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Permission Letter

Flying Bee

MEMBER
Washington 2S9
Installing a used Electronics International EC-1 EGT/CHT gauge and looking for a copy of the permission letter to send in with the STC. Found the STC paperwork and the AML on the website but no luck on a letter. Any help is much appreciated.

Thank you
Craig
 
E.I. instruments are not installed to a specific N number. If you have the instrument in hand, burn a copy of the STC and install it as per the installation manual (on line also).

If an STC'd item needs to be registered to the airplane, the STC holder will tell you in no uncertain terms.

Web
 
Typical FAA, 21.120 requires an STC holder to provide written permission to use an STC, but nothing in Part 43 requires a mechanic to do anything with it or even look for it. There is no requirement in Part 43, or anything in AC43.9F that indicates that permission needs to be attached to the 337.


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Thanks for the input. I called EI this morning to get their take because I'm sure I'm not the first to do this. They also said if the A/C is on the AML list I shouldn't need it but if the FAA wants one EI can produce one for me if I provide a p/n and s/n. I personally don't think one should be required either and will send 337 in without and see what happens, Thanks again for the help!
 
Nothing happens. Incorrect, unsigned, unauthorized 337s get filed every day. Only when an investigation starts do they ever get looked at by a person able to understand them. That way for over a decade.
 
The 337 just goes to the registry. Contractors scan them in and nobody looks at them unless they do an audit.


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Permission letters is a way for the STC holder to track their product... That way, if the FAA ever decides to issue a AD out on your product you can inform the owners of said AD... It is also supposed to keep airplane owners from just copying a modification without paying the individual or company that developed that modification for the paperwork to do that said modification... My PA-22 series skylight modification is a good example of that. I have seen several PA-22's with skylight mods that are similar but definitely not my STC...

Brian
 
Especially for the Mogas STCs. You must have a document stating the plane it applies to.

Permission letters is a way for the STC holder to track their product... That way, if the FAA ever decides to issue a AD out on your product you can inform the owners of said AD... It is also supposed to keep airplane owners from just copying a modification without paying the individual or company that developed that modification for the paperwork to do that said modification... My PA-22 series skylight modification is a good example of that. I have seen several PA-22's with skylight mods that are similar but definitely not my STC...

Brian
 
It is only fair that the STC holder get a return on their investment. That is the primary reason for requiring authorization. But - and this is my opinion only - the STC is a lot like a perpetual patent. I think there should be a mechanism for converting the STC to something like the original type certificate after, say, 20 years.
 
The concept of FAA regulating intellectual property has always bothered me. It is simple to identify that the data is copyrighted and there are already laws that cover that outside 14CFR. I’ll agree with Bob that STC holders deserve fair compensation. Most owners don’t realize the expense associated with obtaining an STC. It can run well over 6 figures just for the engineering and testing for the STC. If that STC involves parts, then you also have the expense of PMA. Not an easy issue no matter how you look at it.


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I think there should be a mechanism for converting the STC to something like the original type certificate after, say, 20 years.

Disagree. Does ford release every drawing after a car is 20 years old?

STCs are serious investments by those who put the time and effort forth to get them approved.
 
So are patented items. I did say “opinion”.

Piper doesn’t have to release drawings either, but if it is on the TC we can do it for free.
 
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