20th April 2021
Whether adding connectivity, improving safety, bolstering functionality or updating passenger cabins, Supplemental Type Certificates — managed by independently regulator-certified companies called design organisations — are in many ways at the heart of modern airlines’ operations.
But what if one of those companies disappears, goes bust or decides it’s getting out of the game? We spoke with Andreas Gherman, advisor for authority relations at the Independent Aircraft Modifer Alliance, a grouping of MRO operators promoting standardisation within the industry. He explains that the resulting orphaned STCs are a hidden and complex risk for aviation — not least because of the myriad STCs in existence [PDF] — but one that IAMA is working hard to reduce.
Part of the complexity is that aircraft operators are responsible for continued airworthiness. In the case of STC-certified modifications, they rely on the certification secured by the design approval holder, or design organisation (DO).
If Example Airways commissions modification work from, say, a DO called Placeholder Technical Services, then it’s Placeholder that secures approval from regulators for that mod. If the mod needs to be changed in some way — an airworthiness directive, or design deficiency, or a desire to further modify the area of the aircraft around the STC — then Example Airways needs to engage Placeholder Technical Services to do so, because Placeholder holds the STC. But what if Placeholder isn’t around any more?
This leads us to the three kinds of orphaned STC situation: one where an STC has been abandoned suddenly, one where it has been surrendered in an organised way, or one where it has been invalidated by regulators.
For an abandoned STC, let’s imagine the DO responsible for it has abruptly gone out of business, its staff dispersed, nobody answering the phones. This leads to an abandoned STC: the DO can’t be contacted by operators, regulators or anyone else.
In the second scenario, where perhaps the DO is exiting the STC business less abruptly — a pivot in business model, say — it (and indeed its operator customer) may be able to find another DO to take on the STC, perhaps with the assistance of a regulator. This is a surrendered STC.
The last scenario is an invalidated STC, which is at this point in time largely a theoretical category. Here, a regulator has decided that either a design or a design organisation itself has gone very wrong, likely through malfeasance or ineptitude. Perhaps test results have been falsified, or something else equally egregious. To avoid a situation where the operator would be required to completely uninstall (and “demodify”) the modification from their aircraft, an operator and regulator might approach a second DO to take on the invalidated STC and make it right.
Doing nothing without a DO holding the STC, quite simply, is not an option. While the aircraft can continue flying in the very short term, the moment that an airworthiness directive requires inspection or corrective measures to be taken, that work would need to be certified by the STC-holding design organisation. And if that DO doesn’t exist any more? That becomes a big problem.
Approaches to Orphaned STCs from the FAA and EASA Differ
“In principle,” Gherman says, the logic behind regulatory principles around orphaned STCs is the same between the US FAA and Europe’s EASA: “‘as an authority, we want to — and we have to — ensure continued airworthiness’.”
To an extent, the regulator perspective is “‘we don’t care about the business of the design organisation — we want these changes, STCs, to have continued airworthiness coverage’,” Gherman explains. That said, “how they do it is a little bit different.”
Compared with EASA, Gherman summarises, “the FAA has a more formalised approach: they have advisory circulars out there, which deal with the subject, and they describe what they do if they become aware of a surrender situation. They have a two step process: first, say, if it’s abandoned, they try to locate the respective design organisation which has disappeared, or whatever the follow-up organisation might be. If it’s surrendered, they strive to find another design organisation to take care of those STCs.”
So what does a new DO need in order to take over an STC? In a word, says Gherman, “everything.”
As headline items, Gherman ticks off a list: “all the engineering and certification work the [former DO] has done: all the showing of compliance, all the tests reports they have made, all the calculations they have made… engineering wise and certification wise, how did they show compliance? What inspection methods did they prescribe for the change configuration?”
And the “everything” may well come in boxes: reams and reams of physical paper, or if the receiving DO is lucky, perhaps PDF files. But that’s just the start: the receiving DO is likely to approach their work differently from the way the original DO did. That’s why, Gherman says, you need a good theoretical insight into the structure of the data that’s being received.
This can be complicated even between companies within the same larger corporate group, Gherman explains, citing “in my previous responsibilities, one example where we took over — in an orderly and orderly manner — STCs from from an affiliate company, which didn’t go out of business, but it stopped being a design organisation. It was even more complex because it was an FAA design organisation and we took it over as an EASA design organisation.”
IAMA is working to make this process simpler and to add trust: members will promise not to simply abandon STCs but to surrender them formally, and to make best efforts to help operators secure a new design organisation among — or even outside — its members.
But a large part of the problem comes from the sheer amount and lack of common structure of the data contained in an STC.
Understanding Data Structure is Crucial to the STC Transfer Process
With little standardised data structure and a historical framework where STC modifications are essentially mailed (more recently either faxed or emailed as Excel files and PDFs) over as thick stacks of paper, transferring STCs is especially complex, even within a wider corporate group.
“My data structure, my design tree, or whatever it’s called in design organisation A, will be totally different from design organisation B that did the same kind of change, because there are so many ways to show compliance,” Gherman explains.
Part of this is inherent to work around STC airworthiness directives being somewhat backwards-looking. An example Gherman gives is a regulator initiative involving structural changes that involved reviewing more than 700 STCs all the way back to 1972.
But nonetheless, “the source of the data — the way they are done, and the way they are also dealt by the authorities — is still far away from from exploiting what is available in digital data technology today,” he says.
“It’s not criticism against the authorities that they are still working that way,” Gherman is quick to point out.
“EASA, more than the FAA, is on its way to create more on data structures and digital documentation flows,” Gherman assesses. “EASA is doing quite some effort to structure the way they receive data from the design organisations. That means they ‘force’ you [to submit data] in a certain frame. And that leads automatically to an upstream harmonisation of how the design organisations work, because they want to work smoothly with the authority, but it will take time.”
It’s clear, as a result, that the world of STCs, especially around the orphaning process, is a ripe opportunity to digitise — and digitalise — legacy processes within aviation.
Join the Challenge
Andreas Gherman, advisor for authority relations at the Independent Aircraft Modifier Alliance, believes that a new design organisation needs ‘everything’ in order to take over a Supplemental Type Certificate. Do you agree?
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