h. AEG inspectors represent the FAA Flight Standards Division. AEG operations inspectors evaluate flight crew operating manuals, manufacturers’ flight training programs, and aircraft designs for operational suitability. Airworthiness inspectors examine the maintenance aspects of the project, and determine the acceptability of the ICA. The AEG maintains the master minimum equipment list (MMEL) for each type of aircraft. If the AEG determines that your STC modification affects the MMEL, you must revise the MMEL.
1-12. FAA Project Classification and Oversight.
a. In addition to the regulatory classifications of a project, we further classify a project to determine the level of FAA oversight and participation. We determine whether projects are “significant” or “non-significant” as defined in agency directives. Although this is an internal classification, you should know that such classifications do occur. The classification helps the ACO identify related issues so that those issues can be included in the early stages of project planning.
b. Significant projects tend to demand increased involvement of FAA personnel, and at a higher level. The directorate may retain signature authority to issue the STC rather than delegate it to the project ACO. Directorate t echnical staff may also take an active role in reviewing the design, evaluating data, and providing policy guidance to the ACO.
1-13. U.S. STCs Using Foreign-Registered Test Aircraft. If you intend to use a foreignregistered test aircraft in the STC certification program, notify us. See chapter 10 for special considerations.
CHAPTER 2. THE STC PROCESS
2-1. General. While this chapter describes the STC certification process for an aircraft, the process is similar for an engine or propeller. Only major changes in type design require approval through issuance of an STC by the ACO. The STC process is divided into five phases:
• Phase I - Conceptual Design (paragraph 2- 2)
• Phase II - Requirements Definition (paragraph 2- 7)
• Phase III - Compliance Planning (paragraph 2- 12)
• Phase IV - Implementation (paragraph 2- 17)
• Phase V - Post Certification Activities (paragraph 2- 34)
2-2. Phase I, Conceptual Design. This phase includes:
• Process orientation.
• Pre-project guidance.
• Familiarization briefing.
• Certification plan requirement.
2-3. Process Orientation. We encourage applicants seeking an STC approval to contact the ACO in their geographic area (see website for ACO locations http://www.faa.gov/aircraft/air_cert/locate_office/aco/) before submitting an STC application.
During this initial contact, an ACO project manager will discuss the type of approval you’re requesting, and assess your knowledge of certification procedures. The project manager will conduct a process orientation for applicants unfamiliar with certification. The process orientation establishes our partnership with you and helps you understand the type certification process as it applies to your design. The orientation will explain the need for certification, the certification process, our role, your responsibilities, and the advantages of maximizing the use of designees.
2-4. Pre-Project Guidance. We require an STC application with a certification plan before providing full access to FAA resources necessary to complete a project. However, before this application, we respond to your questions as a potential applicant about FAA procedural and technical requirements that may arise after your process orientation. The ACO will first direct 9
you to appropriate regulatory, policy, and guidance material, and then perhaps get involved directly. We might do this to determine how unique or novel your proposed design is, or to research past policy applications.
2-5. Familiarization Briefing. Familiarization briefings give potential applicants the opportunity to describe their project to the ACO before application. The main purpose is to familiarize us with your proposed design as you currently know it. Learning about projects before submission of the application also allows the ACO to consider FAA involvement and begin planning resources. In your briefing to us , emphasize any technical issues and unique or novel features. Beyond the design features, tell us about the intended operation, major suppliers and unusual vendor relationships, reliance on approved equipment, project schedule, reliance on designees or delegated organizations, and any other planned alterations on the prototype product.
2-6. Certification Plan Requirement. We will ask you to submit a certification plan for the STC project. The certification plan is a “road map” that both of us will agree on and follow.
In general, the certification plan should contain detailed descriptions of the type design change, methods of compliance, how much and type of testing is necessary, when and where you will use designees, and schedule information. The certification plan should be considered a “living document,” and be revised as necessary when project circumstances change. When revised, the certification plan will need the concurrence of the project manager. Figure 2-4 shows a sample certification plan outline. See further discussion on certification plan contents in paragraph
2-8.
2-7. Phase II. Requirements Definition. This phase includes:
• Applying for STC and submitting the certification plan.
• FAA establishing a project.
• When applicable, submit a project specific certification plan (PSCP).
• Establishing the certification basis.
2-8. Applying for STC and Submitting the Certification Plan.
a. The formal STC certification process begins when you submit the application form, FAA Form 8110-12, Application for Type Certificate, Production Certificate or Supplemental Type Certificate. You submit the application to the FAA ACO responsible for your geographic location. See appendix 1 of this AC for instructions to complete Form 8110-12, and a sample of a completed form.
b. Transmit the application to the ACO with a cover letter and the certification plan, 10
including:
(1) Project description.
(2) Type of product.
(3) Schedule for project completion.
(4) Locations where design, parts manufacturing, and installation work as well as ground and flight tests will be conducted.
(5) Request to schedule a project initiation meeting (at your discretion).
(6) Foreign aviation authority’s agreement if you intend to use foreign-registered aircraft for the STC project.
Note: If the foreign aviation authority plans to validate our STC, then application for that authority’s certification should be made as soon as possible.
(7) Your phone number and e-mail address.
c. We should have evidence of authorization if you intend to authorize one or more agents to represent you during the STC certification program. A letter of authorization is acceptable. Attach it to the letter that transmits the application.
d. We require each applicant to submit a copy of the program’s certification plan with the application package. We expect that you have developed a reasonably detailed program plan before submitting an application for STC. The certification plan should be comprehensive and sufficiently detailed to allow a good understanding of how you plan to accomplish the requirements for certification. One of the first milestones in the STC process is our acceptance of your certification plan. We use the standards in current FAA directives to review your plan.
Your certification plan should include the following elements:
(1) General Information. (Corresponds to sections I through VII in Figure 2-4.)
Applicant identification, along with the application date, and model designation of the unchanged product. Briefly but completely describe the modification. Present the certification basis, including any applicable exemptions, equivalent level of safety findings, and special conditions. Describe your methods of compliance, including tests, component, ground, and flight, analysis, and similarity. Include a list of data that you’ll submit to show compliance.
See chapter 3 for more information about identifying the applicable regulations.
(2) Certification Project Schedule. (Corresponds to section VIII in Figure 2-4.)
Identify dates of major milestones, dates for submittal of data and test plans, dates and locations for parts conformity inspections and installation conformity inspections, dates and locations for testing, and the planned project completion date.
(3) Use of Designees. (Corresponds to section IX in Figure 2-4.) Identify all FAA designees you expect to participate in the project. The list may include designated manufacturing inspection representatives (DMIR), designated airworthiness representatives (DAR), and designated engineering representatives (DER). List each designee by name and include the designee’s number, specialty, point of contact (if necessary), FAA home office, and level of authority. Identify the function or specific compliance determination that each designee will perform as part of the certification plan.
(4) Continued Airworthiness Requirements. (Corresponds to section X in Figure
2-4.) As an STC holder, you must provide ICA to those persons or agencies required to comply with the methods, techniques, and practices in them. The ICA need only address continued airworthiness with respect to the design change for which application was made, and parts or areas affected by the design change. An aircraft may not be approved for return to service until we have accepted the ICA.
e. In addition to the certification plan, you must complete a conformity plan. The conformity plan can be submitted at a later date, but prior to any actual conformity taking place. This conformity plan is a general overview of the project: a list of focal points, description of inspection systems in place and inspection procedures used for conformity inspections, identification and tracking of conformity inspections, description of the conformity inspections, and the plan for airworthiness certification and aircraft return to service at project completion.
f. You are responsible for meeting the milestones set in the certification plan schedule.
Any slippage in the milestone dates may result in a program delay. For the project to proceed as efficiently as possible, we strongly encourage you to coordinate schedule changes with us as soon as possible.
2-9. FAA Establishes a Project.
a. When we accept an STC application, we will establish a project and assign a project manager. After receiving the application and certification plan, the project manager will send you an acknowledgment. The acknowledgment and response will identify the project number, project manager and other members of the FAA certification team, including engineers, flight test personnel, AEG personnel, manufacturing inspection personnel, directorate project officer, and any other team members. The response will also indicate a date for a project initiation meeting as appropriate.
b. We will review your certification plan and concur if it’s satisfactory. If it’s not, we will comment on it or suggest modifications. We will accept the certification plan when the information sufficiently outlines a program to demonstrating compliance with the certification basis by analysis and, if required, by testing (see par. 2-11.). The plan will present your certification procedures and schedule for accomplishing the project.
c. For systems that contain software, prepare a plan for software aspects of the 12
certification (PSAC) and submit it to us after we accept the certification plan, unless it is a previously approved software based on Technical Standard Order (TSO) authorization or other approval process. Detailed guidance for preparation of the PSAC is in RTCA, Inc. document RTCA/ DO-178, Software Considerations in Airborne Systems and Equipment Certification.
d. For systems that contain complex hardware, prepare a plan for hardware aspects of certification (PHAC) and submit it to us after we accept the certification plan. Detailed guidance for preparation of the PHAC is in RTCA, Inc. document RTCA/ DO-254, Complex Electronic Hardware.
2-10. The Project Specific Certification Plan (PSCP). The PSCP is the primary project management tool for coordinating activities between us and applicants who choose to implement the techniques and guidance described in The FAA and Industry Guide to Product Certification (the CPI Guide). You can find this guide at:
http://www.faa.gov/aircraft/air_cert/design_approvals/media/CPI_guide_II.pdf.
2-11. Establish Certification Basis.
a. One of the first tasks in an STC project is defining a certification basis. The certification basis is the set of regulations, special conditions, equivalent safety findings, and exemptions to the rules that identify the airworthiness standards and other standards for which you must show compliance. You must demonstrate compliance with all elements of the certification basis to our satisfaction before we issue an STC.
b. For some significant STC projects we may develop an issue paper to define the project’s certification basis. We designate this as the G-1 issue paper. See chapter 3 of this AC for more details on developing the certification basis. The G-1 issue paper states the FAA’s position and your (applicant’s) position. When we reach an agreement with you, we prepare a conclusion, which becomes the STC project’s official certification basis.
c. The compliance checklist is a valuable aid for you and us to document which regulations apply to the project and how compliance is shown with each regulation. See figure 2-5 for a sample checklist.
2-12. Phase III. Compliance Planning. In this phase the FAA project team makes determinations on:
• FAA involvement.
• Using parts produced by technical standard order (TSO) authorization or parts manufacturer approval (PMA) in certification testing.
• Completed (project specific) certification plan.
• Interim TCB meeting for [project specific] certification plan agreement.
2-13. FAA Involvement. For planning purposes, the FAA and applicant certification teams will determine which aspects of the project the FAA will maintain involvement and the extent of FAA involvement. Due to resource constraints, FAA involvement in certification activities may be limited. FAA certification team members will review your design descriptions and project plans, determine where their attention will yield the most benefit, and coordinate their intentions with you.
a. When a particular decision or event is critical to product safety or compliance determination, we stay directly involved (as opposed to indirect involvement by, for example, DERs). Some key issues that will always re quire our direct involvement include rulemaking (such as for special conditions), equivalent level of safety (ELOS) determinations, developing issue papers, and compliance findings that we consider unusual or typically reserve for ourselves. While these items set the minimum direct FAA involvement, we may also identify additional critical safety findings, based on the safety impact, complexity of the requirement, or the method of compliance. We will determine our level of involvement based on your experience, your internal processes, and the experience of your designees.
b. When we focus FAA resources to oversee the most critical areas, we make the best use of the ACO’s limited resources.
c. Once the project team has determined the findings requiring our involvement, we consider all other compliance requirements acceptable for delegation. Once we delegate a finding, we’ll determine any increase in direct involvement based on its level of criticality.
d. You can write an agreement with your ACO describing the process where you, under the supervision of the management DER, can do the project with maximum independence from us, except for establishing the certification basis, accepting ICA, noise and emissions findings, signing the STC, and approving and signing the flight manual supplement.
See chapter 4 for more information on using designees.
e. We use conformity inspections for both quality assurance and engineering purposes. As part of the type certification pr ocess, the ACO should identify the affected areas of the product to be conformed for certification. During the inspection, FAA manufacturing inspectors base the extent of their assessment on factors such as quality of your conformity paperwork, comparison of inspection results, and size and complexity of the inspection.
f. You are responsible for identifying the test articles used to generate compliance data, and for conducting 100 percent applicant conformity of those test articles as required by 14 CFR § 21.33(b). The ACO identifies features, a ttributes, and components critical to the test results and requests FAA conformity on these test articles with special instructions as necessary. FAA conformity is a validation of your conformity. The manufacturing inspection district office (MIDO) determines what conformity inspections will be necessary for processing production approvals.
g. To expedite agreement on the approval of a completed certification plan or PSCP, develop your test article and schedule data into a conformity plan that the ACO and MIDO can accept with minimal further development. While we encourage your involvement in the conformity plan, we retain the right to make the necessary inspections to determine compliance with the applicable 14 CFR requirements. Therefore, we are responsible for the final content of the plan.
2-14. Using Parts Produced by Technical Standard Order (TSO) Authorization or Parts Manufacturer Approval (PMA) in Certification Testing. Either a Technical Standard Order Authorization (TSOA) or PMA indicates that the FAA has determined that the part produced thereunder conforms to a specifically defined FAA-approved design, and that any deviations from that approved design have been found to have no effect on form, fit, or function of the article. According to 14 CFR § 21.601(b)(4), an article manufactured under a TSOA is an FAA-approved article or appliance for the purpose of meeting the regulations of this chapter that require the article to be approved. For parts produced under a PMA, the corresponding regulatory definition for the fabrication inspection system is 14 CFR § 21.303(h). Marking the part according to 14 CFR § 45.15 also indicates that a part meets the FAA-approved design. For parts approved by TSOA or PMA, part conformity will not be necessary for its use in a certification project.
Note: TSO articles must have separate approval for installation in an aircraft. The article may be installed only if performed under 14 CFR part 43 or the applicable airworthiness requirements. It is the responsibility of those installing the article either on or within a specific type or class of aircraft to determine that the aircraft installation conditions are within the TSO standards. As part of the STC process certain functionality aspects will need to be tested/evaluated, particularly since we have new advanced avionics with extra features and functions not specified in the TSO that will require evaluation as part of the STC process.
2-15. COMPLETED (PROJECT SPECIFIC) CERTIFICATION PLAN. By now, the details of your plan for showing compliance, including the remaining elements outlined in paragraph 2-6 above should be captured by you in the certification plan. From this information, our certification team will determine that, if the plan was successfully executed, its results would show compliance. The amount of detail necessary will vary from finding to finding, but, in general, it decreases when you choose common means of compliance, such as those described in ACs. The certification team should find the plan agreeable before processing conformity requests, approving test plans, witnessing or observing certification tests, or performing any other certification project activities, to ensure that they and you are working with the same fundamental understanding of the certification data.
2-16. Interim Type Certification Board (TCB) Meeting for (Project Specific) Certification Plan Agreement. The TCB meeting establishes consensus on all integrated certification planning. During this meeting, the applicant and the FAA use the PSCP or the certification plan to assess the certification risks of proceeding toward showing and finding compliance. We obtain mutual agreement to the adequacy of the plan and acceptance of the risks before implementation. Our certification team may hold one main interim TCB meeting 15
to agree on how to conduct the project, followed by splinter meetings among our specialized staff to address the certification activities required for the various systems, disciplines, or components of the product design. The TCB meeting for certification plan agreement concludes with the completion of the splinter meetings. Your ACO uses an interim TCB meeting to establish agreement with the certification plan when the following happens:
a. The project requires significant coordination of resources,
b. A face-to-face meeting will help all involved parties understand how compliance will be shown,
c. You or the ACO may ask for one,
d. Certification plan issues need FAA management visibility,
e. The project manager wants to encourage teamwork within the FAA and with you,
f. Many of your comments and questions could be more efficiently addressed in person, and
g. We need to resolve plan deficiencies with you.
Note: For those projects using the techniques and guidance from, The FAA and Industry Guide to Product Certification, the expected level of detail in a PSCP allows our project manager/engineer to identify your deliverables and hold the appropriate parties responsible for fulfilling their commitments. It similarly binds us to the commitments we made.
2-17. Phase IV. Implementation. This phase includes:
• Data Submittal for Approval.
• FAA design evaluation.
• Conformity inspections.
• Applicant test plan and FAA approval.
• (Before witnessing) engineering and flight tests.
• Engineering certification tests.
• Engineering compliance inspection.
• Analysis.
• Experimental airworthiness certificate.
• Ground inspections, ground tests, and flight tests.
• Review of applicant’s flight test results.
• Type inspection authorization (TIA).
• Flight test conformity inspections and certification flight tests.
• Aircraft evaluation group (AEG) activities.
• Aircraft flight manual supplement.
• Supplemental type certificate issued.
2-18. Data Submittal for Approval.
a. Submit all data to the ACO project manager for review and approval. If you modify or update the data during the project, immediately contact the ACO project manager and set up a schedule for submitting changed or modified data to us.
b. In many cases we may need more than one copy of your data submittal package.
Contact the ACO project manager before submitting any data to determine if you should send more than one copy.
c. You are responsible for showing compliance with all the applicable regulations.
Type design and substantiating data should show that the proposed design complies with all requirements in the established certification basis.
• Type design data are drawings, specifications, information on dimensions, materials and processes, airworthiness limitations, and any other data necessary to describe the design of the product.
• Substantiating data is data necessary to show compliance with the certification basis, such as test and analysis reports, and ground and flight test reports.
d. We don’t prescribe a specific format for submitting technical data. But, if you submit it in any form other than original paper copy, we must decide if it’s acceptable. We may have to agree with you, using a memorandum of agreement, on the way you submit data to us.
2-19. FAA Design Evaluation.
a. We examine the design data you submit, conduct inspections and witness tests as necessary, and determine if the data shows that the proposed design complies with the certification basis. We also review and accept or approve substantiating data. We are only responsible for reviewing the submitted data, not for developing the analytical methods.
b. We (or our DER) must approve your test plans before you start a test. Test plans should include all necessary details, such as description of test fixtures and test articles (parts, components, subassemblies, or a complete product), as well as comprehensive descriptions of 17
all testing. Identify components and assemblies requiring conformity, including the test fixture and equipment.
c. We will coordinate project related work only with you or your authorized agent identified on the STC application, FAA Form 8110-12, unless otherwise indicated in a specific authorization. You are responsible for coor dinating any FAA requests with your vendors and subcontractors.
d. After we review the data and determine that it shows compliance with the certification basis, the project manager will notify you that we accepted the data.
2-20. Conformity Inspections. Conformity inspections verify and provide objective documentation that the test articles, parts, assemblies, installations, functions, and test setups conform to the design data. 14 CFR § 21.33(a) requires you to allow us to conduct any conformity inspections we choose during the type certification process. FAA engineering personnel are responsible for determining the need to conduct conformity inspections, and then for requesting that the project MIDO do the required inspections. Because the conformity process is so complex and parts conformity inspections need to be made early in the certification project, consult your project MIDO early about inspections. This ensures the necessary inspections are scheduled at appropriate times. Our manufacturing inspector, or authorized designee(s) will conduct all necessary conformity inspections, verifying that the product conforms to the drawings, specifications, and special processes. The FAA conformity inspection must be successfully accomplished before any certification ground or flight tests are conducted (all completed and signed FAA forms 8100-1, Conformity Inspection Record, must be submitted to the ACO project manager prior to any official certification ground or flight testing).
a. 14 CFR § 21.33(b) says, “Each applicant must make all inspections and tests necessary to determine:
(1) Compliance with the applicable airworthiness, aircraft noise, fuel venting, and exhaust emission requirements,
(2) Materials and products conform to the specifications in the type design,
(3) Parts of the products conform to the drawings in the type design, and
(4) The manufacturing processes, construction, and assembly conform to those specified in the type design.”
b. Submit FAA Form 8130-9, Statement of Conformity, attesting that the articles conform to the proposed design. We should receive these forms from you before doing any FAA conformity inspections. This is the way that the applicant attests that the test articles conform to the proposed type design (see 14 CFR § 21.53(b)).
2-21. Applicant Test Plan and FAA Approval. Prepare a test plan when testing is necessary to show compliance to the regulations. Submit the test plan early enough for us to review and approve the plan before you start the test. In the plan, describe the items you’ll test and a list of all equipment necessary for the test. Describe how to calibrate the equipment (when calibration is required) and have it approved before the test, the required conformities of the test article and setup, and list the specific applicable airworthiness standards. Describe how you expect compliance to be shown, and write a test procedure in step-by-step format with defined pass/fail criteria. After we or the DE R approve the test plan, we request an FAA conformity inspection of the test article and test setup to ensure conformance to the engineering drawings and test plan.
2-22. (Before Witnessing) Engineering and Flight Tests. When witnessing official tests, the witness we authorize will verify that the procedures in your approved test plan are followed and that any data captured by test instrumentation is valid data for the test in question. If the ACO engineer or pilot cannot witness the test, they will authorize another qualified ACO engineer, FAA pilot, or DER; or ask a manufacturing inspector to witness the test.
a. Minimum participants for witnessing the test are our authorized witness and your knowledgeable representative who is able to perform the test. After the test, the FAA- authorized witness signs a record showing the results were obtained by properly following the approved test plan. This record should identify the test and include the results obtained, the decisions reached, and any recommendations the witness made to you. This record is not a substitute for your test report showing completion of the test plan.
b. If a MIDO inspector or DER is the witness, the ACO will coordinate specific instructions, if any, prior to the test.
2-23. Engineering Certification Tests.
a. These tests are used by applicants to demonstrate compliance with a requirement, or to collect quantifiable product or component data necessary for showing compliance. In contrast, certification flight tests rely on, or supplement quantifiable data with, the pilot’s qualitative evaluation. They’re conducted on a test article of the product. A certification flight test may provide both a compliance demonstration for the engineer, as well as a qualitative assessment for the pilot. Examples of engineering certification tests include part qualification, system function, iron bird, fatigue, flammability, landing gear drop test, ground vibration, and electro-magnetic interference tests. Most of these tests satisfy 14 CFR§ 21.35(a)(2).
b. We have established that a reliable way to determine an aircraft’s safety is to show its compliance with minimum standards established by the applicable airworthiness requirements. Therefore, you must adequately evaluate the aircraft by performing engineering tests, analysis, and flight tests. Accomplish each of your tests successfully before conducting any FAA certification flight test. To show co mpliance with a type certification requirement, the conformity of the test article, test setup, and test procedures used, and the validity of the test results must be established for each certification test conducted. In other words, you should submit test reports and substantiating data for all certification testing, plus any other 19