Simone Fevola

No clear guidance within AC 21.101 for changed areas requiring re-substantiation, which may later be deemed significant changed area. for example.... Applicant may waste resources and show compliance to existing regulations based on "un-appreciable" change classification (ie minor change) in advance of FAA determination of significance of change. Later be denied clasification based on audit. Reccomend changing wording to require early faa involvement and therefore read " However, if the FAA finds that the proposed change is significant in an area, the FAA may designate compliance with an amendment to the regulation incorporated by reference in the type certificate...."