ED Decision 2023/013/R
COMPLIANCE-DEMONSTRATION PLAN FOR A MAJOR CHANGE
The compliance-demonstration plan for a major change is a document that allows the declarant to manage and control the design of the major change, as well as the process of compliance demonstration, and that enables EASA to investigate the root cause(s) in the event of a safety issue being discovered.
The description of the change should include an explanation of the purpose of the change, the pre-modification and post-modification configuration(s) of the aircraft, schematics/pictures, and any other detailed features and boundaries of the physical change (this may be supplemented by drawings or outlines of the design, if this helps to understand the design change), as well as the identification of the changes in areas of the aircraft that are functionally affected by the change, and the identification of any changes to the approved manuals.
The items of the declaration of aircraft design compliance made in accordance with Subpart C that are affected by the change and for which a new demonstration of compliance is necessary should be identified together with the means (e.g. calculation, test or analysis) by which it is proposed to demonstrate compliance.
The compliance demonstration should include the analysis for the classification of the change in accordance with GM1 21L.A.103.
In particular, the following information should typically be expected:
— identification of the relevant personnel that make decisions affecting airworthiness and environmental compatibility, and that will interface with EASA during any physical inspection and assessment of the changed product if required under point 21L.B.121(b);
— subcontracting arrangements for design, environmental compatibility and/or production (if applicable).
Point 21L.A.107(d)(1) ‘Description of the major change’
An overview of the:
— architecture, functions, systems;
— dimensions, design weights, payloads, design speeds;
— engines and power/thrust rating;
— materials and technologies;
— cabin configuration aspects;
— options (e.g. weight variants, power/thrust rating variants, optional avionics equipment items, brake options, tyre options, floats, skids).
Point 21L.A.107(d)(2) ‘Operating characteristics, design features and limitations’
— operating speed limitations;
— service ceiling, maximum airfield elevation;
— cabin pressure;
— limit load factors;
— number of passengers, minimum crew, payload, range;
— weight and centre-of-gravity (CG) envelope and fuel loading;
— performance;
— environmental envelope;
— runway surface conditions;
— other items, if considered to be more appropriate, which address the specific aeronautical product.
The declarant should provide detailed information about the means of compliance with the applicable requirements identified under point 21L.A.107(a). This should include the following:
— a compliance checklist addressing each requirement, the proposed means of compliance (see Appendix A to AMC1 21L.A.107(a) below for the relevant codes), and the related compliance document(s);
— identification of industry standards, methodology documents, handbooks and any other acceptable means of compliance, specified in the airworthiness or noise data sheet, which have been followed in the demonstration of compliance;
— when the compliance demonstration involves testing, a description of the ground- and flight-test article(s), test method(s), test location(s), test schedule, test house(s), test conditions (e.g. limit load, ultimate load), as well as of the intent/objective(s) of the testing; and
— when the compliance demonstration involves analyses/calculations, a description/ identification of the tools (e.g. name and version/release of the software programs) and methods used, the associated assumptions, limitations and/or conditions, as well as of the intended use and purpose.
For every aspect mentioned above, the declarant should clearly identify whether the demonstration of compliance involves different means than those contained in the published AMC to the relevant CSs and any method (analysis or test) which is novel or unusual for the declarant.
For every aspect related to compliance with the applicable environmental protection requirements mentioned above, the declarant should clearly identify whether the demonstration of compliance involves means that are described in ICAO Doc 9501 ‘Environmental Technical Manual’.
AMC1 21L.A.108(a) outlines the compliance-demonstration plan for major changes, covering change description, affected declaration items, compliance means, personnel, subcontracting, and detailed compliance documentation.
* Summary by Aviation.Bot - Always consult the original document for the most accurate information.
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