Tuesday, February 4, 2014

STC Permission - Why Bother?

It is the LAW. 
The regulations are clear on the subject of STC permission. Below are some excerpts out of the FAA regulations and other FAA regulatory policy letters, etc..  Also I am providing a link to an interesting article on the topic of intellectual property as related to STCs and the court case example happens to be an engine change on a Cessna 185, similar to CAP STCs for Taylorcraft engine upgrades.

As a Mechanic/STC Installer - Should you participate in installing an STC when there is no permission letter?

As an Owner/Operator - Are you ensuring your paperwork is free of Pirated/Bootleg STC data?

As a Buyer - Do you look for the permission statement that should be retained in the Airplane Records?

Be informed.   Strive to stay legal.
Terry Bowden - Consultant DER

The following is an excerpted quote out of

49 U.S. Code § 44704 - Type certificates, production certificates, airworthiness certificates,

(b) Supplemental Type Certificates.—
(1) Issuance.— The Administrator may issue a type certificate designated as a supplemental type certificate for a change to an aircraft, aircraft engine, propeller, or appliance.

(2) Contents.— A supplemental type certificate issued under paragraph (1) shall consist of the change to the aircraft, aircraft engine, propeller, or appliance with respect to the previously issued type certificate for the aircraft, aircraft engine, propeller, or appliance.

(3) Requirement.— If the holder of a supplemental type certificate agrees to permit another person to use the certificate to modify an aircraft, aircraft engine, propeller, or appliance, the holder shall provide the other person with written evidence, in a form acceptable to the Administrator, of that agreement. A person may change an aircraft, aircraft engine, propeller, or appliance based on a supplemental type certificate only if the person requesting the change is the holder of the supplemental type certificate or has permission from the holder to make the change.

Interesting article related to topic.

The following is an excerpted quote out of

Federal Aviation Administration
[Policy Statement Number ACE-00-23.561.01]

Proposed Issuance of Policy Memorandum, Methods of Approval of 
Retrofit Shoulder Harness Installations in Small Airplanes
An STC cannot be used to modify an aircraft without the permission of the STC holder. Federal Aviation Administration Notice 8110.69 dated June 30, 1997, requires the STC holder to provide the customer (installer or airplane owner) with a signed permission statement that includes the following: (a) Product (aircraft, engine, propeller, or appliance) to be altered, inducing serial number of the product; (b) The STC number; and (c) The person(s) who is being given consent to use the STC. The permission statement needs to be maintained as part of the aircraft records. The requirement for this permission statement originated in the Federal Aviation Authorization Act of 1996 (Public Law 104-264). This provision was put into law to try to stop the ``pirating'' of STC's.

The following is an excerpted quote from

Approved data can be used to substantiate major alterations/repairs and can be derived from:

(2) STC data, if it specifically applies to the item being repaired/altered. NOTE: The Federal Aviation Reauthorization Act of 1996 (Public Law 104-264), specifically section 403, STC, contains specific requirements concerning the use of STCs. It requires that the installer obtain permission from the STC holder to use the STC.