STC certification
Means-of-compliance map support for an STC program
This review readies the means-of-compliance map that connects each STC requirement to how compliance will be shown, so no requirement is assigned a means that leads nowhere. It is run for an aircraft modifier or equipment supplier while the compliance approach is still being set. The work checks that each requirement has a means, that the means chosen is capable of showing what the requirement demands, and that a real evidence path exists behind it rather than an intention. You receive a gap assessment of the requirement-to-means logic, an evidence map showing where each means terminates, and a closure plan for the requirements whose means has no path to evidence.
When this review is needed
- The compliance approach is being set and each requirement needs a means with a workable evidence path.
- A requirement was assigned a means on paper that no test, analysis, or inspection is actually set up to produce.
- A change of means was made mid-program and the map still shows the abandoned approach.
- The map has to show, per requirement, whether compliance comes by test, analysis, inspection, or a combination.
The problem
The means-of-compliance map is where good intentions outrun the evidence plan. A requirement gets assigned a means because a means is required, not because anyone confirmed that means can produce what the requirement asks. Analysis is chosen where only a test would settle the question, or a test is named that the article cannot support. The map reads as a complete plan while some of its rows point at a method that will never generate acceptable evidence, and that dead end is not found until the evidence is due.
What gets reviewed
- Every requirement checked for an assigned means, with none left unmapped
- The suitability of each means to the requirement it is assigned to
- A real evidence path confirmed behind each means, not an intention to generate one
- The choice of test, analysis, inspection, or combination examined per requirement
- Abandoned or superseded means removed so the map shows the current approach
- Requirements whose means has no evidence path collected into a closure plan
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
- Each requirement has an assigned means and none is left without a compliance approach
- The means chosen for a requirement can actually demonstrate what that requirement demands
- Each means terminates in a defined, achievable evidence path rather than an open intention
- A requirement needing test is not assigned analysis where only test would settle it
- The map shows the current means for every requirement, with superseded approaches removed
Evidence normally required
- The requirement set drawn from the certification basis
- The draft means-of-compliance map with its current assignments
- The certification plan defining the intended compliance approach
- The evidence plan or test and analysis schedule behind the means
- Any decisions that changed a means during the program
Common discrepancies
- A requirement assigned analysis where only test can settle the question
- A means with no test, analysis, or inspection actually scheduled to produce its evidence
- A superseded means left on the map after the approach was changed
- A requirement carried on the map with no means assigned at all
What is at stake
A means that cannot produce its evidence is discovered when the evidence is needed, which is the most expensive moment to change approach. Switching from analysis to test late in a program means bench time and schedule the plan never held, and a requirement stuck on an unworkable means reaches submittal with no evidence at all. The map's job is to catch the dead ends while there is still time to choose a different means.
How the work runs
Check for assignment
Confirm every requirement carries a means and none is left unmapped.
Test the suitability
Confirm each means can actually demonstrate what its requirement demands.
Follow the evidence path
Trace each means to a defined, achievable evidence route and flag the dead ends.
Plan the swaps
Collect the unworkable means into a closure plan and identify a viable alternative for each.
What the buyer receives
- A gap assessment of the requirement-to-means logic across the map
- An evidence map showing where each means terminates and which lead nowhere
- A closure plan for the requirements whose means has no path to acceptable evidence
Who uses the output
- Certification engineers setting the compliance approach for each requirement
- Test and analysis leads confirming each means has a schedule behind it
- Program managers tracking which requirements still lack a workable evidence path
How the work fits into the transaction or program
The means-of-compliance map sits between the certification plan and the evidence work, translating the plan's intent into a method per requirement. This review runs while the approach is still changeable, so a dead-end means can be swapped before the evidence schedule is built on it. Its output feeds the compliance matrix, which later indexes the evidence each means produces.
Start with a single asset
Reduce finding cycles by checking the package first.
Jurisdiction-specific considerations
FAA and EASA accept different means for some requirements, so a map built for one authority can assign a means the other will not credit. The review keeps the map honest about which means each authority accepts where an STC is pursued under both.
Regulatory limits
The review checks that each requirement's means is suitable and has an evidence path. It does not accept a means on the authority's behalf, perform the compliance activity, or grant the STC.
What this review does not cover
- Performing the test, analysis, or inspection that a means requires
- Negotiating an acceptable means with the authority
- Any authority acceptance of the means or the STC
Specific to this review
- A means gets assigned because every requirement needs one, so the map's real failure mode is a means that satisfies the box but cannot produce the evidence.
- Switching a means from analysis to test is cheap on paper and expensive once the evidence schedule is built, which is why dead ends have to be found early.
- A superseded means left on the map is a quiet trap, because downstream work can be planned against an approach the program already abandoned.
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. STC application process, certification basis, and continued airworthiness obligations of an STC holder.
European Union / EASA. EASA design and production certification, STCs, ETSO authorizations, and EASA Form 1 release.
RTCA. Environmental qualification test categories and procedures referenced by TSO and equipment qualification.
Federal Aviation Administration. FAA type certification process, certification basis establishment, and compliance findings.
Frequently asked questions
How is this different from reviewing the compliance matrix?
The means-of-compliance map is checked earlier and asks whether the chosen method can produce evidence at all. The compliance matrix is checked later and asks whether the evidence that was produced still supports the claim. Catching a dead-end means here avoids building an evidence schedule that the matrix would later expose as empty.
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.