February 04, 2026

Steven Bentley

Introduction – Executive Summary: The Framework

The regulatory relationship between Brazil (ANAC – Agência Nacional de Aviação Civil) and the US (FAA) is governed by two primary documents.

  • BASA (The Treaty): The high-level executive agreement signed between the two governments. It establishes the legal framework for cooperation and technical assistance in aviation safety.
  • IPA (The Rulebook): The technical document that defines how the BASA is executed day-to-day. It outlines specific procedures for certifying aeronautical products, approving maintenance, and overseeing production.

Note on Terminology

  • EASA  FAA: Uses a TIP (Technical Implementation Procedures).
  • ANAC  FAA: Uses an IPA (Implementation Procedures for Airworthiness).

While they serve the same function, using “TIP” in an ANAC context is technically incorrect and can cause confusion regarding specific validation triggers that differ between the two agreements.

Key Features of the FAA-ANAC IPA

The IPA is designed to move away from “shadow certification” (re-doing the work) toward “validation” (verifying the work).

  1. Risk-Based Validation Principles

The IPA operates on a risk-based approach where the Validating Authority (VA) relies on the Certifying Authority (CA) to the maximum extent possible. The level of review is determined by the Level of Involvement (LOI).

  1. Three Streams of Validation

 

Unlike older agreements that required technical review for almost everything, the IPA introduces three distinct streams for Design Approval:

Acceptance (The “Fast Track”):

    • Feature: The VA issues no technical approval and conducts no review. The CA’s approval is automatically accepted.
    • Scope: TSO appliances, replacement parts, and most minor changes.

Streamlined Validation:

    • Feature: The VA issues a certificate (e.g., STC or TC) but does so without a technical data review.
    • Scope: “Basic” projects where the VA has high confidence and no new safety risks are introduced.

Technical Validation:

    • Feature: The VA actively reviews technical data and compliance findings.
    • Scope: “Non-Basic” projects involving new technology, novel designs, or areas where the CA has limited experience.
  1. The “Basic” vs. “Non-Basic” Classification

This is the core filter of the IPA. The Certifying Authority (not the applicant) proposes the classification:

Best Practice:

Pre-Application Meeting: Hold a technical briefing before the formal application to agree on the “Non-Basic” elements.

Conservative Classification: If a design involves a new “method of compliance” (even if simple), flag it. It is faster to have a “Non-Basic” project with zero LOI (Level of Involvement) than to fight a re-classification mid-project.

Draft the Work Plan for Them: Do not wait for the FAA/ANAC Program Manager (PM) to write the plan. Submit a draft Work Plan with your application, clearly listing which regulations you believe require VA involvement and which do not.

Focus on Differences: In your compliance plan, explicitly highlight where the ANAC regulations differ from 14 CFR (US regulations). If they are identical, argue for zero involvement.

The “Shadow” Strategy: If you must do concurrent validation, treat the VA (e.g., FAA) as if they are a partner, not just a validator. Ensure the Certifying Authority (e.g., ANAC) is invited to all major technical meetings so they witness the VA’s concerns in real-time.

Harmonized Compliance Documents: Create a single “Compliance Checklist” that maps the requirements of both 14 CFR (FAA) and RBAC (ANAC).

Joint Closure: When closing a technical issue (like a flammability test or software glitch), ask for a joint signature or email concurrence from both authorities on the final report to prevent re-opening the issue later.

Level of Involvement (LOI)

This section defines exactly what ANAC (VA) will review. The goal is to limit this list to “risk-based” items only.

  1. Generic Validation Items (GVI)(Administrative items ANAC requires for every project)
  • [ ] Review of the Master Data List (MDL).
  • [ ] Review of the Flight Manual Supplement (AFMS) – specifically for Portuguese language translation accuracy.
  • [ ] Issuance of the Brazilian Type Certificate/STC.
  1. Project Validation Items (PVI)(Technical items specific to this interior mod)

Communication & Coordination

  • Focal Points:
    • FAA Project Manager: [Name/Email]
    • ANAC Project Manager: [Name/Email]
    • Applicant Administrator: [Name/Email]
  • Issue Resolution: Technical issues will be documented using the Certification Issue Paper (CIP) process.
  • Meetings: Bi-weekly status calls to track the LOI items listed above.Best Practices

The “Dual Unit” Rule:

    • Do not delete the imperial units (lbs/inches) if the aircraft is US-registered or might return to the US.
    • Recommendation: Use a “slash” format. Example: “MAX WT 50 LBS / 22 KG”. This satisfies both FAA (primary certification) and ANAC (validation).

Next Steps

Sofema Aviation Services (SAS) and Sofema Online (SOL) Provide Classroom, Webinar & Online training please see the websites email [email protected]

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Tags:

BASA, ANAC - Agência Nacional de Aviação Civil, IPA, shadow certification, Level of Involvement (LOI), Certifying Authority, Conservative Classification, Certification Issue Paper (CIP), Program Manager (PM), Project Validation Items (PVI)