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In an STC symphony the certification plan is the score, the major-domo document that tells who is to play what note when. It is a living manuscript, says Luke Ribich, ASIG’s managing director. It changes as it matures because “stuff always pops up along the way.”
Its genesis begins in Phase I, Conceptual Design, with the kickoff meeting where ASIG familiarizes the FAA Aircraft Certification Office (ACO) with the project and what FAA resources will be needed to complete it, “if we don’t already have access to them, which we usually do,” says Ribich.
Occasionally this briefing can take place virtually, says Ribich, but ASIG prefers meeting face to face, just as it does with its customers, because it simplifies mutually beneficial show-and-tell, the gathering’s essential purpose. Given the depth of detail derived from the definition of work with the operator, ASIG briefing includes who will supply major equipment and any related vendor relationships.
For example, in addition to “certification management and technology insertion,” ASIG may distribute the equipment it’s installing, such as EmPower and the OnBoard IFE system. Such arrangements rarely cause problems because everyone knows about them up front, just like any technical issues related to the STC, or unique or novel features it introduces.
In the simplest terms, in Phase I ASIG and the ACO discuss every aspect of the certification plan before ASIG writes it. The FAA reviews the submitted plan in Phase II, Requirements Definition, which leads to the project’s first milestone, FAA acceptance of the plan.
Briefly, the certification plan includes General Information, a complete, concise description of the modification. It specifies compliance methods and verification data, including ground, air, and component testing. This must be congruent with the certification basis, says Ribich. In certain cases, a project may use a historic level of certification rather than current regulations.
The Schedule of Project Completion predicts all major milestones, submission of data and test plans, and when and where design, manufacturing, parts, installation, and conformity inspections will take place. Meeting deadlines is the key to avoiding delays, so ASIG coordinates all schedule changes with the ACO.
To expedite certification and reduce the demand on ACO resources, at the kickoff meeting ASIG requests that its staff DERs and DARs perform all appropriate engineering and airworthiness work on the FAA’s behalf. The certification plan lists this mutually agreed upon cadre of experts and their contribution to the project.
The Continued Airworthiness Plan tells how the design change will affect the instructions for continued airworthiness and the forthcoming updates. Likewise, there is a conformity plan. If the project involves hardware and/or software not already approved by TSO or conforming to RTCA standards, this, too, must be addressed in the plan.
When the plan passes muster, the FAA accepts it and the ACO assigns a project manager, and it is ready for Phase III, Compliance Planning.
Until next time, stay 5x5, mission ready, and Wired!