Spin test after major change
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The ITSB recommends to EASA to:
Require a spin test for VLA aircraft that goes through a major change, such as for MTOW, even though the C.G. excursion is the same.
An EASA letter dated 19.02.2020 states that EASA has closed the safety recommendation with disagreement.
The Agency has carefully assessed the proposed recommendation, taking into account the justification provided. However, in line with paragraph 21.A.91 of Commission Regulation (EU) N748/2012 (as amended) and the applicable Certification Specifications, a spin test is only required for major changes which are assessed by the applicant and accepted by EASA as having an impact on the spin characteristics as established under the original type certification basis. This applies regardless of the aircraft type-certification basis (e.g. CS-LSA, CS-VLA and CS-23).
For this reason, the mandatory requirement of a spin test for a major changes is not found feasible.