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not everyone has access to EC Regulation 3922/91;

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amendments to the above Regulation are outside the JAA’s control; and

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JAR–1 should not be a cross-reference document.

The DEFWG did accept that the proposal was likely to lead to divergence from ICAO, and did not find the other arguments compelling enough to embark on a fundamental rewrite of the JARs, and the ‘dis-harmonisation’ that this implies. The text of the Arrangements and 3922/91 (they are identical) will, however, be added as IEM to this definition. Additionally ICAO Doc 9569 does not have any of these terms in it.
One commentor preferred to see ‘certification’ instead of ‘type certification’, as this made the text more generic to all JAR–21 related issues, and not just JAR–21 Subpart B. The comment is agreed.