-
Folks, some quick guidelines for using the classified section of the forums:
1. Only supporting members can post ads.
2. Ads will be deleted for expired members.
3. Ads will be deleted if not updated in 45 days
4. Please delete your ad when you have sold your item!
5. Please choose the selectable prefix Wanted or For Sale - when posting.
WHEN THE ORIGINAL POSTER MAKES A POST WITH THE WORD "SOLD" WITH ASTERISKS ON EITHER SIDE (LIKE THIS "*SOLD*" ) IN IT ANYWHERE, THE CLASSIFIED AD WILL BE REMOVED WITHIN 24 HOURS OR SO
Wanted: Certified AOSS shocks
- Thread starter Oliver
- Start date
Hey Doug, Are you aware Burl gets $1500 to transfer the STC? I almost bought a pair and called Burl first. He wouldn't budge.
Steve Pierce
BENEFACTOR
Graham, TX
Burl told me that when I put the AOSS off of a Super Cub I was repairing, temporarily while he was repairing a malfunctioned set off another so the club could keep flying while he was repairing their shocks. I couldn't find anything N number specific in the STC. Cub Crafters stamps their STCs with a statement that the STC is specific to N______. I have not found that on any AOSS STC. I traded my AOSS to someone for some website work.
skywagon8a
MEMBER
SE Mass MA6
"§ 21.120 Responsibility of supplemental type certificate holders to provide written permission for alterations.
A supplemental type certificate holder who allows a person to use the supplemental type certificate to alter an aircraft, aircraft engine, or propeller must provide that person with written permission acceptable to the FAA.
[Doc. No. FAA-2003-14825, 71 FR 52258, Sept. 1, 2006]"
This was put in place to protect the STC holder's property (the STC) from unauthorized use. There are those who have copied another's product for which the other has received approval, and then installed that product without the permission of the STC holder while using the holder's STC number. A certain big manufacturer who you all know was widely known for copying other people's STCs.
Steve Pierce
BENEFACTOR
Graham, TX
So if I buy AOSS shocks and then decide to go with Acme and want to sell my shocks with the STC I bought it is not transferrable? I don't see that in what you quoted. The STC is not N number specific.
I understand your issue, CC copied your STC and then sold it as their own.
I understand your issue, CC copied your STC and then sold it as their own.
skywagon8a
MEMBER
SE Mass MA6
Back in the early 90s the FAA made a requirement that the holders of an STC must provide written permission for a second party to use the STC on a specific airplane. This in effect prohibited anyone from taking an STCd product off one airplane and installing it on another. It's been a long time, I do not remember the exact regulation. Prior to that time we just removed the product from one plane and installed it on another, filled out the 337 showing the installation and we were done. After that time the FAA would not accept the 337 without the permission.
Steve Pierce
BENEFACTOR
Graham, TX
We might need to research that because I believe that happens a lot. I will probably get a call from Burl with all the details. 
Love to see that (requirement??) regulation. I worked for the FAA for twenty years and can't tell you how many Airworthiness Inspectors told me "We are not the STC police." Was I lied to? Also, I don't know how many 337's I've filled out with the statement "Installed I/A/W STC xxxxx" providing no proof of "permission", submitted them to the FAA, and they were then added to the official FAA aircraft records. Am I doing something wrong?
Last edited:
skywagon8a
MEMBER
SE Mass MA6
"§ 21.120 Responsibility of supplemental type certificate holders to provide written permission for alterations.
A supplemental type certificate holder who allows a person to use the supplemental type certificate to alter an aircraft, aircraft engine, or propeller must provide that person with written permission acceptable to the FAA."
I have to side with Steve as I don't see it there either. Nor do I believe there to be a single enforcement initiated, let alone determined by the NTSB as being applicable by your interpretation. Maybe a legal interpretation from FAA Legal Counsel? If there is, then I know I have been lied to for all these years and would appreciate this new information. Regardless, it still doesn't explain why the FAA excepts thousands of 337's without this added "proof". "After that time the FAA would not accept the 337 without the permission." Are they in violation of their own regulation? I always ensure any STC paperwork that was issued N number specific was reissued to the new N number and then added to aircrafts permanent records. Most STC N number specific STC holders that I have dealt with charged a marginal fee to cover the paperwork. I never heard of such a ridicules fee as listed above. Would certainly be a turn off to me when purchasing a mod. Good question to ask I guess. Always considered "blanket" STC's as transferable, kinda like hunting in North Dakota. If it's not posted, you're legal to hunt there.
Last edited:
skywagon8a
MEMBER
SE Mass MA6
bubb2, As I said above this began back in the early 90s. At the time I owned several STCs along with the applicable PMA. During that time the requirement came out that in order for the use of that STC'd product to be used by another, the owner of that STC had to give written permission to the person who wished to use the STC. Prior to that time I just sold the product, after that time I had to give written permission. At that time, I recall writing a letter giving authorization to a reselling distributor who bought large quantities of my product, since there was no way I could issue separate permissions to each of that reseller's customers. At that time, all other STC holders began stamping their STCs with specific use and permission instructions. Prior to that time, that stamp did not appear on the STCs. When an STC product was ordered, the seller began always asking for the N number. Also at that time those who wished to transfer the use the STC to a different airplane from the original began getting permission from the STC holders. Some gave that permission and some charged a small fee. I agree $1500 is over the top. Prior to that time, STC products were often transferred from one airplane to another with the 337s being filled out as you describe. I've done many of them myself. While at this point in time, I can't swear to it, I'm certain this was discussed at the annual IA meetings. Often during these meetings FAA legal had a lot to say, often making us IAs wondering why we kept our tickets. Now here we are 30 years later, after all those IA meetings and annual FAA PMA visits, you are telling me I must have misinterpreted something. At this point in time I've been retired for more than 20 years and am not up to speed and current on those specific regulations. This particular requirement I do remember, as it directly affected me. It's just that I'm unable to go directly to all the FAA's pertaining regulations. Also during that time frame I had close personal relationships with the heads of several divisions of the FAA's New England Region, having worked with them over a period of years prior to them achieving their positions. There are some younger IAs who often have difficulty in finding these permissions to transfer STC products. Surely, they must have been taught this when they went to A&P school? One of them is a member here, perhaps he can back me up?
skywagon8a
MEMBER
SE Mass MA6
bubb2, Prior to that time there was a prolific abuser of the STC and TC usage privileges which likely led to this requirement. Steve P. knows the story. I was made aware of this particular abuser (he was also a customer of mine, who was very slow in paying his bills) and his activities through several phone conversations with folks who called to order my product. They told me that person was using their STCs without permission. He used other people approvals to manufacture and sell the items without being the approval holder or having been given permission. He also made whole airplanes in this manner. I was also told of someone in the Fairbanks area who was copying my product. You are aware that STCs don't provide the same rights as patents? Really, not much of any protection for the approval's owner, yet the approval's owner has all the liability.
sj, Yes that has been widely noticed over the years. Many people have observed differences between FSDOs, so much so that we wonder if they were all part of the same FAA. I think that the permission requirement of which I have spoken came down from the regional level (the FSDO's bosses). It's also been noticed there is a big difference between regions. It is sometimes advantageous to Region shop in order to get something approved. I can give examples of this, though I will not in a public forum.
sj, Yes that has been widely noticed over the years. Many people have observed differences between FSDOs, so much so that we wonder if they were all part of the same FAA. I think that the permission requirement of which I have spoken came down from the regional level (the FSDO's bosses). It's also been noticed there is a big difference between regions. It is sometimes advantageous to Region shop in order to get something approved. I can give examples of this, though I will not in a public forum.
Last edited:
I could tell you stories for days about the inconsistencies of interpretations and applications of FAA regulations not only between regions and offices but between Inspectors within the same office. I worked for the FAA for 20 years, not something I'm really proud of. Some of these inconsistencies, in my opinion, were on purpose with criminal intent although most were because of ignorance and convenance. It's disturbing how many were due to vindictiveness due to an operators "past contempt for the FAA". That being said. I did have the pleasure of working a detail with FAA Legal Counsel as a subject matter expert for Flight Standards, so I know a little bit about the internal workings. You stated a couple things that are clearly NOT stated in the rule. One was about a second buyer and the other about the FAA not accepting 337"s. This is why I asked about an NTSB determination or a FAA Legal Counsel Interpretation. Once a violation is enforced and processed up through the NTSB court, the determination becomes the "law of the land", similar to a Supreme Court ruling. Lacking any enforcement/NTSB determination of an FAA regulation the FAA will often (usually by request from the public) put forth a Legal Interpretation which is just an official opinion to help guide FAA Inspectors in the process of violations and provide clarity to the public. These are just that, an opinion (which like something else, everybody has one), and can still be argued in front of an NTSB judge who would then determine if the FAA opinion is correct. Many times, they are not. I did not dig into any Preamble, public comments, or any FAA's responses to them. Those are the primary resource the FAA uses to write their legal interpretations as they supposedly indicate the "intent" of the regulation. Any direction you could give me there would be appreciated. The vague regulation, as written, does not prohibit any STC user of anything,
This regulation, as written, places the burden on the STC holder, not the owner or installer. No responsibility is assigned to anybody except the STC holder. If an STC holder did not supply this letter (I/A/W the FAA's opinion of what this letter is) the STC holder would be in violation, not the second person owning or installing the STC. No way to argue that fact. Written in black ink. This is not to say the STC holder does not have other means via civil action for the issues you state. It only shows this FAA Regulation is NOT the appropriate vehicle to get you there. Making the STC paperwork N number specific appears to me to be a way for the STC holder to make a few dollars later down the road. I don't think that's a new FAA mandatory requirement as I just purchased PSTOL flaps from Alaska Gear and that STC is not N number specific. They have no record, other than my charge card number as to what airplane those flaps will be bolted to. The STC paperwork with its raised seal, I believe, is the letter, and is transferable, thus the STC holder has met the requirement of the above regulation. Please prove me wrong.
"§ 21.120 Responsibility of supplemental type certificate holders to provide written permission for alterations
A supplemental type certificate holder who allows a person to use the supplemental type certificate to alter an aircraft, aircraft engine, or propeller must provide that person with written permission acceptable to the FAA."This regulation, as written, places the burden on the STC holder, not the owner or installer. No responsibility is assigned to anybody except the STC holder. If an STC holder did not supply this letter (I/A/W the FAA's opinion of what this letter is) the STC holder would be in violation, not the second person owning or installing the STC. No way to argue that fact. Written in black ink. This is not to say the STC holder does not have other means via civil action for the issues you state. It only shows this FAA Regulation is NOT the appropriate vehicle to get you there. Making the STC paperwork N number specific appears to me to be a way for the STC holder to make a few dollars later down the road. I don't think that's a new FAA mandatory requirement as I just purchased PSTOL flaps from Alaska Gear and that STC is not N number specific. They have no record, other than my charge card number as to what airplane those flaps will be bolted to. The STC paperwork with its raised seal, I believe, is the letter, and is transferable, thus the STC holder has met the requirement of the above regulation. Please prove me wrong.
Last edited:
skywagon8a
MEMBER
SE Mass MA6
I wish I could be more specific for you. Keep in mind, I have to operate under the New England Region and you operate under the Alaska Region. I have found that the Alaska Region possesses more logic and reason than any of the other regions, which is why I managed to use your region to get most of my STCs. Here we do what we are told by our FAA. When did your 20 years start? Perhaps it was after the Alaska Region had dropped the process which I have presented? Here they never tell us when they drop a requirement. In fact they tell us very little. I'll give you an example. Back in the early 1970s I turned in a 337 for a radio installation in a PA-18 to my PMI. He handed it back to me saying I didn't need a 337 for a radio installation. So, from then on I never turned in a 337 for a radio installation. Then 20 or 30 years later that very same PMI was talking about it being mandatory to submit 337s for radio installations at one of the annual IA meetings. That created an uproar. Most of the IAs attending had never heard of using a 337 for radio installations. You see, here we had one PMI in one office who didn't inform his charges. So which is it, 337 or not?
Skywagon8a, I worked for the FAA from 2001 until 2021. I resigned the day an illegal medical intervention was mandated for all employees. Here we do what we are told by our FAA. Mistake number one. The FAA always uses intimidation to force operators to comply to their "made up" requirements. This tactic is so prevalent they would joke in the office of citing "FAR 135 and a half". YOU allow this behavior to occur by doing what you are told. Most operators will just comply as it's easier than fighting them. The FAA knows this very well. You need to understand this organization is crawling with criminals. DEMAND to see the Regulation that explicitly requires compliance. If you do, and they can't provide it on the spot, they will huddle up back in the office and conspire against you. They usually will come back with some mealy worded regulation that vaguely touches upon the subject and state "they" interpret that to mean "this". same PMI was talking about it being mandatory to submit 337s Mistake number two. That's when you demand a written Legal Interpratation from FAA Legal Counsel of their mealy worded regulation if they can even cite one. All your IA seminars and PMI statements made by FAA Inspectors are just blah, blah, blah, If it is not codified clearly in FAA Regulation, they have no authority to enforce it, period. If there are legitimate differences of opinion as to their meaning it is the responsibility of the FAA to clarify it. This legally cannot be done with spoken words, it must be written, dated, and signed by the person of authority on FAA letterhead. That will never come from an Inspector or your PMI. FAA Legal Counsel does not relish the prospects of being humiliated in front of an NTSB judge for some stupid, trumped-up violation. The FSDO's are crawling with personnel who have no idea of correctly and legally enforcing regulations. That's why their preferred method is intimidation. As a Regional employee one of my main job functions was to review FSDO produced enforcement cases before we would hand them off to Legal. I estimate that over 90% of those cases had to be returned to the FSDO's due to stop dead errors. Keep in mind, these same enforcements had to be reviewed by the FSDO Office Manager before they were forwarded to me. I'm not sure what the average IQ is for FAA Inspectors, but I was somewhat surprise to recently learn from one of my past colleagues (30-year career Ops Inspector) that he had no idea that THE UNITED STATES of AMERICA (his employer) is a corporation. And said corporation somehow had the authority to determine that all corporations are also a "person". When you understand how this criminal origination works and how it's supposed to work and if EVERYBODY forced them back to how it's supposed to work, we would all be better off. Operators and FAA Employees. But then, I digress.
Last edited:
skywagon8a
MEMBER
SE Mass MA6
Bubb2, Thanks for the lengthy insiders perspective. It's entirely possible that the requirement which this lengthy discussion is all about may have been rescinded before you began your journey. I've reached out to that younger member for his input. Hopefully he can help clear up the question. I'm glad I've retired and hung up most of my many FAA shingles.
Me too. Just work on and fly my airplanes. Cheers.
skywagon8a
MEMBER
SE Mass MA6
Oliver, I apologize, we got carried away on your ad thread. I do have a photograph of the permission stamp on an STC showing it being restricted to just one particular airplane. I just can't seem to be able to post it.
RaisedByWolves
FRIEND
Tx
Most of the STC's come with the raised seal and serial number and n number to an airplane, i would assume so the stc holder has a record of what airplanes there parts are on. I also assume some manufactures get lazy and do not fill out the STC with an n number such as the pstol flaps. Sometimes if you buy a steves gascolator through aircraft spruce the stc is blank. Buy through brian and he fills it out
Side note, got a set of acmes i'm sending the paperwork in and the STC is Aircraft serial number and n number specific
RaisedByWolves
FRIEND
Tx
hotrod180
FRIEND
Port Townsend, WA
I disagree.
If it wasn't notated as being specific to one particular airplane,
someone who buys the STC could photocopy the paperwork & give it to all his buddies.
So IMHO that's a legit reason to make it specific.
I had to get some paperwork from an stc holder a few years ago--
the stc had been purchased & installed by a previous owner, probably 10 or more like 15 years before,
but the airplane files didn't include all the accompanying paperwork.
I had quite a time convincing the stc holder that the stc had been purchased for this airplane,
esp since it now had a different tail number.
I finally convinced him & got the paperwork I needed, though...overwritten with a marker "applies to Cessna 180 Nxxxxx only".
Good point for some STC's, not all. I should have expanded my comment that the N number specific STC holder getting a few more bucks isn't a universal or only reason. Examples: The PSTOL flaps, various floats and skis, shock absorbers and other STC's that include a significant manufactured product that no one is going to duplicate. Your buddy probably isn't going to give you those and if he does, he just gives you the paperwork that goes with them. The STC holder made his money when he originally sold it just like Ford and GM made their money when they sold a new car or an upgraded engine part. Now an STC holder, who produces an easily made product, something that can be easily fabricated has a better reason to make the STC N number specific, as an attempt to protect their intellectual property, but I suspect it's a ploy for a good reason. My main point is I know of no FAA regulation that prohibits you from doing exactly what you said, even with an N number specific STC. The one cited above does not prohibit it and could not be used against anybody who does what you point out, it is specific to the STC holder ONLY. If you can direct me to a regulation that is worded something like; No person shall install an STC on any aircraft that has been issued to another aircraft without the written permission of the STC holder. I would greatly appreciate it. I have no problem changing my opinion with new to me facts. But I can't find it. The main point I'm trying to make (and maybe not that well) is exactly what I've been told by many FAA Airworthiness Inspectors, they are not the STC police. Again, I think it's a ploy some STC holders are using, for good reason, to protect their intellectual property. It's a great alternative to monitoring the applicable fleet of aircraft (I don't believe for a second the FAA would notify them) for the install of their STC though 337's and then pursuing any not on their list with other civil action. You may get sued but you won't get a visit from the Fed's. Others are using it to make a few (or a lot) more bucks. Someone above who makes shocks is a blatant example. He sure didn't lose any money when he originally sold them.
Last edited:
Note the addition of the stamp and signature over the original document signed by the FAA. The original "letter' was the STC holders' compliance to the regulation noted above. Being signed by the FAA shows it was found acceptable as required by the regulation. Note there are no prohibitions to the owner or installer other than it is restricted to a certain aircraft type, other IA responsibilities and that you can't alter it. Obviously, the information about N number specificity was added later. That information was not signed by the FAA but by a representative of the STC holder. No Federal mandate there. I don't think copying it would be considered an alteration. If so, a lot of IA's and aircraft owners I know would be looking at 3 years in prison.
Last edited:
A little deeper dive into the note at the bottom of the second document led me to 14 CFR 21.47. That appears to me to be the transfer from the original STC holder to another SCT holder. It is interesting how it then goes on to state how this certificate does not constitute rights to the design. data, supporting documents, etc. but never cites any Federal Regulation covering any of that. It then cites the original regulation posted by skywagon8a which is obviously specific to the STC holder. This maybe where skywagon8a got the impression STC's are somehow protected by FAA regulation? The middle statement could certainly give grounds for an STC holder to pursue legal action against someone. but not from the FAA. I view that statement, in its construction and entirety, as an attempt from the FAA to give the impression that some FAR prevents you from passing the STC on. Totally in their character, use deceptive tactics and intimidation in areas where you have no authority.
Oliver,
This is not by any means legal advice, just an example of a reality check. As the shocks apparently were sold by the STC holder as non-N number specific, it would be very difficult for him to prove in a court of law they were installed on another aircraft from what was intended by the original buyer, especially if they are not serialized or the original 337 did not list the serial numbers (are they?). All he could prove is that he has no record. The second user has no legal requirement to prove their "innocence'. That's probably why many STC holders now put the specific aircraft data on the letter. Much easier to prove in court if they want to take that avenue. He's probably kicking himself now.
Last edited:
Steve Pierce
BENEFACTOR
Graham, TX
Some STC's are for parts and the selling of the part with the STC is where the STC holder makes their money. I own 3 STCs that are paperwork to modify the wing tip, install an oil cooler and install a bigger engine. I sell no parts, just the intellectual data. I generate my STC cover letters with the N number and owner's name and address. I am required to retain records so if there were to be an issue with one of my STCs I assume the owners could be contacted. I get calls all the time requesting the instructions or some other part of the paperwork. I verify the N number and owner, sometimes the airplane is sold and usually can email the paperwork. I guess I am a fool but I do not charge for it. Sometimes it is a pain to find if I have to go way back to the paper records to verify the N number or original purchaser.
skywagon8a
MEMBER
SE Mass MA6
I don't see any portion of 14 CFR 21.47 as being applicable to the question we (I) have been addressing. I clearly remember the mandate which was given at the time, 30+/- years ago and the reason for it, I just can not remember the particular regulation number(s). At this point in time, I'll let others do the regulation research. If they can then help in confirming my assertion, it will be welcomed. I no longer fill out 337s. At this point in time, it is no more than a memory recall which will hopefully help out others in keeping out of trouble. If I'm proven wrong, so be it. I am certain that many other STC holders have the same point of view which I have because they all began providing specific permissions during the same time frame.
