This is interesting because in the FAA system once you have an STC you have it for ever, with no ongoing fees. For example I was able to fix the Shadin fuel totaliser problem by implementing a decades-old Shadin STC. I doubt many people know about this.
This is another curious one: the KFD840 EASA STC was revoked in 2016
So what happens to existing installations? There weren’t many (less than 10 I suspect) and I did hear that after installation the owners were told the IFR status was lost and were really p1ssed off but could do nothing. One big contributor here rents a KFC840 equipped plane from a school somewhere.
How big are the EASA STC annual fees?
Curiously I can’t find an annual fee for STCs.
What’s very strange is that the annual STC fee for EU designs is three times as much as for non-EU designs.
Why is that strange? A non-EU design has been approved by a foreign CAA, so in theory all the hard work of certification is done, EASA only has to validate it.
A non-EU design has been approved by a foreign CAA, so in theory all the hard work of certification is done, EASA only has to validate it.
Probably not worth arguing about the charging difference, but AIUI you apply for an EASA STC using the FAA STC design data, and there is nothing special about that design data between EASA and FAA (it has to come from EASA 21 or FAA DER respectively, or be in the form of approved documents e.g. installation manuals). EASA does not accept FAA STCs; it accepts certain categories of design data.
The thing I found really surprising is that EASA appears to charge annual fees to STC holders. That makes the economics of EASA STC generation pretty difficult, unless you are selling some pricey hardware on the back of the STC and you keep selling new boxes all the time, in some reasonable quantity. Once the sales drop down to little or zero, you will probably want to abandon that STC and while that obviously cannot make existing installs illegal (unlike a TC which is abandoned which in Euro-land grounds the aircraft) it will prevent somebody doing a fresh install with a secondhand box.
This isn’t going to bother a big player like say Garmin but it makes life hard for a small company, and for all customers who might be installing that company’s products in the far future, perhaps after that company has disappeared. In FAA-land you can make use of an STC even if the company has gone. There remains the interesting case of an STC which states that the STC holder’s permission to use it is required.
I suppose somebody could argue that annual fees for approvals help to create an innovative landscape, via automatic removal of “old” approvals. I saw the same argument with ROHS, where the EU said this drives new product designs and therefore innovation, and obviously hardware and software engineers like that. It just screws the customers…
Probably not worth arguing about the charging difference, but AIUI you apply for an EASA STC using the FAA STC design data, and there is nothing special about that design data between EASA and FAA (it has to come from EASA 21 or FAA DER respectively, or be in the form of approved documents e.g. installation manuals). EASA does not accept FAA STCs; it accepts certain categories of design data
You don’t apply to EASA using the FAA STC data. The FAA STC holder applies to their local FAA ACO and it’s the FAA that deals with EASA and sorts the validation.
Now if an FAA STC holder doesn’t want to go down the validation route, then an EASA Part 21J can apply for a new STC and use some of the FAA STC data, but will still need to produce much of the EASA stuff themselves.
The thing I found really surprising is that EASA appears to charge annual fees to STC holders
The annual fees to hold an EASA Part 21J approval cover the surveillance oversight which EASA conducts (routine audits etc). In addition of course, every STC attracts fees (sometimes very substantial for what can be trivial jobs) as the fees are related to the weight of the aircraft more than the complexity of the design change.
Can it really be true that if an EASA STC holder goes bust and thus stops paying the EASA fees, the STC becomes invalid and an existing installation becomes illegal?
If so, how can STCs be a viable business model, since the STC holder has recurring payouts but no recurring income.
The problem I see with recurring fees for EASA type certs and STCs is it leaves the sword of Damocles hanging over the aircraft owner. Should the manufacturer go bust or lose interest, the owner’s substantially valuable aircraft can become worthless overnight. It’s another reason I’d never own a certified EASA reg plane.