Start with the certification basis, not the DER
Before you search for a DER, pin down what you are certifying and against what. A Part 23 STC for an avionics installation, a Part 25 amended TC for an electrical system change, and a TSO authorization for a new LRU each pull in different regulations, advisory circulars and industry standards. That basis decides which DER discipline and which delegated authority you need.
Write down the certification path (TC, ATC, STC, TSOA or Part 43 major alteration), the applicable 14 CFR parts and amendment levels, and the standards in play, such as DO-178C, DO-254, DO-160 or ARP4754B. That one page is what a DER will ask for in the first conversation.
Match the discipline and the authority
The FAA appoints DERs in nine disciplines: Acoustical, Engine, Flight Analyst, Flight Test Pilot, Powerplant, Propeller, Radio, Structural, and Systems and Equipment. Software, electrical systems and most avionics work fall under Systems and Equipment; communication and navigation radio installations fall under Radio.
The discipline is only half of it. Each DER's appointment carries a defined scope of authority, recorded in the FAA Designee Management System (DMS). A Software DER may be limited by software level; an Electrical DER may be limited to certain system types or to recommending rather than approving. Ask the DER directly what their authority covers and whether it includes your aircraft category, system and level.
Where to look
- FAA Designee Locator: the FAA's public search for individual designees, filterable by designee type, discipline and location. Consultant DERs are listed there.
- Your FAA certification branch (ACO/ACB): project managers can tell you which disciplines they expect DER involvement in and may point you to designees who regularly support similar projects.
- Your supplier and OEM network: avionics suppliers and STC holders usually know which consultant DERs are responsive and which have authority in niche areas such as Level A software or lightning direct effects.
- Consulting firms with DERs on staff: a firm such as Aries Aero Systems can cover several disciplines on one program and back the DER with engineers for the compliance work itself.
Questions to ask before you engage
- 01What discipline and scope of authority do you hold, and does it cover this system, level and aircraft category?
- 02Will you approve data or recommend approval on this project, and what will the FAA retain?
- 03Which FAA branch manages your appointment, and have you worked with the branch on this project?
- 04How do you document findings? Expect a comment/response matrix tracked to closure, not email threads.
- 05What is your availability for the planned Stages of Involvement or conformity and test events?
- 06How do you bill: hourly, or fixed price per review, audit or deliverable?
Engage at planning
The most expensive DER engagement is the one that starts at the end. Findings raised against the certification plan, the PSAC or the PHAC are document edits. The same findings raised at a final software review or a certification flight test become rework, re-verification and schedule slips.
Bring the DER in when the certification plan and compliance checklist are drafted but before they are submitted. Agree with the DER and the FAA project manager on which data the DER will approve, which they will recommend, and which the FAA will retain, and record that split in the plan.
What a good engagement looks like
- A kickoff that confirms the certification basis, the delegation split and the schedule of reviews.
- Written findings against plans and standards, closed before the first FAA Stage of Involvement.
- Findings tracked in one comment/response matrix through each review, with dispositions recorded.
- Close-out with findings of compliance documented on FAA Form 8110-3 within the DER's authority.