STC's

Checkout_my_Six said:
the PMAs are not transferable....they had to "re-apply" for that approval.
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Exactly, even if are an STC holder, the manufacturing approval doesn't go with it. We hold a few STCs but we have to find someone who can legitimately produce the thing. Even the case where the father held the STC and when he died it went to the son, since the STC was in the guy's personal name (not the shop), there's no current manufacturing authority. If you can find existent parts, you can get a new copy of the STC, otherwise you are out of luck (currently).
 
Checkout_my_Six said:
the PMAs are not transferable....they had to "re-apply" for that approval.
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Nope,, once you become the owner of the production certificate, you are the manufacturer. no need for PMAs. you can change any part's design you like.
you buy the company owning the STC you can change any portion the STC you like. You can even require the previous buyers to retro fit to new parts simply by asking the FAA to issue a safety AD requiring what you want upgraded
 
Production certificates are not transferable either Tom. :D

Hence the issue with PMA authorizations.
 
Stewartb said:
I know a few airframe STC holders and their flight testing required high speed dives and spins.
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Tom-D said:
Nope,, once you become the owner of the production certificate, you are the manufacturer. no need for PMAs. you can change any part's design you like.
you buy the company owning the STC you can change any portion the STC you like. You can even require the previous buyers to retro fit to new parts simply by asking the FAA to issue a safety AD requiring what you want upgraded
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Obtaining an AD is not as simple as you imply.
 
Obtaining an AD is not as simple as you imply.
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I don't know how simple he's implying, but it is indeed NOT DIFFICULT if the manufacturer pushes for it. It used to be that the manufacturers took pride in the fact that ADs **WERE NOT** issued against their planes. Now we've had a few manufacturers push the FAA to install onerous ADs that had little motivation OTHER than to increase parts sale revenue for the manufacturer. Believe me, I was quite involved in protesting two of them. My name's even in the preamble for the final rule. On that one, the FAA guy even admitted the stasistics were hokum, but he couldn't really stand up to the pressure of the manufacturer pushing the AD as being safety critical. What he did do on the other hand, is sign off on any reasonable AMOC that people could come up with. I have one of the AMOCd parts in my plane. The type club PMA'd their own part (which is what most people ended up buying). Even a few people got one-off AMOC approval to use parts from Aircraft Spruce.
 
STCs are what they are. Revisions are revisions. STCs are a market thing. PMAs are a manufacturers thing. Different but often related. I have a couple of different tail skis by the same manufacturer. Both are covered by the manufacturer's PMA. The STCs are different. Same ski, different install details, different AML.
 
Checkout_my_Six said:
you'll have to get into the orders in 8120....I'm not getting into that here.
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Here you go.

08/31/2010
8120.2G
2-49
Part 4. Post-PMA Activities
2-49. Transferability.
a.
A PMA is not transferable to another
person, company, or location. The regulations
do not preclude revising approval
letters to show a change in na
me only of the holder, provided
there is no change in the quality system, mana
gement, ownership, or location of the principal
facility. However, the design portion of a PM
A based on an STC may be sold, licensed, or
otherwise transferred. If the STC holder or a li
censee intends to manufacture articles, it must
apply for a new PMA.
b.
In the event a PMA holder is acquired
by another company, with no resulting change
in the legal status of the PMA holder, the acq
uiring company will not be required to apply for
a new PMA. However, the PMA holder must:
(1) Retain possession of
the production approval,
(2) Retain the same quality system, and
(3) Continue to operate at the same locati
on with the same core management officials.
c.
The PI should conduct an on-s
ite visit to ensure that the PMA holder has complied with
the requirements in paragraph 2-49b of this or
der. In addition, the acquiring company should
provide a letter to the MIDO i
ndicating its status as the new
owner of the PMA holder and any
future plans affecting the status of the PMA hol
der. The PI should update the project files to
include documentation indicating the acquisition.
d.
In the event that the status of the PM
A changes (e.g., the PMA holder is disbanded or
absorbed into the acquiring company) or the PM
A holder transfers or relinquishes its production
approval, the ACO or MIDO will ensure that a new application for PMA is submitted for
processing by the FAA.
 
Get it right:
PMA --- simply means you have the FAA's authority to manufacture parts for some one else product.
STC --- Simply means that you have the FAA's authority to modify some ones else product.

WAY to simple for some to understand.
 
Tom-D said:
Get it right:
PMA --- simply means you have the FAA's authority to manufacture parts for some one else product.
STC --- Simply means that you have the FAA's authority to modify some ones else product.

WAY to simple for some to understand.
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Actually, holding an STC says you can sell authorizations to modify a TC'd product.
 
Questions:

1-if I have a mod done to my aircraft (for which the mod Mfg has an STC), do I legally need a copy of the STC, and if so, does my copy of the STC paperwork have to have my tail number and serial number on it? (I think the answers are yes).

2- is a form 337 required to be sent to FAA for each mod that has an STC, and do I need copies to be legal? (I think yes).

3- do any of the STC or 337 copies need to stay on the plane? (I think they don't).

4- last question, does the owners manual or instruction book of the mods need to stay in the plane (just like the POH)? Thinking like GPS, autopilot, BAS harness, etc., to fill up my glovebox...
 
1-Yes, the FAA requires an STC holder to assign permission for the STC to be used on your specific airplane. Its usually a raised seal on the STC document with your airframe info and the STC holder's original signature. STCs are not transferrable to other airframes without new permission paperwork.

2-Your IA uses a 337 to document the alteration and a 337 is sent to the FAA for their records. You keep the STC and 337 copy in your aircraft logs.

3-No

4-If the STC includes a flight manual supplement that needs to be in the plane.
 
StewartB is correct with one exception:

The only 337 that needs to stay in the plane are in-cabin fuel tanks (ferry tanks for ocean crossing, typically).

Yes, part of the STC (these days) are going to include instructions for continued airworthiness, which you and your mechanic will need for servicing and typically a "flight manual supplement. I have a half a dozen supplements for the non-existent Navion flight manual. They include the Autopilot, the GNS480 IFR GPS, The tail modification, The Tip Tanks (the latter two change the W&B), the engine analyzer, and the MX20 MFD. I'm probably missing something doing it from memory. The GPS, MFD, and the AutoPilot all require the respective pilot guides to also be in the aircraft. I have a binder with all the required stuff along with my handy W&B worksheet I created right before my last checkride, in a nice binder in the back.
 
Tom-D said:
Get it right:
PMA --- simply means you have the FAA's authority to manufacture parts for some one else product.
STC --- Simply means that you have the FAA's authority to modify some ones else product.

WAY to simple for some to understand.
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The way I read it, you can't just decide to start building something to sell as a legal replacement part. PSA LED nav light replacement lamps comes to mind. I think the key is creating and maintaining the quality control system to ensure the first or the hundred and first unit meets manufacture specs. Any major change to the business, like selling to another firm, will require an evaluation of the new company and their processes, to ensure the quality is there.

Beechcraft has been bought and sold several times over the last few years. Same with Piper. I wonder what hoops they had to jump through to keep the production line running? A similar scenario I would think.
 
If the processes, employees, and geo-location doesn't change...effectively just a name change....it's a minimal paper work exercise to re-instate the manufacturing certs.
 
STC's are also great recurrent revenue generators for the holder. To wit, try and remove an STec autopilot from one PA 24, and install it in another PA 24. Same airframe, different serial no. Yes, you get to pay STec $$$ for the priviledge. Osborne tip tanks, same dealio.

In fairness, not all STC holders play that game.
 
Don't get me started on J.L.Osborne. They defrauded me out of $1000 for services they never performed.
I asked for a duplicate flight manual supplement as I couldn't find mine when I was updating my paperwork and they wanted $20 for ONE sheet of paper.
One sheet. For an existing customer. I eventually found it still attached to the 337 (never apparently got appended to the non-existent flight manual).
 
Tom-D said:
it really is,, just say this is a safety issue. bingo. new AD.
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If it were that simple, you would be up to your eyebrows in ADs for your airplane because every component manufacturer would use an AD to require the purchase of new product or upgrade.
 
Clip4 said:
If it were that simple, you would be up to your eyebrows in ADs for your airplane because every component manufacturer would use an AD to require the purchase of new product or upgrade.
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I'm glad he doesn't have a clue how this works....cause it just isn't that easy.:confused:
 
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Just for fun, also mentioning that STCs can be sold. And the new owners can change pricing on them as they please.

I'm pretty sure old man Robinson wouldn't haven't charged $900 for half of a piano hinge you could buy at Home Depot, for the rear half of the aileron hinge once the STOL kit is installed.

But the current Robinson STOL STC holder sure does. $900 for half of six piano hinges. (You still use the Cessna half on the front.)

Total rip-off.
 
Sounds like you have a business opportunity. Raise some start up cash, do the engineering, get your approvals and PMAs, then sell low volumes of parts for cheap. No need to be concerned with business principles like return on investment, making a profit, etc. Rock on!
 
Stewartb said:
Sounds like you have a business opportunity. Raise some start up cash, do the engineering, get your approvals and PMAs, then sell low volumes of parts for cheap. No need to be concerned with business principles like return on investment, making a profit, etc. Rock on!
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Me? I already have plenty of business stuff to take care of.

Or are you referring to someone else in the thread?

It would not be possible to duplicate the Robertson STC today. No way. FAA would see it directly affects flight controls and it claims that the very reason people put them on aircraft is an "emergency procedure only" and they'd have kittens.

For better or worse, you'll never see innovations like that again. That was a by-product of the 70's.

FAA can't even handle a company using an unapproved chip in a non-essential to flight ADS-B radio these days. (Not that you'd know avionics are non-essential to flight these days, either.)

Owners of old STCs love to gouge on parts. They didn't pay for all of that stuff. They just buy the STC at the fire sale, cheap, when the original holder gets old or dies. There's no business numbers that justify half of six piano hinges priced at $900.

Now that I think about it, that might be 50% low even. We may have only gotten one wing worth for $900. I'd have to check the sales paperwork. Yeah, pretty sure that's three half piano hinges at $300/ea.
 
Note that an STC doesn't even necessarily require any parts. The auto gas STCs are one example (maybe there's a sticker?)

All this hassle is a big part of why I own and fly an experimental.
 
Then there's the problem of orphaned stc's...or ones that are not orphaned, but no longer suupported.
 
Dana said:
Note that an STC doesn't even necessarily require any parts. The auto gas STCs are one example (maybe there's a sticker?)

All this hassle is a big part of why I own and fly an experimental.
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There's a required sticker/placard. At least on the EAA one.
 
455 Bravo Uniform said:
Questions:
does my copy of the STC paperwork have to have my tail number and serial number on it? (I think the answers are yes).
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Not necessarily. Some manufacturers, like Garmin, issue "blanket" STC permission letters that are not airframe specific. Others (like STec) issue STCs to the individual aircraft.
 
Clip4 said:
If it were that simple, you would be up to your eyebrows in ADs for your airplane because every component manufacturer would use an AD to require the purchase of new product or upgrade.
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http://www.vg-21.org/adnote/98-01-06.html
That whole series of ADs were obtained bt Precision air motive after they documented 7 failure in 35 years of that carb usage.
the whole mess was ran thru SEA FSDO in 1 day by stating there was an emergency safety situation.

I know because I was involved with the three revisions of that AD. made all the hearing at FSDO that resulted getting the final re-write saying you can leave the 2 pice in place and inspect every 100 hours.

those of you that don't think you can get it done in 1 day don't know how fast the FAA work when you scare them bad enough.

the crank AD that recalled so many crankshafts was done in about the same time frame. All the Manufacturer had to do was show the manufacturing defect and bingo... new AD.
 
Chip Sylverne said:
Then there's the problem of orphaned stc's...or ones that are not orphaned, but no longer suupported.
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Apply to your local FSDO, for a list of STCs that are in public domain, there are not that many. (as of a year ago) If they are not on that list, and you can not get the owner to reply you can't use them.
You must show the FAA That you bought the intellectual property owned by the STC developer.
In many cases, the STC was developed for use on the developers aircraft, and they simply do not want the liability of having the info used by others.
 
Checkout_my_Six said:
I'm glad he doesn't have a clue how this works....cause it just isn't that easy.:confused:
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How many ADs have you dealt with? Have you ever even been to a hearing at FSDO?
If so quote the AD
 
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