Avionics News October 2015 - 16

INTERNATIONAL NEWS
Continued from page 15

CANADA

News & Regulatory Updates
Transport Canada publishes advanced
NPA for change to the type design of
an aeronautical product
Transport Canada Civil Aviation has been working on a
revision to CAR 521 since 2010 with several consultations,
both internal and external. Due to many other governmental priorities, the authority has not been able to progress as
quickly as it would like. In the last several months, it has
been preparing an NPA based on all the feedback received.
An advanced NPA to revise CAR 521 was issued in July
2015, covering 10 issues that were identified during this
period:
1. Clarification of terminology and administrative text
changes.
2. Alternate method of data approval.
3. Definition of threshold for a major design change to
CAN-TSO articles.
4. Issuance of special conditions-airworthiness for an
auxiliary power unit.
5. Clarification regarding requirements associated
with reporting and investigation of service difficulty
reporting.
6. Clarification on part design approvals requirements.
7. Addition of early ETOPS as an optional approval
granted as part of a type certification for transport
category aeroplanes.
8. Expansion in applicability for a flight test operations
manual.
9. Addition of requirements for function and reliability
test flights to normal category turbojets.
10. Clarification regarding requirements associated with
validation and acceptance of foreign approvals.
In total, there are 90 proposals for changes to the text of
CAR 521. In most cases, there are changes to the wording to provide better clarification to the intent, such as
changing conformity to compliance and the reintroduction
of major and minor design change terminology. In all the
revisions, there are three significant proposed changes that
may affect the modification business.
One proposal is to revise 521.154, which covers minor
design changes, to remove the applicability to design
approval holders and to include wording that it indicates
minor changes may be approved with procedures accept16

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2015

able to the minister. The wording, as such, seems to indicate all minor changes regardless of who does them needs
to be completed by this method. It may be in conflict with
AWM 571.06, which states that minor changes can be
completed by anyone using acceptable data. The intent of
the acceptable data was to allow those in the field to make
the determination on what was acceptable.
Additionally, the revision is meant to clear up the issue
with respect to a delegate being able to approve a minor
change. The intent is to make it clear that anyone who
has acceptable procedures for minor changes can produce data that meets the definition of "acceptable data."
However, the current proposed wording may have unintended consequences and further restrict a modification
shop from carrying out minor modifications. This would
further affect Canadian shops with respect to competing
with U.S. shops. One of the overall goals of the TCCA
has been to provide a vehicle that would even the playing
field between Canadian and U.S. shops.
Currently, there are specific documents identified as
acceptable to be used to identify an approved design. The
proposal in this NPA is to allow for other forms to be
used to approve major design changes. Currently, CAR
521 only identifies a type certificate, STC, RDA and
TSO approval. This revision would allow delegates to
create procedures and a document that would identify an
approved major design change, thereby opening the door
to "one-off approvals" as was done 20 years ago.
The final significant change is for the definition and
requirements of a certification plan. The current wording is restrictive in the sense that it implies the applicant
would have a complete product and definition of the product at the time of application, when in reality throughout
the program several changes are made. The intent is to
better define what a certification plan really is intended to
do. It recognizes the fact that compliance is not yet demonstrated and all the details may not be known at the time
of application. However, it is trying to implement requirements so that the applications are made at an advanced
stage of the program.
The plan with this advanced NPA is to gather comments up to Sept. 26, 2015, and then carry out face-toface meetings. Also, all comments made during the NPA
process will be provided to the CARAC members for
review. A final NPA will be drafted for acceptance by
CARAC, although no proposed date has been set.
You can review the advanced NPA at: http://
wwwapps.tc.gc.ca/Saf-Sec-Sur/2/npa-apm/actr.
aspx?id=9&aType=1&lang=eng.
Please provide comments and concerns to the AEA by
contacting Kevin Bruce, the AEA's regulatory consultant for
Canada, at kevinb@aea.net.

http://wwwapps.tc.gc.ca/Saf-Sec-Sur/2/npa-apm/actr.aspx?id=9&aType=1&lang=eng http://wwwapps.tc.gc.ca/Saf-Sec-Sur/2/npa-apm/actr.aspx?id=9&aType=1&lang=eng

Table of Contents for the Digital Edition of Avionics News October 2015