Annex F: Substantiation Report (Step 6)

1. General

1.1 This annex provides guidance on the development of a substantiation report identified in this advisory under Step 6 (paragraph 4.2.1.f) of the PBN Design Certification Process.

2. Rationale and Guidance

2.1 The role of the substantiation report is to document any compliance issues, validate any claims of Equivalent Level of Safety (ELOS)/Acceptable Level of Safety (ALOS) and explain to the TAA and OAA the rationale behind any restrictions or limitations that the TAA staff are proposing.

2.2 Examples of compliance issues may include:

1. Failure to meet some of the PBN criteria, either in whole or part;
2. Findings of ELOS;
3. Use of an ALOS argument to support the airworthiness approval; and
4. Request for an exemption to a certification requirement.

2.3 DTAES 3 is responsible for determining whether or not a substantiating report is required, and will coordinate the report with DTAES 6.

2.4 A substantiation report may not be required if the airworthiness approval can be granted based only on the completed compliance matrix, and if the Finding Authorities (FAs) are able to successfully complete all of their findings. This assumes that there are no certification issues to be resolved, nor any requirement to base the approval on an ALOS assessment.

2.5 Compliance issues typically arise during the following stages of the PBN Design Certification Process, and may need to be addressed in the substantiation report:

1. Design Assessment (Step 4). Examples of issues that that may be identified during the design assessment phase and need to be documented in the substantiation report include:
   1. lack of adequate compliance artefacts to make a conclusive assessment that the PBN criteria have been met;
   2. missing or inappropriate PBN criteria selection;
   3. claims that the design meets the ELOS or ALOS criteria;
   4. lack of information to adequately support an ELOS claim;
   5. lack of information to support an ALOS claim;
   6. proposals to use limitations, restrictions or ‘operational/aircrew’ procedures to compensate for design deficiencies, or to compensate for areas of non-compliance; and
   7. requests for exemptions or deviations to the certification requirements.
2. Findings of Compliance (Step 5). Issues that may be raised by the FAs and require resolution in the substantiation report include:
   1. lack of adequate proof of compliance data to make a finding of compliance to the requirement specified in the certification basis;
   2. FA’s comments and/or recommendations to address any issues or design deficiencies identified in the Design Assessment Report;
   3. restrictions and/or limitations recommended by the FA; and
   4. FA’s assessment of any ELOS or ALOS arguments that are used in the recommendation for approval of a design.

2.6 Advisory material related to the use of ELOS and ALOS as methods to address certification issues related to PBN design approval may be found in the ‘CNS/ATM Policy Interpretation’ section of regulatory reference 3.2.1.b., Part 3, Chapter 3, paragraph 3.3.6.

2.7 The following two substantiation report examples are available to DTAES staff:

1. CH146 Area Navigation Airworthiness Substantiation Report (available internally, within DND, at AEPM RDIMS library #1865469)
2. CF188 Area Navigation Airworthiness Approval Substantiation Report – Initial Issue, 2 Nov 2018 (available internally, within DND, at AEPM RDIMS #1826138)