EASA - EWIS ICA Requirements

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EWIS ICA requirements


In case the certification basis is CS-25 Amdt 5 (or later)
according to part 21A.101 (i.e. STC is a significant change
related to EWIS aspects or new product), will the EWIS ICA
discriminant (>30 pax or >7,500 lb) still apply?

Answer

No, if the certification basis is the CS-25 Amdt 5 (or later), all the large aeroplanes
covered by CS-25 shall have to demonstrate compliance with the EWIS regulations
without exception.

Last updated:
03/12/2013

Link:
https://www.easa.europa.eu/en/faq/19430

Would EASA recommend to STC applicants to elect to comply


with CS-25 Amdt 5 (or later) on a voluntary basis?

Answer

From a safety perspective this would be welcomed but from a practical point of
view it may not be the best option when this is not required by Part 21. By electing
to comply with CS-25 Amdt 5 (or later) all new requirements have to be complied
with, which are not limited to SC H-01, CS-25 Appendix H paragraph H 25.5 and
AMC Appendix H 25.5 paragraphs 1 and 6, EWIS ICA. Due to the nature of the new
subpart H, this will induce additional justifications and possibly design changes and
will affect the time needed to approve a project.

Last updated:
03/12/2013

Link:
https://www.easa.europa.eu/en/faq/19431
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Are all the EWIS ICA from the TC holders’ affected aeroplanes
available by now (status July 2010)?

Answer

The TC holders for the affected aeroplanes have finalised their EZAP/EWIS ICA
exercise. With a few exceptions to be soon resolved, final documents are approved
by the FAA and accepted by EASA for all affected TC holders (EU/Non-EU). The
approved EWIS ICA has to be made available to the affected persons. The EZAP
analyses do not form part of the TC holders EWIS ICA.

Last updated:
03/12/2013

Link:
https://www.easa.europa.eu/en/faq/19432

Does a STC with an "EWIS limitation" still present affect the


entry into service of an A/C it is fitted to?

Answer

If NAA during Airworthiness Review Meetings/Sessions of a product at entry into


service of the Certificate of Airworthiness encounters that there are STCs for which
“Limitation requiring updated EWIS ICA to be provided” has not been cleared yet in
the relevant STC approval, they may contact EASA Certification EWIS Team (focal
point Ms. Carla Iorio - carla.iorio [at] easa.europa.eu) for further clarifications on
how this can affect aircraft operations.

Last updated:
03/12/2013

Link:
https://www.easa.europa.eu/en/faq/19436

When is the Special Condition SC H-01 “Enhanced Airworthiness


Programme for Aeroplane Systems - ICA on EWIS” applicable to
the Non-EU STCs to be validated by EASA?

Answer
Page 3 of 12

Non-EU STC applications sent to EASA for validation after 1st of January 2009 will
have to evaluate if it is needed to comply with the Special Condition H-
01 irrespectively of the date of application to the Primary Authority.

Last updated:
03/12/2013

Link:
https://www.easa.europa.eu/en/faq/19440

What is the Special Condition H-01 “Enhanced Airworthiness


Programme for Aeroplane Systems - ICA on EWIS”?

Answer

Please find attached the text of the SC H-01 as amended after public consultation
and introduced in the STC (TC) Certification Basis through the CRI H-01 where
applicable. Refer also to Question “Will we need to amend the TC basis for each
type to include this CS-25 requirement and publish in amended TCDSs?”

Last updated:
03/12/2013

Link:
https://www.easa.europa.eu/en/faq/19439

On which basis / requirement the Agency has requested TC


holders to develop EWIS ICA?

Answer

New and revised certification specifications were introduced through CS-25


“Certification Specifications for Large Aeroplane” amendment 5 with a new Subpart
H – Electrical Wiring Interconnection Systems – EWIS. The new amendment has
been published as part of the ED Decision No. 2008/006/R on the 29th August 2008
and enters into force on September 5th, 2008.
The requirement for existing TC holders to develop EWIS Instructions for Continued
Airworthiness (ICA) derived from the Enhanced Zonal Analysis Procedure (EZAP) is
imposed through the provisions of Part 21A.3B(c)1 for existing TCs, 21A.21(c)(3) for
applicants for TC and 21A.103(a)(2)(iii) for applicants for changes to TC. TC holders
have been notified of the applicability of those provisions through a dedicated letter
Page 4 of 12
that was sent in October 2008. This letter gives further details on the affected
aeroplanes (see Question "The letter dated 07.01.2009 (the letter sent by DOA
Section) specifies certain aircraft class in the footer. Where can we find this
specified in a current regulation?"), deliverables and compliance dates.
Note: The Agency has used this letter in the absence of a regulatory tool similar to
FAR Part 26.

Last updated:
03/12/2013

Link:
https://www.easa.europa.eu/en/faq/19417

On which basis / requirement the Agency is requesting a STC


Applicant to evaluate if a revision to EWIS ICA is necessary?

Answer

New and revised certification specifications were introduced through CS-25


“Certification Specifications for Large Aeroplane” amendment 5 with a new Subpart
H – Electrical Wiring Interconnection Systems – EWIS. The new amendment has
been published as part of the ED Decision 2008/006/R on the 29th August 2008 and
enters into force on September 5th, 2008.
For STC applications received after Jan. 1st 2009, the Agency is mandating the
EZAP related aspects dealing with Instructions for Continued Airworthiness of these
requirements through a generic Certification Review Item with a Special Condition
based on Part 21A.16B(a)3 that will be therefore part of the Certification Basis for
that STC.
Potentially affected applicants have been advised through a dedicated letter that
was sent in October 2008, giving further details on affected aeroplanes,
deliverables and compliance dates.

Last updated:
03/12/2013

Link:
https://www.easa.europa.eu/en/faq/19418

Are these requirements applicable to any major design change


or only to significant or substantial change where the latest
requirements must be considered (according to Part 21A.101)?
Page 5 of 12

Answer

For TC holders for the affected aeroplanes, EWIS ICA requirements are applicable to
any changes to TC.

For STC applicants for the affected aeroplanes, due to the nature of the tool used
(Special Conditions levied on STC applications received), applicability of EWIS ICA
requirements will be limited to new STCs or major changes to STCs. This is
applicable to the transition period until the TCDS of the affected aeroplane is
updated.

It also means for an STC applicant, that when the SC regarding EWIS ICA is in the
TCDS, all changes (major/minor) need review on necessity of revision of EWIS ICA.
(see also Question “Will we need to amend the TC basis for each type to include
this CS-25 requirement and publish in amended TCDSs?” which gives further
guidance on the TCDS.

Last updated:
03/12/2013

Link:
https://www.easa.europa.eu/en/faq/19419

The letter dated 07.01.2009 (the letter sent by DOA Section)


specifies certain aircraft class in the footer. Where can we find
this specified in a current regulation?

Answer

The affected aeroplane types are indicated in the letters sent to all affected TC
holders and potential STC applicants. The affected aircraft types are large
aeroplanes with a type certificate issued after 1st January 1958, that, as a result of
original type certification or later increase in capacity, have -
a maximum type-certificated passenger capacity of 30 or more; or
a maximum payload capacity of 3402 kg (7500 pounds) or more.

Last updated:
03/12/2013

Link:
https://www.easa.europa.eu/en/faq/19420
Page 6 of 12

Some aeroplane types are explicitly excluded from the similar


FAA rule (FAR 26.11(g)). Are these types also excluded from
EASA requirements?

Answer

No, EASA does not have a “pre-defined” list of excluded aeroplane types (similar to
FAR 26.11(g)). On a case-by-case basis, the TC Holders for the affected aeroplanes
may ask the Agency to accept a non-compliance with EWIS ICA requirements.

Last updated:
03/12/2013

Link:
https://www.easa.europa.eu/en/faq/19421

How can we as DOA identify if an aircraft model is applicable or


otherwise has been made compliant (by means of a retroactive
requirement) to this rule? Will it be entered into the TCDS or
will there be an AD requiring that or does each individual DOA
has

Answer

The Agency is considering making public (possibly through the web site) the list of
aeroplane types for which EWIS ICAs have been produced. The exact form has not
yet been defined. Plan is also to have Special Condition formalised and referenced
in the TCDS of the affected product.

Last updated:
03/12/2013

Link:
https://www.easa.europa.eu/en/faq/19422

How will the EWIS/EZAP assessment affect minor modifications


and repairs for TCs/STCs and if the requirements are found to
be applicable would this affect their classification (e.g. minor
becomes major)?
Page 7 of 12

Answer

Applicability to changes for TCs/STCs is addressed in Question “Are these


requirements applicable to any major design change or only to significant or
substantial change where the latest requirements must be considered (according
to Part 21A.101)?”

By principle, the classification of the change is driven by Part 21A.91. The fact that
EWIS ICA may be revised is not in itself a driver for the classification.

It must be noted that for FAR Part 26 compliance, the FAA requires that if the
change needs a revision to the previously developed and approved EWIS ICA, then
the revised EWIS ICA must be submitted to the foreign CAA (for non-US products)
for approval, independently of the minor/major change classification.

Last updated:
03/12/2013

Link:
https://www.easa.europa.eu/en/faq/19423

We anticipate that a CRI may be needed for each STC because


of the need to at least have the applicants use the checklist.
Has EASA considered the effect on the hours to be allocated for
each task to include the extra work? In addition may this not
also a

Answer

The effect of extra work and additional hours needs to be accounted for.
Simple STCs may be subject to change from “simple” to “standard” due to an EWIS
impact. Nevertheless, not all STCs affected by EWIS become automatically
standard.
Classification between simple/standard will be managed according to the processes
in place and the possible need to involve more than one Panel for this specific task.

Last updated:
03/12/2013

Link:
https://www.easa.europa.eu/en/faq/19424
Page 8 of 12

To avoid the extra workload would it not be an idea to have EU


DOAs include consideration of the ICA requirements as part of
their procedures? This would make EWIS part of their normal
practises?

Answer

Yes, this is under consideration.


For TC Holders determination of impact of modifications on EWIS ICA is left to the
applicant (no systematic check for each mod.). This assumes that the appropriate
DOA procedures are in place and have been checked by EASA.

Last updated:
03/12/2013

Link:
https://www.easa.europa.eu/en/faq/19425

Will we need to amend the TC basis for each type to include this
CS-25 requirement and publish in amended TCDSs?

Answer

Yes, the plan is to use the CRI Process and Special Condition tool and make it
become part of the Certification Basis.
The intent of those CRIs and the Special Condition that will be attached is to
complement the letters that have been sent to the Design Approval Holders, not to
replace them. Their objective is to state in an easily identifiable manner the
certification basis to ease future modifications and STCs. Objective is to have that
in place as soon as possible. The exact timing of this incorporation for all affected
products is controlled per program. Expectation is that this will take place until the
end of 2010. This will save the need to issue a SC for each assuming this SC (H-01)
is clearly identified in the cert basis/TCDS of the affected aeroplane.
Note: The TCDSs can be found on the here.

Last updated:
03/12/2013

Link:
https://www.easa.europa.eu/en/faq/19426
Page 9 of 12

The 07/06/10 deadline date for STC applicants - how will this be
managed by EASA if the STC has already been issued. Will a
new project be needed to allow the teams to review the ICAs?

Answer

Yes, once the STC was considered affected by the new rules and a revision of EWIS
ICA was considered to be potentially necessary, the certificate was issued with a
limitation. This limitation states that the STC holder shall submit to the Agency the
final EWIS ICA for the STC by 7th of June 2010.

To remove the limitation, the STC holder has to apply for a Major Change to the
STC. EASA expects the applicant to provide an analysis substantiating that
revisions to the EWIS ICA are not needed or provide updated/new EWIS ICA
documents with associated justification.

It is expected that the STC certificate will be reissued with no limitation at the
conclusion of the process.

Last updated:
03/12/2013

Link:
https://www.easa.europa.eu/en/faq/19427

Once a STC holder has applied for a Major Change to the STC to
remove the limitation stating that the STC holder shall provide
the final EWIS ICA for the STC by 7th of June 2010, what is the
expected timeframe for the EASA acceptance?

Answer

EASA is currently working on these tasks on removing the limitations (status July
2010) and the applicant will be contacted as soon as practical directly from the
involved team.
It must be noted that an important number of applications have been received,
which need to be processed in parallel and also need coordination.

Last updated:
03/12/2013
Page 10 of 12

Link:
https://www.easa.europa.eu/en/faq/19428

If there are two or more modifications being embodied at the


same time - e.g. cargo conversion - how will EASA ensure that
each applicant checks the effect of their design change on the
aircraft and on each others modification's?

Answer

The question is a practical one and also applicable to other aspects of certification
than EWIS ICAs. EASA should point out to the applicants any concurrent application
that may impact the validity of the EZAP analysis.

Last updated:
03/12/2013

Link:
https://www.easa.europa.eu/en/faq/19429

Can an applicant use FAA’s AC 25-27A, notably Appendix B for


the handling of design changes?

Answer

The FAA has published a new issue of the AC 25-27 (rev.A) on the development of
EWIS ICA using the EZAP analysis. The revised AC intends, among others, to
provide more clarity for applicants seeking approval of a design change when one
has no access to the TC holder’s EZAP analyses. It means the availability of TC
holder’s EWIS ICA is sufficient for the STC applicants to assess/develop EWIS ICA for
their change. EASA recognises the use of this AC as an acceptable method of
compliance for the assessment of design changes.

The Appendix B in the AC 25-27A contains new flowcharts, leading through the
process of determining EWIS ICA step by step. First, the applicant must determine if
revised or new EWIS ICA are potentially necessary. If this is the case, the applicant
has two ways to continue in the flowchart, depending whether the TC holder’s EZAP
analysis in the affected zone is available to him or not. Detailed questions in the
flowchart help the applicant in the creation of tasks specific to the design change.
The STC applicant has always to make sure he has the latest (current) TC holder’s
EWIS ICA for the affected zone.
Page 11 of 12

Last updated:
03/12/2013

Link:
https://www.easa.europa.eu/en/faq/19433

For STC to be certified after the 7th of June 2010, what are the
dates EASA would require EWIS ICA to be available?

Answer

For STCs (and changes) certified after the 7th of June 2010, the EWIS ICA (for
affected products) must form part of the data package submitted for approval of
the STC. The impact on EZAP/EWIS ICA has to be analysed and updated EWIS ICA, if
needed have to be provided at the time of approval of the STC.

Last updated:
03/12/2013

Link:
https://www.easa.europa.eu/en/faq/19434

What documents need to be transmitted by the STC applicant to


EASA for the aspect of EZAP/EWIS ICA?

Answer

For design changes that do not require a revision to the existing EWIS ICA, a
statement and justification explaining the rationale for the “no change to EWIS ICA”
is expected in accordance with the available guidance material.
If the process identifies that new/updated tasks are needed, they must be clearly
identified as EWIS ICA tasks. The EWIS ICA should be submitted to EASA as part of
the compliance demonstration. The associated justification can be, for instance the
updated EZAP analyses or an analysis in accordance with Appendix B in FAA’s new
AC 25-27A, when the TC holder’s EZAP analysis of the affected zone is not available
to him.

Last updated:
03/12/2013

Link:
Page 12 of 12

https://www.easa.europa.eu/en/faq/19435

Which are the CS-25 affected aircrafts for which the Special
Condition SC H-01 "Enhanced Airworthiness Programme for
Aeroplane Systems – ICA on EWIS" is applicable?

Answer

The CS-25 affected aircraft for which the SC H-01 is applicable are reported in
the attached document.

CS-25 aircrafts where EWIS ICA requirements are made applicable through CS-25
Amendment 5 or higher, irrespectively of the a/c maximum passenger capacity or
the maximum payload capacity, are not part of this list.

Last updated:
03/12/2013

Link:
https://www.easa.europa.eu/en/faq/19437

What is the official letter sent by EASA regulating the European


EWIS Rules for the STC Holders?

Answer

Please find in attachment the requested letter.

Last updated:
03/12/2013

Link:
https://www.easa.europa.eu/en/faq/19438

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