Staff Instruction (SI) No. 521-004

Changes to the Type Design of an Aeronautical Product

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Issuing Office: Standards Document
SI 521-004
File Classification No.: Z 5000-32 Issue No.: 01
RDIMS No.: 5612291-V49 Effective Date: 2012-03-16


1.1  Purpose

  1. The purpose of this Staff Instruction (SI) is to provide guidance in processing and issuing an approval associated with a change to the type design in accordance with Subpart 521 of the Canadian Aviation Regulations (CARs). This SI is to be used in conjunction with SI 521-005, Supplemental Type Certificates, SI 521-006, Repair Design Approvals and SI 521-007, Part Design Approvals.

1.2  Applicability

  1. This SI applies to all Transport Canada Civil Aviation (TCCA) employees and to individuals and organizations when they are exercising privileges granted to them under an External Ministerial Delegation of Authority.  With respect to delegates, this SI is limited to topics where the delegate is acting on behalf of the Minister.

  2. This information is also available to the aviation industry for information purposes.

1.3  Description of Changes

  1. Not applicable.


2.1  Reference Documents

  1. It is intended that the following reference materials be used in conjunction with this document:

    1. Aeronautics Act (R.S., 1985, c. A-2);

    2. Part I, Subpart 4 of the CARs — Charges;

    3. Part V, Subpart 21 of the CARsApproval of the Type Design or a Change to the Type Design of an Aeronautical Product;

    4. Civil Aviation Directive REG-003—Exemptions from Regulatory Requirements;

    5. Staff Instruction (SI) REG-004—Process for the Assessment of Exemptions from the CARs;

    6. SI 500-004,—Special Conditions-Airworthiness;

    7. SI 500-019,—Issue Papers, Concern Papers and Certification Memoranda;

    8. SI 521-005,—Supplemental Type Certificates;

    9. SI 521-006,—Repair Design Approvals;

    10. SI 521-007,—Part Design Approvals;

    11. Maintenance and Manufacturing Staff Instruction (MSI) 53—Review of Supplemental Instructions for Continued Airworthiness;

    12. Advisory Circular (AC500-015,—Certification Plans;

    13. AC  500-016,—Establishing the Certification Basis of Changed Aeronautical Products;

    14. AC  505-001,—Design Approval Representative Certification;

    15. Policy Letter 500-002,—Establishing the Certification Basis of Changed Aeronautical Products - Interpretation and Policy;

    16. Airworthiness Notice (AN) B043,—Conformity Inspection Associated with Appliance Type Certification or Modification/Repair Approval Projects;

    17. Transport Canada form number 26-0469Design Change Approval Application;

    18. Transport Canada form number 26-0654Notice of Refusal to Issue or Amend a Canadian Aviation Document.

2.2  Cancelled Documents

  1. As of the effective date of this document, the following documents are cancelled:

    1. SI 513-007, Issue 01, 2007-01-15Approval Of Domestic Modification and Repair Designs;

    2. SI 513-008, Issue 01, 2004-10-20Flight Test Division Support of Regional Flight Test Activities.

  2. By default, it is understood that the publication of a new issue of a document automatically renders any earlier issues of the same document null and void.

2.3  Definitions

  1. The following definitions are used in this document:

    1. Aeronautical Product: an aircraft, aircraft engine, aircraft propeller or aircraft appliance or part, or a component part of any of those things, including any computer system and software (Ref. Aeronautics Act R.S.C., 1985 c. A-2 and Section 521.01 of the CARs). This SI does not apply to products approved by a Canadian Technical Standard Order (CAN-TSO) design approval.

    2. Certification Basis: refers to the applicable standards as established in Section 521.157 of the CARs, as appropriate, including any special conditions—airworthiness, findings of equivalent level of safety, and exemptions applicable to the product to be certified.

    3. Certification Plan: a document that clearly identifies the means and methods by which an aeronautical product will be shown to comply with the applicable airworthiness requirements where the airworthiness requirements are identified in the certification basis of the aeronautical product. It is a mandatory document requirement of Sections 521.28 and 521.155 of the CARs. Additional information on certification plans can be found in AC 500-015.

    4. Conformity with the Certification Basis: demonstrating compliance with all of the applicable standards and requirements of the certification basis.

    5. Delegate: any person or class of persons authorized under the authority of Subsection 4.3(1) of the Aeronautics Act to perform functions on behalf of the Minister, subject to the requirements in Chapter 505 of the Airworthiness Manual (AWM).

    6. Finding of Compliance (FOC): A Ministerial determination that the applicant’s compliance demonstration satisfies a requirement specified in the certification basis.

    7. Level of Involvement (LOI): the activities undertaken by TCCA personnel during a product certification activity in performing surveillance of the delegate when the delegate is exercising their delegated authority. Detailed information on LOI can be found in SI 500-003.

    8. Major Change to the type design: an alteration to the type design of an aeronautical product in respect of which a type certificate has been issued that has other than a negligible effect on the weight and centre-of-gravity limits, structural strength, performance, power plant operation, flight characteristics or other qualities affecting its airworthiness or environmental characteristics. This refers to Section 521.152 of the CARs.

    9. Minor Change to the type design: other than a major change to the type design (for the purpose of this SI). This refers to Section 521.154 of the CARs.

    10. National Aeronautical Product Approval system (NAPA): an automated system that provides staff in National Aircraft Certification and the regions with the tools necessary to track the certification of aeronautical products and issue the design approval documents. This system also provides a database of the projects and supporting data for this certification.

    11. Project Manager: the assigned individual within TCCA National Aircraft Certification or the regional office who manages the certification project.

    12. Significant Change: a product level change to the type certificate to the extent that it changes one or more of the following: general configuration; principles of construction; or the assumptions used for the certification criteria, but not to the extent to be considered a substantial change. Not all product level changes are significant. (Ref. AC 500-016).

    13. Standards of Airworthiness: design requirements as defined in the AWM. For design changes, the standards of airworthiness may also be listed on the Type Certificate Data Sheet (TCDS) and may include other standards such as Federal Aviation Regulations (FARs) that form part of the certification basis.

    14. Substantial Change: a product level design change that is so extensive that a substantially complete investigation of compliance with the applicable standards is required, and consequently a new type certificate in accordance with Division II – Type Certificates of Subpart 521 of the CARs, (Ref. AC 500-016).

    15. Type Design:

      1. the drawings and specifications, and a listing of those drawings and specifications that are necessary to define the design features of an aeronautical product in compliance with the standards applicable to the aeronautical product;

      2. the information on dimensions, materials and manufacturing processes that is necessary to define the structural strength of an aeronautical product;

      3. the approved sections of the aircraft flight manual, where required by the applicable standards of airworthiness;

      4. the airworthiness limitations (AWL) section of the instructions for continued airworthiness specified in the applicable chapters of the AWM; and

      5. any other data necessary to allow, by comparison, the determination of the airworthiness and, where applicable, the environmental characteristics of later aeronautical products of the same type or model.

        (Ref: Subpart 101.01(1) of the CARs)


  1. With the implementation of Subpart 521 of the CARs, new documents have been created to support the regulations. All guidance material such as SIs, ACs, and Policy Letters that supported the previous CARs and Chapters 511, 513, 591 and 593 of the Airworthiness Manual (AWM) have been reviewed and the relevant material included in the 521 series ACs and SIs.

  2. Division IV of Subpart 521 of the CARs provides, in detail, the requirements that are common to each of the design approvals addressed in Divisions II Type Certificates, V Supplemental Type Certificates, VI Repair Design Approvals, Division VII Part Design Approvals of Subpart 521 of the CARs, and, as such, is equally applicable.  Because of this, Division IV of Subpart 521 of the CARs is used in conjunction with the other associated Divisions and vice versa.

  3. This SI is organized to mirror Sections and Subsections of Division IV of Subpart 521 of the CARs, so that it can be read in conjunction with Subpart 521 of the CARs.

  4. Although Subpart 521 of the CARs introduced a change in terminology in the English version from “compliance” to “conformity” this SI will be using “compliance” wherever possible to minimize confusion in this document.


    In December 2010, a Notice of Proposed Amendment (NPA) to Subpart 521 of the CARs (NPA 2010-021) was introduced to revert the terminology “conform” and “conformity” back to “comply” and “compliance.”


  1. Division IV is unique within Subpart 521 of the CARs in that it is a generic division that provides the requirements that must be fulfilled to obtain a design approval for a change to an aeronautical product’s type design. It is equally applicable when making a major change to a type design by the type certificate holder from Division II, Type Certificates of subpart 521 of the CARs or by a third party through Division V, Supplemental Type Certificates of subpart 521 of the CARs or restoring an aeronautical product back to its original design - Division VI, Repair Design Approvals of subpart 521 of the CARs or providing a replacement part - Division VII, Part Design Approvals of subpart 521 of the CARs.

  2. Changing the type design of an aeronautical product can be a complex or simple process, therefore the scope of activities will depend on the complexity of the design change.

  3. Once the applicant for the design approval has demonstrated that the changed aeronautical product complies with the applicable certification basis, the Minister will approve the change and issue the appropriate design approval document.

  4. For ease of understanding and from a project management perspective, the requirements and process for obtaining an approval for a change to a type design can be broken down into five (5) phases as shown below. Post certification activities are not discussed here, as they are discussed in Divisions II, V, VI and VII of subpart 521 of the CARs. Organizing the process into these phases facilitates standardized project management milestones and the conduct and integration of work by the applicant’s team and TCCA’s team.  It is not intended that all activities in one phase be completed before work begins on the subsequent phase.

4.1  Pre-application phase

  1. The applicant and TCCA determine which regulations are applicable to the proposed design change and classify the change being considered.

4.2  Phase I: Application and Establishing Certification Basis

  1. This phase identifies the certification approach, planning and strategy which will lead up to the approval of the design change. The primary output is the establishment of the certification basis.

  2. The applicant submits an application for design approval and proposes a certification basis and certification plan. The applicant discusses the project to familiarize TCCA with the conceptual design and general arrangement of the product. TCCA uses the Design Change Approval Checklist to keep the project on track. (See Appendix A). TCCA begins work on the project with the applicant to further define the certification basis and plan.

  3. Once satisfied that all the necessary regulatory and design standard requirements for the product’s type design are included, and a CPR decision record is completed per AC 500-016, the certification basis will be considered to be established by the Minister. This is the certification basis to which the applicant will be required to demonstrate compliance.

4.3  Phase II: Establishing Means of Compliance and Transport Canada Civil Aviation Level of Involvement

  1. The applicant and TCCA agree on a certification plan. It should include a definition of the design change and the agreement on the proposed means and methods of compliance with each requirement of the certification basis, project schedule and the identification of the certification team members who will participate in the compliance demonstration activities throughout the project.   As part of this phase TCCA defines its Level of Involvement (LOI) in the design approval project.

4.4  Phase III: Demonstrate And Record Compliance

  1. In this phase the applicant demonstrates compliance of the product with the certification basis in accordance with the certification plan, and the Minister makes a Finding of Compliance (FOC). As part of this demonstration, the aeronautical product is built/modified and tested, reports are written, compliance documentation is reviewed for acceptability, certification testing begins and the supporting approval documents such as the Aircraft Flight Manual (AFM) and Airworthiness Limitation (AWL) section are drafted. At the end of this phase, the applicant submits a declaration of demonstration of conformity as per section 521.160 of the CARs and the AFM and AWL are approved by Transport TCCA. In addition, TCCA conducts their LOI and declares their LOI complete.

4.5  Phase IV: Approval of a Change To The Type Design

  1. The Minister approves the change to the type design, AWL and AFM, and issues the design approval document.


5.1  General

  1. The pre-application phase consists of activities related to four (4) regulatory sections as illustrated in figure 1 below:
    1. Determining applicability (section 521.151 of the CARs); and

    2. Classifying the design change being considered (section 521.152 through 521.154 of the CARs).

Figure 1 – Pre-application Phase 

Text description

Figure 1 – Pre-application Phase

The pre-application phase consists of activities related to four (4) regulatory sections: Section 521.151 Applications, section 521.152 Change to a Type Design, section 521.153, Change to Type Design Requiring a New Type Certificate, and section 521.154 Change Other than a change to the type design.

5.2  Application - Determining To Whom And What This Division Applies - Section 521.151

  1. Division IV of subpart 521 of the CARs is applicable to:

    1. Design changes for domestic aeronautical products which may be considered major or minor;

    2. Design changes for foreign aeronautical products which may be considered major or minor and which are directed to Division IV from Division XI of Subpart 521 of the CARs;

    3. Existing holders of design approval documents who intend to make a change to the type design of their aeronautical product; and

    4. Applicants for an approval of a change to the type design of an aeronautical product when they are directed to Division IV from another Division of Subpart 521 of the CARs, i.e.: Division II for Type Certificates, Division V for Supplemental Type Certificates, Division VI for Repair Design Approvals, and VII for Part Design Approvals.

  2. A person acting as the applicant’s representative may undertake the actions and requirements of the applicant. However, such arrangement in no way relieves the applicant of their responsibilities and obligations to comply with the CARs.

  3. It should be noted that there are no eligibility requirements for applicants under Division IV of subpart 521 of the CARs as found in other Divisions because:

    1. In the case of existing holders of design approval documents, such as a type certificate holder, they have already committed to carry out their responsibilities as a design approval document holder under Division VIII of the CARs. One of these responsibilities refers to maintaining technical capability, which is the same as eligibility requirements.

    2. In the case of persons other than the original design approval document holder, they must meet the same eligibility requirements described in the respective Divisions II, V, VI and VII of subpart 521 of the CARs.

5.3  Classifying The Design Change

  1. The classification of the change is considered in accordance with Sections 521.152 through 521.154 of the CARs.  There are provisions within these sections to deal with changes that are out of the scope of the requirements of the division, such as those changes requiring a new type certificate.

  2. Sections 521.152 through 521.154 of the CARs can be viewed as a roadmap guiding the applicant to the requirements that apply for the design changes being considered.

  3. The following figures may be helpful in understanding how to determine which Section applies in each individual case.  Use them in conjunction with paragraphs 5.4 through 5.6 of this SI.

Figure 2 – Overview of Section 521.152 of the CARs – Changes to a Type Design 

Text description

Overview of Section 521.152 of the CARs – Changes to a Type Design

A change in a Type Design can be processed in one of three ways:

  • if the proposed change is substantial, it is processed in accordance to section 521.153, Change to Type Design Requiring a New Type Certificate

  • if the proposed change is major, it is processed in accordance to section 521.155, Application for approval of a change to the type design

  • if the proposed change is minor, it is processed in accordance to section 521.154, change other than a change to the type design.

5.4  Change To A Type Design – Classifying The Design Change - Section 521.152

  1. A change to a type design can be processed in one of the following three ways:

    1. If the proposed change is determined to be a substantial change, the change is processed in accordance with Section 521.153 of the CARs requiring the applicant to apply for a new type certificate under Division II of subpart 521 of the CARs.  Refer to section 5.5 of this SI.

    2. If the proposed change is determined to be aminor change to a design approved under an existing approval document, the design approval document holder processes the change in accordance with Section 521.154 of the CARs. Refer to section 5.6 of this SI.

    3. If the proposed change is determined to be a major change to a design approval under an existing approval document, the design approval document holder processes the change in accordance with Sections 521.155 to 521.160 of the CARs. Refer to section 6.0 of this SI.  This will result in the possible issuance of an Supplemental Type Certificates (refer to SI 521-005), an Repair Design Approvals (refer to SI 521-006) or a Part Design Approvals (refer to SI 521-007).

Figure 3 – Classifying the Design Change

Text description

Figure 3 – Classifying the Design Change

  • Design change under consideration
  • Is the proposed change considered to be major?
    • No?
      • Existing design approval document holder could approve per CAR 521.154
    • Yes?
      • Is the proposed change considered to be Substantial?
        • Yes?
          • Requires a new type certificate per CAR 521.153 and Division II
        • No?
          • Requires an application per CAR 521.155
          • Approval of Design change per CAR 521.161 which results in one of three situations:
            • Issue new or revised supplemental type certificate per CAR 521.206
            • Issue new of revised repair design approval per CAR 521.256
            • Issue new or revised part design approval per CAR 521.306

5.5  “Substantial” Changes to a Type Design Requiring a New Type Certificate – Section 521.153

  1. Section 521.153 of the CARs requires that an applicant obtain a new type certificate if the scope and nature of the proposed change in design, configuration, power, power limitations (engine), or weight are such that the original assumptions, methods, means, and/or substantiation are not valid for the changed product.  A new type certificate could be required for either a substantial change to a previously type certificated product or a new design derived through a series of design changes from a previously type certificated product. The question of whether a change is substantial must be addressed at the beginning of the process by applying the principles of the changed product rule (CPR). However, if at any point while developing the certification basis, it becomes clear that the proposed change is a substantial change, the process becomes a new type certificate process under section 521.28 of the CARs.  When a new type certificate is required, Section 521.30 of the CARs specifies the applicable certification basis for the new product.

  2. Additional guidance on the determination of the requirement for a new type certificate and the application of the changed product rule is provided in AC 500-016.

5.6  Change Other Than a Change to the Type Design - Section 521.154

  1. This section applies to:

    1. Design changes that do not change the type design and could be classified as a minor change per subsection 521.152(2) of the CARs; and

    2. Holders of an existing design approval document wishing to make a minor change to that design.

  2. To qualify under this section, the holder of the existing design approval shall have established procedures acceptable to the Minister to deal with such minor changes to ensure that the product continues to comply with its certification basis.  An aeronautical product original equipment manufacturer would be a likely example of an approval holder who would have such procedures. More information on establishing procedures for Section 521.154 of the CARs is provided in AC 521-004.


6.1  General

  1. Phase I for Division IV of subpart 521 of the CARs generally consists of the following steps:

    1. Project initiation and familiarization between the applicant and TCCA;

    2. Submission of an application by the applicant for the change to the type design consisting of the:

      1. Submission of application form or alternate TCCA (accepted form or process);

      2. Description of the change to the type design;

      3. Submission of a proposed certification basis; and

      4. Submission of a proposed certification plan;

    3. Establishment of the certification basis by the Minister.

  2. While there may be some overlap, phase one generally covers sections 521.155 through 521.159 of the CARs.

Figure 4 – Summary of the Application Process for a Change to a Type Design Approval

Text description

Figure 4 – Summary of the Application Process for a Change to a Type Design Approval

Phase I – Application / Certification Basis

Starts with section 521.155 Application for approval of a change to the Type design. The type design consists of 521.158 the Standards of Airworthiness and 521.159 the Aircraft Emission Standards. Together, these two requirements make up 521.157 which is the certification basis.

Section 521.156 is the effective period of an application, which leads to section 521.157 Certification Basis.

6.2  Receive Application For Design Change From Applicant

  1. Applications for design changes may be submitted to the Minister by submitting the application form and other required documents to:

    1. TCCA National Aircraft Certification, the closest TCCA regional office or Transport Canada centre in the area where the applicant resides; or

    2. TCCA indirectly through an industry representative who holds a TCCA Ministerial delegation of authority for aircraft certification design approval work.

6.3  Initial Transport Canada Civil Aviation Review Of Application

  1. TCCA staff shall review the application and supporting documents for completeness and accuracy.  This includes the following documents required per Section 521.155 of the CARs:

    1. The application form.

      1. The applicant must submit their application using either the TCCA form 26-0469, “Design Change Approval Application” or alternate form or process accepted by TCCA;

      2. If the applicant requests concurrent certification by another foreign civil aviation authority, this should be noted in the application and the applicable foreign design requirements should also be specified in the certification basis.

    2. A description of the proposed change to the type design. The description of the design change under consideration needs to be of sufficient detail that TCCA (staff can make a proper assessment of the certification requirements.

    3. A proposed certification basis. The scope and detail of the proposed certification basis is to be commensurate with the complexity of the design change. It must take into account all airworthiness and emission standards that apply to the area of change and must be developed in accordance with and address the requirements of Sections 521.158 and 521.159 of the CARs. An assessment must also be made for the possible requirement for the development and issuance of the following documents whether requested by the applicant or TCCA, some of which may form part of the certification basis:

      1. Issue papers which document the certification basis;

      2. Exemptions;

      3. Special conditions - airworthiness.   Additional guidance is provided in SI 500-004; and/or

      4. Equivalent levels of safety.

    4. A proposed certification plan. This plan should be commensurate with the complexity of the project. For more information on certification plans, refer to AC 500-015.

  2. After the initial review of the application is complete, the TCCA employee receiving the application:

    1. Date stamps the application form and returns a copy of form to the applicant;

    2. Opens a project approval file in the National Aeronautical Product Approval (NAPA) system as noted in section 6.4 of this SI;

    3. Issues a “Fee Memorandum” to the applicant per section 6.5 of this SI; and

    4. Where the person receiving the application is not the project manager, place all related information in a file folder and forward it to the TCCA project manager for review and action per section 6.6 and later.

6.4  Open National Aeronautical Product Approval / National Delegate Web Link Project

  1. TCCA staff will open a project related to the design approval application in the NAPA system. All subsequent correspondence on the subject shall make reference to the NAPA project number.  Refer to the “Help” menu in NAPA for assistance on all aspects of the NAPA database.

  2. Ministerial delegates with appropriate NAPA/Delegate Web Link (NDWL) access and authority will open a NDWL project for the application. All subsequent correspondence on the subject shall make reference to the resulting NAPA Project Number.  Refer to the “Help” menu in National NDWL for assistance on all aspects of the National Delegate Web Link database.

6.5  Issue Fee Memorandum

  1. TCCA staff will issue a fee memorandum using the information provided on the application form referred to in section 6.3 of this SI.  Section 104.05 of the CARs specifies that the charge is to be paid within 30 days of any invoice presented by the Minister.

  2. This requirement equally applies to fees prescribed for approvals issued by delegates.

  3. The fee structure is defined in subpart 104 of the CARs.  As prescribed in section 104.02, fees are payable whether or not the required design approval document is issued.  This means that prescribed fees are still payable should the applicant withdraw the application once the review has been partially completed. No fee is applied where the Minister or design approval document holder initiates a revision to a design approval document to correct administrative errors.

  4. A sample Fee Memorandum is provided in Appendix B of this SI.  This template can be automatically generated within National Aeronautical Product Approval.  Refer to the “Help” menu in NAPA for assistance on creating a fee memorandum.

6.6  Project Manager Review of Application

  1. The project manager is responsible to ensure that a a technical review / assessment of the application is conducted to:

    1. Determine that there is sufficient time to complete the project per Section 521.156 of the CARs;

    2. All applicable Canadian design requirements are specified in the certification basis per Section 521.157 of the CARs;

    3. All applicable foreign design requirements are specified in the certification basis where the applicant has requested concurrent certification by another foreign civil aviation authority;

    4. Establish the certification basis for the change to the type design; and

    5. Fill out the CPR decision record (See Appendix G of this SI).

6.7  Effective Period of an Application - Section 521.156

  1. Section 521.156 of the CARs provides for a period of time that should be sufficient to permit the applicant to complete all the necessary tests, analyses, etc. required to demonstrate that their product or changed product complies with the established certification basis.

  2. Normally, at the time a changed product is approved, no more than three or five years (as appropriate to the product), has elapsed from the date of application. This is to ensure that the certification basis for the changed product is as current as practical. AC 521-004 describes the process of updating the certification basis if these limits are exceeded.

  3. In the case where the design approval document will not be issued within the effective period of the application, the applicant should discuss the situation with the TCCA Project Manager and follow one of the available options prescribed in the CARs. Guidance on this subject is available in AC 521-004.

6.8  Establish Certification Basis – Section 521.157

  1. The general summary of establishing the certification basis for a change to a type design is summarized in Figure 5, below and includes the associated paragraphs from Subpart 521 of the CARs.

    Figure 5 – Summary of Establishing the Certification Basis for a Change to a Type Design

    Text description

    Figure 5 – Summary of Establishing the Certification Basis for a Change to a Type Design

    To establish the certification basis for a change to a type design:

    • Start with a Section 521.155 Application, then
    • Assess proposed Certification basis, then
    • Complete a CPR Record
    • Establish Basis CAR 521.157?
      • No? Applicant reworks proposal, then return to "assess proposed certification basis"
      • Yes? 521.160 Conformity with Certification Basis
  2. TCCA has the responsibility to establish the certification basis required by section 521.157 of the CARs using as a base, the proposed certification basis submitted by the applicant per section 521.155 of the CARs. When establishing the certification basis, due consideration shall be given to:

    1. The applicant’s proposed change;

    2. The applicant’s proposed certification basis;

    3. CPR;

    4. Special Conditions-Airworthiness, findings of equivalent safety, or exemption considerations.

  3. Once the certification basis has been established, the TCCA project manager or delegate shall notify the applicant.

6.9  Standards of Airworthiness - Section 521.158

  1. Section 521.158 of the CARs sets out the requirements for the applicant to identify the applicable standards of airworthiness for a change to a type design. In addition to the standards of airworthiness associated with the AWM 5XX, the change to the type design may be affected by or give rise to Special Conditions-Airworthiness , exemptions, and/or findings of equivalent safety. The standards of airworthiness may also be listed on the Type Certificate Data Sheet and may include other standards such as Federal Aviation Regulations that form part of the certification basis.

  2. The general summary for developing the certification basis applicable to a change to a type design are summarized in Figure 6 below and include the associated Subpart 521 of the CARs paragraph. Emission standards will be discussed in Section 6.16 of this SI.

Figure 6 – Developing the Certification Basis not including Emission Standards

Text description

Figure 6 – Developing the Certification Basis not including Emission Standards

Developing the certification basis not including emission standards:

  • Review standards of Airworthiness CAR 521.158
  • Raise G Series Issue papers SI 500-019
  • Raise special conditions airworthiness (SCASI 500-004
  • Process Exemption Requests CAD REG-003
  • Raise findings of equivalent safety
  • Agree? CAR 521.157

6.10  Review Proposed Standards of Airworthiness

  1. The general summary for establishing the certification basis in accordance with Section 521.157 of the CARs includes the review of all proposed standards of airworthiness.

  2. Proposed standards of airworthiness are to be appropriate for the change. This means that the appropriate standards are addressed at the appropriate change level.  For change levels other than those in the type certificate, consideration must be given for interdependencies between standards. In such cases, all associated standards must be considered at the “later” change level.  The process of determining the appropriate change levels should be done in conjunction with the guidance provided in AC 500-016.

  3. It is a commonly accepted practice for applicants to propose in a certification plan only the standards applicable to the change. This practice, however, does not relieve any responsibility of the applicant to ensure that the change complies with the entire certification basis for the changed product.

6.11  Raise G-Series Issue Papers

  1. An administrative class of issue papers (IPs) known as the “G” Series is used for developing and documenting the certification basis for an aeronautical product. Documentation of the basis for domestic and foreign products shall be accomplished via the use of IPs.  A G-Series IP may be issued for the following conditions:

    1. G-1 IP - contains a complete definition of the certification basis;

    2. G-2 IP - lists special conditions;

    3. G-3 IP - lists findings of equivalent safety;

    4. G-4 IP - lists changes to the standards made after the date of application to the foreign authority with which the applicant elects to comply;

    5. G-5 IP - lists exemptions granted to the applicant.

  2. Although the G-series IPs are most commonly used in establishing certification requirements of a type certificate (Division II of Subpart 521 of the CARs), they are still available as a method of documenting requirements of a change to a type design. Additional information on IPs is provided in SI 500-019.

6.12  Raise Technical Issue Papers

  1. Technical IPs may be developed during the life of the project to record issues and concerns identified by either the applicant or TCCA project managers. Additional information on Technical IPs is provided in SI 500-019.

6.13  Special Conditions - Airworthiness Development

  1. A Special Conditions-Airworthiness may be issued where the change to the type design involves novel or unusual design features inadequately addressed by the standards of airworthiness of the proposed or existing certification basis. Refer to SI 500-004 for detailed procedures for the request and development of Special Conditions-Airworthiness.

  2. The TCCA project manager is responsible for recording on a G-2 IP both TCCA’s and the applicant’s position as the Special Conditions-Airworthiness is being developed.

  3. Once approved, the Special Conditions-Airworthiness shall be recorded as part of the certification basis.

6.14  Exemptions

  1. According to section 5.9(2) of the Aeronautics Act, an exemption from a particular design standard or portion of regulation may be issued if in the opinion of the Minister:

    1. Such exemption is not likely to affect aviation safety; and

    2. Is in the public interest.

  2. In addition, where compliance with a standard is impractical or impossible due to the particular features of the change to a type design an exemption may also be applied.

  3. Upon receipt of a request or determination that an exemption is needed, the TCCA project manager will inform the applicant and provide guidance as to the applicant’s responsibilities in making a formal application in accordance with CAD REG-003. The project manager shall record both Transport TCCA’s and the applicant’s position on a G-5 IP as the exemption is being developed.

  4. TCCA engineers from the Standards Branch, Domestic Regulations section will liaise directly with the applicant for the processing and subsequent issuance of the formal exemption.  The issued exemption will be forwarded directly to the applicant and copied to the project manager as well as an electronic original in the RDIMS database.

  5. The exemption shall be recorded as part of the certification basis.

  6. Further procedures and guidance for the development and approval of exemptions are provided in CAD REG 003 and SI REG 004.

6.15  Findings Of Equivalent Safety

  1. A finding of equivalent safety may be needed where the usually accepted or industry standard means of compliance for a particular airworthiness requirement is not the one proposed by the applicant. As such, the applicant is not requesting an exemption from the requirement, since compliance by another means is proposed. Neither is the particular design novel or unusual to the extent that an Special Conditions-Airworthiness would be considered appropriate. However, some aspect of the design requires further documentation, as part of the certification basis, in order to fully explain and rationalize how the finding of equivalent safety was determined.

  2. Upon receipt of a request or determination that a finding of equivalent safety is needed, the Regional/National Aircraft Certification project manager shall:

    1. Review the applicable information, consult with appropriate specialists in the National Aircraft Certification Branch if required;

    2. Lead or participate in technical discussions as necessary to determine the need for, and the regulatory content of, the finding of equivalent safety; and

    3. Draft a G-3 IP recording both TCCA’s and the applicant’s position. The draft will be written with the assistance of the appropriate National Aircraft Certification specialists if required, and when complete, be circulated to responsible parties for comment. The project manager will send a copy of the draft finding of equivalent safety to the applicant for further discussion. Persons solicited to comment should provide their inputs to the responsible project manager;

    4. Consider comments, make any appropriate changes and prepare the draft finding of equivalent safety for sign-off;

    5. The completed finding of equivalent safety shall then be forwarded to the applicant and filed on the project file.

  3. The finding of equivalent safety shall be recorded as part of the certification basis and documented on the G-3 IP.

  4. Additional information on IPs is provided in SI 500-019.

6.16  Aircraft Emissions Standards – Section 521.159

  1. Section 521.159 of the CARs sets out the requirements for the applicant to identify the applicable aircraft emissions standards for a change to a type design.  Aircraft emissions requirements are contained in Chapter 516 of the AWM.

6.17  Change Affecting the Noise Level of the Aircraft – 521.159(1)

  1. Unless the proposed change is the subject of one of the exempting conditions of Subsection 521.159(2) of the CARs, a change to the type design, which affects the noise level of the aircraft, must demonstrate compliance with the requirements of Chapter 516 of the AWM, or be shown to continue to be within the already established and accepted limits for the aircraft.

6.18  Changes For Which Noise Requirements Do Not Apply – 521.159(2)

  1. Subsection 521.159(2) of the CARs defines a number of instances where the noise requirements described in subsection 521.159(1) of the CARs do not apply.  These exceptions are only from the noise requirements (Chapter 516, Subchapter A of the AWM).  The proposed change to the type design may still be affected by sections 521.159(3) or 521.159(4) of the CARs.

6.19  Fuel Venting Requirements For Turbine-Powered Aircraft – 521.159(3)

  1. A change to the type design to a turbine-powered aircraft must be demonstrated to comply with the requirements of Chapter 516, Subchapter B of the AWM.

6.20  Smoke and Gaseous Requirements For An Aircraft Engine – 521.159(4)

  1. A change to the type design of an aircraft engine must be demonstrated to comply with the smoke and gaseous requirements of Chapter 516, Subchapter B of the AWM.


7.1  Establish Means of Compliance

  1. Once the project manager has the established certification basis in Phase I, a series of reviews and meetings are held as needed between TCCA and the applicant.  The goal is to obtain concurrence on the proposed means and methods that will be used to demonstrate compliance for each of the requirements identified in the established certification basis.

  2. To achieve this goal, TCCA and the applicant may exchange various technical IPs to clarify and document concerns identified during this step, and how the two parties arrived at a conclusion.  Further information on the use of IPs can be found in SI 500-019.

  3. The applicant uses this information to update their certification plan that they previously submitted per Subsection 521.155(d) of the CARs.

7.2  Level Of Involvement Assessment

  1. LOI refers to TCCA oversight of Ministerial delegates. During a certification activity, LOI are those activities undertaken by TCCA in performing surveillance of the delegate when the delegate is exercising their granted authority.

  2. The procedures for defining LOI are described in SI 500-003.


8.1  Compliance With The Certification Basis – Section 521.160

  1. TCCA fulfills various roles and responsibilities during the process of the applicant demonstrating compliance with the certification basis.  These include direct involvement, oversight of delegates, and procedural responsibilities.

8.2  Transport Canada Civil Aviation Participation in Certification Activities

  1. This section refers to TCCA’s direct participation in the performance of certification activities of a design approval project and is considered to be a service provided by TCCA to the applicant.  Examples of areas of the certification activities where TCCA may become involved include, but are not limited to:

    1. An aircraft/rotorcraft flight manual or flight manual supplement;

    2. A master minimum equipment list or master minimum equipment list supplement;

    3. A limitation applicable to an aeronautical product and recorded in the design approval data sheet for that product;

    4. A service life applicable to any life-limited part of an aeronautical product;

    5. A certification maintenance requirement;

    6. An airworthiness directive or an equivalent instruction issued under the authority of a foreign airworthiness authority;

    7. A noise approval applicable to an aircraft;

    8. Making findings of compliance;

    9. Confirmation of the certification basis (if different than that identified on the Type Certificate Data Sheet for a previously certified aeronautical product);

    10. A limitation contained in a maintenance manual, maintenance manual supplement, instructions for continued airworthiness (ICA), or ICA Supplements;

    11. Departures from specific policy and guidance;

    12. New, novel, or unique technologies; and

    13. Design change approvals involving innovative technology or unusual design features not considered in the type certification basis and/or requiring special conditions.

  2. TCCA participation in a change to a type design could include regional and/or National Aircraft Certification participants.

8.3  Assistance by Transport Canada Civil Aviation National Aircraft Certification Branch

  1. National Aircraft Certification assistance is available to regional project managers to support their involvement in the certification plan.  Some typical issues that require National Aircraft Certification assistance / participation include:

    1. Issues requiring the knowledge/experience of National Aircraft Certification;

    2. Issues with international implications;

    3. Issues dealing with continued airworthiness.

  2. Where the assistance of National Aircraft Certification is required, the project manager shall:

    1. Complete the request form shown in Appendix C of this SI;

    2. Submit the request form to National Aircraft Certification project management division; and

    3. Where required, initiate a cost recovery arrangement for National Aircraft Certification participation.

  3. Where delegates require the assistance of National Aircraft Certification, they should contact the responsible project manager who will request support.

  4. An evaluation by National Aircraft Certification flight test division personnel is normally recommended when:

    1. Performance or handling qualities of the aircraft may be affected; or

    2. The flight deck layout or other pilot interfaces may affect crew workload, pilot’s view and/or the ability to reach the necessary equipment.

  5. Where the project manager requires the assistance of National Aircraft Certification flight test division in support of a project, a formal request shall be completed and submitted using the request form shown in Appendix C or by directly contacting the Chief of the Flight Test division.

  6. Where delegates require the assistance of National Aircraft Certification flight test division in support of a project, they should contact the responsible project manager who will request support.

8.4  Test Plan Acceptance

  1. Where the means of compliance for a given airworthiness standard is by means of a test, TCCA will review and accept the test plan prior to the certification test being conducted.

  2. Test plans should contain descriptive content related to:

    1. Test description;

    2. Test apparatus;

    3. Test procedures;

    4. Test vehicle and configuration;

    5. Conformity requirements;

    6. Witnessing requirements;

    7. Roles and responsibilities of key test personnel;

    8. Test details including conditions and pass/fail criteria;

    9. A list of standards for which compliance is demonstrated;

    10. Calibration of measurement equipment;

    11. Data reduction requirements; and

    12. Hazard level with risk mitigation actions.

  3. It is recognised that an applicant may conduct research and development testing without TCCA involvement prior to conducting certification tests. However, TCCA is not obliged to accept data from such a test as a means of demonstrating compliance.

  4. In a case where an applicant performs similar or repetitive tests in order to demonstrate compliance, special agreements with the Minister may be possible to provide block or blanket approval for the associated test plans.

  5. Delegates may be specifically authorized for test plan acceptance by letter of authorization or approved Design Approval Procedures Manual or Engineering Procedures Manual.  Such authorization would normally be for specific tests and in a specific discipline. TCCA may choose to review delegate accepted test plans as an LOI function.

8.5  Issuance of Flight Permit

  1. There are many valid reasons for the applicant to require a flight permit for the aircraft with the change embodied, but prior to the issuance of an approval in accordance with Section 507.04 of the CARs. In this state, the aircraft incorporates unapproved changes to the type design and therefore requires a flight permit in order to fly.  TCCA Safety Inspectors issue flight permits. Maintenance and Manufacturing Staff Instruction 14 explains the process of issuing an experimental flight permit. The following process should be followed for the issuance of a flight permit under these circumstances:

    1. Applicant submits evidence to the project manager that the aircraft is fit and safe for flight;

    2. Applicant submits flight test plan to the project manager for acceptance;

    3. Applicant applies for flight permit directly to the Civil Aviation Safety Inspectors and pays the required fee per Subpart 104 of the CARs;

    4. The Civil Aviation Safety Inspectors seeks a recommendation for the flight permit from the project manager;

    5. The project manager provides the Civil Aviation Safety Inspectors with appropriate information, including:

      1. The NAPA project number;

      2. Flight test plan report number (and revision level);

      3. Specify appropriate conditions/limitations; and

      4. Where appropriate, limit to flight in accordance with accepted flight test plan.

    6. The project manager recommends issuance of the flight permit to the Civil Aviation Safety Inspectors.

8.6  Flight Test Evaluation

  1. Where flight test evaluation is required to substantiate a change to a type design, National Aircraft Certification flight test division, regional specialists, or delegates may do testing and/or witnessing.  Under normal circumstances, the modified aircraft is to be flight tested by the applicant prior to an evaluation by TCCA. This provides a reasonable assurance of compliance and safety of flight. However, by prior agreement some test points may be conducted for the first time with a TCCA flight test specialist onboard.

  2. Detailed guidelines for flight test evaluation are provided in Appendix F of this SI.

8.7  Test Witnessing

  1. Where the means of compliance with the certification basis for a particular design standard is by means of a “test”, the requirements for witnessing the test(s) are to be established during the test plan acceptance phase if not already determined during the certification plan review. This choice of witnessing is based on risk management principles applied by TCCA.  Some of the risk factors include:

    1. Safety implication of the design change;

    2. Level of complexity of the design change and/or test;

    3. Level of variability of the test and/or qualitative nature of the pass criteria;

    4. Level of experience and knowledge of the key test personnel;

    5. The cost or difficulty to the applicant to perform the test; and

    6. Test facilities/resources.

  2. Delegates may be authorized to witness tests on behalf of the Minister in their letter of authorization or approved Design Approval Procedures Manual.  Such authorization is normally for specific tests and in a specific discipline. In a case where the delegate performs similar or repetitive test witnessing as part of the applicant’s demonstration of compliance (as the applicant’s technical capability, as opposed to as a delegate), special agreements with the Minister may be possible to accept alternate individuals for the subject test witnessing.

8.8  Transport Canada Civil Aviation Conformity Inspections

  1. TCCA may choose to conduct independent conformity inspections to confirm that the materials, parts, processes, construction and assembly conform to the type design.  Such conformity inspections may be conducted to:

    1. Ensure continuity between certification test articles and production articles;

    2. Ensure configuration definition data is capable of producing parts that have consistent (i.e. repeatable) qualities affecting airworthiness;

    3. Verify the absence of ambiguity of configuration definition;

    4. Verify information on fits, tolerances, finishes;

    5. Verify material and hardware specifications;

    6. Ensure drawing change control (e.g. revision status);

    7. Ensure no interference or adverse interactions with existing aircraft systems; and

    8. Ensure no interference or adverse interactions with previously installed modifications and/or repairs.

  2. A TCCA conformity inspection is not a requirement for all certification activities.  Any TCCA conformity inspection is additional and subsequent to the company conformity inspection, which is always required.

  3. The following process should be observed when conducting a TCCA conformity inspection:

    1. Project manager requests support from a Civil Aviation Safety Inspectors for the inspection by contacting the appropriate regional manager;

    2. Manager assigns a Civil Aviation Safety Inspectors for the inspection;

    3. Project manager liaises with the applicant and the Civil Aviation Safety Inspectors to create a schedule;

    4. Project manager raises a cost recovery agreement, if required;

    5. Project manager provides the Civil Aviation Safety Inspectors with the detailed inspection requirements and data:

      1. Specific instructions;

      2. Defined expectations and outcomes;

      3. Specific drawings or data;

      4. Specific dimensions and/or features;

      5. Specific tolerances and/or pass criteria; and

      6. Specific data presentation requirements.

    6. The project manager will ensure that the Civil Aviation Safety Inspectors is provided with evidence (signed form AN-B043 or equivalent) that the applicant’s designated Aircraft Maintenance Engineer, Aircraft Maintenance Organization, or suitable Quality Assurance Representative has carried out a full conformity inspection.

    7. Civil Aviation Safety Inspectors performs inspection and provides the project manager with results in writing and a completed form as described in AN-B043 or other agreed upon format.

8.9  Engineering Inspections

  1. An engineering inspection is a specific task carried out by TCCA to review a physical modification to an aeronautical product against the type design definition.  An engineering inspection is not a conformity inspection.  A conformity inspection may be required prior to an engineering inspection.

  2. Some reasons for an engineering inspection are:

    1. To give perspective to the drawings and determine their adequacy;

    2. To provide familiarization with the aircraft including, but not limited to the layout, systems operations and structural load paths;

    3. To show possible interactions and interference between systems or components;

    4. To conduct zonal inspections for the purposes of compliance with standards for flammable fluids, fire zones or interior installations; and

    5. To verify compliance with the requirements of an airworthiness standard.

  3. TCCA or delegates conducting an engineering inspection shall document the results and follow-up with the applicant on any resulting issues of compliance or conformity.

8.10  Finding of Compliance

  1. Where TCCA and/or delegates are required to make a FOC in accordance with the accepted certification plan, a review of reports, drawings and other substantiating data is required. The depth of this review is at the discretion of the authorized TCCA specialist or delegate.  Such review is conducted to determine if the change to the type design meets the minimum requirements of the certification basis.

  2. Within their scope of authority, each delegate involved in a modification program shall:

    1. make the FOC against all elements in the certification basis when the applicant has demonstrated compliance;

    2. not make the FOC where they are aware of a disagreement with the TCCA specialist on whether compliance has been demonstrated; and

    3. confirm that the LOI has been completed before approving changes.

  3. The certification plan, or equivalent, is typically used to record and track the FOC made by the delegate, and, when necessary, the TCCA specialists. TCCA specialists will make the FOC only where there is a limitation of scope of authority of the delegate such as the:

    1. AWL;

    2. AFM;

    3. special conditions - airworthiness; or

    4. where the delegate:

      1. is unavailable to make the FOC; or

      2. does not have full scope of authority for the approval project.

  4. The certification plan sign-off process is a systematic means to record compliance with all the applicable airworthiness requirements.

  5. The TCCA specialist/delegate signs the certification plan beside each item near the end of Phase III. Once compliance has been demonstrated for an item, the appropriate signatures should be added.

  6. The Minister shall also make a finding / determination that, even though the product has been demonstrated to meet the requirements established in the certification basis, no feature or characteristic makes the aircraft unsafe taking into account the category in which the certification is requested.  This requirement is detailed in Subsection 521.160(2) of the CARs for other than restricted category aircraft and subsection 521.160(3) for restricted category aircraft. Issuance of the approval document infers that this finding / determination has been made.

  7. There are four situations that may exist at the end of Phase III with respect to FOC:

    1. Delegate and TCCA agree compliance has been demonstrated: The delegate indicates the FOC by initialling the certification plan against the specific requirement. Where the delegate has a scope of authority for all aspects of the particular requirements, only the delegate signature is required.

    2. Demonstration of compliance with limitations and/or mandated inspections: In some instances, compliance can only be found by the imposition of a limitation and/or inspection. If a limitation/inspection can enable compliance to be found, TCCA shall sign this part of the certification plan. The certification plan should be annotated to include the nature and location of the limitation/inspection that enabled the finding to be made. These limitations/inspections shall also be included as part of the appropriately approved publication e.g. the AFM, and AWL section of the ICA. Compliance items falling into this category are fully compliant, and as such could remain as permanent situations.

    3. A non-compliance exists: Sometimes the delegate cannot make a FOC because compliance has either not been fully established or the modification has been found not to be compliant with the certification basis. The delegate or TCCA specialist is therefore not able to sign the certification plan. Requirements that cannot be signed shall be listed as such and clear and agreed reasons shall be defined for each. Compliance finding items falling into this category may require interim limitations or mandatory inspections to be imposed to assure that any exemptions or findings of equivalent safety are satisfied. The non-compliance cannot be resolved  by placing the aircraft in the “Restricted Category”.

    4. Delegate and the TCCA specialist are known to be in disagreement: In these cases, neither should sign the certification plan. Such a disagreement would normally result in the creation of an issue paper as a vehicle to resolve the problem.

8.11  Approval of Limitations

  1. A change to a type design may introduce or modify limitations of the aeronautical product.  Where TCCA is required to approve limitations, a thorough review of supporting reports, drawings and other substantiating data is required. The depth of this review is at the discretion of the authorized individual.

  2. Examples of such  items that may be affected by the changes include:

    1. Maintenance manual and maintenance manual supplements;

    2. AFM and AFM supplements;

    3. ICA.

8.12  Complete Level of Involvement

  1. The LOI must be complete before the design approval document is issued, regardless of whether TCCA or a delegate issues the approval.

  2. For each project where delegates are involved, the responsible project manager shall:

    1. Ensure the TCCA LOI is complete;

    2. Record the LOI completion on the project file. One acceptable method is to record the LOI completion in National Aeronautical Product Approval;

    3. Communicate the completed LOI to the delegate that is issuing the approval. One acceptable method is to notify the delegate by e-mail that the LOI is complete.

8.13  Receive The Applicant’s Declaration of Demonstration of Conformity

  1. Paragraph 521.160(1)(b) of the CARs requires the applicant to submit to TCCA a properly completed and signed declaration of demonstration of conformity prior to the issuance of the design approval.  The applicant is required to submit this declaration once the type design has been demonstrated to conform to every aspect of the certification basis. This requirement is the same irrespective of whether the approval is issued by TCCA or a delegate.

  2. A person holding a Ministerial delegation of authority may not sign a declaration of demonstration of conformity on behalf of the applicant in their role as a delegate; however they could sign as an individual or organization representing the applicant. Any declarations required by the applicant that are signed by a delegate, shall not use their delegate number.

  3. This declaration is required for each aeronautical product design approval.

  4. A sample statement for the declaration is shown in Appendix D of this SI.

8.14  Receive Signed Undertaking

  1. Paragraph 521.160(1)(e) of the CARs requires the applicant to submit to TCCA a completed and signed undertaking to carry out the responsibilities specified in Division VIII of Subpart 521 of the CARs as a condition for the issuance of the design approval.  This requirement is the same irrespective of whether the approval is issued by TCCA or a delegate.  A sample statement for the undertaking is shown in Appendix E of this SI.


9.1  General

  1. Figure 7 provides a graphical description of the steps leading to the approval of the design change under the Refusal to Issue the approval under Section 521.161 of the CARs.

Figure 7 – Steps for the approval of a change to the type design

Text description

Figure 7 – Steps for the approval of a change to the type design

Steps for the approval of a change to the type design:

  • Applicant Submits Documents To Substantiate Compliance Demonstration

  • Minister Reviews Documents Submitted by Applicant To Substantiate Compliance Demonstration

  • Do the Documents Support the Compliance Demonstration?

    • No? Advise the Applicant of the details of these findings, attempt informal resolution of the issues. Then Applicant Reviews and Resubmits Documents When Issue is Resolved, and returns to Minister to Reviews Documents Submitted by Applicant to Substantiate Compliance Demonstration

    • Yes? Complete The Findings of Compliance and LOI

      • Do any features or characteristics exist that make the aircraft unsafe?

        • No? Issue Approval of Design Change and Related Certificate

        • Yes? Refuse to Issue and advise the Applicant  of the details of these findings. Attempt informal resolution of the issues. Applicant Reviews and Resubmits Documents When Issue is Resolved, then returns to Minister to Reviews Documents Submitted by Applicant to Substantiate Compliance Demonstration.

9.2  Transport Canada Approval and Acceptance of Documents

  1. Within this SI, the term “approve” is limited to design approval documents such as the Supplemental Type Certificates, as well as the AWL section of an ICA, the AFM supplement, and installation/repair instructions.

  2. An acceptance is an acknowledgement by TCCA that an item complies or that a plan should lead to compliance with the certification basis. For example, engineering reports, ICA checklists and test plans would be accepted.

  3. For configuration control purposes, documents such as master document lists, top drawing lists, flight manual supplements and installation drawings or instructions as listed on the approval should be stamped and/or signed by the delegate or the TCCA project manager as appropriate.

9.3  Recording the Certification Basis

  1. The certification basis for the change in type design is to be recorded on the approval document as a listing of the applicable standards with amendment levels. If the certification basis has been selected to be the same as that given in the type certificate data sheets for the affected aircraft or aeronautical product, it is as acceptable to make a reference to that effect rather than repeating it in detail.

9.4  Approval of a Change to the Type Design

  1. Once the applicant has completed all of the requirements of Section 521.160 of the CARs, the Minister shall review the substantiating documents to determine that the aeronautical product complies with the certification basis.

  2. If the Minister finds that the applicant has not satisfactorily demonstrated that their product complies with the established certification basis and / or that a feature or characteristic makes the aircraft unsafe, the Minister shall not approve the design change.

  3. In an attempt to informally resolve the issue, the Minister shall advise the applicant in writing of the details of such finding so that the applicant can take action to address the issue.

9.5  Minister May Refuse to Issue the Design Approval Document

  1. In the event that the finding cannot be resolved informally, TCCA on behalf of the Minister shall issue a formal notice to the applicant notifying them of the Minister’s “Refusal to Issue” the approval in accordance with Subsection 6.71 (1) of the Aeronautics Act.  See section 2.1(1)(s) of this document for the form reference.

  2. As noted on the form, the applicant may request that the Refusal to Issue the approval be reviewed by the Transportation Appeal Tribunal of Canada.

9.6  Minister Issues the Design Approval Document

  1. Once all the requirements noted in section 521.160 of the CARs have been met to the Minister’s satisfaction, TCCA or its delegate shall approve the design change, repair or replacement part by issuing the appropriate approval / certificate document based upon the Division through which the applicant made their application as follows:

    1. Amended type certificate/type certificate data sheet, applied for under Section 521.58 of the CARs and issued under Section 521.57 of the CARs;

    2. New or amended Supplemental Type Certificates, applied for under Section 521.201 or 521.207 of the CARs and issued under Section 521.206 of the CARs;

    3. New or amended Repair Design Approvals, applied for under Section 521.251 or 521.257 of the CARs and issued under Section 521.256 of the CARs;

    4. New or amended Part Design Approvals, applied for under Section 521.301 or 521.307 of the CARs and issued under Section 521.306 of the CARs;

  2. Design approval document numbering and formatting requirements, as well as example design approval documents, are provided in the appropriate SI: Supplemental Type Certificates – SI 521-005, Repair Design Approvals SI 521-006, and Part Design ApprovalsSI 521-007.

  3. TCCA will use the templates embedded in the NAPA database for the design approval document formatting.  Delegates should use the templates embedded in the National Delegate Web Link database system for design approval document formatting.  Delegate issued design approval documents are distinguishable by the “/D” suffix on the document number.

  4. If the approval issuance is for a revision for a previous design approval document and there is a corresponding foreign approval, then TCCA must make application to the foreign authority for validation of the revised approval.  For further guidance on foreign approvals and the related procedures refer to SI 521-005.

  5. Once the design has been approved, the holder now becomes responsible for the continuing airworthiness of the product’s design as described in Division VIII of Subsection 521 of the CARs.

9.7  Minister Issues the Design Approval Documents to a Foreign Holder

  1. TCCA will only issue Canadian design approvals to foreign holders following the type design examination / validation of an existing foreign approval.  The examinations are conducted in accordance with any airworthiness agreement or similar arrangement that exists between Canada and the state of design of the foreign aeronautical product. Any other scenario would have to be consulted with the Standards branch, Aircraft Certification Standards division.

  2. Delegates are not authorized to issue a design approval document to a foreign holder.

9.8  Distribution of Design Approval Document

  1. Once the approval is issued, the signed original design approval document with the TCCA embossed seal attached is sent to the design approval document holder.  If a delegate issues the document, a copy of the approval must be submitted to TCCA, in accordance with the delegate’s Design Approval Procedures Manual. The document will be accompanied by any associated original TCCA approved documents, such as flight manual supplements and maintenance manual supplements.


10.1  Transport Canada Civil Aviation Document Records

  1. The following documents as a minimum should be retained in TCCA records:

    1. Signed Application Form (if applicable);

    2. Copies of signed design approval documents;

    3. Certification plan;

    4. Copies of documentation referenced on the design approval document such as;

      1. AFM Supplements;

      2. Maintenance manual supplements of supplemental ICA;

      3. Top level drawings (or equivalent installation document) controlling the approved type configuration and/or manufacturing process;

    5. Issue papers/certification memos;

    6. CPR Decision Record (See Appendix G of this SI);

    7. FOC forms including Statement of Compliance forms submitted by delegates;

    8. Signed Declaration of Demonstration of Conformity form submitted by the applicant per paragraph 521 160(b) of the CARs;

    9. Signed Undertaking by the applicant to carry out the responsibilities of a design approval holder per paragraph 521.160(e) of the CARs;

    10. Completed Maintenance and Manufacturing Staff Instruction 53 Checklist;

    11. Correspondence;

    12. Decision records; and

    13. ANB043 Conformity Inspection Record if generated.

  2. Refer to Appendix A of this SI for a Design Change Process Checklist.

  3. NAPA may be used to store aircraft certification data as an alternate to the physical file.

10.2  Delegate Document Records

  1. The document recording requirements for delegates are to be in accordance with the Design Approval Procedures Manual / Engineering Procedures Manual and associated Airworthiness Control Procedures.

  2. Refer to Appendix A of this SI for a Design Change Process Checklist.

10.3  Close National Aeronautical Product Approval Project

  1. At the completion of the project, TCCA staff /Delegate will finalize and close the NAPA project.  This process includes:

    1. Returning or securely destroying any applicant supplied data, which is not to be retained;

    2. Securely destroying any data, which was transitory in nature and is not to be retained;

    3. Completing and filing the Design Change Process Checklist shown in Appendix A of this SI;

    4. Setting the NAPA project status to "Completed".


  1. It is not the intent that TCCA keep copies of the applicant’s supporting data after the approval is issued. The holder has retention obligations under Sections 521.365 and 521.366 of the CARs.

  2. TCCA files will retain key compliance related information such as certification plans, issue papers and decision records as well as any data cited on the approval document such as flight manuals and supplements, maintenance manuals/ICAs and master document lists.

  3. After approval is issued, TCCA will upon request by the applicant, return paper copies of supporting data or otherwise shred or erase this data.


  1. Not applicable.


Suggestions for amendment to this document are invited, and should be submitted to:

Chief, Aircraft Certification Standards (AARTC) via the following e-mail address:

Original signed by

Jacqueline Booth
A/Director, Standards Branch
Civil Aviation
Transport Canada


NAPA  NUMBER:  _____________________

Aeronautical Product:  _____________________   Serial Number:  _____________________

checkbox Application Form, 26-0469 or equivalent (521.155(a))

checkbox Change Description (521.155(b))

checkbox Proposed Certification Basis (521.155(c))

checkbox Certification Plan (521.155(d))

checkbox Raise National Aeronautical Product Approval Project Number

checkbox Create Project File

checkbox Issue Fee Memo

checkbox Fee Payment Received

checkbox Establish Certification Basis (521.157)

checkbox Changed Product Rule Decision Record – See Appendix G  (AC 500-016)

checkbox Level of Involvement Assessment – Documented and Communicated

checkbox Request National Aircraft Certification Participation

checkbox Maintenance and Manufacturing Staff Instruction 53 Checklist

checkbox ANB043 Conformity Inspection Record(s)

checkbox Level of Involvement Completed – Documented and Communicated

checkbox Complete Certification Plan Involvement

checkbox Complete finding of compliance, statement of compliance

checkbox Receive Declaration of Demonstration of Conformity (521.160(1)(b))

checkbox Receive Signed Undertaking of Responsibilities (521.160(1)(e))

checkbox Issue Approval (521.161)

checkbox Distribute Approval (Documents)

checkbox File Project, (including all documents required for retention)

checkbox Close National Aeronautical Product Approval Project



Project Number: <insert NAPA number>
Approval Number:
<insert approval number>


<insert date here>

TO: AFFAH, Ottawa

FROM: <insert region here>


Please send an account receivable voucher to:

<insert address here>

For the amount of $  _______

This is for the following approval project:

NAPA Project Number:

Approval Number:

Applicant's Project Number:



Project Type:

Project Description:

Please credit to Cost Centre:    <Regional financial coding>

<Regional contact person>

<Regional contact information>

Canada wordmark


The following information should be included when requesting support:



Target Date:


Area of Assistance Requested:

Description of Support Required:

Documentation Provided:

(This information can be sent by mail or electronically)


  1. The following declaration is one example of how the declaration can be made, however, applicants may choose a variant of this:

Declaration of Demonstration of Conformity

In accordance with subpart 521 of the CARs, I hereby declare that the type design of (name of product) has been demonstrated to conform to the best of my knowledge with its certification basis established by the Minister.

Per certification basis / certification plan document number 1243696 version 34 dated 2011-05-06.


On behalf of: (if applicable)

Position title:









Example of the signed undertaking:

1.   This example is provided as one way the signed undertaking can be presented to the Minister, however it is up to the intended holder to decide how they meet this regulatory requirement, subject to approval by the Minister.

I, [NAME OF INTENDED HOLDER] hereby undertake to carry out the responsibilities of a design approval document holder, as set out in Division VIII of Part V Subpart 21 of the CARs, including:

  1. Technical capability,

  2. Service difficulty reporting,

  3. Establishing a service difficulty reporting system,

  4. Investigation of service difficulty reports,

  5. Mandatory changes,

  6. Transfers,

  7. Record keeping and loss or disposal of records,

  8. Manuals,

  9. Instructions for continued airworthiness, and

  10. Supplemental integrity instructions


Signature of Intended Holder



2.   The intended holder must make this signed undertaking, as it is ultimately the design approval document holder who will be responsible for these areas. If the holder does not have the technical capabilities, they can use an agent, however since the holder ultimately has responsibility for the design, there needs to be an agreement in place between the holder and the agent.

3.   The design approval document will not be issued until the Minister has received this declaration.

4.   More detailed information on these areas can be found in Subpart 521 of the CARs Division VIII


F-1    Pre-Evaluation Activities

  1. Prior to the flight test evaluation, the project manager should ensure that:

    1. Any additional airworthiness inspections, requested by the flight test specialist (e.g. rigging check), in support of the flight test, have been completed;

    2. The Statement of Suitability for Flight Test (TABLE F-1) has been signed;

    3. The installed modification is in compliance with the proposed design change and documented in accordance with Airworthiness Notice B043. Identified discrepancies must be rectified before proceeding with flight testing, unless the flight test specialist and the TCCA (project manager agree that the discrepancies do not have an adverse effect on the flight test evaluation;

    4. There is a suitable, valid flight authority for the flight test (for example, if a night evaluation is required, the flight permit should not specify "day valid flight authority only");

    5. The applicant has agreed with any changes to the flight test plan arising from the review by the flight test specialist;

    6. The applicant will provide a qualified Pilot-in-Command for the flight tests. The Pilot-in-Command assumes ultimate responsibility for the safety of the aircraft and therefore always has the authority to assume control, and make decisions affecting the safety of the flight. The Pilot-in-Command must have previously flown the test aircraft, and be familiar with the design changes that have been incorporated. The experience level of the Pilot-in-Command should be reviewed with the flight test specialist;

    7. The applicant is aware of, and agrees to the flight test crewing arrangement. During a flight test, the TCCA (test pilot normally occupies the primary pilot’s seat and the Pilot-in-Command moves to the co-pilot’s seat. The project manager must ensure that the crewing arrangements are clarified prior to the scheduled flight test;

    8. The applicant has a current detailed loading plan for the weight and centre of gravity required for the tests; and

    9. The project manager must also ensure that the applicant and/or operator of the aircraft has insurance coverage for the flight tests as required by subsection 606.02(8) of the CARs. Many insurance policies do not cover flight tests or operations outside of the certified flight envelope. They may also specify pilot qualifications that the TCCA (test pilot does not possess. Insurance coverage is the responsibility of the applicant, and the TCCA (project manager must confirm that insurance is in place for the flight test in question.

F-2    Aircraft Weight and Balance

  1. It may be necessary to have the aircraft weighed prior to the flight test, to ensure that the weight and balance for the modified aircraft is accurate. The test aircraft should be weighed again if there is any doubt regarding the validity of the weight and balance statement following any major alteration or repair, following maintenance such as aircraft painting, or following a change in the interior arrangement of the pilot/passenger/cargo compartments that cannot be accurately computed. It is also recommended that the aircraft be weighed if it has been more than two years since the last weighing of the aircraft.

  2. For most flight tests that determine performance and handling qualities, the applicant should have detailed loading plans to permit operation of the aircraft:

    1. At the maximum gross weight with the centre of gravity at the forward limit; and,

    2. At a light weight with the centre of gravity at the aft limit.

  3. Depending upon the program, some other loading combinations may be necessary. Normally, the centre of gravity extremes at which the aircraft is tested will be the limits subsequently approved for the modified aircraft.

  4. The TCCA (specialist and/or flight test specialist shall inspect the security of any temporary ballast and ballast retention system required to achieve the desired loading.

F-3    Dual Controls

  1. The applicant should be advised of the need to have dual controls installed and inspected, where appropriate, prior to a TCCA (engineering test pilot evaluation.

  2. In some circumstances, the flight test aircraft may be configured for only one pilot, either because of its single place design, or because of its single control installation. In these cases, the TCCA (engineering test pilot must be advised with sufficient notice to permit him to satisfy aircraft knowledge and proficiency requirements.

F-4    Documentation Available for Review On Site

  1. The project manager, in cooperation with the applicant, should make the following information available to the flight test specialist:

    1. Appropriate aircraft, engine and propeller, flight and maintenance logs;

    2. Current Weight and Balance statement(s) for the modified aircraft test flight(s);

    3. Signed Conformity Inspection Record (per Airworthiness Notice B043);

    4. Flight authority; and

    5. Instrument calibrations if applicable.

  2. When the project manager is satisfied with the documentation. The Statement of Suitability for Flight Test (TABLE F-1) is sent to the flight test specialist.

F-5    Pre-Flight Checklist

  1. Before flight, the flight test specialist will complete a flight test safety checklist similar to that in TABLE F-2.

F-6    Pre-Flight Briefing

  1. Prior to conducting the flight test, the flight test specialist will brief the applicant’s representatives and flight test crew concerning the proposed flight. As a minimum, this briefing will include the following points:

    1. The purpose of the flight test;

    2. The proposed flight profile;

    3. Details concerning the test(s) to be carried out;

    4. Tests where operating limitations may be approached or exceeded;

    5. The delineation of each crew member’s duties and responsibilities during the flight;

    6. The designation of pilot-in-command responsible for the overall safe operation of the aircraft; and

    7. Safety considerations.

  2. The TCCA (project manager or specialist should be present at flight test briefings and debriefings. When the specialist is not available, or is onboard the aircraft during the conduct of the flight test, he shall arrange for a suitable alternate observer to be present. The observer’s primary responsibility would be, in the event of an incident or accident, to explain to appropriate authorities the purpose of the flight test and report the information presented at the pre-flight briefing. The observer should retain a copy of the flight permit, flight test plan, and weight and balance statement. The observer may also be tasked to monitor progress of the test flights, performing a flight watch responsibility.

F-7    Post-Flight Debrief

  1. Immediately following the flight test, a post-flight debrief will be held with the flight test crew and interested parties, to review the significant observations made during the flight.

F-8    Flight Test Debrief Note

  1. Within two working days following the test flight(s), the flight test specialist will provide the project manager with a written flight test debrief note, which may be forwarded to the applicant. This will summarize comments, operating anomalies, certification items and possible certification items. The applicant must respond to all items except comments. All debrief note items must be satisfactorily resolved before the flight test specialist will recommend approval.

F-9    Certification Flight Test Report

  1. Normally, the applicant is responsible to write a certification flight test report, and the TCCA (project manager should clarify this with the applicant. The report should detail the tests accomplished, results obtained and flight test data analysis, as appropriate. The flight test specialist usually reviews the applicant’s flight test report.

  2. However, for certain simpler modifications, the flight test specialist may write the flight test report. In other cases, the flight test specialist may write a report for only that portion of a flight test program in which he participated. This flight test report would be submitted to the project engineer as soon as practicable but would not normally be forwarded to the applicant.

F-10    Approval Recommendation

  1. Before the flight test specialist can recommend approval of the design change:

    1. All responses to debrief note items should be reviewed and accepted;

    2. The flight test report(s), including flight test data analysis report(s), as appropriate, should be reviewed and accepted; and

    3. The AFM Supplement should be reviewed and accepted.

  2. A flight test specialist’s recommendation for approval is applicable to the requirements involving flight test responsibility and may be further limited to specific paragraphs of the AWM. The project manager retains responsibility for determining when compliance has been shown with all appropriate requirements.

  3. Once the conditions have been satisfactorily met, the flight test specialist will notify the project manager in writing that there are no outstanding flight test issues related to the certification of the requested design change, and make a recommendation for approval. The flight test specialist may also sign the compliance plan for those paragraphs for which compliance was found, if so requested by the project manager.

  4. When the program has been completed, and an approval has been issued, the region should send one copy of the final debrief note item responses, the flight test report and approved AFM Supplement, if applicable, and the Supplemental Type Certificates approval document to the flight test specialist.

Table F-1

Statement of Suitability for Flight Test

Aircraft Type/Model:


Serial Number:

Description of Design Change(s):

Statement of Suitability for Flight Test:
This is to certify that I have reviewed the subject design change and that I have reasonable assurance that compliance could be found with all applicable design requirements, except for those requirements that shall be substantiated by flight testing. I consider the aircraft to be safe for flight.

Authorized Person: _________________________           Date:______________________________

(This information can be sent by mail or electronically)

Table F-2

Example of Flight Test Safety Checklist

Test Purpose
Flight Crew
Flight Date
Ref. Checklist Item N/A Yes No
1. Crew Considerations
1.1 Are all crewmembers fit to fly and sufficiently rested?
1.2 Is the crew familiar with operating the aircraft and its test equipment?
1.3 Have all crewmembers had sufficient time to consider the content of the test plan and understand the purpose of the tests?
1.4 Are all crewmembers confident in their ability to carry out the tests required, safely and efficiently?
1.5 Have all ground crewmembers been briefed adequately?
2 Test Planning
2.1 Has a draft AFM or equivalent information covering operation of the aircraft been reviewed?
2.2 Are exceedances of any AFM limitations permitted and agreed to?
2.3 Are any additional flight limitations specified and agreed to?
2.4 Have any specific or unusual limitations been discussed and understood?
2.5 Has the written flight test plan been agreed to?
2.6 Is the flight permit valid for the proposed flight tests?
3 Equipment
3.1 Are adequate communication systems available to all crewmembers?
3.2 Has all required safety equipment been installed and tested as necessary?
3.3 Is survivability equipment adequate for the flight taking into account the testing environment (e.g. over water, winter)?
3.4 Have the Flight Data Recorder and Cockpit Voice Recorder been tested as necessary?
4 Configuration
4.1 Has a conformity inspection been performed?
4.2 Is the aircraft, without the test modifications, in the approved configuration?
4.3 Do aircraft test modifications correlate with required configuration?
4.4 Has disposition of all snags since last flight(s) been reviewed?
4.5 Has significant maintenance action since last flight been reviewed?
4.6 Has all required maintenance been accomplished?
4.7 Is aircraft weight and balance report valid and current for the test configuration?
4.8 Is aircraft correctly loaded in accordance with the weight and balance report?
4.9 Is flight test ballast adequately secured?
5 Safety Planning
5.1 Has the Flight Test Safety Assessment been reviewed?
5.2 Has the flight test plan been briefed?
5.3 Have all required ground tests been completed?
5.4 Have previous tests results been reviewed?
5.5 Have anticipated results (including failures of the system under test) been reviewed?
5.6 Have any special test procedures been reviewed (covered in checklists if necessary)?
5.7 Have build-up techniques been developed?
5.8 Have criteria for discontinuing the test or flight been agreed to?
5.9 Have all safety/recovery procedures been briefed?
5.10 Have escape drills been adequately briefed?
5.11 If devices/interlocks are to be disabled during the flight (e.g. circuit breakers, warning horn, power lever baulk), have procedures been put in place to re-enable the devices following test?
5.12 Have all safety procedures for formation flight (e.g. chase aircraft), been briefed?
5.13 Has Crash Fire Rescue been informed and briefed?
6 Miscellaneous
6.1 Have weather minimums been agreed to?
6.2 Have atmospheric conditions for the tests been agreed?
6.3 Have time of day limitations (e.g. sufficient daylight for rescue operations) been agreed to?
6.4 Is usable fuel commensurate with expected fuel usage during test flight and adequate reserves?
6.5 Are takeoff and landing runway(s) suitable?
6.6 Is the test area suitable?
6.7 Does applicant have insurance coverage in place?
6.8 Has a copy of the flight permit, a copy of the flight test plan and the estimated time of arrival for the flight been left on the ground with a responsible third party?
7 Other
Completed By:




(Project XXXX)

Step 1: Identify the proposed change to the aeronautical product.

(Section 4.1 of AC 500-016)

The changes are as follows or are detailed in the
listed document(s):

Note: A G-1 Issue Paper may be required to track/document the decisions at Step 2 and Steps 5 through 8, and to detail the concluded certification basis.

Step 2: Is the change substantial?

(Section 4.2 of AC 500-016)

checkbox YES  A new type certificate is required. CPR Decision Process is Closed.

checkbox NO  Proceed to Step 3

Step 3: Will the latest standards be used?

(Section 4.3 of AC 500-016)

checkbox YES  Certification basis to use latest standards.  Proceed to Step 8.

checkbox NO  Proceed to Step 4.

Step 4: Group changes into related and unrelated groupings.

(Section 4.4 of AC 500-016)

The changes are grouped as detailed in the listed document(s):

Note:  For multiple groupings, continuation of this process should be split to separate decision records.

Step 5: Is the proposed change significant?

(Section 5.0 of AC 500-016)

checkbox YES  Proceed to Decision.

checkbox NO  Compliance may be shown to earlier standards. Certification basis to be defined and documented as indicated (below). Proceed to Step 8.

Decision: Will the latest standards be used?

checkbox YES  Certification basis to use latest standards. Proceed to Step 8.

checkbox NO  Proceed to Step 6, addressing each area separately (see below).

Identification of Affected Areas:

The area(s) affected by the proposed change have been detailed in Certification Plan document number(s):

Step 6: Is this area affected by the proposed change? (Ask for each area)

(Section 6.1 of AC 500-016)

checkbox YES  Proceed to Step 7.

checkbox NO  Compliance with the latest standards is not required. Compliance may be continued to be shown with the existing certification basis.

Step 7:  Do the latest standards contribute materially to the level of safety and are they practical?

(Section 6.2 of AC 500-016)


checkbox Continuation Sheet(s) Attached

checkbox YES  Certification basis to be established using latest standards.

checkbox NO  Compliance with the latest standards is not required. Compliance may be shown to earlier standards. Certification Basis defined or documented as indicated in below.

Note:  Several standards may apply to each area and the assessment may differ from standard to standard. Indicate Yes if compliance with any latest standard(s) will be required.  Indicate No only if earlier standards are to be applied.


A delegate may develop a proposal for the Yes/No decision of Step 7.  TCCA will make the final determination.

Step 8:  Is the proposed Basis of Certification Adequate?

(Section 8.0 of AC 500-016)

checkbox YES  Stop! CPR Decision Process is Closed.  Determination of Certification Basis is Complete!

checkbox NO  Basis of certification may require later airworthiness standards or Special Conditions – Consult TCCA.

Certification Basis

The certification basis is as follows or as detailed in the listed document(s):

Under the delegated authority, I have examined the change in type design listed above according to established procedures and hereby determine, to the best of my knowledge and belief, that it is. (check one)

checkbox substantial, pursuant to section 521.153 of the CARs

checkbox significant, pursuant to subsection 521.158(3) of the CARs

checkbox not significant, pursuant to subsection 521.158(3)  of the CARs

Name and Signature of Authorized Person


This form can be found in RDIMS 6198464

Transport Canada documents or intranet pages mentioned in this document are available upon request.

Date modified: