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European modifications / approvals / STC database, and ownership of modifications / approvals

I can think of only one thing which EASA has done (and delivered on) since it got going about 10 years ago: the grandfathering of modifications. For example if somebody in Germany got a German CAA approval for some exhaust system (a Major mod, of course) this exhaust can now be installed on any EASA-reg plane.

But there is no central database of modifications, so this is partly useless.

The UK CAA has a database here. If you type in e.g. TB20 in the aircraft type, you get what is obviously a miniscule % of what has been actually done, so the database is obviously very incomplete. It stopped being updated at EASA-time; approx 2003.

I believe Germany has one too. Does anybody have the URL?

Any others?

Otherwise, one might try contacting the (usually American) manufacturer of the equipment and ask if they sold any to Europe, and then try to extract information as to who, and then try to extract information from the (usually) avionics shop which did the mod, and they will want some money for the stuff... anything up to 4 figures if they did any real work on it.

Administrator
Shoreham EGKA, United Kingdom

Here is the list of STCs from the German LBA, divided into aircraft categories and the timeframe:

Ergänzende Musterzulassungen

For GA aircraft ("Kleine Flugzeuge" = "small aircraft):

STCs before 1997

STCs after 1997

The lists are up to date, last change April 17th, 2013.

For your TB20, you can have an MT propeller together with a Gomolzig muffler (very stylish)

Yeah it sucks… for some time ago EASA published approved EASA STC’s. Havent seen that list in a while.
/Sam

The following is my understanding and I would like anyone to correct any of it.

FAA

Minor mods are just a logbook entry by A&P. The mod needs to use parts of a suitable specification (a TSO is sufficient but not necessary) and like all certified aircraft stuff it requires component traceability (8130-3 is sufficient but not necessary). There is no issue with somebody else having done it before, not least because nobody is going to know.

Major mods have several options

  • Type Certificated mod. You can just install the items, with a logbook entry. No fee payable to anybody.
  • STC mod. You can just install the items, an A&P/IA signs off the finished job, and a 337+STC is sent off to Oklahoma. You are supposed to get the STC holder’s permission, which may cost some $$$, and this permission is supposed to be included with the STC sent to Oklahoma (may be in the form of a statement within the STC)
  • Field Approval. You send 337+Approved Data to an FSDO, who approve it (or not). No fee involved. An A&P/IA signs off the finished job, and the 337 is sent off to Oklahoma. The Approved Data can be the content of an STC (but not the STC itself) or the content of another Field Approval, and no fee is payable to the persons who did the aforementioned STC or the Field Approval.
  • DER package. An FAA DER does a design package with an 8110 form. You can then just install the items, an A&P/IA signs off the finished job, and a 337+8110 is sent off to Oklahoma. No fees payable to anybody except of course the DER (usually lots of $$$). This is the favourite route for European avionics shops doing N-reg mods.

EASA

Minor mods can be in-house approved by an EASA 21 company, within certain boundaries. The modification is registered with EASA. The company owns the modification and you need to pay them if you use somebody’s else’s mod. But is that really true? For example countless EDM700s were installed under the blanket UK CAA approval and nobody paid anybody for the approval. Is this a case of a lack of enforcement, or is it that the UK CAA was never collecting money for mods which they approved in-house?

Major mods must be EASA approved. If there is an EASA STC for the mod, you can just install it, with a logbook entry. In all cases, whoever paid for the approval which you are referencing (which may or may not be an STC) can demand a fee from you. So what’s the difference between a major mod (non-STC) and an STCd mod? It looks like either one involves ownership of the mod by the original applicant.

Is the above correct?

What made me think of this was Shorrick’s report of dual GNS installations being common in Switzerland. AIUI, Switzerland is nowadays an “EASA country” so any mods there will be grandfathered to all of EASA. But that doesn’t mean you get the mod for free; the original Swiss proposer can still charge for the use of the approval.

In all cases, there is no “patent” principle and if somebody has got say an STC for installing Box X in aircraft Y, nothing stops somebody else applying for another STC which does exactly the same thing and paying all over again.

Administrator
Shoreham EGKA, United Kingdom

AFAIK, the terms “minor mod” abd “major mod” are not usually used at all in the FAA context.

Mainz (EDFZ) & Egelsbach (EDFE), Germany

AFAIK, the terms “minor mod” abd “major mod” are not usually used at all in the FAA context.

AIRCRAFT EQUIPMENT AND OPERATIONAL AUTHORIZATIONS

Administrator
Shoreham EGKA, United Kingdom

Field Approval. You send 337+Approved Data to an FSDO, who approve it (or not). No fee involved. An A&P/IA signs off the finished job, and the 337 is sent off to Oklahoma. The Approved Data can be the content of an STC (but not the STC itself) or the content of another Field Approval, and no fee is payable to the persons who did the aforementioned STC or the Field Approval.

This doesn’t read exactly right to me. A field approval is when the FSDO inspector approves the data, so the initial submission of the proposed modification is unapproved data plus the form 337. The FSDO then approves the data by signing the 337 in block 3. After installation the IA signs that the work was completed according to the approval, and the 337 is resubmitted.

Another wrinkle is that a very old 337 (pre 1950s IIRC, there is an exact date) and its data can be used as approved data for another plane. This is useful for people with older types, Cubs for example which are often greatly modified. Newer 337s and field approved data cannot be used as the basis for another installation.

I think you have it exactly right, Silvaire. I didn’t put it very well.

The drift of my original post was to work out who exactly owns some prior approval, and thus needs to be paid if that approval is “made use of” (whatever that means).

With an STC (FAA or EASA) it is pretty clear. The STC holder owns the intellectual property (not a term I like to use in connection with avionics STCs, since 99% of the stuff comes straight out of the back of the installation manuals!) and can charge for the use of the STC.

But only if you explicitly make use of the STC (by reference to the STC number).

If I have it right, if you use the content of an STC or the content of a prior Field Approval, you aren’t using anybody’s IP. What about referencing a whole Field Approval, in a FA application? That is allowed, but do you have to pay anybody?

How that works in EASA-land, with non-STC mods, I don’t know.

Administrator
Shoreham EGKA, United Kingdom

Minor mods can be in-house approved by an EASA 21 company, within certain boundaries.

Correct, within the minor boundaries. AND Anyone can apply for a minor modification directly at EASA.

and nobody paid anybody for the approval.

There is ALWAYS someone who does the application, even if there are no charges, someone put time to develop the minor mod, even when it is only copying the installation, which is not the case.

Major mods must be EASA approved.

Major mods can ONLY be done by Part 21 organisations. This is what makes this route expensive, as it is a very expensive certification process.

If there is an EASA STC for the mod, you can just install it, with a logbook entry.

Not complete, In most cases this is true, however some applications still require a minor change to use the STC. This is true for using the GTN installation, where the STC is very broad and the minor change is used to specify the exact installation

major mod (non-STC) and an STCd mod

Is the same

In all cases, there is no “patent” principle and if somebody has got say an STC for installing Box X in aircraft Y, nothing stops somebody else applying for another STC which does exactly the same thing and paying all over again.

True, re-using generates benefits, the major one being faster.

How that works in EASA-land, with non-STC mods, I don’t know.

When I apply for an change, I am the owner of that change, and I put in my effort to gain that approval. It seems very clear / logic to me that you can’t just copy that. You can’t do that with books, software or anything else? Why would it be possible with modifications? A typical change would easily take around 8 hours to generate the paperwork, it is not just a copy of the manual, if you think so you heavily underestimate the process.

Some charge the full amount (EASA fees and labour to generate the design) to the first customer and offer it for free their after as they have the approval. This would be a 750 to 1000 Euro charge for the first customer, and free for others.

I think this is unfair. On most installations I charge the amount of the EASA minor change fee. This means a fixed 290 Euro (EASA fee) cost to all customers. Sometimes I can reuse an approval frequently and I will make money on these approvals, on others, which are basically a one or two off, I will lose money as I don’t get my time paid. On average this works out ok, and give my customers in my opinion a fixed low fee.

JP-Avionics
EHMZ

Many thanks Jesse for the detailed reply.

I was trying to work out the exact process for using a prior approval and who, if anyone, needs to be paid.

What do you think of the UK EDM700 approval for example? Does anybody have to be paid for using it? It seems to me that literally anybody in EASA-land can just reference this approval and install the item, a Minor mod.

And how would one make use of the Swiss 2×GNS approval? (forget for the purpose of this discussion that a GNS is not too likely to go in today) I think the GTN can be installed 2x under its AML STC, or I could be wrong…

Has EASA produced a database of approved mods, pre-2003 (when EASA grandfathered the older mods to all EASA-reg aircraft)? But regardless of whether a mod has appeared in some database, who collects the money or who makes sure the original applicant gets paid?

I think this is unfair. On most installations I charge the amount of the EASA minor change fee. This means a fixed 290 Euro (EASA fee) cost to all customers. Sometimes I can reuse an approval frequently and I will make money on these approvals, on others, which are basically a one or two off, I will lose money as I don’t get my time paid. On average this works out ok, and give my customers in my opinion a fixed low fee.

That’s very admirable. Not all shops do that; I can think of two who bill the whole lot (c. £2000) to everybody afterwards.

Administrator
Shoreham EGKA, United Kingdom
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