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With the certification plan accepted, the project manager and ASIG-FAA team assigned, Phase III of the STC symphony, Compliance Planning, begins, says Luke Ribich, ASIG’s managing director. It completes the certification plan by itemizing how tests and inspections will verify its realization.
How involved the FAA is in this effort depends on the project’s complexity, the available resources, and the experience of the applicant and its designated engineering and airworthiness representatives. Triggers for increased FAA involvement include rulemaking for special conditions, determining ELOS—equivalent levels of safety—developing issue papers, and tasks it never delegates.
Typically, the FAA delegates all but its direct responsibilities, so DERs and DARs, conduct the conformity inspections that demonstrate engineering and manufacturing quality and show compliance. Using common compliance means, such as those outlined in advisory circulars, streamlines the process. Parts built to a TSO have already earned FAA approval, and a Parts Manufacturer Approval, also handled by ASIG, does the same for equipment built specifically for the STC.
Ultimately, the ACO identifies critical test items that generate data for 100 percent compliance, providing special test instructions as necessary. Compliance planning completes the Certification Plan, and if everything it contains is successfully executed, the results will show compliance.
In Phase IV, Implementation, ASIG starts submitting the actual data to the project manager, according to the timetable. Type design data includes drawings, specs, dimensions, materials, processes, airworthiness limitations, and more. Other data comes from design evaluations and conformity inspections of parts, assemblies, installations, test articles and setups, and functions. The FAA evaluates it all to ensure that it matches everything specified in the certification plan.
The FAA can conduct any conformity inspection it wants, and the project must pass them before ground and/or flight testing can begin. When ASIG manufactures an installation kit, it must pass a conformity inspection, usually conducted by a staff DAR, before it can be installed, Ribich says. A second conformity inspection verifies, down to the smallest fastener, that the kit was appropriately installed.
During conformity inspections the test team is finalizing its comprehensive plan, which covers everything from the test items, process, and setup to when and where and witnesses. As with every other aspect of the certification plan, “everyone is on the same page about the level of testing,” and conformity inspections verify that the tests followed the approved plan. Meanwhile, the FAA’s aircraft evaluation group (AEG) is reviewing other aspects, like the electrical wiring interconnection system plan, ICA, and flight manual supplement.
When it is clear the aircraft will meet the certification basis, the FAA issues a Type Inspection Authorization, an internal document clearing the aircraft is ready for its final certification inspections and tests. If these tests deliver as all previous data has predicted, and the AEG has signed off on its reviews, the FAA issues the STC.
Issuance of the STC begins Phase IV, Post-Certification Activities. With the airline in charge of operational safety and airworthiness accountability with ASIG, as appropriate they evaluate, report, and remedy any applicable problems and disseminate this information to all involved, because the rewards of an STC symphony also come with continuing responsibility.
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