EASA operational support to engineering tasks (i.a.

processing of STCs)

Vincent De Vroey
Vincent.De.Vroey@aea.be
www.aea.be

4th EASA-Industry Meeting

Cologne, 17th November 2005
Background

On 23rd May 2005, the AEA wrote to EASA, expressing concerns

about increasing difficulties faced with processing Supplemental
Type Certificate (STC) applications under EASA Design
Organisation Approval (DOA).

The AEA was in particular concerned that if not resolved these

difficulties could put the EU industry at a competitive
disadvantage in the international modification market.

The AEA met with the EASA Certification Director on 7th July to
explore practical solutions for the problems raised. Various
actions and commitments to improve the process were agreed.
Lack of clear procedures is a key problem

1)Lack of written procedures and standardisation

for STC applications and processing

EASA internal working-procedures are still not detailed enough

and have resulted in a lot of confusion on how to apply and make
progress with applications.
Clear procedures are needed now!

EASA agreed to develop standards/policies and to put certain

conditions (i.a. maximum number of hours) in contracts with
NAAs (who act on behalf of EASA).
 Status?
DOA privileges

2) Some NAAs acting on behalf of EASA continue to

check 100% of the data, which is not in line
with DOA privileges

EASA committed themselves to provide training for PCMs and to

set up a working-group to develop more guidance on the scope
of the DOA privileges

In the mean time, some NAA’s continue to check 100% of the

data, with no signal from EASA to them that this should not be
the case. Implications in term of costs and delays are significant.

 Status?
List of persons in charge and central applications office

3) No list of persons allowing direct contact

for STC and AMOC applications and
investigations. This is particularly important
during the STC pre-application phase.

• Still no list published. Up to 6 weeks delay between application

letter and contact with the PCM.

 Clearly unacceptable.

• EASA confirmed, that it has the intention to create a central office

for applications.

 Status?
Late acknowledgement of STC applications

4) Late acknowledgement of STC applications

EASA has the objective in the future to acknowledge applications
within 10 days. This will include information on the team which
has been allocated and will include contact details of the person
in charge.

However, this objective has not been yet met since airlines
continue to be faced with unacceptable late acknowledgement
(up to 6 weeks).
 Solution needed now to avoid serious distress to the EU
repair industry!
Delays technical VISA/issuing STC

5) Important delays between the TV (technical

visa) and the issuing of the STC. Furthermore,
the use of Article 10.3 to release the aircraft
based on the TV is not always possible (e.g.
registration NAA different from the TV NAA).
EASA has a clear objective of a maximum 1 day between the
technical visa and the issuance of the STC,
 Delays are still important (up to 6 weeks).
Furthermore, this may still not be sufficient in all cases (e.g.
aircraft awaiting release to service after final flight test).
 Legal status should be given to the TV, in order to allow
the aircraft release to service immediately after the TV
issuance (as compared to FAA process!), pending final STC
issuance.
STC applications based on FAA STCs

6) Timeframes for processing STC applications

based upon FAA STCs too important. (FAA responds
very quickly)

EASA undertook to look for improvement.

 Problems continue to be faced. Urgent improvements
needed
EASA problems related to FAA STCs

7)Complicated and time consuming EASA processes

for EU Airlines importing used airplanes with
multiple FAA approved non-TC holder STCs
Unless it can be demonstrated that the STCs have been
approved by any of the EU NAAs prior to cut in of the EASA
system (Sept 28, 2003), EASA review and approval of the STCs
is required. Typically this may take 3-5 months, occasionally even
longer.
Some holders of these US STCs are no longer conducting
business. Thus, there are no legal applicants who can process
STC approval applications to EASA!
 A general EASA acceptance of all FAA STCs approved
and installed on airplanes prior to Sept 28, 2003 seems a
pragmatic solution.
Fees & Charges

8) EASA fees & charges payment conditions result

in further delays for administrative reasons and
may result of aircraft grounding

 Some improvement noted but need consistency for all

applicants!
Other issues: EASA AD Process

• Subscription service on AD notification:

EASA notification system (by e-mail) is needed on all changes to
the EASA website (including and specifically on AD items).
 When and at which cost?
• EASA AD Process:
Lack of procedures on who to be contacted with regard to
technical content of EASA ADs. Even the Project Certification
Manager/EASA AD Focal Point does not know necessarily to
whom he should address a question related to the technical
content of an Airworthiness Directive.
 Clarification/procedures needed