Policy Letter (PL)

Appendix A - Aircraft Certification Levels of Service

Timely completion of Transport Canada documentation review is dependent on the quality of documentation submitted. Please refer to Appendix C for information on level of service variables and priorities. These levels of service assume the involvement of an Aircraft Certification delegate.

The following tables identify levels of service for an approval under Chapter 513 of the AWM (Table A-1), an FAA Letter of Technical Standard Order (TSO) Design Approval (Table A-2) or a minor design change to an FAA TSO'd part or appliance (Table A-3).

Table A-1: Levels of Service for an Approval Under Chapter 513 of the AWM

Activity	Prerequisites	Time (Business Days)
Allocation of National Aeronautical Product Approval Information System (NAPA) number.	Receipt of completed Design Change Approval Application Form 26-0469.	2
Issue of approval number to delegate.	Allocation of a NAPA number. Receipt of request from delegate for issuance of number. Acceptance of certification plan.	21
Issue of extension of delegation of authority or level of involvement.	Allocation of a NAPA number. Receipt of an acceptable certification plan excerpt outlining proposed methods of compliance and level of involvement.	2
Review of project specific certification plan.	Allocation of a NAPA number.	10
Review of test plan.	Allocation of NAPA number. Acceptance of Certification Plan. Receipt of test plan	10
Scheduling of Transport Canada conformity inspection.	Allocation of NAPA number. Receipt of conformity inspection request and applicant's conformity report (per AN B043). Receipt of drawing package. Receipt of details as to availability of test article/aircraft and completion of applicant's conformity inspection	52
Issuance of a FAA project number to permit use of FAA Designees.	Allocation of a NAPA number. Receipt of an acceptable certification plan excerpt outlining proposed methods of compliance and level of involvement. Receipt of corresponding technical documentation.	153
Recommendation for the issuance of a (test) flight permit.	Receipt of recommendation from delegate or applicant.	5
Review of the Submitted certification package - Evaluation of the data provided, and response to the client. Approval of Flight Manual Supplement and Airworthiness Limitation, acceptance of Instructions for Continued Airworthiness.	Allocation of a NAPA number. Receipt of satisfactory document. Acceptance of a certification plan Receipt of completed Statement of Compliance on Form AE-100.	654, 5
Issuance of STC or PDA (no Transport Canada level of involvement).	Allocation of a NAPA number. Acceptance of a fully delegated project specific certification plan Receipt of draft certificate. Receipt of completed Statement of Compliance on Form AE-100. Satisfactory audit of documentation package.	2
TCCA submission of application for FAA STC to the New York Aircraft Certification Office.	Issuance of Transport Canada STC or LSTC. Receipt of completed FAA Form 8110-12 and supporting documentation from the applicant	156
Transmittal of FAA STC to Canadian Holder.	Receipt of FAA STC.	2
Recommend alternative means of compliance (AMOC), or revision to an AMOC for an airworthiness directive.	Receipt of request and substantiation from applicant.	5

Notes for Table A-1:

1. When an approval number is requested at the same time as the allocation of a NAPA number, this activity may take place concurrently with the allocation of the NAPA number.
    
2. This only relates to the scheduling of the date of the inspection. The actual date of the inspection will depend upon availability of staff and other factors.
    
3. Correspondence with the FAA indicates that two (2) weeks must be allowed for the FAA to process any request.
    
4. Instructions for Continued Airworthiness (ICAs) require co-ordination with the Aircraft Maintenance and Manufacturing Branch.
    
5. Some Flight Manual Supplements require co-ordination with the Flight Test Division in Headquarters.
    
6. A response from the FAA on the status of the design approval can be expected within 10 business days. The time required for completion of the design approval depends on the complexity of the project, quality and coordination of the ICA's and completeness of the package submitted.

Table A-2: Levels of Service for an FAA Letter of TSO Design Approval

Activity	Prerequisites	Time (Business Days)
Allocation of NAPA number.	Receipt of initial application, certification plan and request for deviation where expected.	2
TC review of initial application, certification plan and equipment design specification. Deviations with pertinent data.	Allocation of a NAPA number. Receipt of initial application, certification plan, equipment design specification and any deviation requests (pertinent data required).	121
Initial type board meeting.	Allocation of a NAPA number. Receipt of initial application, certification plan, equipment design specification and any deviation requests (pertinent data required).	1
Identify Minister's level of involvement or issue of extension of delegation of authority.	Allocation of a NAPA number. Receipt of initial application, certification plan, equipment design specification and any deviation requests (pertinent data required). Excerpt outlining proposed methods of compliance and Minister's level of involvement is identified.	2
TC review and acceptance of compliance program.	Allocation of a NAPA number. Receipt of initial application, certification plan, equipment design specification and any deviation requests (pertinent data required). Excerpt outlining proposed methods of compliance and Minister's level of involvement is identified.	12
Scheduling of TC conformity inspection.	Allocation of a NAPA number. Receipt of initial application, certification plan, equipment design specification and any deviation requests (pertinent data required). Receipt of compliance program. Receipt of conformity inspection request and applicant's conformity report per AN No. B043. Receipt of drawing package. Receipt of details as to availability of the test article and completion of applicant's conformity inspection	52
Review of submitted certification package. Evaluation of the data provided and response to the applicant. TC letter to the FAA for Letter of TSO Design Approval with copy to applicant.	TC inspection conformity complete and accepted with notification to the TC regional project engineer Satisfactory completion of equipment qualification tests (assuming all test witnessing has been delegated) Complete data package submitted to TC for review with request for submission to the FAA for issuance of a Letter of TSO Design Approval Receipt of completed statement of compliance on TC Form AE-100 Satisfactory audit of documentation package.	35

Notes for Table A-2:

1. For a deviation request, a letter requesting the deviation is sent to the FAA with pertinent data supporting the request and a copy is sent to the applicant.
    
2. This only relates to the scheduling of the date of the inspection. The actual date of the inspection will depend upon availability of TC staff and other factors.
    
3. The FAA will issue or deny the application within 30 days after its receipt or, if additional information has been requested, within 30 days after receiving that information., as per FAR 21.605 (e)
    
4. The definitions of Major versus Minor are as per FAA FAR 21.611.

Table A-3: Levels of Service for a Minor Design Change to an FAA TSO'd Part or Appliance

Activity	Prerequisites	Time (Business Days)
Allocation of NAPA number.	Receipt of initial application. Receipt of completed statement of compliance on TC Form AE-100. Receipt of engineering change evaluation substantiating the minor change application. Substantiation package of revised data and documentation submitted to TC along with a list of changes to the TSO'd part or appliance with a request for submittal of a minor change notification letter to the FAA.	2
Review of submitted certification substantiation package. Evaluation of the data provided and response to the applicant. TC minor change notification letter to the FAA with a listing of changes to the TSO'd part or appliance with a copy to the applicant.	Satisfactory completion of equipment qualification tests (assuming all test witnessing has been delegated). Receipt of completed statement of compliance on TC Form AE-100. Substantiation package of revised data and documentation submitted to TC along with a list of changes to the TSO'd part or appliance with a request for submittal of a minor change notification letter to the FAA. Satisfactory audit of documentation package.	20

Appendix B - Historical Aicraft Certification Project Completion Times

Service	Calendar days for project completion (80 %)1, 2, 3	Historical Data: Maximum Project Completion Times 3
Supplemental Type Certificate (STC)	149	1020
Limited Supplemental Type Certificate (LSTC)	84	656
Repair Design Certificate (RDC)	65	438
Part Design Approval (PDA)	217	412

Notes:

1. 80% of projects fall within this duration.
    
2. 20% of all projects extend beyond this time, some significantly due to a wide variety of factors generally associated with the administrative and technical complexity of a project, availability of Transport Canada staff and delegates, and the pace at which the client progresses through the certification process. Reference Appendix C for a more detailed explanation of the factors influencing project duration.
    
3. Each of the durations listed are overall project times, that is, including time waiting for Transport Canada data review, client data and follow-up submission time, and time associated with the factors outlined in Appendix C.

Appendix C - Levels of Service Variables and Priorities

C.1 Variables

In general, certification projects are managed in accordance with a certification plan agreed between Transport Canada and the applicant (reference AC 500-15).

The time required for the certification of an aeronautical product is a function of the technical and administrative complexity of the design project. For example, the following are some of the variables that influence project duration:

1. The quality and volume of required project documentation submitted to Transport Canada;
    
2. The number of parties involved (other regions, regulatory authorities, contractors and sub-contractors, etc.);
    
3. The time of year;
    
4. Novel and unusual designs elements in the product; and
    
5. Unplanned design changes.

Aircraft Certification has, on occasion, received data presented as "final", for a design that is still in the developmental stage. This preliminary presentation of data results in delays due to changing design, added conformity verifications and deviations, failed certification tests, and incomplete test reports.

While Transport Canada Aircraft Certification Engineers will advise on interpretation of standards, they cannot be expected to advise on design concept, or to find compliance prior to design completion. Therefore, the following criteria are to be applied in planning certification programs:

1. Every effort should be made to provide Transport Canada with advance notice of impending certification programs, and to complete development testing prior to beginning Transport Canada certification phase of a design project.
    
2. Acquiring the early support of a qualified Transport Canada delegate is encouraged. Projects submitted without delegate support will receive the lowest priority as noted below.
    
3. Certificate applicants must consider that in advance of certification tests requiring Transport Canada witnessing, test plans must be provided and be approved, and conformity must completed in accordance with AN No. B043 prior to the conduct of the Transport Canada conformity and certification tests.

C.2 Assignment of Project Priority

Within the following categories, projects will be reviewed on a first-come, first-served basis:

1. Transport Canada delegates authority to external delegates to more effectively use available resources. Priority is therefore given to projects prepared by a delegate, followed by those prepared by professional engineers who have relevant experience.
    
2. Given the potential significant impact of project delays both on the traveling public, and on employees and employers, projects submitted on behalf of commercial operators (e.g. a repair design approval) will take priority over those submitted on behalf of private operators; however, it is recommended that a Transport Canada delegate be retained in such situations. Private operators can take steps to ensure they receive the quickest possible service by retaining the services of a qualified Transport Canada delegate.

Since a single company may have multiple concurrent projects that could conflict, it is strongly recommended that the company submit a priority list for their certification projects, to assist Transport Canada in providing all clients the best possible service.