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EASA proposal to relax modification approval

10 Posts

here

NPA PDF

There is a lot of this in there

which is pretty amazing!

Administrator
Shoreham EGKA, United Kingdom

Hoping this would be accepted. It for sure seems to be more senseable.

JP-Avionics
EHMZ

I don’t see anything wrong with EASA admitting the FAA has been doing this long enough to “get it right”.

Great Oakley, U.K. & KTKI, USA

whoa! this is huge! we’ve been wishing that for years… does that mean US STCs will be validated??

ORTAC

No, it’s about broadening the scope where an STC is not required.

Also, it’s not accepted yet. As always in politics, somebody wants something and creates a bill. Others don’t really want it so they start changing the bill. In the end you can hope that there is still something left from the original intention.

This seems to be a realization in EASA that they have over regulated the lighter end of GA to a point were common sense and practicality had become extinguished. No doubt some of the old guard will fight these proposals tooth and nail but on the whole this is very good news.

I can only speculate at the culture shock that will be felt in the corridors of the more conservitive aviation authorities if these proposals become law.

There are moves to validate all STC’s but I think that it may be only after the dust has settled from the first big changes that this will happen.

This just came out from the UK CAA:

Owners and operators of ‘Annex 2’ aircraft, such as ex-military and vintage types eligible for a Certificate of Airworthiness (CofA), can now install any minor modification or change supported by a Supplemental Type Certificate (STC) that was approved by a state with which the UK holds a bilateral agreement – such as the US or Canada – without further CAA involvement.

The value of CofA aircraft just jumped by 20%.

Now, what FAA STCs are available for the Bleriot XI?

EGEO

But an STC = MAJOR MOD.

So this doesn’t make sense.

The only FAA STCs for Minor mods are the “marketing” STCs desired by A&Ps who are illiterate e.g. Concorde batteries.

Administrator
Shoreham EGKA, United Kingdom

I suspect this is dodgy wording in a press release. Here is the actual regulation:

Supplemental Type Certificate
The involvement of the CAA for the approval of a Supplemental Type Cer-tificate (STC) shall be dependent upon the applicant being able to demonstrate that the design change has been approved. The CAA will consider an STC to be approved, without further showing if:
• a bilateral agreement is in place with the State of Design for the STC; or
• the State of Design for the aircraft has issued the STC; or
• the change has been approved by the competent authority of an EASA member State
and that:
• there is sufficient technical evidence of the applicability of the design change to the aircraft;
• there is appropriate approval documentation for the design change from the applicable NAA identified above;
• continued airworthiness information where applicable is available and integrated into the appropriate maintenance programme;
• the embodiment is subsequently recorded in the maintenance records for the aircraft.

EGEO

Of the 7 points bulleted:

1 – “for the STC” means exactly what? The UK CAA has had a bilateral with the FAA for many years.
2 – what does this mean? State of Design?
4 – this is a killer which makes most FAA STCs worthless in EASA-land… see below
5 – this also makes it worthless in most cases (the US STC holder is unlikely to co-operate this far)

Regarding #4 (sufficient tech evidence): let’s say there is an STC for a TB20/IO540C4D5D for a Sky-Tec lightweight starter. On an N-reg you can just install it. On an EASA-reg you will have to prove that all wiring, starter relay, any other relay in the circuit, etc, can carry the starter current.

I have picked a bad example for my argument because this is actually an issue in reality – see e.g. here.

A more obvious case is a MOGAS STC. A MOGAS STC for an engine alone is nonsense. You have to make sure the whole fuel system (seals and sealants and hose materials) can take the alcohol %.

But such a proof requirement undermines the STC system. For example, it renders AML STCs void because you can’t prove that GPS Model X will not be affected by DME Model Y, etc.

Who will decide what “sufficient” means?

IOW, it’s great for gold plating.

Administrator
Shoreham EGKA, United Kingdom
10 Posts
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