This is very interesting – especially the last part.
Does it mean that you can apply for a field approval, using the content of some STC, not the STC itself (i.e. not referencing its number) without the STC holder’s permission? I have seen this done, on the suggestion of an FSDO inspector who I would think knew the rules.
My 3rd point in my last post above referred to an STC which was basically worthless because it added no value to stuff already in FAA approved IMs etc. This may be academic in the case of an autopilot, which is quite a specific thing and for which (a) and STC is required (unless an OEM installation) and (b) one is not likely to have more than one STC available.
If the STC holder is no longer around, you won’t be able to obtain the permission required by 91.403(d) and will be unable to use the STC as the basis for installation. If the holder is still around, but unwilling to provide written permission to use for an STC they allowed you to use, they are in violation of 21.120 which requires them to provide written permission and you can report the issue to the FAA and likely take civil action to force them to comply or pay damages.
How is “still around” defined?
Peter wrote:
How is “still around” defined?
I was just responding to your question.
Peter wrote:
What if the STC holder is no longer around, or is not responding?
If an aircraft was factory equipped with an autopilot also being sold to the aftermarket, did the factory (let’s say Piper) have to submit a copy of the vendor STC permission letter for DAR sign off with the original airworthiness certification package for an individual newly produced airframe? If so that letter should still exist in the aircraft records. If not, something else applied, I would guess a license allowing AP certification for the type under the Piper TC. In that case, it would equally apply to the type today.
I have all the original certification data for my individual airframe and I’m sure most owners do too. It would be interesting to look at those records for a Piper that came from the Piper factory with a vendor manufactured autopilot, to see if an STC permission letter issued by the vendor to Piper Aircraft for the individual serial number aircraft is among them.
Silvaire wrote:
If an aircraft was factory equipped with an autopilot also being sold to the aftermarket, did the factory (let’s say Piper) have to submit a copy of the vendor STC permission letter for DAR sign off with the original airworthiness certification package for an individual newly produced airframe?
No, OEM’s typically integrate the third-party design in the TC, rather than using the STC. They would however use the STC substantiation data for the inclusion, under commercial agreement with the STC holder.
Antonio wrote:
OEM’s typically integrate the third-party design in the TC, rather than using the STC. They would however use the STC substantiation data for the inclusion, under commercial agreement with the STC holder.
In which case as I’ve posted before installing a used autopilot would be a maintenance operation not a modification.
A mod under the TC is called an “OEM-mod” but is a mod nonetheless. It is definitely a mod under EASA but design approval comes in the TC, rather than a separate minor mod or STC.
Typically it is documented in an OEM SB, SL, SEB, SK…., but sometimes it is just the basic IPC calling different options.
The point is that it does not need a separate Part-21 design approval process since approved data is already available under the TC and then it is only a Part-M and Part-145 matter.
In the sense that it does not require design approval under part-21 then it is not a mod, but in the part-M and part-145 maintenance sense it is a mod.
In the FAA world, it is a bit more integrated since the “maintenance world” can provide “design approvals” (Under EASA it is increasingly the case with CS-STAN, but not historically)
The difference between mod-design and maintenance-mod is like an 8110-3 or STC approval vs a form 337 or log entry for reporting installation of a design which is already approved (via 8110-3 or STC or otherwise)
Would you need a form 337 to report a change under an OEM SB?
Unless there is some special FAA policy for autopilots of which I’m not aware, the work on an N-registered aircraft would be documented by a simple A&P logbook entry. I don’t believe a 337 would properly be filed because the installation is not a modification from the type certificated configuration that is already FAA approved, and therefore does not require IA inspection. Perhaps there is such a special FAA policy applicable to autopilots but it’s nothing I’ve run into previously as an owner.
A 337 reports to FAA when a mod outside of the TC is incorporated, referencing approved data outside of the original TC – such as an STC or 8110-3 prepared by an FAA engineering designee. This is not the case for anything within the original TC, including options like for example optional fuel tank configurations for which the mechanic makes a simple logbook entry after installation and that’s it. I have seen 337s filed for optional fuel tank installations but notwithstanding the modern tendency to file a 337 for ‘anything’ I don’t think it’s necessary.
I have no idea if post-certification manufacturer produced service bulletins are automatically FAA approved data that could or would be referenced by a 337 reporting a modification. I would guess they are not approved data otherwise you’d effectively have a manufacturer doing the work of FAA and certifying their own products (effectively writing law), but this is beyond my experience. My IA and DAR friends would know the answer and I’ll ask them next time I see them (they are partners in two planes and usually found in the same place)
