market right on their doorstep. EASA have done a good deed in grandfathering previous national-EU STCs all over the EU, and then they screwed it up by creating a nice gravy train for European firms with the EASA design authority creating paperwork packages which they sell on to others.

[Malcom]

Put your plane on the N reg and have done with all this EU mod clap-trap.

[soay]

That would be even more expensive, because it's a European aircraft without an FAA type certificate.

[IO540]

That seems the worst possible combination. No FAA TC means that the vast majority of aviation parts cannot be used on it (except unofficially ;) ).

[wigglyamp]

Just because a European-manufactured aircraft doesn't have an FAA TC doesn't mean you can't use American parts on it. Most parts for mods (I'm thinking particularly of avionic bits) will have an EASA ETSO, normally equivalent to the FAA version) and so will be eligible for installation on an EU aircraft subject to the necessary installation approval (EASA STC or minor change).

In terms of EASA creating a gravy-train for European design companies to copy FAA STCs and make loads of money for re-selling them, I'd love to see the evidence. As one of the writers of EASA STCs, I don't seem to have a healthy bank balance resulting from these supposed rip-off sales. Also, EASA tend to question much of what FAA have previously approved, leaving the European DOA and equipment manufacturer to do considerable additional substantiation against additional requirements before STCs get approved. Where FAA have guidance material but only require certification against a basic regulation (e.g FAR23), EASA will go much further and require full compliance to the guidance material (e.g AC23-1311-1b for glass cockpits) and the associated EASA CRIs, so we certainly don't get an easy ride!

[Malcom]

The easiest way would be to get the aircraft manufacturer to add the equipment by concocting a service bulletin to add it as an option. That way they keep their proprietry design stuff to themselves and you just fit the gear with the installation manuals provided with the kit. Any additional or special requirements etc can be addressed in the sb without going into all the whys and wherefores.

Best of luck in your "pushing treacle up a hill whilst trying to get a response from a bowl of dead flowers" mission!

[IO540]

I don't think anybody is getting particularly rich out of generating EASA STCs.

It does however remain a good job creation scheme, which is a waste of the customer's money because the same thing would be done in the USA on the existing FAA documentation (or even as a Minor Mod in many cases) and there is no demonstrated safety case for padding it out.

The fault is with EASA, not with the firms who naturally see a business opportunity and make money generating the EASA STCs and selling them on to other installers.

[soay]

The easiest way would be to get the aircraft manufacturer to add the equipment by concocting a service bulletin to add it as an option.
That's what I expected them to do. They obtained the STC in order that they could offer the equipment as an option on new aircraft, so if they can't sell those, it seems that they've decided to extract every last Euro out of any existing customers who are foolish enough to want any upgrades.

[ei-flyer]

Just learn how to fit the part yourself and don't tell anyone.

I don't understand why people get drawn into all this red tape rubbish, it's all pen to paper crap anyway...

[Malcom]

Thats ok for a small knurled flange bracket here and there, but a glass cockpit might be a bit obvious?

[Pilot DAR]

Just learn how to fit the part yourself and don't tell anyone.

I don't understand why people get drawn into all this red tape rubbish, it's all pen to paper crap anyway...


Truely an attitude worthy of ridicule. Exactly the attitude which our industry does not need to be associated with. Once you have read and understand AC43.13, and the various guidance materials associated with major vs minor modifications, and the privileges of non-maintenance trained persons to perform maintenance, come back and tell us about "pen to paper crap".

When you fly and aircraft which suffers a failure, do you expect informed understanding and resolution of that failure? Then always inform (with pen and paper) as to what was done to the aircraft!

Now, I'll have a read of the thread "Safety Does attitude count for more than experience", to see if the writer of the quoted statement is mentioned there....

It is my job to test modifications to evaluate design compliance, write the wording for, approve, and issue STC's. I do this, so the aircraft you might happen to fly, will do what you think it should, and will not do what you think it should not!

I'll respect and support your privilage to fly planes, if you'll respect and appreciate my job of assuring the modifications are done properly, AND DOCUMENTED!

[Malcom]

Trouble we have is that your tried & tested FAA STC is treated with so much contempt and dis-trust here in Easaland - like its been devised & sold by the devil just to bring untold mayhem here in Europe. Re-justifying all your work at extortionate rates is our lot in life if we want to do what you can do, and whilst wrong, will inevitably result in such attitudes.

Daft thing is you can bring your 172 thats been STC'd to the eyeballs over here and fly it anyway on your N reg. And park it next to my G reg 172 that its next to impossible to get STC'd the same. Just goes to show what EASA think of themselves and also their attitude to everybody else in the global theatre.

[Pilot DAR]

Having applied for, and obtained EASA STC's on behalf of my clients, I can say that it can be done. Though I agree, it was obvious to me that there was an attempt on the part of the EASA staff, to re-evaluate something which had been completely evaluated to the satisfaction of Transport Canada, and by people, who were apparently (to me) not at all familiar with what they were looking at. EASA needs to mature....

Something being "easy" or red tape rubbish does not confer upon the pilot/owner the legal or moral right to bypass the system. Work is accomplished on aircraft with no documentation. I know, becasue, from time to time, when it's found out, I am called to evaluated it, and if possible, find a way to approve it. Promoting such activity here is a very poor idea.

Presenting the idea of "fitting the part yourself and don't tell anyone" here is akin to saying "sure, go fly that rental plane beyond it's stated limitations". Posters here reel at the possibilty that some pilot might have zero G'd the plane they will fly next week, but seem completley comfortable (or at least silent) with unapproved maintenance.

The attitude toward safe flying crosses all disciplines equally...

[IO540]

Having applied for, and obtained EASA STC's on behalf of my clients, I can say that it can be done.That's probably because you are a diligent person and you assist your customer with design data and this enables them to obtain the EASA STC.

Most U.S. companies are not interested in anything like that. Many are barely able (or willing) to dial a "foreign" fax number. And why should they? Some 90% of their world market is right on their doorstep; they chuck the thing in a box, chuck in the 8130-3 form, call UPS, and off it goes...

EASA justifies its "need" to recertify everything with phrases like "the world has changed" (an actual phrase from a letter I have from an ex Brit working at EASA), or another popular one "we are Europeans; we must have European, not American, solutions". Only someone who doesn't give a damn what anybody thinks of him would come out with this kind of stuff, which wouldn't be accepted by a 5 year old... "you can't have these sweets because I am bigger than you". EASA has no option because there is no safety case to support their policies; all their arguments are circular. And once not a virgin anymore, why should you care what people think of you?

I don't think anybody with a brain would seriously consider doing a major structural mod without approvals. And AFAIK GA accident history does not indicate that this goes on - at a level which is statistically relevant.

I do think many people see two areas differently though: avionics, and trivia.

EASA has made so many totally silly rulings on avionics that it is a complete farce. You can install 1 x GNS430 but you cannot install 2 x GNS430 because it cannot be "proven" that the failure of one won't bring down the other via the crossfil connection (and Garmin did not co-operate on the supply of data to "prove" it). The little issue of the single-GNS430 installation failing and leaving you with no GPS at all, seems to be lost on EASA ;) And this was on a plane which had 2 x GNS430 on its factory Type Cert, but hey that doesn't count because that was on a later S/N (but same aircraft type)...

All planes are full of trivia which is routinely "fixed" off the books. The joke about light bulbs (lamps in U.S. speak) is that the ones on AOC planes last for ever - the paperwork is so bad that people just change them off the books. The tighter one makes the regs, the more this will go on.

The FAA has a reasonable system where they define the Major Mods (p43 AppA) and everything else is a Minor Mod. Still, the borderline is routinely disputed, especially away from the US mainland, and anywhere where revenue generation is desired ;) In Europe, it is common to disregard the boundary totally and go for a DER approval (iow generate approved data from scratch for each job) every time - the ultimate 6 o'clock covering policy. This increases the cost of an installation by say £1000. So no wonder a lot is done off the books.

If my plane was full of illegal mods I would not be writing this, of course :) Luckily it is still 99% factory standard and the few trivial mods have gold plated paperwork :)