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EASA and FAA different approach for STC

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FAA – 09/27/07 AC 21-40A
c. Any individual or company may apply to change a type-certificated aircraft, aircraft
engine, or propeller.
EASA – https://www.easa.europa.eu/document-library/application-forms/focert00031
Eligibility: To apply for a Major Change or a derivative, you must be the Type certificate holder of the product.

The EASA only allows holders of the type certificate of an airplane to apply for an STC, in the US anybody can submit a project for an STC approval (whether they get it is another question) Given that a large amount of the current install base in Europe is of American origin – pipers, mooneys, cirrus etc, why do you think the EASA made their approach more restrictive than the FAA?
This of course makes it next to impossible for European avionics companies or other entities to develop products to the current install base – the aveo wingtips for Mooney planes had to be sent to the mooney factory for approval (which might explain why they have been in EASA MOD Certification pending status for 2 years)
It also might explain why their is such a paucity of efforts to develop STC solutions for European market specific issues – such as diesel engine retrofit kits, imagine a skydemon nav/com

aidanf123 wrote:

EASA –
Eligibility: To apply for a Major Change or a derivative, you must be the Type certificate holder of the product.

<Facepalm>

ELLX

aidanf123 wrote:

The EASA only allows holders of the type certificate of an airplane to apply for an STC

Wrong, see proof here. Furthermore, a TC holder does not need an STC, it can amend the original TC.

LKBU (near Prague), Czech Republic

I looked it up, under part e anybody can apply for an stc however only under certain onerous circumstances ie you need the approval of the tc holder that they have no objections.
where, under point 21.A.113(b), the applicant has entered into an arrangement with the type-certificate holder,

1. the type-certificate holder has advised that it has no technical objection to the information submitted under point 21.A.93; and

2. the type-certificate holder has agreed to collaborate with the supplemental type-certificate holder to ensure discharge of all obligations for continued airworthiness of the changed product through compliance with points 21.A.44 and 21.A.118A.

21.A.116 Transferability

A couple of previous posts on EASA acceptance of FAA STCs are here. There is as yet no direct unconditional acceptance; AFAIK only Australia does that.

Anyone can apply for an STC and generally the TC holder is not involved. In some cases the TC holder would be hostile to it e.g. Piper really hate the Jetprop STC, and Garmin offered no co-operation for G600 STCs for the King Air, etc.

Whether the process is economical is an entirely separate matter. It’s quite a route for a US STC holder to get the EASA version and most can’t be bothered for the small European market.

Administrator
Shoreham EGKA, United Kingdom

@aidanf123, you are misinterpreting the regulation. This TC holder’s agreement is only necessary when the STC is issued through an arrangement with the TC holder. If the STC developer has adequate resources of its own, nothing is required. I know the situation firsthand because I do documentation-related work for a company that developed two STCs seriously disliked by the TC holder.

LKBU (near Prague), Czech Republic

This is good insight – thank you – still hold onto my dreams of retrofitting to continental 155 diesels onto a twin comanche!!!

Two completely different things!

aidanf123 wrote:

FAA – 09/27/07 AC 21-40A
c. Any individual or company may apply to change a type-certificated aircraft, aircraft
engine, or propeller.

“Change a type certificated aircraft” is completely different from “change a type certificate” that is referred to here:

EASA – https://www.easa.europa.eu/document-library/application-forms/focert00031
Eligibility: To apply for a Major Change or a derivative, you must be the Type certificate holder of the product.
Germany

The rule does a reasonably good job of explaining:

21.A.92 Eligibility
(a) Only the type-certificate holder may apply for approval of a major change to a type design under this Subpart; all other applicants for a major change to a type design shall apply under Subpart E.
(b) Any natural or legal person may apply for approval of a minor change to a type design under this Subpart.

Subpart E is the bit on “Supplemental Type Certificates”.

So changes are either minor or major. Major changes applied for by the TC holders are called “major changes”. Major changes applied for by others are called “STCs”.

Another EASA provision on validation of FAA STCs may be of interest, as it allows validation by an owner without the participation/permission of the original STC holder. As far as I know, there is no equivalent FAA provision.

Major changes applied for by others are called “STCs”.

Maybe I am misreading it but I thought you (a person, though more typically an EASA21 avionics shop) can apply to EASA for a Major Change, without going for an STC.

How did you do the Twin Com vortex generators? I recall reading about it years ago.

Another EASA provision on validation of FAA STCs may be of interest, as it allows validation by an owner without the participation/permission of the original STC holder. As far as I know, there is no equivalent FAA provision.

That must be this.

There are various ways to work the system. This one is also quite amusing but has some excellent explanations by wigglyamp.

Administrator
Shoreham EGKA, United Kingdom
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