|Metro Aviation, a regular STC applicant, says efforts to streamline the process aren’t bearing fruit yet. Photo courtesy of Metro Aviation
For anyone who feels uneasy about the process for obtaining a supplemental type certificate (STC) in 2015, you’re in good company.
Making aftermarket changes to an aircraft has got to be a tense enough experience, especially with operators having to invest tremendous amounts of their time, capital and workforce before they even know whether their application is approved.
But recent changes to the FAA’s certification body have called into question whether traditional methods will even work anymore. In light of apparently growing mystification, Rotor & Wing looked into how organizations large and small are getting STCs, and hopefully their experiences can shed some light on the best way to authorize your much-needed modifications so you can get back to the business of flying.
On Jan. 28, 2015, Helicopter Association International (HAI) hosted an Industry-Government Forum in Alexandria, Va., giving members of the rotorcraft industry a chance to hear directly from and pose questions to FAA representatives on a number of pressing topics. One of the first and most active discussions was the effect the recent FAA restructuring would have on the STC application process. As the Lance Gant, assistant manager of the FAA Rotorcraft Directorate, explained, the agency had been finding it increasingly difficult to balance industry needs with its limited resources.
For starters, the bandwidth and technical capacity of Aircraft Certification Offices (ACOs) to oversee STC applications weren’t enough to handle the incoming requests.
On top of that, holders of organization designation authorizations (ODAs)—“super” delegations from the FAA to approved manufacturers and modification shops created to alleviate the agency’s certification workload—often still required a great deal of FAA oversight to function.
“Those of you who have ODAs know that ODAs are not really seen as effective as they should be at this time,” said Gant. “We’re hearing that not only from you, the industry, but from Congress.”
As a result, the FAA consolidated its Southwest Region certification offices It combined its three ACOs serving non-ODA-supported businesses into the single, full-service Fort Worth ACO. It then created a centralized office to oversee ODAs, called the Delegated Systems Certification Office (DSCO).
So why decrease the number of ACOs? One reason given by Gant is that incoming requests will now be assigned by a small program management team to one of the many journeymen engineers in the office, rather than the old protocol of allowing the much larger engineering group to cherry-pick projects. Hopefully, this will translate into faster turnaround time for STCs.
Many believe that the decisions the FAA is making are ultimately positive, but—as is the case with all large corporations—change takes a long time. For now, even four months later, the process for getting an STC still seems to move at a snail’s pace.
According to some in the industry, it may take more than a shift in logistics to alleviate the bottleneck. Already hurting from the effects of sequestration, the FAA is strained by a dwindling workforce, while the speed of technological innovation in the rotorcraft industry is increasing.
More STC requests are coming in than in years past, and many are new applications of technology never before addressed. According to Ric Peri, vice president of government and industry affairs at the Aircraft Electronics Association (AEA), that combination isn’t a recipe for efficiency.
“The downside is that while aircraft certification at the FAA is probably one of the more progressive divisions (looking at the FAA holistically rather than at individual offices), the individual certification process is still hugely independent,” he said. “So you end up having to educate the FAA engineer on the technology as part of the process. And then every time you take the project to a new ACO, it starts that process all over again.”
On top of that, Peri said, the FAA—like any corporation of that size—has a fair amount of turnover in individual job assignments. Every time an engineer turns over in a project, that project backtracks to bring the new engineer up to speed. “These are things that are really killing the industry, and causing huge price overruns, and frustration,” he said.
Add to that a persistent belief that the FAA has a dual mandate of fostering growth in aviation while simultaneously advocating for its standardization and safety. The increase in number and technical complexity of STC requests is at odds with the traditionally wary agency. As Peri said, “It’s very difficult for an engineer to embrace new and novel technology and still be risk-averse.”
Given that the FAA’s changes are primarily internal, the two-step initial process for requesting STCs is largely unchanged. A business wanting to make what qualifies as a “major change” to an aircraft’s type certificate decides whether to seek STC approval or attempt other means of certification.
If an STC is required, the business contracts through an ODA or a designated engineering representative. The former is more common among OEMs and larger operators with high overheads. The DER is a design engineer who takes on the management of getting the STC ready for approval.
In his work with the AEA, Peri has dealings with many businesses applying for avionics-related STCs. He said he has seen how critical these first two steps are in avoiding major roadblocks later on in the process.
Determining first if a modification actually requires an STC can save a business the tremendous frustration of doing work up front for nothing. This may seem like an easy task, but the FAA has periodically changed the criteria for what requires a given certification.
Hazards of the Process
“The bottom line is that there were a number of technologies that the FAA Rotorcraft Directorate deemed to be new and novel technology and had elevated the installation criteria to STC,” Peri said. “They have since, as a result of efforts going on for three years now, revised a number of those technologies and backed them down to a normal major alteration.” ADS-B Out and helicopter terrain avoidance systems (HTAWS) are two high-profile examples.
As bad as it may seem to go through the STC process unnecessarily, the reverse mistake can be even worse. One helicopter operator that preferred not to go on record reported actually losing a client after seeking field approval for a particular modification, only to find out from the visiting FAA inspector that the request would require an STC.
When it comes to the second step, contracting a DER, Peri cautioned against making the choice too easily. Not all DERs are well-suited to handling the paperwork-heavy, complex STC process.
“What happens is that a lot of maintenance shops will act as a general contractor, but they don’t have the resident regulatory and FAA relationship background to effectively pull it off,” Peri said. “It’s very similar to someone who tries to be a general contractor for having a house built, but really doesn’t understand the relationship between the different trades.”
A good DER should not only be a qualified engineer, but also a good project manager—preferably with past experience specifically managing an STC process.
Finally, the DER should have prior experience with the category of aircraft being modified, as well as with the technology being applied.