Update on CPR

FAA/JAAFAA/JAA

19th Annual FAA/JAA International Conference

Changed Product RuleAircraft Certification Workshop

John McColl

FAA/JAAFAA/JAA


Topics• Conference Objectives

• Background (including TOR, Schedule & Status)

• Issues/Debate/Progress & Agreements to date

• Proposed Changes to AC(J) & Examples

• Training & Implementation

FAA/JAAFAA/JAA


Conference Objectives for CPR

• To explain the current direction of CPR activity.

• Clear Understanding of CPR within Authorities & Industry.

• Unambiguous Advisory Text.

• Agree Upon Implementation & Training.

FAA/JAAFAA/JAA


Background – General • Lack of Adequate Guidance and harmonisation (level

playing field for old and new products) on change aspects of aeronautical products.

• Task Force Established 1990 , International Certification Procedures Task Force (ICPTF)).

• Report issued May 1990 proposing changes to JAR/FAR21 (21.19 & 21.101) to move from a ‘bottom up’ to a ‘top down’ approach to certification of changes.

• JAAC Adopted NPA 21-7 (rule) on 30 May 1999• NPA 21-7 Published in Amendment 2 of JAR-21, 1st March

2001.• FAA Published rule in amendment 21-77 on 7th June 2000.

FAA/JAAFAA/JAA


Background • Advisory material prepared by JAA/FAA/TCCA • This addressed the process and examples for

transport category aeroplanes only.• JAA Circulated NPA21-28 on 1st September 2000.• Adopted by JAAC (after some revisions in March

2001).• NPA 21-28 Published in amendment 3 to JAR-21 on

1st November 2001.• FAA Similarly published AC 21.101 August 2001• TCCA will publish their advisory material based on

the harmonized AC(J).

FAA/JAAFAA/JAA


Background• Effectivity Dates;

10 December 2001 for transport category aeroplanes9 December 2002 for all other products

• Ad Hoc Groups & Steering Committee formed to develop examples for other products.

• Autumn 2001 – Industry & Authority concerns raised regarding implementation & interpretation of ‘significant change’.

• JAA/FAA & TCCA agreed to delay implementation of CPR on all products and continue the revision activity on the advisory material.

FAA/JAAFAA/JAA


Background

• Revised Effectivity Date;

10 June 2003 for all products

• JAA CST in consultation with FAA / TCCA & Industry created another Ad Hoc Group with Specific Terms of Reference.

FAA/JAAFAA/JAA


TOR – CPR – All Products• TOR Agreed @ CST Meeting January 2002

• Pre-TOR Discussion CST & CMT wrt Rule change

• TOR only Address ACJ

• Objective – Implement CPR (Efficiently & Practically) + Harmonise ACJ

• Tight Timescale to coincide with 18 month delay(allows for 6 month training and brings all products together)

FAA/JAAFAA/JAA


TOR Deliverable• Harmonise Red/Blue/Green text

• Add Rotorcraft Examples

• Identify Discriminators (criteria/fast track)

Also:- Develop guidance on ‘extent of change’ ‘cumulative effects’

Other Issues:- AssumptionsService ExperienceBig Reg’s

FAA/JAAFAA/JAA


TOR – 2002 Schedule• Jan 2002 TOR Agreed & Ad Hoc Group Formed

• 25 February 1st Meeting @ CJAA

• 5 March CMT (Open & Closed Presentation) • 29 March Draft ACJ circ to Ad Hoc Group

CST & RST

• April CST & RST Agreement Required (RST presentation 17/18 April) (CST presentation 23/25 April)

FAA/JAAFAA/JAA


• End May Issue Draft NPA (2 month comment period for ACJ)

• Beg Aug Consultation closed for draft NPA (Reg Div pass comments to Ad Hoc Group)

• End Aug Ad Hoc Review late August (meeting 27 to 29 August)

• Mid Sep Presentation of the draft AC(J) to RST (12 September)

FAA/JAAFAA/JAA


• End Sept Presentation of draft AC(J) to CST (25/26 Sept)

• End Sept Final NPA & Support Material to CST & RST for final agreement

• End Oct NPA and support material sent to JAAC for adoption by 30 October 2002.

• End Nov JAAC Agreement & Adopt NPA 21-32

FAA/JAAFAA/JAA


FAA Status

• Draft AC Change 1 now on Public Display• AC Published 23 April + FAA Web Site• Industry & ACO comments by 5 June• Chartered Team meeting 11-13 June• Comments to JAA early August• Review with Ad Hoc Group late August• Publish Dec 2002

FAA/JAAFAA/JAA


TCCA Status• TCCA advisory material will be based on the

harmonized ACJ/AC Change 1. • Canadian industry invited to participate in the public

comment process of FAA/JAA on draft Change 1 pending issuance of Canadian CPR final rule.

• TCCA to remain involved with the FAA and JAA in finalizing ACJ/AC Change 1

• TCCA expects to publish their CPR final rule and advisory material by 1st quarter of 2003.

FAA/JAAFAA/JAA


Ad Hoc Gp Mtg• 28 Participants (Chairman as opposed to St Com)• 3 1/2 Days (JAA/FAA/TCCA/CTA/AECMA/AIA)• Several original ICPTF members• JAA/FAA/TCCA Presentations• AIA Presentation• 1 ½ Days debate on Philosophy and issues• Criteria & Examples agreed – Consensus• Consensus on Major Issues – Agreements

• Post Meeting Note;• Approx 6 additional conference calls & final draft @

issue 20.

FAA/JAAFAA/JAA


Issues• Industry recommended rule re-write because flawed, stop

ACJ, not agreed, outside TOR• Rule is not clear on change (TC amendments or everything)• Perception of Added Cost, Time & Bureaucracy• Significant Criteria Set Too Low • ‘Significant’ = Amended TC was intent of ICPTF• If threshold too low:

Considerable Number of Significant Changes

Configuration Issues make it unworkable

Configuration Issues could add risk

FAA/JAAFAA/JAA


Issues• Setting Criteria too low 95% added effort for 5% benefit

• Industry already complying with 21-7 (21.101) for

derivatives

• Industry / Authorities could not cope with paperwork

• Rule / ACJ is transferring work from FAA to Industry

• Large Number of Major Changes

• Production line changes should be excluded

• DER Delegation may not work (inconsistent interpretation)

FAA/JAAFAA/JAA


Issues• Examples/Tables; Set Too Low and therefore distort intent Cannot capture all changes

‘Conditional’ is of no use‘Too much wiggle room’Regulations column is retroactive application

• Declaration of Not Significant is not value added

• Flow chart is not helpful or logical

• DOA Classification of Not Significant required

• If Criteria is required, the rule Criteria are not appropriate

FAA/JAAFAA/JAA


Debate• TOR is for ACJ only• ACJ & training can accommodate issues with the rule• ACJ needs to clarify CPR wrt TC & Type Design• Review of FAA data suggests actual unique major changes are

relatively low; Part 25, ~ 300 (from 3,000 in a 2 year period)

Part 23, ~ 80

Part 27/29 ~ 60

Part 33/35,~ 60

Total ~ 500• Number of Significant Changes very small

• If threshold correct additional effort and paperwork is negligible.

FAA/JAAFAA/JAA


Debate

• The design change should drive “Significant”, not the rule

• “Significant” should be based on Criteria and not driven by amended TC

• Production line changes would normally be not Significant

• Examples / Tables approximate to amended TC in most cases

• Setting the threshold too high adds risk of getting it wrong

• Classification of not Significant would normally be obvious

• Additional admin burden would be minimal

FAA/JAAFAA/JAA


CPR Cert Basis ProcessSubstantial(New TC)

Minor(N/A)

Major Change

(Significant) (Not Significant)Latest Cert BasisUnless;Not affected areaNot materially contributing to SafetyImpracticalSC’s as normal

Existing Cert Basis

Der

ivat

ive

Mod

els,

Ext

ensi

ve

Mod

ifica

tion

s

Pro

duct

ion

Line

Cha

nges

Elect to Comply

Special Conditions May be appropriate (as normal)

FAA/JAAFAA/JAA


Progress• Criteria set at Product Level• Assumptions, examples added to help understanding• Cumulative Effect, examples added, weight & thrust• Agreed to delete requirements column• Agreed that Examples / Tables are required to supplement

Criteria• Particular debate on assumptions• Product Group Consensus• Excluded examples will be used for training database

FAA/JAAFAA/JAA


Agreements - Consensus• The design change should drive “Significant’’, not the

rule• The change should be at Product level (not

component)• Automatic Criteria for Significant • Tables of Examples that validate Criteria Attempt to have Not Sig examples set at high level• Classification / Delegation of Not Significant• Threshold approximates to Amended TC / Derivative

• AC(J) to be drafted reflecting the above

FAA/JAAFAA/JAA


Changes to AC(J)

• Major re-write & Includes all Products• Minimise confusion (Added an applicability, define) Minor, Major, STC’s, TC, Type Design• Added a General Overview• Updated flowchart with steps that relate to text• Concentrates on the determination of Significant• Addresses classification of changes - Delegation• Clearly stated that threshold normally approximates

to derivative (Product Level)• 3 Automatic Criteria defined• ‘Fast Track’ replaced with more obvious classification

FAA/JAAFAA/JAA


Step 1. Identify theProposed Change

to anAeronautical Product

21.101(a)

Step 4.Is the Proposed Change

considered to beSignificant?21.101(b)(1)

Impractical orNot ContributingMaterially to theLevel of Safety

Unaffected Areas

Not Significant

NEW TYPECERTIFICATE

21.17

Step 5.For every area, is the area affectedBy the by the by by rhe by the bythe

By the Proposed Change?21.101(b)(2)

Step 6.Are the New Requirements

practical and do they contributematerially to the level of Safety?

21.101(b)(3)

Step 2.Is theChange

Substantial?(21.19)

LATEST EARLIER REQUIREMENTS BUT REQUIREMENTS NOT PRIOR TO THE EXISTING CERTIFICATION BASIS

NO

YES

NO

NO

NO

YES

YES

YES

CERTIFICATION BASIS

Step 3. Will thelatest

requirements beused?

Will the latestrequirements be used?

NO

Yes

Yes

No

FAA/JAAFAA/JAA


Changes

• Appendix 1, changed from Process to Examples

Criteria Supplemented by Examples; 168

Part 23, 25 Significant, 43 Not Significant

Part 25, 17 Significant, 13 Not Significant

Parts, 27&29 14 Significant, 9 Not Significant

Parts, E&P 14 Significant, 33 Not Significant

70 98

• Appendix 2, Impracticality (minimum change (23&25) examples)

• Appendix 3, Service Experience (minimum change (25 & 29 examples))

FAA/JAAFAA/JAA


Examples – Significant Changes

Part 23 Only

The following are examples for significant changes:

Description of Product Level Change

21.101(b)(1)(i) Is there a Change to the General Configu-ration?

21.101(b)(1)(i)Is there a Change to the Principles of Construction?

21.101(b)(1(ii) Have the assumptions used for Certification been invalidated?

Notes

Conventional tail to T-tail or Y-tail, or vice versa

Yes

FAA/JAAFAA/JAA


Typical Examples of Significant Changes• Large Aircraft

Conf. Const. Assu.

Derivative model, e.g.

Increased passenger payload,

Freighter version, or

Complete update of a certified aeroplane.

Yes Yes Yes Multiple changes packaged into a new model.

Increased payload new freighter would change the general configuration and assumptions.

Updated aeroplane would change principles of construction.

Modify for flight in known icing conditions by adding ice detection systems.

Yes No Yes New A/C operating Envelope

Requires installation of major new systems & evaluation

FAA/JAAFAA/JAA


Typical Examples of Significant ChangesSmall Aircraft

Conventional tail to T-tail or Y-tail, or vice versa

Yes Yes Yes Change in general configuration.

Likely changes in principles of construction & certification assumptions.

Addition of cabin pressurisation

No Yes Yes Change in cert Assumptions

Requires extensive construction re-assessment.

Conf. Const. Assu.

FAA/JAAFAA/JAA


Typical Examples of Significant ChangesRotorcraft

Extensive changes to equipment, systems, and installations required to support an upgrade to CATA certification approval

No No Yes Engine and drive systems rating changes appropriate for CATA and rotorcraft performance requirements, and change in design requirements specific to CATA

Certification for flight into known icing conditions.

No No Yes

Conf. Const. Assu.

FAA/JAAFAA/JAA


Typical Examples of Significant ChangesEngines

Hydro-Mechanical to FADEC/EEC without backup

Yes Yes Yes Change in engine control configuration. Likely change in model designation. Not interchangeable. Assumptions used for certification may no longer be valid

A change in the containment case from hard-wall to composite or vice-versa, that is not retrofittable

No Yes No Change in methods of construction that can affect inherent strength

Conf. Const. Assu.

FAA/JAAFAA/JAA


Typical Examples of Non Significant Changes

Large Aeroplanes

Change in type or number of emergency exits.

No No No So long as the product change does not require an increase in the number of passengers normally allowed per exit, this is not a significant product level change.

Integrated modular avionics

No No No This is not a product level change – it is a component level change since the basic functionality of the systems are unchanged.

Conf. Const. Assu.

FAA/JAAFAA/JAA



Small Aeroplanes

Addition of wingtip modifications (not winglets)

No No No

Structural strength increases

No No No No change in general configuration, principles of construction & certification assumptions.

Conf. Const. Assu.

FAA/JAAFAA/JAA



Rotorcraft

FLIR or surveillance camera installation

No No No Additional flight or structural evaluation may be necessary but the change does not alter the basic rotorcraft certification

Helicopter Terrain Awareness Warning System (HTAWS) for operational credit

No No No Certified per rotorcraft HTAWS AC guidance material

Conf. Const. Assu.

FAA/JAAFAA/JAA



Engines

Increase/decrease in the number of compressor/turbine stages without resultant change in performance envelope

No No No No change in performance.

Model designation may or may not change. Assumptions are still valid

Changes to limits on exhaust gas temperature

No No No No controversy-No comments

Conf. Const. Assu.

FAA/JAAFAA/JAA


Making the Classification

The applicant for a change to type certificate makes a classification of significant/non-significant (the application of 21.101(b)(1)) in one of two ways;

1. By the authority agreeing to appropriate controls and procedures that enable the applicant to make a declaration of not-significant. In all cases the authority retains the option to become involved. An appropriate declaration by the applicant to the authority would be acceptable for this purpose.

2. By the authority accepting the determination of significance relevant to a major modification based on the applicant’s submission.Note for FAA & TCCA: 2. is replaced by ..2. By delegation, where appropriate guidelines are in place to support a classification of not significant by the applicant. The Authority may accept the not significant determination without further showing and rely on the applicant’s design control system and the authority’s oversight system to monitor and validate decisions.

FAA/JAAFAA/JAA


Training• Training Material (some already available)

(FAA Internal Awareness training was done & TCCA training inc Industry), Do not repeat, Go to Detailed.

Agree common material Use draft AC(J) examples as a database for training

• Training of Trainers ; Use Ad Hoc Gp

Authority & Industry Members

• Training of Authority & Industry Staff (Joint, if possible)

FAA/JAAFAA/JAA


FAA Training

• 3 Meetings to update material to include all products and policy changes regarding the AC.

• Lesson development meetings (July, Oct & Nov ’02)

• Walkthrough meeting in Jan ’03• Prototype class Feb ’03

FAA/JAAFAA/JAA


TCCA Training•Training Lesson development: Oct ‘02 – Jan ’03

•Awareness Level training: Satellite Broadcast–2 sessions (Jan/Feb ‘03)–1 day each

• Specialist Level training; Classroom Delivery–12 sessions (Feb through May ‘03)–3 days each–Different locations across Canada

• Canadian industry is an integral part of CPR training development and delivery

FAA/JAAFAA/JAA


JAA Training

• Population to be trained:

Authority (cert/val JAA teams) 250 (estimated)

Authority (NAAs)

Industry

• Training sessions (only for the cert/val teams):

10 sessions (25 participants)

• Trainers: 5 (JAA)

FAA/JAAFAA/JAA


JAA Training

• Training for JAA trainers:

Duration: 3 days (including preparation)

Location: CJAA

Dates: tbd

Material: From jointly developed with FAA & TCCA.

FAA/JAAFAA/JAA


JAA Training• Training for JAA cert/val specialists

Duration: 3 days (including preparation)Location: CJAA and NAAs (most suitable for each case)Dates: Not yet availableMaterial: From jointly developed with FAA & TCCA.

• Training for Authorities (NAA)

(not yet defined)

• Training for Industry

(not yet defined)

FAA/JAAFAA/JAA


Implementation

• Identify internal procedure changes (JAA/FAA/TCCA)

• Process for PCM’s, Teams & Authorities to submit data to JAA (EASA) on CPR change applications / determinations (Sig & Controversial Not Sig changes)

• Monitor Progress (Consistency)• JAA/FAA/TCCA update & review (initially

every 6 months)

FAA/JAAFAA/JAA


Reviewing Objectives

• Have we set the bar at the correct level for a Significant Change ?

• Clear Understanding of CPR (Authorities & Industry)

• Training (Timescales & Participation)• Implementation

Update on CPR

Documents

Transcript of Update on CPR