Yes, but the FAA does it just like EASA, as far as I know.
I don't understand why a plane or a radio certified by the FAA should automatically be certified by EASA.
Because it is more cost effective and it worked for several decades before EASA came along? Before EASA, smaller NAAs (like FOCA) basically just rubber stamped US approvals.
Yes, but the FAA does it just like EASA, as far as I know.
The FAA's market size is maybe a decade bigger, their safety record better by a factor of 2, their regulatory induced cost lower. They don't need us, we need them.
Although interestingly when speaking with a company which does STCs recently, they are now finding EASA easier to deal with as you pay your money and there is a decision made. FAA is cheaper but with the shutdown, sequester etc is becoming very hard to get to make quick decisions or decisions at all. That makes it tough for commercial organisations.
Interesting to get a different perspective.
As far as I can tell, dealing with FAA FSDOs outside the USA has always ranged from hard to impossible.
They seem to be regarded by the FAA as remote outposts where anything goes
and complaints to the USA are a waste of time.
Every attempt I did (usually via an avionics shop) to get something approved was aborted, due to endless nonsense, or – as in [this project](http://www.peter2000.co.uk/aviation/sn3500/) – the FSDO simply stating complete rubbish e.g. EHSI=EFIS and “therefore” an STC is mandatory… and you can’t go US-style FSDO-shopping if you get what they call a knucklehead inspector, because there is nowhere else to go. Especially as Heathrow has been shut so you just have Frankfurt.
That is why the more specialised avionics shops that are willing to take on nontrivial-paperwork projects use a DER (the US equivalent of an EASA Part 21 design company) to generate an 8110-3 design package, and they send the 337 with the 8110 directly to the FAA (AFS-750) in Oklahoma for filing. Done that way, the FAA doesn’t look at it. It is just like a 337 backed by an STC.
Only 337s for Field Approvals (basically a Major Alteration for which there is no airframe-applicable STC) need FSDO approval and they remain difficult as ever for Europeans. The only practical way to do those is via a contact in the USA who sits down with an FSDO inspector in your behalf. I have done two of those so far (the Sandel EHSI and the KLN94 GPS approach AFMS) and have one coming up (the B&C backup alternator) for which a nice guy (A&P/IA) will sit down with the inspector, for maybe $1k.
The downside of the DER route is that the cost has to be passed on to the customer. I have heard that derassociates.com start at $300 for a simple one-page job (they never return emails unless you are an avionics shop). Typically this gets billed to the customer at about 2000 quid and that also covers some preparation done by the European shop. But one can pay much more if the shop can’t do any design work and offloads the lot onto the DER – I have seen $10k quoted for a 1 page drawing which would have been about 2 days’ work.
The other downside of the DER route is that almost no DER has the authority to generate an AFMS, so if you need that (say for a GPS approach approval) you are screwed, and the only easy option is to blow a load of €€€ on a box that comes with an AML STC which comes with the required AFMS (Garmin or Garmin or Garmin). Needless to say G love this situation.
The upside for the shop is they can use the 8110, paid for by the customer, to get an EASA STC which they can sell to other shops 
That’s why some shops say you (N-reg) need the DER package, maybe for some small part of the job, when actually there is an FAA STC already…
So, yeah, EASA is going to be the lower-resistance route for people who are resource- or knowledge-limited, because you can follow it with a liberal application of €€€.
Whether it would make me go N-reg to EASA-reg…. absolutely NO WAY.
Interesting perspective.
The major factor I consider is the fact that within the FAA they work with Approved Model Lists for a lot of Avionics and other appliances. If your plane is in it, install and be done with it, if not, things get complicated. And for whatever an STC exists, buy the part and have it installed.
The EASA way means you need an STC for EACH MODEL separately and expensively. Equally, you need a new approval and STC for each software revision. When I talked to Avionic shops about installing the Aspen, they told me the STC alone costs a few thousand € plus then you get the oldest software revision as a minor change, if you want the newest one (or a newer one) you need a major change which again means €€€ to EASA. Add to that major paperwork and engineering drawings e.t.c. to be submitted makes an installation of such a device 4-5 times as expensive as it should be.
Likewise with STC’s. If the STC was around before the new Empire hit, you need to find a reference installaton in Europe and can install with a work report, if not, either there is an EASA STC or basically forget it. FAA AML’s or FAA STC’s are regarded as non existent.
I’ve been looking for some “reference installations” for a couple of Mooney STC’s where the owners also would be willing to give me copies of the paperwork to satisfy our FOCA that it really is the same plane e.t.c. Workload, time wasted e.t.c. is horrendous.
Best regards
Urs
Historically, EASA was very much against the whole idea of AML STCs.
A widespread view is that the reason is that EASA employs a lot of ex Part 21 people, and a lot of EASA people are close friends with the Part 21 industry. Of course everybody in the industry denies this.
Then Garmin came along and somehow managed to change EASA’s way of thinking, which gave Garmin a massive commercial advantage.
The certification grandfathering concession which EASA brought in c. 2003 (almost the only good thing EASA has actually delivered to date, IMHO) is of limited value because there is not much of a central database of approvals. The UK CAA has a database (which has not been updated since about 2003) and I think Germany has one. These should point to an avionics installer who might sell you the paperwork they did. But I doubt there will be many Aspen installs in there as that’s quite a recent product.
FAA AML STCs are also very good in the USA, because you don’t have to deal with FSDO inspectors!
Aspen have a EASA STC owned by Avionic Straubing. They had to certify each and every type and subtype as well as each and every software revision. This and the engineering docs they need to do for each installation rise install costs to about a factor of 2.5 to 3 in comparison to American ones.
The reference installs I am looking for are e.g. the LASAR cowling mods e.t.c. Interestingly, LASAR themselfs have preciously few lists of which airplane has their stuff installed. The thing with the grandfather rights is the only saving thing for many of these mods, which would be otherwise uninstallable in Europe. Since 2003, most of the newer mods STC’d in the US are impossible to install here, likewise a lot of folk who buy N-reg planes in the US and try to import them find they have to REMOVE installed STC’s in order to be able to register.
The easiest way for most of us would be that STC’s should be issued by the country under whose jurisdiction the product STC’d is produced and then issued as an ICAO STC which every member state has to accept. Of course this means oversight in case of “convenience countries” but certainly for EASA and FAA this would be the way to go. Likewise, there is no reason aircraft need multiple certificates. The fact that the FAA always insisted on their own has much contributed to the status quo where Europe does the same but with prussian maximum thoroughness.
>FAA AML STCs are also very good
That is how it should be everywhere. I don’t care who issues those STC’s as long as they apply!!!
>Since 2003, most of the newer mods STC’d in the US are impossible to install here
They are not actually impossible. If you throw money at an EASA Part 21 company, they can do it.
What probably happened is that enough big people threw big money at Straubing.
I am sure Straubing were most unhappy about that, but it looks like they eventually caved in
And once you have one approval you can generate others on the back of that.
The vast majority of avionics shops can’t do that. They could buy the paperwork pack from Straubing, or one of the other firms (Lees Avionics, now GAMA, has been a big STC seller in the UK) but they often don’t want to because it makes them look less competent, and of course puts them at a commercial disadvantage to the STC holder. But a lot of design pack selling does take place. A typical paperwork pack price here seems to be about 1.5k for a GPS install.
The smaller firms often just say they can’t do the work, or they quote for it on the basis of “customer is responsible for approvals” which is outrageous because most customers will never realise what that means… I’ve had quotes for a GNS530W and other stuff, like that. I think most GNS430 boxes went in like that (no AFMS etc).
Almost nothing is impossible. I personally know one pilot who spent £8000 certifying a composite oxygen cylinder, in place of his steel one. On an N-reg it would have been easy. On a G-reg… I recall he had to buy a second one and destroy it, as a part of the application.
There is a separate argument about the way an STC is an intellectual property of the STC holder. That makes sense if there is something novel in it, but there almost never is. The design is straight out of the installation manuals. Yet the STC holder obtains a theoretical commercial monopoly on that installation design.
> There is a separate argument about the way an STC is an intellectual property of the STC holder. That makes sense if there is something novel in it, but there almost never is. The design is straight out of the installation manuals. Yet the STC holder obtains a theoretical commercial monopoly on that installation design.
Even in the US, with an STC or AML STC, there is substantial investment by the manufacturer or STC owner to test and obtain approval. The argument of a STC AML is there isn’t anything unique required for most models. In most cases, for a manufacturer is that the commercial interest is in getting the equipment installed and approved. If a third party develops an STC, then their interest is in selling the STC. Even in the US, software updates need to be certified prior to being made available. First comes the TSO approval, which leaves certification of the installation up to the user. Then often a month or so later comes the STC approval. Only then may the software update be added to an installation that uses the STC. Most wait until they can install it as an update to the STC and it is a minor operation, rather than tackling there own certification.
The STC AML for Garmin installations includes support for many specific devices that interface to their equipment or devices that meet a specific TSO and interface requirements established by the STC. In cases where an STC does not support a device that is interfaced to the STC installation, one must seek a field approval for the non supported device. These get written up as a 337 with a field approval something like this: Garmin GTN750 installed in accordance with STC xxxxxxxW installed except for …
If the device supports the interface, then approval is relatively easy to obtain.
>What probably happened is that enough big people threw big money at Straubing.
What I understood is that they wanted to be the ones to be able to offer the Aspen PFD and therefore undertook the STC by themselves with the help and cooperation of Aspen, who were desparate to get a foot into Europe.
Anyone who wishes to install one today in Europe needs to buy their STC. I don’t complain, as at least there is an STC and the guys in Straubing know their job well.
I had a pretty good talk with one of the larger Avionic companies in the last few days and they are now looking into a solution for my particular wishlist. In General however, they say that their business with smaller airplanes has gone down by about 80% in recent years, there is an almost total stop of people upgrading unless forced by EASA’s new rules. Right now there is a frenzy with 8.33 boxes which everyone will need shortly. A lot of people are looking to buy 2nd hand GNS430 boxes now due to that, some of which come on the market due to the GTN series. Garmin had apparently tried to prevent re-use of those boxes by saying they HAVE to be upgraded to WAAS for re-install but were shown the finger, so now they are trying to pull support for them. Apparently they are facing a possible class action in the US due to that, that is why they have not done it yet. Monopolies are never fun.
Maintenance in Europe and with it Avionic upgrade have reached price ranges where they render a lot of older airframes simply obsolete. If an IFR upgrade is more expensive than a used Cirrus, a lot of folks will go that way. And even more will simply give up and try to get a minimal damage recovery out of their old airplanes before shredding their licenses. Reckon that is what I’ll do in the near future.
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