EASA "Minor Mod" process for STC
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EASA "Minor Mod" process for STC
Howdy experts !
I now hold an EASA issued STC (based on a validated US FAA STC) for a gross weight increase for all Cessna 182P and 182Q airplanes. Those familiar with these models know that they are equivalent to the former Reims F182P and F182Q models in all respects. (The "F" Type Certificate Data Sheet [TCDS], now held by Cessna, is identical to the original Cessna TCDS).
Since my original FAA STC did not include the "F" models, EASA could not "validate" those on the new STC, which I understand. However, I was told by EASA certification folks that "F" models could be handled under the EASA STC under a "minor mod" provision. My question is: How does this process work? Is it a big deal? For me as the STC holder, or for my customers?
And one related question: Just like FAA, EASA requires me to provide "third persons" installing the STC with written permission. Can anyone share with me the typical wording of such an EASA STC permission letter?
THANKS !
Tom
I now hold an EASA issued STC (based on a validated US FAA STC) for a gross weight increase for all Cessna 182P and 182Q airplanes. Those familiar with these models know that they are equivalent to the former Reims F182P and F182Q models in all respects. (The "F" Type Certificate Data Sheet [TCDS], now held by Cessna, is identical to the original Cessna TCDS).
Since my original FAA STC did not include the "F" models, EASA could not "validate" those on the new STC, which I understand. However, I was told by EASA certification folks that "F" models could be handled under the EASA STC under a "minor mod" provision. My question is: How does this process work? Is it a big deal? For me as the STC holder, or for my customers?
And one related question: Just like FAA, EASA requires me to provide "third persons" installing the STC with written permission. Can anyone share with me the typical wording of such an EASA STC permission letter?
THANKS !
Tom
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The Minor Mod Question
Sorry to "bump" my own post, but surely someone out there knows the answers or can share a typical EASA STC "Permission Letter". 
Thanks !
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If you hold an EASA Part 21J DOA, you can raise the minor mod to your STC yourself with no EASA involvement provided you've satisfied the classification requirements to justify the change as Minor. If you're not an EASA DOA, then you submit an EASA Form 32 Minor change application.
If, however, the change ends up being classified as a Major by EASA when you send in your Form 32, then you submit a Form 31 to EASA and go through the torture of a new investigation to prove something you already know - that the change is negligible and should have been a Minor anyway!
If, however, the change ends up being classified as a Major by EASA when you send in your Form 32, then you submit a Form 31 to EASA and go through the torture of a new investigation to prove something you already know - that the change is negligible and should have been a Minor anyway!
Last edited by wigglyamp; 11th Nov 2010 at 17:05. Reason: Added more information
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If the STC has been embodied previously in Europe pre a certain date ( that escapes me at the moment) on the same model under a mod, then you do not need a mod at all....... as it is recognised under grandfather rights, what is the STC?
see
http://www.pprune.org/engineers-tech...sna-152-a.html
see
http://www.pprune.org/engineers-tech...sna-152-a.html
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Hey Nutloose. That's very interesting. Thanks for your reply.
But, looks like "grandfather rights" won't be applicable to my EASA STC (10026913, issued 21 August 2009). As mentioned, it's a 68 kg increase in MTOM for Cessna 182P and 182Q airplanes, but does not specifically address the identical Reims "F" models.
The first Reims/European use of the EASA STC is now taking place for some 182P and 182Q airplanes in Finland, including the first F182P. I'm hoping it's going to go well, and have arranged with the AMO to keep me posted on progress (I'm hoping to learn something
). If I do, I'll consider posting a follow-up here.
Thanks again for your thoughts.
Tom
But, looks like "grandfather rights" won't be applicable to my EASA STC (10026913, issued 21 August 2009). As mentioned, it's a 68 kg increase in MTOM for Cessna 182P and 182Q airplanes, but does not specifically address the identical Reims "F" models.
The first Reims/European use of the EASA STC is now taking place for some 182P and 182Q airplanes in Finland, including the first F182P. I'm hoping it's going to go well, and have arranged with the AMO to keep me posted on progress (I'm hoping to learn something
). If I do, I'll consider posting a follow-up here.Thanks again for your thoughts.
Tom
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Tom, I would still check the German site and also the likes of the UK one, If the date is prior to that you may find the countries have their own mod to allow the weight increase, these do not show up on EASA's site as they are country driven ( or were) BUT they are covered under the Grandfather rights across EASA....... Does that make sense
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NutLoose, yes, that does make sense, but I doubt anyone has really done this before (it took me 3 years of effort just to get it through FAA 
). But I do find your notion very interesting and I appreciate you pointing out the differences atwixt EASA and other national CAAs.
Here in Norway, despite not being a true EU member, EASA regs are generally followed... I write "generally" because there are a number of exceptions where the Norwegian CAA wants to go its own way. I guess this is also the case even for many EU states.
Cheers,
Tom
). But I do find your notion very interesting and I appreciate you pointing out the differences atwixt EASA and other national CAAs.Here in Norway, despite not being a true EU member, EASA regs are generally followed... I write "generally" because there are a number of exceptions where the Norwegian CAA wants to go its own way. I guess this is also the case even for many EU states.
Cheers,
Tom
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Well at the very least, you now know if you wish to add anything else in the future where to look
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Hello Tom
As you probably found out yourself by now, EASA is not as easy to convince as the FAA. I am usually dealing only with Electrics/Avionics Mods and not with structural or aerodynamical stuff.
From experience, it usually helps if you have some statement (Non technical objection - NTO) from the manufacturer to accompany your certification compliance. Normally the EASA process is pretty straight forward as a lot of the projects are then actually dealt by the NAAs, which are often easier to deal with as with Cologne.
I would first propose the same as the other ones did to check with the NAAs for the F-Models. Otherwise, I do not see why it should be a problem to create a minor change as addition to the STC without having to do too much work as the weight difference in relation to other should by negligible.
Another interesting approach to overcome the weight difference is the comparison to a similar modification. For the avionics Mods, we usually try to argue based on the comparison of weight and CG based on previously installed or similar certified equipment.
Maybe this helps a little bit further.
Regards,
DAniel
As you probably found out yourself by now, EASA is not as easy to convince as the FAA. I am usually dealing only with Electrics/Avionics Mods and not with structural or aerodynamical stuff.
From experience, it usually helps if you have some statement (Non technical objection - NTO) from the manufacturer to accompany your certification compliance. Normally the EASA process is pretty straight forward as a lot of the projects are then actually dealt by the NAAs, which are often easier to deal with as with Cologne.
I would first propose the same as the other ones did to check with the NAAs for the F-Models. Otherwise, I do not see why it should be a problem to create a minor change as addition to the STC without having to do too much work as the weight difference in relation to other should by negligible.
Another interesting approach to overcome the weight difference is the comparison to a similar modification. For the avionics Mods, we usually try to argue based on the comparison of weight and CG based on previously installed or similar certified equipment.
Maybe this helps a little bit further.
Regards,
DAniel
