Page 27 - UK Regulation Part 21 Initial Airworthiness Annex I (consolidated) March 2022

PART 21 - INITIAL AIRWORTHINESS (ANNEX I)

so small that it might not be considered in isolation from some other related compliance
demonstration activities or data.
A way of meaningfully grouping compliance demonstration activities and data, for example,
is to select some activities and data and group them into a single CDI, as the certification
programme must already contain the applicable requirements, the proposed means of
compliance for each requirement, as well as the associated compliance documents for
each means of compliance.
Another way to meaningfully group the data is to do it at the level of the technically related
compliance demonstration activities and data. This may facilitate the assessment of those
activities and data against the novelty, complexity, and criticality criteria (see AMC
21.B.100(a) and 21.A.15(b)(6)). The resultant CDI may encompass various means of
compliance.
3. Description of CDIs
Each CDI should be sufficiently described in the certification programme, and should detail
the following:
- the scope of the CDI; and
- the information on the novelty, complexity, and criticality of the item being certified.
However, in cases where the rationale of the assessment is obvious, it is considered to be
sufficient to indicate whether or not a CDI is novel or complex, and whether or not the
impact is critical.
Note: Obvious cases are cases for which the classification is straightforward and does not
require additional clarifications. In general, applicant explanations/notes regarding the
proposed classification should be provided, since this will also facilitate the acceptance of
the LOI proposal. Nevertheless, to avoid unnecessary additional effort, these explanations
can be omitted if they are obvious.
Additionally, it is recommended to identify the CAA panel(s)/discipline(s) affected by each
CDI, as this will support the determination of the novelty, complexity, and criticality, and
finally identify the performance of the design organisation approval (DOA) holder.
21.A.15(c) GM Updates to the certification programme
Point 21.A.15(b) recognises that the initial submission of the certification programme may not be fully
complete, e.g. due to schedule constraints of the design, analysis and testing activities.
Furthermore, even if the initial submission of the certification programme is complete, it may be
necessary to amend it throughout the duration of the project.
The certification programme should be updated and resubmitted to CAA. In particular, updates to the
following elements should be provided:
1. any complementary information that was not included in the initial submission of the
certification programme;
2. any change in the intended use or kind of operations of the product itself, or of the aircraft
on which the product is installed;
3. a change in the key characteristics of the product such as but not limited to any declared
limits that are intended to be recorded in the type certificate data sheet (TCDS);
4. any change in the product design or its characteristics that may affect the criteria used to
assess the likelihood of an unidentified non-compliance with the type-certification basis,
operational suitability data (OSD) certification basis or the environmental protection
requirements, including the potential impact of that non-compliance on product safety or
environmental protection, as defined in 21.A.15(b)(6) and 21.B.100(a)(1) to (4);
Note: An update of the DOA dashboard after the first issuance of the certification
programme only needs to be considered if there is a significant change in the
performance.
5. any change to the initial type-certification basis, OSD certification basis or environmental
protection requirements, as applicable to the product, regardless whether the change is
initiated by the CAA or by the applicant;
6. any change in the breakdown of the certification programme into compliance
demonstration items (CDIs) or in the content of those CDIs;
7. any change in the proposed means of compliance, including its/their methodology;
8. any change in the structure of compliance documents that may affect the determination of
CAA’s level of involvement (LoI), as defined in 21.B.100;
9. any relevant change to the design organisation approval (DOA) holder’s personnel (and
design organisation (DO) suppliers) who are involved in the project; and
10. any changes to the schedule that impact on the CAA LoI.
Following each update to the certification programme as submitted by the applicant, the CAA may
update the determination of its LoI in accordance with 21.B.100(c).
21.A.15(d) GM1 Application for the approval of operational suitability data – MMEL for ELA1 and ELA2
For ELA1 and ELA2, the applicant may develop a list of the required equipment to be included in the
TCDS and/or AFM/POH. This list, in combination with the equipment required for the flight by the
applicable implementing rules for a given type of operations, establishes the list of equipment that
must be operative for all flights. The list of the other installed equipment that may be inoperative
constitutes the MMEL.
21.A.15(d) GM2 Determination of type or variant
The criteria for the determination whether an aircraft with a new type certificate (TC) is considered a
new type or is a variant with reference to another aircraft type from the same TC holder for the
purpose of the specific OSD constituent are provided in the applicable certification specifications for
maintenance certifying staff data, flight crew data and cabin crew data.
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