beware of "warranty" R&R labor costs

Here's "the law", from http://www.awp.faa.gov/new/fsdo/release/long1098.htm:

SUPPLEMENTAL TYPE CERTIFICATES

by Cathy VanAssche

In 1996, Title 49 of the United States Code, Section 44704 was amended to
incorporate Supplemental Type Certificates. The regulation now states that
if the holder of the supplemental type certificate (STC) agrees to permit
another person to use the certificate to modify an aircraft, aircraft
engine, propeller, or appliance, the holder shall provide the other person
with written evidence, in a form and manner acceptable to the Administrator,
of the agreement. A person may change an aircraft, aircraft engine,
propeller, or appliance based on a STC only if the person requesting the
change is the holder of the STC or has permission of the holder to make the
change.

The new requirements of the statute do not require the FAA to be an enforcer
of copyright statutes nor an adjudicator of property rights. The FAA
responsibilities for certification activities remain unchanged by this
legislation.

Any person who makes or causes to be made a fraudulent or intentionally
false statement or entry, that falsely expresses permission from an STC
holder to use that STC, may be in violation of 14 CFR Sections § 21.2 or §
43.12. STC holders and installers should be advised to retain records and
copies thereof in order to be able to demonstrate compliance with the
amendment to Section 44704. The owner/operator of the product on which an
STC alteration is installed should be advised to retain a copy of each
permission statement.

For further information on Supplemental Type Certificate Requirements,
please contact your local FSDO for a copy of FAA Notice 8110.69, HBAW 98-16,
and Public Law 104-264.


"Justin Case" wrote in message
...
Unfortunately I'll agree with you that the feds are pretty screwed up.
I'd like to see where it says that her highness can put the interests
of certain individuals in front of others.

The law I'm looking for is the one that seems to be referred to when
everyone says that permission is needed by the STC holder to install
one of his products. I need to drill down and see exactly what it
states so that I may make my case. Doesn't seem to be anyone that can
steer me in the direction of this legendary federal law. If the feds
are going to refer to it, I need to see it, or assume it doesn't
exist.

And as I figured, your 43.5 doesn't do it for me, and I'm not
satisfied with your interpretation. Neither does the referring
paragraphs of 43.9 or 43.11. If your reading of this were actual, it
would then be prudent to see the rules governing the actions of the
administrator. I will not blindly be led by the short hairs into
believing that an appointed individual can alter the laws of this
land. If the administrator is not allowing certain alterations, there
needs to be legitimate reason why, not just a "Duh, okay!".

And when you feel you're up to some real research and interpretation,
then respond with a good argument, not with the silly FAR's.


On Thu, 21 Aug 2003 17:58:07 -0400, "Ron Natalie"
wrote:


"Justin Case" wrote in message
...
Show me! Show me! Show me! Don't quote numbers that appear to make
up your argument. Although your "43.5" may or may not say that, how
do you know your interpretation is correct.

Do you have a copy of the FAR's? Read 43.5 and come back and we
can have an intelligent discussion. They are available he

http://www.airweb.faa.gov/Regulatory...AR.nsf/MainFra
me?OpenFrameSet
How does anybody know anything is correct. I read what it says. It
says that for a major modification you have to file the paperwork to
the satisfaction of the administrator.

So you first have to agree or disagree with me on that.

Now note that the things left to the discretion of the administrator are
a big
can of worms in the FAA. It pretty much means that they don't even have
to write down what they mean by that. They can approve or disapprove
things at whim.

Now it has been my experience and the experience of others here that an
STC is by default acceptable provided you have the appropriate STC
paperwork.

Now where does it say
that the "administrator" has the right to disregard other laws when
not in time of emergency.

What laws are you talking about? I can't make any intelligent comment
if you're going to be so vague?

Show me the numbers so that I can see it
for myself. Help me out here, otherwise I'll think you're saying the
"administrator" may decide that there's too much air in everyone's
tires.

No, I am saying the administrator can determine whether a modification
has
been done in accordance with her self-adopted standards. And anybody
who doesn't believe that hasn't worked with the FAA field system.

Will the FAA prohibit the issuance of a second STC which is identical to an
existing one? The second paragraph text: "do not require the FAA to be an
enforcer
of copyright statutes nor an adjudicator of property rights" would seem to
indicate not. What I am getting at is that if some company is charging too
high a price for an STC what is to prevent a group of owners from hiring a
consultant to file for an identical STC of interest?


"Dan Thompson" wrote in message
...
Here's "the law", from
http://www.awp.faa.gov/new/fsdo/release/long1098.htm:

SUPPLEMENTAL TYPE CERTIFICATES

by Cathy VanAssche

In 1996, Title 49 of the United States Code, Section 44704 was amended to
incorporate Supplemental Type Certificates. The regulation now states that
if the holder of the supplemental type certificate (STC) agrees to permit
another person to use the certificate to modify an aircraft, aircraft
engine, propeller, or appliance, the holder shall provide the other person
with written evidence, in a form and manner acceptable to the
Administrator,
of the agreement. A person may change an aircraft, aircraft engine,
propeller, or appliance based on a STC only if the person requesting the
change is the holder of the STC or has permission of the holder to make
the
change.

The new requirements of the statute do not require the FAA to be an
enforcer
of copyright statutes nor an adjudicator of property rights. The FAA
responsibilities for certification activities remain unchanged by this
legislation.

Any person who makes or causes to be made a fraudulent or intentionally
false statement or entry, that falsely expresses permission from an STC
holder to use that STC, may be in violation of 14 CFR Sections § 21.2 or §
43.12. STC holders and installers should be advised to retain records and
copies thereof in order to be able to demonstrate compliance with the
amendment to Section 44704. The owner/operator of the product on which an
STC alteration is installed should be advised to retain a copy of each
permission statement.

For further information on Supplemental Type Certificate Requirements,
please contact your local FSDO for a copy of FAA Notice 8110.69, HBAW
98-16,
and Public Law 104-264.


"Justin Case" wrote in message
...
Unfortunately I'll agree with you that the feds are pretty screwed up.
I'd like to see where it says that her highness can put the interests
of certain individuals in front of others.

The law I'm looking for is the one that seems to be referred to when
everyone says that permission is needed by the STC holder to install
one of his products. I need to drill down and see exactly what it
states so that I may make my case. Doesn't seem to be anyone that can
steer me in the direction of this legendary federal law. If the feds
are going to refer to it, I need to see it, or assume it doesn't
exist.

And as I figured, your 43.5 doesn't do it for me, and I'm not
satisfied with your interpretation. Neither does the referring
paragraphs of 43.9 or 43.11. If your reading of this were actual, it
would then be prudent to see the rules governing the actions of the
administrator. I will not blindly be led by the short hairs into
believing that an appointed individual can alter the laws of this
land. If the administrator is not allowing certain alterations, there
needs to be legitimate reason why, not just a "Duh, okay!".

And when you feel you're up to some real research and interpretation,
then respond with a good argument, not with the silly FAR's.


On Thu, 21 Aug 2003 17:58:07 -0400, "Ron Natalie"
wrote:


"Justin Case" wrote in message
...
Show me! Show me! Show me! Don't quote numbers that appear to make
up your argument. Although your "43.5" may or may not say that, how
do you know your interpretation is correct.

Do you have a copy of the FAR's? Read 43.5 and come back and we
can have an intelligent discussion. They are available he


http://www.airweb.faa.gov/Regulatory...AR.nsf/MainFra
me?OpenFrameSet
How does anybody know anything is correct. I read what it says. It
says that for a major modification you have to file the paperwork to
the satisfaction of the administrator.

So you first have to agree or disagree with me on that.

Now note that the things left to the discretion of the administrator
are
a big
can of worms in the FAA. It pretty much means that they don't even
have
to write down what they mean by that. They can approve or disapprove
things at whim.

Now it has been my experience and the experience of others here that an
STC is by default acceptable provided you have the appropriate STC
paperwork.

Now where does it say
that the "administrator" has the right to disregard other laws when
not in time of emergency.

What laws are you talking about? I can't make any intelligent comment
if you're going to be so vague?

Show me the numbers so that I can see it
for myself. Help me out here, otherwise I'll think you're saying the
"administrator" may decide that there's too much air in everyone's
tires.

No, I am saying the administrator can determine whether a modification
has
been done in accordance with her self-adopted standards. And anybody
who doesn't believe that hasn't worked with the FAA field system.

On Fri, 22 Aug 2003 15:15:52 GMT, "Peter Gottlieb"
wrote:

Will the FAA prohibit the issuance of a second STC which is identical to an
existing one? The second paragraph text: "do not require the FAA to be an
enforcer
of copyright statutes nor an adjudicator of property rights" would seem to
indicate not. What I am getting at is that if some company is charging too
high a price for an STC what is to prevent a group of owners from hiring a
consultant to file for an identical STC of interest?

The problem is that the STC holders will cheerfully issue another STC
for the same item they've already sold, but at an inflated price.
For example Century will issue an STC for the "1" for the bargain
price of $1000.00. That's 25% of the cost of a new item. Extortion!


"Dan Thompson" wrote in message
m...
Here's "the law", from
http://www.awp.faa.gov/new/fsdo/release/long1098.htm:

SUPPLEMENTAL TYPE CERTIFICATES

by Cathy VanAssche

In 1996, Title 49 of the United States Code, Section 44704 was amended to
incorporate Supplemental Type Certificates. The regulation now states that
if the holder of the supplemental type certificate (STC) agrees to permit
another person to use the certificate to modify an aircraft, aircraft
engine, propeller, or appliance, the holder shall provide the other person
with written evidence, in a form and manner acceptable to the
Administrator,
of the agreement. A person may change an aircraft, aircraft engine,
propeller, or appliance based on a STC only if the person requesting the
change is the holder of the STC or has permission of the holder to make
the
change.

The new requirements of the statute do not require the FAA to be an
enforcer
of copyright statutes nor an adjudicator of property rights. The FAA
responsibilities for certification activities remain unchanged by this
legislation.

Any person who makes or causes to be made a fraudulent or intentionally
false statement or entry, that falsely expresses permission from an STC
holder to use that STC, may be in violation of 14 CFR Sections § 21.2 or §
43.12. STC holders and installers should be advised to retain records and
copies thereof in order to be able to demonstrate compliance with the
amendment to Section 44704. The owner/operator of the product on which an
STC alteration is installed should be advised to retain a copy of each
permission statement.

For further information on Supplemental Type Certificate Requirements,
please contact your local FSDO for a copy of FAA Notice 8110.69, HBAW
98-16,
and Public Law 104-264.


"Justin Case" wrote in message
...
Unfortunately I'll agree with you that the feds are pretty screwed up.
I'd like to see where it says that her highness can put the interests
of certain individuals in front of others.

The law I'm looking for is the one that seems to be referred to when
everyone says that permission is needed by the STC holder to install
one of his products. I need to drill down and see exactly what it
states so that I may make my case. Doesn't seem to be anyone that can
steer me in the direction of this legendary federal law. If the feds
are going to refer to it, I need to see it, or assume it doesn't
exist.

And as I figured, your 43.5 doesn't do it for me, and I'm not
satisfied with your interpretation. Neither does the referring
paragraphs of 43.9 or 43.11. If your reading of this were actual, it
would then be prudent to see the rules governing the actions of the
administrator. I will not blindly be led by the short hairs into
believing that an appointed individual can alter the laws of this
land. If the administrator is not allowing certain alterations, there
needs to be legitimate reason why, not just a "Duh, okay!".

And when you feel you're up to some real research and interpretation,
then respond with a good argument, not with the silly FAR's.


On Thu, 21 Aug 2003 17:58:07 -0400, "Ron Natalie"
wrote:


"Justin Case" wrote in message
...
Show me! Show me! Show me! Don't quote numbers that appear to make
up your argument. Although your "43.5" may or may not say that, how
do you know your interpretation is correct.

Do you have a copy of the FAR's? Read 43.5 and come back and we
can have an intelligent discussion. They are available he


http://www.airweb.faa.gov/Regulatory...AR.nsf/MainFra
me?OpenFrameSet
How does anybody know anything is correct. I read what it says. It
says that for a major modification you have to file the paperwork to
the satisfaction of the administrator.

So you first have to agree or disagree with me on that.

Now note that the things left to the discretion of the administrator
are
a big
can of worms in the FAA. It pretty much means that they don't even
have
to write down what they mean by that. They can approve or disapprove
things at whim.

Now it has been my experience and the experience of others here that an
STC is by default acceptable provided you have the appropriate STC
paperwork.

Now where does it say
that the "administrator" has the right to disregard other laws when
not in time of emergency.

What laws are you talking about? I can't make any intelligent comment
if you're going to be so vague?

Show me the numbers so that I can see it
for myself. Help me out here, otherwise I'll think you're saying the
"administrator" may decide that there's too much air in everyone's
tires.

No, I am saying the administrator can determine whether a modification
has
been done in accordance with her self-adopted standards. And anybody
who doesn't believe that hasn't worked with the FAA field system.

On Fri, 22 Aug 2003 10:53:41 -0400, "Ron Natalie"
wrote:


"Justin Case" wrote in message ...

The law I'm looking for is the one that seems to be referred to when
everyone says that permission is needed by the STC holder to install
one of his products.

There isn't such a law. The issue is what process you can use to approve
the installation. If you have the valid STC paperwork, then the FAA must
accept it because it says that the manufacturer under it's supervision of
the FAA persuant to the STC issuance says that the installation is safe.
Absent the STC, you must prove other documentation to the FAA that they
find acceptable that the installation is safe and that the means for it continuing
to be safe through maintenance is assured. This is frequently a rougher course.

So what you're saying is that the manufacturers state that a part is
safe for the original purchaser to install, but not subsequent owners,
using exactly the same guidelines as the original owner needed to
meet. Correct?

The "law" is something that everyone seems to quote as the authority
for the FAA to require the extortionists' permission to reuse a part
or system. I'm finding more that the law is vaporware, as I always
suspected. When and if I do find it, I'll be able to determine
whether or not there are restrictions or limitations stated.

"Justin Case" wrote in message
So what you're saying is that the manufacturers state that a part is
safe for the original purchaser to install, but not subsequent owners,
using exactly the same guidelines as the original owner needed to
meet. Correct?

The manufacturers won't issue you the paper saying it is safe unless
you pay. The FAA won't accept the STC as the basis for the modification
unless you have the paper. Can you understand that? There's no rule
specifically allowing them to gouge you, but the combination of the above
two effectively does.

The "law" is something that everyone seems to quote as the authority
for the FAA to require the extortionists' permission to reuse a part
or system.

There is no regulation. But that has no bearing on the issue. The regulations
say that the FAA has the discretion to how to approve modifications to aircraft.
The FAA discretion currently says you must either have an STC, or meet some
common industry standard they approve of, or demonstrate by other means that
the modification is acceptable. The STC is a grease through the process. If
the STC holder can charge whatever they want for the paper to do it. If you want
to pursue the other actions, go ahead. It is the case as you suggested that some
field offices will take the presence of the previous approved installations as a good
part of that acceptance, but it's still got to go through the approval process.

On Fri, 22 Aug 2003 15:07:50 -0400, "Ron Natalie"
wrote:


"Justin Case" wrote in message
So what you're saying is that the manufacturers state that a part is
safe for the original purchaser to install, but not subsequent owners,
using exactly the same guidelines as the original owner needed to
meet. Correct?

The manufacturers won't issue you the paper saying it is safe unless
you pay. The FAA won't accept the STC as the basis for the modification
unless you have the paper. Can you understand that? There's no rule
specifically allowing them to gouge you, but the combination of the above
two effectively does.

The "law" is something that everyone seems to quote as the authority
for the FAA to require the extortionists' permission to reuse a part
or system.

There is no regulation. But that has no bearing on the issue.

Yes it does. Why is there a need to refer to a federal law as a
reason not to grant approval? If there's no law, not granting
approval is discriminatory.

The regulations say that the FAA has the discretion to how to approve modifications to aircraft.

And they did, via approval of the STC data for the modification.

The FAA discretion currently says you must either have an STC, or meet some
common industry standard they approve of, or demonstrate by other means that
the modification is acceptable.

Which is contained in the STC that is provided when you buy the part.
If I may, the FAA is now requiring more than an STC. Remember, we're
not manufacturing parts and installing them using someone else's data.
We're using parts and data supplied by the manufacturer. And did I
mentioned they were paid for a long time ago?

The STC is a grease through the process. If the STC holder can charge whatever they want for the paper to do it.

They already have but there are laws against gouging.

If you want to pursue the other actions, go ahead. It is the case as you suggested that some
field offices will take the presence of the previous approved installations as a good
part of that acceptance, but it's still got to go through the approval process.

What I'm trying to clarify is that the practice is not legal, and may
actually be discriminatory. The only guy I know who did it right was
Lew Gage with his oil filter. He would take a used unit, run it
through a series of tests, maybe even x ray, then issue the
replacement STC based on it being a safe to use part. He didn't ask
$75.00 for a sheet of paper as some of the current extortionists do.

Peter Gottlieb wrote:

What I am getting at is that if some company is charging too
high a price for an STC what is to prevent a group of owners from hiring a
consultant to file for an identical STC of interest?

Nothing. Take a look at the Petersen autogas STCs. Now compare that list with
the ones provided by the EAA. Now compare prices.

George Patterson
Brute force has an elegance all its own.

"Justin Case" wrote in message ...
What I'm trying to clarify is that the practice is not legal,

Well you show me a law. I've posted the stuff that shows the regulations
pretty much leave it to the discretion of the adminstrator. If you have so
consumer law that says the FAA is required to do otherwise, let me know.

Justin Case wrote:

Show me the federal law where
it prohibits homicide.

Be a little hard. Homicide is the killing of a human being. Depending on the
circumstances, that's quite legal.

George Patterson
Brute force has an elegance all its own.

You are a moron, G.R. Patterson.

"...Homicide is the killing of a human being.
Depending on the circumstances, that's quite legal..."
and

"...Brute force has an elegance all its own..."

What garbage... Are you for real, man?


"G.R. Patterson III" wrote in message
...


Justin Case wrote:

Show me the federal law where
it prohibits homicide.

Be a little hard. Homicide is the killing of a human being. Depending on
the
circumstances, that's quite legal.

George Patterson
Brute force has an elegance all its own.