Aircraft Modifiers Alliance Working to Streamline Aftermarket STC Process
Nicole Noack, head of the Independent Aircraft Modifier Alliance (IAMA), explains how the organization is embracing the challenge of streamlining the aftermarket STC process for airlines and lessors.
Several months after formally launching at the 2019 Aircraft Interiors Expo (AIX) in April, the Independent Aircraft Modifier Alliance (IAMA) has formed four working groups, welcomed its first advisory member and is preparing to publish a prototype version of a rulebook designed to eventually introduce a new official standard that will stand to represent the supplemental type certificates (STCs) provided by its members.
While the STC process and its associated airworthiness requirements are standard, the way aftermarket organizations document their ability to achieve regulatory airworthiness standards can greatly vary from one part of the world to another. IAMA plans to introduce standards that will ensure the documentation and quality of STCs provided independently, thus improving their perception by airlines and leasing companies relative to service bulletins available from original equipment manufacturers (OEMs).
EAD Aerospace, Envoy Aerospace, Etihad Engineering and Lufthansa Technik are the founding members of the alliance, which also just welcomed Euro-Composites as its first advisory member.
Nicole Noack, head of IAMA, who also leads the strategic partnerships division of Lufthansa Technik, said the alliance has been formed to standardize the type of quality aircraft operators and leasing companies can expect when seeking modifications from independent providers.
IAMA established a membership model that includes three different options, including full and basic membership packages for organizations that provide STC capabilities. Advisory membership has also been opened to airframe and system manufacturers, and airlines, banks and lessors are able to join for free.
“Naturally, our customers feel the OEM solution is more standardized as compared to the STC development process; specifically, the usability and access of documentation or the after sales process,” Noack said. “The independent STC providers — worldwide — vary in those concerns. STC providers often offer faster and more flexible solutions (e.g. turn-key solutions) for mixed fleets, but the variable fulfillment processes are more and more seen as a risk.”
Noack describes aftermarket modifications occurring under OEMs and MROs as similarly requiring massive amounts of paperwork for certification data. There are also design documents provided in the form of wiring diagrams, installation drawings, instructions and material lists. The documentation provides each MRO a way of understanding each individual aircraft modification down to every pin and screw required to enable it, Noack said.
Operators also receive instructions for continued airworthiness and supplements to flight and maintenance manuals to provide guidance about the modification over the life cycle of the aircraft. The way MRO providers document this design data can greatly differ.
Building more predictability into the aftermarket modification process is another major goal for IAMA. Noack says this has become more important as the fleet of leased aircraft continues to grow. In comparison to airlines, leasing companies are increasingly concerned about the transferability of modified aircraft between regions, especially as civil aviation regulators continue to adopt and enact new mandates such as those requiring ADS-B coming up in 2020 or new aircraft tracking requirements taking effect in 2021.
IAMA will also make an effort to reduce the disparate nature of information provided by an STC, which becomes especially important when an operator undergoes a major C check of their aircraft and discovers a problem that can only be resolved by consulting information available within STC paperwork.
To demonstrate the complexities involved with today’s STC processes, Noack gave an example of the types of challenges operators experience when trying to install aftermarket upgrades to their cabin in-flight entertainment and connectivity technology.
“When you’re an airline and you want to do a cabin IFEC upgrade, you might go to the IFE supplier, then to another supplier for the connectivity, and then another for the seats and so on,” Noack said. “Each of these different vendors will establish different congrats with you, but the challenge there is that the IFE equipment has to be able to interface with the connectivity and both of those have to be able to interface with the seats.”
“It needs to be clear who is in the lead of what, where does the installation of the IFE end, where does the installation of the connectivity start, how do you connect them, and who is doing that design data and certification data,” she added.
A major goal for IAMA’s intellectual property working group is to reduce inefficiencies in how intellectual property (IP) information is handled and made available to various STC stakeholders.
Operators and especially lessors, who often install several STCs throughout the lifecycle of an aircraft, often deal with different STC providers, each with their own source of documentation. The operator then has to keep track of that information for as the STC for as long as it is installed on the airframe. IAMA is developing a method by which to have every piece of STC documentation stored in one database or cloud with IP-secured access so only the contract owner has access to that.
Another major STC aftermarket challenge being addressed by IAMA is the acceptance of STCs by civil aviation authorities in different countries. Although this aspect of aftermarket certification has been a long-standing issue for both independent STC providers and OEMs, it has been further highlighted by the current process Boeing is undergoing to lift the international grounding on the 737 MAX.
But the issue stems as far back as September 2015, when the FAA signed new bilateral agreements with the European Aviation Safety Agency (EASA) and Transport Canada (TCCA) specifically stating that the agencies would be eliminating duplicate processes, get safety enhancing equipment installed on aircraft faster and save time and money for both regulators and industry.
Years after those agreements were signed, however, validation of non-basic STCs remains a challenge, Noack said.
“The bilateral agreements are a good base to work on and there was improvement with the TIP6 between EASA/FAA on a streamlined validation process on basic STC,” Noack told Avionics. “Still, validation of non-basic STC can be a hassle, e.g. regarding timelines. IAMA seeks the interaction with major authorities to understand their demands and jointly will work out solutions to ease the work of the validating authority and to ensure valuable preparation on the integrators side.”
Non-IAMA members share the perspective that more improvement is needed regarding the approval of STCs across different aviation authorities at the international level. Ryan Beech, general manager of Certify Nation, a Wisconsin-based provider of aerospace engineering services, told Avionics that the company has been using the bi-lateral agreements for several years.
Earlier this year, CertifyNation completed EASA, FAA and TCCA ADS-B Out STCs for the Boeing 737, and has open STC projects for ADS-B Out on the 747 and 777 right now.
“These agreements are updated periodically, but the transition from FAA STC to EASA or TCCA STC is still not seamless. Ideally, in the future, an STC issued by the FAA, EASA, TCCA, etc. would be recognized globally without needing to go through the validation process that is defined by the bilateral agreements. I’m not sure we’ll ever get there, but we’re working with other industry participants to address the differences between the [civil aviation authorities] and streamline the validation process,” Beech said.
Beech also has experienced the challenges presented by OEMs making access to aircraft technical data such as maintenance manuals, repair manuals and wiring diagrams increasingly difficult in recent years.
“Until recently, access to aircraft technical data has been relatively easy to obtain,” Beech said.
“Some of the larger aircraft OEMs have started enforcing confidentiality and financial agreements for access to this type of data, which is crucial for development of STCs.”
Noack said IAMA has been working closely with Airbus and Boeing as well as authorities to address all of the above-mentioned STC challenges and more. Next steps for the organization include achieving her goal of becoming an official legal entity under association recognition in Germany by January 2020.
By AIX 2020, Noack wants to have the first version of their STC standard rulebook published and ready to become the official guideline that the world’s largest independent providers of aircraft modification use a mark of quality for aftermarket installations.
“One of the major points we want to work on as an association is that we see we can have an impact to the civil aviation authorities if we are able to talk with one voice for the industry instead of 20 to 30 companies that may have a different view on the validation topic,” Noack said.