AIRCRAFT MODIFICATION FLIGHT TEST

CONSIDERATIONS
INTRODUCTION
Contents
1.
2.
3.
4.
5.
6.

Introduction
Types of Modification
Modification Approval Process
Flight Test Requirements
Flight Test Methods
Flight Test Safety

Annex A Terms and Abbreviations

Annex B Certification Flight Test References
References

Part 21 of CASR 1998, Certification and Airworthiness Requirements for

Aircraft and Parts.
CASA Advisory Circular 21-13(0) Australian Designed Aircraft Type
Certification, September 1999.
CASA Advisory Circular 21-15(1) Supplemental Type Certificates,
September 2009.
CASA Advisory Circular 21-40(0) Measurement of Airspeed in Light
Aircraft Certification Requirements, April 2005.
CASA Advisory Circular 23-1(0) Airspeed Airworthiness Standards for the
Installation of Equipment that Protrudes into the Airflow, 2013.
CASA Advisory Circular 21-47(0) Flight Test Safety, April 2012.

Purpose
1.
This paper has been produced in order to provide some background
information and guidance regarding the flight test considerations relating to
modifying aircraft in accordance with Civil Aviation Safety Regulations (CASR) 1998
Part 21 Subparts E and M. People responsible for the certification and flight testing
of aircraft incorporating such modifications may find it useful.
Acronyms
2.

Terms and abbreviations are listed at Annex A.

Definitions
3.

For the purposes of this document:

Certification Flight Testing means those flight tests conducted for the purpose of
demonstrating, or verifying, compliance with the applicable airworthiness standard.
Experimental/Developmental Flight Testing means those flight tests conducted for
the purpose of defining or expanding an aircrafts flight envelope.
Flight Test means the process of developing and gathering data during operation and
flight of an aircraft and then analysing that data to evaluate the flight characteristics of
the aircraft (Sub regulation 21.35 of CASR 1998 refers). In this paper flight test does
not mean a practical test of a persons aeronautical knowledge and flying skill (as per
Part 1 of CAR 1988).
Background
4.
Australian aircraft are often subject to modification under CASR Part 21. This
can occur to examples that have either been type certificated in Australia or
certificated overseas and then accepted for use in this country through the issue of a
Type Acceptance Certificate (TAC). Others, for instance, amateur-built aircraft
operating under the Experimental Certificate system, may also be exposed to
modification projects. The Supplemental Type Certificate (STC) process is one
method under which design approval can be granted Advisory Circular (AC) 2115(1) refers. Fully type-certificated aircraft, once modified, must continue to meet the
requirements of their certification basis and the associated airworthiness standards.
With those modifications that have flight type implications continued satisfaction of
the relevant clauses of the airworthiness standards will probably require some form of
flight testing or assessment be conducted. The aims of this paper are to provide
background information on modification flight testing requirements and to offer
guidance regarding the procedures and techniques that can be employed. While the
requirements are applicable to all aircraft the information provided is focussed toward
flight testing of those at the lighter-weight and lower-speed ends of the scale,
principally those in the primary, normal, utility or acrobatic categories.
TYPES OF MODIFICATION
5.
Those modifications that may have flight type implications would include any
that influence the performance or handling characteristics of the aircraft, any systems
changes liable to affect aircraft operation or have consequences for the pilot and crew,
and anything that requires amendment to the Aircraft Flight Manual (AFM).
6.
Performance and Handling Characteristics. Modifications
that are likely to affect an aircrafts performance or handling
characteristics are as follows:
a.

Any piece of equipment that protrudes into the airflow or

any alteration to the basic shape of the airframe. These
types of modification normally introduce an increase in
the aircrafts overall drag index and will consequently
degrade performance capabilities. Stability and control
characteristics may also be altered if the wake of the
attached equipment affects the airflow over the wing or
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empennage, and especially if it impacts downstream

flight control surfaces. The creation of such effects is
not necessarily restricted to large protuberances; even
small attachments, if strategically located, may
generate significant vortices.
Another important
consideration relates to any changes to the airflow over,
or the pressure field around, pitot tubes or, more
significantly, static ports. Such effects would require a
recalibration of the aircrafts airspeed-indicating and
static pressure instrumentation (see paragraph 12.a
below). Examples of protuberance type modifications
would be:

b.

c.

(1)

Camera, laser or radar pods (or other similar

stores) mounted on aircraft wings, struts, skids or
undercarriage legs, etc.

(2)

Cargo pods or panniers, including those typically

fitted to the underside of an aircrafts fuselage.

(3)

External fuel tanks.

(4)

Agricultural or fire-fighting spray equipment.

(5)

Radio or avionics antennae.

(6)

Nose booms, tail-stingers, or equipment mounted

at wing-tips.

(7)

Ski or float landing gear.

Wing or profile modifications intended to improve the

aerodynamic qualities of the aircraft. Such modifications
would include:
(1)

Changes to the size, profile or shape of wings,

wing-tips, empennage or rotors.

(2)

Introduction of fences, vortex generation (VGs) or

boundary layer control equipment.

(3)

Drag reduction for example, fuselage fairings,

undercarriage spats.

Any changes to flight control systems. For example:

(1)

Changes to primary flight control surface, or tab,

size or profile.

(2)

Changes to flight control surface range or rate of

movement.
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(3)

Tab-gearing ratios, spring sizes, control runs, etc.

(4)

Changes to automatic flight control, auto-pilot and

stability augmentation systems.

d.

Engines and propellers. Any modifications or changes to

the powerplant or propeller installations that involve a
change in power output will affect the performance
capabilities of the aircraft and can also easily affect
handling and stability characteristics. Propeller changes
can include alterations to slipstream and gyroscopic
effects.

e.

Weight and/or CG. Proposals to change, normally to

increase, an aircrafts maximum take-off weight (MTOW)
will affect performance and possibly affect some
handling characteristics. Proposals to alter, increase,
centre of gravity (CG) ranges or limits will probably alter
handling characteristics and may affect some
performance figures. Changes to other weight limits,
e.g. maximum landing weight (MLW), may also require
flight type consideration.

7.
Systems Changes. Popular modifications are those that
involve the replacement, improvement or addition of aircraft
systems. Any systems changes that have implications in the cockpit
or that otherwise affect the way the aircraft is operated will require
flight type assessment to ensure continued compliance with the
requirements of Subparts D, E, F and G of the applicable
airworthiness standard.
Assessment in these cases normally
involves human factors (HF), operability and effectiveness
evaluations. Some systems modifications can also result in flight
characteristics changes.
Both quantitative and qualitative
assessments may be required.
Specific consideration will be
included with modifications that affect operations under the
Instrument Flight Rules (IFR) with complications often raised should
flight into known icing conditions be involved. Systems that can be
subject to modification include the following;
a.

Cockpit controls.

b.

Engines, propellers, fuel systems.

c.

Hydraulics, landing gear, steering, brakes.

d.

Flight instruments.

e.

Electrics.

f.

Avionics and communications.

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g.

Integration and automatic flight systems.

h.

Electronic flight bags.

i.

Cockpit environment, pressurisation, ventilation.

j.

Lighting.

k.

Fields of view.

l.

Seating, harnesses.

m.

Cabin environment, entry and exit.

8.
Aircraft Flight Manual. Many modifications require an
amendment to the Aircraft Flight Manual (AFM) or the generation of
a Flight Manual Supplement (FMS). Flight test or operational aircrew
should be involved with the writing and review of these documents.
MODIFICATION APPROVAL PROCESS
9.
The certification approval processes for aircraft modifications follow those for
the aircraft itself AC 21-13(0) refers. Continued compliance with all requirements
of the original, or updated, certification basis1, including all clauses of the
applicable airworthiness standards, must be redemonstrated, or at least reclaimed.
CASA, or an Authorised Person, must then agree that compliance has been found.
AC 21-15(1) describes the certification process relevant to major changes to a type
design approved under an STC. It also makes reference to changes that can be
approved under CASR Part 21M. In either case the same basic certification process
applies, the essential difference relevant to approvals under Part 21M is the reduced
involvement of CASA itself.
FLIGHT TEST REQUIREMENTS
10. Modifications will require individual analysis and the flight
testing requirements relating to the certification of each modified
aircraft may range from nil to substantial. In all cases the flight test
phases are the same as those applicable to accreditation of the
aircraft itself. Firstly, the applicant is responsible for developmental
flight testing and then for the testing required to demonstrate or
claim continued compliance with the relevant clauses of the
certification basis.
CASA, or an Authorised Person, may then
conduct additional flight tests to validate the applicants results and
compliance claims.
11. Compliance Matrix. A compliance matrix that includes all
relevant clauses of the applicable certification basis should be
generated.
Often, in an attempt to save on paperwork, a
1

See AC 21-15(1) Section 6.2 Design Standard. The design standard for an STC is specified in CASR
21.101(1) as either the regulations mentioned as the certification basis in the TC or the applicable regulations in
effect at the time of application, plus any other amendments that CASA is satisfied are directly related.

compliance matrix for a modification project will be limited to only

those clauses adjudged relevant. However, unless the modification
is one that has absolutely no flight type implications (for example,
an internal structural change that does not affect the aircrafts
weight and balance limits) this matrix is better off including all flight
type clauses. Occasionally, a change in the parameters satisfying
one requirement can have a ripple effect. Those clauses that are
then, indeed, found to be unchanged can be designated Not
Applicable (N/A). Or, in cases where compliance is being claimed
through some method other than flight test (e.g. analysis or
similarity) the reasoning can be included, or referenced, in the
comments column of the matrix. Thus, a complete analysis of the
certification basis is presented to the certification authority and the
possibility of overlooking an applicable requirement is minimised.
12. Noteworthy Items. Some types of modification with flighttype implications can draw special attention when testing
requirements are considered. As follows:
a.

Pressure Error Corrections. Any modification that

changes the pressure field around the aircraft has
potential to affect the errors introduced to the aircrafts
airspeed and altitude measurement systems. This is
particularly relevant for protuberances or attachments
upstream of, or near, the aircrafts static ports. Should
there be any question that the airflow around the static
ports will be altered by the modification then an
airspeed system recalibration should be carried out
(calibration requirements are discussed at AC 21-40(0)
Measurement of Airspeed in Light Aircraft Certification
Requirements). Major changes to the PEC data may
then require redefinition of the operational airspeeds
presented in the AFM or FMS. Changes to V-speeds will
also need to be taken into account during any
performance and handling testing that is required as a
result of the modification.

b.

Performance Requirements. Modifications which are

likely to cause changes to the performance capabilities
of an aircraft can be considered from three aspects:
(1)

Where a modification is expected to cause a minor

but noticeable increase in drag, which is then likely
to result in a small decrement in performance, the
certification authority may accept a reduced
testing philosophy to verify the predicted outcome.
This would entail the accurate measurement of the
decrement as it applies to the most critical
performance
requirement
followed
by
the
conservative factoring of related requirements
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based on the first set of test results. Such would

depend on the basic, unmodified, aircraft
comfortably meeting all the relevant certification
class limits; for example, the maximum stall speed
or minimum climb rate requirements stipulated in
FAR 23 for a normal category aircraft.

c.

(2)

Where a modification may result in a small but

noticeable
increase
in
performance
the
certification authority may again accept a claim of
compliance with the performance clauses based
on the reduced testing philosophy, provided the
applicant does not plan on claiming any credit. In
this case, the original figures would be retained in
the AFM even though the modified aircraft would
be capable of outperforming them.

(3)

Significant
changes,
or
any
claims
for
improvement, in performance would require a
comprehensive retesting of the modified aircraft
such that continued compliance with the standards
can be confirmed and accurate data can be
provided to the operational pilot via an AFM
amendment or FMS. 2

Spinning. Single-engine normal, utility and acrobatic

category aircraft must meet the various spinning
requirements set down in clause 221 of the applicable
airworthiness standard. Spin flight testing can be an
arduous exercise involving elements of elevated risk.
For modifications with limited effect on the flying
qualities of the aircraft the certification authority may
accept a claim of compliance based on analysis as long
as the other handling qualities requirements, especially
the stalling characteristics, of the modified aircraft have
been tested and been shown to have suffered minimal
effect. Nevertheless, spin testing of the modified aircraft
is recommended in the following circumstances:
(1)

Moments of inertia have changed by more than

approximately 5 per cent.

(2)

Power available increases

approximately 10 per cent.

(3)

The modification introduces major changes to the

aircrafts flight control system.

by

more

than

As an example of the effect a modification may have on performance; the introduction of a standard profile cargo
pod on a normal category single-engine aircraft can increase take-off distance figures by 10 to 15 per cent.

d.

(4)

The modification includes the incorporation of

canards.

(5)

The modification introduces major wing changes.

(6)

The modification introduces major changes to the

airflow over the aircrafts empennage.

Vibration, Buffet and Flutter. Flight testing for any

modification that is likely to affect the flight
characteristics of the aircraft should include checks that
compliance with the vibration and buffet requirements
has not been compromised. This is especially relevant
where the modification includes an attachment or a
protuberance into the airflow. In these cases testing
should assess both the effect the modification may have
on the vibration characteristics of the aircraft overall, as
well as the vibratory behaviour of the modification itself.
Specialised
cameras
and
other
flight
test
instrumentation may be required if direct observation of
the mod is not possible. Flutter characteristics should
be reassessed after major modifications particularly if
the aircraft structure, the airflow over control surfaces,
or the flight control system itself, has been altered.

13. Limit Airspeeds and Flight Envelopes. When flight testing

a modified aircraft the general aim would normally be to check that
it continues to meet certification requirements out to the edges of
the flight envelopes (e.g. weight / CG; airspeed / altitude) originally
applicable to the basic aircraft (sometimes known as Limit Basic
Airframe (LBA)). Nevertheless, some modifications may require
adjustment to the LBA envelopes as follows:
a.

Contraction.
Modifications may affect the flying
qualities of the aircraft such that, for compliance with
the requirements of the airworthiness standard to
continue to be met, additional limitations, more
stringent than those established for the basic aircraft,
must be imposed.
For example, certain handling
requirements may only be acceptable if the aft limit of
the CG range is moved forward, or performance
requirements satisfied if weight constraints are applied,
or vibration and buffet requirements met if maximum
speed restrictions are introduced.
All limitations
associated with a specific modification, or combination
of modifications, must be provided in the FMS. In the
case of speed limitations the inclusion of a cockpit
placard is recommended e.g. Maximum Airspeed when
fitted with the ACME Camera Pod 100 KIAS. See also
AC 23-1(0).
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b.

Expansion. Modifications, significantly engine changes, which

allow for substantial increases in performance (as per paragraph
12.b(3) above) may well also require an expanded redefinition of
operational limits after results of the flight test program are
consolidated. In such cases the FMS must contain all new limits and
cockpit placards should be changed. Applicants should also be aware
that should a substantial increase in capability be achieved, such that
the design cruising speed (VC) is increased, then a revision of the
velocity-load factor diagram may be required (cf, for example, FAR
23.333 and 23.335). In these cases a recertification exercise resulting
in a change to the TC is probably warranted.

FLIGHT TEST METHODS

14. Any certification flight test program that is to be conducted on
a modified aircraft must be completed using the guidance material
relevant to the certification basis, or using agreed flight test
techniques and data reduction methods of equal engineering rigour.
A list of some relevant references is provided at Annex B.
15. While the same methods and test techniques are applicable
there may be scope for simplification in the way in which they are
applied. The use of comparative tests is one useful method which
can be especially applicable to the modification of a single aircraft
under CASR Part 21M. In these cases, the particular aircraft, which
is often already well into the ageing aircraft class, is tested in its
unmodified state and the detailed results recorded.
The
modification is then incorporated and the aircraft subjected to the
same flight tests again under, as nearly as possible, the same test
conditions. The two sets of results are compared and the effects of
the modification defined. Additionally, depending on the projected
magnitude of the effects of the modification the certificating
authority may accept testing at the most operationally demanding
conditions followed by some extrapolation to other points about an
envelope.
16. This comparative method should only be applied in cases
where compliances with class limits are not being threatened. If
doubts about such certification basis requirements exist then the
flight test examination of the modified aircraft should be conducted
against the specific airworthiness standards clause and not just the
capabilities of the unmodified aircraft.
FLIGHT TEST SAFETY
17.

The information provided at AC 21-47(0) Flight Test Safety is applicable.

ANNEX A
TERMS AND ABBREVIATIONS

Symbol/Term

Definition

AC
AFM
CAR
CASA
CASR
CG
CoA
FMS
FTS
HF
ISA
LBA
MLW
MTOW
PEC
TAC
TC
TP
VG

Advisory Circular
Aircraft Flight Manual
Civil Aviation Regulations (1988)
Civil Aviation Safety Authority
Civil Aviation Safety Regulations (1998)
Centre of Gravity
Certificate of Airworthiness
Flight Manual Supplement
Flight Test Schedule
Human Factors
International Standard Atmosphere
Limit Basic Airframe (or Aircraft)
Maximum Landing Weight
Maximum Take-Off Weight
Pressure Error Correction
Type Acceptance Certificate
Type Certificate
Test Pilot
Vortex Generator

ANNEX B
CERTIFICATION FLIGHT TEST REFERENCES
The primary sources of information regarding procedures and flight test techniques for use during
CASA certification flight testing are as follows:
1.

CASA Type Certification Procedures Manual

http://www.casa.gov.au/manuals/regulate/type/index.htm

2.

CASA Advisory Circular 21.10(0) Experimental Certificates http://www.casa.gov.au/rules/1998casr/021/021c10.pdf

3.

CASA Advisory Circular 21.13(0) Australian-Designed Aircraft Certification

http://www.casa.gov.au/rules/1998casr/021/021c13.pdf

4.
CASA Advisory Circular 21.40(0) Measurement of Airspeed in Light Aircraft Certification
Requirements
http://www.casa.gov.au/rules/1998casr/021/021c40.pdf
5.

FAA Advisory Circular 23-8B Flight Test Guide for Certification of Part 23 Airplanes.

6.
FAA Advisory Circular 25-7A Flight Test Guide for Certification of Transport Category
Airplanes.
7.

FAA Advisory Circular 27-1B Certification of Normal Category Rotorcraft.

8.

FAA Advisory Circular 29-2C Certification of Transport Category Rotorcraft.

9.

FAA Advisory Circular 90-89A Amateur-Built and Ultralight Flight Testing Handbook

For links to FAA Advisory Circulars see the FAAs Regulations and Policies page at:
http://www.faa.gov/regulations_policies/
Web links for some of the principal flight test societies, schools and organisations are as follows:
10.

Flight Test Society of Australia - http://www.ftsa.org.au/

11.

Society of Experimental Test Pilots - http://www.setp.org/

12.

Society of Flight Test Engineers - http://www.sfte.org/

13.

Flight Test Safety Committee - http://www.flighttestsafety.org/index.html

14.

National Test Pilot School - http://www.ntps.com/

15.

Flight Test Safety Data Base - http://pbma.nasa.gov/ftsdb/Home.aspx

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