IAMA Certified News - September 2021 Issue
Sep 14, 2021
STCs and Interactions with Aviation Authorities
“A typical STC process is complex and has many phases and stakeholders, but initially includes the airline, the owner or operator and the Supplemental Type Certificate provider,” said Andreas Gherman, senior advisor, authority relations at IAMA, the Independent Aircraft Modifier Alliance. “Later, once the respective aviation authorities become the focus of activity, questions about project timeline and costs may arise.” To enlighten stakeholders on how to mitigate risk in these situations, IAMA experts have developed a new whitepaper entitled “Supplemental Type Certificates Interaction with Aviation Authorities”.
For STCs to retain their validity, their integrity must be maintained in the original jurisdiction in which they were approved, and in new jurisdictions as required. In the ecosystem, leaving aside minor modifications, there is the initial STC approval, and the validation of that STC in the new jurisdiction—other than the original approval. With EASA and FAA requirements as the backdrop, the white paper outlines from start to finish the initial STC process, and it offers guidance as to which stakeholders are involved in each phase.
What the white paper uncovers is not only interesting it’s possibly a bit surprising. Gherman explains: “Formally, the customer, the airline, owner, or operator—with the possible exception of test flights—does not play an active role for a significant portion of the seven-phase process. What can result, without a well-developed communications channel between the operator and the STC provider, is that the customer may not be fully aware of the project’s status, potential problems, additional costs.”
This is an important insight. While technically ongoing lines of communication between the provider and the customer are not required by aviation legislation, it is not hard to foresee challenges arising; especially during the critical development and engineering phase. For example, in a project to validate an STC in a new jurisdiction, there may be additional certification requirements unknown to the aircraft operator, which push the project timeline out.
Another potential pitfall is the STC project timeline. “The time required to complete engineering and design work is generally contractually agreed between the customer and the STC provider,” Gherman notes. “The clock starts ticking at the project’s kick-off and stops when approval is received from the respective aviation authority. It’s important to remember that the aviation authority’s administrative and validation activities are also included. These tasks can be somewhat variable and predictably, are completely out of the STC provider’s control. Recognizing this situation, there is little mystery that concerns can develop.”
IAMA’s recommendations to avoid such situations are clear. It involves specific milestone documentation and planning, and of course well-developed communication channels.
Like all of IAMA’s white papers, “Supplemental Type Certificates Interaction with Aviation Authorities” offers helpful, practical advice to both the customer and the STC provider. More than this, it details the context around how modifications achieved through STCs work in the real world.
Modification Experts Eclipse Technics: Finding the balance between competing and sharing
“You could say the modification industry is a bit of a jungle, and modifiers at all levels are experiencing the same pains,” said Patrick Gindre, sales director at Eclipse Technics. “So, when Nicole Noack, then the head of design engineering and communication systems at Lufthansa Technik, and I met at Aircraft Interiors Expo in 2018, we realized that both of our organizations were having to jump a lot of the same hurdles. It was gratifying to learn that a large prestigious organization like Lufthansa Technik had similar challenges to a smaller organization like Eclipse Technics. And so, it was this meeting that planted the seed that would eventually grow into IAMA, the Independent Aircraft Modifier Alliance.”
A founding member of IAMA, Eclipse Technics (Formerly EAD Aerospace), was instrumental in helping the alliance get off the ground. Their long history of design and certification expertise speaks for itself. The company is a division of Eclipse Global Connectivity and was established in 1998 to engineer and develop Supplemental Type Certificates (STCs) and installation kits for Airbus, Boeing, Bombardier and Embraer, among other aircraft types. Early projects included interiors and structural modifications, plus avionics and connectivity systems. Innovation and the resulting expertise, intellectual property, and data are the DNA of Eclipse Technics, allowing the team to bring forward new, ingenious modification solutions for aircraft and rotorcraft.
“After Nicole and I spoke, we were determined to test our ideas and to get feedback from our competitors, which of course wasn’t an easy task,” Gindre explains. “However, the Eclipse team dove into this challenge, offering our time and our wide-ranging And what we wanted to do was share our collective insights and pains we, as individual organizations, had experienced and also share them with others who would take up this important cause.”
Gindre points out the main reasons for the pain, “Historically, the retrofit market hasn’t enjoyed the best reputation. There are several reasons for this. Even if your organization is doing a good job, you were, unfortunately, being judged by the overall poor reputation. And as a result, customers—aircraft operators, lessors and owners—don’t know what to expect regarding documents, authorizations and warranty.”
However, Eclipse Technics, Lufthansa Technik, Etihad Engineering and Envoy Aerospace and other members work diligently to turn the STC’s reputation around. “Eclipse Technics and Eclipse Global Connectivity are deeply committed to best practices,” Gindre explains. “Aircraft owners and operators see far better outcomes when processes are open and transparent. The FAA and EASA spell out the requirements. IAMA makes them easier to follow with tools and support.”
Additionally, the team wanted to open the industry’s eyes to the value that independent modifications provide and educate the market that not only were some companies doing STC projects well, they were also authorized. This led to the development of the IAMA Rulebook and many resources that have helped to start building the credibility of STCs, instilling new confidence in aircraft lessors, operators and owners.
Gindre acknowledges the balancing act between sharing outcomes with competitors and remaining competitive. “Although we would not partner with our competition, sharing lessons learned gives us more confidence, and of course, shows us what we can improve in our own processes.”
Being independent of manufacturers and vendors, the company's approach has always been to select the best system for their client's needs. Their wide-ranging experience is a crucial piece of the puzzle. "As DOA Part 21 and POA holders, we have developed an immense range of FAA and EASA STCs for many fixed-wing and rotorcraft types. We've done retrofit projects for commercial and business aircraft including VVIP and VIP, and military aircraft and helicopters for cabin and cockpit avionics, Satcom and Air to Ground systems, and connectivity system modifications."
Gindre, like the Eclipse Technics team, is committed to the association’s mission and appreciates the membership benefits. “Being a founding member of IAMA is a great honour. We are humbled to work with such renowned organizations as the founding members, Lufthansa Technik, Etihad Engineering and Envoy Aerospace and the members who have joined us since: Carlisle Interconnect Technologies, Fokker Services, The Angelus Corporation, Collins Aerospace, Euro-Composites, and Frequencia. We have so much respect for them. During the height of the pandemic, when things were quite grim for aviation, IAMA rose to the challenge, and we continued to network with our peers and new organizations too, which continues to be a huge benefit to us.”
Learn more about Eclipse Technics at their website.
Orphan STCs: IAMA’s Guidance on the Transfer & Surrender of STCs
Ask any operator, lessor or owner who has lived through trying to get assistance for a no longer supported Supplemental Type Certificate (STC), and you’ll hear about the incredible challenges they faced. Orphan STCs, as they are known, present significant obstacles for these stakeholders and the aviation industry in general. Particularly daunting is the resulting increased risk. The experts at IAMA, the Independent Aircraft Modifier Alliance, understand these challenges, which is why advice on mitigating risk is a key point in the white paper entitled “IAMA STC Transfer and Surrender Guidance.”
“Design Authority Holders (DAH) may be unable to continue supporting an STC for any number of reasons,” explained Nicole Noack, managing director at IAMA. “Unfortunately, such situations can leave operators and owners unaware, unprepared and at risk. Managing the risk around Orphan STCs is complicated, but we want to protect STCs, so we have refined our position on this critical topic. Our principal goal is working towards solutions that will help operators avoid such situations.”
While the new guidance is not intended to be used for compliance with aviation authority regulations, it outlines best practices to execute the transfer or surrender of an STC. Krunal Patel, voluntary technical advisor with the alliance, explains: “IAMA members commit to not abandoning IAMA-endorsed STCs. Instead, with IAMA’s help, they will make a reasonable effort to transfer the STC to another DAH in a timely and orderly manner. The essential point here is to ensure the STC’s continued support, which helps reduce the risk for the aircraft owner, operator and lessor.”
In the manner of dedicated leadership, the alliance is also pledging to help reduce the risk. Noack continued, “For our part, IAMA commits to supporting affected operators and owners should an IAMA endorsed STC require surrendering. We have developed a seven-step process and a detailed task list to accomplish the transfer.”
Unsurprisingly, IAMA recommends strong lines of communication across all stakeholders along with a well-developed and executed plan. “These are the essential ingredients for a successful transfer. DAHs are responsible for supporting their STCs, but in an unavoidable situation of surrender or transfer, we feel the guidance is an invaluable tool. From developing a communications strategy to understanding all the elements needed for this type of exercise, we want to offer IAMA members structured advice,” Patel notes.
With fall rapidly approaching, it seems that the aviation industry still suffers but is also making baby steps towards recovery. And even though the summer months tend to be a little slower, IAMA, the Independent Aircraft Modifier Alliance team, continues to push its agenda forward.
Since our last newsletter, we have said goodbye to Dimitrios Tsirangelos. As our first technical affairs manager, Dimi brought positivity and an entrepreneurial spirit to his work with the IAMA team. He’ll certainly be missed, but we wish him well in his new endeavors. No sooner did we say goodbye to Dimi than we welcomed Ian Devine to the team. With experience as an EASA Part 21J design and certification engineer, Ian is stepping into the role to support the ongoing development of the IAMA Standard. He’ll also lead the work on our many and varied technical subjects. You can learn more about Ian’s extensive experience and connect with him through his LinkedIn profile.
I am pleased to report that our outreach programs, white papers, IVTT events and speaking engagements demonstrate the benefits of supporting IAMA’s vision and mission, and this hard work is paying off. For example, we are pleased to welcome Qantas to our growing list of subscribers. It is gratifying that they share our desire to ensure an open and transparent retrofit market through STCs. Whether you’re an aircraft modifier, an airline operator, an aircraft manufacturer, supplier or lessor, access to the alliance’s resources is invaluable.
Now is an excellent time to remind aircraft modifiers about our reduced membership fees. You can learn more about the levels and benefits on our membership page, but members joining at the basic level in Q4 of this year will retain their memberships until the end of 2022.
So what all have we been doing? In June, IATA held a technical operations webinar. The event entitled a “Cooperative approach to solve challenges in OEM Engineering Data access for aircraft modification” was an excellent opportunity for IAMA’s managing director, Nicole Noack, to present IAMA’s cooperative position on the topic of intellectual property (IP). The insightful subject matter for the presentation comes from our IP working group experts. Nicole was in good company addressing this challenging issue with panellists from easyJet and LATAM Airlines. You can download a copy of the presentation here.
In other news, we’ve recently launched a new initiative: a request for proposal (RFP) service. We created this service to make it easier for airlines, who have a specific requirement, to obtain that upgrade. The airline representative clicks on the button and completes the RFP. IAMA will then help find the appropriate service from one of our endorsed members. It’s a great way for airlines to save time and get the modifications they need from the right provider.
As we “hit send” on this issue of “IAMA Certified News,” there are a couple of additional activities I’d like to highlight. Firstly, we are engaging with new prospects and current members through our virtual exhibit at AIX, the Aircraft Interiors Expo (14-16 Sept). And secondly, by the time you read this newsletter, we will have just announced version 2.1 of the IAMA Rulebook. Building on version 2.0 updates, which focused primarily on STC maintainability and de-modification, this version adds new advice on tackling challenging issues like Orphan STCs. Along with helpful new templates for project management and monitoring, and communications, version 2.1 presents new rules to ensure the proper support of STCs no longer supported by the original design approval holder.
Well, that’s all for now. If you have questions or story ideas, let us know. Here’s to clearer skies ahead and continued progress in this incredible industry we call aviation.
As always, stay safe and be well.
— Marc Pinault, Chairman
Engage with Us
- Aircraft Interiors Expo, Online |14-16 September 2021| Join us at our Virtual Booth
- IAMA Virtual Think Tank (IVTT) 2021 - No: 4 Online | 22 September 2021 - 3 PM CEST| Modifications, their compatibility, and transferability - Operators, Owners, and Airframe OEMs Only -
- MRO Europe, Amsterdam |19-21 October 2021
- Onboard Connectivity Summit, Bremen |16-17 November 2021
Become an IAMA Member
IAMA is open to all aviation market participants including aircraft manufacturers, airlines, suppliers and lessors. The alliance offers three types of paid memberships: Full, Advisory and Basic.
Members have access to specific benefits depending upon their role in the aviation ecosystem, and their membership level. Full and Basic memberships are for organisations with STC capabilities, while Advisory memberships are for airframe and system OEMs (Original Equipment Manufacturers). Airlines, banks and lessors may join for free.
Find out more about our membership possibilities here!