February 04, 2020

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Sofema Aviation Services provides a brief introduction to the concepts and considers recent amendments to Part 21.

Changes to EASA Part 21 Regulation 748/2012

To incorporate ED Decision 2019/003/R introducing AMC/GM to part-21 for proportionality and simplification of airworthiness and environmental certification regulations for small aircraft.

To incorporate Commission Delegated Regulation (EU) 2019/897 of 12 March 2019 amending Regulation (EU) No 748/2012 as regards the inclusion of risk-based compliance verification in Annex I and the implementation of requirements for environmental protection, and the associated ED Decision 2019/018/R amending the AMC and GM to Annex I (Part 21) — Issue 2, Amendment 9.

Level of Involvement (LOI)

The new EASA approach for the definition of Level of Involvement (LOI).

On 3 June 2019, the European Commission has published Commission Regulation (EU) 2019/897 amending Regulation (EU) No 748/2012 as regards of the inclusion of risk-based compliance verification and the implementation of requirements for environmental protection.

The main element of this Regulation is an amendment of the certification process in respect of what is commonly referred to as “Level of Involvement (LOI)”.

How Does LOI – Work?

Applicants will have to propose a break-down of the certification programme into meaningful groups of compliance demonstration activities and data (ref to point 21.A.15(b)(5)and similar provisions).

Then, for each identified group of compliance demonstration activities and data, the affected applicants will have to perform a risk assessment considering the likelihood of an unidentified non-compliance with the type-certification basis, operational suitability data certification basis or environmental protection requirements and the potential impact of that non-compliance on product safety or environmental protection.

Based on this assessment, the applicant shall make a proposal for the Agency’s involvement in the verification of the compliance demonstration activities and data.

EASA will determine its LOI considering the proposals submitted by the affected applicants.

In the areas of handling qualities and minimum performance, the criticality of an unidentified non-compliance may be classified as being critical if it could be related to the airworthiness requirements of the certification basis, or to a non-adherence to an agreed AMC.

A non-compliance is judged to be critical and, therefore, the CDI should also be classified critical, in particular, but not only, if one or more of the following conditions are met:

(i) The part of the change covered by the CDI establishes or affects aircraft performance;

(ii) The part of the change covered by the CDI establishes or alters the aircraft’s flight envelope;

(iii) The part of the change covered by the CDI establishes or alters the handling qualities of the aircraft including the flight control functions (e.g., functional performance of the flight control laws, gains) or the flight protection or flight crew alerting system.

If at the time of proposing or determining the LOI, the above conditions are not certain, and if the applicant still needs to carry out specific compliance demonstration activities in order to verify whether these conditions are met, the CDI shall be classified as ‘critical’.

Sofema Aviation Services & Sofema Online provide regulatory & vocational training compliant with EASA Part 21 Subpart G & Part 21 Subpart J. For additional information please contact team@sassofia.com

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easa part 21, Level of Involvement, Compliance Demonstration Items, LOI, CDI