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Can differences be established from what is defined in the technical instructions?

Yes, provided that there is no breach of the applicable rules. It is contemplated in the technical instructions themselves as the Alternative Means of Compliance (MAC).

Further details can be found in paragraph 7 of APTO-15-ITC-104 (Operational Safety/Technical Instructions) and in point 2 of the unique additional provision of Order TMA/692/2020 for the technical instruction for fuel supply.