My Annex II was previously registered in the UK which in general I was quite happy with. The reason I put it on the dutch register was finally that the permit renewal was a pain for me because I’d have to fly (from Germany) to the UK or an LAA-inspector would have to come over to sign the papers.
To come back to the initial thesis: yes, my experiance is, that the dutch CAA is also very aviation friendly and straightforward e.g. on approving MODs. They even approved an increased MTOM up to the US-limit, just on the basis of another identical aircraft already registered in the Netherlands. I also made a whole new panel layout and they approved that, which shall be deemed as impossible with the LAA.
A major step forward though is the UK liberal approach concerning IFR in permit aircraft.
Peter wrote:
But if you read those treaties you find they never specifically bind either party to automatic mutual STC acceptance. They are 90% bullsh1it and waffle – basically a statement of intentions to be good brothers.
I don’t see why that should be specified, an STC is just a modification like any other modifications. IMO they are straight to the point technical agreements.
Found an Advisory Circular from 1982 that list up all these agreements that the FAA has signed, and some explanations about what they really are (and what they are not).
http://www.faa.gov/documentlibrary/media/advisory_circular/ac21-18.pdf
No one has cancelled these agreements, so clearly they are in effect. But FAA and EASA also have something. I haven’t read it (or the links), but it looks to be something like “we agree to approve your approval, if we approve it” said in a ton of pages in several documents and annexes.
an STC is just a modification like any other modifications
I guess the authorities get emotional about STCs because an STC is not a one-time mod (like the FAA Field Approval or DER 8110 route). It is an approval which immediately applies to possibly a huge number of aircraft and it can be applied without the authorities being able to do anything about it.
Also Europe doesn’t have an equivalent to the DER route. There is no way to do a Major mod without EASA oversight. The rough equivalent to an FAA DER would be an EASA 21 company but they can’t do it alone. All an EASA 21 company can do, without reference to EASA, is some classes of Minor mods. EASA has got the business strung up very tight, trusting nobody with nothing.
Also as I said earlier an STC removes a lot of work from firms that have design approvals, which in some cases they spent a fair bit of time and money on.
There is a big difference between “We will accept an FAA STC as the basis to issue our mod approval” and “Go ahead and do it if there is an FAA STC”
The latter situation is what the CAA have now said.
The former exists in several places and used to be the situation in the UK, but it costs a lot in time and money to get the modification approval in that case.
Peter wrote:
I guess the authorities get emotional about STCs because an STC is not a one-time mod (like the FAA Field Approval or DER 8110 route). It is an approval which immediately applies to possibly a huge number of aircraft and it can be applied without the authorities being able to do anything about it.Also Europe doesn’t have an equivalent to the DER route. There is no way to do a Major mod without EASA oversight. The rough equivalent to an FAA DER would be an EASA 21 company but they can’t do it alone. All an EASA 21 company can do, without reference to EASA, is some classes of Minor mods. EASA has got the business strung up very tight, trusting nobody with nothing.
Also as I said earlier an STC removes a lot of work from firms that have design approvals, which in some cases they spent a fair bit of time and money on.
What do you actually mean? EASA is nothing but an organisation created by sinister lobbyist whose sole purpose is to leech GA to death?
I just mean that, in the real world, commercial interests do exist.
And quite often they hold back innovation, consumer choice, etc.
If I pay you €100k/year to regulate the thickness of Mars Bar wrapping paper, and one day the Mars Bar manufacturer can apply an FAA STC which does you out of a job (remember you have a house, a wife, 6 kids, a Porsche Cayenne, a mistress, etc) will you say “OK, my job was stupid and pointless anyway, I am happy this happened because it gives me the opportunity to look for a real job which adds real value to our society”?
What I am told by many maintenance companies, over the years, is that they would like FAA STCs to be accepted directly, because it would generate a lot more installation business for them.
However, some of them are EASA 21 firms some of whom make a good living from developing EASA STCs (avionics, mainly) which they sell to other installers for €1000+ a time.
Some of them even charge N-reg customers ~ €2000 for a DER package (for some mod) which they then use to obtain the EASA STC – I got such a “deal” proposed to me once (didn’t go for it because the product came with an AML STC anyway, and the proposed DER package was a spurious proposition, ostensibly needed for mounting the box).
Peter wrote:
I just mean that, in the real world, commercial interests do exist.And quite often they hold back innovation, consumer choice, etc.
And that is one reason we have governments, to give innovation space to thrive and take apart stagnant corrupting monopoly situations. Nothing is perfect, but EASA sometimes look really strange and decadent as a (super)governmental organisation. Then again, the next minute they look like a good thing. LAPL, ELA, VLA are all steps in the right direction where practical solutions have taken over for stagnant and irrelevant regulations.
