ISTAT Jetrader - Spring 2022 - 34

Navigating an Orphaned
Supplemental Type
Certificate Situation
by Kimberly Miller, Lessor/Owner Advocate, Independent Aircraft
Modifier Alliance (IAMA)
A
ircraft operators are responsible for
the continued airworthiness of the
airframes and engines they operate.
This starts with knowing the status
of relevant type certificates (TCs) and
supplemental type certificates (STCs).
Therefore, continued technical support
provided by the design approval holder (DAH) of the TCs and
STCs is essential. So, what happens when the DAH no longer
provides support? The Federal Aviation Administration (FAA)
and European Union Aviation Safety Agency (EASA) have
different processes in place to ensure continued support for
TCs and STCs, and risks to operators differ by how the TC or
STC has been orphaned.
" There are a variety of reasons why a DAH might stop
supporting an STC, " says Andreas Gherman, senior adviser of
authority relations at the Independent Aircraft Modifier Alliance
(IAMA). " Some circumstances that can result in orphan STCs
include the business closing, the loss of its approval as a design
organization or, in rather seldom cases, the invalidation of an
STC by the aviation authority that had granted its approval. Any
one of these situations creates a problem. When a DAH removes
its support of an STC, this can create major risks for the
operator and challenges to restoring continued airworthiness. "
Surrendered STCs
A surrendered STC is one where the DAH has declared that
it no longer supports its STC and has duly informed the
34 * THE OF F I C I AL PUBL I CAT I ON OF ISTAT
responsible aviation authority and, ideally, the operators
affected by their decision. However, in real-life situations,
it might be difficult for the DAH to locate all the affected
aircraft and their operators, as the aircraft may have
changed operators many times since the installation of the
STC. The resulting risk for the operator(s) is that they may
not become aware of the action of the DAH.
Abandoned STCs
An abandoned STC is one where the DAH has stopped
supporting an STC because it went out of business, has
lost its approval as a design organization, or for any
other reasons in which it cannot and will not continue its
support for the STC. In most of these cases, the DAH has
not informed the responsible authority and the affected
operators. As a result, the operator(s) remain unaware that
their aircraft's STC(s) are no longer supported until in need
of support.
Invalidated STCs
An STC can also be invalidated by the respective aviation
authority. If this happens, the approval basis of the STC is
no longer valid and the affected aircraft cannot be operated
until the STC is re-instated or removed from the aircraft
(i.e., pre-modification status is reestablished). Although
invalidations occur rarely, the severity of the consequences
to the operator could be high.
ISTAT Jetrader - Spring 2022

Table of Contents for the Digital Edition of ISTAT Jetrader - Spring 2022
