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Whats your dream STC

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.

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

LSZH(work) LSZF (GA base), Switzerland

I think the USA got there first and nobody has a right to tell them their system is substandard.

It's not perfect (for example if you ask enough FSDO inspectors whether you need a 337 to put avgas in your fuel tank, eventually you will find one who will say YES, and I have seen plenty of that kind of crap myself on some projects I did) but it's the best there is, within what is possible with a human-staffed organisation.

Europe has always been doing projects that are purely politically motivated. Hardly suprising, given how small a place it is and how economically insignificant most European countries are.

EASA's publicly stated drive is "we are European and we need European regulation, not American regulation". If that's the best justification they can come out with (and it really does seem to be just that) what chance have we got?

In addition to desperately trying to play Big Enough Boy, Europe has the same problem as the USA which is having to keep out dodgy-certified products. There is no way the FAA or EASA can (or should) accept "ICAO compliant" certification from a country in which document forgery or corruption is the default way of doing things, and that means most of the 3rd World.

So simply accepting ICAO certification is not a way forward, because the only way ICAO could have got ~200 countries to sign the treaty is by watering it down to the absolute basics, which is something like private flying is allowed worldwide if the aircraft reg matches the country issuing the pilot papers, and for noncommercial flying only. On top of that you can build international passenger services but only using bilateral agreements.

ICAO certification, e.g. the USA accepting STCs issued by the Peoples' Republic of Upper Volta, was never going to work because the latter's certification processes are PROB99 going to be utterly bogus.

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. Australia accepts US STCs and US 337s.

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. It probably should but Europe has so deliberately set out to piss off the USA that there probably isn't much goodwill left now.

Disbanding ICAO would be a really bad idea because private flying would immediately end in most of the world. In the vast majority of countries around the world, it's only ICAO which enables you to keep a private plane and fly it. Private flying is one of the biggest expressions of personal freedom which means any half respectable dictator would be mad to allow it. We tend to think of Europe as a free place but I think most of Europe would have banned private flying soon after WW2 if it wasn't for ICAO.

Administrator
Shoreham EGKA, United Kingdom

While I can surely sympathize with aviators in many countries seeking protection from their local government and rationalization by ICAO, I greatly disfavor international law applied to US aviation. Apart from anything else it would be grossly unconstitutional in the US. I want no direct influence whatsoever from overseas aviation regulators in the US. My family came here to escape their kind of nonsense, and in ennumerable trips to the EU over the last decade (4 in the last year) I am increasingly convinced it was the right thing to do.

Its probably worth pointing out that the independent FAA system is a very useful (to all of us) thorn in EASA's side, showing EASA that they are fundamentally wrong in their approach. Our job in the US is to stop US regulators learning from EASA and their like, not vice versa.

I hear you Peter, but the problem is not that easy.

To be fair, it is not Europe which started the "your approval is fine but we don't care, we'll do our own" but the FAA.

Generally, I'd like to see ICAO becoming the standard and a compulsory acceptance by ICAO members of STC's accepted by manufacturers of airframes, avionics and their regulative authority.

That would mean that any STC, AML but also C of A issued by the ICAO state of manufacture of the airframe and the additional appliance would have to be accepted by ALL ICAO States without any restriction.

There is NO reason whatsoever for approvals by each and every nation or regulator if all of them comply to the common certification criteria lied down in ICAO. All that happens today is state protectionism and job/revenue creation by the respective regulators plus follows a political agenda to eliminate GA particularly in Europe.

EASA has NO place to demand and restrict their own certification for US certified airplanes, US made avionics and their AML's as well as STC's certified for US made airplanes by US manufacturers.

The FAA has no place to demand and restrict their own certification for European made airplanes, European made avionics and their AMLs, as well as STC's certified for European made airplanes by European manufacturers.

And they both have no place to demand and restrict certification of a mixture of both, nor do they have a place to demand and restrict their own certification for, say, Russian or Chinese produced airplanes, as long as mutual reckognition is granted under the blanket of ICAO.

the same of course goes for FCL issues too.

But importantly, it has to go both ways. The FAA has for a long time been regarded, rightly so, as the leading certifier for Western built airframes and products, but that time now is over. Europe has become it's equal, even if the bureaucracy here is far worse, and it is time for the FAA and EASA to pretend otherwise.

Likewise, protectionist measures to keep Antonov's and Tupolevs e.t.c. out of the West may now safely be stopped too. The Cold War is over, but it's been replaced by a 3 way trade war between the US, Europe and Russia. That has to stop.

Otherwise, we may well admit that ICAO has failed as a world aviation authority and disband it.

LSZH(work) LSZF (GA base), Switzerland

The best thing would be for EASA to have a blanket acceptance of US STCs

Why adopt a working system, this idea is totally absurd.

United Kingdom

I have been told that premium Mogas will not have any Ethanol for a long time to come, so switching to premium is an option.>

We're lucky in our area to still be getting Regular EN228 RON95 mogas that passes the alcohol test, but we are forbidden in the UK from using Premium grade.

Maoraigh
EGPE, United Kingdom

The best thing would be for EASA to have a blanket acceptance of US STCs, but that would demolish the European Part 21 work creation scheme

Administrator
Shoreham EGKA, United Kingdom

PDAR - I'm sure that as you say, non-alcohol auto gas is still available in Canada, but in most US states it has become either very difficult to find or unavailable. In my state, I'd estimate its been more than 5 years since we've been able to buy it. Prior to that, my aircraft operated on auto gas under STC.

Some might remember the well publicized (but typical) regulatory mess under which oxygenates were mandated by government, MTBE was approved, used and then subsequently banned by government when they found the cure was worse than the non-existent disease. Stations shut down, contaminated tanks dug up etc, to rectify a nonsensical series of mis-steps by government amateurs apparently undergoing on the job training. In pursing the endless circles of their taxpayer funded environmental religion, they also made the use of leaded Avgas effectively mandatory, in the process removing the ROI for the substantial private effort to generate existing auto fuel STCs.

We worked on a Mogas/Enthanol STC many years ago. This involved more than a hundred hours of test flying a modified 150. With a number of modest changes, the 150 ran perfectly well on 100% Ethanol, and would also run on any blend with gas all the way to straight Mogas. There were challenges though with operating procedures, relative to the much greater fuel flow when running Ethanol.

There is probably little incentive for [whomever] to undertake such an STC in this market. The testing required was intense in the day, and probably worse now. Mogas is still available in North America with no Ethanol, I have it delivered to my tank several times a year, and have never had Ethanol in it (I check).

There are "issues" with corrosion with Ethanol fuel, though this is manageable. There are also material compatibility concerns, though the 150 has the most metal fuel system of most planes, so is a good candidate for such an STC.

I have been told that premium Mogas will not have any Ethanol for a long time to come, so switching to premium is an option. When the time comes that I can no longer get Ethanol free Mogas, I probably will undertake a limited STC for my 150, though I doubt I want to hold a full STC for everyone else's. For the very small profit to be had for a STC sale, once you've covered all the testing and approval costs, it's just not worth the risk of some goof suing you, 'cause he ran out of Ethanol Mogas, and crashed. Even defending such a lawsuit can take more than all the profit from all STC sales.

The only protection from such risks I can imagine would be to have a group of 150 owners form a company to hold such an STC, and every STC purchaser must buy shares in the company. Perhaps that way, the risk is not held by any one person. But, corporate dealings are not my strong point, issuing STC's is....

Home runway, in central Ontario, Canada, Canada
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