Supplemental Type Certificates and Interactions with Aviation Authorities
Sep 19, 2021
A typical STC process is complex and has many phases and stakeholders, but once the respective aviation authorities become the focus of activity, questions about the project timeline and costs may arise. Subject experts of IAMA, the Independent Aircraft Modifier Alliance, are in constant effort to enlighten stakeholders on how to mitigate risk in these situations and pursue our laudable mission to create an open, transparent aviation ecosystem. Following this purpose, we have put together an educational paper entitled “Supplemental Type Certificates Interaction with Aviation Authorities.”
For an STC to retain its validity, its 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.
Keeping in mind the requirements of two major aviation authorities, EASA and FAA, 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 but it’s possibly a bit surprising. 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 has been an ongoing issue within the aviation sector. As such, this is an important insight for the aviation sector as a whole.
What are the main perils can aviation sector stakeholders expect?
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 aircraft engineering services and design work is generally contractually agreed between the customer and the STC provider. The clock starts ticking at the project’s kick-off and stops when approval is received from the aviation authorities It’s important to remember that the authorities’ 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.
How to evade the challenges?
Our recommendations for all aviation sector participants to avoid such situations are clear. It involves specific milestone documentation and planning and well-developed communication channels.
Like all of our 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.