AC 25-27A

Advisory circular · Development of Transport Category Airplane Electrical Wiring Interconnection Systems Instructions for Continued Airworthiness Using and Enhanced Zonal Analysis Procedure

Approved
May 4, 2010
Last reviewed
June 30, 2017
Cancels
AC25-27
Family
AC 25-27 · 2 versions
Revision
A
14 CFR parts
25, 26
14 CFR sections
§ 25.1729§ 26.11

Guidance, not mandatory unless a rule or AD requires it. DRS record last changed October 23, 2026.

Show pages 61–72

Appendix E

b. Section 26.11.

“§ 26.11 Electrical wiring interconnection systems (EWIS) maintenance program

(a) Except as provided in paragraph (g) of this section, this section applies to transport category, turbine-powered airplanes with a type certificate issued after January 1, 1958, that, as a result of the original certification, or later increase in capacity, have—

(1) A maximum type-certificated passenger capacity of 30 or more or

(2) A maximum payload capacity of 7,500 pounds or more.

(b) Holders of, and applicants for, type certificates, as identified in paragraph (d) of this section must develop Instructions for Continued Airworthiness (ICA) for the representative airplane’s EWIS in accordance with part 25, Appendix H paragraphs H25.5(a)(1) and (b) of this subchapter in effect on [effective date of this final rule] for each affected type design, and submit those ICA for review and approval by the FAA Oversight Office. For purposes of this section, the “representative airplane” is the configuration of each model series airplane that incorporates all variations of EWIS used in production on that series airplane, and all TC-holder-designed modifications mandated by airworthiness directive as of the effective date of this rule. Each person specified in paragraph (d) of this section must also review any fuel tank system ICA developed by that person to comply with SFAR 88 to ensure compatibility with the EWIS ICA, including minimizing redundant requirements.

(c) Applicants for amendments to type certificates and supplemental type certificates, as identified in paragraph (d) of this section, must:

(1) Evaluate whether the design change for which approval is sought necessitates a revision to the ICA required by paragraph (b) of this section to comply with the requirements of Appendix H, paragraphs H25.5(a)(1) and (b). If so, the applicant must develop and submit the necessary revisions for review and approval by the FAA Oversight Office.

(2) Ensure that any revised EWIS ICA remain compatible with any fuel tank system ICA previously developed to comply with SFAR 88 and any redundant requirements between them are minimized.

(d) The following persons must comply with the requirements of paragraph (b) or (c) of this section, as applicable, before the dates specified.

(1) Holders of type certificates (TC): [insert date 24 months after effective date]

(2) Applicants for TCs, and amendments to TCs (including service bulletins describing design changes), if the date of application was before [effective date of final rule] and the certificate was issued on or after [effective date of final rule]: [insert date 24 months after effective date], or the date the certificate is issued, whichever occurs later.

(3) Unless compliance with § 25.1729 of this subchapter is required or elected, applicants for amendments to TCs, if the application was filed on or after [effective date of final E-9

Appendix E rule]: [insert date 24 months after effective date], or the date of approval of the certificate, whichever occurs later.

(4) Applicants for supplemental type certificates (STC), including changes to existing STCs, if the date of application was before [effective date of final rule] and the certificate was issued on or after [effective date of final rule]: [insert date 30 months after effective date], or the date of approval of the certificate, whichever occurs later.

(5) Unless compliance with § 25.1729 of this subchapter is required or elected, applicants for STCs, including changes to existing STCs, if the application was filed on or after [effective date of final rule], [insert date 30 months after effective date], or the date of approval of the certificate, whichever occurs later.

(e) Each person identified in paragraphs (d)(1), (d)(2), and (d)(4) of this section must submit to the FAA Oversight Office for approval a compliance plan by [insert date 90 days after effective date of final rule]. The compliance plan must include the following information:

(1) A proposed project schedule, identifying all major milestones, for meeting the compliance dates specified in paragraph (d) of this section.

(2) A proposed means of compliance with this section, identifying all required submissions, including all compliance items as mandated in part 25, Appendix H paragraphs H25.5(a)(1) and (b) of this subchapter in effect on [effective date of this final rule], and all data to be developed to substantiate compliance.

(3) A proposal for submitting a draft of all compliance items required by paragraph

(e)(2) of this section for review by the FAA Oversight Office not less than 60 days before the compliance time specified in paragraph (d) of this section.

(4) A proposal for how the approved ICA will be made available to affected persons.

(f) Each affected person must implement the compliance plan, or later approved revisions, as approved in compliance with paragraph (e) of this section.

(g) This section does not apply to the following airplane models:

(1) Lockheed L-188

(2) Bombardier CL-44

(3) Mitsubishi YS-11

(4) British Aerospace BAC 1-11

(5) Concorde

(6) deHavilland D.H. 106 Comet 4C

(7) VFW-Vereinigte Flugtechnische Werk VFW-614 E-10

Appendix E

(8) Illyushin Aviation IL 96T

(9) Bristol Aircraft Britannia 305

(10) Handley Page Herald Type 300

(11) Avions Marcel Dassault - Breguet Aviation Mercure 100C

(12) Airbus Caravelle

(13) Lockheed L-300”

b. NPRM Preamble Discussion (70 FR 58526, October 6, 2005). Part 26 was proposed as a new Subpart I to Part 25. The placement of these requirements was changed in the final rule.

“B. Part 25 Subpart I—Continued Airworthiness and Related Part 25 Changes As discussed below, the following proposals are applicable to holders of existing TCs for transport category airplanes and applicants for approval of design changes to those certificates. On July 12, 2005, we issued policy statement PS-ANM110-7-12-2005, “Safety – A Shared Responsibility – New Direction for Addressing Airworthiness Issues for Transport Airplanes” (70 FR 40166). The policy states, in part, “Based on our evaluation of more effective regulatory approaches for certain types of safety initiatives and the comments received from the Aging Airplane Program Update (July 30, 2004), the FAA has concluded that we need to adopt a regulatory approach recognizing the shared responsibility between design approval holders (DAH) and operators. When we decide that general rulemaking is needed to address an airworthiness issue, and believe the safety objective can only be fully achieved if the DAHs provide operators with the necessary information in a timely manner, we will propose requirements for the affected DAHs to provide that information by a certain date.”

We believe that the safety objectives contained in this proposal can only be reliably achieved and acceptable to the FAA if the DAHs provide the operators with the EWIS- and fuel­ tank-system-related maintenance information required by the proposed operational rules for Parts 91, 121, 125, and 129. Our determination that DAH requirements are necessary to support the initiatives contained in this proposal is based on several factors:

• Developing EWIS and fuel tank system ICA is complex. Only the airplane manufacturer, or DAH, has access to all the necessary type design data needed for the timely and efficient development of the required EWIS and fuel tank system maintenance tasks.

• FAA-approved EWIS and fuel tank system ICA need to be available in a timely manner. Due to the complexity of these ICA, we need to ensure that the DAHs submit them for approval on schedule. This will allow the FAA Oversight Office having approval authority to ensure that the ICA are acceptable, are available on time, and can be readily implemented by the affected operators. Additionally, accurate and timely information is necessary to ensure alignment with the requirements of the Fuel Tank Safety Rule (FTSR). The compliance deadline for the operational requirements of the FTSR was extended to facilitate this alignment, as stated E-11

Appendix E in the Federal Register notice “Fuel Tank Safety Compliance Extension (Final Rule) and Aging Airplane Program Update (Request for Comments)” (69 FR 45936).

• The proposals in this NPRM affect a large number of different types of transport airplanes. Because the safety issues addressed by this proposal are common to many airplanes, we need to ensure that technical requirements are met consistently and the processes of compliance are consistent. This will ensure that the proposed safety enhancements are implemented in a standardized manner.

• The safety objectives of this proposal need to be maintained for the operational life of the airplane. We need to ensure that future design changes to the type design of the airplane do not degrade the safety enhancements achieved by the initial incorporation of EWIS and fuel tank system ICA. We need to be aware of future changes to the type designs to ensure that these changes do not invalidate the maintenance tasks assigned to a particular type design when the ICA are first developed under the requirements of this proposal.

Based on the above reasons and the stated safety objectives of FAA policy PS-ANM110-7-12-2005, we are proposing to implement DAH requirements applicable to EWIS and fuel tank system ICA.

In the past, we have issued a similar requirement in the form of a special federal aviation regulation (SFAR). But SFARs appear in various places in the CFR and are difficult to reference as a whole. The FAA believes that placing these types of requirements in a new subpart of part 25, which contains the airworthiness standards for transport category airplanes, would provide a single, readily accessible location for this type of requirement. Therefore, we are proposing new subpart I to part 25 to contain these requirements.

In preliminary discussions with foreign airworthiness authorities of the concept of this new subpart, they have expressed concerns that their regulatory systems may not be able to accommodate these types of requirements in their counterparts to part 25. While agreeing on the need for these types of requirements, they have suggested that it may be more appropriate to place them in part 21 or another location. As discussed below, because we expect these new subpart I requirements to be similar to new part 25 airworthiness standards, we have tentatively decided to place them in part 25. However, we specifically request comments on the appropriate location of these requirements, particularly from the foreign authorities. If, based on comments received, we conclude that another location is more appropriate, we may move them in the final rule. Because such a move would not affect the substance of the requirements themselves, we would not consider this to be an expansion of the scope of this rulemaking that would require additional notice and comment procedures.

Section 25.1 Applicability.

As stated in § 25.1, part 25 currently prescribes airworthiness standards for issuance of TCs, and changes to those certificates, for transport category airplanes. As discussed in more detail above, with this NPRM the FAA is proposing to expand the coverage of part 25 to include a new subpart I containing requirements that must be complied with by current holders of these certificates. Therefore, we are proposing to amend § 25.1, “Applicability,” to state that part 25 E-12

Appendix E also includes requirements for holders of these design certificates. As discussed in the FAA’s final rule, “Fuel Tank Safety Compliance Extension and Aging Airplane Program Update” (69 FR 45936), this NPRM is one of several proposals for adoption of these kinds of requirements for current holders of type certificates.

A theme common to this and other possible subpart I proposed rules is that the rulemaking projects include proposals for changes to operational rules to require operators to implement programs or take other actions that the FAA has determined are necessary for safety.

In several recent rules we have adopted operational requirements without a corresponding requirement for design approval holders to develop and provide the necessary data and documents to support the operators’ compliance. The difficulty encountered by operators in complying with these rules has convinced us that the corresponding design approval holder requirements are necessary to enable operators to comply by the regulatory deadlines.

Section 25.2 Special retroactive requirements.

Section 25.2 currently contains “special retroactive requirements.” These requirements are “retroactive” in the sense that they require applicants for changes to TCs to comply with requirements that were not applicable to the original TC. As discussed below, proposed subpart I would have a similar effect, in that it would impose new requirements on both existing design certificate holders and applicants for changes to those certificates. Therefore, we are proposing to amend § 25.2 to make reference to proposed subpart I.

Section 25.1801 Purpose and Definition.

Paragraph (a) of this section states that this subpart would establish requirements for holders of TCs to take actions necessary to address particular safety concerns or to support the continued airworthiness of transport category airplanes. Such actions may include, but are not limited to, performing assessments, making design changes, developing revisions to ICA, and making necessary documentation available to affected persons.

The specific applicability of each subpart I rule will be established as part of the rulemaking adopting each rule. Generally this subpart would also apply to applicants for type certificates and changes that are pending as of the effective date of this rule. It would also apply to future applicants for changes to existing type certificates. Under § 21.101, the FAA may determine that it is not appropriate to require such applicants to comply with new airworthiness standards, such as proposed new subpart H. However, it is appropriate for them to comply with the same requirements as existing certificate holders. Otherwise, the safety improvements that result from type certificate holder compliance with these requirements could be undone by later modifications.

For example, in the case of this proposed rule, as discussed below, operators would be required to revise their maintenance programs based on EWIS ICA developed by the type certificate holder. Unless future STC applicants are required to provide similar ICA for their modifications, the TC holder’s ICA could become obsolete or, in some cases, even provide incorrect and potentially unsafe information as applied to the STC holder’s modification. In other cases, because subpart I rules accompany corresponding operating requirements, failure of E-13

Appendix E an STC applicant to comply with a subpart I rule could make it impossible for an operator to comply with the corresponding operating requirement. Subpart I does not apply to future applicants for TCs, because those applicants will be covered by other proposed changes to part 25, including Appendix H.

Therefore, adoption of a new subpart I rule would also necessitate new requirements for certification of changes to TCs that are in addition to the requirements that are specified under § 21.101. Under that section, if a change is “significant” and certain other criteria are met, the applicant would have to show compliance with the latest airworthiness requirements. For example, an applicant applying for such a change after this final rule becomes effective would have to comply with the proposed EWIS requirements in subpart H. Even if we determine that these broader regulations do not apply, the applicant for a change must still comply with the subpart I rule.

Paragraph (b) of this section provides a definition of the term “FAA Oversight Office.”

The FAA Oversight Office is the aircraft certification office or office of the Transport Airplane Directorate with oversight responsibility for the relevant TC or STC, as determined by the Administrator. As stated later in the discussion of the proposed operating rules, the primary means for operators to comply with those requirements would be by implementing programs or taking other actions developed by the TC and STC holders under this proposed subpart. In each case, to ensure compliance with the relevant subpart I rule, the TC and STC holder’s compliance documentation (for example, in this case, EWIS ICA) must be submitted to the FAA Oversight Office. Because we expect this will be a standard approach to compliance with the requirements of this subpart, we are including this definition in this section to avoid having to repeat it in each section within this subpart.

25.1805 Electrical Wiring Interconnection Systems (EWIS) Maintenance Program.

This proposal would apply to holders of TCs and to applicants for new TCs, amended TCs, and supplemental TCs if the application was filed before the effective date of this rule and the certificate was issued on or after the effective date of this rule. It would also apply to future applicants for approval of changes to existing TCs.

Paragraph (a) states that this rule would apply, with some exceptions, to transport category turbine-powered airplanes with a maximum type-certificated capacity of 30 or more passengers, or a maximum payload capacity of 7500 pounds or more resulting from the original certification of the airplane or later increase in capacity. This would result in the coverage of airplanes where the safety benefits and the public interest are the greatest.

The reference to the originally certificated capacity, or later increase in capacity, is intended to address two situations:

• In the past, some designers and operators have tried to avoid applying requirements mandated only for airplanes over specified capacities by getting a design change approval for a slightly lower capacity. By referencing the capacity resulting from original certification, this proposal would remove this possible means of avoiding compliance.

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Appendix E

• It is also possible that an airplane design could be originally certified with a capacity slightly lower than the minimum specified in this section, but through later design changes, the capacity could be increased above this minimum. The reference to later increases in capacity would ensure that, if this occurs, the design would have to meet the requirements of this section.

Compliance is not proposed for airplanes with a certificated passenger capacity of fewer than 30 passengers, or having a maximum capacity of less than 7500 pounds payload resulting from original certification, because it is not clear at this time that the possible benefits for those airplanes would be proportionate to the cost involved. The FAA intends to evaluate the merits of applying these requirements to those airplanes. We are currently working with ATSRAC to assess how these issues might be addressed in those transport category airplanes. We request comments on the feasibility and benefits of requiring holders of TCs for those airplanes to comply with these requirements.

This proposed rule, as it applies to EWIS, is not applicable to holders of existing (already issued) STCs. Often, the wire design for STC installations of EWIS was based on operator or repair station standard practices and therefore details of the installation are not available. In the cases where such information is available, it would usually indicate that the wiring for the modification follows the same path, or is in the same airplane zone, as the wiring in the original type design. We anticipate that operators would inspect those areas while performing the TC holder’s EZAP program. We also expect that any possible discrepancies will be further mitigated by operators incorporating applicable EWIS maintenance tasks into the maintenance program for that zone. Accordingly, the FAA has decided not to require compliance with this section for existing STCs. However, if an existing STC is amended, this section would apply to the amendment.

TC holders, who design EWIS on airplanes, are the technical experts who possess information about those systems. This proposal would apply to the following:

• TC holders.

• Applicants for TCs and for approval of design changes to existing TCs whose applications are pending when this rule becomes effective.

• Future applicants for approval of design changes to existing TCs.

Section 25.1805(b) would require TC holders to complete a comprehensive assessment of the EWIS of each “representative” airplane for which they hold a TC, develop inspection and maintenance instructions for them, and incorporate those instructions into the airplane’s ICA.

The “representative” airplane is defined as the configuration of each model series airplane that incorporates all the variations of EWIS used on that model, and that includes all TC-holder­ designed modifications mandated by AD, as of the effective date of this rule.

For example, for the Boeing Model 737, the representative airplane would be the configuration of each of the airplane series, 737-100 through 737-900 that incorporates all the variations of EWIS used in producing each airplane series. The purpose of this definition is to ensure that the TC holder considers the full range of EWIS configurations that may affect the E-15

Appendix E results of the EZAP. Further, AD 99-03-04 applies to all Boeing Model 737-100, -200, -300, -400, and -500 series airplanes. It requires installation of components to provide shielding and separation of the fuel system wiring from adjacent wiring. It also requires installation of flame arrestors and pressure relief valves in the fuel vent system. Boeing would be required to develop ICA for each of those series airplanes as modified by installation of these components and all other modifications mandated by ADs.

The purpose of including these mandated design changes is to ensure that the TC holder’s EZAP addresses the existing configuration of airplanes in the operating fleet, rather than just the configuration produced and delivered by the manufacturer.

Applicants for approval of design changes would be required to evaluate the effect of their proposed change on the EWIS ICA developed by the TC holder for the representative airplane and to develop EWIS ICA to address those effects. For TC holders, this requirement would apply to any design changes that may affect the ICA for the representative airplane. This includes service bulletins describing such design changes. Under § 21.113, these design changes are amendments to the TC.

A description of what must be included in those ICA, and the EZAP that must be used to develop them, is contained in the section of this preamble discussing the proposed revision to Appendix H, part 25.

The requirement for ICA was effective on January 28, 1981. TC holders whose application was dated before that date are not subject to that requirement. This proposal would require TC holders who do not have ICA for specific airplane models to create EWIS ICA for them. As discussed below, air carriers and operators of those airplanes would then be required to revise their maintenance or inspection programs based on the new ICA for EWIS and fuel tank systems.

As discussed earlier, SFAR 88 requires TC holders to develop maintenance and inspection instructions to assure the safety of the fuel tank system. Proposed § 25.1805(b) would require that TC holders align the fuel tank system instructions with the results of the EZAP applied to EWIS to ensure compatibility and minimize redundancies. All EWIS would be subject to review in developing the EWIS ICA, and the appropriate instructions for their maintenance and inspection would be required. But some EWIS are also part of the fuel tank system. The requirements for their maintenance and inspection might be more specific than those for wiring in general, and might contain additional requirements. That is why the two must be reviewed for compatibility.

As discussed later in this section, the ICA for fuel tank system electrical wiring required by SFAR 88 will be determined in accordance with guidance provided by Policy Statement ANM100-2004-1129, “Process for Developing Instructions for Maintenance and Inspection of Fuel Tank Systems Required by SFAR 88” (a copy of which may be found in the docket), or other acceptable process. Compliance with Subpart I will require ICA for the same wire to be determined using an EZAP. While these processes have similarities, they may result in identification of different tasks and intervals. The ICA maintenance tasks and intervals that E-16

Appendix E result from these determinations are expected to be additive. If there is a conflict in the task or interval, for purposes of this section, the FAA Oversight Office will resolve the conflict.

The ICA should be reviewed to ensure that any maintenance tasks for EWIS do not compromise fuel tank system wire requirements, such as separation or configuration specifications. If there is an inspection or maintenance requirement for EWIS and the fuel tank system within the same zone, there must be an effort to align the task interval. In addition, design certificate holder’s existing documents containing EWIS and fuel tank system ICA should be reviewed to either remove or cross-reference redundant information.

The compliance plan required by this proposal must include identification of those common locations in the airplane where EWIS and fuel tank ICA apply. The considerations for compatibility and minimization of redundancy for the two systems will be reviewed and approved by the FAA Oversight Office. The plan for documenting the required ICA for EWIS and fuel tank system will also be reviewed as part of the compliance plan. These documents are critical to the effort that will be required of operators to show compliance with the operational rules contained in this proposal. We intend that the ICA information, both in content and format, will be readily usable by the affected operators for developing proposed changes to their maintenance or inspection programs. Generally, the information contained in the ICA for the fuel tank system required by SFAR 88 would include:

• The location of the fuel tank system components to be maintained or inspected and any access requirements.

• Any unique procedures required, such as special, detailed inspections or dual sign-off of maintenance records.

• Specific task information, such as inspections defined by pictures or schematics.

• Intervals for any repetitive tasks.

• Methods, techniques, and practices required to perform the task.

• Criteria for passing inspections.

• Any special equipment or test apparatus required.

• Critical Design Configuration Control Limitations—for example, wire separation or pump impeller material specifications—that cannot be altered, except in accordance with the applicable limitation.

The information for EWIS ICA would generally include:

• Identification of each zone of the airplane.

• Identification of each zone that contains EWIS.

• Identification of each zone containing EWIS that also contains combustible material.

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Appendix E

• Identification of each zone in which EWIS is in close proximity to both primary and back-up hydraulic, mechanical, or electrical flight controls and lines.

• The location of the EWIS components to be maintained or inspected and any access requirements.

• Any unique procedures required, such as special, detailed inspections, or a dual sign-off of maintenance records.

• Specific task information, such as inspections defined by pictures or schematics.

• Intervals for any repetitive tasks.

• Methods, techniques and practices required to perform the task.

• Criteria for passing inspections.

• Any special equipment or test apparatus required.

• Instructions for protection and caution information that will minimize contamination and accidental damage to EWIS during performance of maintenance, alterations, or repairs.

• Guidelines for identifying wiring discrepancies and assessing what effect such discrepancies, if found, could have on adjacent systems, particularly if these include wiring.

• Critical Design Configuration Control Limitations—for example, wire separation specifications—that cannot be altered, except in accordance with the applicable limitation.

Policy Statement No. PS-ANM100-2004-10029 provides guidance on acceptable processes for developing fuel tank system ICA as required by SFAR 88. The FAA expects that engineers from aircraft certification offices or from the Transport Airplane Directorate will review and approve the results of the EZAP.

The three groups whose compliance with this proposal would be required, and their required compliance dates, indicated in paragraph (c), are as follows:

• Existing TC holders: No later than December 16, 2007.

• Current applicants for TCs and amendments to TCs (including service bulletins describing design changes) whose applications are pending and future applicants for TC amendments: No later than December 16, 2007, or the date of approval of their application, whichever is later.

• Pending and future applicants for STCs: No later than June 16, 2008, or the date of the approval of their application, whichever is later.

Future applicants for changes to TCs that comply with proposed § 25.1739 would not be required to comply with this section. As discussed previously, under § 21.101, applicants for E-18

Appendix E “significant” changes that meet certain criteria must comply with the latest airworthiness requirements. If this NPRM is adopted as a final rule, such a future applicant would have to comply with § 25.1739. Because the proposed requirements of that section are more extensive than the proposed requirements of § 25.1805, requiring compliance with this section would be redundant.

In determining the compliance schedules for the requirements covered in this proposal, the FAA balanced the safety-related reasons for the rule against the need to give industry enough time to comply with it. Therefore, before setting the proposed compliance times for the TC holders to complete their analysis of their representative type design, the FAA considered the following:

• Input from industry.

• Current or planned compliance periods of several aging-related rulemakings, such as the pending Aging Airplane Safety proposed rule, Fuel Tank System safety initiatives (69 FR 45936, 66 FR 23086), and the pending Widespread Fatigue Damage proposal.

• Safety improvements that will result from compliance with this rule.

• Industry’s current efforts to incorporate some of these safety initiatives.

ATSRAC recommended a compliance time of 24 months for TC holders to develop these ICA. To align this proposal with other rules in the aging airplane program, the FAA has adjusted the time frame to that of other rules discussed earlier, so that operators can more efficiently comply with requirements to revise their maintenance programs. To support this realignment, compliance dates that allow an 18-month time frame for TC holders to develop the EWIS ICA and 12 months for operators to implement them were determined to be appropriate and were included in this proposal. We believe these time frames are supported by the experience gained from the EZAPs already performed. Since ATSRAC made its recommendation, several manufacturers have applied an EZAP to their type design airplanes and have completed those reviews.

When we initially drafted this proposal, we assumed the final rule would be adopted by mid-2006. As a result, we set the compliance dates in the proposal using the mid-2006 time frame as the baseline. However, the proposed rulemaking process took longer than we had anticipated. Consequently, we expect that the time frame for adoption of the final rule will be sometime after mid-2006. We recognize that this delay will adversely impact the compliance dates we propose for TC holders and operators and we may need to adjust them. Therefore, we request and will consider your comments on revising the proposed compliance dates. Once the ICA are approved by the FAA Oversight Office, the submitter must make the ICA available to affected persons as required by § 21.50.

Because this proposal sets a precedent in introducing part 25 requirements for holders of existing TCs, it is the FAA’s expectation that they will work closely with the FAA Oversight Office in putting together a compliance plan for developing the required ICA. Proposed section E-19

Appendix E

25.1805(d) would require that the compliance plan be approved by the FAA Oversight Office as sufficient basis for showing compliance with the proposed § 25.1805.

Development of a compliance plan is necessary to ensure that TC holders thoroughly understand the requirements of this proposal and produce on time appropriate ICA that are acceptable in content and format in addressing the maintenance and inspection tasks for EWIS and the fuel tank system. Integral to the compliance plan will be the inclusion of procedures to allow the FAA to monitor progress towards compliance. These aspects of the plan will help ensure that the expected outcomes will be acceptable and on time for incorporation by the affected operators in accordance with the operational rules contained in this proposal.

To help ensure that TC holders are fully informed of what is necessary to show compliance with these requirements, as previously discussed, we are issuing AC 120.XX, and have issued a policy statement that describes an acceptable means, but not the only means, of complying with these requirements for developing EWIS ICA and the fuel tank system ICA required by SFAR 88. AC 120-XX, “Program to Enhance Transport Category Airplane Electrical Wiring Interconnection System Maintenance,” provides an enhanced zonal analysis procedure (EZAP) for completing a review of the representative airplane covering all areas, including the flight deck (or cockpit), electrical power center, fuel tank wiring, and powerfeeder cables. Policy Statement ANM100-2004-10029, “Process for Developing Instructions for Maintenance and Inspection of Fuel Tank Systems Required by SFAR 88,” provides guidance for identifying ICA, including any airworthiness limitations, as a result of the fuel tank system review required by SFAR 88 and compliance with Amendment 102 to part 25 Appendix H and § 25.981.

Proposed § 25.1805(d) is intended to provide TC holders, applicants with pending TC-amendment or STC applications, and the FAA with assurance that they understand what means of compliance are acceptable and have taken necessary actions, including assigning sufficient resources, to achieve compliance with this section. This paragraph is based substantially on “The FAA and Industry Guide to Product Certification,” which describes a process for developing project-specific certification plans for type certification programs. A copy of this guide may be found in the docket. This planning requirement would not apply to future applicants for TC amendments or STCs because, as described in the guide, this type of planning routinely occurs at the beginning of the certification process.

The guide recognizes the importance of ongoing communication and cooperation between applicants and the FAA. Section 25.1805, while regulatory in nature, is intended to encourage establishment of the same type of relationship in the process of complying with this section. In particular, in addition to other necessary information, paragraph (d)(3) makes it clear that, to the extent that they intend to use means of compliance different from those already identified as acceptable by the FAA, it is imperative that they identify those differences at the earliest possible stage so any compliance issues can be resolved without risk of unnecessary expenditure of resources or, ultimately, noncompliance.

Proposed § 25.1805(d) would require TC holders and applicants to submit to the FAA Oversight Office the following within 90 days after the effective date of the rule:

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