OIG audit of STCs might slow down the process-HELP?

The US DoT Office of Inspector General (OIG), as required by specific Congress language, announced that it was starting a “series of audits focused on FAA’s consistency of interpretation and application of policy regarding supplemental type certificates (STCs)…” The focus of this investigation includes: 

• FAA has sufficient controls in place to provide reasonable assurance that inspectors are consistent in determining what aircraft alterations require an STC,

and

• FAA inspectors process STC applications consistently across FAA offices and geographic regions.

This most demanding, exacting, laborious and safety intense mission of the FAA involves its CERTIFICATION OF AIRCRAFT, ENGINES, AVIONICS, AND PROPELLERS. While the burden of proof that the product is AIRWORTHY is on the applicant, it is incumbent on the FAA staff to determine whether it meets the applicable safety criteria. This assignment’s difficulty has increased dramatically as aeronautical engineering innovation has escalated. It appears that new certificate applications have increased in numbers and complexity of the products.

As the Congressional record upon which the OIG’s audit is based notes, the Supplemental Type Certificate request process has deteriorated to an unacceptably slow pace. The same segment of this private technical experts who support STC applications throughout the country assert that the FAA offices apply the airworthiness standards inconsistently. Again, a plausible explanation of these variances may trace back to the changes in the technology being presented to them.

This background creates insights INTO HOW AN STC APPLICATION WILL BE HANDLED BY THESE FIELD OFFICES. Knowing that an OIG auditor may be reviewing the cases that the FAA staff person is handling, he or she likely will be exceptionally careful. In particular, strict consistency with all FAA internal guidance will be THE RULE.

Yes, such close attention will slow the approval steps, but GOING BY THE BOOK, adhering to strict safety standards and national guidance, is the relevant standard for civil servants. Fast, inaccurate action is not justified EVEN IF Congress has questioned the pace of these offices.

What this likely scenario suggests that, while the OIG investigates, an STC applicant is WELL ADVISED to include in the submission copies of all the relevant pages of Advisory Circulars, Handbooks, internal memoranda as well as decision papers issued by other FAA staff on similar STC approvals.  Someone who can assemble all of these reference materials should minimize delay; elsewise the OIG audit could actually slow down STC approvals.

DOT IG To Examine Consistency in FAA STC Process

Consistency and proper assessment of the need for STCs are targets

By Matt Thurber • Editor-in-Chief

November 20, 2024

The U.S. Department of Transportation’s Office of Inspector General (OIG) is auditing the FAA’s “CONSISTENCY OF INTERPRETATION and application of policy regarding SUPPLEMENTAL TYPE CERTIFICATES (STCs)” as required by the FAA Reauthorization Act of 2024. The act specifies audits of STCs, repair stations, and technical standard orders, and the STC audit will be the first.

Companies that develop STCs and seek FAA approval have been complaining that their projects are suffering significant delays due to a lack of FAA resources and consistent application of the regulations. Many also believe that there is RELUCTANCE ON THE PART OF FAA PERSONNEL TO APPROVE COMPLEX STCS because of problems identified as part of the two Boeing 737 Max crashes and the resulting deficiencies in FAA oversight of Boeing certification processes. Critics allege that inconsistency in STC approval decisions is also a problem with the process.

According to the DOT watchdog, the FIRST AUDIT’S OBJECTIVES are “to determine whether (1) FAA has sufficient controls in place to provide reasonable assurance that inspectors are consistent in determining what aircraft alterations require an STC, and (2) FAA inspectors process STC applications consistently across FAA offices and geographic regions.” OIG inspectors will conduct the audit at FAA headquarters in Washington, D.C., and FAA regional offices responsible for STC approvals.