Easa CRD - Master - SC - E-19 - 2021-04-07

EASA–SC E-19 Electric / Hybrid Propulsion System - Comment Response Document
Comment
Comment Comment
is
is an EASA
substanti
Comment summary Suggested resolution observation comment EASA response
ve or is an
Section, table, or is a disposition
NR Author Page objection
figure suggestion*
**
Requirements provided in the SC E-19 are deemed to be

Changes of requirmentens comparing serial hybrid with parallel
1 Jonas Büttner - - Yes Noted technology agnostic. Specific Means of Compliance may however
hybrid propulsion?
be proposed for a kind a hybrid propulsion architecture.
EHPS.390 Electrical Wiring and Interconnect System (EWIS) –

The EWIS must be designed and installed such that :
1. It is suitable for the electrical loads, mechanical loads
and the environmental conditions expected in the application
(temperature, humidity, icing, EMI/HIRF/Lightning, sand/dust,
exposure to fluids)
2. It provides physical separation and electrical isolation in
the wiring consistent with the system redundancy/safety
objectives and accessibility for maintenance
3. It minimizes mechanical strain, potential for
abrasion/chafing or other mechanical damage. and allows for Partially
2 FAA DK Add EHPS.390 20 Yes The proposed wording is covered by EHPS.370 (a).
reasonable deformation and stretching without failure accepted
4. EWIS components are labeled or otherwise identified to
facilitate identification of the EWIS components and their
design limitations, if any.
5. EWIS design minimizes potential for fire and smoke in
the installed environment with potential exposure to
flammable fluids/vapors and hot ambients
Electrical bonding provides an electrical return path capable of
carrying both normal and fault currents without creating a
shock hazard or damage to the EWIS components, other
airplane system components, or structure.
It is inappropriate to demand DO-178 for the power controller, but
for no other elements of the powertrain. E.g. what good is DO-178 Two-step proposal: a) Introduce proportionality for Gliders and
software, if a cockpit indicator errorously displays data received LSA, introduce design assurance (DO-178) for CS-23 and up. b) The following intended aircraft applications have been removed
3 Pipistrel All All from the "perfect" controller? Further - DO-178 for powered gliders resolve the disconnect of having design assurance on certain Yes Accepted from the scope: CS-22, CS-LSA, CS-23 level 1 day VFR and Light
(CS-22) has never been demanded before and is not in line with CS- elements of the powertrain (e.g. power controller) but not UAS.
22 Subpart H, where engines can be approved with less rigor than others (e.g. indication means).
CS-E (Far-33).
The two SC are independant.
The SC E-19 is a transveral SC addressing any kind of
What is the link between EHPS-SC and VTOL-SC?
electric/hybrid propulsion system for any A/C.
The Boeing
4 All No yes Noted For example, if an applicant wishes to certify a VTOL A/C with the
Company It would be recommended to have some type of explanation of the
electric propulsion system included in the A/C Type Design, the
link between this two SCs.
certification basis of the A/C would consist of at least the SC VTOL
and the SC E-19 EHPS.
DO-160 EMC effects is just covering electrical systems up to

Dedicated working groups in several standardisation bodies are
AMC Associated AMC should at least cover CS-E 80 (equipment) and its 270V dc, max 320V, surge voltage 425V. EHPS systems of
5 Rolls-Royce 25 Yes No Accepted currently working on the topic. The results of these WG is
EHPS.330(d) AMC and the use of DO-160 significantly higher voltage require a new test definition
intended to be used as a MoC.
concerning EMC.
The EHPS might contain much more Critical components than
the classic CS-E 850. There are other rotating components
That is why it is stated "at least". Guidance will be be provided
6 Rolls-Royce AMC EHPS.80 25 ...Associated AMC should at least cover CS-E 850… such as generator, e-Motor, and elements critical in respect of Yes No Accepted
accordingly.
propeller loss (reduction gearbox front housing), or loss of
integrity (single load path brackets), or electric shock etc.
TE.CERT.00142-002 © European Union Aviation Safety Agency. All rights reserved. ISO9001 Certified.
Proprietary document. Copies are not controlled. Confirm revision status through the EASA-Internet/Intranet.
An agency of the European Union
Page 1 of 77
AMC paragraph
7 Rolls-Royce 25 Repeated words "Fuel Contamination" Remove repeated words Yes No Accepted Corrected.
13
(include EHPS.350(e)).
If the "Essentially Single Fault Tolerant" criteria (of CS-E 50(c)(2))
are included for piston or turbine engines, and the EHPS forms part
of the functional mainline thrust shaft between one or more energy
Add section EHPS.350(e)(4):
sources and one or more propulsion devices, then the criteria
"If the EHPS controls an amount of thrust on a passenger-
should apply also to the EHPS control system.
carrying airframe equivalent to either: CS-E 50(c)(2) states "essentially single fault tolerant". The term
This has a substantial effect on the architecture of the EHPS control
(i) At least 50% of total airframe thrust in a centralised essentially in itself removes the complusory aspect of the single
system. Could the airframe afford to lose a significant proportion
position, such that "insufficient total thrust" should be fault tolerant.
of thrust from a single failure of its EHPS control system, many of
considered; or The SC E-19 is an objective based SC. As such, it is not the intent to
which (failures) could cause loss of one engine's worth of thrust? If
(ii) At least 50% of the equivalent engine thrust in a impose a design solution.
not, the criteria should be compulsory in the same way as CS-E
decentralised position, such that "asymmetric thrust" should However, the mentioned examples are fully relevant and should
50(c)(2) is for one engine, leading to redundancy in the system such
be considered; be looked at during the certification process.
AMC paragraph that, in full-up dispatch, No Single Failure of the EHPS control Partially
8 Rolls-Royce 25 then the "Essentially Single Fault Tolerant" criteria of CS-E Yes Yes The top/down approach of the safety assessment as proposed in
19 system shall cause Loss of Thrust Control equivalent to 10% of the accepted
50(c)(2) shall be met and demonstrated for the EHPS control EHPS.80 , starting from an A/C FHA should lead to a safety
total (centralised propulsion device) or 10% on one side
system. requirement at EHPS level that is adapted to the intended A/C
(decentralised propulsion devices, depending on turning moment).
If the amount of thrust controlled by the EHPS is less than 50% application.
If one EHPS controlled more than the equivalent of one engine's
of total airframe thrust in a centralised position and less than Safety and reliability requirements should be distinguished.
worth of thrust, this would put more eggs in one EHPS basket than
50% of the equivalent engine thrust in a decentralised position, Reliability requirements may not be related to the certification of
there were with the equivalent discrete engines, raising the EHPS
such that the risks of both "insufficient total thrust" and an aircraft but more related to operational requirements (For
failure risk level beyond that of the equivalent engine control
"asymmetric thrust" can both be shown to be insignificant example an A/C availability of 99.5%).
system. All the more reason to mandate equivalence in Essential
from all single EHPS control system failures, then the criteria
Single Fault Tolerance. This is more important for passenger-
remain as an AMC to EHPS.80."
carrying aircraft because Loss of Thrust Control could have an
immediate effect on passengers, assuming that any airframe may
be able to regain control prior to landing, following a significant
LOTC from the EHPS control system failure.
Associated "The Means of Compliance will be based on existing material: CS-E,
Interpretative CS-22 Subpart H…" is ambiguous. If a gas turbine based generator is No suggestion, as the intention/objective is not well The intention of this paragraph is to explain that the existing
9 Rolls-Royce 25 Yes No Noted
Material / Means used, does it mean that the gas turbine engine (that drives the understood. material may be used to show compliance to the SC E-19.
of Compliance generator) is expected to comply with CS-E?
Associated "EHPS.80 (c): Associated AMC should at least cover CS-E 850
Interpretative (Compressor, Fan and Turbine Shafts), AMC CS-E 850 and the No suggestion, as the intention/objective is not well
10 Rolls-Royce 25 Yes No Noted Yes, if a shaft is part of the propulsion system.
Material / Means associated CM". Would this also apply to all electric platforms, with understood.
of Compliance no gas turbine engine as a source of power?
Airbus propose to updated § 2. of the Associated Interpretative

Associated Material / Means Of Compliance section as follows (new
Interpretative The list of existing material quoted in paragraph 2 should include CS proposed text shown in underlined italic font):
11 AIRBUS 25 No Yes Accepted Other CS could be used.
Material / Means 23, CS 25, CS 27 and CS 29 2. The Means of Compliance will be based on existing material:
Of Compliance CS-E, CS-22 Subpart H, CS 23, CS 25, CS 27, CS 29 , ASTM F3338-
18, existing Special Conditions…
Language unclear. Interpetive Material and AMCs are EASA
Associated documents. Actual "Means of Compliance" is owned by applicant.
Interpretive The first two points seem reasonably clear on this. However, Clarfy intent. For example, should some refences to "AMC" be
12 Rolls-Royce 25 Yes No Accepted "Associated AMC" replaced by "The Means of Compliance".
Material / Means multiple "EHPS.xxx: Associated AMC should at least cover CS-E yyy" to "Proposed MoC" or similar.
of Compliance are confusing. Are they supposed to mean that the applicant's
proposed MoC for EHPS.xxx should consider the AMC for CS-E yyy ?
Lange Aviation
13 Associated... 25 Grammar “Contaminated fuel” double in note 13. Yes Accepted Corrected.
GmbH
Page 2 of 77
The term "installed" covers EHPS.370 (a) associated to EHPS.80

Partially
14 Airbus DS Contents 2 Missing Dedicated paragraph for Electrical Bonding (CS-E 135) Consider add missing paragraph Yes No (Hazardous EHPS effect adresses the risk of human injury).
accepted
Specific guidance will be provided in Means Of Compliance.
(except CS-25 aircrafts)

Should be qualified that it’s unmanned aircraft carrying people.
15 FAA DM EHPS.10 3 Otherwise, would all hazards below and related requirements Clarification Yes Accepted EHPS.15 "'hazardous EHPS effect" has been modified accordingly
apply? I.e concentration of toxic products, electrocution of crew,
etc.
(except CS-25 aircrafts)

16 FAA PH EHPS.10 3 Delete the “s” Yes Accepted Corrected.
“s” in aircraft should be eliminated
Paragraph 5.
“…interface aspects between rotors and/or propellers…”
There seems to be a need to differentiate between “rotors and
17 FAA DJ EHPS.10 3 Yes Noted This paragraph has been deleted as judged not necessary.
props” that are external to the EHPS and “rotors” that are an
integral part of the EHPS. This statement seems to be referring to
an external rotor as on a helicopter.
EHPS.10 is stating, that SC-EHPS is applicable for EHPS and the This paragraph has been deleted as judged not necessary.
interface to rotors and/or propellers. However, in EHPS.240 it is Rotors identified in EHPS.240 are to be understood as any rotating
directly addressing rotor design. On the other hand, applicability to element in an EHPS (rotor in an electric machine, of a compressor,
18 Volocopter EHPS.10 4 propellers is explicitly excluded and reference to CS-P is given. Yes Accepted a turbine, a fan...) that may release high energy debris in case of
Volocopter wants to better understand the scope of SC-EHPS and burst.
the potential boundary to rotors and/or propellers as well as Propeller are indeed excluded from the EHPS as being covered by
differentiation to be considered between rotors and propellers. CS-P.
The SC is applicable to all aircraft, regardless of the type
certification basis. Many sections refer to the safety objectives of The following intended aircraft applications have been removed
Lange Aviation Safety objectives (and other references to CS) should be
19 EHPS.10 3 this basis or the intended aircraft application. But these objectives Yes Accepted from the scope: CS-22, CS-LSA, CS-23 level 1 day VFR and Light
GmbH defined explicitely, if not or insufficiently defined in the CS.
are not defined for all CS, e.g. CS-22. Therefore those sections are UAS.
void from the beginning.
The SC states that CS-25 is excluded only due to lack of emission
requirements. It is reasonable to apply the same SC to e.g. CS-22
and CS-23, due to the similar scope and extent of the basic CS. But
in comparison CS-25 goes into much more detail due to higher risk The scope of the SC should be limited to certain CS, which are The following intended aircraft applications have been removed
Lange Aviation
20 EHPS.10 3 and complexity involved typically. It is therefore questionable if a similar in scope and level of detail. A more thorough and Yes Accepted from the scope: CS-22, CS-LSA, CS-23 level 1 day VFR and Light
GmbH
common SC should be established. This might either be too cursory detailed SC could be derived for CS-25. UAS.
to provide effective guidance, too detailed for other applications, or
feature many exemptions and distinctions according to the CS
involved.
Exclusion of CS-25 aircrafts based only on emissions omits the

opportunity for the other principles to apply for the purpose of
determining safe propulsion system architectures for future
Consider the scope and whether the principles could be
platforms.
21 Rolls-Royce EHPS.10 3 applied to potential EHPS of CS-25 aircraft whilst excluding the Yes No Accepted The scope has been modified accordingly.
Suggest rewording to say: "The emissions requirements of CS-25
emissions item.
aircrafts are excluded at this stage because they are not yet defined
for EHPS.", then refer to specific parts or regulations of CS-25 and
CS-E for those exclusions as required.
Fully supportive of the need to integrate the propulsion system

into the aircraft. This requirements shall be equivalent to
Additional certification requirements beyond this Special Condition section CS-E 20
need to be satisfied at the aircraft level in order to safely integrate Propose to reintegrate initial wording : “This Special Condition Not
22 SAFRAN EHPS.10 3 Yes No This paragraph has been deleted as judged not necessary.
an EHPS into a manned or unmanned aircraft and these are outside addresses the interface aspects between rotors and/or accepted
of the scope of this Special Condition. propellers and the need to consider the integration of the
Electrical Propulsion Unit into the manned or unmanned
aircraft.”
Page 3 of 77
The wording “power for fligt” (“… which is used to provide or

produce lift/thrust/power for flight”, “…that are not used to
produce lift/thrust/power in flight”) and the EHPS definition in
EHPS.15 give the impression that overlaps between EHPS and This is the intent of the various paragraphs where reference is
J. Jézégou
23 EHPS.10 3 powerplant system (in aircraft CS) or electrical power generation (in Observation No Accepted made to the Type-Certification basis of the intended aircraft
ISAE-SUPAERO
aircraft CS) or APU are possible, eventually leading to not clearly- application. (example of EHPS.370 (a))
defined interfaces between various systems and applicants (e.g.
EHPS vs. CS23.2430-Powerplant installation, energy storage and
distribution systems)
“(except CS-25 aircrafts)”

“Propellers are also outside the scope of this Special Conditions as
the certification specifications for propellers are provided in CS-P. “
No contradiction ha sbeen observed as the SC E-19 is not limited
Propeller excluded is in contradiction with Lift/thurst unit definition
to VTOL aircrafts.
given during discussion related to SC-VTOL:
Propellers are "products" as defined by the Basic Regulation. CS-P
6. Lift/thrust unit
Airbus defines the certification requirements for those products.
24 EHPS.10 3 A lift/thrust is considered to be any engine or motor that directly Clarify the definition Yes No Noted
Helicopters For the rotors, the certification requirements are provided in the
contributes to providing lift or thrust and includes its controller, the
CS of the intended aircraft application. For example, in a VTOL, the
connected effector (e.g. rotor, propeller, fan) and any related
SC VTOL provides the certification requirements for the rotors.
actuators (e.g. pitch change, tilting, vectoring).
Fans are covered by the SC E-19 (as part of an engine).
7. Lift/thrust system
The Lift/thrust system is composed of; the lift/thrust units, their
related energy supply and energy management system.
“EHPS.10 Scope
We ask EASA to either replace “Electrical Propulsion Unit” with
…
“Electric / Hybrid
This Special Condition addresses the interface aspects between
Propulsion System” here or provide clear definitions in order to
rotors and/or propellers and the conditions for installation of the
better understand
Electrical Propulsion Unit into a manned or unmanned aircraft.”
the scope and prevent misinterpretation. For example: where
The Boeing We ask EASA to consider whether an error was made using the
25 EHPS.10 3 is 'Electrical no yes Accepted This paragraph has been deleted as judged not necessary.
Company term “Electrical Propulsion Unit” here and to clearly define terms
Propulsion Unit' defined in this document? Is ‘Electrical
used in this document to avoid confusion and misinterpretation.
Propulsion Unit’ clearly
Additionally, we suggest using the term “electric” in lieu of
understood or is there a standard definition in a different
“electrical” in this application for consistency with other uses.
document?
Section EHPS.15 Terminology, defines Electric / Hybrid Propulsion
We recommend adding this definition to section EHPS.15.
System (EHPS), however 'Electrical Propulsion Unit' is not defined.
EHPS.10 SCOPE:
The Boeing
26 EHPS.10 3 EHPS.10 Applicability: no yes Accepted Corrected.
Company
This should consistent with other SC which uses applicability.
EHPS.10 Scope
…
This Special Condition is applicable to any Electric / Hybrid
Propulsion System, so called hereafter EHPS, which is used to
provide or produce lift/thrust/power for flight in any manned and
unmanned aircraft (except CS-25 aircrafts), both during normal and
Flight control computers are outside the scope of this SC.
emergency operations.
This Special Condition is applicable to any Electric / Hybrid The terminology "Propulsion System" is a reference to the Basic
Propulsion System, so called hereafter EHPS, which is used to Regulation (EU) 2018/1139 definition.
Electric or hybrid-electric propulsion aircraft to varying degrees will
The Boeing provide or produce lift/thrust/power, or potentially flight Partially It is intended that the new functions in which an EHPS is involved
27 EHPS.10 3 use electric machinery and gas powerplants driving rotors and/or no yes
Company control, for flight in any manned and unmanned aircraft accepted will be addressed via the top/down safety assessment approach.
propellers to provide both flight control and propulsion. This will be
(except CS-25 aircrafts), both during normal and emergency For example, on a VTOL A/C, the EHPS control system is intended
most common in highly distributed propulsion architectures using
operations. to control the engine speeds according to a speed law that will be
electric machinery directly driving rotors and/or propellers. We
defined by the Flight control computer(s).
accept using the label “Propulsion” in EHPS, but it is important to
recognize and clearly define that this system does not necessarily
have the same functions as a traditional gas powerplant driven
aircraft where the gas powerplant substantially just provides
thrust/power/lift. The simplest example is an eVTOL aircraft where
in many cases the lift rotors are the primary flight control effector.
Page 4 of 77
An alternative would be to use the term “Elecrtric / Hybrid Power

System” instead and then define it as providing thrust/power/lift
and potentially other functions such as flight control.
This is already covered by EHPS.30.

"Each EHPS Installation Manual will document the limitations Partially
28 TCCA EHPS.10 3 Suggest to add text, if needed The scope of the SC E-19 i snow limited to case where the
required for integration into each particular aircraft application." accepted
intended aircraft application is known.
Second paragraph states: “This Special Condition is applicable to Can an explanation be added as to what is meant by the
29 TCCA EHPS.10 3 any Electric / Hybrid Propulsion System without any power range applicability being limited to “System without any power range Noted Sentence has been deleted.
limitations.” limitations
Given the varying degrees of electrification, it is possible that a new

gas turbine engine design (for which the existing Part 33 rules The SC EHPS can be used to certify a turbogenerator based on a
would be adequate) could be certified using the EHPS rules because CS-E engine. The resulting safety level will be adapted to the
of the addition of electric propulsion components. For example: a intended aircraft application.
As deemed appropriate by the Agency, SC-EHPS may be
traditional turboprop engine is outfitted with an additional It is not the intent of EASA to apply systematically the SC EHPS to
applied to systems which interface with CS-E or CS-P products,
generator supplying partial power to other electrically driven props. any electric/hybrid propulsion system. If an applicant is willing to
30 TCCA EHPS.10 3 or in conjunction with CS-E standards. The EHPS TCDS and Noted
The entire system could be certified under SC-EHPS. The concern is make use of CS-E complemented with an additional Special
I&OM would require the installation of the specified
that a subsystem of an EHPS that is essentially a CS-E product may Condition, this can be possible and compatible with Part 21
certificated product, in accordance with EHPS.30.
result in a higher level for safety if CS-E is applied. It is understood requirements.
that the issue is design specific, but the Authorities should be Specific guidance will be provided in a Certification Memorandum
prepared for EHPS designs which incorporate new models of to part 21 regarding the ways to certify an EHPS.
existing CS-E engines.
The intent of the SC E-19 is to provide technical requirements for

an EHPS. It is not the intention of the SC E-19 to fix the scope of
Is this an 'open door' for DOAs to specify their system 'scope' for an
the DOA of a company.
Vertical EHPS? Different DOAs may include or exclude equipment within A stronger definition of the scope may aid both EASA and
31 EHPS.10 (Scope) 3 Yes Noted For the time being, EASA is willing to offer flexibility in order to
Aerospace this EHPS system which could lead to a divergence in achieved DOAs.
enable innovation.
safety (e.g. Batteries).
Specific guidance will be provided in a Certification Memorandum
to part 21 regarding the ways to certify an EHPS.
The intent of the SC E-19 is to provide technical requirements for

an EHPS. It is not the intention of the SC E-19 to fix the scope of
It is not clear whether the SC is intented for an Aircraft-TC applicant Applicability of SC could be stated more clearly and explicitly. the DOA of a company.
32 Flying Whales EHPS.10 EHPS.11 3 or EHPS–TC applicant? Can we use this SC to obtain a TC for EHPS The possibility of certifying an EHPS component with an ETSO Yes No Noted For the time being, EASA is willing to offer flexibility in order to
or only to be considred as a subpart to the Aircraft CS? could be clarified. enable innovation.
Page 5 of 77
Pitch Control System could be part of the applicability. To be

FARADAY Propellers are outside the scope of this Special Conditions. What
33 EHPS.10 Scope 3 Yes No Noted discussed on a case by case as for today during an engine
aerospace about pitch control systems ?
certification.
FARADAY Propellers are outside the scope of this Special Conditions. What
34 EHPS.10 Scope 3 Yes No Noted The same applicability as for piston and turbine engines applies.
aerospace about belt reducers or gearboxes ?
The text "This Special Condition is applicable to any Electric / Hybrid

Suggested text:
Propulsion System without any power range limitations" is
confusing and requires clarification. The range of an all electric Partially
35 Rolls-Royce EHPS.10 Scope 3 This Special Condition is applicable to any Electric / Hybrid Yes No The sentence has been removed
aircaft will differ from current operating range standards. The scope accepted
Propulsion System. Limitations with respect to operating range
should clarify that operating range considerations are not part of
are not in scope of this special condition.
this specical condition.
The scope of the special conditions does not explicitly mention that Please clarify if the SC E-19 scope is also for issuance of EHPS Both cases are identified in the SC E-19.
36 Rolls-Royce EHPS.10 Scope 3 the certification requirements provided are for the issuance of the type certificate (as mentioned in EHPS.30) or the EHPS need to Yes No Accepted Specific guidance will be provided in a Certification Memorandum
type certificate be certified under A/C TC. to part 21 regarding the ways to certify an EHPS.
A definition of an Integrated Propeller/Fan should be added to

EHPS.15 Terminology: Any rotating device that has blades,
shrouded or unschrouded, which is part of the EHPS and which
It seems to be implicitly assumed that shaft power would be is used to convert shaft power into thrust or lift for the aircraft.
The propeller (shrouded or unschrouded) is out of the scope of
converted to thrust using a propeller, for which CS-P provides the The requirements of CS-P shall apply, even though an
the SC E-19 as covered by CS-P.
airworthiness requirements. It is not clear how fans or ducted fans Integrated Propeller/Fan would not be type certificated to CS- Partially
37 Rolls-Royce EHPS.10 Scope 3 Yes No Fans are part of the propulsion system: this is the same logic as for
need to be treated, and when a rotating propulsive assembly is a P, but as part of the EHPS. An applicant may apply for relief accepted
turbine engines.
ducted fan or a shrouded propeller. It should be recognised that when agreeing the acceptable means of compliance to EHPS if
Open rotor are not considered at this stage for EHPS.
shrouded propellers/fans may be part of the EHPS. the integrated propeller/fan design has features that
inherently exclude characterisitics which are subject to CS-P
requirements.
Definition of the thrust need to be added.
Amend first paragraph :This Special Condition is applicable to
For consistency, we ecommand a different wording. EHPS cannot
any Electric / Hybrid Propulsion System, so called hereafter Not Fans are considered as being part of the scope. Therefore lift or
38 VOLTAERO EHPS.10 Scope 3 produce lift or thrust alone; it needs to be connected to a propeller, YES NO
EHPS, which is used to provide or produce power accepted thrust is applicable to EHPS.
fan or rotorcraft blades.
lift/thrust/power for flight
Delete paragraph “Electric / Hybrid Propulsion Systems that
are not used to produce lift/thrust/power in flight are outside
Wheels electric motors do not ensure the same function as an
Applicability should be extended to wheels electrical motors. We do of the scope of this Special Condition. As an example, electric Not
39 VOLTAERO EHPS.10 Scope 3 YES NO EHPS. They should be cosnidered as part of the landing gear
not understand why they are excluded. motors that drive wheels for taxiing or electric motors for air accepted
system.
conditioning systems are outside of the scope of this Special
Condition.”
This Special Condition follows the “one-size-fits-all” approach,
which has put unnecessary burden upon design- and production- Exempt CS-22 products:
organisations of GA-aircraft for years. In the course of the EASA “This Special Condition is applicable to any Electric / Hybrid
initiative GA-Roadmap this approach was realized to be contra- Propulsion System, so called hereafter EHPS, which is used to
productive. provide or produce lift/thrust/power for flight in any manned
This document conflicts with at least four out of six strategic and unmanned aircraft (except CS22 and CS-25 aircrafts), both
OSTIV principles that were set up by EASA in the GA-Roadmap: during normal and emergency operations. The following intended aircraft applications have been removed
40 Michael EHPS.10 Scope 3 One size does not fit all CS-25 aircrafts are excluded at this stage because emissions Accepted from the scope: CS-22, CS-LSA, CS-23 level 1 day VFR and Light
Greiner Instead, this SC covers all manned and unmanned aircraft (at this requirements are not yet defined for EHPS. UAS.
stage except CS-25) CS-22 aircraft are excluded because one size does not fit all.
Adopt a risk-based approach. Concerning Electric Propulsion there is already an existing
Although the safety assessment is supposed to lead to Special Condition SC E-01 for CS-22/LSA products. Concerning
proportionality, it is questionable to me, if the effect is really felt by Hybrid Propulsion a proportional Special Condition has still to
the designers. This document covers all objectives that potentially be defined.“
could lead to a CS-25 certification (not at this stage, but for a
Page 6 of 77
different reason). Now the first task to the designer is to discuss

away everything that is not applicable to a powered sailplane. As SC
E-19 could also be applied to pure electric propulsion systems, one
can simply compare it with SC E-01 to see the amount of difference.
Protect ‘what shows to work well’ unless there are demonstrable
and statistically significant safety reasons against doing so
This would require to recognise and develop the SC E-01. But
instead Special Condition E-19 contains the maximum objectives
due to its wide scope. Even when it is only an alternative to SC E-01,
it might become an arduous job for the designer to distance his
project from the objectives given in SC E-19. There is no connection
to the concepts, operational requirements, and levels of safety that
are already inherently weaved into CS22 and SC E-01.
In short, it would be appreciated, if it would clearly be said, that the
level of requirements/objectives for CS 22 is defined by SC E-01.
Safety assessments like in EHPS.80 are not the typical approach in
CS-22 certification. I agree that in such technology, which handles
much energy in small, confined spaces, brainwork must be required
to identify potential hazards. But design organizations in CS-22
world have not yet grown to such size, that they can handle such
formal approaches.
On the other hand, if designers have to discuss away many topics
like bird-strike for sailplanes, they will rather seek that their
national government opts-out for 600kg in Annex I of the BR. This
would be contra-productive since the appropriate level of safety of
CS-22 and SC E-01 would then be replaced by microlight standards.
Nothing gained, but much lost.
Make the best use of available resources and expertise
The introduction of CS E-19 will set a new standard with objectives
that go beyond existing SC E-01. For such an overthrowing project it
would be appropriate to investigate into available experience
among the CS-22 stakeholders. The Certification Directory/General
Aviation/Small Aeroplanes has a history of maintaining CS22 with
the support of OSTIV (ostiv.org). The Sailplane Development Panel
of OSTIV has founded a Working-group Electric Propulsion (WEP) to
gather experience and research activities on electric propulsion for
CS22 aircraft. The stakeholders are aware, that on the basis of
existing operational experience it will be necessary to continue the
development of objective-tailored SC-22.2014-01 and SC E-01. The
CS-22 community is willing to contribute. However, including CS-22
into the scope of SC E-19 could make such further efforts felt as
fruitless and frustrating.
Airbus propose to update the wording of EHPS.10 Scope as
The scope excludes CS-25 aircraft apparently only because of the follows (new proposed text shown in underlined italic font):
absence of emissions requirements. Airbus consider this exclusion This Special Condition is applicable to any Electric / Hybrid
is not justified. If the intent is ultimately that the requirements in Propulsion System, so called hereafter EHPS, which is used to
the proposed SC E-19 also apply for EHPS to be installed on CS-25 provide or produce lift/thrust/power for flight in any manned
aircraft, the general exclusion should be removed. It is not clear to and unmanned aircraft (except CS-25 aircrafts), both during
Airbus why the appropriate emissions requirements could not be normal and emergency operations. Note that for CS-25
enforced on EHPS via the aircraft certification basis. A note could be aircrafts are excluded at this stage because this Special Scope modified accordingly to include EHPS for CS-25 aircraft.
added about the emissions requirement question rather than a full Condition shall be completed with appropriate emissions The possibility to certify the EHPS as part of the intended A/C
Partially
41 AIRBUS EHPS.10 Scope 3 exclusion of CS-25 applications. requirements that are not yet to be defined for EHPS. NO YES application is not relevant in the SC E-19 as it is allowed by the
accepted
In addition, this paragraph should be updated to clarify the fact that This Special Condition is applicable to any Electric / Hybrid Basic Regulation (EU) 2018/1139. It is therefore considered
the Special Condition can be used as an element of the aircraft Propulsion System without any power range limitations. accepted in the EASA framework.
certification basis in complement to the necessary Electric / Hybrid Propulsion Systems that are not used to
installation/integration requirements pertinent to each intended produce lift/thrust/power in flight are outside of the scope of
aircraft application. this Special Condition. As an example, electric motors that
Finally the term Electrical Propulsion Unit is used only once in the drive wheels for taxiing or electric motors for air conditioning
SC in this Scope paragraph. The intent of using this specific term systems are outside of the scope of this Special Condition.
shall be clarified. Propellers are also outside the scope of this Special Conditions
as the certification specifications for propellers are provided in
Page 7 of 77
CS-P.
This Special Condition addresses the interface aspects between
rotors and/or propellers and the minimum conditions for
installation of the Electrical Propulsion Unit into a manned or
unmanned aircraft. It can be directly used as an element of the
concerned aircraft certification basis. However, additional
certification requirements beyond this Special Condition and
pertinent ot each intended aircraft application need to be
satisfied at the aircraft level in order to safely integrate an
EHPS into a manned or unmanned aircraft and these are
outside of the scope of this Special Condition.
Whereas it is understood that this SC could be applicable to any

Werner Scholz, Introduce: “Simplified versions of this SC and/or simplified
manned / unmanned aircraft, it should be mentioned that simpler The following intended aircraft applications have been removed
European criteria to show compliance are possible if possible, failure Partially
42 EHPS.10 Scope 3 version of this SC could exist for simpler aircraft and/or aircraft suggestion from the scope: CS-22, CS-LSA, CS-23 level 1 day VFR and Light
Sailplane conditions do not result into critical / hazardous failure modes accepted
where failure of the propulsion system does result into less UAS.
Manufacturers for the aircraft.”
hazardous conditions (e.g. as with a powered sailplane).
Werner Scholz,
European I am no expert in English language, but I believe the plural of Replace “aircrafts” with “aircraft” throughout the document.
43 EHPS.10 Scope 3 observation Accepted Corrected
Sailplane aircraft is aircraft (not aircrafts), same probably true for propeller… (And do the same with Propeller(s)).
Manufacturers
The notion of lift has to be kept as in some particular intended
PAGE 3 (for example) : This Special Condition is applicable to
applications as VTOL, the EHPS could participate to the lft of the
All the Mention of lift is outside of the scope of a propulsion system. Lift is any Electric / Hybrid Propulsion System, so called hereafter Partially
44 SAFRAN EHPS.10, EHPS.15 No Yes aircraft. However, is has been added that the the control of the
document related to aircraft manoeuver. EHPS, which is used to provide or produce power for accepted
lift to ensure the aircraft sustentation, controllability and
lift/thrust/power for flight
maneuverability is an aircraft function.
Electrical arcing is indeed a potential source of fire.

The paragraph does not provide the types of fire but only adresses
Partially the risk of fire in general, whatever the source of fire.
45 FAA GH EHPS.100 11 This missed the arc-fault concerns Yes
accepted The source of fire will be adressed in MOC.
Associated to this, EHPS.370 points to intended aircraft
application requirement which will adress also high voltages risks.
Paragraphs (a) and (b) in this section correspond to CS-e 130. If

we’re allowing hybrid systems that have liquid fuel burning engines, Partially The SC E-19 follows an objective based approach. The "how", as
46 FAA PH EHPS.100 11 Yes
don’t we need to have the appropriate versions of CS-e 130(b), (c), accepted developed in CS-E 130 will be adressed in MOC
(d), (e), (f), and (g) as well?
An acceptable probability, i.e. extremely remote, should be

Lange Aviation Partially Requirement is similar to existing requirement. Associated
47 EHPS.100 11 “Minimise probablity” is an abstract and undetermined expression. defined, depending on the effect of the fire on structure, Yes
GmbH accepted guidance will explain how to 'minimize'
crew,...
the risk of fire in general, whatever the source of fire.
Lange Aviation Batteries are not discussed here in detail, although they feature The inherent dangers of and the protection against a battery Not The type of fire will be adressed in MOC.
48 EHPS.100 11 Yes
GmbH high energy content and are not intrinsically safe in most cases. fire should be mentioned explicitely. accepted EHPS.380 will also provide requirements relative to the intended
aircraft application. Indeed, fire protection will not be the same
for a CS 23 level 1 aircraft and a VTOL enhanced category.
General (b) In addition, the design and construction of the EHPS must
The point is here to minimize internal fire that could result in the
Aviation minimize the probability of the occurrence of an internal fire Major/concep Not
49 EHPS.100 11 EHPS 100- (b) Why is Catstrophic not included here? non-containment of high energy debris.
Manufacturers that could result in structural Failure or Hazardous or tual accepted
The CAT failures are dealt in EHPS.100 (a)
Association Catastrophic EHPS Failure.
Specific guidance will be provided for a) in order to address the

Considering Smoke to be equally critical, whether smoke
toxicity linked to the materials used in the EHPS.
50 Flying Whales EHPS.100 11 requirements should be considered within the scope of EHPS or Clarification Yes No Noted
At aircraft level, the proper installation and ventilation will be
aircraft?
addressed.
Page 8 of 77
As a difference from CS-E, no design requirements (fire-grade,

shielding, ventilation, drainage) are included.
Lacking that, the A/C integrator will need to have detailed
information about how the particular engine has been certified in
order to ensure that fire requirements at A/C level are also fulfilled.
51 Airbus DS EHPS.100 11 Information regarding materials used, fire hardening of the engine Proposal is be included as part of the requirements or in AMC Yes No Accepted Associated guidance will explain how to 'minimize'
in general and all its components (in particular for the engine
mounting system or for any flammable fluid line or tank included as
part of the design), quantity and type of flammable fluids, electrical
installation stds used (...) need to be requested to assess the fire
risk at A/C level.
The SC E-19 follows an objective based approach. The "how", as

developed in CS-E 130 will be adressed in MOC. For example, on
If a combustion engine is part of the Integrated Hybrid Propulsion
VTOL aircraft, EASA has proposed other zones qualification in
System, all of the essential electrical systems for the continuation Suggest defining fire zone and fire resistant / fire proof Not
52 TCCA EHPS.100 11 order to cope with electrification.
of flight should be protected from effects of fire and also be fire requirements in this section accepted
Regarding the protection of A/C systems necessary for the
resistant or fireproof as determined by the certification authority.
continuation of the flight, this will be dealt as part of the aircraft
certification.
a) Removed from CS-E "In addition, the design and construction of

Engines must minimise the probability of the occurrence of an
internal fire that could result in structural Failure or Hazardous
Engine Effects."
CS-E 130(c) to (g) were not retained in this SC. Removing the
requirements related to fire protection of external, fuel/oil tank, Achieve equivalent level of safety by including a performance Partially The SC E-19 follows an objective based approach. The "how", as
53 TCCA EHPS.100 11
firewall, EEC, draining/venting, mounting structure and fire zone based version of these requirements accepted developed in CS-E 130 will be adressed in MOC
requirements for EHPS may not provide the same level of safety as
existing regulations. EHPS could contain many of the same, or
similar, fuel or oil systems and components as CS-E engines.
Additionally, the threat of battery fire should be specifically
considered for mount, controllers, and other components.
Fire protection section should specifically consider fire protection Consider adding specific requirement for EHPS mounting Partially The SC E-19 follows an objective based approach. The "how", as
54 TCCA EHPS.100 11
of EHPS mounting structure (fireproof, unless…?) structure fire protection capability. accepted developed in CS-E 130 will be adressed in MOC
Recommend adding:
"(c) EHPS high voltage electrical wiring interconnect systems
Another similar SC has an item (c) recommend adding text in the Partially developed in CS-E 130 will be adressed in MOC.
55 TCCA EHPS.100 11 should be protected against arc-faults. Any non-protected
suggested resolution. accepted On top of that it is also covered by the EHPS.370 and its related
electrical wiring interconnects should be analysed to show that
AMC.
arc faults do not cause a hazardous EHPS effect."
"…must minimize the probablily of occurrence…": what does Suggest revising text to "... must minimize the probability of
Partially Requirement is similar to existing requirement. Associated
56 Bell EHPS.100 (a) 11 "minimize" mean here? It would benefit from some more the occurrence to the extent needed to satisfy the SSA" to Yes No
accepted guidance will explain how to 'minimize'
clarification. clarify.
Paragraph a) address the minimization of the fire spread.

The requirement only requires provision to minimise the
developed in CS-E 130 will be adressed in MOC.
EHPS.100 Fire probability of the occurrence and spread of fire and subsequent Fire protection requirements should be made to be Partially
57 Rolls-Royce 10 No Yes The firewall requirement may be required for an internal
protection effects. While this is similar to CS-E130 the requirement does not equivalently rigorous as CS-E 130 accepted
combustion engine but not for an electric engine. Also to be noted
include the relevant CS-E 130 subsections regarding firewalls.
that electrical fires linked to the chemistry of the batteries may
require different means to avoid the spread of the fire.
Page 9 of 77
Airbus propose to update the wording of EHPS.100 Fire

Airbus note that the proposed paragraph is very much Objective Protection - as follows (new proposed text shown in underlined
Electrical arcing is indeed a potential source of fire.
Based oriented and much leaner than CS-E 130. The proposed sub- italic font):
paragraph (b) seems only applicable to turbine engines, hence may (a) The design and construction of the EHPS and the materials
EHPS.100 Fire Partially the risk of fire in general, whatever the source of fire.
58 AIRBUS 11 be kept but only as a supplemental specific requirements. With the used must minimise the probability of the occurrence and N Y
Protection accepted The source of fire will be adressed in MOC.
new electrical propulsion systems, Airbus consider that the spread of fire during normal operation and EHPS failure
Associated to this, EHPS.370 points to intended aircraft
electrical arcing risk also becomes a potential fire risk that deserves conditions, and must minimise the effect of such a fire.
application requirement which will adress also high voltages risks.
particular attention and should therefore be added (b) In addition, particular attention must be given to risks of
internal turbine fires and of high voltage electrical arcing.
It would be useful to have better guidance on fire zoning given the
EHPS.100 Fire AMC to cover fire zoning in relation to the risk of arcing as an
59 Rolls-Royce 11 introduction of new potential ignition sources and the fact that Yes No Accepted Associated guidance will explain how to 'minimize'
Protection ignition source.
arcing will occur and can’t be avoided. <See also comment 82>
FARADAY EHPS.100 Fire To what level should the design and construction of the EHPS and
60 11 Yes No Noted Associated guidance will explain how to 'minimize'
aerospace Protection (a) the materials minimise the probability of ….
FARADAY EHPS.100 Fire

61 11 Same question about the word "minimize" Yes No Noted Associated guidance will explain how to 'minimize'
aerospace Protection (b)
Batteries are indeed a potential source of fire.

In reference to « failue conditions » : the risk of fire in general, whatever the source of fire.
62 FAA DK EHPS.100(a) 11 Yes Noted
Including battery thermal runaway The source of fire will be adressed in MOC.
EHPS.380 will also provide requirements relative to the intended
aircraft application.
In reference to « minimise » :
63 FAA JF EHPS.100(a) 11 Yes Accepted Corrected accordingly
Inconsistent spelling. See next paragraph.
64 SAFRAN EHPS.11 3 Remove the notion of MoC specifically accepted & at project level when specifically accepted by the Agency at project level. Yes Yes Accepted Corrected accordingly
We suggest to include a new item:
The information security applied to aviation is a new topic for some
"(c) To comply with EHPS.350, the applicant can follow the
65 Embraer S.A. EHPS.11 3 applicants and its means of compliance may not be well known. yes no Accepted Specific guidance will be provided in the Means of Compliance.
guidance provided by ED-202A Airworthiness Security Process
The items (a) and (b) does not list any document like ED-202A.
Specification or propose an equivalent AMOC”.
Consistency has been ensured.

The "english style guide" from the European Comission
General comment: On the use of the word “shall” and “must”.
recommends to make use of "shall" when it is a bingin
Q1. Should the text throughout only use either “must” or "shall"?
66 TCCA EHPS.11 3 Suggest to clarify and revise text, if needed. Noted requirement (like Part 21). However, for CS or Special Conditions,
Q2. Is there an EASA policy which states that it is acceptable to use
as the requirements are non-enacting terms, the term 'must'
either term?
should be used. Indeed, an apllicant can devaite from a
requirement if he demonstrates an equivalent level of safety.
Werner Scholz, EHPS.11

EASA may accept also other alternative means of compliance than
European Acceptable Add “which may include consensus standards or other
67 3 consensus standards (e.g. requirements developed within Ostiv as suggestion Accepted This is the intent of the paragraph EHPS.11 (b)
Sailplane means of alternative means, when…”
part of the Ostivas [Ostiv airworthiness standards]).
Manufacturers compliance
EHPS: What is meant by Electrical Wiring Interconnection System?

This concerns all types of electric wiring and connectors necessary
Only EWIS related to production of lift/thrust/power (means High
for the good functioning of the EHPS.
68 Volocopter EHPS.15 5 Voltage lines), or as well the EWIS Low Voltage components, used Yes Noted
Nevertheless , the EWIS terminology has been removed as not
for example to generate control signals and low voltage power
applicable to all intended aircraft applications.
supply?
EHPS Control System:
69 Volocopter EHPS.15 5 Why are battery or energy storage device management systems Yes Noted Exclusion has been removed
specifically excluded from the EHPS Control System definition?
Page 10 of 77
The EHPS Control System excludes all battery management

systems, these systems are highly critical to the safety of the
Include the battery or energy storage management system as
Lange Aviation aircraft and should be discussed in this SC. Many types of batteries
70 EHPS.15 4 subsystem of the EHPS control system or define discrete Yes Noted Exclusion has been removed
GmbH are not intrinsically safe and feature a high energy content. This will
specifications.
cause catastrophic failures, if the battery management system and
recharging systems are not properly designed.
The SC refers to “electric engines”, when “engine” is usually used to “Electric engine” in this SC should be replaced by “electric
Lange Aviation Not Engine refers to the definition provided in the CS-Definition and
71 EHPS.15 4 describe an engine powered by fuel, i.e. turbine/piston engine. motor” to discriminate more clearly between turbine/piston Yes
GmbH accepted the Basic Regulation (EU) 2018/1139.
“Electric motor” is more appropriate. engine and electric motor.
Torque is considered as a limitation, not a rating. A rating is used

For electric motors a rating in terms of torque instead of power
Lange Aviation Not to delcared later on performances at aircraft level. It is not a
72 EHPS.15 4 might be more appropriate in certain cases. This comment applies Introduce torque as rating in addition to power and thrust Yes
GmbH accepted maximum value but the minimum power that any produced
to all mentions of “power and/or thrust” in this SC.
engine shall deliver during the entire flight and over its entire life.
“Failure to shut down” could relate to more serious (e.g. turning Corrected and replaced by "(vi) Complete inability to stop any
The point should be clarified to address the hazardous effect
Lange Aviation rotor) or less serious (e.g. control system) issues. In some cases a rotating parts
73 EHPS.15 5 caused, instead of the intended or accidental inability to shut Yes Accepted
GmbH shutdown of a subsystem might even not be possible or advisable, (vii) Complete inabilibty to isolate any component that could
down.
e.g. battery management and monitoring. cause a hazard to the aircraft "
Corrected and replaced by "(vii) Complete inability to stop any
For new applications, not to refer to EHPS, and prefer sub system rotating parts
74 SAFRAN EHPS.15 5 Complete inability to shut down the sub system of the EHPS Yes Yes Accepted
EHPS (viii) Complete inabilibty to isolate any component that could
cause a hazard to the A/C "
75 SAFRAN EHPS.15 4 Document refer to electric motor or electric engine Use only one wording : electric engine is preferred Yes Yes Accepted Corrected accordingly
Why the Battery or Energy Storage Management System are

excluded for the EHPS Control System? There is no reason to
76 SAFRAN EHPS.15 4 EHPS Control System definition No Yes Noted Exclusion has been removed
exclude it, and they may be highly linked to the whole EHPS
Control/Management System.
(viii) This effects deals with electrocution of person causing
fatal injury. Additionally, excessive magnetic field should be
77 SAFRAN EHPS.15 5 HAZARDOUS EHPS effect No Yes Accepted Corrected accordingly. Specific guidance will have to be provided.
added, potentially causing fatal injury people sensible to this
effect.
Operators & maintainers should be considered with different

“Hazardous EHPS effect […] (viii) Electrocution of crew, passengers,
Airbus approach compared to crew & passengers either by having a
78 EHPS.15 5 operators or maintainers, sufficient to cause serious or fatal injury.” Yes No Accepted Corrected accordingly
Helicopters dedicated safety classification or dedicated methodology to
Novelty is to include effect on maintenance people on Civil.
show compliance (e.g. industrial rules, …).
Electric Distribution System could also be included in to the

Whether Electrical Distribution System is in the scope? Only EWIS is
79 Flying Whales EHPS.15 4 definition to make sure that equipment such as contactors, Yes No Accepted
specified in the definition.
circuit breakers etc. are included within EHPS
(Emergency Rating) Yes, OEI rating as defined for a turbine engine can be considered
80 Flying Whales EHPS.15 4 Clarification Yes No Noted
Does this include OEI conditions? as an Emergency Rating
“EHPS.15 Terminology
…
EHPS Control System: A system or device that controls, limits, We ask EASA to explain and clarify why “battery or energy
The Boeing
81 EHPS.15 4 monitors or protects the operation of the EHPS or a sub-system of storage device management system” are excluded from this no yes Noted Exclusion has been removed
Company
the EHPS excluding any battery or energy storage device definition. Where are these elements covered?
management system.”
We ask EASA to clarify this definition. This definition seems to
Page 11 of 77
contradict the definition presented in the document for “Electric /

Hybrid Propulsion System (EHPS)”. The definition states: An Electric
/ Hybrid Propulsion System may include, but is not limited to,
electric motors, inverters, turbine engines, piston engines,
generators, electrical wiring interconnection systems, electrical
power generation, energy storage systems, integrated fans, cooling
systems and power management system. An EHPS is intended to
produce lift, thrust or power for flight.
“EHPS.15 Terminology
…
Emergency rating: Means an engine and/or generator rating
intended to be used in the event of a failure leading to a power
and/or thrust loss of a sub-system of the EHPS and requiring the
We ask EASA to clarify. We think emergency rating should not Rating definition has been reworded. However, ratings are used to
remaining sub-systems of the EHPS to compensate fully or partially
The Boeing just affect the engine and/or generator, but the entire EHPS Partially define the intended aircraft performances. For the energy storage
82 EHPS.15 4 the associated power and/or thrust loss.” no yes
Company including the energy storage system. We recommend changing accepted device, special atention will have to be made to ensure the proper
We ask EASA to clarify. We think this should also consider the
“an engine and/or generator” supply of electric power in all expected flight conditions.
energy storage system. Consider this example: if a battery string is
lost, the other string(s) must be able to support safe landing and
hence will have to tolerate higher discharge rate and might be
allowed to go to higher temperature limits (e.g. emergency energy
storage temperature rating).
Means the effect of Hazardous EHPS failure condition. As a
minimum, the following effects must be regarded as Hazardous
EHPS Effects:
i. Non-containment of high-energy debris,
ii. Concentration of toxic products in the air of the cabin that is
sufficient to incapacitate crew or passengers
iii. Significant thrust in the opposite direction to that commanded
by the pilot,
iv. Uncontrolled fire,
v. Failure of the EHPS mounting system leading to inadvertent EHPS Means the effect of Hazardous EHPS failure condition. As a
separation, minimum, the following effects must be regarded as Hazardous
vi. Release of the propeller by the EHPS, if applicable, EHPS Effects:
vii. Complete inability to shut down the EHPS. i. Non-containment of high-energy debris,
viii. Electrocution of crew, passengers, operators or maintainers, ii. Concentration of toxic products in the air of the cabin that is
sufficient to cause serious or fatal injury. sufficient to incapacitate crew or passengers
The SC E-19 addresses propulsion system that are not only
iii. Significant thrust in the opposite direction to that
The Boeing Not dedicated to VTOL.
83 EHPS.15 5 Many current VTOL configurations use propellers and rotors which commanded by the pilot, no yes
Company accepted The point adressed here is not the loss of thrust but the risk of
augment safety that could be used to improve the impact of effects iv. Uncontrolled fire,
release of high energy debris following propeller release.
considered Hazardous per CS-E510 g2 . CS-E510g(2) states the v. Failure of the EHPS mounting system leading to inadvertent
following effects must be regarded as Hazardous Engine Effects: EHPS separation,
(i) Non-containment of high-energy debris; vi. Release of the propeller by the EHPS, if applicable,
(ii) Concentration of toxic products in the Engine bleed air for the vii. Complete inability to shut down the EHPS.
cabin sufficient to incapacitate crew or passengers; viii. Electrocution of crew, passengers, operators or
(iii) Significant thrust in the opposite direction to that commanded maintainers, sufficient to cause serious or fatal injury.
by the pilot;
(iv) Uncontrolled fire;
(v) Failure of the Engine mount system leading to inadvertent
Engine separation;
(vi) Release of the Propeller by the Engine, if applicable;
(vii) Complete inability to shut the Engine down.
Losing one rotor may be considered major, rather than Hazardous,
since the effects may not produce a large reduction of vehicle
capabilities or safety margin.
Means a part that relies upon meeting prescribed integrity Means a part which failure is likely to result in Hazardous EHPS
specifications of EHPS.90 to avoid its Primary Failure, which is likely Effects, reliance must be placed on meeting the prescribed The SC E-19 addresses propulsion system that are not only
The Boeing to result in a Hazardous EHPS Effect. integrity specifications of EHPS.90 (EHPS critical parts) in order Not dedicated to VTOL.
84 EHPS.15 5 no yes
Company to support the objective of an Extremely Remote probability of accepted The safety objectives are driven by the intended aircraft
The SC does not provide information on the safety objectives being Failure 10-? (or provide equivalent information than SC-VTOL application and may therefore not be the same for all EHPS.
thought by the authority for EHPS per AMC VTOL.2510)
Page 12 of 77
In the case of hydrogen based electrical systems, is the hydrogen

Hydrodgen Storage System or hydrogen use is outside the scope
energy storage used for propulsion considered as part of the EHPS? Consider modifying EHPS.380 to cope with hydrogen energy
85 Airbus DS EHPS.15 4 No No Noted of the special condition.
If yes => EHPS.380 requires meeting Aircraft TC basis which may not storage system
EHPS.380 renamed to reflect the focus on propulsion battery.
include appropriated requirements for hydrogen
The mentioned aerodynamic effects can indeed lead to important

issues and they should therefore be considered.
“Hazardous EHPS effect […](iii) Significant thrust in the opposite However, the mentioned aerodynamic effects are consequences
direction to that commanded by the pilot,” of the reverse rotation that is already addressed.
Electrical machines can rotate in the reverse direction in case of Proposal is to also add aerodynamic and aeroelastic effects Not Aerodynamic stability, absence of flutter is also adressed via
86 Airbus DS EHPS.15 5 Yes No
control malfunction. This reverse rotation, especially in a non-pitch caused by the faulty operation of the EHPS. accepted EHPS.230 Virabtion Survey. EHPS.230 (c) also covers fault
controlled fan/propeller system can lead to strong aerodynamic conditions.
effects and potential fan/propeller flutter In any case, the mentioned list is non-exhaustive. It is a minimum.
If an applicant determines another failure effect, he can add it to
the list for its project during the certification process.
Short circuit arcs are indeed of high importance with regards to
EHPS but they may not necessarily be considered as Hazardous
EHPS failure condition.
Arc faults and their consequences (arc flash or arc blast) have
“Hazardous EHPS failure condition”
been added to (viii)
Another risk to consider is the structural damage due to electrical
Structural damage are already covered by the release of high
effects (e.g. short-circuit arcs) Proposal is to include additional risks related to structural Partially
87 Airbus DS EHPS.15 5 Yes No energy debris, the release of a propeller/rotor or the failure of the
Electro Magnetic Hazard could also be added here as a EHPS damage due to electrical effects and to EMH. accepted
EHPS mounting system.
malfunction could alter the frequencies and magnitudes of the
EMH effects should be assessed at A/C level and could therefore
EMH couplings and affect critical systems if not well mastered.
be part of the town/down analysis requested by EHPS.80.
In any case, the mentioned list is non-exhaustive. It is a minimum.
If an applicant determines another failure effect, he can add it to
the list for its project during the certification process.
Definition added.
Zeroavia
88 EHPS.15 high energy debris needs to be defined Accepted However, this question is often raised by the Industry and it might
James Lawson
be of interest to create a working group on it.
Toxic products are not envisaged in all EHPS configurations.

what toxic products are envisaged for an electric/ hybrid-electric
Zeroavia However, if the EHPS contains products that could be toxic for the
89 EHPS.15 propulsion system. Why can they not be prohibited completely, Noted
James Lawson crew or the passengers, this event should be looked as an
particularily if there is no compelling reason to use them?
Hazardous EHPS effect.
In ‘Hazardous EHPS effect’ terminology, item viii uses the word Suggest to replace with:
‘electrocution…’. The definition of electrocution is “to be killed or (viii) Electric shock of crew, passengers, operators or Partially
90 TCCA EHPS.15 5 The paragraph has been reworded.
severely injured by electric shock”, but the terminology uses maintainers, sufficient to cause serious or fatal injury. accepted
‘sufficient to’. Which then, by definition, equates to ‘electrocution’
Since these terms are reserved for aircraft, it is suggested
Catastrophic Aircraft Effect and Hazardous Aircraft Effect are
91 TCCA EHPS.15 5 direct reference be made to aircraft requirements or aircraft Accepted Corrected accordingly.
defined in this EHPS.
advisory material.
Hazardous EHPS failure condition:
"leading to" is ambiguous. Either use "resulting in" or
EHPS failure conditions leading to one of the following effects:
92 TCCA EHPS.15 5 "contributing to", depending on intent. Consider Revising for Accepted Corrected accordingly.
(i) Hazardous Aircraft Effect
clarity.
(ii) Catastrophic Aircraft Effect
Systematic use of EHPS rather than engine and/or generator

EHPS.15 & all the The definition of rating has been reworded.
93 SAFRAN 4 Consistency of the definition & wording to avoid confusion For example: Means a sub system EHPS engine and/or Yes Yes Accepted
document Consistency has been checked in the rest of the document.
generator rating intended to be…
The scope of the EHPS will be aircraft dependant, however the SC

Vertical Suggest to define the battery (for electric only aircraft, main Not
94 EHPS.15 (Term.) 4 E-19 does not cover many applicable requirements for the Yes Refert o EHPS.380 for associated requirements.
Aerospace power source) as out of scope of the EHPS. accepted
certification of a battery.
Page 13 of 77
Hazardous EHPS effect includes eletrocution of crew, passengers,

(viii) Product related injury to crew, passengers, operators or
EHPS.15 operators or maintainers, sufficient to cause serious or fatal injury.
95 Rolls-Royce 5 maintainers sufficient to cause serious or fatal injury such as No Yes Accepted Arc faults leading to arc flash or arc blast have been added.
Terminology Eletrocution is only one potential cause of harm due to an electrical
may be caused by electrocution or arc flash events
system. Others exist, for example, arc flash
Major Aircraft effect and Major Aircraft failure conditions are Failure effect have to be assessed at aircraft level.
EHPS.15 defined in the Terminology but not Major effect and failure Implement in EHPS.15 a definition for major effect and major Not However, EASA decided to keep the Hazardous EHPS effect in
96 Rolls-Royce 5 Yes No
Terminology conditions for the EHPS. This terminology is also used in EHPS.80 failure conditions for EHPS accepted order to allow the use of critical parts as it is made today for
<linked to comments 7 and 47> turbine engines.
Control System definition inconsistent because all component
control/protection system seems to be incuded exept for the
EHPS.15 battery management system (BMS). The rationale is not clear. With
97 Rolls-Royce 4 Clarify the rationale Yes No Accepted Exclusion of the BMS has been removed
Terminology regards to component control and protection at component level,
there is no difference between a protection system for the battery
and component protection for an e-motor
Failure Conditions and Effects are defined, acceptable rates (eg
Extremely Remote) are not, despite being used in the body of the Add appropriate Terminology refences, or a reference to The extremely remote rate as mentioned in EHPS.80 (d)(1)(i) as
EHPS.15
98 Rolls-Royce 4 document. Is this an intentional omission ? If so, would there not external definition (in Associated Interpretive Material / Means Yes No Accepted been explained as being the one defined in the associated Type-
Terminology
be a pointer to an external definition required ? of Compliance section ?). Certification basis of the intended aircraft application(s)
[See also comment 51 from JvdM]
Failure conditions leading to one of the following effects:
Definition of "Hazardous EHPS failure condition" should include
EHPS.15 (i) Hazardous Aircraft Effect
99 Rolls-Royce 5 failure conditions leading to Hazardous EHPS Effect Yes No Accepted Added
Terminology (ii) Catastrophic Aircraft Effect
<see also comment 7 which questions reference to Aircraft Effects>
(iii) Hazardous EHPS Effect
Hazardous EHPS effect: (vi) refers only to propeller. Does not Same logic as for today CS-E engines. Fans are addressed via FBO
EHPS.15 "…propeller/fan, regradless whether or not it is integrated in Partially
100 Rolls-Royce 5 include other types of propulsive devices that convert shaft power Yes No and the risk of release of high energy debris.
Terminology the EHPS," accepted
to thrust. Aircraft rotor has been added.
Probabilty Terms such as "Extremely Remote" are not defined. This

EHPS.15 is a sensible approach because the definition of "Extremely
101 Rolls-Royce 4 Not applicable. Comment is a positive observation only. Yes No Noted
Terminology Remote" is aircraft platform dependent, i.e. 1E-07 for CS-25 aircraft
and 1E-06 for some CS-23 aircraft.
Why does the EHPS control system definition exclude the battery or A system or device that controls, limits, monitors or protects
EHPS.15 energy storage device management system. If these are part of the the operation of the EHPS or a sub-system of the EHPS
102 Rolls-Royce 4 No Yes Accepted Exclusion has been removed
Terminology EHPS scope then they are part of the EHPS control system <see also including any battery or energy storage device management
comment 49> system where these are within the scope of the EHPS.
Page 14 of 77
Emergency rating. This should allow the option for time based
There is no exclusion to time based emergency ratings. In fact, the
EHPS.15 emergency ratings such as those for turbine engines for multi-
103 Rolls-Royce 4 include the option of time based emergency ratings Yes No Accepted maximum permitted duration for any rating is requested as per
Terminology engined rotorcraft in CS-E. EHPS.40 should also specifically refer to
EHPS.40(d). This includes emergency ratings.
this under Emergency ratings.
Lift/thrust/power are mentioned. This does not mean that they

We recommend to modify the last sentence as such : “An EHPS
EHPS.15 Improve EHPS definition. EHPS cannot produce lift or thrust alone; it Not have to produce all of them. Propellers are indeed exlcuded but
104 VOLTAERO 4 produces power., is intended to produce lift, thrust or power YES NO
Terminology needs to be connected to a propeller, fan or rotorcraft blades. accepted fans are not. If a fan is part of the EHPS, then the EHPS will
for flight.”
produce lift or thrust
We recommend to delete the definition of
- Hazardous EHPS effect
- Hazardous EHPS failure condition
EHPS.15 - Catastrophic Aircraft Effect Not
105 VOLTAERO 5 and 6 Improve coherence with well known definition YES NO Consistency has been ensured.
Terminology - Hazradous Aircraft Effect accepted
- Hazardous Aircraft Failure Condition
- Major Aircraft Effect
- Major Aircraft Failure Condition
These three plans define a closed-loop system which link the
assumptions made in the Engineering Plan to how the part is
Avoid misunderstanding as we already have documents defined.
manufactured and maintained in service; the latter two aspects
The proposed “ Engineering Plan” is already covered by the
are controlled by the Manufacturing and Service Management
Certification programme and the Maintenance Manual. We recommend to delete the definition of
Plans respectively.
EHPS.15 The proposed “ Manufacturing Plan” is already covered by the - Engineering Plan Not
106 VOLTAERO 6 YES NO The objective for an applicant is to develop a closed loop system
Terminology Master drawing list and the drawings. - Manufacturing Plan accepted
where the combination and interconnectivity of these elements
The proposed “ Service Management Plan” is already covered by - Service Management Plan
enhances product integrity. Speicif guidance will be provided to
the Maintenance Manual. The repair Manual has never been
identify the skill sets that should be present in establishing the
requested.
three plans, with aim of ensuring cross discipline inclusion to
achieve a closed loop system.
The need for defining in this Special Condition a specific category – Airbus propose to update the wording of EHPS.15 Terminology
Hazardous EHPS effect – is not obvious. On the contrary, Airbus as follows:
consider that it creates undue complexity and confusion in the way Delete the following lines in the table:
to perform the safety demonstration for an EHPS. Identifying a Hazardous EHPS effect
specific Hazardous EHPS effect may only remain meaningful for the Hazardous EHPS failure condition
EHPS.15 Not The EHPS hazardous effect allows to make use of critical parts in
107 AIRBUS 5 turbomachine part of hybrid system. Therefore, Airbus propose to Catastrophic Aircraft Effect NO YES
Terminology accepted the EHPS in the same logic as for CS-E
delete all the definitions of EHPS/Aircraft effects and Failure Catastrophic Aircraft Failure Condition
conditions from the Terminology paragraph and to refer only to Hazardous Aircraft Effect
aircraft effects and failure conditions in the rest of the Special Hazardous Aircraft Failure Condition
Condition, except when specifically discussing non-containment of Major Aircraft effect
turbomachine high-energy debris and propeller release. Major Aircraft Failure Condition
EHPS.15
"Means an engine and/or generator rating intended to be used in The term engine (even for electric motor) has to be kept for
Terminology - Not
108 Rolls-Royce 4 the event of a failure….." It is suggested that the term 'motor' Add the term 'Motor' Yes No consistency purposes with the Basic regulaion and the CS-
"Emergency accepted
should be added in addition to engine and/or generator Definitions
rating"
EHPS.15 "Means an engine and/or generator rating intended to be used….." The term engine (even for electric motor) has to be kept for
Not
109 Rolls-Royce Terminology - 4 It is suggested that the term 'motor' should be added in addition to Add the term 'Motor' Yes No consistency purposes with the Basic regulaion and the CS-
accepted
"Normal rating" engine and/or generator Definitions
EHPS.15
Terminology It would be helpful to include examples of potential categories of
110 Rolls-Royce "Inadvertant 5 exceedances, such as: voltage, current, torque, speed, temperature Add examples as listed Yes No Accepted Examples added
transient EHPS etc.
exceedance"
EHPS are different from a single motor as they most of the time
This and each of these Aircraft Effects may be an over reach for an include several motors. As such, failures modes cannot be only
EHPS.15
engine manufacturer. Determining if a failure at the engine level is assessed anymore at motor level but at aircraft level (e.g. when
111 FAA GH Catastrophic 5 Clarify why these definitions are included herein. yes Noted
Catastrophic at the aircraft level is the installer’s responsibility and the propulsion system takes part in the flight control function).
Aircraft Effect
the installer is best skilled to do this. This is why safety objectives have to be derived from the intended
aircraft application. The aircraft manufacturer will provide these
Page 15 of 77
data as it is already done today between aircraft manufacturers

and engine manufacturers. EHPS manufacturers do need to take
into account safety objectives that are provided by the aircraft
manufacturers in order for them to be able to perform the
complete aircraft safety analysis.
include several motors. As such, failures modes cannot be only
assessed anymore at motor level but at aircraft level (e.g. when
Not sure how these can be required at the engine approval level as the propulsion system takes part in the flight control function).
EHPS.15 they are dependent upon the installation. The engine approval This is why safety objectives have to be derived from the intended
112 FAA JP Catastrophic 5 holder does not have control over these effects and conditions, the yes Noted aircraft application. The aircraft manufacturer will provide these
Aircraft Effect installer is responsible for this evaluation. This seems to assume the data as it is already done today between aircraft manufacturers
engine approval is part of the aircraft. and engine manufacturers. EHPS manufacturers do need to take
Not sure how these aircraft effects and conditions are known by the propulsion system takes part in the flight control function).
EHPS.15 the EHPS OEM. These electric propulsion aircraft are not “typical This is why safety objectives have to be derived from the intended
113 FAA DJ Catastrophic 5 configurations” we are used to seeing. UAS are also addressed in yes Noted aircraft application. The aircraft manufacturer will provide these
Aircraft Effect this special condition and the failure conditions/effects will vary data as it is already done today between aircraft manufacturers
greatly with configuration and operation. and engine manufacturers. EHPS manufacturers do need to take
The term emergency has been chosen with regards to the diversity
The term “emergency” implies to me a potentially catastrophic
of the new products architecture. Some EHPS will be able to cope
event is possible. Should this term be used especially since many
EHPS.15 with the loss of 1 engine, 2 engines, 3 engines…Therefore the term
applications using an EHPS will have distributed propulsion which
114 FAA DJ Emergency 4 yes Noted OEI (One Engine Inoperative) become not usable for all EHPS. On
one of the benefits is the accommodation of propulsion failures?
ratings top of that the EHPS could suffer from power loss in case of failure
For helicopters we use the phrase OEI. Shouldn’t we consider
of battery pack and not only due to the failure of one of the
something more along those lines?
engines.
Since Energy Storage is being considered in this special condition
EHPS.15
should “thermal runaway” be mentioned? It may be contained and Thermal runaway will falls most probably into the category
115 FAA DJ Hazardous EHPS 5 yes Noted
not cause an uncontrolled fire but will certainly affect the energy Catastrophic Aircraft effects
effect
supply for propulsion.
EHPS.15 Relative to Hazardous

116 FAA DM Hazardous EHPS 5 Refer to comment above. For unmanned aircraft carrying load only Clarification yes Accepted If applicable has been added
effect (no people), some of these hazards don’t apply
I find all the definitions below quite confusing.

Seems to me it’s intended to link the effects to the failure
EHPS.15 conditions noted in the TC basis. If so, I don’t see the link between
The EHPS hazardous effect allows to make use of critical parts in
117 FAA DM Hazardous EHPS 5 the TC basis and Hazardous EHPS effects. Meaning you’ll always yes Noted
the EHPS in the same logic as for CS-E.
failure condition have to account for those Hazardous EHPS effects regardless what’s
in the TC basis. I may be missing something, but if this is true, then
why all the other definitions of catastrophic, aircraft level, etc?
EHPS.15
It is not clear that this definition is needed or that it is a true
118 FAA JF Hazardous EHPS 5 yes Accepted (iii) Hazardous EHPS effect has been added
definition. Do all Haz EHPS failure conditions lead to (i) or (ii)?
failure condition
EHPS.15
Again, used of “abnormal” is not a clear qualifier. Why not model
Inadvertent
119 FAA DM 5 from EASA’s CS-Definitions of inadvertent transients (speed, yes Accepted Corrected accordingly
transient EHPS
torque, and temperature). These definitions don’t use “abnormal”
exceedance
Page 16 of 77
Not clear the intended use of “normal” which is a vague qualifier.

You clearly define “emergency rating” as linked to some propulsion
Normal rating removed
EHPS.15 failure. But you define “normal rating” to relate to the type of flight Suggest not using “normal rating” and “normal transient”, just
120 FAA DM 4 yes Accepted Normal transient exceedances is kept. The definition is deemed
Normal rating operations. Usually, flight operations are normal, abnormal, and “rating” and “transient”.
clear enough to avoid confusion with operations.
emergency. For example, an aborted takeoff is an abnormal flight
condition. I think would be confusing.
We suggest to change the text from:
An Electric / Hybrid Propulsion System may include, but is not
limited to, electric motors, inverters, turbine engines, piston
engines, generators, electrical wiring interconnection systems,
electrical power generation, energy storage systems,
EHPS.15, Electric Generators, electrical power generation, energy storage systems integrated fans, cooling systems and power management For the time being, EASA is willing to offer flexibility in order to
/ Hybrid are typically part of the aircraft electrical system and certified system. An EHPS is intended to produce lift, thrust or power Not enable innovation.
121 Embraer S.A. 4 yes no
Propulsion under aircraft regulations. Recommended to keep these items out for flight. accepted Specific guidance will be provided in a Certification Memorandum
System. of the scope of this SC. To: to part 21 regarding the ways to certify an EHPS.
An Electric / Hybrid Propulsion System may include, but is not
limited to, electric motors, inverters, turbine engines, piston
engines, integrated fans, cooling systems and power
management system. An EHPS is intended to produce lift,
thrust or power for flight.
A sub-system of the EHPS may include examples such as a
turbine engine, a piston engine, an electric engine, a generator,
Generators, electrical power distribution system, and energy For the time being, EASA is willing to offer flexibility in order to
an electrical power distribution system, a EHPS control system
EHPS.15, Sub- storage system are typically part of the aircraft electrical system Not enable innovation.
122 Embraer S.A. 4 or, an energy storage system. yes no
system of EHPS and certified under aircraft regulations. Recommended to keep accepted Specific guidance will be provided in a Certification Memorandum
To:
these items out of the scope of this SC. to part 21 regarding the ways to certify an EHPS.
A sub-system of the EHPS may include examples such as a
turbine engine, a piston engine, an electric engine or, an EHPS
control system.
The SC needs to recognise the effect on the propulsion system of
Consider adding that consideration should be given to the the
extracting secondary offtakes for aircraft use. Typically this is Specific guidance will be provided in the Means of Compliance
123 Rolls-Royce EHPS.20 6 effect of secondary offtakes (electrical, hydraulic, pneumatic Yes No Accepted
discussed in the certification requirements for configurtion and when the secondary offtakes may have an effect on the EHPS.
etc.) on the EHPS
interfaces, Endurance test etc
“The list of all the parts and equipment, including references to the
124 Airbus DS EHPS.20 6 Consider add “including SW builds” Yes No Accepted Added
relevant drawings, …” Software (SW) is missing
Airbus propose to update the wording of EHPS.20 EHPS

Configuration as (new proposed text shown in underlined italic
font)follows
The list of all the parts and equipment, including references to
This paragraph requires to establish the list of all parts and
EHPS.20 EHPS the relevant drawings, which define the proposed type design
125 AIRBUS 6 equipment which defines the type design. The wording type design NO YES Accepted Paragraph (b) has been added accordingly.
Configuration of the EHPS, must be established. When the EHPS is certified as
is not appropriate if there is no Type Certificate for the EHPS.
part of the Aircraft Type Certificate, this corresponds to the list
of all the parts and equipment, including references to the
relevant drawings which define the EHPS configuration for the
aircraft type design.
The loads induced by any part of the EHPS must be identified in
the installation instructions (according to EHPS.30(b)).
The loads induced by the intended aircraft application must be
established by the aircraft design holder (according to the
Distinction is made now between the loads induced by the EHPS
aircraft specifications)
and the loads induced by the intended aircraft application.
Note: We are recommending to add a new paragraph EHPS.35, Partially
126 SAFRAN EHPS.200 11 Loads are assumptions. Yes Yes EHPS.30 covers already the needs of CS-E 35 and it will allow to
corresponding to the CS-E 30 “Assumptions”, that allows to accepted
have these assumptions clear in the installation manual.
take into consideration the intended aircraft characteristics.
Guidance will be provided accordingly.
‘Loads induced by any part of the EHPS’ is quite generic and a
clear AMC should be established to list the different cases to
take into consideration (type of loads, case to be considered,
etc…).
Page 17 of 77
Proposal is to add the underlined text “(a) The loads induced

To be in line with the EHPS.220, load assumptions coming from
by any part of the EHPS or induced by the intended aircraft This is covered by EHPS.30 (b)(7). Specific guidance will be
127 Airbus DS EHPS.200 11 aircraft (i.e. gyroscopic, interface...) need to be declared in the Yes No Accepted
application must be established. Load assumptions coming provided.
installation manual
from aircraft need to be declared in the installation manual.
Werner Scholz, The headline “fatigue loads” implies that perhaps a full blown-up
The following intended aircraft applications have been removed
European EHPS.200 Static fatigue analysis might be required. Add regarding guidance and/or introduce some tiering (i.e. Partially
128 11 suggestion from the scope: CS-22, CS-LSA, CS-23 level 1 day VFR and Light
Sailplane and fatigue Loads Again, for CS-22H the engine is required to run safe for 50 hours simplified requirements for simpler aircraft). accepted
UAS.
Manufacturers and that’s it basically…
Airbus propose to update the wording of EHPS.200 as follows

(new proposed text shown in underlined italic font):
EHPS.200 Strength
(a) The static and fatigue loads induced by any part of the EHPS
or induced by the intended aircraft application must be
established.
(b) A stress analysis must show that there is suitable design
EHPS.200 Static
margin at the declared operating limits for each of the EHPS
and Fatigue EHPS.200 deals with the loads and the proper function of all
sub-system such that the EHPS will function properly under the
Loads, EHPS.210 systems under these loads
loading conditions established in EHPS.200(a).
Strength, The intent of these three paragraphs might be simplified and merge Partially EHPS.210 is especially focused on the stress analysis.
129 AIRBUS 11 & 12 (c) (1) The EHPS mounting attachments and related structure, N Y
EHPS.220 into a single paragraph in line with the existing CS-E 100 accepted
must be able to withstand the specified loads without failure,
Mounting EHPS.220 is removed as covered by EHPS.30, EHPS.200 and
malfunction or permanent deformation
Attachment end EHPS210
(2) Whent the EHPS is not certified as part of the Aircraft Type
Structure
Certification, the maximum allowable loads for the mounting
attachments and related structure must be specified in the
Installation Manual
(d) Maximum stresses in the EHPS must be determined by tests,
validated analysis, or a combination thereof, and must be
shown not to exceed minimum material properties defined in
EHPS.50
Cross reference to EHPS.30 is now made in the paragraph
EHPS.200 Approved documents referred to, first letters should be capitalized,
EHPS.200.
130 TCCA EHPS.210 11 and consider referring to EHPS.30 and EHPS.40 as appropriate to be Make edits. Accepted
Paragraph 220 has been suppressed and is now covered by
EHPS.220 consistent with the rest of the SC.
EHPS.200 and 210.
EHPS.200 The paragraph is unclear. The aircraft designer will deal with loads
Not EHPS.200 should be maintained, especially if the EHPS is certified
131 VOLTAERO Static and fatigue 11 and fatigue by compliance with the aircraft certification We recommend to delete paragraph EHPS.200. YES NO
accepted as stand-alone product.
loads requirements to obtain the TC or STC.
AMC on EHPS.200 should be corrected in a way to clearly state:

“…should at least cover CS-E 190, where applicable”. Otherwise, all It is not mandatory to fulfill requirments for aerobatic use. AMC
132 Volocopter EHPS.200(b) 12 Yes Accepted
EHPS would need to be designed to fulfill requirements for will be reworked. However, the requirement is correct.
aerobatic use which is unreasonable.
Added accordingly.
133 SAFRAN EHPS.210 11 (a) Lack electrical stress (a) “A mechanical, thermal and electrical stress…” Yes Yes Accepted
Sepcific guidance will be provided in the Means of Compliance.
(b) a test or a validated analysis may not be possible for all

EHPS parts (i.e. some does not undergo any significant stress)
and the means to demonstrate the maximum stress should be
Partially
134 SAFRAN EHPS.210 11 (b) validated analysis transfer MoC. Proposal: “Maximum stresses in the EHPS must Yes Yes This will be part of a specific guidance
accepted
be determined by satisfactory practice for the material
involved, due account being taken of the particular form of
construction and the most severe operating conditions…”
Page 18 of 77
Design margins need to take into consideration the defined flight Suggest defining the design margins across the flight and
135 TCCA EHPS.210 11 Accepted Sepcific guidance will be provided in the Means of Compliance.
and environmental envelope. environmental envelope.
Mechanical, thermal, and electrical stress analyses must Added accordingly.

136 FAA GH EHPS.210 (a) 12 Here the electrical stress was lost yes Accepted
show… Sepcific guidance will be provided in the Means of Compliance.
It is accepted and of course needed that the operation of the EHPS

does not result into exceeding stresses and thermal loads which
Werner Scholz, cause failures. Nevertheless, if the margins for all parts and
European EHPS.210 properties need to be shown, this could become a rather arduous Add regarding guidance and/or introduce some tiering (i.e. Partially
137 11/12 suggestion from the scope: CS-22, CS-LSA, CS-23 level 1 day VFR and Light
Sailplane Strength task – especially for simpler aircraft. It would be much more useful simplified requirements for simpler aircraft). accepted
UAS.
Manufacturers for the applicant to suggest a typical operation cycle and then show
by testing x-times this cycle that the system works properly and
does not fail (same philosophy as in CS-22H.
138 SAFRAN EHPS.22 7 Typo : to remove the word “or” Alternatively the Instructions for Continued Airworthiness or… Yes No Accepted Corrected
“EHPS.22 Identification
…
(b) Major EHPS modules that can be changed independently in
service must be suitably identified so as to ensure traceability of
parts and to enable proper control over the interchangeability of We ask EASA to clarify and define what Major EHPS modules
The Boeing Reworded. Modules has been replaced by "engine modules" and
139 EHPS.22 7 such modules with different EHPS variants.” are. Suggest changing “modules” to “components or no yes Accepted
Company EHPS components and sub-systems has been added.
Clarification Needed: "Major EHPS Modules" is not defined subsystems”
anywhere in the document. We ask EASA to define it in order to
avoid confusion and interpretations. The term “module” is also not
used anywhere else and can be confused with specifically applying
to “battery modules”.
Your understanding is correct.

Does "variants" also mean to include "derivatives"? If yes, then we 'Derivatives' is no more a used term in EASA during the
140 TCCA EHPS.22 7 Suggest to clarify intent, if applicable Accepted
suggest to make sure that it is interpreted as such for future use. certification process.
Specific guidance will be provided in the Means of Compliance.
"Major EHPS modules that can be changed independently in service

must be suitably identified so as to ensure traceability of parts and
to enable proper control over the interchangeability of such Add conditional statement: "Where parts are required to be
141 Rolls-Royce EHPS.22 (b) 7 Yes No Accepted Coorected accordingly.
modules with different EHPS variants." - This requirement traceable, or identifiable to manage interchangeability,……",
precludes designs which may be able to satisfy all requirements
without needing to be traceable

Sub-paragraph (a) would only be applicable if there were an EHPS
identification as follows (new proposed text shown in
Type Certificate equivalent to the existing Engine Type Certificate. It
EHPS.22 EHPS underlined italic font): Partially
142 AIRBUS 6 is therefore too restrictive and should be updated to remain NO YES EHPS.22 (a) removed to avoid redundancy with Part 21.
identification (a) For the elements of the EHPS that are covered by their own accepted
applicable to a situation where the EHPS does not have a Type
Type Certificate / ETSO, identification must comply with
Certificate
21A.801 (a) and (b), and 21A.805 as necessary
Werner Scholz,
European EHPS.22 Is it really needed to include a requirement (markings of parts)
143 6/7 Delete requirement if found to be a duplication. suggestion Accepted EHPS.22 (a) removed to avoid redundancy with Part 21.
Sailplane Identification which is valid for all parts of the aircraft anyway?
Manufacturers
Page 19 of 77
This assumes that the EHPS is a single element mounted, similar to

Airbus an existing turbomachine. Given the modular nature of EHPS Partially EHPS.220 has been removed as covered by EHPS.30, EHPS.200 and
144 EHPS.220 12 Reword “(b) Each EHPS element mounting attachment..." Yes No
Helicopters systems, it would be better to state that "Each EHPS element accepted 210.
mounting attachment..."
This is addressed in the definition of Hazardous EHPS effect.
EHPS.220
The EHPS mountings will be addressed in the specific guidance of
Mounting No specific fire requirements on features of the EHPS which form Is this covered under Hazardous EHPS Effects (v) EHPS
145 Rolls-Royce 12 Yes No Noted EHPS.100. For example, the means of compliance may be different
Attachment and part of the mounting structure or EHPS attachment points. Sepatation?
for an internal combusiton engine installed in a designated fire
Structure
zone and for an air-cooled electric engine.
(a) Thrust is added and as for the EHPS.210, all EHPS parts will
not undergo significant vibration stresses. Proposed text : “
The EHPS must be designed and constructed to function
throughout its normal operating range of rotor speeds and
146 SAFRAN EHPS.230 12 Introduce power or thrust Accepted Corrected accordingly
EHPS output power or thrust, including defined exceedances,
without inducing excessive stress in any all affected parts of
the EHPS parts because of vibration and without imparting
excessive vibration forces to the aircraft structure”
General
(c) The effects on vibration characteristics of excitation forces The complete aircraft design is required to perform an assessment
Aviation Major/concep Not
147 EHPS.230 12 EHPS 230- (c) - Why is catastrophic not included? caused by Fault conditions must be evaluated and shown not at aircraft level. This part of the aircraft certification process when
Manufacturers tual accepted
to result in a Hazardous or catastrophic EHPS Effect. assessing the EHPS installation.
Association
The vibration survey may be based on a FEA if the model used has
148 EHPS.230 why only vibration survey, why not FEA? Noted been validated.
Zeroavia Specific guidance will be provided in the Means of Compliance
James Lawson
A Performance Based Rule version of this could be added,
similar to: "[...] throughout the declared flight envelope and EHPS.230 is based on CS-E 650 for which all MoC related words
Compared to EHPS.230 (b), CS-E 340 (Vibration Test) specifies the Partially
149 TCCA EHPS.230 12 EHPS operating range for the intended installation have been removed.
margins that should considered at each power setting accepted
configuration. Adequate design margin must be demonstrated Specific guidance will be provided in the Means of Compliance.
at critical conditions
States 'electric field excitation' please clarify in the AMC what this
Vertical AMC to clarify scope of the ‘electric field excitation’ including
150 EHPS.230 (b) 12 means (EMI or current fluctuations causing vibrations, or Yes Accepted Specific guidance will be provided in the Means of Compliance
Aerospace sources.
electrically induced magnetic excitation?)
Further definition in an AMC to define what does EASA

Vertical
151 EHPS.230 (c) 12 Please clarify the boundary of 'fault conditions' consider to be the fault conditions level > system level or Yes Accepted Specific guidance will be provided in the Means of Compliance
Aerospace
Aircraft level fault conditions?
I don’t think this adequately captures the types of loads that

electrical systems would generate and pass-on to the surrounding
systems to and in particular high frequency vibration, whether
torsional or radial resulting from high frequency pulse width
modulation, and the fact that it propagates through the system,
EHPS.230 "electrical" has been replaced by "electromagnetic".
152 Rolls-Royce 12 due to probably low damping. Brackets and sensors would be more Add some consideration for additional sources of vibration. Yes No Accepted
vibration Specific guidance will be provided in the Means of Compliance.
likely to have high frequency resonance modes due to their light
weight and stiffness, ironically causing control and protection
devices to be more sensitive to vibration than on a traditional gas
turbine. It refers to “rotor speeds” and “electrical field excitation”
which could be misleading.
Page 20 of 77
(c ) imposes a more stringent requirement than EHPS.80. For

EHPS.80, it is acceptable to have Hazardous EHPS Effects occurring
at a rate that is Extremely Remote, when parts are subjected to
nominal fatigure loads. To require that parts whose failure may
"(c) The effects on vibration characteristics of excitation forces
result in Hazardous EHPS effects do not fail when subjected to
caused by Fault conditions must be evaluated and shown not
fatigue loads resulting from failure (Fault) conditions is regarded to
EHPS.230 to result in a Hazardous EHPS Effect with a probability that is Not
153 Rolls-Royce 12 be overly stringent. The mitigation to prevent the onset of Yes No Consistency with CS-E 650 (g) is maintained.
Vibration Survey unacceptable under EHPS.80." accepted
Hazardous EHPS effects may involve shutting down the affected
component (to limit accumulation of fatigue cycles and prevent
This is similar to the approach of CS-E 525.
structural failure), where the shut-down function also has an
inherent failure rate. Such combinations of failures can be modelled
by Fault Tree Analysis, but would never be able to demonstrate a
null rate of occurrence.
Airbus propose to update the wording of EHPS.230 Vibration

EHPS has been added.
In subparagraph (c), it is not clear what ‘Fault conditions’ need to Survey - as follows:
Hazardous and Catastrophic aircraft effects are not considered as
EHPS.230 be considered and why only Hazardous EHPS Effect shall be (c) The effects on vibration characteristics of excitation forces Partially
154 AIRBUS 12 N N the complete aircraft design is required to perform an assessment
Vibration Survey prevented. caused by EHPS fault conditions must be evaluated and shown accepted
at aircraft level. This part of the aircraft certification process when
Further clarification should be candidate for a future MOC. not to result in a hazard (High Energy Debris, Propeller release,
assessing the EHPS installation.
hazardous or catastrophic aircraft effects)
The wording could be interpreted in a way that a survey could

include something like a ground vibration test and / or simulation
Werner Scholz, Specific guidance will be provided in the Means of Compliance.
of a wide range of frequencies, etc.. At least for simple aircraft it
European EHPS.230 Add regarding guidance and/or simplify the wording of the Note that the following intended aircraft applications have been
155 12 should be sufficient to demonstrate safe operation over the full suggestion Accepted
Sailplane Vibration Survey paragraph. removed from the scope: CS-22, CS-LSA, CS-23 level 1 day VFR and
operation range without undue vibration. If this would be sufficient
Manufacturers Light UAS.
to fulfil this requirement, then at least add guidance material to
explain this without the danger of misunderstanding.
The more likely distributed nature of an EHPS makes a vibration

EHPS.230 Add wording to emphasise the importance of interface This is covered by EHPS.30.
156 Rolls-Royce 12 survey problematic. It will be very installation dependent and the Yes No Accepted
Vibration Survey management and set a suitable working group looking at AMC Specific guidance will have to be defined.
aircraft interfaces will be very difficult to specify.
EHPS.230 We recommend to delete in paragraph a) :”to the aircraft Partially In the event where the intended aircraft application is not known,
157 VOLTAERO 12 The EHPS designer does not know the aircraft design. YES NO
Vibration Survey structure”. accepted specific guidance will be provided in the Means of Compliance.
158 Rolls-Royce EHPS.230(b) 12 Scope needs to include all magnetic flux in motors or generators. Replace "electrical" with "electromagnetic". Yes No Accepted Corrected accordingly
For the use of an EHPS for a VTOL, the use of the term 'rotor' may
Consider rewording ‘Rotors’. Depending on the type of aircraft 'Rotors' - consider rewording to "rotating parts" within the indeed lead to confusion. However, the SC E-19 is not only
Vertical Partially
159 EHPS.240 13 (CTOL / VTOL) there may be a mix of Rotors (left devices) and EHPS. CS-P is defined to be outside of this SC scope, stating Yes intended for VTOl applications.
Aerospace accepted
propellers (forward thrust devices) "rotors" may confuse the reader. A 'rotor' definition in the context of the SC E-19 has been included
in EHPS.15.
AMC is linked to CS-E 840 but should also cover CS-E 850 for
160 SAFRAN EHPS.240 13 Associated AMC shaft failure/loss of load cases. Yes No Accepted Specific guidance will be provided in the Means of Compliance
‘Sufficient strength’ shall be defined in the associated MoC.
Consistency with CS-E is maintained.

General (b) Rotors must be shown to provide adequate strength margin
Hazardous and Catastrphic aircraft effects are not considered as
Aviation with respect to burst, growth and damages, that could result in Major/concep Not
161 EHPS.240 13 EHPS- 240-(b) - Why catastrophic is not included? the complete aircraft design is required to perform an assessment
Manufacturers a hazardous or catastrophic EHPS effect, above the certified tual accepted
Association operating conditions and speeds assumed in EHPS.240 (a).
Page 21 of 77
If the EHPS contains a compressor or a turbine, it must be

Consistency with CS-E is maintained.
General demonstrated that after Failure any single compressor or
Hazardous and Catastrphic aircraft effects are not considered as
Aviation turbine blade will be radially contained and that no Hazardous Major/concep Not
162 EHPS.240 13 EHPS 240 - Why catastrophic is not included? the complete aircraft design is required to perform an assessment
Manufacturers or catastrophic EHPS Effect can arise as a result of other tual accepted
Association damage to the EHPS that is likely to occur before the EHPS is
shutdown following a blade Failure.
this is not sufficiently defined to be verifiable? Is this a normal or

Zeroavia
163 EHPS.240 abnormal overspeed i.e. an overspeed that is the result of a failure? Noted Specific guidance will be provided in the Means of Compliance
James Lawson
Combinations of failures?
Airbus Acceptable overspeed margins will be included in the

164 EHPS.240 13 Include in AMC acceptable overspeed margins Yes No Accepted Specific guidance will be provided in the Means of Compliance
Helicopters corresponding AMC?
Flying Whales would like to understand what are the categories of A 'rotor' definition in the context of the SC E-19 has been included
165 Flying Whales EHPS.240 13 Clarification Yes No Accepted
rotor considered on this requirement? in EHPS.15.
“EHPS.240 Overspeed and Rotor Integrity

…
(b) Rotors must be shown to provide adequate strength margin
The Boeing with respect to burst, growth and damages, that could result in a
166 EHPS.240 13 We ask EASA to define what “adequate margin” is. no yes Accepted Specific guidance will be provided in the Means of Compliance
Company hazardous EHPS effect, above the certified operating conditions
and speeds assumed in EHPS.240 (a).”
The definition of “adequate margin” is not provided and introduces
significant ambiguity as written.
Define rotors: as per comment to Subpart A, it is suggested to
certify the gas turbine or piston engine portion of the Hybrid
A 'rotor' definition in the context of the SC E-19 has been included
167 TCCA EHPS.240 13 Note comment for the Subpart A. propulsion systems through the existing rules (CS-E or CS-APU) Accepted
in EHPS.15.
and this Special Condition to insure minimum safety
requirements at the integration level.
No margin between he speeds considered and the operating Add "Adequate design margin must be demonstrated" to Added.
168 TCCA EHPS.240 13 Accepted
conditions are required. include conditions beyond certified operating conditions. Specific guidance will be provided in the Means of Compliance.
Please clarify the intent of (c) "EHPS operating limitations that

affect rotor structural integrity must not be exceeded in service.".
169 TCCA EHPS.240 13 Please review and provide clarification. Accepted This has been suppressed.
Intent is unclear as the operating limits are stated to not be
exceeded in service by their definition.
Partially
170 FAA GH EHPS.240 (a) 13 The last sentence in (a) could be captured in the AMC yes Specific guidance will be provided in the Means of Compliance
accepted
The term "adequate margin" is used here, but that's vague. Does
171 Bell EHPS.240 (b) 13 Add guidance towards what is considered "adequate" margin Yes No Accepted Specific guidance will be provided in the Means of Compliance
adequate margin mean it's tested up to 125% RPM, or similar?
Page 22 of 77
Airbus propose to update the wording of EHPS.15 Terminology

as follows (new proposed text shown in underlined italic font):
This paragraph applies to any type of rotor that may be used in
an EHPS (i.e. turbine rotor, cooling fan rotor, electric motor
rotor…)
(a) A rotor overspeed must not result in either rotor burst,
rotor growth or other damage that could result in a hazardous
EHPS.240 This paragraph is understood as being applicable to any rotor EHPS effect. This must be shown by test, validated analysis, or
Airbus A 'rotor' definition in the context of the SC E-19 has been included
172 Overspeed and 13 within the EHPS. This might be specified since several type of rotors a combination of both. Applicable assumed speeds must be Yes No Accepted
Helicopters in EHPS.15.
Rotor Integrity will be used in future Electric/Hybrid propulsion systems. declared and justified. Those shall account for failure
conditions, including loss of load.
with respect to burst, growth and damages, that could result in
a hazardous EHPS effect, above the certified operating
conditions and speeds assumed in EHPS.240 (a).
(c) EHPS operating limitations that affect rotor structural
integrity must not be exceeded in service.
Airbus propose to update the wording of EHPS.240 Overspeed

and Rotor Integrity - as follows (new proposed text shown in
underlined italic font):
This paragraph applies to any type of rotor that may be used in
an EHPS (i.e. turbine rotor, cooling fan rotor, electric motor
rotor…)
(a) A rotor overspeed must not result in either rotor burst,
rotor growth or other damage that could result in a hazard
((High Energy Debris, Propeller release, hazardous or
EHPS.240 This paragraph is understood as being applicable to any rotor
catastrophic aircraft effects). This must be shown by test, A 'rotor' definition in the context of the SC E-19 has been included
173 AIRBUS Overspeed and 13 within the EHPS. This might be specified since several type of rotors N Y Accepted
validated analysis, or a combination of both. Applicable in EHPS.15.
Rotor Integrity will be used in future Electric/Hybrid propulsion systems.
assumed speeds must be declared and justified. Those shall
account for failure conditions, including loss of load.
with respect to burst, growth and damages, that could result in
a hazard (High Energy Debris, Propeller release, hazardous or
catastrophic aircraft effects), above the certified operating
conditions and speeds assumed in EHPS.240 (a).
(c) EHPS operating limitations that affect rotor structural
integrity must not be exceeded in service.
EHPS.240
CS-E 840 % levels are not read-across here, what should be used
174 Rolls-Royce Overspeed and 13 Clarify the acceptable levels of margin. Yes No Accepted Specific guidance will be provided in the Means of Compliance
then?
Rotor Integrity
Werner Scholz,
EHPS.240 (b) what are adequate strength margins? (b) Specific guidance for 'adequate strength margin' will be
European (b) clarify
175 Overspeed and 13 (c) of course, operating limitations must not be exceeded in suggestion Accepted provided in the Means of Compliance.
Sailplane (c) delete as this is obvious
Rotor Integrity service… (c) suppressed
Manufacturers
176 Rolls-Royce EHPS.240(a) 13 Capitalization for consistency "Hazardous EHPS Effect" Yes No Accepted Corrected accordingly
For the time being, EASA is willing to offer flexibility in order to

enable innovation.
Cranfield
States “if” the EHPS is certified as part of the aircraft certification. Is EHPS can be certified as part of the aircraft or a stand-alone
177 Aerospace EHPS.25 7 Clarification of wording or intent on certification of EHPS. Yes No Noted
there an alternative? e.g. an EHPS certificate? engine product.
Solutions Ltd
Page 23 of 77
(b) The Instructions for Continued Airworthiness must be provided

in dedicated manuals. Alternatively the Instructions for Continued
178 Rolls-Royce EHPS.25 7 Correct typographical error Yes No Accepted Corrected
Airworthiness or can be provided in the aircraft relevant manuals if
the EHPS is certified as part of the aircraft certification.
179 TCCA EHPS.25 7 In (b) delete the word "or" Suggest to delete text, if needed Accepted Corrected
Suggest this section define what ICA would consist of at the A similar wording, performance-based, as CS-23 amendement 5
Not
180 TCCA EHPS.25 7 ICA section is too general. integrated package ( i.e. internal combustion engine + electric has been used.
accepted
motors/generators + power distribution ). Specific guidance will be provided in the Means of Compliance.
Lange Aviation
181 EHPS.25 (b) 7 Grammar Delete “or” in “...Airworthiness or can...” Yes Accepted Corrected
GmbH
We recommend to delete paragraph b):

EHPS.25 (b) The Instructions for Continued Airworthiness must be
Instructions for Improve coherence with the practise. Paragraph b) is not useful. It provided in dedicated manuals. Alternatively the Instructions Not EASA has to define in which form and manner the manuals have to
182 VOLTAERO 7 YES NO
Continued seems much better not to define the format. for Continued Airworthiness or can be provided in the aircraft accepted be provided.
Airworthiness relevant manuals if the EHPS is certified as part of the aircraft
certification.
EHPS.25
(c ) Does not consider mandatory scheduled operational
Instructions for
checks/tests. It may not be practicable to implement built-in-tests "…each mandatory replacement time, operation check,
183 Rolls-Royce Continued 7 Yes No Accepted Reworded to take into account all kind of actions.
for all functions, especially functions that are mechanical in nature, structural inspection…"
Airworthiness
so it is possible that scheduled operational checks are required.
(ICA)
EHPS.25
Provisions for critical parts mentioned in CS-E 25 (b) is covered by
Instructions for Why is the full scope of CS-E 25 not included. For example the
Partially EHPS.25 and EHPS.90.
184 Rolls-Royce Continued 7 provisions for critical parts. There is a requirement within EHPS.90 Include the full scope of CS-E 25 No Yes
accepted The SC E-19 is objective based. Specific guidance will be provided
Airworthiness regarding ICA but the scope of ICA should be fully defined here.
in the Means of Compliance.
(ICA)
Airbus propose to update the wording of EHPS.25 Instructions

EHPS.25 for Continued Airworthiness (ICA) - as follows:
Instructions for b) The Instructions for Continued Airworthiness must be
185 AIRBUS Continued 7 Typo to be corrected provided in dedicated manuals. Alternatively the Instructions YES NO Accepted Corrected
Airworthiness for Continued Airworthiness or can be provided in the aircraft
(ICA) relevant manuals if the EHPS is certified as part of the aircraft
certification.
Within aircraft falling under Part-ML (e.g. all sailplanes) there is a

clear separation between airworthiness limitations and TBO
EHPS.25
Werner Scholz, intervals. Hard ALI (typically the maximum flight time hours for the
Instructions for
European structure) cannot be changed without certification action in Introduce a clear definition what ALI and what TBO should Airwothiness limitations and TBO are indeed 2 separate data. TBO
186 Continued 7 suggestion Noted
Sailplane accordance with Part-21, whereas TBO intervals might be changed include. does not necessarily fall into the Airworthiness limitations.
Airworthiness
Manufacturers in the aircraft maintenance plan. This proposed EHPS.25 puts both
(ICA)
types of definitions under the ALI which is too onerous for later
operators.
187 Volocopter EHPS.25(b) 8 Remove “or” Yes Accepted Corrected

Not This is not a typo. Word with big letters are refering to defintions
188 Volocopter EHPS.250 14 Failure failure Yes
accepted providede by EASA. Refer to CS-Definitions amdt 2
EHPS is typically being powered by small shaft turbines which
are likely having may have a radial compressor component
…. After failure any single compressor or turbine blade will be Partially Specific guidance will be provided in the Means of Compliance.
189 Rolls-Royce EHPS.250 13 (impeller --> tri-hub burst) and a free turbine. Hence Yes No
radially contained… accepted Specific guidance will be provided on the wording "likely to occur".
containment requirements should be more in agreement with
the also consider the requirements of CS-APU.
Page 24 of 77
Should reflect also the blade failure in the electrical

motors/generator.
Proposed text : EHPS.250 addresses now containment for all kind of rotating
190 SAFRAN EHPS.250 13 This paragraph does not cover electrical motor/generator No Yes Accepted
'If the EHPS contains a compressor or a turbine or equivalent parts.
bladed disc, it must be demonstrated that after Failure any
single compressor or turbine blade will be contained and...'
General
EHPS.250 - Suggest adding that the energy levels and trajectories
Aviation Major/concep The word 'radially' has been removed. Specific guidance will be
191 EHPS.250 13 from any axial debris exiting the EHPS should be defined in the Accepted
Manufacturers tual provided as part of the means of compliance.
installation manual.
Association
Airbus Is this applicable to open rotor /prop fans? It should be explicitly

192 EHPS.250 13 Explicitly states if applicable to open rotor/prop fans Yes No Noted Open rotor or propeller are not considered as part of the SC E-19.
Helicopters stated

EHPS.250 Compressor or turbine blade failure containment
demonstrated that after Failure any single compressor or
turbine blade will be radially contained and that no Hazardous
EHPS Effect can arise as a result of other damage to the EHPS EHPS.250 addresses now containment for all kind of rotating
that is likely to occur before the EHPS is shutdown following a parts.
The containment requirement should be applicable to any high Partially
193 Embraer S.A. EHPS.250 13 blade Failure. yes no However, EASA does not request to provide containment of rotor
energy rotor, not limited to compressors and turbines. accepted
To: failure for the entire compressor or turbine disks. Same logic as
EHPS.250 High-energy rotors containment CS-E is applied.
If the EHPS contains a high-energy rotor, it must be
demonstrated that after Failure any rotor will be radially
contained and that no Hazardous EHPS Effect can arise as a
result of other damage to the EHPS that is likely to occur before
the EHPS is shutdown following a rotor Failure.
Is this applicable to open rotor /prop fans? It should be explicitly

194 Airbus DS EHPS.250 13 Explicitly state if applicable to open rotor/prop fans Yes No Noted Open rotor or propeller are not considered as part of the SC E-19.
stated
Not
195 TCCA EHPS.250 13 Note comment for the Subpart A. Suggest to redefine the concept. Refer to answer provided for comment for Subpart A
accepted
Designs may include one or more fans, should be rewritten to

196 TCCA EHPS.250 13 Include consideration for fan failures. Accepted Paragraph has been reworded.
include.
EHPS.250
Compressor or
197 Rolls-Royce turbine blade 13 Grammar. "shutdown" is a noun, not a verb. "...before the EHPS is shut down following…" Yes No Accepted Corrected accordingly.
failure
containment
Airbus propose to update the wording of EHPS.250 Compressor
or Turbine Blade Failure Containment - as follows (new
proposed text shown in underlined italic font):
EHPS.250 It is not clear why the containment requirement is limited to radial
Compressor or containment. Axial containment should also be required. In
demonstrated that after failure any single compressor or
198 AIRBUS Turbine Blade 13 addition, the wording may be improved to specify that the blade N Y Accepted Corrected accordingly
turbine blade will be radially contained. In addition, it shall be
Failure failure and damages subsequent to the blade failure are to be
demonstrated that no hazard (High Energy Debris or Propeller
Containment considered
Release, hazardous or catastrophic aircraft effects) can arise as
a result of subsequent damage to the EHPS that is likely to
occur before the EHPS is shutdown following a blade Failure.
This should be interpreted as any rotating item, including bits of the
rotor, gears, etc… not “compressor and turbine blades”. I think
EHPS.250 EHPS.250 addresses now containment for all kind of rotating
199 Rolls-Royce 13 hybrid engines will have reduction gearboxes, that seems inevitable Clarify the definition. Yes No Accepted
containment parts.
given the need for light weight, high power density motors (more
efficient) and slow fans.
Page 25 of 77
Is it worth mentioning specific issues, such as drag and potential

200 Rolls-Royce EHPS.260 13 Consider examples as listed Yes No Accepted Examples will be provided in a specific guidance.
overspeed of an unloaded windmilling device?
General If any of the EHPS main rotating systems continue to rotate

Aviation after the EHPS is shutdown while in flight, this continued Major/concep Reworded to make reference to the safety assessment made
201 EHPS.260 13 EHPS 260 - Why catastrophic is not included? Accepted
Manufacturers rotation must not result in any Hazardous or Catastrophic tual under EHPS.80.
Association EHPS Effects.
EHPS.260 Continued Rotation
The requirement imposes a more stringent requirement than
EHPS.80. For EHPS.80, it is acceptable to have Hazardous EHPS
ffects occurring at a rate that is Extremely Remote. EHPS.260 does
"If any of the EHPS main rotating systems continue to rotate
EHPS.260 not provide scope for a combination of continued rotation and pre-
after the EHPS is shut down while in flight, this continued
202 Rolls-Royce Continued 13 existence of latent failures that reduce the safety margins. For Yes No Accepted Corrected accordingly
rotation must not result in any Hazardous EHPS Effects with a
Rotation example, continued rotation with a failure in an oil circuit that is
probability that is unacceptable under EHPS.80."
only used during windmilling may result in Hazardous EHPS Effect.
An FTA will consider the rate of occurrence of both and would
demonstrate an Extremely Remote probability of Hazardous EHPS
Effects, but would not demonstrate a null rate.
EHPS.260 Consistency with CS-E wording is maintained.
Airbus The paragraph shall be updated in order to require to prevent If any of the EHPS main rotating systems continue to rotate Partially
203 Continued 13 Yes No Specific guidance will be provided as part of the Means of
Helicopters hazards not only for the main rotating system after the EHPS is shutdown while in flight, this continued accepted
Rotation Compliance.
rotation must not result in any hazards (High Energy Debris or
Propeller release, hazardous or catastrophic aircraft effects)
Airbus propose to update the wording of EHPS.260 Continued

Rotation - as follows (new proposed text shown in underlined
The paragraph shall be updated in order to require to prevent
EHPS.260 italic font)
hazards beyond the perimeter of the EHPS. Reworded to make reference to the safety assessment made
204 AIRBUS Continued 13 If any of the EHPS main rotating systems continue to rotate N Y Accepted
In addition, a MOC shall be added to precise the meaning of the under EHPS.80.
Rotation after the EHPS is shutdown while in flight, this continued
main rotating systems.
rotation must not result in any hazards (High Energy Debris or
Propeller release, hazardous or catastrophic aircraft effects)
The term ‘sudden’ is unclear, proposed text : “The EHPS must

be designed and/or installed such that it is capable of
Not
205 SAFRAN EHPS.270 14 Rain conditions satisfactory operation throughout its specified operating No Yes Consistecy with CS-E wording is maintained
accepted
envelope when subject to maximum rain conditions in flight
envelope…”.
Specific guidance based on CS-E will be provided as part of the

206 TCCA EHPS.270 14 What is " the certification standard concentration of rain"? Add direct reference to current certification rain environments. Accepted
Means of Compliance.
EHPS.270 to 290 have no equivalent requirement with regards to Water ingestion is requested for piston engines in CS-E 430.
piston engines in CS-E. This might lead to a competitive CS-E 230 dedicated to piston engines deals with design
The requirements should be in line with the requirements for
Lange Aviation disadvantage of EHPS compared to piston engines. It is not clear precautions for the risk of icing and blockage of the air induction
207 EHPS.270 - 290 13-14 pistion engines, or it should be differentiated according to the Yes Accepted
GmbH why EHPS should fulfill additional requirements compared to other system, covering so the risk of icing and snow.
potential hazards or particularities of the EHPS in question.
propulsion systems. Why is this required for gas turbines and not EHPS.290 (a) allows to take credit from the engine installation to
for piston engines? cover the bird or hail strike (cowlings protections, propeller...)
There could be improved clarity of what the 'operating The opeation under rain conditions are considered as normal
Vertical EHPS.270 and envelope' allows the TC DOA to select or avoid when showing operations, whereas flight under icing or snow conditions can be
208 14 EHPS.270 allows 'operating envelope' but EHPS.280 does not. Yes Accepted
Aerospace 280 compliance. Consider whether 'operating envelope' should be forbidden as part of the aircraft flight manual.
in both EHPS.270 and 280. Specific guidance will be provided in the Means of Compliance.
Page 26 of 77
Werner Scholz,
For sailplanes, no certification standard concentration of rain is Add “…subject to sudden encounters with the certification The following intended aircraft applications have been removed
European EHPS.270 Rain Partially
209 13 / 14 defined; it should be possible either to not allow operation in rain standard concentration of rain as applicable to the category of suggestion from the scope: CS-22, CS-LSA, CS-23 level 1 day VFR and Light
Sailplane conditions accepted
or to use word like “light / heavy rain” without such a definition. aircraft.” UAS.
Manufacturers
The opeation under rain conditions are considered as normal

EHPS.280 cross-refers to the applicable aircraft certification code
EHPS.270 Rain operations, whereas flight under icing or snow conditions can be
210 AIRBUS 14 for the icing/snow conditions. Rain conditions for this paragraph Certification standards for rain shall be described in details. N N Accepted
Conditions forbidden as part of the aircraft flight manual.
EHPS.270 are missing.
EHPS.270 Should this requirement include hailstorm? Hail strike is included in Add direct reference to current certification hail and hailstorm The intent to is to have a similar approach to CS-E.
211 TCCA 14 Accepted
EHPS.290 the EHPS.90 from a FOD perspective. environments. Specific guidance will be provided in the Means of Compliance.
The installation of the EHPS but also the flight envelope of the The opeation under rain conditions are considered as normal
aircraft have a lot of influence on rain effect. Flight in those operations. Propoer function of the EHPS under these conditions
EHPS.270 Not
212 VOLTAERO 13 conditions may also be prohibited. It is under the responsibility of We recommend to delete in paragraph EHPS.270. YES NO shall be demonstrated.
Rain conditions accepted
the aircraft designer. The EHPS requirements cannot be more Specific guidance will be provided in the Means of Compliance to
severe than the aircraft requirements. take into account the installation effects.
213 FAA GH EHPS.280 14 Seems to deviating from PBR yes Noted
A counter opinion to 32 was expressed :

I don’t know what you mean by ‘deviating from PBR.’ To me this is
a performance based rule. It says there must not be a problem
within the specified envelope/conditions. If you don’t specify the
conditions it would not be enforceable (i.e., how much ice or
214 FAA AS EHPS.280 14 yes Noted
snow). Same as the rain requirement, above. Could even go
further, to add detail similar to that under bird strike, etc., below.
Also, the operational regulators need to know the capability of the
engine/aircraft to make enforceable operational regulations, such
as when you can launch into certain weather conditions.
Cranfield
215 Aerospace EHPS.280 14 References EHPS.30(e). This doesn’t exist. Yes No Accepted Corrected accordingly.
Solutions Ltd
General comment to add a § assumptions to cover data from

216 SAFRAN EHPS.280 14 Icing è assumptions Yes No Accepted It is covered by EHPS.30.
Aircraft applicant
General EHPS.280 - The ice protection specifications should be described if

Remove "as specified in EHPS.30(e)" and add in what was
Aviation it listed as a reference. Freezing fog on ground condition is not Major/concep
217 EHPS.280 14 supposed to be written in the regulation describing the Accepted Corrected accordingly.
Manufacturers specified and EHPS.30(e) does not exist, but is recorded in the tual
instruction manual.
Association regulation to describe the ice protection specifications.
Even if the aircraft is not allowed to flight in icing conditions, the

propulsion system has always been requested to demonstrate
Is it applicable to aircraft which is not certified to operate in icing Suggestion is to add the condition: “if aircraft requests Not
218 Flying Whales EHPS.280 14 Yes No capability to do so. The intent is to follow the same approach as
condition? certification for flight in icing conditions” accepted
CS-E. That is why the wording is very similar.
Page 27 of 77
“EHPS.280 Icing and snow conditions

The EHPS and any of its sub-system must function satisfactorily
when operated throughout the conditions of atmospheric icing
The Boeing (including freezing fog on ground) and falling and blowing snow
219 EHPS.280 14 This could be a typographical error. EHPS.30 (e) does not exist. Yes No Accepted Corrected accordingly.
Company defined in the propulsive system installation ice protection
specifications of the Type-Certification basis of the intended aircraft
application, as specified in EHPS.30 (e).”
Please reference the correct requirement.
Should consider operating envelope within existing certification
environments for atmospheric icing, supercooled large droplets and
ice crystals. As the environments are defined regardless of the
aircraft operating in it, they should be prescribed (direct reference) Even if the aircraft is not allowed to flight in icing conditions, the
and only the applicable operating enveloped under consideration propulsion system has always been requested to demonstrate
220 TCCA EHPS.280 14 demonstrated. Additionally, Authorities have generally certified Add direct reference to current icing environments Accepted capability to do so. The intent is to follow the same approach as
engines to more severe conditions than those required at the CS-E. That is why the wording is very similar.
aircraft level. Accordingly, adequate margin should be Specific guidance will be provided in the Means of Compliance.
demonstrated. Industry working groups and regulators have put
significant effort into defining various icing environments, these
should be explicitly retained when certifying EHPS.
EHPS.280 Icing
Airbus Typo, the requirement to identify the applicable A/C Type when operated throughout the conditions of atmospheric icing
221 and Snow 14 Yes No Accepted Corrected accordingly.
Helicopters Certification Basis is specified in EHPS.30(b)(4), not EHPS.30(e) (including freezing fog on ground) and falling and blowing snow
Conditions
defined in the propulsive system installation ice protection
specifications of the Type-Certification basis of the intended
aircraft application, as specified in EHPS.30(b)(4)(e).
Airbus propose to update the wording of EHPS.280 Icing and

Snow Conditions - as follows (new proposed text shown in
EHPS.280 Icing The EHPS and any of its sub-system must function satisfactorily
Typo, the requirement to identify the applicable A/C Type
222 AIRBUS and Snow 14 when operated throughout the conditions of atmospheric icing Yes N Accepted Corrected accordingly.
Certification Basis is specified in EHPS.30(b)(4), not EHPS.30(e)
Conditions (including freezing fog on ground) and falling and blowing snow
defined in the propulsive system installation ice protection
specifications of the Type-Certification basis of the intended
aircraft application, as specified in EHPS.30(b)(4)(e).
Werner Scholz,
EHPS.280 Icing The following intended aircraft applications have been removed
European similar as for Rain conditions… (point 13); Partially
223 and snow 14 similar as for Rain conditions… (point 13) suggestion from the scope: CS-22, CS-LSA, CS-23 level 1 day VFR and Light
Sailplane no snow / icing requirements typically required for sailplane accepted
conditions UAS.
Manufacturers
EHPS.280 Icing and snow conditions

when operated throughout the conditions of atmospheric icing
EHPS.280 Icing
(including freezing fog on ground) and falling and blowing snow
224 Rolls-Royce and snow 13 Yes No Accepted Corrected accordingly.
defined in the propulsive system installation ice protection - was this intended to be EHPS:30(b)(4) or other reference?
conditions
specifications of the Type-Certification basis of the intended aircraft
application, as specified in EHPS.30 (e). EHPS.30 e does not exist in
the document
EHPS.280 Icing
Minor grammatical correction - Should read: 'The EHPS and any of
225 Rolls-Royce and snow 12 Correct wording Yes No Accepted Corrected accordingly.
its sub-systems...'.
conditions
Page 28 of 77
The installation of the EHPS but also the flight envelope of the Even if the aircraft is not allowed to flight in icing conditions, the
EHPS.280 aircraft have a lot of influence on ice and snow effect. Flight in propulsion system has always been requested to demonstrate
Not
226 VOLTAERO Icing and snow 14 those conditions may also be prohibited. It is under the We recommend to delete in paragraph EHPS.280. YES NO capability to do so. The intent is to follow the same approach as
accepted
conditions responsibility of the aircraft designer. The EHPS requirements CS-E. That is why the wording is very similar.
cannot be more severe than the aircraft requirements. Specific guidance will be provided in the Means of Compliance.
'AMC suggests use of Fairings/cowlings to be the means to protect

Vertical the EHPS from Bird/hail/FOD. Due to nature of distributed EHPS on A comment in the AMC may aid the TC DOA in understanding The term "installed" addresses indeed this possibility. Specific
227 EHPS.290 14 Yes Accepted
Aerospace VTOL Aircraft the demonstration of compliance will likely be at that the compliance to EHPS.290 may be at Aircraft level. guidance will be provided in the Means of Compliance.
Aircraft (SC-VTOL) level, and deferred from this SC.
Will there be a dedicated AMC for SC-EHPS or could existing draft

Dedicated AMC will be provided. Refer to the presentation made
228 Volocopter EHPS.290 15 AMC for bird strike in accordance with SC-VTOL.2250(f) be used in Yes Noted
at the Rotorcraft symposium in 2019.
the case, where the EHPS is to be used on a VTOL aircraft?
Not The mentioned inconsistency is not understood. The text is kept as

229 SAFRAN EHPS.290 14 Bird ingestion – mention of catastrophic effect not consistent It is proposed not to mention Aircraft Catastrophic Effect. Yes No
accepted is.
Is HIRF/Lightning aggression included in the §EHPS.290,

HIRF/Lightning agreesion is covered by EHPS.30, EHPS.330,
EHPS.330 or EHPS.490? A specific § may be needed as for other
230 SAFRAN EHPS.290 14 HIRF / Lightning specific requirement Yes No Noted EHPS.370, EHPS.380 and EHPS.490.
CS at aircraft level (including the protection at EHPS sub-
Specific guidance will be provided.
system or equipment level).
231 Zeroavia EHPS.290 Suggest adding bird and hail size. Accepted Specific guidance will be provided in the Means of Compliance
James Lawson
“EHPS.290 Bird, hail strike and impact of foreign matter
(a) The EHPS must be designed and/or installed so that any impact
by bird or hail, or other impact of foreign matter, that is likely to
occur in any one flight will not cause any Hazardous EHPS Effect or
Catastrophic Aircraft Effect as defined in EHPS.15.”
1) The statement, “impact by bird or hail, or other impact of foreign

matter, that is likely to occur in any one flight will not cause”
requires further explanation. “likely to occur in one flight” needs to
be made clear so that this approach can be followed
2) EHPS-80 does not provide clear safety objectives as defined for Consistency with CS-E approach has to be kept for turbine
EASA SC-VTOL which identifies at aircraft level a failure rate of 10-9. “EHPS.290 Bird, hail strike and impact of foreign matter engines.
We would need to understand the target For example, CS-E510 (a) The EHPS must be designed and/or installed so that any Regarding 1): specific guidance will be provided for the bird and
The Boeing defines in a (3) It must be shown that Hazardous Engine Effects are impact by bird or hail, or other impact of foreign matter, that is Partially hail strike. For the other FOD, each applicant will have to propose
232 EHPS.290 14 no yes
Company predicted to occur at a rate not in excess of that defined as likely to occur in any one flight will not cause any Hazardous accepted its approach.
Extremely Remote (probability less than 10-7 per Engine flight EHPS Effect or Catastrophic Aircraft Effect as defined in Regarding 2): safety objectives are derived from the intended
hour). The estimated probability for individual Failures may be EHPS.15.” aircraft application. That is the intent of EHPS.80(a)(3).
insufficiently precise to enable the total rate for Hazardous Engine Regarding 3): Noted
Effects to be assessed. For Engine certification, it is acceptable to
consider that the intent of this paragraph is achieved if the
probability of a Hazardous Engine Effect arising from an individual
Failure can be predicted to be not greater than 10-8 per Engine
flight hour (see also CS-E 510 (c)). In case that the safety target has
not been defined it should be deleted as recommended.
3) It is possible that multiple-rotor and/or push propeller or
alternative based vehicles may be able to sustain CSF&L without
resulting in a hazardous Classification of Failure Conditions. Please
refer to comments 14 and 15
Page 29 of 77
Should consider include threat from ice-sheet ingestion from inlet

or other aircraft courses. Change to : "[…] bird, hail, ice slabs, or
Ice slab is related to icing conditions. It is therefore covered under
other impact of foreign matter". Partially
233 TCCA EHPS.290 14 Modify to include ice-sheet strike. EHPS.280.
Again, “Hazardous EHPS Effect or Catastrophic Aircraft Effect as accepted
defined in EHPS.15” may be redundant as HAZ EHPS Effects are
defined as those leading the CAT or HAZ A/C Effects.
Airbus propose to update the wording of EHPS.290 Bird, Hail

Strike and impact of foreign matter - as follows (new proposed
text shown in underlined italic font):
EHPS.290 Bird, Hail and Other Foreign Matter Strike and
Ingestion
(a) The EHPS must be designed and/or installed so that any
impact by or ingestion of bird or hail, or other impact of foreign
Paragraph a) has been corrected. However, considering only high
The proposed paragraph implies that ingestion of foreign matter matter, that is likely to occur in any one flight will not cause
energy debris for the Hazardous EHPS effect is not in line with
might not be an issue. Airbus consider that the ingestion threat any hazard (High Energy Debris or propeller release, hazardous
today practices on CS-E. This has not been taken into account.
may remain a problem for certain design and therefore propose to or catastrophic aircraft effects)Hazardous EHPS Effect or
Paragraph b) is there to cover cases where the intended aircraft
extend the scope of the paragraph. It is not clear also what added Catastrophic Aircraft Effect as defined in EHPS.15.
EHPS.290 Bird, application must demonstrate its capability to ensure a CSFL,
value subparagraph (b) is bringing. A single paragraph requiring no (b) It must also be shown that the impacts defined on EHPS.290
Hail Strike and Partially including following bird or hail strike. This is not the case for basic
234 AIRBUS 14 hazards as a result of impact/ingestion is likely to be sufficient. (a) will not preclude the continued safe flight and landing (as N Y
impact of foreign accepted Category of as specificed in SC VTOL.
Subparagraph (c) is too broad. It is not clear if it is meant to defined in the Type-Certification Basis of the intended
matter "as defined in the Type-Certification Basis of the intended
addresses several hail encouters within one flight for instance or application(s)) of the aircraft as a consequence of an
application" has been replaced by "if defined in the Type-
one single multiple bird impacts event. In addition, a reference to unacceptable:
Certification Basis of the intended application" to emphasis this
applicable hail/bird encounters conditions should be included in the (1) loss of performance;
point.
requirement. (2) deterioration of EHPS/Aircraft handling characteristics;
Specific guidance will be provided to clarify this.
(3) exceedance of any EHPS operating limitation.
(c) Multiple impacts must be included in the demonstration
unless it can be shown that they are unlikely
(b) Hail encouters are specified in CS-E appendix A.
(c) For bird, the EHPS design shall be able to sustain the
relevant ingestion conditions of CS-E 800 and strike conditions
of the intended aircraft type certification basis
A CSFL is indeed not requested on single engine A/C after the loss
of the engine. Paragraph b) is there to cover cases where the
intended aircraft application must demonstrate its capability to
EHPS.290 Bird, (b)(1) is probably not achievable for an aircraft that is equivalent to
ensure a CSFL, including following bird or hail strike.
hail strike and a single engine platform. A total loss of power or thrust on a single (1) loss of performance, unless addressed by the aircraft safety Partially
235 Rolls-Royce 14 Yes No "as defined in the Type-Certification Basis of the intended
impact of foreign engine platform would in most cases preclude continued safe flight assessment; accepted
application" has been replaced by "if defined in the Type-
matter and landing.
Certification Basis of the intended application" to emphasis this
point.
Specific guidance will be provided to clarify this.
Werner Scholz, EHPS.290 Bird,

European hail strike and similar as for Rain conditions… (point 13) Partially
236 14 similar as for Rain conditions… (point 13) suggestion from the scope: CS-22, CS-LSA, CS-23 level 1 day VFR and Light
Sailplane impact of foreign no bird strike / hail conditions typically required for sailplane accepted
UAS.
Manufacturers matter
Page 30 of 77
SC EHPS is not dedicated to CS-23 application.

EHPS.290 Turbine engines certified according to C-E that are installated on
The CS-23 amdt 4 does not consider bird impact apart on the
Bird, hail strike Not CS-23 have demonstrated capability to sustain bird and hail strike.
237 VOLTAERO 14 canopy. The EHPS requirements cannot be more severe than the We recommend to delete in paragraph EHPS.290. YES NO
and impact of accepted Piston engine are considered protected by the installation which is
aircraft requirements.
foreign matter what is proposed in (a) where an applicant can take credit from
the installation.
Relative to « …or Catastrophic Aircraft Effect as defined… »
238 FAA JP EHPS.290(a) 14 Don’t think the EPHS applicant can identify all CAT aircraft effects, yes Yes Noted
the propulsion system takes part in the flight control function).
that is done by the installer.
Proper coordination with the aircraft manufacturer will be
requested.
impact by bird or hail, or other impact of foreign matter, that is
The EHPS manufacturer should not be responsible to define what EHPS are different from a single motor as they most of the time
likely to occur in any one flight will not cause any Hazardous
are the Major, Hazardous or Catastrophic Aircraft Effects. This include several motors. As such, failures modes cannot be only
EHPS Effect or Catastrophic Aircraft Effect as defined in
categorization will be very dependent of the aircraft propulsion Not assessed anymore at motor level but at aircraft level (e.g. when
239 Embraer S.A. EHPS.290(a) 14 EHPS.15. yes no
architecture and this analysis should be made by the aircraft accepted the propulsion system takes part in the flight control function).
To:
manufacturer. Recommended to delete any reference to aircraft Proper coordination with the aircraft manufacturer will be
level effects. requested.
impact by bird or hail, or other impact of foreign matter, that is
likely to occur in any one flight will not cause any Hazardous
EHPS Effect as defined in EHPS.15.
In reference to « unlikely », Is this going to be qualified or

240 FAA JF EHPS.290(c) 14 Yes Noted Specific guidance will be provided.
quantified in the MoC
Refer instead to the definition of "Extremely Remote" in CS- Not

241 Rolls-Royce EHPS.290(c) 13 Define "unlikely". This word should be avoided in safety analyses. Yes No Specific guidance will be provided.
Definitions accepted
Since many of the users of electric propulsion will be eVTOL should

something similar to helicopter power assurance be mentioned?
Power assurance check is an aircraft request (like in CS-29) for
242 FAA DJ EHPS.30 7 We don’t know how electric motors may deteriorate over time in yes Noted
performance purposes and not a propulsion request.
aircraft applications so it seems important this would be addressed
at least initially until experience is gained.
enable innovation.
Cranfield
Refers to “type certificate”. Is this an EHPS certificate or the aircraft EHPS can be certified as part of the aircraft or a stand-alone
243 Aerospace EHPS.30 7 Clarification of wording or intent on certification of EHPS. Yes No Accepted
type certificate? engine product.
Solutions Ltd
Proposal to create an assumption paragraph (similar to CS-E30)

244 SAFRAN EHPS.30 8 Requirement shall be mentioned in assumption report (3) Yes Yes Accepted EHPS.30 (b)(7) has been added to indicate the assumptions.
for the EHPS
Refer to EHPS.30 (b)(1): it provides the technical inputs for the

aircraft designer to properly design the powerplant.
245 Jonas Büttner EHPS.30 8 Safety instructions for installation is missing in EHPS.30 (b) Yes Noted Concerning the physical installation by a maintenance operator,
the maintenance manual will provide the instruction for a safe
installation on the aircraft.
Page 31 of 77
“(b) The instructions must include at least the following:

(1) Installation instructions for each system which constitutes the
EHPS” The instrcutions manual for installating and operating the EHPS is
Reference to engine servicing instructions including types of fluids intended for the aircraft designer and not the maintenance
to be used, engine maintenance manual, instructions for storage operators. Therefore, the maintenance manual, instructions for
are missing. Partially storage and the safe handling of electric component are not par of
246 Airbus DS EHPS.30 7 Consider add missing instructions. Yes No
Missing mention that assumptions used to comply with this accepted it but are part of the engine maintenance manual which is part of
regulation need to be part of the installation instructions (in line the ICA.
with CS-E 30). Assumptions have been added (refer to EHPS.30 (b)(7).
Probably implicit, but should also include the instructions for safe Type of fluids to be used has been added (refer to EHPS.30 (b)(8)
handling of the electrical components during installation,
maintenance and operation.
In (b)(3) add a comma “,” at the end

In (b)(5) revise text to read "EHPS configuration, and "
247 TCCA EHPS.30 8 Suggest to revise text, if needed Accepted Corrected accordingly. The paragraph has been reworded.
In (b)(6) revise text to read “…to demonstrate compliance to the
requirements identified in the Type-Certification Basis…”
(6) The necessary data to allow the installer to demonstrate the EHPS can be certified apart from intended aircraft certification.
compliance to the requirements identified in the Type-Certification Proposal as follow: (6) The necessary data to allow the installer
Not Requirements of the intended aircraft application are defined
248 SAFRAN EHPS.30 8 basis of the intended aircraft application. to demonstrate the compliance to the requirements identified Yes Yes
accepted according to its associated Type Certification basis.
This paragraph is not consistent with page 3 “additional in the Type-Certification basis of the intended aircraft
certification requirements…” application.
249 FAA DJ EHPS.30 (b)(3) 8 Detail could be provided in the MOC for this information. yes Accepted Specific guidance will be provided in the Means of Compliance.
This seems to be an incomplete thought. (3) is supposed to As stated, the instructions mut include…"the interface conditions,
250 FAA JF EHPS.30 (b)(3) 8 complete the statement ”The instruction must include …”. In (3) it yes Noted reliability specifications and safety analyses for those components
is not clear what must be included. upon which the EHPS certification is based"
Using ‘Type-Certification Basis’ seems excessive and could be

Suggest replacing ‘Type-Certification Basis’ with ‘aircraft type Not Requirements of the intended aircraft application are defined
251 FAA JP EHPS.30 (b)(4) 8 interpreted as requiring identification of an installation part and yes
and category.’ accepted according to its associated Type Certification basis.
amendment level for EHPS approval.
"(b) The instructions must include at least the following:

........
(3) Where an EHPS relies on components which are not part of the
EHPS, the interface conditions, reliability specifications and safety
EHPS.30
analyses for those components upon which the EHPS certification is
Instructions
based"
manual for
252 Rolls-Royce 8 - It is not foreseeable that it would be practical to include safety "…conditions, reliability specifications and safety rationale for Yes No Accepted Modified accordingly
installing and
analyses of components outside the EHPS. Those components may those components…"
operating the
be sourced by the airframer, independent from the influence of the
EHPS
EHPS supplier. It would be sufficient for the EHPS supplier to clearly
state the reliability specifications (failure rates, acceptable latencies
of failures, qualitative requirements to address common modes
etc.) with the rationale for the specification.
EHPS.30
Instructions
No assumptions mentioned (b)(1) Installation instructions for each system which
manual for
253 Rolls-Royce 7 (b)(1) Installation instructions for each system which constitutes constitutes the EHPS including necessary assumptions Yes No Accepted EHPS.30 (b)(7) has been added to indicate the assumptions.
installing and
the EHPS, associated with a typical EHPS installation,
operating the
EHPS
Page 32 of 77
Airbus propose to update the wording of EHPS.30 Instructions

manual for installing and operating the EHPS - as follows (new
Sub-paragraph (a) implies there is a separate Type Certificate for
the EHPS. Again Airbus consider this is not necessarily required and (a) Each applicant must prepare and make available to the
EHPS.30
note that the previous paragraph (EHPS.25 ICA) also consider this Agency prior to the issuance of the type certificate, and to the
Instructions
possibility (if the EHPS is certified as part of the aircraft certification installer at the time of delivery of the EHPS, approved
manual for
254 AIRBUS 7 written in EHPS.25(b)). If the EHPS is certified as part of the aircraft instructions for installing and operating the EHPS. Alternatively, NO YES Accepted Modified accordingly
installing and
type certification, it is not clear why separate installation/operating if the EHPS is certified as part of the aircraft certification, EHPS
operating the
instructions would be required. The paragraph should therefore be installation/operating instructions pertinent to the operator of
EHPS
updated to address the situation where there is no separate EHPS the aircraft will be provided in the aircraft relevant manuals
TC.
(b) When the EHPS is certified independently of the aircraft, the
installation/operating instructions required by this Special
Condition must include at least the following:….
We recommend to delete the 4), 5) and 6).
(4) The Type-Certification Basis which is (are) assumed as being

The aircraft designer, Type Certificate Holder of future Type
applicable to the intended
EHPS.30 certificate Holder, has the responsibility of certifying the EHPS on
aircraft application must be identified in the installation
Instructions its aircraft. The responsibility of the EHPS designer is to provide the EHPS.30 has been modified to take into account the two different
instructions,
manual for installation instructions, the operating instructions and the Partially certification possibilities.
255 VOLTAERO 8 (5) The aircraft parts and equipment that may be mounted on, YES NO
installing and limitations. It is the responsibility of the aircraft designer to comply accepted Specific guidance will be provided in a Certification Memorandum
or driven by, the EHPS, which
operating the with thoses instructions and limitations. He will also have to to part 21 regarding the ways to certify an EHPS.
are not part of the declared EHPS configuration.
EHPS demonstrate the compliance to the applicable requirements in
(6) The necessary data to allow the installer to demonstrate
order to obtain the relevant EASA approval for its aircraft.
the compliance to the
requirements identified in the Type-Certification basis of the
intended aircraft application.
Not
256 Volocopter EHPS.30(b)(3) 9 Sentence has no ending Yes The sentence is correct
accepted
Given the role of ARP4754A in defining a systems-engineering

approach to aircraft development, and its adoption for large
aircraft programmes, I expected to see something similar to
EHPS.80 (a)(3) and EHPS.350 (b) have been reworded to address
EHPS.30, EHPS.350 (b) to seek that the system definition and integration (at Partially
257 Rolls-Royce 7, 18 Consider adding this within the proposed SC. Yes No develoment assurance.
EHPS.350 least of avionics) is done to an accepted standard. Particularly accepted
relevant for more distributed controls - including details in the
Installation Manual does not really reflect how modern aircraft are
designed and developed.
If the EHPS contains reciprocating engines or turbine engines, then

The adjective "safely" has been added.
any fuel system of the EHPS must be designed and constructed so
Fire risk is covered under EHPS.100.
that it will function properly in all flight attitudes and atmospheric “ Fuel systems must be designed to avoid any risk of fuel Partially
258 TCCA EHPS.300 15 Specific guidance will be provided in the Means of Compliance,
conditions . ignition in electromagnetic environment accepted
such as electrical bonding to ensure electrostatic discharge to
. Does the word properly means also safely? This sentence does not
ground or to air.
highlight the risk related to fuel ignition
Any technology related to the use of hydrogen, whether used to

feed fuel cells or combustion engines is outside the scope of this
Lange Aviation The limiting sub-clause should be deleted: "Any fuel system...". Not
259 EHPS.300 15 Other types, i.e. fuel cells, will also need a fuel system. Yes special condition. These technologies request further work and
GmbH The same applies to b). accepted
research before defining the associated certification
requirements.
Page 33 of 77
This requirement only applies if there is a reciprocating or turbine

engine as part of the hybrid installation. This means the Any technology related to the use of hydrogen, whether used to
requirements would not apply to an EHPS where a hydrogen fuel feed fuel cells or combustion engines is outside the scope of this
Increase the scope of the requirement e.g. to include Not
260 UK CAA EHPS.300 15 cell is used to generate electricity to then feed to a motor/battery Yes special condition. These technologies request further work and
consideration of hydrogen fuel cells. accepted
buffer/storage arrangement. This does not seem to be logical as H2 research before defining the associated certification
fuel cells have both fuel and O2 supply challenges which should be requirements.
considered.
It is proposed to add negative g to the text for functioning
condition :
261 SAFRAN EHPS.300 15 Negative G Yes Yes Accepted Corrected accordingly
(a) “…so that it will function properly in all flight attitudes
including negative g….”
AMC of EHPS.300 list CS-E 560 but should also cover full CS-E
262 SAFRAN EHPS.300 15 Associated AMC Yes Yes Accepted This will be part of the specific guidance work to be performed.
670.
The intent is to provide a self-supporting Special Condition in

order to facilitate the use.
Reciprocating or turbine engines should comply with original CS-E
Not However, the use of a modified "type certified" engine as part of
263 Embraer S.A. EHPS.300 15 requirements. Recommended to delete this section or to refer to We suggest to delete this paragraph. yes no
accepted an EHPS will ease the certification process of the EHPS as the
applicable CS-E requirement.
applicant, if holder of the TC for the certified engine will be able to
take credit from the past certification and reuse certification data.
“(b) If the EHPS contains reciprocating engines or turbine engines,
then evidence must be provided that the complete Engine fuel
system is capable of functioning satisfactorily with fuel containing
the maximum quantity of liquid/solid contamination, likely to be Proposal is to add mention of prevention of ice build-up in fuel Modified accordingly. Note however that this was already
264 Airbus DS EHPS.300 15 Yes No Accepted
encountered in service, for a period sufficient to ensure that the system (water ice accumulation) identified as being part of the specific guidance to be created.
Engine will not malfunction as a result.”
Explicit mention of prevention of Ice build-up in fuel system (water
ice accumulation) is missing.
If the EHPS contains reciprocating engines or turbine engines, then This will be made via the Means of Compliance.
265 TCCA EHPS.300 15 The requirement should point to CS-E (E250 / E560) Accepted
surely the relevant parts of CS-E would apply? Specific guidance will be provided in the Means of Compliance.
Not
accepted
This rule is scoped to include only reciprocating or turbine engines. Any technology related to the use of hydrogen, whether used to
It is suggested that fuel cells and other possible power sources - feed fuel cells or combustion engines is outside the scope of this
EHPS.300 Fuel Include all power plants, not just reciprocating and turbines in Not
267 Rolls-Royce 15 even as yet unknown options - should be included. A fuel cell, for Yes No special condition. These technologies request further work and
system rule scope accepted
example, could run on Hydrogen and maybe even one day on research before defining the associated certification
kerosene. requirements.
No reference to declaration of approved fuel specification including

EHPS.300 Fuel any additive and the associated limitations in flow, temperature Consider to add reference to declaration of approved fuel Declaration and approval of types of fuels and additivies has been
268 Rolls-Royce 15 Yes No Accepted
system and pressure that ensure proper Engine functioning under all specification added.
intended operating conditions.
Page 34 of 77

(a) If the EHPS uses fuel, contains reciprocating engines or
turbine engines, then any fuel system of the EHPS must be
designed and constructed so that it will function properly in all
Declaration and approval of types of fuels and additivies has been
Airbus consider that the requirement to substantiate and declare flight attitudes and atmospheric conditions in which the EHPS
added.
Airbus EHPS.300 Fuel approved fuel specifications should be maintained in this Special is expected to operate. Partially
269 15 Yes No However, the use of fuel is for the moment only considered for
Helicopters System Condition. In addition Airbus suggest more generic wording for the (b) If the EHPS uses fuel; contains reciprocating engines or accepted
reciprocating and turbine engine. The use of hydrogen is not
section. turbine engines, then evidence must be provided that the
considered as part of the SC E-19.
complete Engine fuel system is capable of functioning
satisfactorily with fuel containing the maximum quantity of
liquid/solid contamination, likely to be encountered in service,
for a period sufficient to ensure that the Engine will not
malfunction as a result.
Werner Scholz,
Showing of compliance by using typical fuel types / typical The following intended aircraft applications have been removed
European EHPS.300 Fuel Add regarding guidance and/or introduce some tiering (i.e. Partially
270 15 containment must be sufficient, otherwise this becomes rather suggestion from the scope: CS-22, CS-LSA, CS-23 level 1 day VFR and Light
Sailplane system simplified requirements for simpler aircraft). accepted
arduous UAS.
Manufacturers
Airbus propose to update the wording of EHPS.300 Fuel System

- as follows (new proposed text shown in underlined italic
font):
(a) If the EHPS uses fuel, contains reciprocating engines or
turbine engines, then any fuel distribution system of the EHPS
must be designed and constructed so that it will function
properly in all flight attitudes and atmospheric conditions in
which the EHPS is expected to operate.
(b) If the EHPS uses fuel; contains reciprocating engines or
turbine engines, then evidence must be provided that the
Declaration and approval of types of fuels and additivies has been
Airbus consider that the requirement to substantiate and declare complete EHPS distribution fuel system is capable of
added.
EHPS.300 Fuel approved fuel specifications should be maintained in this Special functioning satisfactorily with fuel containing the maximum Partially
271 AIRBUS 15 N Y However, the use of fuel is for the moment only considered for
System Condition. In addition Airbus suggest more generic wording for the quantity of liquid/solid contamination, likely to be encountered accepted
reciprocating and turbine engine. The use of hydrogen is not
section. in service, for a period sufficient to ensure that the EHPS will
considered as part of the SC E-19.
not malfunction as a result.
(c) Each fuel specification to be approved, including any

additive, and the associated limitations in flow, temperature
and pressure that ensure proper Engine functioning under all
intended operating conditions must be declared and
substantiated
(d) Any reliance placed upon the assumed installed conditions
or installation requirements must be declared in the
instructions for installation as defined in EHPS.30.
Each engine is equipped with a fuel system generally composed of

We recommend to modify the paragraph adding a sentence :
EHPS.300 Not pumps, filters, lines, fuel metering device…
272 VOLTAERO 15 The fuel system is generally part of the aircraft design. “If the EHPS installation instructions defines a fuel system, this YES NO
Fuel system accepted TThe SC E-19 does not adress the aircraft fuel system for which
paragraph applies.”
the certification requirements are provided in the relevant CS.
Is it worth having a paragraph parallel to EHPS.300(b)? Malfunction

of a lubrication system, owing to contamination by liquid or solid,
could lead to fire, friction, overheat and potential debris release,
Consider analogue of EHPS.300(b) for lubrication system (and
273 Rolls-Royce EHPS.310 15 some of which may be Hazardous EHPS Effects; hence the EHPS Yes No Accepted New EHPS.310(b) has been added.
note similarity to CS-E 570, particulaly paragraph (b))
lubrication system should function satisfactorily "for a period
sufficient to ensure that the Engine will not malfunction as a
result".
Page 35 of 77
Paragraph EHPS.310 (b) has been added.

CS-E 270 requirements should be applicable. Recommended to Partially The other pragraphs are covered by other SC EHPS paragraphs
274 Embraer S.A. EHPS.310 15 Refer to CS-E 270 requirements. yes no
refer to CS-E 270 requirements. accepted (like CS-E.270(d) addressed by EHPS.320) or will be part of the
specific guidance to be provided.
There are other aspects of CS-E for oil / lube systems that are This will be made via the Means of Compliance.
275 TCCA EHPS.310 15 Review CS-E270 and E570 for relevant aspects. Accepted
relevant here. Specific guidance will be provided in the Means of Compliance.
Not
accepted
It is proposed to add negative g to the text for functioning

EHPS.310 & condition :
277 SAFRAN 15 Negative G Yes Yes Accepted Corrected accordingly.
EHPS.320 (a) “…so that it will function properly in all flight attitudes
including negative g….”
It is proposed to have a equivalent requirement between
EHPS.310(a) and EHPS.320(a) as the cooling system may use
liquid system à for EHPS.320(a), it is proposed the following
EHPS.310 &
278 SAFRAN 15 Consistency between §EHPS 310(a) and §EHPS.320(a) text : “The design and construction of the EHPS cooling system Yes Yes Accepted Corrected accordingly.
EHPS.320
must ensure adequate cooling in all flight attitudes and
atmospheric conditions in which the EHPS is expected to
operate”.
Fire protection level is function of the nature of the coolant. If the
coolant is not considered as a flammable fluid, there is no need to
meet the Flammable Fluid Fire Protection.
Note however that this demonstration should take into account
A link to the fire protection requirement is proposed for liquid also failure cases and the installation. For example, let's consider a
EHPS.310 & cooling system : “If it is a liquid cooling system , the cooling Not water/glycol coolant. If a leakage appears and the environment
279 SAFRAN 15 Fire Protection Yes Yes
EHPS.320 fluid must meet the Flammable Fluid Fire Protection accepted conditions are such that the water evaporates first, only the glycol
requirement as defined in §EHPS.100” remains which is a flammable fluid. In this configuration, the
coolant will be considered as a flammable fluid.
This will be part of the specific guidance provided as part of the
EHPS.100 and EHPS.30 as there is a need to take into account the
installation.
EHPS.310 & Indeed, any type of cooling system should be considered in the
280 SAFRAN 15 Associated AMC to §EHPS.320 Nota: AMC to §EHPS.320 should also cover the liquid systems Yes No Accepted
EHPS.320 MoC.
Appropriate type of oil requirement has been added.
No reference to: Oil contamination limits and protection is now covered by new
EHPS.310 - appropriate type of oil declaration EHPS.310(b), EHPS25 and EHPS.30(b)(8).
281 Rolls-Royce Lubrication 15 - oil contamination limits and protection Consider to add reference to the identified items Yes No Accepted Impact on EHPS when the oil flows between the EHPS lubrication
system - impact on EHPS when the oil flows between the EHPS lubrication system and the Propeller control system is covered by EHPS.310(a)
system and the Propeller control system. and the specific guidance that will be provided as part of the MoC
(based on CS-E 270).
Airbus propose to update the wording of EHPS.310 Lubrication
System - as follows (new proposed text shown in underlined
italic font):
EHPS.310 Lubrication system
(a) Any lubrication system of the EHPS must be designed and
EHPS.310 Airbus consider that the requirement to substantiate and declare constructed so as to ensure the proper functioning of the EHPS
282 AIRBUS Lubrication 15 approved oil specifications should be maintained in this Special in all flight attitudes and atmospheric conditions in which the N Y Accepted This covered by EHPS.30(b)(8)
System Condition EHPS is expected to operate.
(b) Each brand and type of oil to be approved, and the
associated limitations, must be declared and substantiated.
(c) Any reliance placed upon the assumed installed conditions
Page 36 of 77
Some requirement use the generic statements

(x) Any _____ system of the EHPS must be designed and
constructed so as to ensure the proper functioning of the EHPS in
all flight attitudes and atmospheric conditions in which the EHPS is
expected to operate.
(xx) Any reliance placed upon the assumed installed conditions or Each high level requirement is indeed applicable to these systems.
EHPS.310 installation requirements must be declared in the instructions for For very high-level generic rules, expand each requirement to However, how to show compliance may differ pending the
Partially
283 TCCA EHPS.320 15 installation as defined in EHPS.30. describe the intent of the rules as it pertains to the system in technology that is used. For example, an oil lubircated system is
accepted
EHPS.340 Understanding that these rules are written using the Performance question. deemed different than a greased one.
Based Rulemaking philosophy, several requirements using the Specific guidance will be provided in the Means of Compliance.
generic wording invoque the question of whether multiple rules
can be folded into each other. Additionally to appearing redundant,
the high-level nature of the rules might make it difficult for
applicant's to propose MoC that meet the expectations of the
Authorities.
Why doesn’t this include the same sub-paragraph (b) as the fuel
system? Example: water in the oil causes corrosion. The sub-
284 FAA AS EHPS.310(a) 15 Yes Accepted New EHPS.310(b) has been added.
paragraph (b) above may imply filtration systems to limit oil
contamination, or contamination detection systems.
Is it worth having a paragraph parallel to EHPS.300(b)? Loss of
cooling could lead to Hazardous EHPS Effects. There is potential to
This is part of the safety assessment that should be made as
specify that, if Hazardous EHPS Effects are possible from loss of Partially
285 Rolls-Royce EHPS.320 16 Consider analogue of EHPS.300(b) for cooling system Yes No requested by EHPS.80.
cooling, then the cooling system strategy should employ accepted
EHPS.300(b) is more dedicated to the presence of contaminants.
redundancy, diversity or other measures to ensure that cooling
capability is not lost completely by any single failure.
Cooling does not include a provision for contamination, but This would create an inconcsistency with CS-E and would not ease
Not
286 Rolls-Royce EHPS.320 15 experience with other fluid means shows that it is good practice to include a provision for contamination <See also comment 18> Yes No the use of certified engines as part of the EHPS.
accepted
include such provisions Specific guidance could be provided to propose the best practices.
Proposal is to mention that if coolant is acting also as electrical This is part of the safety assessment that should be made as
Cooling of electrical systems is sometimes used as part of the Partially
287 Airbus DS EHPS.320 15 isolator, loss of cooling shall take that into account as an Yes No requested by EHPS.80.
electrical isolation strategy of the electrical component. accepted
additional risk. Specific guidance will be provided in the MoC.
“(a) The design and construction of the EHPS cooling system must
ensure adequate cooling in all normal operating conditions within
This is part of the safety assessment that should be made as
Airbus Group the declared flight envelope.” Partially
288 EHPS.320 15 Consider add missing requirement Yes No requested by EHPS.80.
(ADS) Missing CS-E 260 requirement that appropriate means or provision accepted
Specific guidance will be provided in the MoC.
for liquid-cooled Engines means shall be provided to detect loss of
coolant
This is already covered by EHPS.290. If the cooling system is

damaged or impaired by a FOD, this will lead to an increase of
Consideration of foreign matter ingestion, if the source of cooling is Consider adding requirement regarding capability to withstand
289 TCCA EHPS.320 15 Accepted temperature above the temperature limits and that is covered by
external air? or preclusion of such foreign matter.
EHPS.290 (b)(3).
Specific guidance will be provided in the Means of Compliance
The internal combustion engine and electrical motors/generators

Include the liquid cooling boiling concerns over the flight Partially This is intended to be covered by EHPS.320(a).
290 TCCA EHPS.320 15 might have completely different cooling systems based on different
envelope. accepted Specific guidance will be provided in the Means of Compliance.
types cooling media.
Page 37 of 77
Airbus propose to update the wording of EHPS.320 Cooling

System - as follows (new proposed text shown in underlined
italic font):
(a) Any cooling system of the EHPS must be designed and
constructed so as to ensure the proper functioning of the EHPS
in all flight attitudes and atmospheric conditions in which the
EHPS is expected to operate. The design and construction of the
EHPS.320 Cooling Airbus propose to amend the wording to be consistent with the
291 AIRBUS 15 EHPS cooling system must ensure adequate cooling in all N Y Accepted Corrected accordingly.
System previous fuel and lubrication system paragraphs
normal operating conditions within the declared flight
envelope.
(b) Each brand and type of cooling fluid to be approved, and
the associated limitations, must be declared and substantiated
(c) Any reliance placed upon the assumed installed conditions
Relative to « … and is substantiated by a verification methodology
acceptable to the Agency. »
292 FAA DJ EHPS.320(a) 15 Yes Noted EHPS.320 has been reworded.
What does normal mean? Normal operating conditions could,
especially for a UAS, mean just about anything.
General
(b) The failure of equipment installed on or driven by the EHPS
Aviation Major/concep Partially
293 EHPS.330 16 EHPS 330- (b) - Why catastrophic is not included? must not result in further damage likely to produce a Catastrophic Effect is now considered but at aircraft level.
Manufacturers tual accepted
Hazardous or Catastrophic EHPS Effect.
Association
This requirement are derived from CS-E 80 but should

applicable only to EHPS sub-system and not to the whole EHPS
(as for the turbine engine).
The considered equipment are those which are mounted on
the sub-system.
Proposed text for EHPS.330(a) : “Mountings and drives for all
equipment to be installed on the EHPS sub-system must be
294 SAFRAN EHPS.330 16 Equipment applicability / EHPS sub-system / MoC Yes Yes Accepted Corrected accordingly
designed to permit safe operation of the EHPS with the
equipment fitted”
Same philosophy should apply to (b), (c), (d) requirements
Does the considered equipment are only those defined in the
EHPS type design or also those part of the aircraft type design
(and mounted on the EHPS sub-system, as the same as for CS-E
80(c)) ?
295 TCCA EHPS.330 16 In (d) missing dot; should read "EHPS.20" Suggest to revise text, if needed Accepted Corrected accordingly
The list of essential systems for flight continuation has to be

provided by the aircraft manufacturer depending on the aircraft
architecture and characteristics.
Define the concept of essential systems for flight continuation Not
296 TCCA EHPS.330 16 Some systems might be essential for the safe continuation of flight. This exchange of information is ensured via to the top/down
that needs to sustain a defined level of electrical power. accepted
approach requested in EHPS.80.
EHPS.330 addresses only the equipment mounted on the sub-
systems of the EHPS (like a starter for a turbine engine)
Not
297 TCCA EHPS.330 16 Note comment for the Subpart A/page 17 Suggest to redefine the concept. Refer to answer provided for comment for Subpart A
accepted
Could EASA please elaborate on the definition of “drives”
298 Volocopter EHPS.330 (a) 17 mentioned Yes Accepted Specific guidance will be provided as AMC E 80.
in EHPS.330(a)?
Page 38 of 77
Airbus propose to update the wording of EHPS.330 Equipment

font):
(a) Mountings and drives for all equipment to be installed on
The equivalent requirement in CS-E (CS-E 80) is really limited to the
the EHPS must be designed:
design of mounting and drives of the equipment. Airbus consider Hazardous EHPS effect is not limited to the release of High Energy
EHPS.330 (i) to permit safe operation of the EHPS with the equipment Partially
299 AIRBUS 16 that the same spirit should be maintained in this Special Condition N Y Debris.
Equipment fitted. accepted
and that the proposed sub-paragraph (b) should be reworded Haz and Cat Aircraft Effect are now considered.
(ii) to prevent the failure of equipment to result in further
accordingly.
damage likely to produce a hazard (High Energy Debris or
propeller Release, Hazardous or Catastrophic aircraft effect)
(c) Each item of installed equipment must be installed
according to the limitations specified for that equipment.
The modern code such as the amendment 5 of the CS-23 defines
We recommend to modify the paragraph :
EHPS.330 the reliability at the level of the aircraft and not at the level of the Not
300 VOLTAERO 16 - Deleting (b) and (d) YES NO SC E-19 is not dedicated to CS-23 or a type of aircraft.
Equipment equipment. Its seems unconsistant to use a terminology as accepted
- Renumbering ( c ) in (b).
“Hazardous EHPS effect”.
§(b) should be linked to § EHPS.460 dealing with
starting/restarting capability.
301 SAFRAN EHPS.340 16 Ignition / start-restart capability Proposal : No Yes Accepted This will be part of the specific guidance provided in the MoC.
“…in which the EHPS is expected to operate in accordance with
EHPS.460(b)(2).”
EHPS is not limited to the use of piston engines. The requirements

are objective base requirements allowing to provide specific
CS-E 240 requirements should be applicable. Recommended to Partially
302 Embraer S.A. EHPS.340 16 Refer to CS-E 240 requirements. yes no guidance depending on the nature of the EHPS sub-systems.
refer to CS-E 240 requirements. accepted
As such, CS-E 240 will be used to create the specific guidance asit
was stated in the paragraph "Means of Compliance"
Unclear requirement. Ignition system simply needs to provide This requirement is an objective base requirement allowing to
303 FAA WM EHPS.340(a) 16 uninterrupted service when/if required. This leaves room for dual Yes Noted provide specific guidance depending on the nature of the EHPS
ignition systems or higher reliability single ignition systems. sub-systems.
Altitude is part of the atmospheric conditions.

In reference to « in all flight attitudes and « :
The ignition system is not limited to spark plugs or equivalent
304 FAA WM EHPS.340(a) 16 Why attitudes? How do attitude impact Ignition ? Did you mean Yes Noted
means. It must be considered in conjunction with the fuel system
altitudes?
which can be affected by the aircraft attitude.
Lange Aviation “Reasonable assurance” is an abstract and undetermined Should be defined in terms of probabilities depending on Consistency with CS-E should be maintained.
305 EHPS.350 18 Yes Accepted
GmbH expression. severity of potential effect. Specific guidance will be provided in similar way as AMC E 50(e).
CS-E.50 is intended for single engine.

However, on full electric distributed propulsion, the EHPS control
CS-E 50 Engine Control System has para (h) that addresses Aircraft- system is fully relying on the aircraft power supply. A complete
Supplied Electrical Power. There does not appear to be an Include consideration of aircraft-supplied electrical power for Partially loss of the aircraft electric power supply will lead to the total loss
306 UK CAA EHPS.350 17 Yes
equivalent in the EHPS Special Condition. Why is this not addressed the Engine Control System. accepted of power which is a considered as a Catastrophic Aircraft Effect.
as it will still need to be considered for the Engine Control System? Therefore, the aircraft power supply should be part of the safety
assessment to be performed according EHPS.80.
As a remark, the EHPS Control System could be made of an
EHPS general control system plus EHPS Sub-System control (as
for Engine Control System).
In the definition of the EHPS Control System, energy storage is
307 SAFRAN EHPS.350 17/18 General Accepted Exclusion has been removed.
excluded while it is included in the EHPS Sub-System definition
à It is propose to include the Energy Storage Control System in
the EHPS Control System as an Energy Storage System may be
dedicated to propulsive function.
308 SAFRAN EHPS.350 17/18 AMC (a) may be interpretative, AMC needed Accepted Specific guidance will be provided in the Means of Compliance.
(b) The difference between ‘flight envelope’ and ‘operational Replaced by "in all flight attitudes and atmospheric conditions in
309 SAFRAN EHPS.350 17/18 Flight Envelope definition Accepted
envelope’ may have to be explained. which the EHPS is expected to operate."
Page 39 of 77
(e)(2) There is an inconsistency with this paragraph. Only the
Aircraft TC Holder can demonstrate compliance with the
aircraft safety objectives. For the Aircraft it is the Aircraft TCH.
This is why safety objectives have to be derived from the intended
This Special Condition requirement applies to an EHPS Not
310 SAFRAN EHPS.350 17/18 A/C Certification basis aircraft application. The aircraft manufacturer will provide these
applicant (with its own Certification Basis). accepted
Proposed text:
(2) Not have any single failures that result in Hazardous EHPS
Effect(s) or Catastrophic Aircraft Effect; and..
(e)(3) : in addition to effects listed for local event, electrical

event could be also added.
311 SAFRAN EHPS.350 17/18 Electrical effect for local event Accepted Electrical arcing added
Proposed text :
“.. or : Electrical Arcing ,Mechanical Jamming or Failure ….”
(f) this paragraph seems partially redundant with the §(a) for
which exceedance of operating limitations has to be avoided.
312 SAFRAN EHPS.350 17/18 Protection system Concerning Protection system, does the objective of the § aim Accepted Paragraph dedicated to Protection Systems has been reworded.
at be focused on the availability of the function during
maintenance intervals?

(g) Aircraft-supplied data ==> same remark as for (e)(2) for
system is fully relying on the aircraft power supply. A complete
Catastrophic Aircraft Effect +why exclude power command
Partially loss of the aircraft electric power supply will lead to the total loss
313 SAFRAN EHPS.350 17/18 Power command signal and electrical power excluded signals ? Why the Aircraft supplied electrical power are
accepted of power which is a considered as a Catastrophic Aircraft Effect.
excluded from this requirement? Why not include also aircraft-
Therefore, the aircraft power supply should be part of the safety
supplied electrical power ?
(h) ‘That may result in adverse effect on the safety of the

aircraft’ à It is proposed to remain at EHPS level: "that may
result in adverse effects on the specification flown down by the
aircraft applicant to allows the intended aircraft application to
314 SAFRAN EHPS.350 17/18 EHPS perimeter meet the qualitative and quantitative safety objectives defined Accepted Requirement targeted to EHPS.
in the type-certification basis of the intended aircraft
application safety of the aircraft". This may be defined in a
separate requirement if it sought to be applied not only to
EHPS Control System.
General Replaced by "Instructions for installation and operation of the

Aviation EHPS 350- (2) The environmental limits must be established and Add A/RFMS specifically since installation manual may not Major/concep EHPS ".
315 EHPS.350 17 Accepted
Manufacturers documented in the Installation Manual required by EHPS.30 include A/RFMS.. tual As stated by EHPS.30, this can be part of the relevant aircraft
Association manuals.
“(f) Protection systems

The design and functioning of EHPS control devices and systems,
“(f) Protection systems
together with EHPS instruments and operating and maintenance
The design and functioning of EHPS control devices and
instructions, must provide reasonable assurance that the EHPS
The Boeing systems, together with EHPS instruments and operating and
316 EHPS.350 18 operating limitations will not be exceeded in service.” no yes Noted Paragraph dedicated to Protection Systems has been reworded.
Company maintenance instructions, must provide reasonable assurance
Needs Clarification: an exceedance of continuous engine operating
that the EHPS operating limitations will not be exceeded in
limits up to the approved transient limits may happen in emergency
normal operating service.”
conditions. It is important to detect the transient and be sure that
the maximum transient does not have detrimental effects.
Page 40 of 77
A requirement to have a means to stop the EHPS (as CS-E 50

(k)) could be still required as the ‘inability to shut down the
engine’ is considered as a HAZ EHPS effect.
317 SAFRAN EHPS.350 18 EHPS stop requirement MoC à discussion should held around the applicability of the Accepted Paragraph added to deal with EHPS stop and isolation.
AMC 20-3 MoC for the EHPS (applicability of the LOPC rate,
general philosophy of primary system and backup system,
etc….).
In (f) Revise to read "(1) The design…"
In (f) Add "...limitations, that affect the structural integrity of the
rotating parts or the electrical integrity of the EPU electrical system,
will..."
In (f) Add “ (2) When electronic overspeed protection systems are
provided, the design must include a means for testing, at least once
per EPU start/stop cycle, to establish the availability of the
protection function. The means must be such that a complete test
Paragraph EHPS.350(f) has been reworded and addresses the
of the system can be achieved in the minimum number of cycles. If
comment.
the test is not fully automatic, the requirement for a manual test
must be contained in the EPU instructions for operation.”
EJPS control system electrical power supply:
In (f) Add "(3) When overspeed protection is provided through
hydromechanical or mechanical means, it must be demonstrated
by test or other acceptable means that the overspeed function
Partially system is fully relying on the aircraft power supply. A complete
318 TCCA EHPS.350 18 remains available between inspection and maintenance periods." Suggest to revise and add text, if needed
accepted loss of the aircraft electric power supply will lead to the total loss
Add:
of power which is a considered as a Catastrophic Aircraft Effect.
"(i) EHPS control system electrical power
(1) The EHPS control system must be designed such that the loss,
malfunction, or interruption of the EHPS control system electrical
power source will not result in a hazardous EHPS effect,
unacceptable transmission of erroneous data, or continued EHPS
EHPS shut down means: covered by EHPS.350(d).
operation in the absence of the control function.
(2) If any electrical power is supplied from the aircraft to the EHPS
control system for powering on and operating the EHPS, the need
for and the characteristics of this electrical power, including
transient and steady state voltage limits, must be identified and
declared in the EHPS installation manual.
(j) EHPS shut down means
Means must be provided for shutting down the EHPS rapidly."
Paragraph (b)
The use of the terminology “Complex Electronic Hardware” could
cause confusion with respect to the scope of what should be Replace “Complex Electronic Hardware” by “Airborne
319 TCCA EHPS.350 17 Accepted Corrected accordingly.
addressed by this paragraph. The suggestion is to use the same Electronic Hardware”
terminology as the recent EASA’s AMCs and CMs .Use “Airborne
Electronic Hardware”.
The SC removed evaluation and documentation of resulting
operability characteristics from:
CS-E 50(g) Aircraft-Supplied Data
(2) be detected and accommodated. The accommodation strategy
must not result in an unacceptable change in thrust or power or an Expand to include the intent of the CS-E version of the rule, in a
320 TCCA EHPS.350 17 Accepted Added accordingly.
unacceptable change in Engine operating and starting manner consistent with PBR style.
characteristics. The effects of these Failures on Engine power or
thrust,
Engine operability and starting characteristics throughout the flight
envelope must be evaluated and documented.
Page 41 of 77
In reference to:
“CS-E 50 (j) Engines having a 30-Second OEI Power rating must
incorporate means or provision for means for automatic availability
Adapt and include CS-50(j) to account for controls related to
and automatic control of the 30-Second OEI Power within its
321 TCCA EHPS.350 17 augmented thrust time-limited modes of operation. Accepted Added accordingly.
operating limitations (see AMC E 50(j)).“
Review other paragraphs from CS-E 50 for applicability.
Instead of x-time OEI, there may be high thrust availability designed
to compensate for loss of thrust of some propulsors (loss of 3
thrusters out of 5), and a rating associated to the mode.
This requirement may still be applicable, both for the turbine
Removed: CS-E 50 (k) Means for shutting down the Engine rapidly
322 TCCA EHPS.350 17 or piston portions of a hybrid design, but also for cutting Accepted It is covered by EHPS.350 (d)
must be provided.
electrical loads in various situations.
It would be good to keep this high level to potentially use the EHPS.350(b) has been renamed to reflect the development
323 FAA DJ EHPS.350 (b) 17 System Verification Policy. Harmonization talks are planned in this Yes Noted assurance aspects.
area for early summer with EASA. Development assurance has also been added to EHPS.80(a)(3).

system is fully relying on the aircraft power supply. A complete
Partially loss of the aircraft electric power supply will lead to the total loss
324 FAA GH EHPS.350 (i) 18 Requirements for electrical power to the control has been lost. Add it back in. Yes
accepted of power which is a considered as a Catastrophic Aircraft Effect.
The protection system must be designed and constructed so

Paragraph (f) Protection system
EHPS.350 Control that foreseeable Failures or malfunctions leading to local
325 Rolls-Royce 17 This paragraph (f) does not refer to protection. <see also comment Yes No Accepted Paragraph dedicated to Protection Systems has been reworded.
System events in the intended aircraft application, such as fire,
36>
overheat must not result in loss of the protection function
The term "essentially" is always subject to discussions during

There is no equivalent to CS-E50 (c )(2) 'in the Full-up Configuration,
engine certification and does not consitute a clear requirement.
the system is essentially single Fault tolerant for electrical and
CS-E is dedicated to single engine design (while considering
EHPS.350 Control electronic Failures with respect to LOTC/LOPC events'. that rule can Partially
326 Rolls-Royce 18 Consider including an equivalent to CS-E50 (c )(2) in EHPS.350 Yes No generic installations to define generic safety objectives like the CS-
System be a substantial control system architecture driver, so if it applies, it accepted
E 50(c)(2)).
should be included in the rules, not just the AMCs. (see also
SC E-19 derives directly the safety objectives from the intended
comment 22)
aircrfat application.
EHPS.350 Control Not

327 Rolls-Royce 18 Not convinced that (e )(3) adds anything to (e )(2). leave out (e )(3) Yes No A local event may not be the result of a single failure.
System accepted
EHPS.350 Control (f) covers CS-E50 (e ) but at higher level; given the high level of (f) I Partially
328 Rolls-Royce 18 leave out (f) Yes No Paragraph dedicated to Protection Systems has been reworded.
System am not convinced it adds anything to (a). accepted
"The design and functioning of EHPS control devices and systems,
together with EHPS instruments and operating and maintenance
instructions, must provide reasonable assurance that the EHPS
EHPS.350 EHPS
329 Rolls-Royce 18 operating limitations will not be exceeded in service." Define "reasonable assurance". Yes No Noted Paragraph dedicated to Protection Systems has been reworded.
Control System
What is "reasonable assurance"? Is this related to the safety
assessment? In which case should the level of assurance not be
commensurate with the hazard being protected?
EHPS.350 (g) excludes the power command signal from this
EHPS.350 EHPS regulation (as does CS-E 50) but I would have thought that more Consider including the power command signal in the scope of
330 Rolls-Royce 18 Yes No Accepted Corrected accordingly
Control System should be done to ensure that loss or corruption of the power the regulation.
command signal should be detected and accommodated.
Page 42 of 77
Werner Scholz, The requirement (b) for the deign assurance could become a
European EHPS.350 EHPS difficult task especially when applied onto the software Add regarding guidance and/or introduce some tiering (i.e. Partially
331 17 suggestion from the scope: CS-22, CS-LSA, CS-23 level 1 day VFR and Light
Sailplane Control System development. Here the limited possibilities for developers for the simplified requirements for simpler aircraft). accepted
UAS.
Manufacturers small aircraft sector could be exceeded very fast.

Control System - as follows (new proposed text shown in
Sub-paragraph (a) should be completed to include a requirement to
EHPS.350 EHPS Control System
provide adequate power response to control inputs. This is
(a) The EHPS control system design must be such that: Paragraph (a) has been corrected accordingly.
identified today in CS-E and also in CS 25 and should be maintained.
(1) the EHPS does not experience any unacceptable operating Paragraph (d) has been removed as covered by EHPS.30 and
The intent of sub-paragraph (d) is not obvious. It is not clear what
characteristics (including unacceptable power oscillations) or EHPS.330a dn replaced by EHPS isolation.
EHPS.350 EHPS added value it brings compared to § EHPS.490 and EHPS.30.
332 AIRBUS 17 exceed any of its operating limitations N Y Accepted Paragraph dedicated to Protection Systems has been reworded.
Control System Sub-paragraph (f) seems to be redundant with sub-paragraph (a).
(2) it performs its intended function throughout the declared Time limited dispatch is kept separated as not required for the
Sub-paragraph (g) may be combined with sub-paragraph (e)
A/C operational envelope in a manner which: certification. It is considered easier to keep it separated from
Sub-paragraph (d) could be combined with subparagraph (a)
(i) enables immediate modulation of EHPS power following EHPS.350.
The time limited dispatch requirement could be added to this EHPS
flight crew command with adequate sensitivity
Control system paragraph
(ii) enables selected values of relevant control parameters over
changing atmospheric conditions
(iii) complies with the operability specifications under EHPS.460

(b) Design Assurance
Any software and complex electronic hardware, including
programmable logic devices, shall be designed and developed
using a structured and methodical approach that provides a
EHPS.350 EHPS added value it brings compared to § EHPS.490 and EHPS.30.
333 AIRBUS 17 level of assurance for the logic, that is commensurate with the N Y Accepted Corrected accordingly.
Control System Sub-paragraph (f) seems to be redundant with sub-paragraph (a).
severity of the hazard associated with the failure or
malfunction of the system using this software or hardware,
and is substantiated by a verification methodology acceptable
to the Agency.
(c) EHPS control system failures.

The EHPS control system must:
(1) Meet the safety objectives of the intended aircraft
application;
(2) Not have any single failures (including loss of or corruption
of aircraft-supplied data) that result in High Energy Debris or
EHPS.350 EHPS added value it brings compared to § EHPS.490 and EHPS.30. Not Hazardous EHPS effect is not limited to the release of High Energy
334 AIRBUS 17 Propeller Release or Catastrophic Aircraft Effect; and N Y
Control System Sub-paragraph (f) seems to be redundant with sub-paragraph (a). accepted Debris.
(3) Be designed and constructed so that foreseeable Failures or
malfunctions leading to local events in the intended aircraft
application, such as fire, overheat or Failure leading to damage
to EHPS Control System components, must not result in a High
Energy Debris or Propeller Release or Catastrophic Aircraft
Effect due to EHPS Control System Failures or malfunctions.
Sub-paragraph (a) should be completed to include a requirement to (d) Information system security protection.
provide adequate power response to control inputs. This is EHPS control systems, including networks, software and data,
identified today in CS-E and also in CS 25 and should be maintained. must be designed and installed so that they are protected from
The intent of sub-paragraph (d) is not obvious. It is not clear what intentional unauthorized electronic interactions that may
EHPS.350 EHPS added value it brings compared to § EHPS.490 and EHPS.30. result in adverse effects on the safety of the aircraft. The
335 AIRBUS 17 N Y Noted
Control System Sub-paragraph (f) seems to be redundant with sub-paragraph (a). security risks and vulnerabilities must be identified, assessed
Sub-paragraph (g) may be combined with sub-paragraph (e) and mitigated as necessary. The applicant must make
Sub-paragraph (d) could be combined with subparagraph (a) procedures and instructions for continued airworthiness (ICA)
The time limited dispatch requirement could be added to this EHPS available that ensure that the security protections of the EHPS
Control system paragraph controls are maintained.
Page 43 of 77
(e) If approval is sought for dispatch with Faults present in an

EHPS control system, a time limited dispatch (TLD) analysis of
the EHPS control system must be carried out to determine the
dispatch and maintenance intervals. The time-weighted-
average of the Full-up Configuration and all allowable dispatch
configurations with Faults must meet the safety objectives of
the intended aircraft application and For each proposed
Sub-paragraph (a) should be completed to include a requirement to dispatchable configuration, it must be shown by test or
provide adequate power response to control inputs. This is analysis that:
identified today in CS-E and also in CS 25 and should be maintained. (1) The EHPS remains capable of meeting all EHPS
The intent of sub-paragraph (d) is not obvious. It is not clear what specifications for the operability aspects covered by EHPS.460
EHPS.350 EHPS added value it brings compared to § EHPS.490 and EHPS.30. (2) The ability to control the EHPS within limits is maintained; Not Hazardous EHPS effect is not limited to the release of High Energy
336 AIRBUS 17 N Y
Control System Sub-paragraph (f) seems to be redundant with sub-paragraph (a). (3) Protection is maintained against High Energy Debris or accepted Debris.
Sub-paragraph (g) may be combined with sub-paragraph (e) Propeller Release and Catastrophic Aircraft Effect, if provided
Sub-paragraph (d) could be combined with subparagraph (a) solely by the EHPS control system and shown to be necessary
The time limited dispatch requirement could be added to this EHPS by the safety analyses required under EHPS.80 and EHPS.350;
Control system paragraph (4) A means is maintained to provide necessary signals to
identify EHPS control system Faults;
(5) A further single Failure in the EHPS control system will not
produce a High Energy Debris or Propeller Release or a
Catastrophic Aircraft Effect;
(6) The Engine continues to meet its certification specifications
for external threats;
(7) The proposed dispatch interval is justified.
EHPS.350 EHPS
FARADAY Can the Agency details what are "unacceptable operating
337 Control System 17 Yes No Accepted Specific guidance will be provided in the Means of Compliance.
aerospace characteristics"
(a)
We recommend to modify the paragraph (b):
“(b) Design Assurance
Any software and complex electronic hardware, including
programmable logic devices, shall be designed and developed
EHPS.350 This is why safety objectives have to be derived from the intended
using a structured and methodical approach that provides a Not
338 VOLTAERO EHPS Control 17 The EHPS designer does not know the safety level of the aircraft. YES NO aircraft application. The aircraft manufacturer will provide these
level of assurance for the logic, that is commensurate with the accepted
System data as it is already done today between aircraft manufacturers
severity of the hazard associated with the failure or
malfunction of the systems in which the devices are located,
and is substantiated by a verification methodology acceptable
to the Agency. “
EHPS.350 We recommend to modify the paragraph : Paragraph dedicated to Protection Systems has been reworded.
The EHPS failures are already dealt with in EHPS.80 Safety Partially
339 VOLTAERO EHPS Control 17 - Delting (e) YES NO Specific requirement applies on top of the safety objectives
assessment. accepted
System - Renumbering (f) in (e). derived from the EHPS.80.
EHPS.350 The EHPS designer does not know the safety level of the aircraft. We recommend to modify the paragraph : This is why safety objectives have to be derived from the intended
Not
340 VOLTAERO EHPS Control 18 The EHPS failures are already dealt with in EHPS.80 Safety - Delting (g) YES NO aircraft application. The aircraft manufacturer will provide these
accepted
System assessment. - Renumbering (h) in (f). data as it is already done today between aircraft manufacturers
(4) Not have any single electrical or electronic failures that Covered by 350(e)(2).
result in Hazardous EHPS Effect(s). This applies to hard faults Specific guidance will be provided in the MoC to define the nature
341 FAA DK EHPS.350(e) 17 Add item Yes Accepted
(short circuits, open circuits, out-of-range) and soft faults (in- of the failure including hard (short circuits, open circuits, out-of-
range shifts, drifts, erratic fluctuations) range) and soft faults (in-range shifts, drifts, erratic fluctuations).
Page 44 of 77

(e) EHPS control system failures.
The EHPS control system must:
(1) Meet the safety objectives of the intended aircraft
application;
(2) Not have any single failures that result in Hazardous EHPS
Effect(s) or Catastrophic Aircraft Effect; and
(3) Be designed and constructed so that foreseeable Failures or EHPS are different from a single motor as they most of the time
malfunctions leading to local events in the intended aircraft include several motors. As such, failures modes cannot be only
application, such as fire, overheat or Failure leading to damage assessed anymore at motor level but at aircraft level (e.g. when
The EHPS manufacturer should not be responsible to define what
to EHPS Control System components, must not result in a the propulsion system takes part in the flight control function).
are the Major, Hazardous or Catastrophic Aircraft Effects. This
Hazardous EHPS Effect or Catastrophic Aircraft Effect due to This is why safety objectives have to be derived from the intended
categorization will be very dependent of the aircraft propulsion Not
342 Embraer S.A. EHPS.350(e) 17 EHPS Control System Failures or malfunctions. yes no aircraft application. The aircraft manufacturer will provide these
architecture and this analysis should be made by the aircraft accepted
To: data as it is already done today between aircraft manufacturers
manufacturer. Recommended to delete any reference to aircraft
(e) EHPS control system failures. and engine manufacturers. EHPS manufacturers do need to take
level effects.
The EHPS control system must: into account safety objectives that are provided by the aircraft
(1) Meet the applicable safety objectives; manufacturers in order for them to be able to perform the
(2) Not have any single failures that result in Hazardous EHPS complete aircraft safety analysis.
Effect(s); and
(3) Be designed and constructed so that foreseeable Failures or
malfunctions leading to local events in the intended aircraft
application, such as fire, overheat or Failure leading to damage
to EHPS Control System components, must not result in a
Hazardous EHPS Effect due to EHPS Control System Failures or
malfunctions.
Once again, I believe that inclusion of Aircraft Effects is an the propulsion system takes part in the flight control function).
EHPS.350(e)(2) overreach. The engine manufacturer is less that qualified to make This is why safety objectives have to be derived from the intended
Not
343 FAA GH and (3) 17 that level of judgement. That is the role of the installer. While I Yes Yes aircraft application. The aircraft manufacturer will provide these
accepted
Also in (g)(1) agree that the engine manufacturer needs to be aware of these data as it is already done today between aircraft manufacturers
threats he is not the best individual to certify these facts. and engine manufacturers. EHPS manufacturers do need to take
Vertical Provide clarity on what ‘reasonable assurance’ means to the

344 EHPS.350(f) 18 What does EASA mean by 'reasonable assurance'? Yes Noted Paragraph dedicated to Protection Systems has been reworded.
Aerospace agency
345 FAA DJ EHPS.350(g) 18 A total loss of thrust for most eVTOLs would be catastrophic. Yes Noted This has to be assessed as requsted per EHPS.80.
More clarify is required on the following: "Single failures leading to AMC to define the types of ‘power command signals’, this
Vertical
346 EHPS.350(g) 18 a loss, interruption or corruption of aircraft-supplied data (other could include speed control (i.e. RPM command), or it may Yes Noted Folllowing received comments, the exclusion has been removed.
Aerospace
than power command signals from the aircraft)" include torque control but not necessarily speed.
(g) Aircraft-supplied data. Single failures leading to a loss,
interruption or corruption of aircraft-supplied data (other than
power command signals from the aircraft), or aircraft-supplied
data shared between independent EHPS or independent
engines of a EHPS must: (1) Not result in a Hazardous EHPS
Aircraft level system safety assessment should evaluate effects on Effect or Catastrophic Aircraft Effect for any EHPS installed on Not
347 Embraer S.A. EHPS.350(g) 18 yes no aircraft application. The aircraft manufacturer will provide these
the aircraft and it is not required to evaluated by this SC. the aircraft; and (2) Be detected and accommodated. accepted
To:
(g) Aircraft-supplied data.
Single failures leading to a loss, interruption or corruption of
aircraft-supplied data (other than power command signals
from the aircraft), or aircraft-supplied data shared between
independent EHPS or independent engines of a EHPS must:
Page 45 of 77
(1) Not result in a Hazardous EHPS Effect; and

(2) Be detected and accommodated.
This implies to me that total loss of thrust, landing off-site, etc. are
EHPS.350 (g)(1) and (g)(2) do not imply this.
EHPS.350(g)(1) acceptable. Given that this is a design choice (single input from the
348 FAA AS 18 Yes Noted The criticality of such events should be made at aircraft level by
and (2) airplane that could affect all engines), maybe the requirements
the aircraft manufacturer.
from EHPS 290(b) would be more appropriate.
Same methodology and requirements as for CS-E.
(a) is important as it defines the non obligation to show
Shouldn’t one high level rule be written and have (a) thru (e ) be
compliance to this requirement.
addressed in the MOC? The MOC requirements seem like they Not
349 FAA DJ EHPS.355 18 Yes (b) provides additional safety and operational requirements for
could vary considerably between fixed wing, rotorcraft/eVTOL, and accepted
each dispatchable configuration.
UAS.
Detailed guidance is provided as per ARP5107B. Similar guidance
should be made for EHPS control system.
Lange Aviation Search document for “engine” and replace with “EHPS” where
350 EHPS.355 18 “EHPS” instead of “Engine” in several instances Yes Accepted Corrected accordingly.
GmbH appropriate
351 Rolls-Royce EHPS.355 18 (b)(6) Typo: Substitute "EHPS" instead of "Engine" Substitute wording Yes No Accepted Corrected accordingly.
An AMC is needed to define the perimeter that could be

covered in this requirement (named here EHPS Control
Specific guidance will be provided as part of the Means of
352 SAFRAN EHPS.355 18 AMC System). Accepted
Compliance.
The philosophy for the EHPS dispatch is understood as the
same as for Engine Dispatch, please explain.
‘Catastrophic Aircraft Effect’ à There is an inconsistency with
this paragraph. Only the TC Holder can demonstrate EHPS are different from a single motor as they most of the time
compliance with the aircraft safety objectives. For the Aircraft include several motors. As such, failures modes cannot be only
it is the Aircraft TCH. assessed anymore at motor level but at aircraft level (e.g. when
This Special Condition requirement applies to a EHPS applicant the propulsion system takes part in the flight control function).
(with its own Certification Basis). This is why safety objectives have to be derived from the intended
Not
353 SAFRAN EHPS.355 18 EHPS perimeter Engine word left, proposed text : aircraft application. The aircraft manufacturer will provide these
accepted
(5) A further single Failure in the EHPS control system will not data as it is already done today between aircraft manufacturers
produce a Hazardous EHPS Engine Effect and engine manufacturers. EHPS manufacturers do need to take
(6) The EHPS Engine continues to meet its certification into account safety objectives that are provided by the aircraft
specifications for external threats; manufacturers in order for them to be able to perform the
(7) The requirement includes all aircraft safety objectives à complete aircraft safety analysis.
please explain ?
Same methodology and requirements as for CS-E.

General (a) is important as it defines the non obligation to show
Aviation EHPS 355-(b) For each dispatchable configuration it must be shown (b) For each dispatchable configuration it must be shown by Not compliance to this requirement.
354 EHPS.355 18 Minor
Manufacturers by test or analysis that:- 'or' may be an issue here. test and analysis that: accepted (b) provides additional safety and operational requirements for
Association each dispatchable configuration.
Detailed guidance is
It may not be appropriate to include aircraft level effects here. Not
355 FAA PH EHPS.355 (b)(5) 18 Yes aircraft application. The aircraft manufacturer will provide these
Again overreach accepted
Is there an ALS? Otherwise requiring operators to follow the TLD

356 FAA AS EHPS.355 (d) 19 Yes Noted The ALS is part of the ICA requested in EHPS.25.
may not be legally enforceable
Page 46 of 77
Time limited dispatch is kept separated as not required for the

certification. It is considered easier to keep it separated from
EHPS.355 Time- This paragraph could be combined with EHPS.350 as it pertains to Not
357 AIRBUS 18 See proposal above N Y EHPS.350.
Limited Dispatch the Control System accepted
Specific guidance may have to be developed to support new
intended aircraft architectures.
We recommend to modify the paragraph (b) (5):
EHPS.355 This is why safety objectives have to be derived from the intended
(5) A further single Failure in the EHPS control system will not Not
358 VOLTAERO Time-Limited 18 The EHPS designer does not know the safety level of the aircraft. YES NO aircraft application. The aircraft manufacturer will provide these
produce a Hazardous Engine Effect or a Catastrophic Aircraft accepted
Dispatch data as it is already done today between aircraft manufacturers
Effect; “

(b) For each dispatchable configuration it must be shown by
test or analysis that:
(1) The EHPS remains capable of meeting all EHPS
specifications for the operability aspects covered by EHPS.460
(2) The ability to control the EHPS within limits is maintained;
(3) Protection is maintained against Hazardous EHPS Effects
and Catastrophic Aircraft Effect, if provided solely by the EHPS
control system and shown to be necessary by the safety
analyses required under EHPS.80 and EHPS.350;
(4) A means is maintained to provide necessary signals to
produce a Hazardous Engine Effect or a Catastrophic Aircraft
Effect;
Analysis for each dispatchable configuration that is related to an Not
359 Embraer S.A. EHPS.355(b) 18 (7) The proposed dispatch interval is justified. yes no Same methodology and requirements as for CS-E
aircraft effect should be evaluated under CS-MMEL requirements. accepted
To:
(b) For each dispatchable configuration it must be shown by
test or analysis that:
(1) The EHPS remains capable of meeting all EHPS
specifications for the operability aspects covered by EHPS.460
(2) The ability to control the EHPS within limits is maintained;
(3) Protection is maintained against Hazardous EHPS Effects, if
provided solely by the EHPS control system and shown to be
necessary by the safety analyses required under EHPS.80 and
EHPS.350;
(4) A means is maintained to provide necessary signals to
produce a Hazardous Engine Effect;
(7) The proposed dispatch interval is justified.
The title of the requirement deals with ‘connection’, however,

it is understood that the requirement concerns the installation
Paragraph has been reworded to explain the complete link from
360 SAFRAN EHPS.360 18 Title and requirement not sufficiently explicit but also the necessary information (EHPS state, battery SOC, Accepted
EHPS.80 to design to EHPS.30.
etc..) to be provided to the aircraft (for display purpose for the
crew). As an example, CS-E 60(a) could be used.
Page 47 of 77
Add "(a)"
Add
"(b) The instrument or sensor connections must be designed or
361 TCCA EHPS.360 19 labeled to ensure a correct connection. Suggest to revise and add text, if needed Accepted EHPS.360 has been reworded.
(c) Any instrumentation on which the Safety Assessment (see
EHPS.80) depends must be specified and declared mandatory in the
EHPS installation manual."
Removed:
CS-E 60(b) "A list of the instruments necessary for control of the
This requirement may still be applicable, both for the turbine
Engine must be provided in the instructions for installation. The
or piston portions of a hybrid design, but also for cutting
362 TCCA EHPS.360 19 overall limits of accuracy and transient response required of such Accepted EHPS.360 has been reworded.
electrical loads in various situations.
instruments for control of the operation of the EHPS must also be
Review other paragraphs from CS-E 60 for applicability.
stated so that the suitability of the instruments as installed may be
assessed."
EHPS.360
Instrument and Partially Paragraph has been reworded to explain the complete link from
363 AIRBUS 19 The intent of this paragraph is covered under EHPS.80 Airbus propose to delete the paragraph. N Y
Sensor accepted EHPS.80 to design to EHPS.30.
Connection
EHPS.360 This rule is a bit weak given the variety of new sensors and other
Electrical protections are not part of this paragraph.
364 Rolls-Royce Instrument and 19 protective devices (e.g. fuses) that turn up as a result of Clarify the definition. Yes No Accepted
This paragraph is dedicated to the instrumentation.
Sensors electrification.
The requirement should also cover protection of connected This is covered by EHPS.370 which refers to the intended aircraft
Lange Aviation The interdependence of systems connected to the distribution
365 EHPS.370 19 systems, e.g. from overloads and fluctuations, short circuits in Yes Accepted application requirements.
GmbH network, especially in case of failures is not discussed.
one system. Specific guidance will be provided.
What happens if the system is unloaded? There is a lot of energy
that has to be managed in order to avoid going somewhere it is not
wanted. Potential for a generator to be disconnectred from a
366 Rolls-Royce EHPS.370 19 Consider paragraph (d) to cover disconnection of loads. Yes No Accepted Added accordingly.
storage device, leaving no energy-sink. Add paragraph (d):
"Disconnection of loads shall have no detrimental effects on the
Electrical power generation and distribution.
This is already covered by EHPS.370 which refers to the intended
The means of compliance to EHPS.370 makes reference to CS-E
aircraft application requirements where electrical bonding is
367 Rolls-Royce EHPS.370 19 135, Electrical Bonding. Why isn't the scope of CS-E 135 included in Include the full scope of CS-E 135 Yes No Accepted
addressed.
full within this SC?
The Title could be ‘EHPS Electrical power generation and

distribution’.
There is an inconsistency with this paragraph. Only the TC
Holder can demonstrate compliance with its Certification Basis.
For the Aircraft it is the Aircraft TCH.
It is important to keep proportionality in the certification
This Special Condition requirement applies to a EHPS applicant
requirements.
(with its own Certification Basis).
Not An EHPS dedicated to CS-23 level 2 aircraft will not have the same
368 SAFRAN EHPS.370 18 EHPS perimeter Proposed text:
accepted requirements as those for a CS-25 product.
(a) The electrical power generation and distribution of the
Specific guidance will be provided to define the requirements
EHPS must be designed and constructed so as to meet the
applicable depending on the intended aircraft application.
Type-Certification basis of the specification of the intended
aircraft application
(c) Does the ‘connected loads’ are those only to the EHPS or
could be also all connected loads (as for aircraft electrical loads
connected to the EHPS) ?
This § does address failure cases for which Hazardous EHPS
effects must be prevented. It is proposed to address during the Specific guidance will be provided as part of the Means of
369 SAFRAN EHPS.370 Failure conditions assessment Accepted
MoC the conditions for which the protective devices has to be Compliance.
substantiated.
Page 48 of 77
General The term "detrimental" is often ued in the different Certification

EHPS.370 - A detrimental effect is not described in part (c).
Aviation Describe a detrimental effect either in the EHPS.370 regulation Major/concep Specifications.
370 EHPS.370 19 Hazardous and catastrophic effects are described in the Accepted
Manufacturers or in the terminology section. tual Specific guidance will be provided as part of the Means of
terminology section.
Association Compliance.

Electrical power generation and distribution should be certified
Not enable innovation.
371 Embraer S.A. EHPS.370 19 under aircraft certification requirements. Recommended to delete We suggest to delete this paragraph. yes no
accepted Specific guidance will be provided in a Certification Memorandum
this requirement.
Include some requirements that the electrical systems

The list of essential systems for flight continuation has to be
(generators, motors, transmission cables, controllers and
provided by the aircraft manufacturer depending on the aircraft
protective devices) shall be able to furnish the required power
Not architecture and characteristics.
372 TCCA EHPS.370 19 Some systems might be essential for the safe continuation of flight. at the proper voltage and frequency.
accepted This exchange of information is ensured via to the top/down
Define the concept of essential systems for flight continuation
approach requested in EHPS.80.
that needs to sustain a defined level of electrical power.
EHPS.370 refers to the intended aircraft application requirements.
Define load shed capability.
Not
373 TCCA EHPS.370 19 Note comment for the Subpart A. To redefine the concept. Refer to answer provided for comment for Subpart A
accepted
Relative to ‘Type Certification Basis of the’,

Not The sentence would not be correct as one cannot show
374 FAA JP EHPS.370 (a) 19 Just identifying the intended aircraft application should be Suggest removing ‘Type Certification Basis of the’, Yes
accepted compliance to an intended aircraft application.
sufficient.
Presumably this is aiming rather for no derimental effect on the
EHPS.370 c) The term "detrimental" is often ued in the different Certification
platform. One example: pyrofuses can’t be reversed back to letting
Electrical power Specifications.
375 Rolls-Royce 19 current flow the way a fuel shut-off valve can, this means a “safe” Clarify the definition. Yes No Accepted
generation and Specific guidance will be provided as part of the Means of
outcome for the EHPS where the HV cables are protected and don’t
distribution Compliance.
burn, but this could be very bad for the platform: no more power!
The term "detrimental" is often ued in the different Certification

EHPS.370 Specifications.
Electrical power Some architectures include motors which may regenerate electrical Evaluate if the risks correlated with such operation need to be Specific guidance will be provided as part of the Means of
376 Rolls-Royce 19 Yes No Accepted
generation and energy under specific conditions. covered in EHPS.370 Compliance.
distribution Note that electrical energy recuperation mode is also addressed in
EHPS.460(e) where specific guidance will also be provided.
BMS is now part of the EHPS control system and thus subject to
Lacking a requirement to ensure the EHPS electrical power and
EHPS.370 Suggest a similar requirement to EHPS.350(e) be included in Partially EHPS.350 requirements.
377 TCCA 19 distribution systems / electrical storage systems does not have
EHPS.380 EHPS.370 & 380. accepted EHPS is subject to the safety assessment process as requested in
failures that could result in hazardous EHPS effects
EHPS.80.

We may have a gap as we do not believe that the Battery systems Not enable innovation.
378 FAA GH EHPS.380 19 Remove or change the purpose to make this a link to ESS Yes
should be a part of engine requirements. accepted Specific guidance will be provided in a Certification Memorandum
This seems difficult to impose as a requirement on the EPHS

applicant. If the EHPS is installed in an airplane without VTOL
capability, then later an aircraft with VTOL capability, it could drive
Indeed, requirements may not be identical depending on the
different requirements for the ESS, specifically the ESS emergency
intended aircraft application. However, it is important to keep
landing condition evaluation. Installation in the VTOL aircraft would Not
379 FAA JP EHPS.380 19 Yes Yes proportionality in the certification requirements.
not invalidate the initial EHPS approval, it just would not be accepted
The scope of the Special Condition is now limited to the case
approved in the new VTOL aircraft. My intent here is to clarify that
where the intended aircraft application is known.
the aircraft level requirements should not be imposed on the EHPS
as an engine level requirement, only as a limitation established
during EHPS approval used to determine installation eligibility.
Page 49 of 77
It has to be differentiated between power and energy. Especially

Both, power and energy, have to be assessed for safe
concerning the failure of the power generating engine, the energy
Lange Aviation continued flight and landing, taking into account operational
380 EHPS.380 20 storage device has to deliver a high enough power, while the stored Yes Accepted Energy replaced by "power supply".
GmbH considerations, i.e. time to safe landing, and reliability of
energy also has to be sufficient for a time long enough for
power generation system.
continued flight and landing.
The mentioned case is a specific configuration and can not be used

In a hybrid configuration only the emergency rating depends solely to define applable requirements for all kind of architectures.
Lange Aviation It should be differentiated between emergency and normal
381 EHPS.380 20 on the energy storage device. Otherwise the power generating Yes Accepted Paragraph (b) has been reworded to be architecture and usage
GmbH ratings, taking into account different hybridisation concepts.
engine will deliver a part or all required power. agnostic..
If not intended, perhaps change

Cranfield Wording seems to preclude hybrid configurations. What if the ESS “…at all time during the flight….” Paragraph (b) has been reworded to be architecture and usage
382 Aerospace EHPS.380 20 provides only part of the required energy in certain phases of For Yes No Accepted agnostic..
Solutions Ltd flight? With the rest provided by other sources. “…at all times for which it is required during the flight….” Specific guidance will be provided in the Means of Compliance.
Or something equivalent.
"(b) If the EHPS contains an electric energy storage device providing
electric energy to an electric engine(s), it must be designed and
constructed so as to provide the required energy for the electric
engine(s) of the EHPS at all time during the flight in order for them
to provide the rated powers defined in EHPS.40." - This Paragraph (b) has been reworded to be architecture and usage
383 Rolls-Royce EHPS.380 20 requirement does not necessarily take into account many of the Consider rewording or removing this requirement Yes No Accepted agnostic..
likely architectures for EHPS where it may be perfectly acceptable Specific guidance will be provided in the Means of Compliance.
not to meet the requirement due to redundancy or alternate
sources of energy. Suggest a review of the common architectures
(full electric, parallel hybrid, series hybrid) and either remove or
reword this requirement
What happens if, by design, the energy storage device does not
have sufficient energy, on its own, to provide the energy for full "It" replaced by "Propulsion battery".
thrust, but is used to supplement another source? In this case, Paragraph (b) has been reworded to be architecture and usage
384 Rolls-Royce EHPS.380 20 Replace "it" with "EHPS" Yes No Accepted
Paragraph (b) has an ambiguous "it"; propose we replace with agnostic..
"EHPS" to avoid referring to only the energy storage device of the Specific guidance will be provided in the Means of Compliance.
EHPS
(a) If the EHPS contains an energy storage device, the energy

storage device and its management system must be designed and Where can appropriate requirements on energy storage
385 Rolls-Royce EHPS.380 19 Yes No Noted Specific guidance will be provided in the Means of Compliance.
constructed so as to meet the Type-Certification basis of the management system be found?
intended aircraft application.
It is important to keep proportionality in the certification

requirements.
Same comment as for EHPS 370 : (a) … must be designed and
Not An EHPS dedicated to CS-23 level 2 aircraft will not have the same
386 SAFRAN EHPS.380 19/20 EHPS perimeter constructed so as to meet the Type-Certification basis of the
accepted requirements as those for a CS-25 product.
specification of the intended aircraft application
(b) it's not up to EHPS applicant to manage the energy (the

responsibility should remain to the aircraft manufacturer who
knows the mission). EHPS applicant shall guarantee the power
at the EHPS level.
The aircraft manufacturer shall specify the amount of energy
387 SAFRAN EHPS.380 19/20 Power supply instead of energy to be stored, the criticality of the unavailability or erroneous Accepted Corrected accordingly.
information. EHPS applicant will have therefore to
demonstrate that how the storage system meets the
specification and indicate the amount of energy stored with
the right level of reliability with respect to criticality.
Proposed text : “If the EHPS contains an electric energy storage
Page 50 of 77
device providing electric power to electric engine(s), it must be

designed and constructed so as to provide at all time during
the flight the required power for the electric engine(s) of the
EHPS to provide the rated powers defined in EHPS.40”
As for EHPS.370, this § does address failure cases for which

Hazardous EHPS effects must be prevented. It is proposed to Specific guidance will be provided as part of the Means of
388 SAFRAN EHPS.380 19/20 Failure conditions assessment Accepted
address during the MoC the conditions (physical separation of Compliance.
the BMS control system, …).
EHPS 380- (b) What about the safety assessment of the Energy
General Storage System? "If the EHPS contains an electric energy storage The propulsion battery, if part of the EHPS, must be part of the
Aviation device providing electric energy to an electric engine(s), it must be safety assessment requested in EHPS.80. The safety objectives
389 EHPS.380 20 Include ESD Safety Assessment. Question Noted
Manufacturers designed and constructed so as to provide the required energy for begin derived from the intended aircraft application, there is no
Association the electric engine(s) of the EHPS at all time during the flight in inconsistency.
order for them to provide the rated powers defined in EHPS.40."
The requirements will be provided in the relevant Type-

With the increasing utilization of electric energy storage devices in
With the available battery inservice experience, suggestion is Certification basis of the intended aircraft application.
390 Flying Whales EHPS.380 19 the EHPS architecture, we feel the need to add have more specific Yes No Noted
consider more specific requirements. Specific guidance will be provided as part of the Means of
requirements under this category
Compliance.

Energy storage system should be certified under aircraft
Not enable innovation.
391 Embraer S.A. EHPS.380 19 certification requirements. Recommended to delete this We suggest to delete this paragraph. yes no
accepted Specific guidance will be provided in a Certification Memorandum
requirement.
Reword “(b) If the EHPS contains an electric energy storage

“(b) If the EHPS contains an electric energy storage device providing
device providing electric energy to an electric engine(s), it must
electric energy to an electric engine(s).”
be designed and constructed so as to provide and absorb the
392 Airbus DS EHPS.380 20 The energy storage systems can be charged in flight, be used as a Yes No Accepted Paragraph (c) has been added.
required energy for the electric engine(s) of the EHPS at all
buffer and also charged on ground. In Li-ion applications, the
time during the flight in order for them to provide the rated
charging is typically more stringent than the discharging.
powers defined in EHPS.40.”
Suggest removing ‘Type Certification Basis of the’, just

Not The sentence would not be correct as one cannot show
393 FAA JP EHPS.380 (a) 19 See above comment in 370(a) identifying the intended aircraft application should be Yes
accepted compliance to an intended aircraft application.
sufficient.
This “energy storage device” could be just a battery for some hold
Paragraph (b) has been reworded to be architecture and usage
up purpose, emergency, etc..or an energy system to power the
394 FAA DJ EHPS.380 (a) 19 Yes Accepted agnostic..
motors full time. As Gary says Maybe. The line is not clear where
this is part of the propulsion system or the aircraft installation.
What if the ESD is only for certain phases of flight such as takeoff? Paragraph (b) has been reworded to be architecture and usage
395 FAA DJ EHPS.380 (b) 20 Will this be allowed with the statement “at all time during the Yes Accepted agnostic..
flight…”? Specific guidance will be provided in the Means of Compliance.
Page 51 of 77
(b) If the EHPS contains an electric energy storage device

providing electric energy to an electric engine(s), it must be
designed and constructed so as to provide the required energy
(b) The text "provide the required energy for the electric engine(s)
for the electric engine(s) of the EHPS at all time during the
of the EHPS at all time during the flight in order for them to provide Paragraph (b) has been reworded to be architecture and usage
EHPS.380 Energy flight in order for them to provide the rated powers defined in
396 Rolls-Royce 20 the rated powers" requires an ESS with unlimited duration. For an Yes No Accepted agnostic..
Storage System EHPS.40 for the rated duration of the energy storage device.
all electric aircraft, the power output of the ESS will only allow Specific guidance will be provided in the Means of Compliance.
Note also comment 20 requests revision of this wording but
operation at the rated power for a stated duration.
does not address the 'rated duration' topic for all electric
aircraft propulsion raised here - potential need to have an
additional section in EHPS.380
EHPS.380 Energy Paragraph (b) has been reworded to be architecture and usage
397 Rolls-Royce 20 Typo: 'at all time' should be 'at all times'. Correct wording Yes No Noted
Storage System agnostic..
Suggest this wording:

If the EHPS makes use of stored energy, this must be certified
as an element of the EHPS.
From a certification perspective an energy storage system
(a) If an energy storage device is included, the energy storage
(EHPS.380) could be viewed as analogous to a fuel tank and
device and its management system must be designed and
therefore out of EHPS scope. Or it could be viewed as an energy
constructed so as to meet the Type-Certification basis of the For the time being, EASA is willing to offer flexibility in order to
storage element for power management within the EHPS (in which
EHPS.380 Energy intended aircraft application. Partially enable innovation.
398 Rolls-Royce 20 it might be in a similar state of charge upon landing as it was on Yes No
Storage System (b) If an electric energy storage device is included providing accepted Specific guidance will be provided in a Certification Memorandum
take-off.) Our strong preference is for the latter, since any
electric energy to an electric engine(s), it must be designed and to part 21 regarding the ways to certify an EHPS.
propulsion system which manages energy storage during a mission
constructed so as to provide the required energy for the
is likely to be critically dependent upon storage system
electric engine(s) of the EHPS at all time during the flight in
performance.
order for them to provide the rated powers defined in
EHPS.40.(But also note additional comment 20 above, relating
to this last sentence)
This SC should provide far more detail regarding requirements for

energy storage systems, as this is one of the main areas of The requirements will be provided in the relevant Type-
EHPS.380 Energy regulatory uncertainty facing projects particulary those that include Include means of compliance for Lithium battery based energy Certification basis of the intended aircraft application.
399 Rolls-Royce 19/20 No Yes Accepted
Storage System Lithium batteries. This standard should include specific details storage systems Specific guidance will be provided as part of the Means of
equivalent to the scope covered by DO-311 and approved means of Compliance.
compliance for these systems.
The requirements will be provided in the relevant Type-

Certification basis of the intended aircraft application.
400 Rolls-Royce EHPS.380 ESS 19 No reference to DO 311A Clarify the status of DO-311A. <See also comment 83> Yes No Accepted
Compliance.
Instructions for installation and operation are not certification

requirements. They are outputs of the EHPS design and
We recommend to modify the paragraph (a):
certification process.
(a) If the EHPS contains an energy storage device, the energy
EHPS.380 It is important to keep proportionality in the certification
storage device and its management system must be designed Not
401 VOLTAERO Energy Storage 19 The EHPS designer does not know the safety level of the aircraft. YES NO requirements.
and constructed so as to meet the installation instructions, accepted
System An EHPS dedicated to CS-23 level 2 aircraft will not have the same
operating instructions and limitations.Type-Certification basis
requirements as those for a CS-25 product.
of the intended aircraft application. “
Design and construction of the management system of the energy

storage device is addressed here, although SC-EHPS excluded this
by
402 Volocopter EHPS.380(a) 20 Yes Noted Exclusion of the BMS has been removed.
definition according EHPS.15. Could EASA please provide a
rationale,
why it should be considered in EHPS.380?
Page 52 of 77
There are 2 (d) sub-parts.

403 Volocopter EHPS.40 9 Yes Accepted Corrected accordingly.
In sub-part (f), “is” should be replaced by “are”
Are the referenced “ratings” applicable to the system as a whole or

Cranfield
for each of the applicable sub-systems? e.g. gas turbine/piston
404 Aerospace EHPS.40 8 Clarification of applicability of ratings. Yes No Noted Refer to the ratings deinfition provided in EHPS.15.
engine and motors? Are ratings of an engine connected to a
Solutions Ltd
generator instead of a propeller/fan required?
Equivalent § to CS-E 745 should be clearly declined in SC-EHPS.

Electrical system (Battery) : State Of Charge, State Of Health : to Power response is addressed in EHPS.460 (c)
405 SAFRAN EHPS.40 8 & 25 Battery could limit the current and impact EHPS performance Yes Yes Accepted
add consideration of State Of Power Specific guidance will be provided and will be cover CS-E 745
in case of high power request during a given period.
what is meant by "to enable the aircraft safety analysis to be

Partially "To enable the aircraft safety analysis to be carried out" has been
406 Zeroavia EHPS.40 carried out." Instead, suggest "and must be consistent with safety
accepted removed
James Lawson analysis assumptions."
“EHPS.40 Ratings and operating limitations
… “EHPS.40 Ratings and operating limitations
(b) EHPS operating limitations includes any limitation required to be …
The Boeing
407 EHPS.40 8 monitored to ensure the safe operation of the EHPS and its (b) EHPS operating limitations includes any limitation required no yes Accepted Modified accordingly
Company
associated sub-systems.” to be monitored to ensure the safe operation of the EHPS and
We ask EASA to refer to existing standards that are used for similar its associated sub-systems.”
evaluations because the current language is unclear.
“EHPS.40 Ratings and operating limitations
…
(f) Each selected rating must be for the lowest power that all EHPSs
The Boeing We ask EASA to clarify the intent of this requirement, Wording is issued from CS-E.
408 EHPS.40 8 of the same type is capable of producing under the conditions used no yes Accepted
Company specifically what “the lowest power” means in this context. Specific guidance will be provided in the Means of Compliance
to determine that rating at all times during the flight and at all
times between overhaul periods or other maintenance.”
An explanation of the lowest power is not provided.
"as well as for Emergency Ratings if needed" is ambiguous. What

Zeroavia
409 EHPS.40 does if needed mean? Instead, suggest "if required by the safety Accepted Clarification added.
James Lawson
analysis."
What has to be included in the TCDS is not part of the

requirements for which compliance has to be shown by applicants.
In (a), revise text to read Add "...established by the Agency and
Any other information necessary for the safe operation of the
included in the type certificate data sheet,..." Partially
410 TCCA EHPS.40 8 Suggest to revise and add text, if needed EHPS is not part of EHPS.40, except for the limitations that is
Add new "(g) Any other information necessary for safe operation of accepted
covered by EHPS.40(b).
the EHPS."
Any other information necessary for the safe operation of the
EHPS are covered by EHPS.30 and EHPS.80.
Page 53 of 77
In reference to Take-off Power and Max Continuous Power….

I am still not sure that these two rating definitions are appropriate
for EP. Going back to the ASTM Standard, my goal was to get
people thinking about ratings based on the intended Duty Cycles.
Problem I am concerned about is the very differenct utilization and
MCP and MTOP ratings have been kept as they are of common
capabilities of an electric engine. Both of these are very different
usage in the aviation. However, EHPS.40 (e) opens the door for
411 FAA GH/WM EHPS.40 (c) 8 from Turbine and Recip engines. yes Noted
new ratings that the applicant have to defined. It follows the
A counter arguement was posted :
notion of duty cycle.
1) It may only be applicable to hybrids using internal combustion
(IC) engines.
2) Power and thrust for IC engines is inferred by a number of
operating parameters required in 33.7. EHPS applicants (many are
new to aviation) need detailed ratings requirements for their ICs.
EHPS.40 Ratings
412 Rolls-Royce and operating 8 There are two items (d) Correct numbering Yes No Accepted Corrected accordingly
limitations
A duration is requested here. Could there be another way defined

The duration must be established by the applicant and may differ
to
413 Volocopter EHPS.40(d) 9 Yes Noted from one application to the other.
limit the use in this phase (e.g. based on system specific
The limitation of use is also design dependant.
parameters)?
Excessive could be understood as greater than what is necessary
to comply with the declared or intended to be declared ICA.
However, this may link the results of the test to ICA and may
(1) and (2): Can EASA please provide an example, of what would be
414 Volocopter EHPS.410 22 Yes Accepted further complicate the certification process if updates of the ICA
understood to be “excessive” for further guidance?
are made in the future.
Compliance.
(c) ==> it should be interesting to specify that the EHPS must

meet the 3 conditions after each of the subpart D tests in order
not to leave any ambiguity (we will not do all the tests with
only one EHPS and demonstrate at the end that it is still in the EHPS.410(c) has been changed to cover the case of several EHPS
criteria) or EHPS sub-systems use to cover all the tests required under
(c) è Upon completion of the tests in Subpart D, the EHPS and Supbart D. Specific guidance will be provided as part of the Means
415 SAFRAN EHPS.410 21 Pass / fail criteria its components must […] be capable of operating at its No Yes Accepted of Compliance.
declared ratings while remaining within limits. From Safran
understanding, this criterion should not apply to all EHPS tests Pass/fail criteria for teardown inspection is now limited to
but mostly to test simulating EHPS actual in service usage (such EHPS.450 and consistent with CS-E approach.
as durability or ingestion tests). The endurance test (EHPS.420)
to be performed under all operational limits simultaneously is
more severe than actual EHPS usage in service.
EHPS 410- (a) Maintenance of the EHPS is permitted during the

General
tests in accordance with the service and maintenance instructions
Aviation Partially Specific guidance will be provided as part of the Means of
416 EHPS.410 21 submitted in the Instructions for Continued Airworthiness defined Add video requirement for some safety tests. Minor
Manufacturers accepted Compliance.
in paragraph EHPS.25- Is there any video required for any of the
Association
tests?
General
Aviation EHPS.410 - Suggest clarifying that the ICA may be in draft form Partially Specific guidance will be provided as part of the Means of
417 EHPS.410 21 Minor
Manufacturers when the tests are being run. accepted Compliance.
Association
Page 54 of 77
“EHPS.410 General Conduct of Tests

… Excessive could be understood as greater than what is necessary
(b) The EHPS or its parts must be subjected to any additional tests to comply with the declared or intended to be declared ICA.
and maintenance that the Agency finds necessary, if during the However, this may link the results of the test to ICA and may
The Boeing We ask EASA to clarify what is excessive? How do we quantify
418 EHPS.410 21 tests: no yes Accepted further complicate the certification process if updates of the ICA
Company it?
(1) the frequency of maintenance during the testing is excessive; are made in the future.
Need to have clarification of terms to avoid confusion and Compliance.
interpretations.
No because they provide the criteria for which the requirement

applies.
419 FAA DJ EHPS.410 (b) 21 Can’t all items (1) to (4)be MoC? Yes Noted
Specific guidance will be provided as part of the Means Of
Compliance.
This is a good question and the answer is not known up to day.

EASA believes the industry has the knowledge to be able to
If a gas turbine/piston engine is part of the EHPS, does that require
Cranfield propose a meaningful and safe mean of compliance.
its own endurance testing in accordance with CS-E/ CS-APU? Or is a If the former, it needs rewording to require endurance testing
420 Aerospace EHPS.420 21 Yes No Accepted That is why EASA is collaborating actively with SAE E-40 and
test of the whole system considered adequate to cover the of sub-systems.
Solutions Ltd EUROCAE WG113 which aim at providing a Mean of Compliance.
individual sub-systems?
Note that one intent is to facilitate the use of certified engine as
part of an EHPS when an applicant is willing to do so.
“EHPS.420 Endurance Demonstrations

…
(b) When approval is sought for a Normal Transient EHPS
Exceedance, it must be substantiated that the EHPS is capable of
“EHPS.420 Endurance Demonstrations it is important to differentiate both cases.
operation at the maximum EHPS transient condition of the affected
… Normal transients EHPS exceedances are considered part of the
EHPS parameter(s) without maintenance action.
(b) When approval is sought for a Normal Transient and / or EHPS design and are required to ensure the safety of the aircraft.
(c) When approval is sought for an Inadvertent Transient EHPS
inadvertent EHPS Exceedance, it must be substantiated that In this case, no maintenance action should be required.
Exceedance, it must be substantiated that the EHPS is capable of
the EHPS is capable of operation at the maximum EHPS For example, if on power request there is a need to exceed
operation at the maximum EHPS transient condition of the affected
The Boeing transient condition of the affected EHPS parameter(s) followed Not transitory a torque limitation on a turboshaft engine in order to
421 EHPS.420 21 EHPS parameter(s) without maintenance action other than to no yes
Company by ICAs provisions without maintenance action. accepted achieve a fast engine response and adequate aircraft
correct any failure that led to the exceedance.
(c) When approval is sought for an Inadvertent Transient EHPS controllability, then this should be considered as "Normal
Exceedance, it must be substantiated that the EHPS is capable transient EHPS exceedances and declared in the Instructions for
1) In EHPS.350 EHPS Control System, there is no exceedance
of operation at the maximum EHPS transient condition of the installation and operation of the EHPS.
allowed. It needs to be clear in which conditions, exceedance would
affected EHPS parameter(s) without maintenance action other Whereas Inadvertent transients EHPS exceedances are not the
be allowed.
than to correct any failure that led to the exceedance. results of the EHPS design and may require a maitenance action.
2) Unscheduled maintenance following maximum transient uses
should be considered, and it should be part of the ICA. Any
electrical system degradation is a process that is a function of
several variables; aging is only one of these.
I recommend this be better defined. Also, I read “limit capabilities” Add a sentence to the end of this paragraph (“The EHPS Time between overhaul is covered by EHPS.430.
Partially
422 FAA AS / PH EHPS.420 (a) 21 as speeds and temperatures; is it supposed to also cover time manufacturer should justify the specific time duration. . .” to Yes Specific guidance will be provided as part of the Means of
accepted
between overhauls? attempt to better define this test. Compliance.
This is a good question and the answer is not known up to day.

More clarity on endurance demonstration would be beneficial for
AMC to be created dedicated to electric motors, which defines propose a meaningful and safe mean of compliance.
Vertical EHPS.420 electric motors (e.g. 150-hour test). The link to CS-E and its AMC is
423 21 the minimum level of endurance testing to be completed for Yes Accepted That is why EASA is collaborating actively with SAE E-40 and
Aerospace (Endurance) more applicable to Hybrid systems. Will EASA create a new AMC
an electric motor. EUROCAE WG113 which aim at providing a Mean of Compliance.
specifically for electric Motors?
Airbus propose to update the wording of EHPS.420(a) as

follows (new proposed text shown in underlined italic font):
There is a need to more precisely identify that the Endurance test is
EHPS.420 EHPS.420 Endurance Demonstration
Airbus expected to test the robustness of the EHPS when it is operated at
424 Endurance 21 (a) Each EHPS must be subjected to an endurance Yes No Accepted Corrected accordingly
Helicopters its defined limits. This will help calrify the difference with the
Demonstration demonstration of safe operation under all defined operational
durability demonstration requirement.
limits of the EHPS. The demonstration shall be of sufficient
duration with respect to cycles and power settings.
Page 55 of 77

There is a need to more precisely identify that the Endurance test is
EHPS.420 EHPS.420 Endurance Demonstration
expected to test the robustness of the EHPS when it is operated at
425 AIRBUS Endurance 21 (a) Each EHPS must be subjected to an endurance N Y Accepted Corrected accordingly
its defined limits. This will help clarify the difference with the
Demonstration demonstration of safe operation under all defined operational
durability demonstration requirement.
limits of the EHPS. The demonstration shall be of sufficient
duration with respect to cycles and power settings.
For the rest of SC-EHPS, there is always considered “the EHPS”,

while No differentiated consideration. "Each" has been replaced by
426 Volocopter EHPS.420(a) 22 Yes Noted
in EHPS.420(a) “each EHPS” is chosen. "The" in all affected paragraphs.
Does this wording imply a differentiated consideration?
The endurance demonstration for the EHPS could be made on

a case by case basis using different EHPS sub-system
propose a meaningful and safe mean of compliance.
endurance strategy (test, analysis …) and should be part of the
That is why EASA is collaborating actively with SAE E-40 and
427 SAFRAN EHPS.420/430 21 Endurance demonstration of the EHPS / EHPS sub-system discussion for the MoC. This comment is also applicable to Yes No Accepted
EUROCAE WG113 which aim at providing a Mean of Compliance.
EHPS.430. Endurance demonstration should be standardized to
have a common approach and philosophy for this
demonstration.
This sounds like an IMI test to me, but it could be good to separate
428 FAA AS EHPS.430 22 Yes Noted
TBO from off-schedule testing (EHPS 420 above)

EHPS.430
FARADAY propose a meaningful and safe mean of compliance.
429 Durability 22 Can EASA specify what is the "durability expectation" Yes No Noted
aerospace That is why EASA is collaborating actively with SAE E-40 and
Demonstration
EUROCAE WG113 which aim at providing a Mean of Compliance.

propose a meaningful and safe mean of compliance.
EHPS.430
FARADAY Can EASA confirm that simulation can be the only mean of That is why EASA is collaborating actively with SAE E-40 and
430 Durability 22 Yes No Noted
aerospace compliance for durability demonstration EUROCAE WG113 which aim at providing a Mean of Compliance.
Demonstration
At this stage, EASA does not foresee the simulation has being a
sufficient mean of compliance.

Same comment for the EHPS.420, the calibration propose a meaningful and safe mean of compliance.
demonstration for the EHPS could be made on a case by case That is why EASA is collaborating actively with SAE E-40 and
431 SAFRAN EHPS.440 22 Calibration Assurance for the EHPS / EHPS sub-system Yes No Accepted
basis using different EHPS sub-system calibration strategy (test, EUROCAE WG113 which aim at providing a Mean of Compliance.
analysis …) and should be part of the discussion for the MoC. Note that one intent is to facilitate the use of certified engine as
A disassembly is useful for mechanically stressed components, e.g.

engine, but not applicable to electric systems, e.g. a battery. These
This paragraph has been reworded.
Lange Aviation should instead be subjected to electrical testing, if applicable. Many Differentiate according to degradation behaviour of
432 EHPS.450 22 Yes Accepted Specific guidance will be provided as part of the Means of
GmbH electrical components also do not exhibit degradation, for those components.
Compliance.
testing by just testing the function of the system would be
effectual.
Page 56 of 77
As proposed in EHPS.410 (c), teardown inspection proposed in

EHPS.450 shall be applicable for the endurance test. It is more
stringent than the CS-E philosophy where the pass/fail criteria
does not impose to have the engine part in a serviceable limits
for as defined in the ICA. This may imply to have ICA available
at the end of the endurance test where limit of the EHPS will
be tested, additionally, the endurance does not reflect real
condition of the EHPS but correspond to an EHPS limit capacity
demonstration where part may be more degraded than in
service. However, EHPS applicant may defined how the
This paragraph has been reworded. Consistency with CS-E is made.
degradation is detected and mitigated during the EHPS in-
433 SAFRAN EHPS.450 22 Pass/fail criteria No Yes Accepted Specific guidance will be provided as part of the Means of
service life.
Compliance.
Proposed text : “After the endurance and durability test have
been completed, the EHPS must be completely disassembled.
Each EHPS component must be within service limits and
eligible for continued operation in accordance with
information submitted with the instructions for continued
airworthiness provided in EHPS.25. When for endurance test,
parts are beyond serviceable limits as defined in the ICA, it
has to be demonstrated that the failure or degradation will
be detected and accommodated during the in-service life of
the EHPS”
Relative to « … EHPS must be completely disassembled. » This paragraph has been reworded. Consistency with CS-E is made.
434 FAA DJ EHPS.450 (a) 22 This should be restated? This could be defined in the MOC. Yes Accepted Specific guidance will be provided as part of the Means of
Completely disassembled for an electric motor may not be clear. Compliance.

EHPS.450 Teardown Inspection EHPS.410(c) has been changed to cover the case of several EHPS
The first sentence of EHPS.450(a) might be understood as implying (a) For both the endurance and durability demonstrations test or EHPS sub-systems use to cover all the tests required under
EHPS.450
Airbus that the same EHPS is used for both the endurance and durability have been completed, the EHPS must be completely Supbart D. Specific guidance will be provided as part of the Means
435 Teardown 22 Yes No Accepted
Helicopters tests. Airbus consider this is not the intent and therefore propose disassembled after each test has been completed. Each EHPS of Compliance.
Inspection
anupdate of the wording component must be within service limits and eligible for EHPS.450(a) has been reworded and is consistent with CS-E
continued operation in accordance with information submitted approach.
with the instructions for continued airworthiness provided in
EHPS.25.

EHPS.450 Teardown Inspection EHPS.410(c) has been changed to cover the case of several EHPS
The first sentence of EHPS.450(a) might be understood as implying (a) For both the endurance and durability demonstrations test or EHPS sub-systems use to cover all the tests required under
EHPS.450
that the same EHPS is used for both the endurance and durability have been completed, the EHPS must be completely Supbart D. Specific guidance will be provided as part of the Means
436 AIRBUS Teardown 22 Accepted
tests. Airbus consider this is not the intent and therefore propose disassembled after each test has been completed. Each EHPS of Compliance.
Inspection
an update of the wording component must be within service limits and eligible for EHPS.450(a) has been reworded and is consistent with CS-E
continued operation in accordance with information submitted approach.
with the instructions for continued airworthiness provided in
EHPS.25.
EHPS.460 should also cover specific functioning modes / Specific guidance will be provided as part of the Means of
437 SAFRAN EHPS.460 26 AMC architecture of the EHPS, especially for electrical systems. This yes no Accepted Compliance.
could be addressed within corresponding AMC. Note that EHPS Specific Operation is now placed in EHPS.480.
The proposal to have a possibility not to demonstrate the
starting/restarting capability of the EHPS is not understood
“…unless it is shown that there is no safety benefits…”.
Corrected accordingly.
438 SAFRAN EHPS.460 26 Starting and restarting strategy Question may be if the function is required by the aircraft yes no Accepted
manufacturer (necessary procedure for aircraft operation).
Proposal could be “…unless not required by the aircraft
manufacturer for aircraft operation as declared in the IOM…”
Page 57 of 77
Proposed MOC for EHPS.460 (e)(2) states that AMC should at

least cover specific functions. CS-E 920 is quoted in the
proposed MOC whereas, from Safran understanding, CS-E 920
439 SAFRAN EHPS.460 26 (e) (2) MOC does not allow to validate a specific function or a particular yes no Accepted EHPS.480(c) has been added accordingly.
usage but rather a “design”margin regarding OEI 30s power
rating. A dedicated EHPS chapter could be created to address
this requirement?
440 FAA DJ EHPS.460 (e) 24 Relative to reference to propeller (two times) Add “or rotor” Yes Accepted Added accordingly.
… “(e) EHPS specific operation

If the EHPS is designed to operate with a propeller, all Consistency with CS-E wording is maintained.
EHPS.460 (1) If the EHPS is designed to operate with a propeller, all applicable
applicable EHPS demonstrations required by this special Partially Specific guidance will be provided as part of the Means of
441 Rolls-Royce Operational 24 EHPS demonstrations required by this special condition must be Yes No
condition must be performed with a representative propeller accepted Compliance.
Demonstration performed with a representative propeller.”
and governor (if applicable). Note that EHPS Specific Operation is now placed in EHPS.480.
- Add ‘and representative propeller governor’.
Werner Scholz, Same approach as CS-E. Refer to AMC E 710.

EHPS.460
European What is the meaning of (d) Rotor Locking Demonstration – is this Specific guidance will be provided as part of the Means of
442 Operational 23 / 24 Clarify suggestion Noted
Sailplane valid for rotors (like for helicopter) or any turning parts? Compliance.
Demonstration
Manufacturers Note that EHPS Specific Operation is now placed in EHPS.480.
Airbus propose to update the wording of EHPS 460(a)

Operational Demonstration -as follows (new proposed text
shown in underlined italic font):
The scope of the expected operational demonstration should be EHPS.460 Operational Demonstration
clearly defined. It does not appear appropriate to use the bracket
EHPS.460 with the wording etc.in sub-paragraph (a). Also, the list of (a) The operational demonstration must include tests,
Brackets have been removed and will be part of the specific
443 AIRBUS Operational 23 operations provided in sub-paragraph (a) and the overall paragraph validated analysis, or a combination thereof to demonstrate N Y Accepted
guidance to be provided as part of the Means of Compliance.
Demonstration should be consistent meaning that additional conditions to be the performance of the EHPS (starting, power response cycling,
demonstrated have to be added to the paragraph or the list in the acceleration, overspeeding, rotor locking and any specific
bracket has to be reduced. operations etc.) throughout its declared flight envelope and
operating range.
The declared EHPS operational characteristics must account for
installation loads and effects.
Airbus propose to update the wording of EHPS 460(b) as

For the starting/restarting requirement, Airbus propose some
(b) Starting and restarting/relighting
clarification of the wording for ground start as it is considered that
(1) The applicant must demonstrate the capability of the EHPS (1) has been reworded accordingly.
EHPS.460 the term ‘safely’ is not appropriate. Requiring a ‘reliable’ start
to safely reliably start under all declared ground atmospheric Partially (2) has been reworded and replaced by "unless not required for
444 AIRBUS Operational 23 performance appears more appropriate. For the restart/relight N Y
temperature conditions. accepted aircraft operation". Specific guidance will be provided in the
Demonstration requirement, Airbus do not understand the purpose of the ‘no
(2) The EHPS design must allow the shutdown and restart or Means of Compliance.
safety benefit provision’. It is not clear how a restart capability
the relight of the EHPS, or the affected sub-system of the EHPS,
cannot increase safety margin and therefore be beneficial.
in flight within an established envelope, unless it is shown that
there is no safety benefit of providing this functionality.

(d) Rotor Locking Demonstration
If shaft rotation is prevented by a means to lock the rotor(s),
the EHPS must be subjected to tests, validated analysis, or a
combination thereof that includes repeated locking and This is implied by the beginning "if shat rotation is prevented by a
unlocking operations to sufficiently establish reliable rotor means to lock the rotor(s)". As for AMC E 710, specific guidance
Rotor lock demonstration is not required if there is no safety Partially
445 Embraer S.A. EHPS.460(d) 23 locking performance. yes no will be provided to explain when this rotor locking function can be
benefit of an EHPS (or affected sub-system) restart. accepted
To: provided.
(d) Rotor Locking Demonstration Note that Rotor Locking Demonstration is now placed in EHPS.470.
If shaft rotation is prevented by a means to lock the rotor(s),
the EHPS must be subjected to tests, validated analysis, or a
combination thereof that includes repeated locking and
unlocking operations to sufficiently establish reliable rotor
Page 58 of 77
locking performance, unless it is shown that there is no safety

benefit of providing this functionality.
I don’t see a SC that captures the requirements for propeller Propellers are outside the scope of the SC E-19.
446 FAA JP EHPS.490 24 controls within the EHPS or inclusion of a thrust producing fan in Yes Noted Fans are covered by the SC E-19 as stated in the EHPS definition
the EHPS (ref F3338 paragraphs 5.24 and 5.25). provided in EHPS.15.
“AMC of § EHPS.490 should also cover the CS-E 170 (and

corresponding AMC) plus the specific effects related to EHPS
Scecific guidance will be provided as part of the Means of
447 SAFRAN EHPS.490 AMC architecture, especially for electrical systems (such as, but not yes no Accepted
Compliance.
limited to magnetic interference, lightening) that could affect
the whole EHPS (not limited to equipement).”
We suggest to include a new item:
"When required by EHPS.350 and information security risks
that are identified during the information security risk
The information security applied to aviation is a new topic for some assessment need to be mitigated, security verification should
applicants and dedicated security tests may be required. be used to evaluate the efficiency of the mitigation means:
Partially Specific guidance will be provided as part of the Means of
448 Embraer S.A. EHPS.490 24 NPA-2019-01 text can be used to provide this information. (i) This verification may be performed by a combination of yes no
accepted Compliance to EHPS.350 (h) and EHPS.490.
If EHPS.350 is applicable, dedicated security tests will reduce the analysis, security-oriented robustness testing, inspections, and
possibility of vulnerabilities due to implementation errors. reviews; and
(ii) When necessary, by security testing that addresses
information security from the perspective of a potential
adversary.”.
Add "a"
Add "
(b) Temperature limits must be established for each component
that requires temperature-controlling provisions in the aircraft
installation to assure satisfactory functioning, reliability, and Partially This is already covered by EHPS.30.
449 TCCA EHPS.490 24 Suggest to revise and add text, if needed
durability. accepted Specific guidance will be provided.
(c) Voltage and current limits must be established for each
component that requires voltage or current controlling provisions,
or both, in the aircraft installation to assure satisfactory
functioning, reliability, and durability."
“ Among these additional tests, the environmental tests: which

To compensate environmental limits of EHPS equipment that
must demonstrate that the EHPS can operate in HIRF or in Partially Same approach as in CS-E.
450 TCCA EHPS.490 24 cannot be demonstrated in accordance with endurance tests EHPS
atmospheric electricity (Lightning, ESD) environment , without accepted Specific guidance to be provided in the Means of Compliance.
490 recommend system and components additional test..
endangering aircraft flight..
Requiring tests under all declared environmental and operating

Werner Scholz, EHPS.490
conditions could become rather arduous – it should be possible to The following intended aircraft applications have been removed
European System, Add regarding guidance and/or introduce some tiering (i.e. Partially
451 24 propose test conditions at then do in addition some single test suggestion from the scope: CS-22, CS-LSA, CS-23 level 1 day VFR and Light
Sailplane equipment and simplified requirements for simpler aircraft). accepted
points in the more extreme conditions and/or to substantiate also UAS.
Manufacturers component tests
by service experience with similar devices.
EHPS.490
The intent of this paragraph is unclear. It seems not applicable. Any
System, Not For example, controllers might be qualified according to DO 160 in
452 VOLTAERO 24 system, equipment or component would be substantiated by test We recommend to delete the paragraph EHPS.490. YES NO
equipment and accepted order to fulfill this requirement.
or analysis.
component tests
Airbus propose to delete section EHPS.490 and to update the

wording of the introduction to Subpart D as follows (new
Airbus understand the purpose of this paragraph is to identify that
EHPS.490 Compliance with the requirements for Endurance (including The Airbus understanding is correct.
other tests (in particular qualification tests) may have to be
System, periods of EHPS Limits exceedance), Durability, Vibration, Over Partially Consistency with CS-E wording is maintained.
453 AIRBUS 24 performed in addition to the complete EHPS tests defined in the N Y
equipment and Torque, Temperature limit demonstration, Operation (including accepted Specific guidance will be provided as part of the Means of
subpart D. Airbus suggest that this is indicated in the introduction
component tests Power Response, Rotor Locking, Operation with a variable Compliance.
to the subpart but not as a specific requirement
pitch thruster, and Operation with a fixed pitch thruster) must
be substantiated via test performed on a complete EHPS
representative of the intended Type Design, validated analysis,
Page 59 of 77
or a combination thereof. The following provisions in this

section provide the objective for these tests. Additional partial
system tests, component qualification tests may have also to
be performed in order to address requirements in other
subparts of the SC as well as demonstrating that systems and
components are able to perform their intended function in all
environmental and operating conditions of the intended
aircraft installation
Especially for the battery system the use of a large number of semi-
finished products/COTS, i.e. battery cells, can be expected. How are
Lange Aviation these considered in terms of specification and variation in Provide guidance material on semi-finished products/COTS and
454 EHPS.50 9 Yes Accepted Specific guidance will be provided in the Means of Compliance
GmbH properties? Also, the manufacturer might not be willing to provide applicable regulations
detailed insight into manufacturing methods and processes. How
can the use of such products be facilitated?
Part (a) "The design values of properties of materials must be
suitably related to the minimum properties stated in the material
455 Rolls-Royce EHPS.50 9 specification and meet or exceed the properties assumed in the Re-write to clarify meaning No Yes Accepted Reworded
design data, over the life time of the EHPS.".......... is not worded
clearly such that the intent of the requirement is unclear.
"minimum properties stated in the material specification and meet

Zeroavia or exceed the properties assumed in the design data" is clumsy Partially
456 EHPS.50 Replaced by "relevant properties".
James Lawson wording. Instead of "properties" suggest "performance" because accepted
some properties such as color do not have a minimum.
Not Consistency with CS-E is maintained. The service conditions are

457 TCCA EHPS.50 9 Add "...service conditions declared in the installation manual." Suggest to revise and add text, if needed
accepted not provided in the installation manuals.
The specification of corrosion may limit the considerations of an Propose more general statement such as: "[...] assumed service
458 TCCA EHPS.50 9 Accepted Corrected accordingly.
applicant. conditions over the life of the product."
Insulation bearkdown has been added but the examples that are
EHPS.50 For hybrid systems there are better examples of deterioration over
459 Rolls-Royce 9 Consider including better examples for hybrid systems. Yes No Accepted provided does not constitue an exhaustive list.
Materials time than corrosion e.g. insulation break-down
Given the definition in EHPS.15, is the management system of the

energy storage device to be excluded from the safety analysis of
460 Volocopter EHPS.80 10 Yes Noted Exclusion has been removed
the
EHPS?
It should be made clear that functional safety of a product has to be
assessed and that standards and procedures according to the
current state of the art at this moment have to be applied. Any
ambiguity between this SC and other law (i.e. COUNCIL DIRECTIVE
85/374/EEC & ISO 26262) must be avoided. For the manufacturer
The AMC should point out other applicable legislation, provide
any such ambiguities,loopholes, or contradictions between EASA
guidance on the current state of the art regarding safety
Lange Aviation regulations and other legislation puts him in a precarious legal
461 EHPS.80 9 assessments and acceptable regulations, and be regularly Yes Accepted Specific guidance will be provided in the Means of Compliance
GmbH position and will compromise safety.
updated. Any ambiguities, loopholes, or differences with
Furthermore, the complexity of even “simple” EHPS or subsystems
respect to other legislation must be avoided.
absolutely necessitates a structured safety assessment and
development approach (ED-79, DO-178,...). For example, a
professional battery management system can feature tens of
thousand of lines of software code. The safety of such a system can
only be materialised by employing such development procedures.
Page 60 of 77
(iii) Multiple Failures that result in the Hazardous EHPS Effects, This is why safety objectives have to be derived from the intended
Hazardous Aircraft Effects or Catastrophic Aircraft Effects defined in Clarify why aircraft level safety is referred to which would be aircraft application. The aircraft manufacturer will provide these
462 Rolls-Royce EHPS.80 9 Yes No Noted
EHPS 15. - why are the last two categories included as they relate to covered by aircraft certification data as it is already done today between aircraft manufacturers
the aircraft and engine manufacturers. EHPS manufacturers do need to take
EHPS.80(a)(1)(i) has been reworded accordingly to clarify this.
463 Rolls-Royce EHPS.80 9 Paragraph (b) is missing Renumber further paragraphs or state "not used" Yes No Accepted Corrected
EHPS provides EHPS Failures Conditions identified as potential
contributor to a hazardous aircraft effect according to the
EHPS-030.
Partially aircraft application. The aircraft manufacturer will provide these
464 SAFRAN EHPS.80 9 (2) Aircraft safety analysis, not EHPS responsibility Propose to maintain only major EHPS effects & hazardous EHPS Yes Yes
accepted data as it is already done today between aircraft manufacturers
effects or add “…for Hazardous Aircraft Effects or Catastrophic
Aircraft Effects in accordance with safety objectives defined in
the EHPS.30…”
EHPS applicant could not conform directly to aircraft type
certification basis.
Proposed text:
(3) proposal : "It must be shown by the EHPS applicant that
(3) Safety objective related to type certification basis of the Partially aircraft application. The aircraft manufacturer will provide these
465 SAFRAN EHPS.80 9 EHPS design and construction is compliant to the aircraft Yes Yes
intended aircraft accepted data as it is already done today between aircraft manufacturers
specification flown dow by the aircraft applicant to allows the
intended aircraft application to meet the qualitative and
quantitative safety objectives defined in the type-certification
basis of the intended aircraft application."
Aircraft applicant needs to define to EHPS applicant all necessary aircraft application. The aircraft manufacturer will provide these
466 SAFRAN EHPS.80 9 CS-E 30 should be adapted in SC-EHPS Yes Yes Accepted
assumptions (e.g. : quantitative & qualitative safety objectives) data as it is already done today between aircraft manufacturers
467 SAFRAN EHPS.80 9 No (b) Reallocate paragraph Yes No Accepted Corrected
Page 61 of 77
Not and engine manufacturers. EHPS manufacturers do need to take
468 SAFRAN EHPS.80 10 (D).(1).(ii) : Aircraft safety analysis, not EHPS responsibility To propose to remove § Yes Yes
accepted into account safety objectives that are provided by the aircraft
Paragraph has been modified to clarify the roles and
responsibilities of the aircraft manufacturer and the EHPS
manufacturer. Specific guidance will be provided in the Means Of
Compliance.
Partially
469 SAFRAN EHPS.80 10 (5) Filght crew action To move in EHPS.30 Yes Yes Crew action replaced by Operating instructions.
accepted
AMC of § EHPS.80 should include a reference to AMC 510 (h)
470 SAFRAN EHPS.80 10 (d)(2) - AMC Maintenance errors / human factors and also address maintenance errors especially related to Yes No Accepted Guidance will be provided accordingly
electrical systems and wiring
General EHPS80-(c)- If the Primary Failure of certain single elements that If the Primary Failure of certain single elements that are likely
Aviation are likely to result in Hazardous EHPS Effects cannot be sensibly to result in Hazardous or catastrophic EHPS Effects cannot be Major/concep Not This § is related to the definition of critical part defined in
471 EHPS.80 9
Manufacturers estimated in numerical terms, reliance must be placed on meeting sensibly estimated in numerical terms, reliance must be placed tual accepted EHPS.15.
Association the... on meeting the…
DAL association is a process. It does not define the safety

General (ii) the occurrence of Hazardous and Catastrophic Aircraft objectives.
Aviation Effects at rates in excess of the rates defined in the The extremely improbable is only related to Catastrophic Aircraft
472 EHPS.80 10 EHPS 80- (ii) - Why is DAL extremely improbable is not stated? Question Noted
Manufacturers associated Type-Certification basis of the intended aircraft effect. For Hazardous Aircraft effect, an extremely remote failure
Association application(s) must be extremely improbable rate is more appropriate. Otherwise, the safety requirements
would be too demanding.
General
Aviation
473 EHPS.80 10 EHPS 80- (2) Is appropriate manuals unclude A/RFMS? Add A/RFMS to the relevant manuals. Minor Accepted Added
Manufacturers
Association
General
EHPS 80-(5) Flight crew actions. These actions must be identified in
Aviation
474 EHPS.80 10 the operating instructions manual and appropriately substantiated Should A/RFMS be called out as well? Question Accepted Added
Manufacturers
at aircraft level if the intended aircraft application is known
Association
"extremely remote" is associated with a probability not a rate.

475 Zeroavia EHPS.80 Instead of "rate in excess of" and "rates in excess of" suggest Accepted Corrected
James Lawson "probability in excess of" and "probabilities in excess of."
It is understood that the comment is relative to EHPS.90 and not
Instead of "service management plan" should it be "in-service Not EHPS.80.
476 EHPS.80
Zeroavia management plan." accepted Wording is not change so as to keep consistency with existing
James Lawson rules.
The Boeing
477 EHPS.80 9 Please correct or add missing paragraph Missing bullet (b) Yes No Accepted Corrected
Company
(d) If the acceptability of the safety analysis is dependent on one or
(i) necessary for preventing the occurrence of Hazardous EHPS
more of the following items,
The Boeing Effects at a rate in excess of Extremely Remote (probability less Extremely remote probability is now linked with its definition for
478 EHPS.80 10 they must be identified in the analysis and appropriately no yes Accepted
Company than 10-? per flight hour); the intended aircraft application.
substantiated:
(ii) the occurrence of Hazardous and Catastrophic Aircraft
(1) Maintenance actions being carried out at stated intervals. The
Page 62 of 77
maintenance intervals must be published in the Airworthiness Effects at rates in excess of the rates defined in the associated
Limitations section of the Instructions for Continued Type-Certification basis of the intended aircraft application(s)
Airworthiness (refer to EHPS.25) when:
Effects at a rate in excess of Extremely Remote; or
(ii) the occurrence of Hazardous and Catastrophic Aircraft Effects at
rates in excess of the rates defined in the associated Type-
Certification basis of the intended aircraft application(s)
1) The safety targets need to be clear to define an approach.

2) Refer to CS-E510 which defines (3): It must be shown that
Hazardous Engine Effects are predicted to occur at a rate not in
excess of that defined as Extremely Remote (probability less than
10-7 per Engine flight hour). The estimated probability for
individual Failures may be insufficiently precise to enable the total
rate for Hazardous Engine Effects to be assessed. For Engine
certification, it is acceptable to consider that the intent of this
paragraph is achieved if the probability of a Hazardous Engine
Effect arising from an individual Failure can be predicted to be not
greater than 10-8 per Engine flight hour (see also CS-E 510 (c)). In
case that the safety target has not been defined it should be
deleted as recommended.
479 Jonas Büttner EHPS.80 9 (b) is missing so far. Yes Accepted Corrected
“(iii) Multiple Failures that result in the Hazardous EHPS Effects, the propulsion system takes part in the flight control function).
Hazardous Aircraft Effects or Catastrophic Aircraft Effects defined in This is why safety objectives have to be derived from the intended
EHPS 15.” aircraft application. The aircraft manufacturer will provide these
480 Airbus DS EHPS.80 9 Yes No Noted
Novelty with respect to CS-E. Here catastrophic A/C effects are also data as it is already done today between aircraft manufacturers
considered. This will imply having at least a preliminary A/C FHA. and engine manufacturers. EHPS manufacturers do need to take
EHPS certification potentially linked to an A/C design. into account safety objectives that are provided by the aircraft
In (a)(1)(i) delete period to read “ ...analysis, ”

481 TCCA EHPS.80 9 Suggest to revise text, if needed Accepted Corrected accordingly.
In (a)(1)(iii) missing a dot; should read "EHPS.15"
Page 63 of 77
Suggest this section define applicability of the safety
The Safety Assessment seems to be requested at the aircraft level Partially aircraft application. The aircraft manufacturer will provide these
482 TCCA EHPS.80 9 assessment only at the Integrated Hybrid Propulsion System
rather than at the propulsion unit itself. accepted data as it is already done today between aircraft manufacturers
level.
In appropriate sections of EHPS it is suggested to define

The list of the systems essential for the continuation of the flight
essential systems for flight continuation that needs to sustain a
Load sheding and definition+analysis of loads essential for the has to be established at aircraft level. This is part of the safety
defined level of electrical power. Not
483 TCCA EHPS.80 9 continuation of flight should be a capability of the an Integrated assessment that has to be made under EHPS.80.
In case of an OEI, remaining Internal combustion engine(s) on accepted
Hybrid Propulsion System. The OEI case mentioned is a specific case related to a specific
the aircraft or Aircraft Energy Storage System should be able to
architecture. This could be part of Means Of Compliance.
sustain the above defined power.
Editorial: Reason for "Failure Conditions" with capitalisations? only

capitalize terms found in EHPS.15 or other titles.
484 TCCA EHPS.80 9 Editorial: "[...] in the analysis. , and detailed [...]" to "[...] in the Minor edits. Accepted Corrected accordingly
analysis and detailed [...]"
Editorial: "EHPS 15" is EHPS.15
EHPS.80(a)(iii) removes the need to consider safety-system failures

that are relied upon in the analysis, as stated in CS-E 510 (a) (iii) and
the reference to CS-E 510 (d), which was removed in this document
(copied below). These considerations would likely still apply to
EHPS, therefore should be retained.
SC removed: CS-E 510 (d) “If reliance is placed on a safety system to
prevent a Failure progressing to cause Hazardous Engine Effects,
Review paragraphs for applicability and include performance Partially aircraft application. The aircraft manufacturer will provide these
485 TCCA EHPS.80 9 the possibility of a safety system Failure in combination with a basic
based wording to EHPS.80. accepted data as it is already done today between aircraft manufacturers
Engine Failure must be included in the analysis. Such a safety
system may include safety devices, instrumentation, early warning
devices, maintenance checks, and other similar equipment or
procedures. If items of a safety system are outside the control of
the applicant, the assumptions of the safety analysis with respect to
the reliability of these parts must be clearly stated in the analysis
and identified in accordance with CS-E 30
The addition of : "(d)(2) If errors in maintenance of the EHPS,

including the EHPS Control System, could lead to Hazardous EHPS
Effects, Hazardous or Catastrophic Aircraft Effects, appropriate
procedures must be included in the relevant EHPS manuals."
Considering that HAZ EHPS Effects are defined in EHPS.15 as the The text does not refer to Hazardous Failure Conditions. No
486 TCCA EHPS.80 9 Please review and provide clarification. Noted
effects of EHPS failure conditions that lead to either HAZ or CAT contradiction has been identified.
Aircraft Effects, the text may redundant, otherwise it indicates that
EHPS maintenance errors that do not result in HAZ EHPS effects, yet
still lead to HAZ or CAT Aircraft level effects need to be considered.
Please clarify intent
Page 64 of 77
We suggest to change the text from::

(a) (1) An analysis of the EHPS, including the control system,
must be carried out in order to assess all Failure Conditions
that can reasonably be expected to occur. This analysis must
take account of:
(i) Aircraft-level devices and procedures assumed to be
associated with a typical installation or the intended aircraft
application. Such assumptions must be stated in the analysis. ,
and detailed in the Installation Instructions of EHPS.30.
(ii) Consequential secondary Failures and dormant Failures.
(iii) Multiple Failures that result in the Hazardous EHPS Effects,
Hazardous Aircraft Effects or Catastrophic Aircraft Effects
defined in EHPS 15.
(2) A summary must be made of those Failures Conditions that
could result in Major Aircraft Effects, Hazardous EHPS Effects,
Hazardous Aircraft Effects or Catastrophic Aircraft Effects EHPS are different from a single motor as they most of the time
together with an estimate of the probability of occurrence of include several motors. As such, failures modes cannot be only
those effects. Any EHPS critical part must be clearly identified assessed anymore at motor level but at aircraft level (e.g. when
The EHPS manufacturer should not be responsible to define what in this summary. the propulsion system takes part in the flight control function).
are the Major, Hazardous or Catastrophic Aircraft Effects. This (3) It must be shown that the design and construction of the This is why safety objectives have to be derived from the intended
categorization will be very dependent of the aircraft propulsion EHPS allows the intended aircraft application to meet the Partially aircraft application. The aircraft manufacturer will provide these
487 Embraer S.A. EHPS.80 (a) 9 yes no
architecture and this analysis should be made by the aircraft qualitative and quantitative safety objectives defined in the accepted data as it is already done today between aircraft manufacturers
manufacturer. Recommended to delete any reference to aircraft type-certification basis of the intended aircraft application. and engine manufacturers. EHPS manufacturers do need to take
level effects. To: into account safety objectives that are provided by the aircraft
(a) (1) An analysis of the EHPS, including the control system, manufacturers in order for them to be able to perform the
must be carried out in order to assess all Failure Conditions that complete aircraft safety analysis.
can reasonably be expected to occur. This analysis must take EHPS.80(a)(1)(i) has been reworded accordingly to clarify this.
account of:
application. Such assumptions must be stated in the analysis,
(iii) Multiple Failures that result in the Hazardous EHPS Effects
defined in EHPS.15.
(2) A summary must be made of those Failures Conditions that
could result in Hazardous EHPS Effects together with an
estimate of the probability of occurrence of those effects. Any
EHPS critical part must be clearly identified in this summary.
(3) It must be shown that the design and construction of the
EHPS meets the qualitative and quantitative safety objectives
for the Hazardous EHPS Effects.
This is not considered as guidance as these paragraphs ensures

that the safety analysis is performed up tot the aircraft level, thus
EHPS.80 (a)(1)(i)
488 FAA DJ 9 This section including (i) thru (iii) seems very prescriptive yes Noted ensuring consitency between EHPS and aircraft safety objectives.
to (iii)
Guidance will be provided to describe what are the data to be
provided in details.

EHPS.80 (a)(1)(i) Not
489 FAA GH 9 In the world of PBRs this sounds a bit like MoC Consider moving this to the AMC yes ensuring consitency between EHPS and aircraft safety objectives.
to (iii) accepted
Added: means a Failure of a part which is the result of the prior

490 FAA DK EHPS.80 (a)(1)(ii) 9 Define consequential secondary failures Add to Terminology yes Accepted
Failure of another part or system.
Page 65 of 77
Is the distinction between Hazardous EHPS Effect and Hazardous Hazardours EHPS effects are defined in order to introduce EHPS
491 FAA JG EHPS.80 (a)(1)(iii) 9 Yes Noted
Aircraft Effect necessary? critical parts while ensuring consistency with CS-E
492 FAA DK EHPS.80 (a)(1)(iii) 9 Add Major to Hazardous or Catastrophic aircraft effects. Yes Accepted Modified accordingly
If there is an expectation to meet various levels of airplane level
probabilities, what are the standards to support them? In part 33,
the existing standards are the foundation for compliance with
required probabilities, see rule below. This draft is emulating part
33. As such, it only supports the hazardous EHPS effects.
Yes, the intent is to define the acceptable probabilities of the EHPS
493 FAA DM EHPS.80 (a)(2) 9 §33.75(c): “The primary failure of certain single elements cannot be Yes Noted
failures according to the intended aircraft application.
sensibly estimated in numerical terms. If the failure of such
elements is likely to result in hazardous engine effects, then
compliance may be shown by reliance on the prescribed integrity
requirements of §§ 33.15, 33.27, and 33.70 as applicable. These
instances must be stated in the safety analysis.”
The references to Aircraft Level effects over reaches the traditional This is why safety objectives have to be derived from the intended
boundaries. aircraft application. The aircraft manufacturer will provide these
494 FAA GH / WM EHPS.80 (a)(2) 9 Yes yes Noted
Again, this doesn’t make sense. An EHPS manufacturer can’t predict data as it is already done today between aircraft manufacturers
every future aircraft and installation using their product. and engine manufacturers. EHPS manufacturers do need to take
495 FAA JG EHPS.80 (a)(2) 9 Similar comment as above (see 26) yes yes Noted
Isn’t this really just the general objective of obtaining a TC? I don’t
496 FAA JG EHPS.80 (a)(3) 9 see a requirement here that an applicant could reasonably show Yes Noted
compliance with.
Page 66 of 77
Shouldn’t EHPS.50 Materials and EHPS.240 Overspeed and Rotor

497 FAA JG EHPS.80 (c) 9 Yes Accepted These paragraphs are included.
Integrity also be included?
Yes for a full electric propulsion system for which it has been
demonstrated that no single failure can lead to a Hazardous EHPS
effect (Full containment of high energy debris has been
demonstrated...).
However, for a VTOL aircraft, there could be cases where EHPS
critical parts would be still required in order to provide a certain
If an EHPS is to be certified together with an aircraft in accordance
level of safety and quality on the final product.
to
Let's consider for example an hybrid propulsion with a turbine
498 Volocopter EHPS.80 (c) 10 SC-VTOL, there is no use of critical parts foreseen. Therefore, Yes Noted
engine. High energy debris release may not be avoided in turbine.
EHPS.80(c) would become “n/a”.
So critical parts may be required.
Does EASA agree with this understanding?
However, the turbine may be located so as to ensure that no
single failure will lead to a CAT event.
This approach, combined with the SC VTOL allows defining an
hybrid propulsion system that is compatible with the safety
objectives of SC VTOL while ensuring a low probability of release
of high energy debris.
499 FAA GH EHPS.80 (d) 10 This not very Performance Based Could this be moved to AMC? Yes Noted ensuring consitency between EHPS and aircraft safety objectives.
We suggest to change the text from::
(d) If the acceptability of the safety analysis is dependent on
one or more of the following items, they must be identified in
the analysis and appropriately substantiated:
(1) Maintenance actions being carried out at stated intervals.
The maintenance intervals must be published in the
Airworthiness Limitations section of the Instructions for
Continued Airworthiness (refer to EHPS.25) when:
(ii) the occurrence of Hazardous and Catastrophic Aircraft
Effects at rates in excess of the rates defined in the associated
Type-Certification basis of the intended aircraft application(s)
(2) If errors in maintenance of the EHPS, including the EHPS
Control System, could lead to Hazardous EHPS Effects,
Hazardous or Catastrophic Aircraft Effects, appropriate
The EHPS manufacturer should not be responsible to define what the propulsion system takes part in the flight control function).
procedures must be included in the relevant EHPS manuals.
are the Major, Hazardous or Catastrophic Aircraft Effects. This This is why safety objectives have to be derived from the intended
(3) Verification of the satisfactory functioning of safety or other
categorization will be very dependent of the aircraft propulsion Not aircraft application. The aircraft manufacturer will provide these
500 Embraer S.A. EHPS.80 (d) 10 devices at pre-flight or other stated periods. The details of this yes no
architecture and this analysis should be made by the aircraft accepted data as it is already done today between aircraft manufacturers
verification must be published in the appropriate manual.
manufacturer. Recommended to delete any reference to aircraft and engine manufacturers. EHPS manufacturers do need to take
(4) The provision of specific instrumentation not otherwise
level effects. into account safety objectives that are provided by the aircraft
required.
(5) Flight crew actions. These actions must be identified in the
operating instructions manual and appropriately substantiated
at aircraft level if the intended aircraft application is known.
To:
(d) If the acceptability of the safety analysis is dependent on
one or more of the following items, they must be identified in
the analysis and appropriately substantiated:
(1) Maintenance actions being carried out at stated intervals.
The maintenance intervals must be published in the
Airworthiness Limitations section of the Instructions for
Continued Airworthiness (refer to EHPS.25) when:
(ii) (deleted)
Page 67 of 77
Control System, could lead to Hazardous EHPS Effects,

appropriate procedures must be included in the relevant EHPS
manuals.
(3) Verification of the satisfactory functioning of safety or other
devices at pre-flight or other stated periods. The details of this
verification must be published in the appropriate manual.
(4) The provision of specific instrumentation not otherwise
required.
(5) Flight crew actions. These actions must be identified in the
operating instructions manual and appropriately substantiated
at aircraft level if the intended aircraft application is known.
Extremely remote probability is now linked with its definition for

501 FAA Jf EHPS.80 (d)(1) (i) 10 Where is “Extremely Remote” Defined Yes Noted
the intended aircraft application.
Why only apply these rate guidelines to maintenance actions?

Either move them up earlier in the regulation to apply to all
conditions that could produce hazardous EHPS effects or remove These two paragraphs detail when including data in the
them. Airworthiness Limitations section of the ICA.
EHPS.80 (d)(1) (i) Partially
502 FAA JG 10 Yes Safety continuum is ensured whith reference to the extremely
and (ii) accepted
These rates also need to be on a sliding scale consistent with the remot definition provided in the Type Certification Basis of the
safety continuum for how these products are intended to be intended aircraft application.
operated. Applying a extremely remote probability of occurrence
doesn’t seem consistent with this.
Flight Crew Alerts and Actions – The alerting means and Alerting is part of the instrumentation mentioned in (4).
503 FAA DK EHPS.80 (d)(5) 10 Yes Accepted
recommended crew actions must be identified Crew actions has been replaced by Operating instructions
(6) Maintenance Crew Messaging and Actions – These must be

identified in the operating instructions manual and
EHPS.350 (g) addresses the data that are provided by the aircraft
appropriately substantiated at aircraft level if the intended
in order for the EHPS to function properly.
aircraft application is known.
504 FAA DK EHPS.80 (d)(5) 10 Add items Yes Accepted EHPS.360 has been reworded and is now called “A/C instruments”.
It addresses the determination of the parameters to be displayed
(7) Monitoring Systems – Prognostic and health management
in the aircraft in order to ensure a safe monitoring of the EHPS.
functions pertinent to determination of EHPS and aircraft
airworthiness
The EHPS.80(a)(1)(i) states: Aircraft-level devices and procedures

assumed to be associated with a typical installation or the intended
aircraft application. Assumption: EHPS TC is in scope of this SC.
EHPS.80 Safety The SC E-19 scope is limited to cases where the intended aircraft
Assessment It is not clear how to meet several EHPS requirements assuming Clarify if the EHPS TC can be achieved with a consistent list of application is identified.
typical installation since the A/C failure conditions classification and assumptions to assume a typical A/C installation.
quantitative safety objectives are required to be met. Can be all this
part of the assumptions?
Page 68 of 77
(d)(5) Flight crew actions. These actions must be identified in the If the intended application is known, EASA epxects the EHPS
operating instructions manual and appropriately substantiated at (d)(5) Flight crew actions. These actions must be identified in provider and the aircraft manufacturer, if these are different
EHPS.80 Safety aircraft level if the intended aircraft application is known. the operating instructions manual and appropriately Partially entities, to work in coordination on the interfaces between the
506 Rolls-Royce 10 Yes No
Assessment substantiated at aircraft level if the intended aircraft accepted EHPS and the aircraft. Operation instructions are one of the
The A/C level requirements and compliance evidence should not application is known. interfaces.
be with the EHPS applicant responsibility. Rewording has been made as a substantiation may not be feasible.
(3) It must be shown that the design and construction of the the propulsion system takes part in the flight control function).
there is no safety objective defined for EHPS on its own. This
EHPS allows the intended aircraft application to meet the This is why safety objectives have to be derived from the intended
implies that the restriction of not necessarily fullfilling the safety
EHPS.80 Safety qualitative and quantitative safety objectives defined in the aircraft application. The aircraft manufacturer will provide these
507 Rolls-Royce 9 objectives of an intended a/c application must be stated in the Yes No Accepted
Assessment type-certification basis of the intended aircraft application. The data as it is already done today between aircraft manufacturers
assumtions or installation document
demonstrated safety objectives must be published in the and engine manufacturers. EHPS manufacturers do need to take
<Also related to comment 51>
installation manual. into account safety objectives that are provided by the aircraft
Airbus propose to update the wording of EHPS.80 Safety
assessment - as follows (new proposed text shown in
(a) When the EHPS is certified as part of the Aircraft Type
Certificate, a safety analysis of the EHPS, including the control
system, must be carried out, as per the safety analysis
requirements of the certification specification applicable to the
concerned aircraft, in order to assess all Failure Conditions that
can reasonably be expected to occur.
(1) In addition to each aircraft type certification safety analysis
requirements, it must be demonstrated that the probability of
an individual Failure leading to non-containment of High
Energy debris or Propeller release as applicable can be
predicted to be not greater than 10–8 per HEPS flight hour
(2) If the Primary Failure of certain single elements that are
likely to result in High Energy Debris or Propeller release cannot
be sensibly estimated in numerical terms, reliance must be
This paragraph is mixing EHPS effects and aircraft effects and is not The scope of the Special Condition is now limited to the case
placed on meeting the prescribed integrity specifications of
providing clear objectives for EHPS effects. With the aim of adding where the intended aircraft application is known.
EHPS.90. Any such critical part shall be identified in the safety
clarity whilst maintaining flexibility in the possible certification For the time being, EASA is willing to give flexibility in order to
analysis
EHPS.80 Safety approaches (with or w/o a specific EHPS Type Certificate) Airbus is Partially enable innovation.
508 AIRBUS 9 and 10 (3) Any dependence of the safety demonstration on N Y
assessment respectfully proposing a complete rewording of the proposed accepted EHPS can be certified as part of the aircraft or a stand-alone
maintenance / instrumentation must be clearly identified in the
paragraph. The new proposal also takes into account the comment product.
safety analysis and published in the A/C ICA/manuals as
NR 3 made about the Terminology paragraph. Proposal is also Specific guidance will be provided in a Certification Memorandum
required in particular (AMC EHPS.80(a))
made to include some considerations as part of a future AMC. to part 21 regarding the ways to certify an EHPS.
(b) (1)When the EHPS is not certified as part of the Aircraft
Type Certificate, an analysis of the EHPS, including the control
system, must be carried out in order to assess all Failure
Conditions that can reasonably be expected to occur.
(2)(i) The analysis must show that the design and construction
of the EHPS allows the intended aircraft application to meet the
qualitative and quantitative safety objectives defined in the
type-certification basis of the intended aircraft application.
(ii) In addition, it must be demonstrated that the probability of
an individual Failure leading to non-containment of High
Energy debris or Propeller release can be predicted to be not
greater than 10–8 per HEPS flight hour
(iii) If the Primary Failure of certain single elements that are
likely to result in High Energy Debris or Propeller release cannot
be sensibly estimated in numerical terms, reliance must be
placed on meeting the prescribed integrity specifications of
Page 69 of 77
EHPS.90. Any such critical part shall be identified in the safety

summary
(3) Any dependence of the safety demonstration on
maintenance / instrumentation must be clearly identified in the
safety analysis and published in the EHPS ICA/manuals as
required in particular
(AMC EHPS.80(b))
To be added as AMC EHPS.80(a)

(1) If maintenance actions being carried out at stated intervals
are necessary for preventing the occurrence of High-Energy
Debris or Propeller release at a rate in excess of 10-8 per HEPS
flight hour, or for complying with the numerical probabilistic
objectives of the aircraft certification basis the maintenance
This paragraph is mixing EHPS effects and aircraft effects and is not intervals shall be published in the Airworthiness Limitations
providing clear objectives for EHPS effects. With the aim of adding section of the Instructions for Continued Airworthiness of the
clarity whilst maintaining flexibility in the possible certification concerned aircraft application
Some proposed paragraphs as "future AMC" are to be kept at
EHPS.80 Safety approaches (with or w/o a specific EHPS Type Certificate) Airbus is (4) If errors in maintenance of the EHPS, including the EHPS Partially
509 AIRBUS 9 and 10 N Y requirement level.
assessment respectfully proposing a complete rewording of the proposed Control System, could lead to High Energy Debris or Propeller accepted
Guidance will be provided accordingly to support EHPS.80.
paragraph. The new proposal also takes into account the comment release, Hazardous or Catastrophic Aircraft Effects, appropriate
NR 3 made about the Terminology paragraph. Proposal is also procedures shall be included in the relevant aircraft manuals.
made to include some considerations as part of a future AMC. (5) If verification of the satisfactory functioning of safety or
other devices at pre-flight or other stated periods is required as
part of the safety analysis, the details of this verification shall
be published in the appropriate manual.
(6) If the provision of specific instrumentation not otherwise
required is necessary for the safety analysis, it shall be clearly
identified as part of the safety analysis.
To be added as AMC EHPS.80(b)

(1) The analysis required by EHPS.80(b) shall take account of:
application. Such assumptions must be stated in the analysis. ,
(iii) Reliance placed on a safety (protection) system
(2) A summary shall be made of those Failures Conditions
together with an estimate of the probability of occurrence of
those Failure Conditions that could result in
(i) High Energy Debris or Propeller release
This paragraph is mixing EHPS effects and aircraft effects and is not
(ii) Major Aircraft Effects, Hazardous Aircraft Effects or
providing clear objectives for EHPS effects. With the aim of adding
Catastrophic Aircraft Effects
clarity whilst maintaining flexibility in the possible certification
(3) If maintenance actions being carried out at stated intervals Some proposed paragraphs as "future AMC" are to be kept at
EHPS.80 Safety approaches (with or w/o a specific EHPS Type Certificate) Airbus is Partially
510 AIRBUS 9 and 10 are necessary for preventing the occurrence of High-Energy N Y requirement level.
assessment respectfully proposing a complete rewording of the proposed accepted
Debris or Propeller release at a rate in excess of 10-8 per HEPS Guidance will be provided accordingly to support EHPS.80.
paragraph. The new proposal also takes into account the comment
flight hour, or for complying with the numerical probabilistic
NR 3 made about the Terminology paragraph. Proposal is also
objectives of the intended aircraft certification basis the
made to include some considerations as part of a future AMC.
maintenance intervals shall be published in the Airworthiness
Limitations section of the HEPS Instructions for Continued
Airworthiness (refer to EHPS.25) or of the concerned aircraft
application
Control System, could lead to High Energy Debris or Propeller
release, Hazardous or Catastrophic Aircraft Effects, appropriate
procedures shall be included in the relevant EHPS manuals.
(5) If verification of the satisfactory functioning of safety or
other devices at pre-flight or other stated periods is required as
part of the safety analysis, the details of this verification shall
be published in the appropriate manual.
Page 70 of 77
(6) If the provision of specific instrumentation not otherwise

required is necessary for the safety analysis, it shall be clearly
identified as part of the safety summary.
(8) If flight crew actions are required as part of the safety
analysis, these actions shall be identified in the operating
instructions manual and appropriately substantiated at aircraft
level if the intended aircraft application is known.
The wording of this requirement does only allow simplified showing

Werner Scholz, of compliance (e.g. for simpler aircraft or sailplanes) if the PCM
European EHPS.80 Safety would allow – if not this could become a rather arduous task – even Add regarding guidance and/or introduce some tiering (i.e. Partially
Sailplane Assessment more so when probabilities for different failure types are simplified requirements for simpler aircraft). accepted
UAS.
Manufacturers requested. At least some guidance should be included how
simplified showing of compliance could be possible here.
Review and correct wording

EHPS.80 Safety
512 Rolls-Royce 10 (d) (1) (ii) is not comprehensible. Is there some wording missing? [Bruce Cook input: Would make sense if "necessary for Yes No Accepted Reworded
Assessment
preventing" were moved from (i) to the end of (1) main text.]
"(a)(3) It must be shown that the design and construction of the

EHPS allows the intended aircraft application to meet the
qualitative and quantitative safety objectives defined in the type-
EHPS.80 Safety certification basis of the intended aircraft application." This is a Not applicable. Comment is a positive observation only.
Assessment sensible approach to align the EHPS safety objectives with that of <Repeats support for this approach also seen in comment 51>
the intended aircraft application. It prevents over-design for some
CS-23 applications, where the safety objective for Hazardous
effects is 1E-06 and not 1E-07 as for CS-25 applications.
(c ) It is a sensible approach to limit Critcal Parts to Hazardous EHPS

Effects, i.e. to not extend the criteria to Hazardous EHPS Failure
Not applicable. Comment is a positive observation only.
EHPS.80 Safety Conditions, since this would extend the scope of Critical Parts to
514 Rolls-Royce 9-10 <But note comment 7 on inclusion of Aircraft level safety Yes No Noted
Assessment many parts in a single engine application (e.g. CS-23), where it is
effects>
not practicable to apply Critical Part controls to all components that
can result in a total loss of power.
We recommend to replace paragraph (1): (1) An analysis of the
EHPS, including the control system, must be carried out in
EHPS.80 The following intended aircraft applications have been removed
This paragraph is unconsistent with the safety level of some light order to assess all Failure Conditions that can reasonably be
515 VOLTAERO Safety 9 YES NO Accepted from the scope: CS-22, CS-LSA, CS-23 level 1 day VFR and Light
aircraft. expected to occur. This analysis must take account of the
assessment UAS.
installation Instructions, operating instructions and limitations
of the EHPS.
This paragraph is unconsistent with the safety level of some light
aircraft. “Secondary failures and dormant failures” are never Partially
516 VOLTAERO Safety 9 We recommend to delete paragraph (a) (1) (ii) YES NO from the scope: CS-22, CS-LSA, CS-23 level 1 day VFR and Light
considered in General Aviation. As the applicability does not include accepted
assessment UAS.
CS-25, the text has to be consistent.

aircraft. “Multiple failures” are never considered in General Partially
517 VOLTAERO Safety 9 We recommend to delete paragraph (a) (1) (iii). YES NO from the scope: CS-22, CS-LSA, CS-23 level 1 day VFR and Light
Aviation. As the applicability does not include CS-25, the text has to accepted
assessment UAS.
be consistent.
EHPS.80
It is not the responsibility of the EHPS designer to certify the Not the propulsion system takes part in the flight control function).
518 VOLTAERO Safety 9 We recommend to delete paragraph a) (2). YES NO
aircraft. accepted This is why safety objectives have to be derived from the intended
assessment
Page 71 of 77

It is not requested to show compliance with the intended aircraft

application, but to allow the intended aircraft application to meet
the qualitative and quantitative safety objectives defined in the
EHPS.80
It is not the responsibility of the EHPS designer to certify the Not type-certification basis of the intended aircraft application.
519 VOLTAERO Safety 9 We recommend to delete paragraph a) (3). YES NO
aircraft. accepted In other words, the demonstration of compliance to type-
assessment
certification basis of the intended aircraft application remains at
aircraft level.
No change is made to the text but guidance will be provided.
EHPS.80
520 VOLTAERO Safety 9 Typing error ( c ) should be (b) YES NO Accepted Corrected
assessment

aircraft. Quantitative failure analysis are never considered in We recommend to modify paragraph (c) as such : Partially
521 VOLTAERO Safety 9 YES NO from the scope: CS-22, CS-LSA, CS-23 level 1 day VFR and Light
General Aviation. As the applicability does not include CS-25, the (b) The safety assessment shall identify the critical parts. accepted
assessment UAS.
text has to be consistent.
EHPS.80
522 VOLTAERO Safety 10 Typing error ( d ) should be (c) YES NO Accepted Corrected
assessment

aircraft, not clear and adds nothing. The designer shall be left free Partially
523 VOLTAERO Safety 10 We recommend to delete paragraph (d). YES NO from the scope: CS-22, CS-LSA, CS-23 level 1 day VFR and Light
to define its installation instructions, operating instructions and accepted
assessment UAS.
limitations.
Define quantitative figures relevant for the EHPS aircraft Extremely remote probability is now linked with its definition for
Vertical (a) probability vs impact, no quantitative figures for achieved safety
524 EHPS.80(a) 9 category, or provide reference to established safety targets Yes Accepted the intended aircraft application.
Aerospace are defined
(e.g., AMC 25.1309). Guidance will be provided to support EHPS.80.
The requirement asks for EHPS safety assessment that includes assessed anymore at motor level but at aircraft level (e.g. when
Aircraft effects. the propulsion system takes part in the flight control function).
The possible highly-integrated nature of some aircraft architectures This is why safety objectives have to be derived from the intended
To rely on the overall safety assessment, including EHPS, at
J. Jézégou that incorporates EHPS renders this overall assessment necessary. Partially aircraft application. The aircraft manufacturer will provide these
525 EHPS.80(a) 9 aircraft level in aircraft CS, and to focus as EHPS effects in the Suggestion No
ISAE-SUPAERO However, in case of EHPS standalone certification with an applicant accepted data as it is already done today between aircraft manufacturers
SC.
that is not the aircraft manufacturer, the responsibility required and engine manufacturers. EHPS manufacturers do need to take
from the applicant for such an assessment may not be relevant. into account safety objectives that are provided by the aircraft
(CS-APU -> only APU effects / CS-E -> only E effects) manufacturers in order for them to be able to perform the
526 Volocopter EHPS.80(a)(1)(i) 10 Typo: “. ,” Yes Accepted Corrected
Page 72 of 77
Vertical
527 EHPS.80(b) 9 (b) is missing State “(b) reserved” Yes Accepted Corrected
Aerospace
Vertical
528 EHPS.90 10 The word 'engine' is used repeatedly here Replace ‘engine’ with ' EHPS' or 'Engine / Motor' Yes Accepted Corrected
Aerospace
Lange Aviation There is a risk of nullifying the whole purpose of the safety The AMC should provide guidance which procedures are
529 EHPS.90 10 Yes Accepted Guidance will be provided accordingly
GmbH assessment when applying superficial methods here. acceptable, e.g. as in AMC CS-E 515.
Lange Aviation “EHPS critical part” instead of “Engine critical part” in several Search document for “engine” and replace with “EHPS” where
530 EHPS.90 10 Yes Accepted Corrected
GmbH instances appropriate
Cranfield
531 Aerospace EHPS.90 10 Should “Engine Critical Part” be ‘EHPS Critical Part’? Reword if not intended. Yes No Accepted Corrected
Solutions Ltd
Scope of aparagraphs is too small, referring to "engine" erroneously Replace "Engine Critical Part" with "EHPS Crtitical Part". 4
532 Rolls-Royce EHPS.90 9 & 10 Yes No Accepted Corrected
when "EHPS" is intended in this context. 4 instances. instances.
Partially
533 SAFRAN EHPS.90 10 (a) Engine mentioned To replace by EHPS sub system Yes No Replaced by "EHPS"
accepted
Reword part (a) to "An Engineering Plan which outlines how to

establish and maintain the respective combinations of loads,
General material properties, environmental influences, operating
Aviation conditions, and the effects of parts influencing these Partially Consistency with CS-E is maintained.
534 EHPS.90 10 EHPS.90 - The regulation could be reworded to avoid confusion Editorial
Manufacturers parameters. To allow each engine critical part to be withdrawn accepted Guidance will be provided accordingly
Association from service at an approved life, before hazardous engine
effects can occur, validated analysis, test or service experience
must be evaluated."
Editorial: Change "Engine Critical Parts" to "EHPS Critical Parts" (x3)

535 TCCA EHPS.90 10 Minor edits. Accepted Corrected accordingly
Editorial: "Hazardous Engine Effects" to "Hazardous EHPS Effects"
Werner Scholz, Similar to EHPS.80: Guidance for simpler aircraft is missing, which
European EHPS.90 EHPS could lead to onerous way of showing compliance. Within CS-22H Add regarding guidance and/or introduce some tiering (i.e. Partially
Sailplane Critical Parts the engine is required to run safe for 50 hours and that’s it simplified requirements for simpler aircraft). accepted
UAS.
Manufacturers basically…
Airbus propose to update the wording of EHPS.90 Critical Parts
font):
The integrity of the EHPS Critical Parts identified under

EHPS.80 must be established by:
(a) An Engineering Plan, the execution of which establishes and
EHPS.90 EHPS The wording of this paragraph needs to be adapted in line with maintains that the combinations of loads, material properties, Partially Consistency with CS-E is maintained.
537 AIRBUS 10 & 11 NO YES
Critical Parts proposed new EHPS.80 environmental influences and operating conditions, including accepted "Engine" has been replaced "EHPS"
the effects of parts influencing these parameters, are
sufficiently well known or predictable, by validated analysis,
test or service experience, to allow each Engine EHPS Critical
Part to be withdrawn from service at an Approved Life before
High Energy Debris or Propeller release can occur. Appropriate
Damage Tolerance assessments must be performed to address
the potential for Failure from material, manufacturing and
Page 73 of 77
service-induced anomalies within the Approved Life of the

part. The Approved Life must be published as required in
EHPS.25.
Part 21 provides rules as per coordination with Design and

manufacturing.
The three plans identified in EHPS.90 define a closed-loop system
which link the assumptions made in the Engineering Plan to how
the part is manufactured and maintained in service; the latter two
EHPS.90 aspects are controlled by the Manufacturing and Service
The paragraphs b) and c) are already covered by Part 21, subpart F Not
538 VOLTAERO EHPS Critical 11 We recommend to delete paragraphs (b) and (c). YES NO Management Plans respectively.
ang G for b), 21.A.6 and 21.A.120A for c). accepted
Parts The objective for an applicant is to develop a closed loop system
where the combination and interconnectivity of these elements
enhances product integrity. Speicif guidance will be provided to
identify the skill sets that should be present in establishing the
three plans, with aim of ensuring cross discipline inclusion to
achieve a closed loop system.
The critical rotating parts and rotor integrity requirements for gas
Loss of load is one failure condition leading to overspeed for
turbines are not applicable to electric or reciprocating (including
EHPS.90 Suggest these sections be revised as deemed appropriate by Not engine.
539 TCCA 13 Wankel) engines. Unlike a driven turbine stage, if a piston or
EHPS.240 EASA. accepted But a rotor burst could be the result of an engine overspeed due
electrical engines suffers a sudden loss of load its rotor will not
to control system malfunction or a production defect.
accelerate indefinitely until burst.
SAFRAN thanks EASA for the development of this special

condition which is an important step. SAFRAN does support
540 SAFRAN General N/A Comments Introduction No No Noted
any discussion around this special condition and the coming
Means of Compliance (MoC).
The SC E-19 is a self supporting document.

enable innovation.
Certification basis should be define starting from CS-E + SC-
EHPS can be certified as part of the aircraft or a stand-alone
E19, or SC-E19 should be standalone.
engine product.
We recommend adding in the scope EHPS.10 the following
From industrial standpoint, need a clear & complete certification sentence: “This Special Conditions can be used as applicable
to part 21.
541 SAFRAN General N/A specification basis covering the propulsion system. for the certification of an EHPS”. No Yes Accepted
To be noted that the intent is to ease the use of certified engines
We use to have CS-E + SC ? As an example, fuel system requirements are defined in this
as part of an EHPS in order to make use of certification data
Special Condition for fuel engines, whereas a full set of
already available.
requirements is already defined in the CS-E. Having different
The SC EHPS is not aimed to be the only means to certify an EHPS.
requirements may provide confusion.
Pending the architecture of the EHPS under certification, one
applicant could request to make use of CS-E with an additional
Special Condition.
It should be interesting to work on the “Engine” definition (in

the CS-Definition) to be compatible with this new propulsion
This is not the purpose of the SC E-19.
system or to use another generic word to introduce the
542 SAFRAN General N/A Engine definition Yes No Noted However, this may be considered for a future update of the CS-
propulsion system and the dynamic lifting system, this
Definition
definition has to be compatible with Thermal Engine, Electrical
Engine, EHPS, …
EBAA (Corina Thank you for the opportunity to comment.

543 General No No Noted
Stiubei) As an organisation we do not have any specific comments.
VOLTAERO supports the proposal as some requirements for

544 VOLTAERO General General support of the proposal NO NO Noted
electrical and hybrid propulsion systems were necessary.
Page 74 of 77
Q1. Has EASA considered the use of SAE ARP4754 when drafting
this Special Condition? If yes, where can be the guidance be found? ARP4754 could be used pending the intended aircraft application.
545 TCCA General Suggest to clarify intent, if applicable Noted
SAE ARP4754 may be applicable to all other types of aircraft not Specific guidance will be provided in the Means of Compliance.
just CS-25.
There is another SC being drafted by another Authority on a similar It is the intention of EASA to promote harmonization.
topic, hence this SC should be harmonized with the other Authority. However, EASA is not aware of another SC begin drafted by an
546 TCCA General This will make future regulations on this new technology be more Harmonized SC between the certifying authorities. Noted authority that adresses hybrid systems or even complete
acceptable worldwide and will aid in a level playing field for all propulsion systems. The only other Special Condition known to
concerned. EASA that is currently drafted addresses a single electric engine.
If the intention of this SC is to allow Certification of an installation-

General neutral powerplant, then certain requirements which would seem The SC E-19 scope is limited to cases where the intended aircraft
547 Rolls-Royce N/A Please clarify the SC intent Yes No Noted
comment to require an airframe/installation to be fully defined beforehand application is identified.
should be clarified.
SC E-19 is based on CS-E requirements.It intends to provide the

same level of safety.
To be noted that the intent is to ease the use of certified engines
This SC allows a reciprocating or gas turbine engine as a sub-system as part of an EHPS in order to make use of certification data
of an EHPS. However there is no specific reference to CS-E or CS- Each turbine or piston engine within the scope of the EHPS already available.
General Partially
548 Rolls-Royce n/a APU. EHPS should be qualified to an equivalent safety standard as must be type certified in accordance with CS-E, or meet No Yes The SC EHPS is not aimed to be the only means to certify an EHPS.
comment accepted
an engine so therefore any such engine used as a subsystem should accepted specifications. Pending the architecture of the EHPS under certification, one
be type certified. applicant could request to make use of CS-E with an additional
Special Condition.
A dedicated Certification Memoradum to Part 21 will provide
guidance regarding the ways to certify an EHPS.
It should be clarified that this SC can be used for: For the time being, EASA is willing to offer flexibility in order to
Airbus Identification of - Propulsion system Type Certification, or Partially enable innovation.
549 1 Add clarification Yes No
Helicopters Issue - Propulsion system certification requirements in the frame of accepted A dedicated Certification Memoradum to Part 21 will provide
aircraft Type Certifiction. guidance regarding the ways to certify an EHPS.

Comment n° 1 is also valid specifically for the case of an hybrid
Airbus Identification of Partially enable innovation.
550 1 system for which one could envisage that CS-E remains applicable Add clarification Yes No
Helicopters Issue accepted A dedicated Certification Memoradum to Part 21 will provide
to the turbomachine element.
Within the mail of Mr. Rossotto dated 16.6.2020 to the WEP group
of Ostiv SDP it was detailed that powered sailplanes are eligible for
Werner Scholz,
simpler requirements – just as CS-22 J / H requirements are less Clarify that Electric and / or Hybrid Propulsion Systems for The following intended aircraft applications have been removed
European Identification of Partially
551 1 extensive than those of CS-E or for larger propeller. Therefore, it powered sailplanes (and VLA) could be less extensive and/or suggestion from the scope: CS-22, CS-LSA, CS-23 level 1 day VFR and Light
Sailplane Issue accepted
should be included in the identification of the issue, that the specified in a simplified SC. UAS.
Manufacturers
requirements of SC E-19 could be replaced by less extensive
requirements for sailplanes (or VLA).
Delete reference to CS-22:

“The certification specifications that are usually applicable to
It is correct that CS22 subpart H Engines does not consider Electric aircraft engines (except powered sailplanes) are contained in
and/or Hybrid Propulsion Systems, but there does exist an CS-E amendment 5. However this certification specification
OSTIV The following intended aircraft applications have been removed
Identification of appropriate Special Condition CS E-01 for this case does not consider Electric and / or Hybrid Propulsion Systems.” Partially
552 Michael 1 suggestion objection from the scope: CS-22, CS-LSA, CS-23 level 1 day VFR and Light
Issue A strategic principle of the EASA GA-Roadmap is: “Protect ‘what This could be added if necessary: accepted
Greiner UAS.
shows to work well’ unless there are demonstrable and statistically “As far as Electric Propulsion Systems for CS-22/LSA aircraft are
significant safety reasons against doing so” concerned, SC E-01 is applicable.”
“A SC E-19 engine can be installed in the same manner as a CS-
E engine in a CS-22/LSA-aircraft.”
Page 75 of 77
Airbus propose to update wording of the ‘identification of

issue’ as follows (new proposed text shown in underlined italic
font):
This Special Condition has been developed to support
Applications received by the Agency for the certification of
Electric and / or Hybrid Propulsion Systems.
The certification specifications applicable to aircraft turbine
and reciprocating engines are contained in CS-E. CS-22 subpart
H also contains specifications for spark and compression-
ignition engines used to power sailplanes. CS-22, CS-23, CS-25,
CS-27 and CS-29 all contain certification specifications
The wording used in the Identification of Issue seems to imply that
applicable to the integration of those traditional fuel-burn
the proposed Special Condition is a one to one replacement of CS-E.
engines into various airframes.
Contrarily to what CS-E states (ref to CS-E 10 Applicability), it is
None of these certification specifications however consider For the time being, EASA is willing to offer flexibility in order to
however nowhere explicitly stated that the proposed SC now
Identification of Electric and / or Hybrid propulsion systems. Partially enable innovation.
553 AIRBUS 1 contains airworthiness specifications for the issue of type No Yes
Issue The purpose of this Special Condition is to provide a minimum accepted A dedicated Certification Memoradum to Part 21 will provide
certificates, and changes to those certificates, for Electric and / or
set of requirements that an Electric and / or Hybrid Propulsion guidance regarding the ways to certify an EHPS.
Hybrid Propulsion Systems. Airbus suggest to modify the wording in
System shall satisfy to be eligible for installation on CS-22/CS-
order to clarify this is a possibility that is offered with the proposed
23/CS-25/CS-27/CS-29 aircraft/rotorcraft/sailplane. It can be
SC to have the EHPS included in the vehicle TC.
used in its entirety or in part directly as an element of the
aircraft/rotorcraft/sailplane certification basis w/o the need for
the issuance of a specific Engine Type Certificate.
This Special Condition is articulated so as to provide objective
based certification requirements which are independent of the
propulsion system design or architecture. The type of
technology used in the propulsion system will be addressed in
the Acceptable Means of Compliance. Acceptable Means of
Compliance will depend on the type of EHPS that is considered
and on the type of aircraft on which the EHPS is intended to be
integrated.
In case of certification of an aircraft according SC-VTOL, SC-EHPS is

understood to be used for either standalone TC of the EHPS to
show compliance to VTOL.2400 (b) “…must be type certified,…” or
SC-EHPS enable innovation.
554 Volocopter All can be used as a specification in case of certifying the EHPS Yes Noted
General A dedicated Certification Memoradum to Part 21 will provide
together with the aircraft, which will show compliance to
VTOL.2400 (b) “…or meet accepted specifications”.
Can EASA provide feedback if they agree with this understanding?
In case of certifying an EHPS together with an aircraft according SC-

VTOL, many of the requirements provided by SC-EHPS are as well
existing in SC-VTOL.
EHPS shall comply with the requirements provided in the SC E-19.
SC-EHPS Can EASA please advise, if duplicated requirements for the EHPS
555 Volocopter All Yes Noted If similar requirements are provided in the intended application,
General should be demonstrated by showing compliance to SC-EHPS or can
there is no need to duplicate the work.
also be demonstrated directly via SC-VTOL (e.g. Safety assessment,
strength requirements, etc.)? Would it need special mentioning,
where such approach is used?
Page 76 of 77
The Energy Storage System is now only limited to battery system.

Battery systems are considered active components for the electric
engines. A strong interconnection exists between how the electric
engine is controlled and the way the battery discharges and vice-
Suggest this Special Condition to insure minimum safety
versa. It can be so considered as an equipement necessary for the
conditions for only the electrical equipment, power
functioning and the control of the engine.
distribution and overall integration of the Hybrid Propulsion
An integrated Hybrid Propulsion System could include a gas turbine For the time being, EASA is willing to offer flexibility in order to
Systems.
or piston engine + electric motor. enable innovation. Battery system can be considered as part of
It is suggested to keep the Energy Storage System outside this Not
556 TCCA Subpart A The scope of this special condition is considered too broad to the EHPS or as part of the aircraft. Requirements concerning the
Special Condition. Energy Storage could involve very complex accepted
address all the safety concerns related to all the details of an battery system refers to the aircraft ones in order to ensure
safety concerns and could be a special condition by itself.
Integrated Hybrid Propulsion System consistency.
The gas turbine or piston engine portion of the Hybrid
The SC EHPS is not aimed to be the only means to certify an EHPS.
propulsion systems could be certified through the existing
Pending the architecture of the EHPS under certification, one
rules (CS-E or CS-APU).
applicant could request to make use of CS-E with an additional
Special Condition.
A dedicated Certification Memoradum to Part 21 will provide
SUBPART C –
557 Rolls-Royce SYSTEMS and 15 Typo: 'Equipements' should read 'Equipment'. Correct wording Yes No Accepted Corrected accordingly
EQUIPEMENTS
What about electrical failures such as Overvoltages, Overcurrents, Consider add missing substantiation requirements to cover
SUBPART D – Partially EHPS.490 covers the need.
558 Airbus DS 21 Sudden Step Load management, etc..? overvoltages, overcurrents, sudden step load management, Yes No
SUBSTANTIATION accepted Specific guidance will be provided in the means of compliance.
The listed requirements seem particular to combustion engines. etc..
Airbus propose to update the wording of the introduction to

Subpart D as follows (new proposed text shown in underlined
Airbus understand that the intent of this subpart is to prescribe italic font):
requirements for complete EHPS tests (by opposition to partial Compliance with the requirements for Endurance (including
tests) that would have to be performed on top of the requirements periods of EHPS Limits exceedance), Durability, Vibration, Over The Airbus understanding is correct.
Subpart D prescribed in the other subparts of the SC. If this is confirmed this Torque, Temperature limit demonstration, Operation (including Partially Consistency with CS-E wording is maintained.
559 AIRBUS 21 N Y
Substantiation should be stated more clearly. In addition, the introductory text Power Response, Rotor Locking, Operation with a variable accepted Specific guidance will be provided as part of the Means of
makes reference to Vibration, Over Torque and Temperature Limit pitch thruster, and Operation with a fixed pitch thruster) must Compliance.
demonstration whereas the section does not contain any be substantiated via test performed on a complete EHPS
requirements for such tests. representative of the intended Type Design, validated analysis,
or a combination thereof. The following provisions provide the
objective for these demonstrations.
* Please complete this column using the word “yes” or “no”

** Please complete this column using the word “yes” or “no”
Page 77 of 77

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EASA–SC E-19 Electric / Hybrid Propulsion System - Comment Response Document

Requirements provided in the SC E-19 are deemed to be

EHPS.390 Electrical Wiring and Interconnect System (EWIS) –

DO-160 EMC effects is just covering electrical systems up to

Airbus propose to updated § 2. of the Associated Interpretative

The term "installed" covers EHPS.370 (a) associated to EHPS.80

(except CS-25 aircrafts)

(except CS-25 aircrafts)

Exclusion of CS-25 aircrafts based only on emissions omits the

Fully supportive of the need to integrate the propulsion system

The wording “power for fligt” (“… which is used to provide or

“(except CS-25 aircrafts)”

An alternative would be to use the term “Elecrtric / Hybrid Power

This is already covered by EHPS.30.

Given the varying degrees of electrification, it is possible that a new

The intent of the SC E-19 is to provide technical requirements for

The intent of the SC E-19 is to provide technical requirements for

Pitch Control System could be part of the applicability. To be

The text "This Special Condition is applicable to any Electric / Hybrid

A definition of an Integrated Propeller/Fan should be added to

different reason). Now the first task to the designer is to discuss

Whereas it is understood that this SC could be applicable to any

Electrical arcing is indeed a potential source of fire.

Paragraphs (a) and (b) in this section correspond to CS-e 130. If

An acceptable probability, i.e. extremely remote, should be

Specific guidance will be provided for a) in order to address the

As a difference from CS-E, no design requirements (fire-grade,

The SC E-19 follows an objective based approach. The "how", as

a) Removed from CS-E "In addition, the design and construction of

Paragraph a) address the minimization of the fire spread.

Airbus propose to update the wording of EHPS.100 Fire

FARADAY EHPS.100 Fire

Batteries are indeed a potential source of fire.

Consistency has been ensured.

Werner Scholz, EHPS.11

EHPS: What is meant by Electrical Wiring Interconnection System?

The EHPS Control System excludes all battery management

Torque is considered as a limitation, not a rating. A rating is used

Why the Battery or Energy Storage Management System are

Operators & maintainers should be considered with different

Electric Distribution System could also be included in to the

contradict the definition presented in the document for “Electric /

In the case of hydrogen based electrical systems, is the hydrogen

The mentioned aerodynamic effects can indeed lead to important

Toxic products are not envisaged in all EHPS configurations.

Systematic use of EHPS rather than engine and/or generator

The scope of the EHPS will be aircraft dependant, however the SC

Hazardous EHPS effect includes eletrocution of crew, passengers,

Probabilty Terms such as "Extremely Remote" are not defined. This

Lift/thrust/power are mentioned. This does not mean that they

data as it is already done today between aircraft manufacturers

EHPS.15 Relative to Hazardous

I find all the definitions below quite confusing.

Not clear the intended use of “normal” which is a vague qualifier.

Airbus propose to update the wording of EHPS.20 EHPS

Proposal is to add the underlined text “(a) The loads induced

Airbus propose to update the wording of EHPS.200 as follows