Aircraft Certification Policy Letter (ACPL)

ACPL No.: 16
Issue No.:  1
Issue Date:  2000-12-05
AARD File:  5009-0-16

Aircraft Certification Policy Letter (ACPL)

Subject: Installation of Complex or Integrated Avionics Equipment on General Aviation Aircraft

1.0 Purpose

The purpose of this ACPL is to provide Aircraft Certification personnel and delegates, and Maintenance and Manufacturing (M&M) personnel with general information and procedural guidelines associated with the installation approval of complex or integrated avionics equipment.


For the purpose of this ACPL, the following clarification is provided:

  1. A system is considered complex when its operation, failure modes, or failure effects are difficult to comprehend without the aid of analytical methods. Failure Modes and Effects analysis (FMEA) is an example of such methods.

  2. Typically, integrated avionics systems means the integration of units of multiple independent functionality in a single hardware or software unit.

  3. Various navigation sensors and displays, various communication systems, and a combination of communication and navigation systems, with or without moving map displays etc., are examples of such equipment and systems.

  4. The classification level of the associated software will depend on the ramifications likely to result from a system failure.

2.0 Reference Documents

  1. Canadian Aviation Regulations (CAR), Part V, Subpart 13, Division II - Canadian Changes to Type Design, section 513.07 - Applicable Standards;
  2. Aircraft Certification Staff Instruction (ACSI) No. 22 - Approval Procedures - Domestic Design Changes; and
  3. FAA Advisory Circular (AC) 23.1309-1C - Equipment, Systems, and Installations in Part 23 Airplanes.

3.0 Background

The advancement of avionics systems has evolved in a level of installation complexity which was not prevalent for General Aviation Aircraft originally type certificated to the former Civil Air Regulations (CAR) 3 and Federal Aviation Regulation (FAR) Part 23 standards, up to Amendment 23-40. Amendment 23-41 dated October 26, 1990 provides additional type certification requirements. It also introduced additional requirements for the identification of such systems and related equipment, and their installation on aircraft.

4.0 Policy

4.1 The installation guidelines contained in this ACPL apply to aeroplanes type certificated to CAR 3/FAR Part 23 (pre-amendment 23-41)/AWM Chapter 523 standards; and rotorcraft type certificated to the former Civil Air Regulations (CAR) 6/FAR Part 27/AWM Chapter 527 standards.

4.2 The additional requirements outlined in FAR Part 23, Amendment 23-41 pertaining to General Aviation Aeroplanes may also be applied to rotorcraft type certificated to CAR 6/FAR Part 27 standards, notwithstanding the fact that Amendment 27-21 dated November 6, 1984 to FAR Part 27, section 27.1309 did not address such requirements for rotorcraft. Compliance with such requirements may be mandated through the issuance of Special Conditions, Airworthiness (SCA).

4.3 The installation of integrated or complex avionics equipment on aeroplanes/aircraft type certificated to CAR 3/FAR Part 23 and CAR 6/FAR Part 27 standards should be evaluated to determine if additional airworthiness requirements as outlined in paragraph 5.0 below need to be applied.

5.0 Additional Airworthiness Requirements

5.1 A Functional Hazard Analysis (FHA) is to be completed by the applicant in accordance with the guidance provided in FAA AC 23.1309-1C, with details to be submitted to TCCA along with the STC application. The applicant may have to obtain Failure Modes and Effects Analysis (FMEA) data from the Avionics Manufacturer in order to complete a quantitative analysis of the installation.


A quantitative analysis is often used for Catastrophic or Hazardous Failure Conditions of systems that are complex, where service experience is insufficient to substantiate their safety, or for systems that have attributes/characteristics that differ significantly from those applicable to conventional systems.

5.2 The FHA shall address the probability of providing misleading information including loss of failure annunciation to the pilot. Refer to FAA AC 23.1309-1C for details.

5.3 In relation to the use of previously developed software, additional considerations concerning the software certification aspects shall be taken into account. Refer to FAA AC 23.1309-1C for details.

6.0 Termination

This ACPL will be cancelled upon the publication of a pertinent Airworthiness Manual Advisory (AMA) on the subject matter.

Original signed by:

K. J. Mansfield
Director, Aircraft Certification


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