Appendix C to GM 21.A.101 A method to determine the changed and affected areas

ED Decision 2017/024/R

C.1     Overview.

C.1.1  When a product is changed, some areas may change physically, while others may change functionally. EASA refers to this combination as changed and affected areas. For example, an extension to the wing of a fixed-wing aircraft would physically change the wing tip and likely other wing structure. Some areas of the airframe may have sufficient strength for the increase in load and would change functionally, i.e. they would carry greater load, but they would not change physically. These areas have associated certification specifications, which become part of the certification basis for the change.

C.1.2  Figure C-1 below provides an overview of one method that applicants may use to determine the changed and affected areas and the applicable certification specifications.

Figure C-1. Method to Determine the Changed and Affected Areas

C.2     Physical Changes.

C.2.1  Steps.

—    Step 1. Make a list of the physical changes.

—    Step 2. List the corresponding certification specifications applicable to the physical changes.

—    Step 3. List the amendment level recorded on the existing certification basis of the baseline product and the amendments on the date of application.

C.2.2  Example.

The change is adding a winglet to a fixed-wing aircraft and a change to the leading-edge slats for a performance increase. As part of the change, an electrically driven slat actuator is modified by changing the mounting structure of the actuator used to connect the actuator to the slat. The actuator structure is changed. The electrical system in the actuator is not affected. The applicant would list certification specifications applicable to the actuator. The applicant would not list the certification specifications applicable to the electrical system of the actuator. See Table C-1 below for an example of how to chart a physical change and the associated certification specifications.

Table C-1. Example of Associating a Physical Change with the Applicable Certification Specifications

* These would be certification specifications related to structural aspects only.

C.3     Functional Changes.

C.3.1  Steps.

—    Step 1. Describe each change.

—    Step 2. Describe the effects of the change (e.g. structural, performance, electrical, etc.).

—    Step 3. List the areas, systems, parts, and appliances that are affected by those effects.

—    Step 4. List the certification specifications associated with the effects for each area, system, part, or appliance.

—    Step 5. List the amendment level recorded on the existing certification basis of the baseline product and the amendments on the date of application.

C.3.2  Example.

The change is adding a winglet to a fixed-wing aircraft and a change to the leading-edge slats for a performance increase. The wing root bending moment has increased. The loads in the wing box are increased but the wing box has sufficient structural margins to carry the higher loads. Thus, the wing box is not physically changed but its function has changed because it carries greater loads. See Table C-2 below for an example of how to chart a functional change, its effects, and the affected areas (steps 1 through 3 above). See Table C-3 below for an example of how to chart an area affected by a functional change and the associated certification specifications (steps 4 and 5 above).

Table C-2. Example of a Functional Change, Affected Areas, and Associated Effects

* There may be other effects as well.

Table C-3. Example of Associating Affected Areas with the Applicable Certification Specifications

* These would be structural certification specifications only. There could be other certification specifications applicable to the wing box. But since the effect is structural, then only the structural certification specifications are applicable.

C.4     Combine the Lists.

C.4.1  EASA typically presents the certification basis for a product by certification specification and not by area. The next step is to combine these two lists. However, since only a portion of the product is being changed, the changed and affected areas of the new certification basis need to be identified. The unchanged area is not required to comply with the certification specifications in effect at the date of application. (See point 21.A.101(b)(2))

C.4.2  When the change is quite extensive, applicants will save time by listing all the certification specifications applicable to the category of product they are certifying. They can use Table C-4 below in the next step where they will identify any other exceptions that they would like EASA to consider.

C.4.3  Example. If we use the examples above for the combined list for the actuator structural changes and the wing box functional change, then the certification basis would be listed as shown in Table C-4 below.

Table C-4. Example of a Combined List of Physical and Functional Changes with Applicable Certification Specifications

* These represent structural certification specifications.