Major change program
Certification plan review for a major change program
This review examines the certification plan that frames a major change, confirming the proposed basis is defensible, the affected areas are honestly scoped, and the review commitments match what the data package will contain. A certification specialist reads the plan against the change it describes, finding the promises of coverage or level of involvement that the evidence path will not support. The output shows where the plan overcommits or leaves scope unstated. You receive a gap assessment, a plan-to-evidence map, and a closure plan before the plan is agreed with the authority.
When this review is needed
- A major change is being scoped and the plan sets commitments the program will be held to for its whole life.
- The proposed certification basis has not been pressure-tested against the actual extent of the change.
- The plan lists affected areas and someone needs to confirm nothing touched by the change was left off.
- The authority is about to agree the plan and any overcommitment in it becomes binding.
The problem
The certification plan is written early, when the change is still partly a concept, so it tends to promise more coverage and less residual work than the program later delivers. A basis proposed to look complete can miss a special condition the change actually triggers, and affected-area lists drawn from a first pass often omit a system the change reaches indirectly. Those early optimistic commitments harden once the authority agrees the plan.
What gets reviewed
- The proposed certification basis tested against the actual extent and effects of the change
- Affected areas and systems checked so nothing the change reaches is left unlisted
- Review commitments and level of involvement compared to what the evidence path can produce
- Special conditions and equivalent-level-of-safety items the change may trigger identified
- The compliance approach for each affected area confirmed to have a viable evidence route
- Assumptions in the plan surfaced where they are load-bearing but unstated
Scope this review
Tell us the asset, the event, and the evidence in scope, and we will outline a focused first engagement.
Identify what is missing against the means of compliance.
What gets validated
- The proposed basis covers the regulations and special conditions the change actually engages
- Every system or area the change affects appears in the plan's scope
- Each review commitment in the plan has an evidence path that can meet it
- The stated means for each affected area is achievable within the program
- Load-bearing assumptions are written down rather than left implicit
Evidence normally required
- The draft certification plan for the major change
- The change description and the systems it affects
- The applicable regulations and any candidate special conditions
- The planned evidence approach for each affected area
- Prior authority correspondence on the basis, if any
Common discrepancies
- A basis that omits a special condition the change actually triggers
- An affected system the plan does not list because the change reaches it indirectly
- A review commitment the planned evidence path cannot meet on schedule
- A load-bearing assumption about the installation left unstated in the plan
What is at stake
A plan that overcommits creates obligations the data package cannot meet, and closing that gap late means either extra evidence under deadline or a renegotiation with the authority from a weak position. A basis that missed a special condition surfaces as a finding after the design is frozen, when the change to answer it is most expensive.
How the work runs
Test the basis
Read the proposed basis against the extent of the change and identify any special condition or regulation it should engage.
Scope the affected areas
Trace the change through the aircraft to confirm every system it reaches is listed in the plan.
Check the commitments
Compare each review commitment and means to the evidence path the program can realistically produce.
Resolve before agreement
List the basis and scope items to settle so the plan the authority agrees is one the program can meet.
What the buyer receives
- A gap assessment naming the plan's overcommitments and scope omissions
- A plan-to-evidence map linking each commitment to a viable evidence route
- A closure plan for the basis and scope items to resolve before agreement
Who uses the output
- Certification leadership agreeing a plan they can hold the program to
- Engineering leadership confirming each affected area has a real evidence route
- Compliance managers tracking the basis and scope items still to settle
How the work fits into the transaction or program
The plan review runs at the front of the program, before the plan is agreed with the authority, because everything downstream inherits its commitments. Catching an overcommitment or a missing area here is a plan edit, whereas catching it after agreement is a renegotiation, so the review protects the program's later flexibility.
Start with a single asset
Reduce finding cycles by checking the package first.
Regulatory limits
The review tests the plan for a defensible basis, honest scope, and achievable commitments. It does not agree the plan or the basis on the authority's behalf, approve the change, or make any compliance finding.
What this review does not cover
- Negotiating the plan or basis with the authority for the supplier
- Producing the evidence a commitment will require
- Any airworthiness or compliance determination on the change
Specific to this review
- The plan is the one document written before the work exists, so it is the easiest place to promise coverage the evidence will not later support.
- A missing special condition in the basis is cheap to add before agreement and expensive to answer after the design is frozen.
- Affected-area lists most often omit systems the change reaches indirectly, because the first pass scopes only the systems it touches directly.
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.
Federal Aviation Administration. STC application process, certification basis, and continued airworthiness obligations of an STC holder.
Frequently asked questions
Why review the plan before the authority agrees it rather than after?
Once the plan is agreed, its commitments are binding and changing them means renegotiating from a position of having overpromised. Reviewing it beforehand turns an overcommitment or a missing area into a plan edit instead of a mid-program concession.
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.