The regulatory update and new amended AMC & GM establishes flight recorder equipage requirements for certain turbine-engined aeroplanes and helicopters with an MCTOM of 2 250 kg or more and aeroplanes with an MOPCS of more than nine, if first issued a new individual Certificate of Airworthiness on or after 5 September 2022 (see, CAT.IDE.A.191 and CAT.IDE.H.191, Lightweight flight recorder).

This regulatory amendment and associated means of compliance and guidance material provide compliance with ICAO Annex 6, Part I requirements for a globally harmonised reporting format for runway surface conditions, airworthiness standards, and performance data.

The compliance date for the new standards for aeroplane landing performance calculation was deferred last year from 5 November 2020 until 12 August 2021  in response to the pandemic (see, Regulation (EU) 2020/1187).  

The purpose of this Certification Memorandum is to provide specific guidance for applicants when
demonstrating compliance with CS-E 515 (a) for Engine Critical Parts. This CM provides guidance concerning
the recognition of non-hazardous features (an area, a region, or a zone whose localised failure will not result
in a Hazardous Engine Effect) within an Engine Critical Part and how such features may be credited within
the Engineering Plan of CS-E 515 (a).

Historically, the safety assessment of applications for airworthiness approval have focussed on risks
associated with malfunctioning or failing systems and equipment installed on the aircraft. In this process, the
operational use of the systems and equipment was assessed, but generally, no credit was provided for the
operational safety benefits that the installation of such systems and equipment would provide.
The purpose of this Certification Memorandum (CM) is to provide an approach to the demonstration of
compliance to certain CS 23 and CS 27 specifications that is in line with reference standard guidance as
adapted to installation of system/ equipment that provide operational safety benefit. This is achieved by
introducing credits for systems or equipment that provide operational safety benefits in the determination
of the Development Assurance Level (DAL)1
The intent of the Net Safety Benefit policy is to facilitate the introduction of new, safety enhancing
technologies in the current, fleets that have been shown to provide operational safety benefits so as to
improve the overall safety performance of the operation.
It should be noted that whilst the FAA’s NORSEE policy and EASA’s Net Safety benefit policy aim to achieve a
similar goal, the scope, applicability and processes of both policies are different. In part this is due to differing
regulatory environments. For example; in the EASA system, the so called ‘field approvals’ do not exist. EASA
does however accept ‘standard changes’ under CS-STAN. The Net Safety Benefit policy is limited to
applications for airworthiness approval through a Major Change to an existing Type Certificate or a
Supplemental Type Certificate. The policy does not apply to changes covered by CS-STAN or to Minor
Changes.
The guidance provided in this CM is non-binding and provides complementary information and guidance with
the aim to complement the current CS and associated AMC.