The lack of a new regulatory framework for compulsory certification of civil aviation equipment in the Russian Federation, designers and manufacturers of this equipment raises numerous requests for application and interpretation of the Aviation Rules previously developed and applied by the IAC Aviation Register, Part 21 "Certification of Aviation Equipment, Designers and Manufacturers" (AR- 21).
In connection with the use of the Aviation Rules AR-21 by the Federal Air Transport Agency (FATA) when issuing the “Certificate of the designer of Supplemental type Certificate of Aviation Equipment” № FATA-R-1 to FSUE GosNII GA and issuing an information letter on this subject from August 25, 2017 № 19386 / 03 the IAC Aviation Register has to declare that the publication of these documents indicates the incompetence of FATA officials in the field of certification of civil aviation equipment and organizations of designers of this technology.
The use of the term "designer of the Supplemental Type Certificate" demonstrates ignorance or misunderstanding of provisions of the Aviation Regulations (AR-21). According to AR-21, a legal entity intending to introduce the amendments into a certified type design of aviation equipment, but not being a Type Certificate holder, must obtain Supplemental Type Certificate and Modification Designer Certificate. In this case, the issued certificate № FATA-R-1 is neither a Supplemental Type Certificate nor a Modification Designer Certificate specified by AR-21. As the name of the issued certificate implies FSUE GosNII GA has been recognized as the designer of the document "Supplemental type certificate", but not as the designer of aviation equipment or its modifications.
It should also be noted that the scope for specifying modifications in the standard design of aviation equipment for which the FSUE GosNII GA has been approved as their designer has not been specified in the appendix to the certificate № FATA-R-1.
In addition, the AR-21 does not provide the issuance of Supplemental Type Certificates for aviation equipment that does not have a type certificate (An-24, An-26 aircraft, AI-24 engine).
Therefore, FATA statement about compliance of FSUE GosNII with the requirements of AR-21, Section J, does not have sufficient grounds.
Granting by FATA the right to FSUE GosNIIA GA to act on behalf of the authorized body for specified resources tracking is not related to certification procedures of modifications and modifications designer developed by AR-21.