Silvaire and Peter,
appears I did not make myself clear. No, I do not advertize the US accepting "foreign law" nor the EU to do so, but things like that do not work on the basis of "first come first served" or without reciprocity.
Personally I think we can agree on the fact that both European products certified in Europe and American products certified there will have equally high stages of quality and the certification process in both places is strict enough for one to accept the other without requiring a double process which costs millions of dollars/euros.
Likewise, if an American manufacturer certifies an STC or AML with the FAA, or an European manufacturer does the same with EASA, then there is no reason for quality or process which justifies that both require a total re-exam under their respective rules. They could, if the will were there, accept each other's STC's and AML's without having to waste loads of cash with re-certifications.
Therefore, Peter, if you say, in two consecutive paragraphs that :
But there is no reason for the EU to refuse US STCs. Both "countries" have more than adequate level of QA. That is just pure protectionism.
As to why the FAA doesn't accept EU STCs, my answer is why should it? The USA "owns" most of the world's aviation industry, so it probably can't be bothered.
Then you exactly point to the problem. It does not work like that. You want the EU to accept FAA STC's without hassle but you find it ok that the US doesn't accept European STC's. I find that unfair and to an extent that is the reason why many European politicians have gone out of their way to piss off the US as you say. If US STC's should be good enough for Europe, then European STC's should be good enough for the Americans. That exactly is the source of the problem.
That is why I propose that the criteria for mutual acceptance of ICAO conform certifications are the only way to stop this nonsense and to stop nationalist interests costing us tens of thousands of dollars.
Clearly, if Europe and EASA were as efficient as the FAA in certification issues, we'd maybe not ask the question, but it isn't. That is why many of us feel the system is inferior, which in it's bureaucracy is true enough, yet on terms of quality of the certified items it is not.
Add to that the manufacturers, who I understand are part of the process. Until EASA came along, it was simply expected by US manufacturers that a new plane certified by them would be accepted without hassle in Europe. However, if Airbus or Diamond or Extra or Tupolev wanted to sell a plane in the US, they had to re-do the whole certification process. Why should they?
Personally, I believe we won't get unilateral acceptance of FAA standards unless the FAA relents and accepts the standards of other countries as well. That does not have to mean countries who are not up to the task or if there are proven deficiencies, they can still doublecheck each others certifications and refuse one if they feel it breaks rules, but at least we'd get some reason in the GA market.
The Alternative in the long run will be that we will see US manufactured goods flying only outside Europe and European products only in Europe. That does not help anyone. It would be the revival of the situation where Russian Products were not allowed to be used in the West and vice versa. Do we really want to go there? I think not.
that Europe needs to rethink their bureaucracy and make things easier for GA is no question. But things have to go both ways, otherwise European GA will be the one to pay the bills.
The rest is politics. Neither the EU nor the US will accept the "others" laws and rules without hassle, so the idea that EASA should simply go away and let the FAA take over European GA is simply not on. Apart, it is not the solution either, the solution is to get EASA to become competitive towards the FAA and not rejective. So the only way to get both of them to even go near a mutual reckognition will be if it can be done via an international organisation like ICAO or via a bilateral agreement. Which is easier to achieve is to be seen, but one of the two should be the ultimate goal.
Best regards Urs
A European produced aircraft, on N-register in the US, sold with an a EASA type certificate if that were legal would be uncompetitive for a number of reasons, including the following.
1) The need for a 'support organization' to maintain the TC and the concern that the aircraft will become valueless if no support organization exists in the future. No such issue exists on an FAA TC.
2) No FAA to filter foreign ADs and rewrite/delete them to something that fits within the spirit of an airworthiness directive versus a revenue enhancing mandatory service bulletin.
3) The allowance of maintenance manual procedures that mandatorily direct damage repairs to the manufacturer in order to operate under the Type Certificate. That is illegal for an FAA approved maintenance manual.
There are a lot of other issues. I own a European produced aircraft that has an FAA type Certificate issued 42 years ago on the basis of its foreign type certificate. It having an FAA Type Certificate is what makes it a practical aircraft to own and operate.
FAA Type Certification of aircraft produced in some foreign countries on the basis of the Type Certification in their country of origin has existed under treaty for many years. German type certified Extras were originally FAA certified by that protocol.
