PS Anm 25 08

1
Policy
Statement
Subject: Application of AC 20-170, Date: 05/ 23/ Policy No:
Integrated Modular Avionics Development, 2013 PS-ANM-25-08
Verification, Integration, and Approval
Using RTCA/DO-297 and Technical Initiated By:
Standard Order-C153. ANM-100
Summary
This policy statement describes Federal Aviation Administration (FAA) Transport Airplane
Directorate certification policy on when the guidance of Advisory Circular (AC) 20-170,
Integrated Modular Avionics Development, Verification, Integration, and Approval Using
RTCA/DO-297 and Technical Standard Order-C153, dated October 28, 2010, is relevant to a
particular part 25 certification program and should be applied. This policy statement is necessary
because of the wide range of complex, highly integrated systems that could be referred to by a
part 25 applicant as an integrated modular avionics (IMA) system. This policy statement
provides criteria and resources to help applicants and aircraft certification offices determine if
the guidance in AC 20-170 is applicable, regardless of how the system is referred to or what
name it has been given.
Definition of Key Terms
In the text below the terms “must,” “should,” and “recommend” have a specific meaning that is
explained in Attachment 1.
Current Regulatory and Advisory Material
AC 20-170, Integrated Modular Avionics Development, Verification, Integration, and Approval

Using RTCA/DO-297 and Technical Standard Order-C153, was published on October 28, 2010.
That AC recognizes the industry standard RTCA/DO-297, Integrated Modular Avionics (IMA)
Development Guidance and Certification Considerations, dated November 8, 2005, as an
acceptable means of compliance. This policy statement highlights material that is contained in
RTCA/DO-297 that will assist applicants and their suppliers in making the determination about
the relevancy of the guidance material contained in AC 20-170.
2
Relevant Past Practice
The FAA published AC 20-145, Guidance for Integrated Modular Avionics (IMA) That
Implement TSO C153 Authorized Hardware Elements, in 2003. That AC was canceled with the
release of AC 20-170, which incorporated relevant material from AC 20-145. Additional issues
regarding the design, verification, and installation of IMA systems have been addressed in
aircraft program-specific issue papers. The need for many of these issue papers was removed
when AC 20-170 was published, as either the guidance provided in RTCA/DO-297 or the AC
text itself addressed those issues.
Policy
1. Background. When IMA systems began to be used in commercial aircraft, they shared
several specific architectural attributes, such as a number of generic computing modules
and shared supporting resources—such as Input/Output (I/O) processing modules and
power supplies—installed in one or more cabinets. During this time, applicants and
developers of these IMA systems normally used AC 20-145 as one acceptable means of
compliance to meet the regulations.
However, technology has advanced since those first-generation IMA systems. There are
many variations, large and small, on the possible system architectures of an IMA. As a
result, these systems may not resemble those first-generation IMA systems. AC 20-145 no
longer fully addressed the issues encountered during the development, verification, and
installation of increasingly complex IMA systems. AC 20-170 is intended to address these
additional issues.
The purpose of this policy is to help part 25 applicants determine when the guidance
contained in AC 20-170 is relevant to their airborne systems. Please note that this policy
does not make compliance to AC 20-170 mandatory. That AC, as with all ACs, documents
one, but not the only, acceptable means of compliance to the applicable regulations.
However, if applicants are not going to adopt the guidance contained in AC 20-170 as their
acceptable means of compliance, then they should propose a method that addresses all the
issues covered in that AC.
2. IMA System Definition. AC 20-170 and RTCA/DO-297 provides the following definition
of an IMA:
“Shared set of flexible, reusable, and interoperable hardware and software

resources that, when integrated, form a platform that provides services. These
services are designed and verified to a defined set of safety and performance
requirements, to host applications performing aircraft functions.”
Although the current guidance material provides a definition of an IMA system, some
applicants contend that it contains enough ambiguity to not provide a conclusive method of
establishing if an airborne system is or is not an IMA. Applicants and system designers
under part 25, therefore, should also consider the architecture, functions, and components
to determine if an airborne system is or is not an IMA.
3
As stated in AC 20-170, paragraph 1-4.d, an IMA system is defined by the system

architecture and not by the functionality that system provides. IMA systems may not
always implement functions historically regarded as “avionics,” such as flight deck
displays, navigation, and communication. IMA systems may also be used to implement
other aircraft functionality, such as fly-by-wire flight controls, inertial reference/air data
systems, and electrical power systems. There may be more than one IMA system on an
aircraft. An IMA system could feasibly mounted within an engine assembly.
3. Examples of an IMA System. To aid in the effort of providing a more definitive way of
establishing an IMA system, Annex D of RTCA/DO-297 provides several examples of
possible architectures. Part 25 applicants should consult these examples to determine if the
guidance material in AC 20-170 is relevant.
4. Key Characteristics of an IMA System. Some instances of IMA systems may not exactly
fit the examples of Annex D of RTCA/DO-297. Tables 1 and 2 in Section 2.3 of
RTCA/DO-297 also provide information regarding the key characteristics of an IMA
system as well as the hosted applications. The key characteristics in these tables may also
be used in the determination if an airborne system is an IMA. These tables are not intended
to be used as checklists that would provide a definitive “yes” or “no” answer to the
question of whether any particular system is indeed an IMA. Rather, applicants and their
suppliers should use these key characteristics as a reference when attempting to determine
when AC 20-170 and RTCA/DO-297 are applicable.
5. Relevancy of the Guidance Contained in AC 20-170. The guidance provided in

AC 20-170 is relevant and should be considered to be an acceptable means of compliance
if an airborne system in question meets any of the following criteria:
a. Fits the definition of an IMA in paragraph 2,
b. Resembles one or more of the examples of Annex D of RTCA/DO-297 in

paragraph 3, or
c. Contains key characteristics discussed in paragraph 4 that indicate the system may be
an IMA.
Note: As indicated in paragraph 4, the lists of IMA key characteristics in Tables 1

and 2 in Section 2.3 of RTCA/DO-297 are not intended to be a checklist. The
presence of only a single attribute from these tables is not enough to categorize an
airborne system as an IMA. These tables are intended to be used as a guide and,
therefore, a specific number of these attributes cannot be identified. Engineering
judgment is required.
Please see AC 20-170, paragraph 7-5, to determine if the guidance in AC 20-156, Aviation
Databus Assurance, to dedicated data networks for IMA systems is relevant.
4
As stated previously in paragraph 1, this policy statement does not require an applicant to
adopt the specific guidance in AC 20-170. Guidance material contained in an AC
represents one, but not the only, acceptable means of compliance. If an applicant chooses
to not use the guidance in AC 20-170 as its selected means of compliance, then it should
be prepared to propose an alternative method of compliance. The proposal for an
alternative means (other than the one published in AC 20-170) should address the technical
and procedural issues contained in that AC. The applicant should be prepared to document
its proposed approach with an issue paper.
6. Technical Standard Orders (TSO) and Relevance of AC 20-170. The presence or

absence of TSO-Authorized (TSOA) articles within the avionics system does not affect the
decision of whether AC 20-170 is relevant to the development, integration, and approval of
that airborne system. If the system has been granted one or more TSO authorizations,
AC 20-170 provides guidance about how compliance data from the TSOA may be used to
show compliance to the applicable regulations and guidance material at the installation
level for the purpose of obtaining aircraft certification. Applicants seeking a type
certificate or approval of a change to type design should refer to AC 21-50, Installation of
TSOA Articles and LODA Appliances, dated February 11, 2011. This AC includes more
information regarding appropriate use of FAA-approved data under a TSOA to support
showing compliance to the airworthiness regulations applicable to the category of the
product on which the TSO article is being installed.
Effect of Policy
The general policy stated in this document does not constitute a new regulation. Agency
employees and their designees and delegations must not depart from this policy statement
without appropriate justification and concurrence from the FAA management that issued this
policy statement. The authority to deviate from this policy statement is delegated to the
Transport Standards Staff Manager.
Conclusion
The Transport Airplane Directorate has concluded that it is necessary to create policy on when to
apply the guidance in AC 20-170, Integrated Modular Avionics Development, Verification,
Integration, and Approval Using RTCA/DO-297 and Technical Standard Order-C153 in part 25
applications. The general policy stated in this document does not constitute a new regulation or
create what the courts refer to as a “binding norm.”
Jeff Duven
Acting Manager, Transport Airplane Directorate
Aircraft Certification Service
Attachment
5
Attachment 1
Terms
Table A-1 defines the use of key terms in this policy statement. The table describes the
intended functional impact.
Table A-1 Definition of Key Terms

Regulatory Acceptable Methods of Recommendations
Requirements Compliance (MOC)
Must Should Recommend
Language
Refers to a regulatory Refers to instructions for Refers to a
Meaning
requirement that is a particular MOC recommended
mandatory for design practice that is
approval optional
Functional No Design Approval Alternative MOC has to None, because it is
Impact if not met be approved by issue optional
paper.

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1

Definition of Key Terms

Current Regulatory and Advisory Material

AC 20-170, Integrated Modular Avionics Development, Verification, Integration, and Approval

Relevant Past Practice

“Shared set of flexible, reusable, and interoperable hardware and software

As stated in AC 20-170, paragraph 1-4.d, an IMA system is defined by the system

5. Relevancy of the Guidance Contained in AC 20-170. The guidance provided in

a. Fits the definition of an IMA in paragraph 2,

b. Resembles one or more of the examples of Annex D of RTCA/DO-297 in

Note: As indicated in paragraph 4, the lists of IMA key characteristics in Tables 1

6. Technical Standard Orders (TSO) and Relevance of AC 20-170. The presence or

Table A-1 Definition of Key Terms

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