Nicole Noack, who has 17 years of base maintenance and modification experience with Lufthansa Technik and is head of the Independent Aircraft Modifier Alliance (IAMA), spoke with Lee Ann Shay on the sidelines of MRO Middle East in Dubai about overcoming concerns over supplemental type certifications.
What was main reason for forming the Independent Aircraft Modifier Alliance?
If you pursue a modification, you have two options to get approval for the mod: one is through an OEM service bulletin and the other is through a supplemental type certification (STC). Challenges amongst the STC providers come from lease return conditions and the fact an aircraft moves between different operators and aviation authorities, as well as airframe manufacturers limiting access to intellectual property. Those challenges were the main approaches that brought us together. If you look a little deeper, airlines usually prefer OEM solutions over STCs even if they don’t lease aircraft because you’re dealing with one provider, which makes it more predictable. If you look at the STC market, there are more than 2,000 EASA and FAA STC holders. You might not know what you get so as a group we want to strengthen the STC as one of two options to modify an aircraft.
Do lessors restrict STCs on their aircraft, similar to the use of PMA parts?
It depends on the leasing companies. Sometimes they just push it onto their lessee—saying I want to have an STC-free aircraft back. We get their point—if you have an STC on an aircraft that you want to transfer between Japan and Brazil, for example, you need validation work. That is where we have to jointly work to find solutions.
IAMA’s mission statement includes promoting certain standards. What are they?
The core initiative is the standard. Standards already come from authorities: If you want to approve a modification through an STC you have to meet the aviation authority’s standards as a minimum. The whole process of the STC project starts with an RFP and ends with the end of a modification, or a demod, or when the aircraft is scrapped. But in between that, you need your STC supplier, and that’s where we’re creating the standard. If you are an operator and you go into a modification with an independent supplier, you want to be assured that after installing the modification, it will be maintained. You have the instructions for continued airworthiness, but what if you have damage that wasn’t covered? Even after five years, you want to have support. And that is something we want to solve within the alliance because there is a risk if you go with an independent and it loses interest in aftersales support. We take pain points from leasing companies and airlines and we want to solve them, so a modification project becomes more predictable, no matter which of our members you use.
If there are 2,000 STC holders, what is your membership goal for 2000?
Most STC holders only have one or two each. Our membership model aims to get significant players who support the mission and will work together to shape the alliance, the standards and the other initiatives such as digitization. We will limit those full members to 20. We are eight now. We also said if we create a standard, we want to open that standard to smaller and mid-size companies that might not have the intent to shape the standard but want commit to it and are willing to get audited.
Is there confusion about STCS from lessors and airlines?
Absolutely. Similar to the perception of the PMA, it’s similar for STCs but for different reasons. One example is how primary structural modifications effect aging aircraft. Do I lose the extended service goal? We at IAMA say no, because we take our premeasures, which we will put into the standard that our instructions for continued airworthiness will cover that period. There are also prejudices against influenes of STCs on service bulletins that you later install, which causes confusion. So yes, there are perceptions that you can’t install on OEM solution if you already have an STC. That is not the case. It is a matter of evaluating the aircraft and the premodification condition.
IAMA is approaching its one-year anniversary in April. What have been your accomplishments and what’s next?
Our biggest accomplishment since launching is still being here because I think people outside the alliance questioned that. We formed as an association and the members own the IAMA strategy. We doubled our members and established contact with IATA to raise awareness. We also developed the whole concept of the standard and started addressing airline pain points. We have a working model so we can tackle the next challenges, including leasing and primary structure modifications. We will then evaluate the digitalization form and see how we can share our documents in a more standardized way with the customers. There are also lots of opportunities on the regulator side.
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