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1. TERMS AND DEFINITIONS

2. GENERAL

Unofficial translation

Approved by 

Deputy Head of
Federal Air Transport Agency
M.Bulanov

[signed]

April 9, 2017

METHODICAL RECOMMENDATIONS
FOR ORGANIZATION AND CONDUCTION IN THE FEDERAL AIR TRANSPORT AGENCY OF THE PROCESS TO ESTABLISH THE COMPLIANCE OF THE LEGAL ENTITIES ENGAGED IN AIRCRAFT AND AERONAUTICAL PRODUCTS DESIGN WITH THE ESTABLISHED REQUIREMENTS    
2017

Aeronautical products— with regard to these Guidelines, the aeronautical products are the civil aircraft (hereinafter — AC), aviation engine, propeller and appliances, including avionics.
Aviation Register of the Russian Federation  (hereinafter – Aviation Register of Russia) – federal autonomous enterprise subordinated to the Authorized body, mainly tasked with supporting the execution by the founder of the functions established in the legislation of the Russian Federation.
Aviation  Rules (AR) - airworthiness set of procedures, rules, that are mandatory for the safety and environmental protection.
Safety - a condition in which the risks associated with aviation activities related to the operation of aircraft or directly providing such operation are reduced to an acceptable level and controlled.
Appliance Minor Change — modification, which does not lead to the essential change of the appliance type design or its characteristics.
Aeronautical Product Minor Change – modification, which does not essentially effect the aeronautical product airworthiness and its environmental effect.
Appliance Major Change - modification, which leads to the essential change of the appliance type design or its characteristics.
Aeronautical Product Major Change - modification, which essentially effects the aeronautical product airworthiness and its environmental effect
Civil AC - aircraft classified in accordance with the air legislation as belonging to civil aviation, and used to meet the needs of citizens and the economy, including air transportation and aerial works.
Type Certificate (approval document) Holder – Applicant that received the Type Certificate or other approval document in accordance with the established procedure.
Compliance documentation - documentation containing the results of calculations, inspections, tests and assessments obtained during the certification of the aeronautical product or appliances qualification and establishing their compliance with applicable requirements.
Supplementary Type Certificate – approval document that is issued in accordance with the established procedure to the applicant who is not the type certificate holder of the aeronautical product and proving compliance of the aeronautical product with the applicable requirements associated with the modification introduced in the type design by the Applicant.
Applicant - legal entity that has submitted an application to the Authorized body for obtaining of the approval document.
Application - application of a legal entity (applicant), submitted to the Authorized body for obtaining an approval document.
Design documentation - a set of design documents containing, depending on their purpose, the data necessary for the design, manufacture, control, acceptance, delivery, operation and repair of the aeronautical product.
Airworthiness - aeronautical product conditions, defined by the applicable requirements implemented in its design and characteristics, allowing a safe operation within the established operational limitations and operating methods.
Modification – any change to the type design of the aeronautical product or appliance
Independent Inspection - organizational structure accredited by the Authorized body for the implementation of control functions in the design organization.
Airworthiness Requirements - aviation rules, which contain requirements for the design and performance of the aeronautical product aimed at ensuring flight safety.
Aeronautical Product – AC type, engine type, propeller type.
Major Change Approval  - document issued to the type certificate holder  and proving the compliance of the aeronautical product with the applicable requirements related to the Major Change made to its type design.
Approval for appliance installation - a document previously issued to the aeronautical product designer allowing the use of appliance.
Approval letter for appliance - a document issued to the appliance designer and proving the compliance of the vendor item type with the requirements of the qualification basis allowing the vendor item use on a particular aeronautical product.
Approval Document - document issued by the Authorized body proving compliance with applicable requirements.
Designer - legal entity engaged in the design of aeronautical product.
Safety Risk - the expected probability and severity of the consequences or results of the hazard.
Appliance Design Approval - a document issued to the appliance designer and proving the compliance of the type with the requirements of the qualification basis, allowing the use of appliance of this type on various aeronautical products.
Design Organization Approval - a document issued to the Designer proving that the Design organization meets the applicable requirements.

Type Certificate - the document issued to the designer and proving compliance of the established type design of the aeronautical products with the requirements of the certification basis.
Certification Basis - a document containing airworthiness and environmental requirements applicable to a particular aeronautical product.
Certification Center (CC)  - organization accredited by the Authorized body to participate in the works, within the scope of application submitted by the applicant to the Authorized body, for the purpose of expert evaluation of the results of works.
Design Assurance System - organizational structure, responsibilities, procedures and resources to ensure the proper functioning of the design organization.
Safety Management System (SMS) - a comprehensive approach to safety management, including the necessary organizational structure, hierarchy of responsibilities, guidelines and procedures.
Aeronautical Product Quality Management System (AP QMS)  - activities through which the organization sets its goals and identifies the processes and resources required to achieve the desired results in order to meet the demands of consumers and the desire to exceed the expectations of consumers.
Product specifications - a document containing information about the standard design, parameters and characteristics of the manufactured aeronautical product, which are subject to control and evaluation in the manufacture and acceptance of product as a finished product.
Type Design - the design of the aeronautical product, reflected in its design and operational documentation, approved in accordance with the requirements of aviation regulations, certified by the type certificate.
Authorized Body - Federal Executive body authorized by the Government of the Russian Federation to carry out substantiation of compliance with the established requirements.
Operational Documentation - documentation containing operational limitations and regulating flight operation, maintenance, airworthiness during the aeronautical product operation.
Export Certificate - the document issued for the exported specimen of the certified aeronautical product and proving compliance of the specimen to requirements of the importing state.

Present Methodical recommendations were developed to support the Federal Air Transport Agency in enforcing requirements established by the Air Code of the Russian Federation dated 19.03.1997 N 60-ФЗ, Order of the Government of the Russian Federation dated 28.11.2015 No. 1283 « On amending and termination some of the acts of the Government of the Russian Federation » and Order of the Government of the Russian Federation dated 07.10.2016 No. 1011 «On amending some of the acts of the Government of the Russian Federation and terminating some clauses of some of the acts of the Government of the Russian Federation» to confirm the compliance of legal entities engaged in the aircraft and aeronautical products design (hereinafter -  compliance confirmation).
Present Methodical recommendations define the procedures related to the Federal Air Transport Agency internal process, interaction with the Federal autonomous organization «Aviation Register of the Russian Federation» (hereinafter - Aviation Register of Russia) and accredited certification centers (those that are involved) to  establish the compliance of legal entities designing the aircraft and other aeronautical products to the existing requirements.
The design organization approval is issued by the Federal Air Transport Agency  based on the conclusion of the Aviation Register of Russia resulting from the review of the Application and supporting documents, and the on-site check signed by the members of the Commission. The conclusion states on the possibility to grant the approval document to the design organization on the basis undertaken compliance activities.
1.1	Present Methodical recommendations are intended to be used by:
-	Departments of the Federal Air Transport Agency, carrying out functions for the provision of public services for the compliance substantiation with the applicable requirements of aircraft and other aircraft equipment the design organizations;
-	Aviation Register of Russia;
-	certification centers accredited by the Federal Air Transport Agency, which are involved to establish compliance of the legal entities designing the aircraft and other aeronautical products; 
-	legal entities (hereinafter - Applicants) submitting the Application for Certification as organizations engaged in the aircraft and aeronautical products design (hereinafter  - Aeronautical products designers), which are
-	designers applying for the mandatory certification of the aircraft, aircraft engine, propeller or aircraft avionics of the civil aircraft  in accordance with the paragraph 3 Article 8  of the Air Laws Regulations of the Russian Federation (hereinafter  - Air Laws Regulations);
-	designers holding the Type certificate, operational suitability certificate, or any other act of the civil aircraft type design approval issued before the January,1 1967;
-	designers of modifications of civil aircraft type design, aircraft engine and propeller as per the paragraph 4 of Article 37 of the Air Code, which are not holders of the Type certificate, operational suitability certificate, or any other act of the civil aircraft type design approval issued before January,1 1967;
1.2	The confirmation of compliance of designers with the applicable requirements is conducted within the scope of declared activity. 
1.3	Foreign designers might apply for the Russian certification and obtain it if found compliant with the applicable requirements.
1.4	Individual persons may not apply for Design Organization Approval.
1.5	Design of aeronautical products without Design Organization Approval is forbidden.
1.6	Design Organization Approval might be issued both to the aircraft developer and aeronautical products developer or in various combination of both.
Section 2. Design Organization Approval (DOA) procedures 
2.1	Applicability
Present Methodical recommendations contain approval procedures for legal entities that develop aircraft and other aeronautical products – Designers, as well as rights and obligations of the applicants to obtain the Design Organization Approval (DOA) and DOA Holders.
Any organization that for the first time submits to Federal Air Transport Agency of Russia (FATA) an application for obtaining Type Certificate/ Supplemental Type Certificate or Certificate for auxiliary engine and other aeronautical product shall apply for Design Organization Approval Certificate.
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2.2	Application submission and review
Application for obtaining DOA or changes to a DOA shall be submitted to FATA.
The application shall be supported by:
-	license for aeronautical product development (if so stipulated by the legislation);
-	copies of basic documents certified under a notarial procedure;
-	organizational structure;
-	quality manual or similar document;
-	flights safety control manuals for aircraft being under design/ development and under operation by the organization;
-	list of documents, which are effective within organization and which control Designer functions;
-	data on qualifications and professional background of the top managers and other employees within organization, who are responsible for making decisions that affect aeronautical product airworthiness and environment protection;
-	information on the applicants’ focal to liaise with FATA, Aviation Register of Russia during certification procedures;
-	data on operational background of the organization in terms of aeronautical product development, production and operation control;  
- list of developed aeronautical products or their modifications;
FATA reviews the submitted application and supporting documents to establish that composition and content of the submitted documents enable to accept the Application or to request the provision of supplementary data to admit the Application.
FATA by its decision sends the application and supporting documents to the Aviation Register for analysis of the submitted documents.
Based on the results of the application and supporting documents’ review the Aviation Register prepares conclusion on a positive confirmation of compliance and sends it to FATA.
To perform on-site checks, FATA appoints a committee by way of an order. The composition of the committee is defined by FATA Director General.
On-site check is performed on the basis of checklists, where the applicant conformity/non-conformity to the established requirements is marked.
Based on checklists filling after completion of check a report is commissioned, which is signed by the members of the committee.
The report contains information about applicant conformity/non-conformity to the established requirements.
2.3	Issue of DOA 
If the report contains information about the applicant conformity to the established requirements, FATA issues the certificate.
If there are reasons for certificate issue refusal, FATA makes a decision to refuse to issue a certificate.
FATA informs Designer about the decision made.
2.4	Aeronautical product quality management system (AP QMS) 
Designer shows FATA committee that aeronautical product quality management system (AP QMS) has been integrated and maintained and is capable to provide constant monitoring of the development, certification and operation of those aeronautical products and its modifications, that are within the scope of the Application.
AP QMS ensures development of the aeronautical products, which conform to the respective requirements in part of airworthiness and environment protection and its further sustainability.
AP QMS defines allocation of responsibilities, operating procedures and resources required to ensure proper functioning of the Designer with respect to its current structure.
Designer submits for consideration a Quality manual (or other document), which establishes directly or with the use of references the conformity to international standard ISO 9001:2015 “Quality management systems. Requirements”:
- the organization has adopted a process approach in developing, integrating and improving the effectiveness of the quality management system in order to improve customer satisfaction by meeting the requirements of relevant airworthiness standards and requirements for environmental protection from aviation impact;
-	the Concept of risk - oriented thinking is implemented in the organization, as it plans and implements actions in response to risks and capabilities;
-	the top management have developed, integrated and maintains a quality policy that is accessible, up-to-date, brought to the employees’ knowledge, understood by them and applied in the organization;
-	the top management have established such a state in the organization, when responsibilities and duties  are allocated, brought to the executors’ knowledge and understood in the organization.
-	the organization determines the risks and capabilities for which response actions are required to prevent or reduce incidents or accidents that occur or are likely to occur with aeronautical products developed by the organization;
-	 the organization plans and implements actions to respond to these risks and to assess their impact;
-	provision is made in the organization for internal control of the aeronautical products QMS records keeping, their conformity to the effective structure and functions of the Designer. Control procedure should ensure the independence of the inspectors from the audited, as well as information sharing with the person or group of persons responsible for the adoption of corrective measures, detection of the system shortfalls and violations from the procedures established in the procedures system;
-	the organization has implemented a design assurance system, where all planned and systematic actions provide sufficient confidence that an organization can develop products or components in accordance with applicable certification requirements and environment protection requirements;
-	the personnel like “compliance engineers” is in place. This personnel is responsible for approval of compliance documents by signing these documents, including test programs and data necessary to verify compliance with applicable requirements and environmental requirements, as specified in the compliance program and approval of technical content (sufficiency, technical accuracy ...), including any subsequent revisions of the manuals approved by FATA (Flight Manual, Airworthiness limitations Section, Continued Airworthiness Instructions, and the Certification Maintenance Requirement (CMR), where applicable). "Compliance Engineers" act as independent inspection for demonstration of compliance, which comprises verification by a person who hasn’t composed compliance data. Such a person may work together with persons who prepare compliance data;
-	the personnel is appointed from certification department, who is responsible for interface between Design organization, FATA and Aviation Register of Russia;
-	to design an aeronautical product or appliance in compliance with applicable certification and environmental requirements, it is required:
-	to show and confirm conformity to the requirements in part of environment protection, and
-	to demonstrate this compliance;
-	 functions of the structural divisions of the Designer, including the certification services, officials and specialists involved in the development and certification of the aeronautical products and its modifications, as well as in continuation of the aeronautical products airworthiness;
-	interface procedure between Designer,  FATA and Independent Inspection, as well procedure of information submission  to these organizations;
-	certification  process procedure and certification procedures implementation, including monitoring of the products intended for certification tests as well as their configurations;
-	records keeping that defines type design;
-	monitoring of the supplied materials, vendor items, sections, parts and appliances as well as works co-performers for conformity to the requirements established
-	Manufacturer interface procedure;
-	procedure for ensuring airworthiness of the approved type design in the course of operation and observation of the environmental requirements.
Quality Manual is introduced with revisions to reflect current state of the Design organization.
2.5	Safety management system (SMS) for Designer of aircraft, engines or propellers.
Designer demonstrates to FATA committee that safety management system has been integrated and maintained. It consists of 4 components and 12 elements that reflect minimum requirements:
1.	Policy and target to ensure flight safety of aircraft being under development, or already designed and being in operation:
1.1	Top management duties and responsibilities;
1.2	Safety responsibility hierarchical arrangement;
1.3	Appointment of the employees responsible for flights of the being under development, or already designed and being in operation;
1.4	Measures planning coordination in case of emergency;
1.5	SMS documentation.
2.	Risk control to ensure flight safety of aircraft being under development, or already designed and being in operation:
2.1	Hazard sources identification.
2.2	Assessment and mitigation of safety risks for the aircraft being under design/ development, or under operation by the organization.
3.	Ensuring flight safety of aircraft being under development, or already designed and being in operation:
3.1	Flights safety control and quantitative assessment of the aircraft being under design/ development, or under operation by the organization.
3.2	Revisions implementation.
3.3	Designer QMS constant development.
4.	Promotion of safety issues relevant to flight safety of aircraft being under development, or already designed and being in operation:
4.1	Personnel preparation and training.
4.2	Information exchange about flights safety of the aircraft being under design/ development, or under operation by the organization.
2.6	Designer shall demonstrate to FATA commission that:
-	All divisions maintain sufficient staff, which has necessary qualification, experience and authority required to perform assigned duties; and all of this, along with staff accommodation, work stations equipment and facilities, enables development of aeronautical products, which meet the airworthiness and environmental protection requirements, as well as assurance of this compliance later on when in service.
-	There is comprehensive and effective cooperation between and within the divisions on the airworthiness and environmental protection issues.
- Quality Manual with the detailed description or references to the Design Organization standards describing the following procedures:
procedure to ensure and maintain of the Designer’s personnel required skill level, including knowledge of documents of the aeronautical products quality system and certification system
procedure for periodic staff qualification (competence assessment), as well as qualification results presentation and recording
procedure for internal supervision of compliance with the documented quality system procedures and system compliance with the effective Design Organization structure and functions
procedure for cooperation with the Authorized Agency and Independent Inspection, which implement mandatory certification of aeronautical products at the design, testing, certification, serial production and operation stages
procedure for certification of aeronautical products under development, namely:
а)	development and approval of the plan of certification activities (calculations, simulation, aeronautical product or its prototype operating records review, aeronautical product certification (laboratory, bench, ground and flight) tests)
b)	certification activities accomplishment and results presentation
c) demonstration of aeronautical product readiness for certification tests
d)	preparation of application for leader test pilots participation in certification tests
e)	certification test operations metrology support
f)	qualification of test equipment used for certification tests
procedure for certification of type design modifications
procedure for compilation of appliances  list (including imported appliances to be installed on the aeronautical product) and supervision of appliances operations on the aeronautical product
procedure for design documentation management, namely:
а)	requirements for contents, structure and execution of design documentation, including design documentation in soft copies
b)	procedure of design documentation development, harmonization and approval
c)	procedure of design documentation development, harmonization, approval  and revision based on the results of certification tests (configuration management)
d)	management of design documentation developed by third parties
e)	development and approval of design documentation package describing the certified type design.
procedure for development and introduction of changes into software of the developed aeronautical products based on the results of the certification tests, with identification of the software version
procedure for compilation, keeping, storage and handling of the list of vendor items included into certified type design, with identification (in the list) of vendor items software versions
procedure for compilation, keeping, storage and handling of the list of critical structural components included into certified type design
procedure for assurance of quality of the supplied components and materials, and of rendered services for development of components by co-contractors, namely:
а)	establishment and formalization of requirements for performance of the components under development
b)	selection and supervision of organizations, which supply components and materials required for manufacturing of prototypes.
procedure for manufacturing and configuration control of prototypes, namely:
а)	assignment of Designer’s divisions responsible for supervision of prototypes manufacturing
b)	supervision of prototypes compliance with the design documentation, including prototypes manufactured by third parties
c)	development and execution of documents (logbook, certificate or any equivalent document), which show compliance of the aeronautical product designed for performance of a certain type of testing (as well as aeronautical products manufactured by third parties) with the design documentation
procedure for elaboration of a comprehensive production launch plan
procedure for release of design documentation and subsequent changes, which reflect type design modifications, for serial production
procedure for supervision of serial production of the certified aeronautical products, presentation of the supervision results and follow-up control of corrective actions
procedure for obtaining and reporting data on different events (flight accidents, incidents, failures, faults) occurred in the process of manufacturing of aeronautical products, in service, and during repair, as well as development of corrective and preventive actions
- Flight Safety Manual for aircraft under development or already designed and operated, with the detailed description or references to Design Organization standards
- Aircraft, engine or propeller Designer shall demonstrate to the Federal Air Transport Agency that it has developed and maintains the flight operations safety management system in accordance with the requirements of Russian Federation Government Regulation No. 1215 “On procedure of development and application of aircraft flight safety management systems, as well as collection and analysis of data on hazard and risk factors, which create a threat to civil aircraft flight safety, storage and exchange of this data”, dated 18.11.2014.
2.7	Changes in the aeronautical products quality management system and safety management system
Upon issuing the Design Organization Approval, each change in the aeronautical product quality assurance system and/or safety management system, which has significant impact on compliance with applicable requirements or assessment of aeronautical product compliance with the airworthiness and environmental protection requirements, shall be evaluated by the Design Organization Approval Holder to make sure that the Design Organization continues complying with applicable requirements upon implementation of this change.
Data on major changes and assessment of these changes agreed upon with the Independent Inspection shall be submitted by the Design Organization Approval Holder to the Federal Air Transport Agency.
Based on analysis of the obtained data, the Federal Air Transport Agency shall take decision on possibility and terms of further validity of the Design Organization Approval.
The Federal Air Transport Agency shall notify the Design Organization Approval Holder of the decision taken.
2.8	Design Organization Approval transfer
Design Organization Approval is not transferable.
2.9	Design Organization Approval scope of approval 
The Design Organization Approval scope of approval: types of design activities and approved organization functions; types and categories of aeronautical products, which are recognized as developed by this Design Organization.
The scope of approval is an integral part of the Design Organization Approval.

2.10	Design Organization Approval change
Each change in Design Organization Approval or its scope of approval requested by the Design Organization Approval Holder shall be approved by FATA. Application for change approval shall be submitted by the Design Organization Approval Holder in the prescribed format.
The change shall be made by the FATA provided that it is found that the Designer complies with the applicable requirements.
2.11	Design Organization Approval validity
The Design Organization Approval is valid from the date of its issue till the date of its suspension or cancellation by the Federal Air Transport Agency.
The Design Organization Approval terminates if the Design Organization Approval Holder is liquidated.
The Design Organization Approval can be suspended or terminated by the   Federal Air Transport Agency if:
-	Designer does not comply with the applicable requirements.
-	There is objective evidence that the Design Organization Approval Holder fails to provide adequate control over the certified aeronautical products.
-	The Design Organization Approval Holder refused to perform his duties.
The Federal Air Transport Agency shall notify the Design Organization Approval Holder of the decision on Design Organization Approval suspension or cancellation.
If the Design Organization Approval is cancelled, it shall be returned to the Federal Air Transport Agency.
2.12	Design Organization Approval renewal
The suspended Design Organization Approval can be renewed by the Federal Air Transport Agency as soon as the Designer eliminated the causes of the Design Organization Approval suspension.
2.13	Design Organization Approval Holder authorization
The Design Organization Approval Holder, with regard to the aeronautical products specified in the Design Organization Approval scope of approval, shall perform the following activities:
-	Development and modification of aeronautical products with proof of their compliance with the applicable requirements.
-	Classification of aeronautical products modifications as major or minor changes.
-	Certification of aeronautical products minor changes.
-	Issuance of technical publications for introduction of minor changes, without approval by the Federal Air Transport Agency (except for the documents to be approved directly by the Federal Air Transport Agency).
-	Specification of flight safety conditions to issue flight clearance for the aircraft, which do not comply with airworthiness requirements for the time being.
- Maintaining (within the Organization) of aeronautical products certification division and flight safety division subordinated directly to the Head of Design Organization.
-	Approval of repair documentation and revisions to this documentation.
2.14	Design Organization Approval 
-	Maintains aeronautical products quality management system in the state corresponding to the actual Design Organization structure, allocation of responsibilities and working procedures.
-	Maintains flight safety management system for the developed aeronautical products.
-	Ensures that Quality Manual and Flight Safety Manual are main guiding documents.
-	Supervises the certified aeronautical products compliance with the airworthiness and environmental protection requirements, and making sure that these aeronautical products are not in unsafe condition.
-	Supervises aeronautical products production, operation and repair control.
-	Maintains the system for recording and analysis of data on failures, faults, defects and other aviation incidents to develop and take corrective actions.
-	Reports to the Federal Air Transport Agency on failures, faults, defects and other aviation incidents, which have resulted or can result in unsafe condition of the aeronautical products.
-	Ensures the development and submission of engineering solutions to the Federal Air Transport Agency to enable issuance of Airworthiness Directives; taking timely measures on implementation of engineering solutions stipulated in the Airworthiness Directives.
-	Reports to the Federal Air Transport Agency on any changes in the aeronautical products quality management system and/or safety management system, which can require updating of data specified in the Design Organization Approval.
-	Supports periodic checks by the Federal Air Transport Agency Committee to prove validity of the Design Organization Approval.
2.15	Certification division for existing aeronautical products and flight safety division within the Design Organization
There shall be certification division and flight safety division (for the developed aeronautical products) within the Design Organization. These divisions shall apply Provisions approved by the Designer, shall be subordinated directly to the Head of Design Organization and shall coordinate activities of other divisions, which implement flight safety, airworthiness and environmental protection requirements applicable to the developed aeronautical products in the aeronautical products design and performance. Besides, these divisions shall exercise internal control over compliance with the certification and safety management procedures, as well as follow up the certification activities.
2.16	Aeronautical products certification testing conditions
Before initiation of certification (qualification) tests, the Designer and Independent Inspection (on Designer’s site) shall execute certain documents (logbook, certificate or any equivalent document) for each aeronautical product to be tested. These documents shall prove compliance of the aeronautical product with the design documentation and shall be executed according to the established procedure.
To establish type design, it is required to specify (in the documents executed based on the certification test results) the aeronautical product configuration, to which the test materials and findings on compliance with the airworthiness and environmental protection requirements apply.
The Designer shall admit to test flights test pilots (outside pilots of unmanned aircraft), who hold valid licenses and have rating sufficient for test flights performance. 
Before admitting to flights, the Applicant shall provide required training for the test pilots (outside pilots of unmanned aircraft) and check their readiness for flight operations according to the certification test programs.
2.17	Compliance verification
To check Design Organization Approval Holder compliance with the specified requirements, the Federal Air Transport Agency shall make inspection checks once every three years according to para. 2.2.