LAMPIRAN KEPUTUSAN DIREKTUR JENDERAL PERHUBUNGAN UARA

NOMOR : SKEP / 240 / IX / 1998

TANGGAL : 01 September 1998

Advisory Circular

21-93
MODIFICATION APPROVAL AND
RETURN TO SERVICE AFTER
EMBODIMENT OF MODIFICATION

Revision : Revision 1
Date : September 1998

REPUBLIC OF INDONESIA – DEPARTMENT OF TRANSPORT

DIRECTORATE GENERAL OF CIVIL AVIATION
JAKARTA - INDONESIA

AC21-93 1
1. Purpose

This Advisory Circular provides information and guidance to aircraft

manufacturer, operators, aircraft maintenance organizations and DAC personnel
concerning the requirements and procedure for approval of modified product
operated under Indonesian registration.

2. Related CASR sections

CASR Part A21 - Subpart D and E

CASR Part 121 - Subpart H and other CASR Parts addressing operating rules
when published.
CASR Part 145
CASR Part 43

Note : The new CASRs published by DGCA are referring to “alteration” where
previous CASRs referred to “modification”. In the Indonesian
airworthiness system the terms “alteration” and “modification” are
equivalent and must be considered as such in all CASR, AC or SI
published by DGCA.

3. Requirements

• CASR Part A21 Subpart D provides requirement for the approval of

change to type certificate.
Paragraphs 21.95 and 21.97 provides requirements for approval of minor
and major changes in type design.
• CASR Part A21 Subpart E provides requirements for the issuance of
STC.
• CASR Part 43 paragraphs 43.5 and 43.7 provides requirements for return
to service of modified products

4. Background

Before the implementation of regulation quoted in paragraph 2 above various

methods have been used by DAC to process approval of modification embodied
on a product operated in Indonesian while insufficient guidance was available to
the industry and DAC personnel to discharge properly their respective
responsibilities.

The lack of guidance material has so far created confusion within the industry
and DAC on what were their respective responsibilities.

5. Definitions

AC21-93 2
1) Civil Aviation Authority (CAA) where used in this document, is an
airworthiness authority that is recognized by the DGCA as having a
competent airworthiness system that provides confidence that product
designed under their control have a level of safety comparable to those
designed under the control of DGCA. The list of these airworthiness
authorities is given in DAC Policy Letter No. 7.

2) Product is an aircraft, aircraft engine or propeller.

3) Aircraft means a device that is used or intended to be used for flight in the air.

4) Modification is any change in the design of a product or appliance.

5) Approval of a design change to a product means DGCA approval of

engineering data substantiating compliance of the design change with the
certification basis applicable to the product.

6) Person is any individual, organization or enterprise.

7) Major modification is any modification that :

(1) might appreciably affect weight, balance, structural strength,

performance, power plant operation, flight characteristics, or other
qualities affecting airworthiness, or
(2) is not done according to accepted practices or cannot be done by
elementary operations.

Note : Typical operations classified as major modifications are listed in

Appendix 1 to this AC.

8) Minor Modifications is any modification of a product or appliance other than a major

modification.

Note : Typical operations classified as minor modifications are listed in

Appendix 2 to this AC.

9) Return to service, means to certify any product or appliance fit for service by
issuing a maintenance release, certificate of maintenance, serviceable tag as
the case may require.

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6. Abbreviation

AC Advisory Circular
AFM Airplane Flight Manual
AMO Approved Maintenance Organization

AC21-93 3
CAA Civil Aviation Authority
CASR Civil Aviation Safety Regulation
CMR Certification Maintenance Requirement
C of A Certificate of Airworthiness
DAC Directorate of Airworthiness Certification
DGCA Directorate General of Air Communication
SDAP Sub Directorate of Aeronautical Product
SDE Sub Directorate of Engineering
SDFO Sub Directorate of Flight Operation
SDMC Sub Directorate of Maintenance Control
STC Supplemental Type Certificate
TC Type Certificate

7. Responsibilities

The approval process of a modification embodied on a product must involve :

• The person applying for the approval of the design change, who in
accordance with CASR part A21 has the responsibility to demonstrate that
the design change complies with the applicable DGCA airworthiness codes
(CASR Part 23, 25, 27, 29, 33, 34, 35 and 36)
• The person installing the modification on a product who in accordance with
CASR Part 43 has to demonstrate that this installation has been done using
methods / techniques and practices acceptable to the DGCA.
• The person approving the return to service of a modified product who in
accordance with CASR Part 43 has the responsibility to demonstrate that the
modification complies with applicable DGCA airworthiness requirements.
• The DAC who has the responsibility to verify that compliance with all
applicable requirements has been demonstrated. Within DAC the
responsibility are split between SDE and SDMC as follows :

- SDE has the responsibility to verify that engineering data submitted by

the applicant for the design change approval comply with the applicable
airworthiness codes (CASR 23, 25, 27, 29, 33, 34, 35 or 36).

- SDE may when necessary require

1) the assistance from SDAP when the demonstrations of compliance

refer to test for which conformity of the test article needs to be verified
with respect to CASR 21.33.

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2) the assistance from SDFO when the demonstrations of compliance
refer to flight tests.

- SDMC has the responsibility :

AC21-93 4
 1) to verify that the embodiment of the modification has been done in
accordance with approved data and using methods/techniques and
practices acceptable to the DGCA.
2) when this verification has been completed satisfactorily, to approve
the modified product for return to service.

Note : These DAC responsibilities may be delegated in accordance with

existing CASRs (Part 43, Part 121, Part 145, Part 183,...)

8. Change in Type Design ( or Design changes)

• A design change is the engineering definition of a modification on a Type

Certificated Product.

With respect to CASR 21 there is two categories of design changes :

a) Changes that are so extensive that they require a new type certificate
(refer to CASR 21.19). These design changes are not addressed in
this AC.

b) Changes that do not require a new Type Certificate and are entitled
“Changes in Type Design” (refer to CASR 21 Subpart D). These later
design changes are addressed in this AC.

• No product can enter the Indonesian register unless the definition of the
product has been approved by the DGCA.

• No aircraft can be operated under Indonesian registration unless all the

design changes applied on this aircraft after the issuance of the first
Indonesian Certificate of Airworthiness for this aircraft has been
approved by the DGCA.

• CASR 21.91 prescribes procedural requirements for the approval of

changes in Type Design.

8.1. Classification of Changes in Type Design

CASR 21.93 defines classification of changes in type design as “minor

change” and “major change”.

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- A “minor change” is a change in type design that has no appreciable effect
on the weight, balance, strength, reliability, operational characteristics or
other characteristics affecting the airworthiness of the product.

- A “major change” is any change that is not considered as a “minor change”.

AC21-93 5
 The applicant for a design change approval has the responsibility to propose,
together with the application, a classification for the design change.
The DGCA will review the proposed classification and when this classification
does not meet the criteria of 21.93 will require the applicant to reclassify the
design change.

Taking into account the different design change approval procedures given in
paragraph 8.2 to 8.4 below, classification of changes in type design
according to CASR 21.93 must be perfectly understood by the applicant and
DAC personnel.

Note : Examples of “major change” and “minor change” are given in CASR
Part 43 Appendix A and in this AC in Appendix 1 and 2 .

8.2. Minor Change approval process

a) Minor change where the applicant for approval is the TC holder.

Approval of this change is subject to procedure developed in Staff

Instruction 21-01 “Type Certification procedure” for Indonesian product and
Staff Instruction 21-03 “Validation procedure of foreign type certificate” for
imported products.

Note : When a minor change is generated by a Foreign TC holder, then

DAC recognize without further engineering evaluation the
approval of the change from the authority of the country of design
(refer to SI 21-03).

b) Minor change where the applicant for approval is a person other than the
TC holder.

- The applicant for the design change approval must fill an application
form DAC Form 21-9 (refer to appendix 3) and submit that form to DAC,
Sub Directorate of Engineering, together with the data substantiating
compliance of the change with the applicable airworthiness codes.

Before submitting the compliance data to the DAC the applicant must :

1) develop all descriptive and substantiating data necessary for the

approval.
2) determine that the design data comply with applicable regulation
(compliance finding)

- Upon receipt of the file (Form 21-9 and the compliance data) SDE of
DAC will verify the proper classification of the design change and the
compliance findings from the applicant.

AC21-93 6
 If the classification and the compliance data are found acceptable then
the Deputy Director for Engineering or his authorized representative will
sign the DAC Form 21-9. The original of the Form will be sent back to
the applicant and a copy attached to the compliance data will be kept by
SDE for archiving.
If the classification or the compliance data are not found acceptable,
proper communication will be arranged with the applicant to solve the
issue. In case of significant disagreement on the compliance data the
file will be returned to the applicant with the mention : “rejected”.

8.3. Major change/STC approval process

a) Major change where the applicant for approval is the TC holder.

Approval of this change is subject to procedure developed in Staff

Instruction SI 21-01 “Type Certification procedure” for Indonesian products
and SI 21-03 “Validation procedure of Foreign Type Certificate” for
imported products.

Note : When a major change is generated by a Foreign TC holder, then

DAC SDE evaluate the change and when satisfied that this
change complies with the applicable certification basis approve it
(refer to SI 21-03).

b) Major change where the applicant for approval is a person other than the
TC holder.

According to CASR 21.113 “any person who alters a product by

introducing a major change in type design, not great enough to require a
new application for a type certificate under 21.19 shall apply to the
Director General for a Supplemental Type Certificate, except that the
holder of a type certificate for the product may apply for amendment of the
original type certificate”.

In other words any “major change” where the applicant for approval
is a person other than the TC holder is a STC.

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The applicant for the design change approval must fill a DAC Form 21-4
“Application for Type Certificate, Production Certificate, or Supplemental
Type Certificate” (refer to appendix 4), and address it to DAC together with
data substantiating compliance of the change with the applicable
airworthiness codes.

Before submitting the compliance data to the DAC the applicant must :

1) define the certification basis applicable to the STC. This certification basis
may be different from the certification basis applied to the TC product to
be modified.

AC21-93 7
 2) develop adequate data to substantiate compliance with the certification
basis applicable to the STC.
3) provide a statement of compliance with each compliance report
substantiating compliance with the certification basis applicable to the
STC.
4) if necessary develop the addendum to operational manuals (AFM, CMR,
Airworthiness limits...) that may be affected by the STC.

Upon receipt of the file (Form 21-4 and the compliance data) SDE of DAC
will evaluate the certification basis and the compliance data from the
applicant.

The compliance data will be evaluated by DAC in accordance with

guidance given in Staff Instruction 21-01 Chapter 4 “Supplemental type
Certificate”.

When the DGCA is satisfied that the modified design meets the applicable
regulation, a STC (DAC Form 21-5 - refer to appendix 5) will be issued.

Note : STC from Foreign origin should be validated by DAC in accordance

with guidance provided in DAC Staff Instruction 21-03.

The extent of DAC involvement in such validation process may

vary taking into account the complexity of the STC and the
competence of the airworthiness authority the country of design
for the STC.

When the airworthiness authority of the country of design for the

STC belongs to the list of CAAs recorded in DAC Policy Letter No.
7, the validation process may be limited to the issuance of a DAC
letter recognizing that the Foreign STC can be installed on
Indonesian registered aircraft. In such a case issuance of an
Indonesian STC is not necessary.

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8.4 Return to service of a product altered by the installation of a
modification.

a) Modification designed by a person other than the TC holder :

Return to service is ruled by CASR part 43 paragraph 43.5.

Approval of a design change that represent a modification (signature by

DAC of DAC Form 21-5 or DAC Form 21-9) is not a sufficient condition
to allow return to service of a product altered by the installation of a
modification.

No product altered by the installation of a modification can be returned to

service unless :

AC21-93 8
 • the design data substantiating compliance of the modification with the
airworthiness codes (CASR 23, 25, 27, 29, 33, 35 and 36) have been
approved by DAC (DAC Form 21-5 or DAC Form 21-9 signed by DAC),
and

• the modified design does not affect any other previously installed
modification, and

• the installation of the modification has been performed in compliance

with accepted industry practices and applicable CASRs by a suitably
approved person, and

• After installation of the modification the aircraft is safe for flight.

DAC Form 43-337 (refer to appendix 6) is the appropriate form available to

the operators, approved maintenance organization (AMO) or aircraft
owners to record embodiment of modification indicating details and
approval.

When all the steps of DAC Form 43-337 are completed satisfactorily then
the aircraft can return to service. DAC Sub-Directorate of Maintenance
Control has the responsibility to control the proper use of DAC Form 43-
337.

Note : Guidance to use DAC Form 43-337 are provided in DAC AC 43-9.
“Instruction for completion of DAC Form 43-337”.

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b) Modification designed by the TC holder :

Return to service is ruled by CASR Part 43 paragraph 43.5.

Embodiment of such modifications on a product by persons other than the

manufacturer is addressed through Service Bulletins approved by the
authority of the country of design.

Approval of the Service Bulletin by the authority of the country of design

means that the corresponding design change has been substantiated by
approved compliance data. In such a case a DAC Form 21-9 signed by
DAC is not required.

The record of embodiment of the Service Bulletin must be done using

DAC Form 43-337.

AC21-93 9
 The Service Bulletin reference must be recorded in that form (Description
of Work Accomplished).

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APPENDIX 1

EXAMPLES OF MAJOR MODIFICATIONS

1. AIRFRAME MAJOR MODIFICATIONS

(a) Major changes to the basic design or external configuration of any structural
component such as :
- Wings
- Tail surfaces
- Fuselage
- Engine mounts
- Control system
- Landing gear
- Hull or floats
- Elements of components (spars, ribs, fittings, shock absorbers, bracing,
cowlings, fairings, balance weights, etc.) of an airframe.

AC21-93 10
 - Hydraulic and electrical actuating systems or components
- Rotor blades

(b) All change to the empty weight or empty balance which result in an increase
in the certificated maximum weight or alternation of the center of gravity limits
of the aircraft.
(c) Changes to the basic design of the fuel, oil, cooling, heating, cabin
pressurization, electrical, hydraulic, deicing, and exhaust systems.
(d) Modifications to the wing or to fixed or movable control surfaces which affect
flutter and vibration characteristics.
(e) Installation or modification of any system affecting the structural
airworthiness, flight behavior, or control of the aircraft.

2. POWERPLANT MAJOR MODIFICATIONS

(a) Conversion of an aircraft engine from one approved model to another

involving any changes in compression ratio, propeller reduction gear, impeller
gear ratios or the substitution of major engine parts which requires extensive
rework and testing of the engine.
(b) Modification of the engine by replacing aircraft engine structural parts with
parts other than those supplied by the original manufacturer or otherwise
specifically approved by the DGCA.
(c) Installation of an accessory which has not been approved for the engine.
(d) Removal of accessory that listed as required equipment on the aircraft or
engine specification.
(e) Installation of structural parts other than the type of parts approved for the
installation.
(f) Conversions of any sort for the purpose of using fuel of rating or grade other
than that called for in the engine specification.

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3. PROPELLER MAJOR MODIFICATIONS

(a) Change in blade design

(b) Changes in hub design
(c) Changes in governor or control design
(d) Installation of a propeller governor or feathering system
(e) Installation of propeller deicing system
(f) Installation of parts not approved for the propeller
(g) Any changes in the design of a balance propeller or its controls.

AC21-93 11
 11
APPENDIX 2

EXAMPLES OF MINOR MODIFICATIONS

Changes such as the following to an airframe, powerplant, propeller or appliance

are considered minor modifications.

1. AIRFRAME MINOR MODIFICATION

(a) Installation or removal of specific items of optional equipment listed in the

aircraft specification when such installation is made in accordance with the
manufacturer’s instructions.
(b) The installation or removal of equipment of equal or less weight and in the
location as that listed as that optional equipment in the aircraft specification.
(c) Changes of a minor nature made to Structural and non-structural elements
for the purpose of improving the service life or alteration of the maintenance
costs.
(d) All changes to the empty weight or empty balance which do not result in a
increase in the certificate maximum weight or alteration of the center or
gravity limits of the aircraft.

AC21-93 12
2. POWERPLANT MINOR MODIFICATIONS

(a) Alterations to supporting brackets or braces of unit of the powerplant which

do not adversely effect the structural integrity of such parts.
(b) Changes to the cowling which do not affect engine cooling, such as revisions
to mounting brackets attachments.
(c) The alteration or conversion of an aircraft engine by simple substitution of
parts of different design or addition of DGCA approved parts in accordance
with approved practices, and in conformity to the engine manufacturer’s or
DGCA instruction.

3. PROPELLER MINOR MODIFICATIONS

(a) Initial installation of a propeller spinner.

(b) Changes to the basic design of, or the relocating of, brackets or braces of the
propeller controls.
(c) Changes to the basic design of propeller control rods or cables.

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AC21-93 13
 Appendix 5

REPUBLIC OF INDONESIA
DEPARTMENT OF TRANSPORT
DIRECTORATE GENERAL OF AIR COMMUNICATION

Supplemental Type Certificate

Number XXX

This certificate issued to : Applicant

Certifies that the changes in the type design for the following product with the limitations and
conditions therefore as specified hereon meets the airworthiness requirements of Part YY of Civil
Aviation Safety Regulations.

Original product – Type Certificate Number : 000

Make : ACX
Model : ACX-M

Description of Type Design Condition :

This certificate and the supporting data which is the basis for the approval shall remain in affect until
surrendered, suspended, revoke, or a termination date is otherwise established by the Director of the
Directorate General Of Civil Aviation

Date of application : dd-mm-yyyy

Date of issuance : dd-mm-yyyy

On behalf of Director General Of Civil Aviation

[ Name ]

Director of Airworthiness Certification

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AC21-93 14