What kind of limitation is this? Anyway, even without knowing this my opinion is that you would have to obtain a STC (supplemental type cert)from your local ACO (FAA aircraft cert office). Unless of course if you owned the TC (type cert). But you would have to still work the change thru the ACO. The best way to proceed (in my opinion) is to contact a DER (designated engineering rep).
If we purchase a certain 3rd party's STC, It will come with a limitation.
I don't believe it's valid. It's weasel worded to the point it has no technical meaning. It's not even structured to be limitation that can be observed?
when is a limitation no a limitation ...
when it's "weasel worded to the point it has no technical meaning. It's not even structured to be limitation that can be observed"
if the limitation has no or little operational or economic impact to the operator, i think they're smart enough to know it.
whilst it's not "very" ethical, could you reverse engineer the STC, making it different enough to avoid nasty "legal issues" and delete the limitation ?
i'd consult with the FAA before buying the STC. Perhaps they would let you simply revise the flight manual supplement to remove the limitation (without amending the STC). Now you can negotiate a lower price (based on having a limitation) then nix it.
I don't know what catagory your aircraft is so I don't know which FAR Part governs your aircraft, but I am constantly involved in producing STC products under Part 25, Transport Catagory Aircraft. In our world at least, a Flight Manual Supplement limitation can be removed but normally only through a configuration change. Removing such a limitation would require demonstrating to the FAA that the reason for the limitation has been resolved.
Typically that occurs in one of two ways. First, the STC for the offending equipment (the 3rd party STC, in your case) could be amended to resolve the condition that required the limitation. Second, some other configuration change may occur on the aircraft (another STC, a service bulletin, etc) which, while in the process of changing the aircraft configuration, resolved the condition that required the limitation.
In the few cases where we can remove a limitation due to configuration changes, it requires analysis, testing, drawing inspections, or some combination of the above to substantiate removing the limitation.
Without knowing the catagory, FAR Part, details of the limitation, and the existing aircraft configuration, I am unable to offer any more specific information. The earlier suggestion by Kwan to consult a DER with experience in the equipment that causes the limitation is an excellent idea.
As you may know aircraft flight manuals have limitation sections that are FAA approved. The only one that can give relief is the FAA Aircraft Certification Office (ACO). Across the United States there are nine ACO offices. I work for the Oakland FSDO and our ACO is located in Los Angles. If a person wants relief you should send a letter to your local FSDO, they will send a letter to the regional ACO (Flight Test Branch) and ask for assistance. The Flight Test Branch will provide a letter back to the FSDO who will then contact you back with the information acceptable or unacceptable.
You should know all changes to flight manual should go thru the FSDO who will process it thru Flight Test Branch. What you are requesting will require a FAA Form 337 to make the one time change to the limitation section.
Aviation safety inspectors (ASI) no longer approve data for use on multiple aircraft as in the past. For one aircraft a FAA Form 337 would be submitted for field approval in accordance with FAA Order 8300.10 Vol. 2 Chapter 1. This Order is available on the FAA web site at
You are right if it is relief of several aircraft the STC process how you should approach it. I happen to have a copy of Western Pacific manual for STC’s if you send me a private e-mail and tell where to send a copy I would be happy to. Or you can contact the FAA engineering office in your region and they will send you a copy also.
I appreciate your offer, I'll go ahead and contact the FAA engineering office in our region. It’ll be a good discovery exercise.
I need to remain anonymous to participate in the tips group. To establish an association with my employer might mean clearing every comment before posting it.
A private connection would take new hot mail address or something. I’d just as soon forgo anything that requires managing another password.
