A Type Certificate, or TC, is a necessary step for airworthiness in both crewed and uncrewed aircraft. A TC or RTC involves an extensive assessment performed by aviation authorities such as EASA to determine whether an aircraft manufactured according to the approved design can receive an airworthiness certificate. This is known within the industry as a complex and significant milestone and requires prior approvals, including Design Organisation Approval (DOA) and Production Organisation Approval (POA).
The following article details information from Murzilli Consulting's experts on Type Certification, Design Organisation Approval, Production Organisation Approval, what it means for European Drone Regulations, how the TC process works and how a potential applicant can prepare for it.
What Does a Type Certificate Mean for European Drone Regulations?
There are currently two European regulations that concern Type Certificates:
Part 21 of Annex I of Regulation (EU) 748/2012 concerns both uncrewed and crewed aviation and specifies the requirements and procedures for the certification of aircraft and their related products, parts and appliances (including engines and propellers) and of design and production organisations.
The European Commission’s Regulation (EU) 2019/945, Article 40 states that an unmanned aircraft system (UAS) in the certified category and classified under Specific Assurance and Integrity Levels (SAIL) V and VI are subject to Type Certification (TC) or a Restricted TC (RTC).
The EU has divided all drone operations within Europe into three categories: open, specific, and certified. A drone’s operation can be characterised using a chart such as this one:
If a drone is categorised into the Specific Category, it is required to undergo a risk assessment known as the Specific Operations Risk Assessment (SORA) methodology. The SORA method was developed by the Joint Authorities for Rulemaking on Unmanned Systems (JARUS), which, at the time of inception was led by Murzilli Consulting’s CEO, Lorenzo Murzilli. The methodology evaluates factors such as air and ground risks as well as their mitigations to determine if the operation is lower risk (SAIL I and II), medium risk (SAIL III and IV) or higher risk (SAIL V and VI).
Operations that have gone through the SORA process and have been determined as either SAIL V or VI are required to obtain a Type Certificate. This first calls for the design holder (typically the manufacturer) to prepare a Design Organisation (DO) and apply for a Design Organisation Approval (DOA), issued by EASA.
What is a DOA?
A Design Organisation or DO must demonstrate that it has the necessary processes, qualified personnel and internal operations in place to maintain the safety and reliability of the aircraft design. An organisation must apply to EASA to become a DOA holder by demonstrating that the aircraft complies with the requirements of Part 21 Subpart J. The terms of approval are defined by:
🔸Scope of approval: The type of design activities, including fields of expertise
🔸Categories of products such as large aeroplanes, engines, small rotorcraft, sailplanes, etc
🔸List of products for which a DOA holder is a Type Certificate holder or applicant (if applicable)
🔸A DOA holder may obtain the following privileges:
- They can perform design activities within the scope of approval
- Have compliance documents accepted by the Agency without further verification
- Perform activities independently from the Agency
🔸Limitations can be placed on any of the above points
After EASA has accepted the DOA application, an EASA-appointed DOA Team Leader will conduct the investigation as shown below:
** Image is based on EASA’s original design **
An organisation that has the DO approved and is a DOA holder (or have begun the process with EASA), may also need to submit their Production Organisation for approval (PO) to achieve a POA. The Production Organisation (PO) is an independent process, similar to the DO, but as the name suggests, it defines the regulatory framework for the production requirements and procedures that a company must follow to achieve the Production Organisation Approval (POA). Once these approvals have been submitted, an applicant can move on to the TC process.
What is the Type Certificate Process?
In Europe, EASA has provided an online application form for applicants to obtain a Type Certificate. However, there are several steps that need to be looked at first to ensure an organisation has all the required documentation before the final submission:
How to Prepare for a Type Certificate
As with most certification processes, ensuring that an organisation is prepared with correct and up-to-date information and documentation is the fastest way to successfully go through the Type Certificate process. Any organisation that is attempting to secure a Type Certificate must make sure that their design process aligns with the regulatory requirements at all phases of the process. From the initial concept phase to the final testing phase, the drone must have a compliant design with an established design organisation that meets EASA’s requirements.
Preliminary and critical design reviews can be conducted using internal testing to ensure the drone can perform in all pre-determined conditions. During these reviews, any design issues can be identified and corrected, which will avoid delays during the certification process.
To ensure an organisation is well-prepared for Type Certification, Murzilli Consulting’s team of experts have created a Type Certification service that provides end-to-end support, including management of the design review, customised templates, and guidance on the required documentation. The service is managed by our industry experts Richard Boden and Thilo Uebbert, who both led teams on one of the first FAA Type Certification projects and Juanjo Sola, Murzilli Consulting’s Director of Regulatory Affairs and the former Head of UAS Division at AESA. The service is broken down into two phases:
Phase 1 of Murzilli Consulting’s Type Certification service involves pre-planning in the form of preparing a Design Review (DR) and a Design Management System (DMS).
The Design Review service involves 4 baseline steps, which are:
1. End-to-end project management of the design review
2. Review and update the client’s airworthiness concept of operations (ConOps) and aircraft requirements document.
3. End-to-end support and guidance on documentation
4. Support meeting the requirements listed in the design review compliance checklist
Murzilli Consulting offers additional support on the Design Review service to customise the process according to the client's needs. These include event management and master of ceremony for the design review, as well as a report highlighting the results and recommendations for the design review.
The Design Management System service involves:
1. Support achieving the perfect balance between agility and stringent processes
2. Achieving the minimum requirements for an effective design management system (DMS)
3. Custom DOH templates
4. Review and update of the client’s DOH
This service also offers several additional steps including; collecting, creating and writing the DOH and DOH training for relevant teams.
After the initial design has been successfully approved, Phase 2 of the Type Certification can begin. Murzilli Consulting’s Type Certification service is broken down into the following 9 steps:
Murzilli Consulting’s customised services also include additional support, including; defining and implementing the design process, defining all design reviews such as critical design review or final design review, coordinating and establishing the flight test operations, preparing and reviewing flight test plans, reports and technical publications, supporting with aircraft and system safety assessments and authority liaison and management.
Once the authority has approved the Type Certificate, the aircraft can be produced by the production organisation and will be considered airworthy. However, organisations with a TC or RTC should be aware that they are obligated to comply with the latest regulatory updates and maintain the drone’s design integrity throughout its operational life.
Achieving a Type Certificate is an important step for drone manufacturers as they produce aircraft that are intended to operate in regulated airspace within Europe, and internationally. The process to ensure that the design and design organisation meets the regulated safety and performance standards enables the drone industry to advance by setting standards for operations in high-risk environments. This certification process, with the support of expert drone consultants, makes today’s regulatory landscape more accessible for organisations and marks a milestone for future operational endeavours within the innovative air mobility sector.
Would you like to know more about our complex support services for Type Certification? Write to us for more information or to book an initial consultation.
