Issue Papers

Effective Date: 11 September 2025

Reference: C-05-005-001/AG-001 – Technical Airworthiness Manual, Part 2, Part 3, Chapter 2, and Part 5, Chapter 5

OPI: DTAES 3-5

1. Purpose

1.1. This Technical Airworthiness Authority (TAA) Advisory provides guidance for the development, staffing and response to Issue Papers (IPs).

2. Applicability

2.1. This TAA Advisory applies to Directorate of Technical Airworthiness and Engineering Support (DTAES), Project Management Office (PMO) and Weapon System Management (WSM) staff, as well as associated contractors (Original Equipment Manufacturers (OEMs), In-service Support (ISS) or Design Support Networks (DSNs)) who will be involved in the development, staffing or response to IPs.

2.2. The guidance provided in this advisory is based on the consideration that IPs may be used both during the certification of out-of-scope design changes, and for initial type certification activity, both of which are managed by DTAES 3. 

3. Related Material

3.1. Definitions

See the Technical Airworthiness Manual (TAM) (reference 3.2.a) Glossary for applicable definitions.

3.2. Regulatory References

1. Canadian Forces Technical Order (CFTO) C-05-005-001/AG-001 – Technical Airworthiness Manual (TAM)
2. TAA Advisory 2023-02 – Special Conditions
3. TAA Advisory 2017-01 – Acquisition Contract Requirements for Obtaining Technical Airworthiness Clearance (available internally, on the DTAES intranet)
4. DAOD 3003-1 – Management, Security and Access Requirements Relating to Controlled Goods
5. CFTO C-02-007-000/AG-001 – Controlled Technology Access and Transfer (CTAT) Manual, Part 2, Section 1
6. Technical Airworthiness Clearance (TAC) Database Tracking Tool (AEPM RDIMS #2382581)

4. Discussion

4.1. During initial type certification or design change certification, there may be a need to formally document an issue regarding a certification requirement or means of compliance. The IP is the means by which the issue is formally documented. IPs are also required to document gaps in certification basis requirements, or means of compliance, which require a special condition (reference 3.2.a, 2.1.2.S1). Special conditions are issued when airworthiness codes do not have suitable certification requirements for new or novel design features that need to be certified. In this situation, the TAA can add a new requirement to the certification basis by approving and issuing a special condition. For more information on special conditions see reference 3.2.b.

4.2. An IP can be raised by any stakeholder. However, they are normally raised by the applicable DTAES specialist involved in the technical issue.

4.3 IP Development. It is incumbent on the individual who has identified the certification-related issue to develop the IP. Annex A provides an IP template. The following paragraphs provide information on how to complete this template.

1. Controlled Goods. If the IP contains or may contain any technical data, the document must be marked to indicate whether or not the technical data are Controlled Goods, in accordance with reference 3.2.d. The markings must conform to Figure 2.1.3 or Figure 2.1.6 of reference 3.2.e.
2. Fleet/Project Name, File Number and RDIMS. Include the fleet type designation (e.g., CH148) and, if applicable, the name of the project (e.g., MHP), and the originator’s file and RDIMS numbers. Ensure that all stakeholders have “Normal” access to the RDIMS file to facilitate updates to the IP.
3. Specialist(s). List all the specialty areas involved in the IP (e.g., avionics, software, flight sciences, etc.).
4. IP Number. The DTAES 3 Project Officer (PO) generates the IP ID number to ensure the numbering sequence is consistent with the applicable certification program. In general, the numbering convention should be “Aircraft Type Designation-IP-nn-yyyy” where “nn” is a locally-assigned register number, and “yyyy” represents the year the IP was raised (e.g., CH148-IP-02-2007). The DTAES 3 PO will maintain a register of all IPs generated for each project for which they are responsible (see paragraph 4.5 for more information).
5. Revision. Each time the IP is revised to include input from either the TAA or the applicant, or the final disposition, the revision number must be updated. The revision number for the initial release should be “0”.
6. Date. The date provided in this section should be the date that the IP was originated. As the applicant’s position, the TAA and applicant's responses, and the final disposition are added, the dates for the additions should be included at the beginning of the new text.
7. Status. The IP status, (either “draft”, “open” or “closed”) is included here. “Open” signifies that the IP has been officially released, but the final disposition has not yet been signed off. The status switches to “Closed” when the IP is being staffed for final disposition signatures.
8. Subject. The originator provides the subject of the IP by identifying the system affected and the nature of the issue.
9. Certification Requirement(s). If the IP is addressing one or more existing certification requirements in the certification basis, then they should be listed in this section. If the IP is addressing the need for new certification requirement(s), such as the case for a special condition, this section should be marked “n/a”.
10. References. All documents referenced within the IP should be listed here, along with their RDIMS number, if possible. This list can be updated with the addition of the applicant’s position, or subsequent TAA or applicant responses. All documents listed in this section must be referenced in the IP.
11. Statement of Issue. This section provides the executive summary of the issue. The originator should provide a concise statement describing the issue. It should be as brief as practical, without including background information or discussion of the subject.
12. Discussion. In this section, the originator should provide all information necessary to explain the background or rationale for the Statement of Issue. In many cases, the IP exists due to a difference in interpretation of a particular requirement. It is in the Discussion section that this interpretation is explained, with all relevant rationale provided.
13. TAA Position. The originator must provide a concise statement defining what action the TAA is requesting from the applicant as a result of the Statement of Issue. As the issue itself has already been defined (Statement of Issue) and explained (Discussion), there is no need to reiterate or elaborate on it. In the case of a special condition, the TAA position can simply state that a special condition to address the incomplete certification requirements must be issued by the TAA (see reference 3.2.b). The TAA position section also includes the TAA signature block, which officially releases the IP to the applicant (see section 4.4 for IP staffing). The IP originator, their section head and DTAES 3 will all sign the IP. If more than one specialist is involved, then all originators and their section heads are required to sign.
14. Applicant Position. The applicant provides their initial response to the IP in this section. Ideally, this should be the only response to the IP, but there are many cases where the applicant does not fully agree with the issue or with the TAA’s position, and resolution of the IP will be iterative. This section can be drafted by the contractor on the applicant’s behalf. However, the applicant (at least the PMO System Engineering Manager (SEM) or WSM Senior Design Engineer (SDE)) must sign this section. It is also recommended that the PMO certification manager sign this section, along with the author. As there is no equivalent position in the WSM organization, this additional signature is not required.
15. TAA and Applicant Response(s). Additional TAA and applicant response sections may be required to fully resolve the IP. If not required, these sections can be left out of the IP. Signatures are not required for these sections. However, the date of the response must be included, and the IP revision number will require updating. All revisions to the IP should be uploaded into the RDIMS file as a new version, which will allow reviewers to see the complete set of iterations. Section 4.4 provides the details regarding the staffing of IP responses.
16. Final Disposition. Once the issue has been resolved, a summary of the resolution should be provided in this section. For special conditions, this can simply be a statement that the applicant has agreed to the requirement for the special condition, providing the special condition number and RDIMS reference (if available at the time). This section requires the signatures of all stakeholders, starting with the applicant and finally the TAA signatures. Once the final disposition text has been drafted and is deemed acceptable, the DTAES 3 PO can change the IP status to “closed” before staffing for signatures.

4.4 IP Staffing. It is the responsibility of the DTAES 3 PO to ensure that the initial IP, subsequent TAA positions and final disposition have been reviewed, and are acceptable to all TAA staff signatories. The DTAES 3 PO must ensure that all DND stakeholders have Normal access to the AEPM RDIMS file, and that the file is updated after each release, including subsequent TAA and applicant positions and final disposition. All IPs become part of the aircraft type record, and the DTAES 3 PO should ensure that the fleet WSM has access to all IP RDIMS files.

4.4.1 The IP should be sent to the applicant with a covering letter, which is drafted by the DTAES 3 PO and signed by DTAES 3. The covering letter should briefly summarize the reason for the IP and provide an expected response due date to ensure that the applicant does not take an unreasonable amount of time responding to the IP. A template letter has been provided at Annex B to this advisory.

4.4.2 All exchanges of IP revisions must go through the DTAES 3 PO, and it is the responsibility of IP originators and applicants to ensure that the DTAES 3 PO receives a copy of the latest IP revision.

4.5 IP Register. It the DTAES 3 PO’s responsibility to develop an IP tracking register for each project or fleet (normally, an Excel spreadsheet), which should be referenced in the TAC Database Tracking Tool (reference 3.2.f).  The IP tracking register should include, as a minimum, the following information:

1. IP number;
2. Subject;
3. RDIMS number;
4. Originator;
5. Date Opened;
6. Date Issued (TAA signatures);
7. Date of Applicant response;
8. List of actions – include the organization who is assigned the action, and the date that action is required by;
9. Updates; and
10. Date of IP closure.

4.6 Airworthiness Approval. The Provisional Technical Airworthiness Clearance (PTAC) Report will list all IPs and their status. Provisional certification (provisional Airworthiness Approval and/or provisional Type Certificate) can be granted with open IPs, as long as safety of flight issues have been identified and mitigated. However, full certification (Airworthiness Approval and/or Type Certificate) and TAC cannot be granted until all IPs have been closed (reference 3.2.a, 2.1.2.S1 and 3.2.2.S4). It is the responsibility of the DTAES 3 PO to ensure that all IPs have been closed prior to full Type Certification or Airworthiness Approval of DTAES 3-certified design changes.

4.7 In accordance with the TAM (reference 3.2.a) 5.5.2.S1, as mentioned in paragraph 4.4, all finalized IPs are part of the aircraft type record. Therefore, the DTAES 3 PO must ensure the WSM organization has access to all IP RDIMS files.