Canadian Limited Supplemental Type Approval LSTA for use as approved FAA Data

Hello all you supercubers, I'm new to supercubs.org. I have been working on tube and fabric Pipers for over 30 years. Just saying I'm not new to this. Ok I finally have my PA-18/150 ready to go....but now needed a DAR-T to inspect my aircraft for an airworthiness certificate issuance. It came out of Canada its registered US. All of my STC' that were done in Canada were all A OK but I have an LSTA limited supplemental type approval LSTA for extended baggage, fishing rod box, under rear seat storage and landing gear safety cables. This is all on a official TCCA document signed by a regional engineer for TCCA with a conformity certificate (our 337 form). The FAA is trying to say that is not approved data so far. I have been going through the 8010's and AC's regarding the maintenance implementation program between FAA and TCCA. What I see is if the data was approved by a delegate for the minister, it should be accepted in the US as it was in Canada. Of course the Feds never semto look at things logically and always send you down the dead end road of a field approval. Add the DER fees and the months or years of waiting, um that's where I'm at. Is anyone familiar with LSTA's? Has anyone ever gotten approval with one? Thank you for any information you can provide.

NOT a mechanic, but I did fly a cub once in the past:roll:

Make your life easier- remove the cables, and fishing rod tube. Maybe even the baggage if it is not one of the STC'd ones like Atlee's.

For your day of time removing all of them, it won't be worth the fight. Just remove, get the cub approved, then put them back on and sign off as appropriate!! The cables were an Atlee Dodge STC if I recall. Which baggage you have makes a difference, If it is an Atlee, it would be an STC also. Search F. Atlee Dodge.

Rod tube- good luck.

Hope this helps

Again, just a pilot that has owned aircraft- ymmv

That is an option I have to consider. There nice mods done by Interior Pacific Flight Systems in BC, no longer in business. The baggage is different than Atlee's and all the others. This may be my only option just trying to see if anyone has delt with this TCCA LSTA to FAA approval thing. Thank you for the comment!

would those even be consider MAJOR mods in todays FAA world?? yes, we previously would be major, and someone got STC for gear cables... but under new guidance, I would consider it MINOR, it's a bolt on item! that doesn't change the gear....

how was baggage installed? clamped in? if no major welding mods/moving tubes, then that could be minor here & now....

same with fish tube!

make one log entry say you had inspected the items and determined them to be minor?? no 337 needed??

That's a great angle, I need to do some more research into that being a minor alteration. Seems things tend to work a bit differently in the lower 48. Now that I have had the DAR look and started the path of no return it could be more difficult. I agree for a "bolt on" mod idea it is a minor alteration. The Fed I talked to regarding this but not directly involved said because the loading had changed it was a major. Some data I found was if the gross weight and CG envlope had not changed it would be a minor alteration also. Thanks for the reply I figured one of you AK dudes would have a different angle or have dealt with one of these LSTA's before. Trying to get things approved the right way but when the FAA treats a supercub like it's a 200 passenger crowd killer it makes you wonder.

Supercub Works said:

..not directly involved said because the loading had changed it was a major. Some data I found was if the gross weight and CG envlope had not changed it would be a minor alteration also. ..

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yup, MINOR.. I had my FAA PMI teach me that back in 2007 or so, when I fabricated a bolt in extended baggage in a covered fuselage, and I wanted a field approval for it. he explained it was only a minor mod, log book entry, since none of that gross weight and CG envelope stuff was going to be changed...

Use FAA documents to your advantage! Get the flowchart from AC43-210A and answer each question yes or no. If you come out as a minor alteration, make a log book entry indicating as such. If you come up with it as a major alteration, you could have the TCCA LSTC validated to make it a FAA one time STC, or possibly a DER Approved Major Alteration or a Field Approval by FAA or a DART with the appropriate function.

In any case, you need an A&P to sign off a 100 hour inspection before the DAR comes out to issue the Airworthiness certificate. He should be the one that reviews the major/minor determination.


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Thank you for the information the more the better. The aircraft is signed off for an annual/100hr, the DAR has looked at the aircraft I have been looking over AC 43-210A and the other references cited. Seems the issue is my DAR and the DAR's new manager/supervisor are not accepting the LSTA, conformity certificate and log book entry from Canada as approved data. There is an AC regarding approved data from foreign sources that seems to apply. Can I ask for an explanation of why they won't approve the data or will I get one?

Canadian LSTC, or full STC is not considered “approved data” as is. The bi-lateral aviation safety agreement allows FAA to “validate” the TCCA data to issue an FAA STC, but this takes quite a bit of time (6 month to 2 years depending on complexity).

Did the DAR accept your application (8130-6)? If so, and if he isn’t going to issue the certificate, he is required to issue a letter of denial explaining what the discrepancies are.

When you go through the AC43-210A flow chart, do you come up with major or minor? If minor, use that as your ammunition against the need for “approved data” I.e. need for having the LSTC validated. Ask them to show you, using the flow chart, how the alterations are Major. If they are major, suggest you get a DAR with field approval authority or a DER with major alteration authority to look at it and see if it is within their scope to issue the approval and have your A&P/IA fill out a 337 for them.


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The DAR did not give a letter of denial so I think it was accepted. He needed to seek advise from his oversight in regards to the LSTA. I now accept that it is not approved but could be a number of different ways. As to the flow chart the mods do not change the gross weight or CG envelope, strength, performance, PP Opps, flying characteristics, or other airworthiness. Accepted practices or elementary operations? Accepted operations as per AC 43.13? If so I end up at a minor alteration. I think the DAR thinks that since there is more space for baggae it could effect the weight and balance. I don't know for sure. There is a flight manual supplemet that states no change to gross weight or CG envelope, location to center of compartments, and max weight placards. I appreciate your knowledge regarding this process, thank you!

****You need to read FAR Part 43 for major vs minor. And remember that an FAR always trumps an AC (advisory circular).****

When it comes to 'loading' it's only a major if it affects the weigh and balance envelope, i.e. you change your fore and aft CG limits. NOT just weigh and balance. If it was just anything that effected the weight and balance, you'd be doing a 337 every time you carried a fat passenger in the back and another when they got out.

And always make the faa guy shows you, in the FAR's, what he's basing his opinions on. His decision must be based on an actual FAR rule, not just his 'feelings'.

Web

Even more great advise. I feel like I'm studying for the IA written exam again, may be I should I'm supposed to know this stuff too! I think see a light at the end of the tunnel but it's still kinda dim. I can't help but do my own homework when going through a new process. The information here is outstanding!

dgapilot said:

Use FAA documents to your advantage! Get the flowchart from AC43-210A and answer each question yes or no. ....

Click to expand...

Can ypou post a link?
I've read through many discussions (aka arguments) on how something could be done as a minor vs no, it needs a field approval or STC,
on this site as well as BCP.
If there's an easier way to answer this question, it'd sure be handy.

https://www.faa.gov/documentLibrary/media/Advisory_Circular/AC_43-210A_CHG_1.pdf

Pg 14, 15

Send me a PM with your email and I'll send a copy of the Major/Minor presentation I give at IA seminars.

I have removed the extended baggage compartments so I can get the airworthiness certificate issued. The FAA will not accept an LSTA as approved data without explanation. The next step to try and get these modifications approved is get the data approved as per the bilateral agreement (long wait and difficult). A field approval with DER/DAR is where this is going. The determination was that it is a major alteration because the "structure carries the load" according to the DAR. I may have someone that can help with drawings but I will still need the help of a DER to approve the data. I hope to get the cub in the air soon and work on getting or trying to get approval for the baggage compartments sometime soon. Is there any DER's out there that might be willing to help with a project like this? I would greatly appreciate any help or direction with this.

Supercub Works said:

. The determination was that it is a major alteration because the "structure carries the load" according to the DAR. ..

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that's a load of BS.... wasn't an issue with my PMI, I added a clamp in extended baggage, and he said minor..... like all things FAA... depends on who you ask.... I got my guidance from the administrator, and I will never ask again!

Supercub Works said:

The determination was that it is a major alteration because the "structure carries the load" according to the DAR.

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That is a baseless opinion with absolutely no relation to the FAR's. Read FAR 43, appendix A. Nowhere does it say that a major alteration is one where the 'structure carries the load'. Ask the DAR to cite the criteria in appendix A.

Web

I think the angle they are taking in part 43 appendix A is (a) major alterations, (1) airframe major alterations, (iii) fuselage as fuselage was altered. In figure 3-2, the wording is appreciable effect on structural strength. There is no determination if it is a "bolt in" or "permanent welded tabs, brackets". When installing shoulder harnesses an owner can install them if it "bolts in". Welding a bracket or riveting a bracket for a shoulder harness is a major alteration right? I tried to go the route of minor alteration they just won't go that direction. What about landing gear safety cables? Does a "bolt on" set of cables alter the landing gear? Or appreciable effect on the landing gear. I don't think so but you never know what the FAA might determine. Of course the is plenty of STC's for them but is that really needed. What about floorboards? CC sells "STC'd" floor boards. So changing a plywood floorboard is a major alteration? Again I do not think that is a major alteration. Major vs. Minor? One mans major is another mans minor. Sometimes when they say no they refuse to look at any other way to get a modification done. Has anyone gotten a "field approval" using same make and model of a previously approved 337? I have only gotten 3 approved in 30 years and every time I had to add more data than was on the original and have it sent back and forth many times. The last one was for a skydive door on a 182H. It took about 2 years. There is only 2 DAR'S in my state and only one can issue the certificate I need. What's a guy have to do to get a reasonable determination? Thanks for the input, this has been informative to say the least.

Everybody thinks that STC's that are issued by Canada and the US are automatically accepted in both countries. But that is simply not the case. The key issue here is what is called the State of Design (where the aircraft was designed and developed).
Example #1- Cessna's State of Design is of course the United States. Let’s say this aircraft is registered and operated in the US and has been modified with one or many American STC’s. It is legal because the FAA have approved the US STC's. The State of Design has approved the modifications of the aircraft operated in their country under their over sight responsibilities.
Example #2 Same Cessna gets exported to Canada. The aircraft goes through an extensive import inspection. The modifications are inspected and found acceptable, as the modifications are recognized as approved data, issued by the aircraft state of design, the FAA.
Example#3 Same Cessna is sold back to the US. In the time it was operated and registered in Canada it was modified with a Canadian STC. During the export / import inspection, inspectors could not find any evidence that the Canadian data/ modification had met the approval standards set by the FAA, State of Design. So now we have a problem.
Canadian STC's should have been Americanized, that is that when a Canadian STC is applied for, a copy of the drawings and approved data is sent to the FAA. If the FAA concludes that the data is correct and acceptable, they will issue their own US STC . Therefore, the Canadian STC holder will not only have a Canadian STC but also an American STC. If this had been done the aircraft would have been eligible for export. It is important to note that this is the responsibility of the DER or DAR applying for the STC.
Canada holds the State of design for many of the DeHavilland products. DHC-2 aircraft being exported back into Canada would face the same problems if the US STC's incorporated in them had not been issued a duplicate Canadian STC.
I hope this long winded explanation helps.

Great explanation! I do understand this situation a lot better thanks for the responses. The DAR should be here next week to issue the airworthiness certificate as the Canadian modifications are now removed. I'm planning on getting some drawings done and try to get this approved with DER 8110 at a later date. Anyone willing to help with this possibly? I think that the rear under seat storage that is "bolted in" is a minor alteration. I may put it back in and enter it in the logs as a minor at a later date.