Provisional certification: it’s still subject to change
Assuming the marketplace wants the aircraft, nothing is more important to
an aircraft manufacturer than FAA type certification–the government seal of approval that vindicates thousands of manhours of work, hundreds of millions of dollars of research, engineering, cutting metal and composites, hammering together an aircraft and mountains of paperwork to prove that all aspects of the aircraft meet airworthiness certification regulations and standards.
But just as there is more to certification than the full type certificate–manufacturers still need a production certificate–there is also more than one form of certification, and manufacturers have used both as evidence that their aircraft has received the FAA’s highest blessing.
When most of us think of certification, we are probably considering the term full type certification. The FAA issues a type certificate when it agrees that a manufacturer has met all the certification regulations.
Before the FAA issues the full type certificate, manufacturers are eligible to apply for the other type of certification, called a provisional type certificate.
A provisional type certificate is a design approval, according to the FAA, that comes with time and operational limitations. The original purpose of the provisional type certificate was to help the aviation industry in the transition to the jet age by allowing airlines to begin training and learning how to operate their new jets before flying passengers and during the final stages of certification.
Manufacturers that take the provisional certification route use that status to conduct training, demo flights, market surveys and flight testing of instruments, accessories and equipment and to perform in-service testing, according to the FAA.
Provisional certification doesn’t necessarily mean that the airplane is not ready for prime time; it just means that it hasn’t yet met all of the final requirements for full certification. “For the issuance of a provisional TC,” the FAA explained, “the applicant must show the airplane is safe for flight and meets the airworthiness standards appropriate for its proposed type-certification basis.”
The manufacturer is permitted to operate under a provisional type certificate with some systems disabled, such as ice protection, autopilot and pressurization, and those would be limitations on the provisional certificate. Naturally, the manufacturer must be able to show that flight with those systems disabled is safe.
In the business jet world, manufacturers have used provisional certification to indicate that the aircraft has achieved FAA certification while finishing final certification tests and paperwork and outfitting first-delivery aircraft with paint and interiors, a process that usually takes up the time remaining for issuance of the full type certificate.
On Dec. 11, 1996, the Gulfstream V received a provisional type certificate, followed by full type certification in April 1997. Joe Walker, president of Adam Aircraft, who worked as a salesman for Gulfstream at that time, recalled, “We had about a year’s worth of completion work to do before customer delivery, and that seemed to make sense, to get a provisional then go ahead with the final certification while we were doing the completion work.” Six years later, the G550 was also awarded provisional type certification, in December 2002.
Raytheon used the provisional certification process for the Hawker 4000 (née Horizon), obtaining the provisional type certificate on Dec. 23, 2004. Full certification was imminent at press time. Provisional type certificates are limited to two years.
Cessna has used the provisional process, too, receiving provisional certification for the Sovereign in December 2003.
The provisional certification process isn’t limited to U.S.-based manufacturers. Embraer received provisional certification of its E170 in 2003, from Brazil’s regulators. Australia also uses provisional type certificates.
Some companies, however, elect not to use the provisional certification process. “We are not applying for provisional certification,” said an Eclipse Aviation spokesman about the upcoming certification of the Eclipse 500 very light jet. “We are going for a full type certificate.”
Another Mile Marker
While issuance of provisional type certificates might seem premature to some, there are advantages. “The benefit of these incremental certificates,” said Walker, “is that it’s a positive sign to the external environment that the company is making progress from somebody’s view other than their own.” Indeed, in the FAA’s words, “The FAA applies the same airworthiness standards to both the provisional and full TC programs.”
“There’s a fair amount of constituencies that are interested in that progress,” said Walker. “If it’s a start-up company, the investors are interested. If it’s an established OEM, it’s the parent company. The customers, the supplier base are interested, as are the employees.”
Provisional certification may also help with financial constraints imposed on a manufacturer. “In most of these aircraft programs,” he explained, “there are financial milestones that are tied to ‘certification.’ And sometimes the definition of certification is a little bit gray. What the external environment is looking for is some indication of certification, be it provisional or baseline or whatever.”
Said Susan Cabler, assistant manager of the aircraft engineering division in the FAA’s certification service, “[Provisional certification] is almost a statement [a manufacturer] can make to investors, backers and customers: ‘I’m really close; the FAA thinks I’m really close.’”
In the case of Adam Aircraft’s A500 piston twin, which received FAA certification last May, this was not a provisional type certificate, according to Walker. Adam officials consulted with the FAA about whether to obtain provisional certification first, but with FAA encouragement they elected to achieve what Walker terms “baseline” certification, which is a regular type certificate with restrictions.
On the A500, for example, the six-seat interior, Avidyne avionics and ice-protection system had yet to be certified. In addition, the airplane was not approved for flight at night or in IFR conditions. Walker said that Adam won’t be seeking provisional certification for the A700 jet, although the A700 will also receive a similar type of baseline type certificate with fewer restrictions, given the experience with the A500 program.
For an aircraft manufacturer, Walker said, “Regardless of what level of certification, it is a huge differentiator between a company that’s continuing to develop a product versus one that a governmental regulator has declared certified. It’s kind of like graduating from college. You either graduated or you didn’t. And your grade point average–not a lot of people ask for that, they just want to know if you graduated.
“Ultimately the market is going to be the determinant on acceptance of the delivered product,” he concluded. “Because if you haven’t met the customer’s expectation relative to product features, he’s not going to take delivery of the airplane.”