Certification evidence package
Closing STC compliance claims asserted without substantiating evidence
This closure work audits an STC evidence package for compliance claims that assert something is met without a document that substantiates the assertion. It is run for the modifier when the package reads as compliant but a claim, once questioned, has no report, analysis, or record standing behind it. The work walks each claim in the package, checks for a current substantiating document, and either ties the claim to that evidence or restates it plainly as an open item. You receive a claim-by-claim audit, an evidence request list for the unsupported assertions, and a disposition package where every claim either resolves to a document or is carried as open.
When this review is needed
- A statement of compliance asserts a claim that no document in the package supports.
- A summary was written ahead of the evidence and the evidence never caught up.
- A reviewer probed a claim and the author could not produce a substantiating record.
- Claims survived from a draft package after the supporting analysis was rescoped.
The problem
An evidence package accumulates claims as it is written, and it is easy for an assertion to outlive its support. A summary statement is drafted expecting an analysis to land, the analysis is deferred or changed, and the claim stays in the package reading as settled. The words assert compliance, but there is no document behind them, and the gap is invisible until someone asks to see the proof for that specific line. A package full of confident assertions can be hollow in places, and only a claim-by-claim check against actual documents shows where.
What gets reviewed
- Each compliance claim in the evidence package identified and listed
- A check for a current substantiating document behind every claim
- Claims matched to the evidence that actually supports them
- Claims with no supporting document restated as open items
- Assertions that overstate what the evidence shows corrected to match it
What gets validated
- Every claim points to a document a reviewer can open and read
- The cited document substantiates the specific claim, not a related one
- Claims are worded to match what the evidence actually demonstrates
- Assertions with no recoverable support are stated openly, not left implied
- No claim in the package asserts compliance on wording alone
Evidence normally required
- The certification evidence package and its statements of compliance
- The controlled evidence library of reports and analyses
- The compliance matrix linking claims to evidence, where one exists
- Change history for analyses that were rescoped during the program
- Contact points for the authors of the underlying evidence
Common discrepancies
- A summary claim drafted ahead of an analysis that was later deferred
- An assertion that overstates a result the evidence only partly supports
- A claim surviving from a draft after its analysis was rescoped away
- A statement of compliance with no document tied to it anywhere in the package
What is at stake
An unsupported claim that reaches formal review is worse than an openly stated gap, because it reads as an assertion the modifier could not back up when tested. A reviewer who catches one begins treating every claim as unproven until shown otherwise, which slows the entire review. Claims left unsupported at issuance become a weakness that resurfaces at the first amendment, when the package has to stand again and the missing evidence is even harder to assemble.
Move from findings to resolution
Identify the missing data behind the finding.
How the work runs
List every claim
Extract each compliance assertion from the package's statements and summaries.
Check for support
Confirm a current document substantiates each claim as worded.
Resolve or open
Tie the claim to its evidence, correct overstated wording, or restate it as an open item.
Package the audit
Deliver a package where every claim resolves to a document or is carried open.
What the buyer receives
- A claim-by-claim audit marking each claim supported or open
- An evidence request list for the assertions with no substantiating document
- A disposition package where every claim resolves to evidence or is carried open
Who uses the output
- Certification leads presenting a package where every claim survives a direct question
- Engineering authors supplying the evidence for their unsupported assertions
- Program managers tracking which claims still lack a substantiating document
How the work fits into the transaction or program
This audit is the final honesty check on the evidence package before it goes to a reviewer, sitting after the matrix and verification work and validating what they produced. Its open-item list feeds back into remediation, and its cleaned package is what the finding-closure review reads, so the review opens on claims the modifier has already backed or openly declared.
Start with a single asset
Confirm each requirement maps to substantiating evidence.
Jurisdiction-specific considerations
A claim substantiated to one authority's satisfaction can require additional or differently framed evidence for another, particularly where the two structure their statements of compliance differently. The audit notes where a supported claim on the primary submission may read as unsupported on a validating filing until the evidence is re-presented.
Regulatory limits
This work ties claims to evidence or restates them as open. It does not produce the missing evidence, judge whether a claim is compliant, approve the modification, or grant the STC. Whether a substantiated claim demonstrates compliance remains the authority's finding.
What this review does not cover
- Producing the analysis or test behind an unsupported claim
- Rewriting the compliance approach or the means behind a claim
- Any determination that a claim demonstrates compliance
Specific to this review
- An unsupported claim is more damaging than a disclosed gap, because it is an assertion the modifier could not defend when asked.
- Claims outlive their evidence most often when a summary is drafted before the analysis it anticipated, and the analysis then changes.
- One caught unsupported claim shifts a reviewer's posture from sampling to full scrutiny, so the cost is felt across the whole package.
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.
European Union / EASA. EASA design and production certification, STCs, ETSO authorizations, and EASA Form 1 release.
Frequently asked questions
Isn't restating a claim as open just admitting the package is incomplete?
It is a truthful statement of where the evidence stands, which is stronger than an assertion that collapses under a question. A reviewer trusts a package that declares its open items and distrusts one where a confident claim turns out to have nothing behind it. The open list also feeds remediation so those items can be closed with evidence rather than words.
Relevant glossary terms
Related pages
Where this fits
Talk to an engineer who has done this work
We will walk through your current state, the records or evidence involved, and a scoped first engagement.
Talk through the aircraft, records, evidence, deadline, and next useful step.