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STC on Reims Cessna EASA vs. FAA

I found this on the EASA website:

How does EASA deal with STCs on Reims-built Cessna models?

Answer

STCs approved on US-built Cessnas and their applicability to Reims-Cessna models.

Reims-Cessna was a French company that manufactured US-designed Cessna aircraft under licence. These included the F150, F152, F172, F177, F182, F337, F406 and their variants. These aircraft were identical to the US-built aircraft but the French aircraft were given DGAC Type Certificates. For this reason, FAA STCs approved for US-built Cessna models do not formally apply to Reims-Cessna models; this also applies to validated STCs. However, because the Reims-Cessna aircraft are identical to the US-built aircraft, and because there is no technical investigation necessary to extend the applicability of STCs to the French-built aircraft, EASA can extend the grandfathered approval to Reims-built aircraft but the approval has to be legally recorded. The mechanism that is used is the minor change, even if the modification would normally be classified as STC (ie, a major change). The applicant should apply on an EASA Form 32 referring to the FAA STC and its EASA grandfathered approval in the application.

Note that all Reims-Cessna models are now covered under FAA Type Certificates, with the exception of the FTB337G and GA which are covered by EASA SAS and the F406, which is still the responsibility of Reims Aviation Industries (RAI).

If my interpretation is correct, this means that all the FAA STCs (there are a lot of them) can be applied to EASA registered Reims built Cessnas.

What does „minor change“ mean and how is it done in practice? Is it expensive?

Last Edited by Snoopy at 03 Jul 16:43
always learning
LO__, Austria

That is how I interpreted the rules, I was the owner of one French built 152 and another one built in the USA and treated them identically when it came to STC’s.

Thanks @A_and_C , can you share an example of applying a STC (procedure, paperwork and cost)? Thank you very much!

Last Edited by Snoopy at 04 Jul 18:01
always learning
LO__, Austria

If you can achieve the mod you want with a cooperative maintenance person, that may be a quick, though imperfect solution.

Bear in mind that an STC is a supplement to a TC (hence the name). The STC certificate will state the TC which it is supplementing (the “following product…”). It would be difficult to defend installing an STC on an aircraft which is not on the TC which the STC is supplementing. I run across it frequently, where the STC holder simply did not think to include another near identical aircraft on an STC application, and the FAA will not offer to approve an aircraft type which the applicant did not request. So there are omissions. Indeed, Cessna contacted me, and asked me to include the Caravan on an STC which I hold, which covers dozens of Cessnas – I just did not think to include the Caravan when I applied – brain fart on my part. I had the FAA reissue, now the Caravan is included, and Cessna is happy.

When presented to me, I will issue a serialized STC to the subject plane to explicitly link that airplane to an STC otherwise not directly linked. I don’t know that EASA process for this, however, I have found EASA very methodical, and easy to work with on several projects I have done with them.

If you have found the cooperative person, and slipped the mod through, that’s fine. However, it’ll be the elephant in the room with that plane. Each annual inspection should catch it, as should a pre purchase inspection, and an import or export certainly will. Just be prepared to deal with it through to proper completion if it is caught in the future….

Home runway, in central Ontario, Canada, Canada

I recently came across a very similar example to the one provided by @Pilot_DAR, oddly enough involving a Canadian built plane. An ex-RCAF DH Chipmunk in FAA standard category (such a thing is possible), equipped with Slick mags that are STC approved for virtually every variation of Gipsy engine, except the one installed on the plane. Unfortunately the owner had given away the OEM BTH mags. My A&P IA friend was doing an Annual pretty much as a favor, money was probably not involved, and this plus an unapproved toe brake conversion put an end to it. In the end he advised the guy to put it on Experimental Exhibition or figure out those two items and the owner instead vaporized, doubtless looking for a cooperative IA… to get him through another year.

Last Edited by Silvaire at 06 Jul 04:18

Yes this sort of thing is certainly caught on import, although possibly not on export. One pretty big case I know of probably halved the value of the plane… The company which didn’t read the STC properly when they did the installation offered to sign the plane’s Annual off every year if it is brought to them every year

Administrator
Shoreham EGKA, United Kingdom

It would be difficult to defend installing an STC on an aircraft which is not on the TC which the STC is supplementing.

I don’t understand what you mean.

The Reims C150, as laid out in the text above from EASA, is on the FAA TC. So all FAA STCs should be usable for a EASA registered Reims F150, using a minor change „grandfathered“ procedure, correct?

always learning
LO__, Austria

Using the Cessna 150 as an example: All American made 150’s are made under TC 3A19. There is also a TC for the French made 150’s, A13EU. Each list the respective 150s, and not the others. Therefore an STC issued against 3A19, is not a supplement to TC A13EU. Simply because the STC applicant did not make application against both TC’s, not necessarily because of the design compliance/installability of the mod – yes, the planes 3A19 to A13EU might be the same in respect of the mod.

I have found the FAA to be even more fussy that Canada in this theme. I hold both a Transport Canada and FAA STC for the same mod on a number of GA types. For the Transport Canada eligibility list, my listing “Cessna 182 series” (for example) was accepted by Transport Canada. However, the FAA insisted that I write out the eligibility list to say: “Cessna 182, 182A, 182B … etc.”. The FAA’s stated logic being that although my mod was installable and approveable on all present models of the 182, should Cessna add a new model of the 182 in the future, my mod would not have been proven, yet the simple “182” eligibility would allow installation on the future model. I didn’t argue this logic, and 18 years later, both my STC’s still differ this way.

I agree that these are paperwork only issues, and have little physical effect on the airplane, but airplanes fly on paperwork!

Following Silvaire’s example, a friend approached me, as the Luscombe he owned, had been found during inspection to have the wrong mags, would I issue a serialized STC to allow the mags which were installed on this flying plane? I dug into it. The plane had had an engine change to a Lycoming O-235. That engine change was only applicable as a floatplane, and his was a landplane (he didn’t even have the floats, nor a float rating). Worse, it turned out that this particular model of the O-235 was no longer supported by Lycoming, and had been removed from the TC for the engine. There was no parts catalog. I could not do an STC if I wanted to, technically, the engine does not have a TC. Despite my support, Transport Canada could not issue a flight permit to fly it to a maintenance base, because an AD structural inspection was overdue (’cause the C of A annual inspection was overdue). He had the wings removed, and trucked it out, as the airport where it sat was silly expensive for tiedowns. It was sold as is, where is on the trailer. It will not fly in that configuration as a certified plane again.

Again, all paperwork only problems, but they grounded and greatly devalued the plane. If you’re getting away with sidestepping the paperwork, just understand how doing that could affect you in the future. Maybe it matters to you, maybe not so much, just understand….

Home runway, in central Ontario, Canada, Canada

Pilot_DAR wrote:

The FAA’s stated logic being that although my mod was installable and approveable on all present models of the 182, should Cessna add a new model of the 182 in the future, my mod would not have been proven, yet the simple “182” eligibility would allow installation on the future model.

That may be the reason given by the FAA, but there is possibly more to it than that depending upon the STC. Specifically, autopilot STCs are not automatic even for all models on the same type certificate. A good example is the Garmin GFC500, which is approved for my R172K on TC 3A17, but neither (yet) the 172RG nor 175 which are also both on TC 3A17. Given Garmin’s thoroughness quickly producing long AMLs for new products, I don’t believe this to be an oversight.

Last Edited by chflyer at 06 Jul 13:21
LSZK, Switzerland

Using the Cessna 150 as an example: All American made 150’s are made under TC 3A19. There is also a TC for the French made 150’s, A13EU. Each list the respective 150s, and not the others.

Thank you, I couldn’t find it on the FAA website list, only searching for A13EU directly revealed this.

always learning
LO__, Austria
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