Advisory Circular (AC) No. 500-015 Issue 1

The purpose of this Advisory Circular (AC) is to provide the aviation community with guidance on the development process, format, and content of a Certification Plan prepared for aeronautical product type certification, or modification and repair design approval activities.

Note:

Certification Plans are not required for those cases where the means and method of substantiating compliance are well understood and agreed to by both Transport Canada and the applicant. The need to develop a Certification Plan should be discussed with Transport Canada to determine if the complexity of substantiating compliance to a specific requirement warrants development of a Certification Plan.

1.2 Guidance Applicability

This document is applicable to all Transport Canada personnel, delegates and industry.

1.3 Description of Changes

This document, formerly AMA No. 500/15A is reissued as an AC. With the exception of minor editorial changes and updated references, the content is unaltered.

1.4 Termination

This document does not have a terminating action. It will however, be reviewed periodically for suitability of content.

2.0 References

2.1 Reference Documents

It is intended that the following reference materials be used in conjunction with this document:

(a) Chapter 505 of the Airworthiness Manual (AWM) - Delegation of Authority;

(b) Chapter 511 of the AWM - Approval of the Type Design of an Aeronautical Product;

(d) Chapter 523-VLA of the AWM - Very Light Aeroplanes;

(e) Chapter 523 of the AWM - Normal, Utility, Aerobatic and Commuter Category Aeroplanes;

(f) Chapter 525 of the AWM - Transport Category Aeroplanes;

(g) Chapter 527 of the AWM - Normal Category Rotorcraft;

(h) Chapter 529 of the AWM - Transport Category Rotorcraft;

(i) Advisory Circular (AC) 511-002 - Type Certification Procedure for Canadian Aeronautical Products;

(j) Aeronautics Act;

(k) FAA Advisory Circular (AC) 23-8A - Flight Test Guide for Certification of Part 23 Airplanes;

(l) FAA Advisory Circular (AC) 25-7A - Flight Test Guide for Certification of Transport Category Airplanes;

(m) FAA Advisory Circular (AC) 27-1B - Certification of Normal Category Rotorcraft; and

(n) FAA Advisory Circular (AC) 29-2C - Certification of Transport Category Rotorcraft.

2.2 Cancelled Document

As of the effective date of this document, AMA No. 500/15A dated 10 June 2003 is cancelled.

2.3 Definitions

For this AC:

(a) Certification Plan is a document that clearly identifies:

(i) the means and methods by which an aeronautical product will be shown to comply with the applicable airworthiness requirements, where the airworthiness requirements are typically identified in a compliance record document;

(ii) the agreed level of delegation granted to the applicant for each applicable requirement; and

(iii) the agreed level of involvement of certification team members (Transport Canada and Delegates) for each applicable requirement.

(b) Level of delegation means the specific delegation granted to a Delegate, who has the appropriate scope of delegation to make a finding of compliance with a specific requirement (or set of requirements) and to approve the associated data;

(c) Level of involvement means the specific involvement that Transport Canada specialists or Delegates will have when making a finding of compliance with a specific requirement (or set of requirements) and approving the associated data;

(d) Compliance record document means a document prepared by the applicant, or the applicant's Delegate(s), which identifies the basis of certification, the method of compliance to be employed for each requirement, the referenced documentation used to substantiate the findings of compliance, and typically a signature area to be signed or initialed to signify findings of compliance and/or recommendations for findings of compliance for each requirement in the basis of certification. The Compliance record document is alternatively referred to as a compliance program document and as a compliance plan in the regulations or as a General Compliance Program (GCP);

(e) Aeronautical product means an aircraft, aircraft engine, aircraft propeller, or aircraft appliance; and

(f) Delegate means any person or corporation authorized under the authority of subsection 4.3(1) of the Aeronautics Act to perform functions on behalf of the Minister, subject to the conditions named in AWM Chapter 505.

3.0 Background

The referenced airworthiness standards require that an applicant provide compliance record documentation that identifies the method of compliance and where this is documented for each requirement in the basis of certification. Certification project management and tracking activities are performed using documents such as the GCP, which is generally sufficient to establish the means of compliance and, to a certain extent, how compliance will be shown against the established basis of certification. The GCP served as an excellent tool to manage and document the certification process, to record findings of compliance or recommendations for findings of compliance, and approval of associated data through signature or initials of the appropriate specialists. Over time, however, the complexity of aircraft designs and the number of delegates involved in certification programs have increased whereas the time allotted to complete these projects has tended to be shortened.

The GCP has historically included codes signifying the means of compliance to be used to substantiate compliance with each requirement (i.e., T for Test, A for Analysis, etc.), but these codes provide little or no detail as to how this was to be accomplished. This lack of detail early in a project has resulted in misunderstandings between Transport Canada and applicants that did not become apparent until late in the project, becoming a serious impediment to meeting a project's target dates and, in some cases, resulting in significant financial obstacles to the applicant.

Although there is usually considerable discussion to define the basis of certification near the start of a certification project and, in some cases, the basic means of compliance to be identified in the GCP (i.e., Test vs. Analysis), there is usually a lack of early detailed discussion on the applicable means of compliance and the associated methods of compliance. Consequently, there is usually limited or no formal documentation of these more detailed discussions and explanations of the methods of compliance that will be used. The objective of the Certification Plan is to promote detailed discussions on the means and methods of compliance between Transport Canada specialists and the applicant early in the project, and to document these discussions and agreements between Transport Canada and the applicant.

Through the identification and documentation of certification activities, it is possible to clearly identify the compliance documentation and activities to be completed to demonstrate compliance with the applicable requirements. Documentation of the detailed methods of compliance ensures that there is a record of agreements reached, which may assist an applicant in avoiding duplication of certification activities when obtaining foreign certification.

Early identification of division of responsibilities, expectations, documents, data and tests will clarify who has responsibility for approval of the type design and substantiating data. Additionally, information concerning all certification testing and compliance reporting can be consolidated into a single master schedule to provide visibility into resource allocation and the overall test-witnessing schedule.

3.1 Objective of a Certification Plan

The objective of a Certification Plan as a tool in the certification or approval process is to:

(a) Improve overall communications and efficiency of the certification process;

(b) Provide an early and clear understanding of expectations to achieve certification;

(d) Provide early identification of potential certification problems;

(e) Optimize the certification process by agreement on the Certification Plan before involvement of other authorities (parallel certification process); and

(f) Provide a documented record of agreements for the information of other authorities in consideration for foreign certification activities that could include preparation of issue papers or certification review items.

4.0 Certification Plan Development Process

4.1 Prior to starting development of a certification plan

Prior to starting development of a certification plan, Transport Canada and the applicant should:

(a) Review the specific aeronautical product type certification, modification, or repair approval activity and related GCP to determine if a Certification Plan will be required for the project; and

(b) Discuss the complexity of substantiating compliance to a specific requirement, or set of requirements, to determine if there is a need to develop a Certification Plan for those requirements. A Certification Plan may not be required for those cases where the means and method of substantiating compliance are well understood and agreed to between Transport Canada and the applicant through previous approval programs.

The format and content of the Certification Plan, identified in sections 5.1 and 5.2 below, should be discussed with Transport Canada. If the applicant is from a delegated organization, these plans should be prepared and/or reviewed by its Delegates prior to submission to Transport Canada. Additional information on the tailoring of Certification Plans prepared for performance and flight characteristic requirements of the AWM is in section 6.0 below.

4.2 Preparation, review, and acceptance of Certification Plans

Preparation, review, and acceptance of Certification Plans may be accomplished using the process shown by the flowchart in Appendix A of this AC, and the following:

(a) Transport Canada, the applicant and Delegates should discuss and agree on which requirements listed in the GCP require Certification Plans, the level of detail to be presented, and the general format of the Certification Plans (i.e., sequential paragraphs versus paragraphs grouped by subject area, etc.).

(b) Transport Canada, the applicant and Delegates should discuss the means and methods of compliance to be used for each requirement. Mutual agreement should be reached on what information is critical to support the finding of compliance and should be contained in the Certification Plan.

(c) he applicant and Delegates prepare the Certification Plan for each requirement, applicable to their functional specialty, to document the agreement reached in paragraph (b) above, using the information on content and format provided in section 6.0 below.

(d) The applicant and Delegates should define what compliance documentation, data and testing will be required to support the agreed means and methods of compliance from paragraph (b) above.

(e) The applicant and Delegates should develop a certification activity schedule for all documentation and data, and test activities where there is Delegate or Transport Canada participation identified in paragraphs (b) and (f).

(f) The applicant shall provide Transport Canada with a copy of the draft Certification Plan and coordinate Certification Plan meetings as required with Transport Canada to review and discuss the plans. The draft Certification Plan may evolve through several subsequent meetings and throughout the life of the project.

(g) Transport Canada should determine the level of delegation to be granted to the applicant's Delegates (if applicable) for each requirement, and shall specify Transport Canada's level of involvement in the defined documentation, data, or testing identified in paragraph (d) above. At this point, it is recommended that the applicant and the Delegates review the GCP to ensure it is consistent with the Certification Plan content. The expectation is that by the Initial Type Board the specialists should have prepared draft Certification Plans and reached agreement on the content.

(h) Once agreement is reached on Certification Plan content, the applicant and Delegates shall revise the plan to reflect all agreed to changes to date, and provide it under cover letter to Transport Canada for acceptance. The cover letter will signify that the applicant's internal management agree with the Certification Plan contents. Transport Canada will respond by letter from the Project Management Division in Headquarters (HQ), or the responsible Regional Aircraft Certification office to indicate agreement with the Certification Plan at the appropriate revision status.

(i) he applicant, Delegates and Transport Canada shall periodically review the Certification Plan and update the content and schedules as appropriate to reflect changes in agreement or technical direction that may occur. Changes should be identified to Transport Canada for concurrence if the applicant or Delegates make them.

5.0 Format and Content

5.1 Essential elements

There is no mandatory presentation format for Certification Plans; however, Appendix B provides a simplified example for illustration purposes. Regardless of the appearance or format selected by the applicant, a useful Certification Plan contains five essential elements:

(a) Identification of the requirement or group of requirements being addressed. Normally Certification Plans are developed for each requirement, or each group of requirements (by subject or specialty) applicable to the aeronautical product under consideration. For example, if one grouped AWM Chapter 525, Subchapter C - Structure requirements into a single Certification Plan it could be done sequentially by requirement, in groups (i.e., flight loads), or grouped by major components (i.e., landing gear);

(b) A detailed explanation of the means and methods that will be used to demonstrate compliance;

(c) A record of delegation identifying whether the finding of compliance, and approval or recommendation for approval of data substantiating compliance to the requirement, has been delegated or has been retained by Transport Canada;

(d) Clear definition of the activities and documentation and data that will demonstrate compliance to the requirement; and

(e) Clear identification of Transport Canada's and the Delegate's level of involvement, and the level of delegation to the applicants Delegates.

5.2 Content of a Certification Plan

The following provides an applicant with a more detailed explanation of the content of a Certification Plan:

(a) The applicable requirement or set of requirements shall be identified;

(b) The full requirement title shall be quoted. The full wording of the requirement should be presented to reduce misunderstanding of the content and to eliminate cross-reference to other documents, such as the GCP (i.e., the Certification Plan, although cross referenced on the GCP, shall be a self-explanatory stand alone document whose content is compatible with the information in the GCP);

(c) The description of the means of compliance should explain the means by which compliance will be demonstrated, which should be fully spelled out (i.e., Flight Test, not FT), so that there is no potential for ambiguity (i.e., is FT flight test or functional test?). This is a repeat of what is documented in the GCP which typically uses codes that denote analysis, test, flight test, ground test, inspection, drawing review, or other agreed terminology. If multiple means are required to demonstrate compliance, then each specific means will be documented;

(d) The detailed method of compliance used to show compliance will be an expansion of the information contained in the GCP. The level of detail to be presented for the method of compliance should be discussed between Transport Canada and the applicant, and should consider and document in the Certification Plan when required, the following:

(i) The specific (or worst case) conditions required to demonstrate compliance;

(ii) Any critical assumptions used;

(iii) The pass/fail criteria (applicable normally to "Test" as a means of compliance);

(iv) An explanation of what specific levels of performance a system or component must attain to be in compliance; and

(v) Any other information considered important when describing how compliance is to be demonstrated.

Note:

Historically, the means of demonstrating compliance for Flight Test airworthiness requirements have been documented in the form of Test Definition Sheets (TDSs). The TDS describes in detail the means of compliance test methods and conditions, however, they are typically not ready in a time comparable to the Certification Plan. Recognizing that the TDS will provide a similar level of detail for the flight test airworthiness requirements as would be in a Certification Plan, and that Transport Canada Flight Test specialists will review the TDS in detail, it would be acceptable to use the TDS in place of the Certification Plan.

(e) The applicant shall provide a full list of documents, data, and tests that will be used to demonstrate compliance with the requirement or group of requirements. This list shall include any activity to be completed (i.e., performance of a test) or any document to be prepared or in place (i.e., test report, compliance report, test plan, etc.);

(f) The applicant may elect to include a schedule associated with the documents, data, or tests identified in subparagraph (v) above, to monitor for potential resource and schedule conflicts. It is the applicant's responsibility to periodically review and revise the schedules to make sure that they remain current and that any conflicts are resolved in a timely manner. If the applicant wishes, and Transport Canada agrees, the scheduling information may be provided in a separate document to simplify schedule planning and upkeep. If a separate document is used, a reference should be put in the Certification Plan to point to the document where the schedule information can be found;

(g) The agreed level of delegation for each requirement or group of requirements shall be documented and clearly identify any stipulations, coordination requirements, or limitations placed on that delegation. This level of delegation will identify whether the finding of compliance, and approval or recommendation for approval of data substantiating compliance to the specific requirement, has been delegated to the applicant, or whether it has been retained by Transport Canada. If delegated to the applicant, the finding of compliance and approval of data is typically signified by the responsible Delegate signing or initialing against the requirement in the GCP. If not delegated, the responsible Delegate shall still sign or initial the GCP, but in this case as a recommendation for data approval. As far as the Certification Plan is concerned, a simple "Delegated, Yes/No" check box or equivalent adjacent to the specific requirement is all that is normally required to specify the agreed level of delegation;

(h) The level of involvement of Transport Canada, the applicant, and Delegates is defined for each of the documents, data, or tests identified in paragraph (e) above, and this level of involvement shall be clearly recorded in the Certification Plan. This portion of the Certification Plan becomes the agreement between Transport Canada, the applicant, and the Delegate(s) on those activities the Transport Canada specialists and Delegate(s) shall complete before a finding of compliance can be made against the requirement. As such, the level of involvement describes a list of documents and data, as well as defining the work to be completed by Transport Canada and the Delegate(s) for each requirement; and

(i) The level of involvement can be depicted in a "matrix format" as shown by the example in Appendix B of this AC. Each activity, such as the conduct of a test, completion of a report or assembling of data is listed. Transport Canada's and the Delegates' levels of involvement for each document, data or test can then be shown next to the activity. The example in Appendix A of this AC shows that even though the finding of compliance, and approval of the associated data used in substantiating compliance has been delegated, Transport Canada has decided to retain involvement in some activities, including review and acceptance of Test Plan #13 and #14, Rig Test witnessing, and review and acceptance of Report 6A. This example illustrates that Transport Canada can still maintain involvement in activities leading to the finding of compliance where desired or required, but not have to make the actual finding. The level of detail that can be presented for each requirement using a level of involvement matrix ensures that Transport Canada, the applicant, and the Delegate(s) understand their respective expectations and obligations.6.0

6.0 Flight Test Considerations

For the performance and flight characteristics requirements of Subchapter B of AWM Chapter 5XX (i.e., 523, 523-VLA, 525, 527, and 529), the means of compliance is always a combination of flight test and analysis. The required flight tests change very little from program to program and the discussions which take place are normally at too detailed a level to be facilitated using a certification plan. Level of involvement is similarly discussed at the flight test point level (i.e., which specific test points is Transport Canada going to fly?).

6.1 Test Pilot Assessments for Subchapter B Requirements

For requirements of Subchapter B of AWM Chapter 5XX (i.e., 523, 523-VLA, 525, 527, and 529), to minimize the effort both to produce and to review the certification plans, it is acceptable to provide a reduced level of detail in the Certification Plan which could comprise:

(a) The requirement;

(b) A reference to associated advisory material, such as ACs, Joint Aviation Authorities (JAA) Advisory Circulars (ACJs), or specific paragraphs in system specific Advisory Circulars (ACs);

(c) The specialty (Flight Analyst - Performance, Flight Analyst - Flight Characteristics, Test Pilot, or Systems Specialist);

(d) Level of Delegation;

(e) Report, Test Plan, and/or detailed test definition document listing, if desired; and

(f) Transport Canada Flight Test level of involvement is normally defined by a standard list of certification test points and is specified in detail in the detailed test definition documents. Only if there are exceptions to the normal Transport Canada flight test program would Transport Canada's level of involvement be discussed in the Certification Plan.

This same format has been used for GCP's in the past except for the possible reference to level of involvement.

Exceptions to this simplified format may be advantageous when a non-standard situation exists because, for example, there has been a rule change, the manufacturer desires to use derivative data from a previous model, or it is proposed to use a means of compliance not listed in AC 25-7, 23-8, or paragraphs in ACs 29-2 or 27-1 dealing with flight tests. In this case the Certification Plan could be of use in obtaining early agreement for the general approach to substantiation of compliance.

6.2 Test Pilot Assessments for Non-Subchapter B Requirements

Currently, no means have been proposed to capture qualitative flight test aspects of the other subchapters, which may be documented in Certification Plans covering other disciplines. Given that it is impractical for the Flight Test Division to review Certification Plans for all disciplines in an attempt to pick out the flight test aspects, there is a need for a Certification Plan that summarises the proposed Non-Subchapter B flight tests in a format that can be reviewed with an acceptable level of effort. This Certification Plan should only include those tests that require a Test Pilot finding of compliance resulting from a subjective assessment of:

(a) Level of skill;

(b) Consistent operation;

(d) Crew procedures;

(e) Crew workload;

(f) Inadvertent operation;

(g) Continued safe flight and landing; or

(h) Any other design feature requiring pilot judgement.

The preferred format of this listing would be by Air Transport Association (ATA) chapter numbering so that tests appropriate to any particular system could be easily located.

7.0 Headquarters contact

For more information please contact:

Policy Standards Coordinator (AARDH/P)
Phone: (613) 990-3923
Facsimile: (613) 996-9178
E-mail: AARDH-P@tc.gc.ca

Original signed by Maher Khouzam

M. Khouzam
Chief, Regulatory Standards
Aircraft Certification Branch

Appendix A - Certification Plan Development Process Flowchart
Appendix B - Certification Plan Example

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