S easonal

T echnical
C ommunication

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INDEX
Editorial3
Inside the story 4
Rulemaking rotorcraft – External installations
Certification Memo 5
Technical subject -
Chemical oxygen generators security concerns 6
Rulemaking – New part 21, new privilege 7
International cooperation - Bilateral agreement
and “Outside track II process” with China 9
Questions and answers – Online publication 10
Upcoming Events 11
 Dear e-STC Newsletter readers,
EDITORIAL the summer is often mistaken for a moment in year during which no interesting changes are to be expected.
For this edition of the e-STC
Newsletter, special thanks to:

Once again, last summer has proven to be all but quiet. This Newsletter is highlighting a few topics that will possibly impact your business models, Michele Ambrosio,
your procedures and your design data. Junior PCM Large Aeroplanes

The growing importance of international relationships for aviation is all over the press. In particular, the EU-China bilateral agreement has taken a giant José-Miguel Angulo Manso
leap toward regular validation of STC processes. You will find further details in our dedicated article. PCM VTOL

While I am delighted to regularly highlight how innovative the STC holders solutions can be, the regular business that pays the bills is not forgotten. Ralf Bader,
Strengthening the EASA –Industry relationship, the Large Aeroplanes department has given more weight to the STC coordinator role. This led to the Chief PCM EU products
implementation of new activities this summer.
Phillip Brooke,
This means in particular more resources dedicated to the strategic management of the STC projects. The five staff members involved in this activity is Certification policy officer
moreover directly attached to the head of department.
Charles Leboeuf,
As STC coordinator, my aim is to ensure the expected level of safety, industry support and Agency visibility. This can be reached by enhancing the EASA Chief PCM Validation process
STC projects management with regards to standardisation, efficiency and communication.
Jan Loncke,
Breaking down those high-level goals, several activities were identified which resulted in the following outputs (the list is not exhaustive) for our all benefit: VTOL OPS expert
- Agency visibility: the now well-established EASA STC Workshop induced the wider coordination activity
- Industry support: the use of a generic mailbox for all kind of questions related to STC [email protected] Thomas Manthey,
- Quality management: EASA-internal upfront check of all Large Aeroplanes STC Technical Visa Cabin Safety Expert
- Standardisation: EASA – National Aviation Authorities strengthened communication, strategic review of the PCM focal points list
- Efficiency: STC projects resources management centralised by the STC coordinator Thomas Ohnimus,
- Level of Safety: new and important technical topics highlighted in the STC Newsletter, FAQ webpage updated Senior Cabin Safety Expert
If there is one point to remember, it would be the fact that I am committed to support all STC applicants when they encounter difficulties that the
regular certification team cannot solve. Francesca Scaramuzzino,
Junior PCM Large Aeroplanes
I can regularly meet STC holders during the year, but be aware that you are over 500 organisations holding a Design Organisation Approval worldwide!
Thus please check the online possibilities to reach out to EASA (Website, EASA Youtube channel, Facebook, Twitter…) and spread this message to your Javier Vicedo,
colleagues! Senior EASA representative in China
and North Asia
In this edition, you will discover the following topics:
- inside the story: Jan Loncke, Rotorcraft expert
- rulemaking rotorcraft: external installations certification memo
- technical subject: chemical oxygen generators security concerns
- rulemaking: new part 21, new privilege
- international cooperation: Bilateral agreement and “Outside track II process” with China
- questions and answers – online publication
- upcoming events
I hope you will enjoy reading this Newsletter and look forward to hearing from you!

Sincerely,
Nicolas Duprez
EASA Large Aeroplanes Department - STC Coordinator

To unsubscribe from this Newsletter, send a message to [email protected].

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INSIDE THE STORY

EASA welcomed recently Jan Loncke as new VTOL OPS expert

When the job posting for my function was launched, it bore the title Rotorcraft OPS expert. By the time I could start at EASA the
title had changed to VTOL OPS (Vertical Take-Off and Landing vehicles Operations) expert.

This swift change is typical for the times we currently live in. There are many changes and challenges to come, such as urban air
mobility, e-VTOL (electrically powered VTOL) and other new technologies that find their way in for instance training devices.

Originally I graduated as an industrial engineer in electro-mechanics, but my operational experience as helicopter pilot in Helicopter
Emergency Medical Services, Offshore and Helicopter Hoist Operator was a factor that weight in my recruitment by EASA, next to
my professional history as quality manager, auditor and safety officer.

So within EASA, internally I’m here to help building a bridge between different EASA departments using my operational experience.

Outside EASA, I am here to support the industry. I will stimulate and work to improve multilateral cooperation aiming at safe, but
still profitable business. In a context of a level playing field I will keep an eye for proportionate solutions.

I am also striving towards a risk-based level playing field, in order to protect the final users, let’s say of air mobility in general,
which is you, me, everybody. Not limited to an acceptable level of safety in the operation of helicopters, but actively working
towards continuous safety improvement with all stakeholders involved, and that includes all forms of aviation where a ‘vertical
lift’ dimension of some sort comes in play.

So basically, the rotorcraft safety roadmap is my road book for the years to come. I’m looking forward to working with all of you
in this – fast-rate changing - environment where we face all these challenging evolutions.

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RULEMAKING ROTORCRAFT – EXTERNAL
INSTALLATIONS CERTIFICATION MEMO
The new Certification Memo is Similarity considerations On top of that, the CM is referencing the
meant to help all stakeholders on relevant standards and guidance materials that Expert TIPS
the path to a successful certified Most design changes installing external systems you will need in the frame of the generation of
project. Is your next project on the basic aircraft configuration are considered the compliance data. Such as the CM dedicated For flight tests, the effect of the external
possibly a minor change after all? “major”. to Night Vision Systems (NVIS) CM-FT-01 in the installation on the airspeed and altimeter
section about to the compatibility of external calibration is the first area to be assessed.
EASA can accept upon request by the applicant, installations with existing NVIS installations.
Certification approach standardised the additional of new camera/FLIR models to As a  matter of fact, if an external installation
External installations on helicopters and existing major changes/STCs as minor changes has the potential to impact the airflow around
Applicability
subsequent modifications are common changes when the criteria below are met: the pitot and/or the static port, the applicant
to the initial design to fulfil specific needs of - The same main original fixed structural Be aware that external fixtures extensive in terms should address this area before proceeding any
operators. provisions are kept and are installed in the of weight/surface/volume as large agricultural further with the flight test activity, as the results
same location on the helicopter kits, external rigid water tanks for fire-fighting of all the subsequent tests may be affected by
EASA certification experience has shown that operations, collapsible buckets or external the errors induced by the altered calibration.
non-TC holder applicants face often difficulties - The new camera/FLIR has: platforms used for Human External Cargo (HEC),
in defining the appropriate classification of o the same or lower weight hoist and cargo hook installations are considered
changes. The completeness of the compliance o the same or lower exposed surface to be outside of the scope of this CM.
demonstration is another challenge that led EASA area and
to issue a  dedicated certification memorandum o the same or greater ground clearance Examples of external installations to which this
(CM-21.A-D-002). than the one approved in the initial Certification Memorandum is applicable:
major change/STC and
The EASA VTOL Department has thus recently - External equipment boxes with fixed
developed a  CM on helicopter external - Establishing a “Similarity” statement might be equipment (fixed mass and CG)
installations to support Supplemental Type an acceptable MOC in the case of the original - Cameras
Certificate (STC) applicants during the certificate holder or appropriate internal - Searchlights
certification process. The initial edition of this competence in the required domains in order - Loudspeakers
CM aims at giving guidance to EASA applicants to be able to technically assess and justify
about the structural and flight disciplines only. such statements
Potentially this scope could be expanded to other Authors
disciplines in future revisions of the CM. Structures and flight tests compliance
Our special thanks go to the EASA structures expert Emily LEWIS and to the flight expert Francesco PAOLUCCI
More precisely and as already described in The CM is providing details about the different who have been the main technical contributors to the development of this CM, together with the Product
the document itself, the purpose of this CM is aspects of the necessary compliance data. Certification Manager Jose Miguel ANGULO.
to provide specific guidance for certification
of external installations on helicopters, for For instance, the approach to be used in order Should you have dedicated questions about this topic, do not hesitate to contact Jose-Miguel Angulo (Jose-
modifications for which CS 27/29.865 is not to demonstrate compliance with the vibration [email protected]).
applicable. It deals with external fixtures and requirements is mentioned with useful elements
devices that are non-extensive in terms of weight, such as the extent to which analysis can be used. The CM-21.A-D-002 has been published on the EASA website.
external surface are and/or volume.

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TECHNICAL SUBJECT - CHEMICAL OXYGEN
GENERATORS SECURITY CONCERNS
The Security concerns about certain types of oxygen generators are
impacting cabin completion centers’ business. Are you aware of the Expert TIPS
differences between EASA and FAA? For validation of a COG with the FAA, you might upfront elect to comply to CS 25.795
The security concerns (d) at amendment 17, which is harmonised with FAR 25.795 (d) at amendment 25-145,
making the FAA validation straightforward.

Oxygen systems have been a mandatory part of airliners configuration since the beginning of the pressurized
commercial flights.
You might be impacted anyway!
Their history, while being quite interesting from an engineering point of view, has known a remarkable
episode with the concerns raised about their security. However, be careful about the following case which might impact an STC project that has not considered
this issue in the first place.
The Chemical Oxygen Generators (COG) are easy to install as there is no need to connect them to oxygen
bottles through lines of pipes through the whole aircraft. For this reason, they are quite popular amongst Aircraft registered in the USA (or in countries applying the FAA rules) have to implement the measures in
the cabin completion centers’ design offices. FAA AD 2012-11-09 as per operational regulations. This is a security concern and the FAA is adamant in
having this significant difference in the applicable requirements being implemented before the import
In a nutshell, a vulnerability was discovered in the design of the COG which, if intentionally modified by certificate is issued.
a person having access to the aircraft (“tampering”), could have generated damages to the aircraft and to
the passengers. The analysis made by the relevant authorities concluded that the lavatories-installed COG In this case you might upfront elect to comply to CS 25.795 (d) at amendment 17, which is harmonised with
were most exposed to such tampering. FAR 25.795 (d) at amendment 25-145, making the FAA validation straightforward.

The regulators’ reactions The newcomer

Initially, the FAA published on March 8th, 2011 the AD 2011-04-09. The chemical oxygen generators technology is now confronted to the arrival of the pulse oxygen generators
technology on the market. The latter are gaseous systems not exposed to those particular security concerns.
This AD required that chemical oxygen generators installed inside of lavatories on certain transport category
airplanes be rendered inoperative in order to address the security concern. Compliance with this AD resulted Be aware that for this technology EASA has defined an Equivalent Safety Finding (for instance F-GEN9-1 for
in a  non-compliance with other US regulations and the AD contained a  provision to permit operation Boeing aircraft) for “Minimum mass flow of supplemental oxygen component qualification”. The proposed
notwithstanding those other requirements. aircraft manufacturer design does show compliance with 25.1443(c) but with the provisions of this ESF.

The FAA AD 2011-04-09 has since been superseded by AD 2012-11-09. The new AD required a terminating For STC holders, it means that the installation of pulse oxygen systems not certified already for the aircraft
action to reinstall a supplemental oxygen system in the lavatories that were modified per AD 2011-04-09. manufacturer might lead to the need for such an ESF at project level.

EASA certification is about security too!

Those AD were not adopted by EASA after a decision that was made at the European Commission level. Since
CS 25 amendment 17, the security issues related to the installation of COG are addressed by CS25.795(d) Security is now a topic that has many more implications for EASA applicants than in the past.
with AMC 25.795(d) giving guidelines for tamper-resistant designs.
In particular CS25.795 is addressing several issues that need to be carefully taken into account by Design
Those EASA requirements are not retroactive and, should your STC not elect to comply to CS 25 amendment Organisations. Several large transport aircraft include these requirements in their certification basis already.
17 or later amendment, are not applicable for EASA STC applications. The STC certification basis remains the
one mentioned in the aircraft EASA TCDS. Do not hesitate to ask the PCM in charge of your project in case of doubt!

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RULEMAKING – NEW PART 21, NEW PRIVILEGE

The New Part 21 is now available. The new privilege Scope for STC/Major changes
is opening new territories for STC holders. How can
you take benefit from this? Of course, there is a well-defined framework in order to grant this privilege
as per the below listed AMC and GM to part 21, how to extend the privileges
New Part 21 of a Design Organisation.

The last update to Part 21 changed significantly certain rights and Now sit down, get your first officer’s attention and go through the
obligations of design organisations and of the competent authorities. checklist below!

Regulation (EU) 2019/897 amending Regulation (EU) No 748/2012 and its Should you identify a set of projects that are sufficiently similar to benefit
Part 21 was adopted on March 12th 2019: it introduces not only the now from this privilege, check first that they meet the ‘eligibility’ criteria: KEY FACTS
often presented concept of risk-based Level of Involvement but also the  Existence of a reference project: at least one major change / Part 21 is a Regulation of the EU, it contains the
new privileges to approve “certain major changes” “certain major repairs” STC approved by EASA in the past rights and obligations of organisations and the
and “certain major STCs” without an application to EASA.  Similarity: The design, installation and operation are basically competent authorities.
the same as in such reference project
Regulation(EU) 2019/897 amends Regulation (EU)
Approved Design Organisations are entitled to apply for it since  Repetitiveness of the certification process: The certification
No 748/2012 and its Part 21.
June 23rd 2019. process is repetitive, i.e. identical to, or part of, the already
approved referenced project(s) Over 50 changes were made to the previous Part 21
 Performance and experience in previous projects in total.
New privilege
o ‘medium’ or ‘high’ level of performance during at least In particular, it introduces the concept of risk-based
Three new privileges are encompassed by the new wording in 21.A.263: the latest project referenced, to demonstrate ‘similarity’ Level of involvement and new privilege for Design
and ‘repetitiveness’ Organisations to approve “certain” Major Changes /
“(c) A holder of a design organisation approval shall be entitled […] o ‘low’ or ‘very low’ likelihood of an unidentified STC without application to EASA.
non-compliance for all the groups of compliance The new privileges entered into force on
5. to approve certain major repair designs under Subpart M to products demonstration activity and data (CDIs) 23 June 2019.
or auxiliary power units (APUs); […]
The new LOI approach becomes mandatory by
Does your project meet all criteria? 23 March 2020.
8. 
to approve certain major changes to a  type-certificate under
Subpart D; and If yes, make sure that this time you match none of the following limitations
on eligibility:
9. to issue certain supplemental type-certificates under Subpart E and  changes that require a revision to a type certificate data sheet
approve certain major changes to those certificates.” (TCDS) or a type certificate data sheet for noise (TCDSN);
 changes that require an amendment to the existing certification
We are focussing on the STC projects in the frame of this newsletter. basis by a special condition, equivalent safety finding, deviation
or ‘elect to comply’;
The main idea is to allow for one particular DOA holder to approve changes  changes that revise airworthiness limitations or operating
classified “Major” similar to those that have been previously approved limitations, unless otherwise agreed with EASA;
by EASA.  changes that are intended to be used as alternative means of
compliance to an airworthiness directive (AD);

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 changes that are made mandatory by an AD or that are the terminating action of an AD;
 changes that are classified as ‘significant’ in accordance with point 21.A.101;
 changes for which, in the affected area and for the operations for which the design is to be
certified, more conservative certification requirements are applicable which were not used in
the description of the EASA-approved procedure of the DOA holder,
DOA ltd.
DOA ltd.
 changes that affect the noise and/or emissions characteristics of the changed product, unless Approved
Approved
otherwise agreed with EASA;
 changes that affect a part or system, a single failure of which may have a catastrophic effect
upon the product, and for which critical characteristics have been identified, which should be
controlled to ensure the required level of integrity;
 changes to engines or propellers, a single failure of which may have a hazardous effect upon the
product, and for which critical characteristics have been identified, which should be controlled
to ensure the required level of integrity; and In order to obtain the privilege, DOA holders need to apply for an amendment of the TOA of their DOA with Form 82.
 changes for which a  non-compliance has been found in the referenced change during the
continued-airworthiness process. The related procedure needs to be prepared and submitted to your DOA Team Leader together with a “List
associated with the privilege” (defining the projects).
If your set of projects has passed the checklists hurdle, go on reading this article in order to find out how
the privilege can be granted. The related “justification document” will then need to be presented and approved.

Relevant guidance Those elements will then be assessed on a joint effort by the DOA Team Leader, the Product Certification
Managers and Experts who were exposed to your previous projects.
Keeping in mind that your EASA DOA Team Leader is your point of contact for this topic, you will find the
necessary guidance material in the AMC/GM to Part 21 Issue 2 amdt 9 published in August 2019. Should the outcome of the assessment be positive, your Terms Of Approval will be modified to encompass
your new privilege.
We consider here only STC and corresponding Major Changes.
The next approval under this privilege will thus be handled fully within your Design Organisation, i.e. without
The guidance material provide a lot of details that help to understand the nature of such privileged changes application to EASA.
regarding the eligibility and the related processes.
Roadshows
For instance, the repetitiveness is seen in terms of the applicable requirements and the compliance
demonstration. In this context, a ‘requirement’ means any element of the type-certification basis as specified Roadshows took already place in Rome, Prague and Cologne, during which this topic was presented with
in point 21.B.80, the operational suitability data (OSD) certification basis as specified in point 21.B.82 and many details. The lively exchanges between the presenters and the audience were very fruitful.
the environmental protection requirements as specified in point 21.B.85.
I went around and asked some participants for their reaction on one occasion:
The diagram below shows the references to the new guidance material and their related scope. - “the conditions are giving a very narrow spectrum of possible cases”
- “there is one only case I can think of for my business”
- “this is probably not a tool that can be used by smaller Design Organisations”
- “this is more appropriate to Organisations selling a standardised product rather that to those
making tailored solutions”

Conclusion

This change is new to EASA and to your approved design. Let us discover together how to make the best
use of it.

If you are willing to apply for this new privilege, you will need to read all details in the guidance material. Should you need further support about this topic, please contact your DOA Team Leader or Leonardo.
Thankfully, the below diagram is summing up the key points to be aware of: [email protected].

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INTERNATIONAL COOPERATION - BILATERAL
AGREEMENT AND “OUTSIDE TRACK II PROCESS”
WITH CHINA
The EU –China relationship has known this summer a significant development for
the aviation industry. The Bilateral Aviation Safety Agreement (BASA) will make it
possible to validate non-TC holders’ design approvals between both Parties.

Bilateral agreement signed

The bilateral civil aviation safety agreement (BASA) between the EU and China on Civil Aviation Safety was signed on May
20th 2019.

The main objective of the BASA is to support worldwide trade in aircraft and related products.

Once its entry into force expected sometime in 2020, this agreement will remove the unnecessary duplication of evaluation
and certification activities for aeronautical products by the civil aviation authorities, and therefore reduce costs for the
aviation sector. The BASA also promotes cooperation between the EU and China towards a high level of civil aviation safety
and environmental compatibility. The following guidelines need to be
considered for each validation effort
Individual working arrangements: no more! with CAAC:
In anticipation of the entry into force of the BASA (after ratification of the Agreement by both Parties) and its implementation - the regular CSV process (EASA Form 41) needs to be used
via agreed Technical Implementation Procedures, a “Temporary guidance material for validation of products outside Track - the local end-customer needs to provide the STC holder with
II and without working arrangement” was signed between EASA and the CAAC on August 06th. a letter of intent
- contacts between the STC holder and the validation authority
In accordance with the principles of the BASA, and pending its entry into force, this temporary Guidance Material is (CAAC) are acceptable
developed for any individual project applied or to be applied from both sides which is outside the previously agreed - written record of any requests is suggested whenever these
technical exposure scheme (Track II) and without a Working Arrangement between CAAC and EASA. It describes operational require EASA input
procedures to be used to enable acceptance of civil aeronautical products from both sides. - one CSV application needs to be sent for each certificate to be
validated
Paving the way to the Chinese market for European STC holders - for European applicants, the EASA PCM remains the main point
of contact
Before entry into force, both EASA and CAAC have agreed to make it possible for European STC holders to ask for validation - please keep the EASA representative in China in copy of all
by CAAC of their EASA certificates using a specific process designed for this transitional period. This allows easier access to applications for validations
the Chinese market for European Design Organisations. This way of working will remain valid until publication of relevant
Technical Implementation Procedures (TIP).

In case of questions/comments about this process, please contact the corresponding PCM or our EASA representative in
China Javier VICEDO ([email protected]).

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QUESTIONS AND ANSWERS – ONLINE PUBLICATION

Your questions are the fuel of our communication effort.

We published them online recently.
Whoever was involved in STC projects together with EASA already has certainly encountered issues that
needed EASA answers.

We strive to share those answers and therefore have published a large batch of questions and their associated
answers on our website.

Check out our FAQ webpage dedicated to “Certification of products and organisations”!

A large number of questions was recorded, in particular about topics that were raised in the frame of the
yearly EASA STC workshops.

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 UPCOMING EVENTS
EASA is inviting industry participants to attend to events in for coordination,
information and support purpose. Come and help us prepare the future of aviation!

New Part-21 amendment, what is changing for me? – Info session

When? October 30th /31st 2019
Where? Airbus St. Martin, Toulouse, France

2019 EASA-FAA Workshop on Additive Manufacturing

When? November 05th/ 07th 2019
Where? EASA Headquarters, Cologne, Germany

Side Meeting Day (prior the Product Certification & DOA Workshop 2019)
When? November 18th 2019
Where? EASA Headquarters, Cologne, Germany

Product Certification & Design Organisation Approval Workshop 2019

When? November 19th / 20th 2019
Where? Maritim Hotel, Cologne, Germany

Rotorcraft and VTOL Symposium in Cologne

When? December 10th / 11th 2019
Where? Pullman Hotel, Cologne, Germany

Check the details about those events and many more on our website!

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 Let’s continue this
two-ways communication
and cooperation.
We kindly invite you
to share by e-mail to:
[email protected]

European Union Aviation Safety Agency

P.O. Box 10 12 53
D-50452 Cologne, Germany
http://www.easa.europa.eu An Agency of the European Union
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