ISTAT Jetrader - Autumn 2020 - 43

In doubt, however, is the commercial "right to use"; the
authorization of the use of installation and maintenance
data for operation; how the authorization is written;
where the authorization is held; and ease of maintaining
the authorization.

Understanding the Data
There are legal intellectual property (IP) aspects associated
with authorizing the commercial right to use data. STC
holders have both the right and the obligation to own and
maintain the IP for their modifications and approvals. It
would be a simpler world if the operator that contracted the
modification operated the aircraft throughout its life cycle,
but as this is not often the case, clear and concise rules and
guidelines are needed to reduce friction in aircraft transfers.
To better appreciate the intricacies, let's look at the
records an STC holder possesses in relation to obtaining an
STC versus the information required to operate the aircraft.
In securing an STC, the holder must develop and maintain
the following data:
*	 Substantiation - structural substantiation reports,
system substantiation reports, etc.
*	 Manufacturing - LRU or kit fabrication data
*	 Test - flammability test results, qualification test
results, on-aircraft test results, etc.
*	 Installation - wiring diagrams, wire routing
drawings, etc.
*	 Maintenance - instructions for continued

updated, maintained and available to current and future
owners and operators of the aircraft.
The intent of the right to use authorization is to allow
the owner or operator to use the STC installation and
maintenance data to modify, maintain and operate the
aircraft specified under the authorization. The right to use
authorization is not intended to cover any other use, e.g.,
repurposing or reselling STC data, unless the STC holder and
operator or owner have previously agreed otherwise.

The Solution
Working with a cross-functional group of equipment
manufacturers, STC holders, operators and lessors, IAMA
developed its Rulebook. The Rulebook outlines and prescribes
the implementation of the rules and guidelines for all
members to alleviate these times of transfer pain points
caused by STCs. Key enhancements that improve the transfer
process include:
*	 Addressing the right to use statement to the legal
operator/owner of aircraft
*	 A statement of automatic transferability to any future
or subsequent operator/owner of the aircraft
*	 A full list of documents covered under the specific
right to use statement
*	 Duplicate location of the right to use statement, within
documentation packages
These few steps enable transfer planning in advance,
without the requirement of assignment or further

There are legal IP aspects associated
with authorizing the commercial right to
use data. STC holders have both the right
and the obligation to own and maintain the
IP for their modifications and approvals.
airworthiness, electrical load effects, functional test
procedures, etc.
*	 Modification - structural installation drawings, etc.
*	 Operation - flight manual supplements, weight and
balance effects, etc.
The preceding may be shared with the contracting party
but are not data required for operation and use. Installation,
modification, maintenance and operational records are
required for ongoing use of the aircraft and must be shared,

documentation gathering, and support the enhancement of
the value to the asset and free use for future operators.
All IAMA members have agreed to these rules and
guidelines. Members support standardizing the entire STC
process to the benefit of all stakeholders: aircraft and
equipment OEMs, airlines and owners.
To learn more about how the rules enable a seamless
transfer, please visit iamalliance.aero and gain free access
to the IAMA Rulebook and all related content.
Jetrader

* AUTUMN 2020 * 4 3
http://www.iamalliance.aero
ISTAT Jetrader - Autumn 2020

Table of Contents for the Digital Edition of ISTAT Jetrader - Autumn 2020
