Means of compliance
Closing STC requirements that have no assigned means of compliance
This closure work resolves STC requirements that sit on the compliance plan with no means of compliance assigned to them. It is run for the modifier when a requirement is acknowledged and tracked but nobody has decided how it will be shown compliant, so there is no method, no evidence source, and no owner. The work reviews each unmethoded requirement, selects a means of compliance appropriate to it, names the evidence that will demonstrate it, and assigns a person to close it. You receive a completed compliance plan with a method per requirement, an evidence request list for the newly assigned items, and a disposition package showing every requirement routed to a closure path.
When this review is needed
- A requirement is on the plan but its method-of-compliance field is blank.
- A late requirement was added without deciding how it would be demonstrated.
- Two requirements share a method that only fits one of them.
- A reviewer asked how a requirement will be shown compliant and no method exists.
The problem
A means of compliance is the decision that turns a requirement into a plan of work: this one is shown by test, that one by analysis, another by inspection or review. A requirement with no means of compliance is stuck before any evidence can exist, because nobody has decided what evidence to produce. These requirements are easy to leave behind, since the plan lists them and the tool shows them present, but the method column is empty and no owner is chasing anything. Until each has a method, an evidence source, and an owner, it cannot start moving toward closure.
What gets reviewed
- Every plan requirement with no means of compliance assigned
- A method selected for each: test, analysis, inspection, or review
- The evidence source that each assigned method will produce
- A closure owner named for every newly methoded requirement
- Shared methods split where one does not fit both requirements
What gets validated
- Each requirement carries a means of compliance suited to what it demands
- The named evidence source can actually demonstrate the requirement
- Every newly methoded requirement has an owner accountable for closing it
- A method reused across requirements genuinely fits each one it is assigned to
- No requirement is left on the plan with a blank method field
Evidence normally required
- The compliance plan with its method-of-compliance column
- The requirement set the plan is built to satisfy
- The means-of-compliance definitions the program uses
- The engineering owners available to take newly methoded requirements
- Any prior method decisions from comparable modifications
Common discrepancies
- A late requirement added to the plan with no method ever assigned
- A method copied across requirements that only fits one of them
- A requirement whose assigned method cannot actually demonstrate it
- A methoded requirement with no owner to drive it to closure
What is at stake
A requirement with no means of compliance produces no evidence, so it stays open by default and blocks the finding of compliance for its part of the demonstration. Discovered late, it can force a method that needs test or analysis on a schedule that had no room for it. A reviewer reads an unmethoded requirement as a planning gap and looks for others, turning one blank field into doubt about how completely the compliance was thought through.
Move from findings to resolution
Identify the missing data behind the finding.
How the work runs
Find the unmethoded set
Filter the plan to every requirement with a blank means-of-compliance field.
Select a method
Assign each a means of compliance suited to what the requirement demands.
Name source and owner
State the evidence the method will produce and assign a person to close it.
Package the routing
Show every requirement on a defined closure path for reviewer disposition.
What the buyer receives
- A completed compliance plan with a means of compliance per requirement
- An evidence request list for the requirements newly assigned a method
- A disposition package showing each requirement on a defined closure path
Who uses the output
- Certification leads confirming every requirement has a route to compliance
- Engineering owners taking on the newly methoded requirements
- Program managers scoping work when a new method needs test or analysis
How the work fits into the transaction or program
Assigning means of compliance is the step that turns a requirement into evidence-producing work, so it precedes the verification and matrix checks that assume a method exists. This work runs early in finding closure, ahead of the evidence-completeness reviews, so a requirement that needs a costly method is found while the schedule can still absorb it.
Start with a single asset
Confirm each requirement maps to substantiating evidence.
Jurisdiction-specific considerations
The two authorities accept overlapping but not identical means of compliance for a given requirement, and a method that is routine for one may need justification for the other. The closure work notes where a means of compliance chosen for the primary submission may need a different or supplemented method to satisfy a validating authority.
Regulatory limits
This work assigns methods, evidence sources, and owners so each requirement can move toward closure. It does not judge whether a chosen means of compliance is acceptable, produce the evidence, approve the modification, or grant the STC. Acceptance of the method remains the authority's finding.
What this review does not cover
- Producing the test, analysis, inspection, or review evidence itself
- Negotiating the acceptability of a method with the authority
- Any determination that a means of compliance is acceptable
Specific to this review
- A requirement with no means of compliance is stuck before any evidence can begin, so it is the earliest form of a closure gap.
- The tool listing a requirement can mask a blank method field, which is why unmethoded requirements survive to a reviewer's question.
- Choosing the method is where cost is set: the same requirement can close by review or by a test campaign depending on the means selected.
Sources
U.S. Government (eCFR). Type certificates, STCs (Subpart E), TSO authorizations (Subpart O), PMA (Subpart K), and export airworthiness approvals (Subpart L).
Federal Aviation Administration. FAA type certification process, certification basis establishment, and compliance findings.
SAE International. Development assurance process at aircraft and system level, including requirements capture and validation.
Frequently asked questions
Why not just assign the cheapest method to every open requirement?
The method has to actually demonstrate the requirement. A review or analysis that cannot substantiate what the requirement demands only moves the gap downstream, where a reviewer rejects it. The closure work selects a means that fits each requirement, then flags the ones whose only valid method carries real cost so the schedule impact is visible up front.
Relevant glossary terms
Related pages
Where this fits
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