If the change to STC is Basic and does not require a change by the Certification Authority to STC, how does the operator/CAMO know the change is directly accepted?
As a matter of principle, when a Basic major design change does not affect the TC, TCDS, TCDSN, its approval by the CA (under provisions of TIP §3.3) is considered as a valid approval by the VA and will be accepted without any review and without any issuance of a VA approval.
In the specific case of STCs:
- If the Basic major change is brought by someone else than the STC holder, then it will trigger another STC (hence to be approved following the streamlined path)
- If the Basic major change is brought by the STC holder:
- If STC was revised to cover this change: to be approved following the streamlined path
- If there was no need to revise the STC: the mutual acceptance path (as per TIP §3.2) is applicable.
This is a very rare case where the major change to STC would be already covered by the documentation quoted on the STC certificate. This could be the case for an update of AML, update of ALS when no date is indicated on the certificate (ref. mention …”or later revisions of the above listed document(s) approved/accepted under the EASA system”).
In this very specific case, as for basic accepted design changes, the modality of approval by the CA serves as “proof”/indication that the change is directly accepted.
It is in the interest of the design approval holder to maintain a clear status of the nature of its changes approvals (validated or not, basic or non-basic). In case of doubt, confirmation should be sought from the CA.
Can a US manufacturing organisation use an EASA minor change as the means to apply to the FAA for a 'Request for Conformity'& permit release of parts on a 8130-3?
The FAA has launched an exemption process for extending the scope of approval of manufacturing organisation to the production of design approved by EASA only
Are there FAA fees to pay for STC validation?
The FAA does not charge any fee for validation
EASA/FAA Bilateral agreement Technical Implementation Procedures: Does EASA and FAA intend to improve the required 15 working days just for issuance of the approval which in worst case keeps the prototype aircraft on ground?
The 15 working days are not prescriptive, they indicate the maximum period of time for streamlined validation.
In case technical review is needed, adequate time for investigation has to be considered.
EASA/FAA Bilateral agreement Technical Implementation Procedures:The 15 days as timeline for the streamlined validation is far beyond reality! Is your statement based on own experience? The same question for Non-Basic validations with the 90 days timeline.
The 15 days have to be considered upon the receipt of the complete data package for a streamlined validation. There is no commitment for Non-basic validations to complete the evaluation and issue consequent approval in the time of 90 days.
EASA/FAA Bilateral agreement Technical Implementation Procedures: About the Validation Authority process, should the demonstration of FAA compliance (CS/FAR) be systematically provided by the applicant ? or not needed because checked by EASA?
The demonstration of compliance and related applicant's declaration of compliance have to be provided by the applicant. EASA can release the statement of compliance upon being provided with the above elements. The applicant should perform the compliance demonstration activity without being requested by EASA.
Are minor changes automatically accepted by both authorities (EASA and FAA) independently if they were designed by Designated Engineering Representative (US DER) or EASA Approved Design Organisations (DOA), independently from the registry of the aircraft?
Yes, it is possible. Minor changes covered by TIP §2.2.1/2.3.1 and TIP §3.2.2 are eligible to automatic acceptance by both authorities, independently of the registry of the aircraft and independently of whether they were designed by US DERs or DOAs.
However, as per the terms of the Bilateral Aviation Safety Agreement between US and Europe, the automatic acceptance is only applicable when the design approval is granted to an applicant located within the territory of US or the European Union.
Are minor repairs treated as the same as minor changes between FAA and EASA?
Minor repairs covered by TIP §2.2.2/2.3.2 are eligible to automatic acceptance by both authorities. In principle they are treated the same way as minor changes, although for a minor repair the applicant does not have to show compliance with the Validation Authority certification basis.
It seems that EASA PCMs prefer to close EASA type investigation before the involving of FAA for validation purpose.
Concurrent validation as per TIP rev 6 is only accepted for Non-basic design changes. Concurrent validation principles are expressed in TIP rev 6 para 3.5.7.3.
Can an EASA Design Organization use Designated Engineering Representative (DER) approved minor changes with no EASA involvement?
Yes, when covered by TIP §2.3.1, DER approved minor changes issued to US design holders are automatically accepted by EASA.
One of our customers is not accepting an EASA minor change to FAA STC on an Airbus Aircraft. They need the FAA STC to be validated by EASA first. What’s your opinion?
The minor changes are considered changes to the aircraft and there is no formal link to the STC. Therefore the FAA STC does not need to be validated by EASA.