Präsentation zum Thema: "Bericht die Entwicklungen bei der EASA,"— Präsentation transkript:
1 Bericht die Entwicklungen bei der EASA, Luftsport und EASABericht die Entwicklungen bei der EASA,über Part M, Gebühren und mehr…vonWerner “micro” Scholz, Sprecher derEuropean Sailplane ManufacturersTagung Technik des BWLV,Stuttgart
2 über den Vortrag und den Vortragenden: Auszug aus den Berichten für die Europäischen Segelflugzeughersteller“Mer könnet alles nua koi Hochdeutsch – deshalb Folien in NeudeutschWerner “micro” Scholz:Segelflieger seit 1980Akaflieg StuttgartIcaré Solar-MotorseglerRolladen-SchneiderSTZ-AFL – Sprecher der Herstellerkein Prüfer……
5 EASA – the most important topics in 2007/08: new Fees & Charges regulationPart M – maintenance / continuing airworthinessPart 66 – maintenance staffMDM.032 – simple rules for small aviationnew / closed topics since 2005:Certification of sailplane equipmentcrashworthiness of glider cockpits
7 new EASA Fees & Charges regulation EASA committee (all member states) voted positively for new F&C regulation onstill the “political will” is: certification shall be paid by the industryEASA certification costs approx. 45 Mio. € per yearmost fees are now “flat fees” (not charged on an hourly basis which has been set to 225€)Anmerkung: nicht zu verwechseln mit kommender neuer LuftKostV !!
8 new EASA basic regulation 0216/2008: published in the European Journal on and will enter into force 20 days laterEASA will be also responsible for “operations” (OPS) and licenses (FCL)basic rules for OPS and FCL (e.g. medicals will not be dropped completely, language proficiency, etc.)adoption of ICAO rules in Europedefinition of “commercial activities”clarification of Annex II definitions
9 Part M – maintenance / cont. airworthiness Part M is published and in use since 2003, nevertheless the member states opted to use national regulation for operations excluding commercial air transport untilthis date is still fixed – it is written in 2042/2003 and can therefore only be changed by the European Commission (not EASA)EASA stated always that Part M “was written to let existing maintenance continue”nevertheless EASA has already accepted that the regulation is too onerous for small aviation
10 Part M – maintenance / cont. airworthiness (cont.) most problematic aspects for small aviation:the “renewal” (now: Airworthines Review Certificate – ARC) will not be issued directly after the physical inspection but by the competent authority or by an organisation which is responsible for continuing airworthiness (CAMO / controlled environment)many administrative steps (= delays expected!)difficult for more than gliders in Europenew organisations / new procedures neededill fitting to inspections by free-time personnel
11 Part M – maintenance / cont. airworthiness (cont.) most problematic aspects for small aviation:the aircraft maintenance documentation (now: maintenance program) has to be approved by the competent authority / CAMOmostly the maint. programs are consisting of manufacturers information plus individual inspection reports – nevertheless approval is needed!some member states already ask for separate maint. programs (30 pages and thicker!)inspectors will spend more time with paper instead of checking the gliderissuance of ARC based on paperwork not necessarily on physical inspection
12 Part M – maintenance / cont. airworthiness (cont.) most problematic aspects for small aviation:the role of existing inspectors / inspection organisations is still unclearrepair shops and gliding federations are unsure if they should apply for Subpart F (maintenance) and/or Subpart G (CAMO)the Part 66 about maintenance & inspection (now: certifying staff) does not apply for gliders – national rules apply theremember states have nevertheless already changed national training / licensing systemseveryone is waiting for the big bang in September ´08
13 Part M – maintenance / cont. airworthiness (cont.) most problematic aspects for small aviation:multitude of organisation approvals“full service” can be offered only if Subpart F & G plus eventually Part 145 approval is existingmanufacturers also have to apply if they want to conduct maintenance on their own productscontrary opinions in supervising NAA about possible combination within organisation manualsEASA fees & charges do normally not apply for European maintenance organisations but set a very high example of possible fees
14 Part M – maintenance / cont. airworthiness (cont.) most problematic aspects for small aviation:complexity of Part M and related regulationstext is full of abbreviations / cross-references making it difficult to readofficial translations are sometimes inconsistentimportant AMC material only available in Englishdue to ongoing rulemaking activities (see next slide) nobody knows what will be the basis after
15 Part M – maintenance / cont. airworthiness (cont.) resulting Rulemaking activities:M.005 “Pilot-owner maintenance”; looks into Annex VIII of Part MM.017 “review NPA 7/2005”; looks into possible relaxations of Part M for small aviation – possible results range from “total new Part M Light” to “amended AMC”MDM.032 “simpler rules for small aviation”; not only focused on maintenance but will have possibly strong impact therewhat are the results right now?
16 Part M – maintenance / cont. airworthiness (cont.) Comment Response Document (CRD) “Part M”:Notice of proposed amendment NPApublishedend of comment phase on with 661 comments from 149 National Aviation Authorities, organisations and personsCRD lists ALL comments plus regarding EASA “answers”CRD only available in English languagecontains furthermore general comments and explanations, time schedule AND: proposed new regulation … including complete Part M “new”comment period until after that EASA will issue an “opinion”EC commission will issue regulations change based on this opinion
17 Part M – maintenance / cont. airworthiness (cont.) Comment Response Document (CRD) “Part M”:transition provisionsgrandfathering of continuing airworthiness management organisations (= CAMO) for 1 yeargrandfathering of maintenance organisations approvals (= Subpart F) for 1 yearissuance of ARC possible by competent authority and by existing organisations for 1 yearexisting national certifying staff will be able to continueall excluding commercial air transport
18 Part M – maintenance / cont. airworthiness (cont.) Comment Response Document (CRD) “Part M”:issuance of ARCbelow 2730 kg MTOM a CAMO with regarding approval might issue the ARC directlyalternatively the competent authority can issue the ARC upon recommendation by a CAMO not having this approval or upon request by the owner or in case of a safety threat
19 Part M – maintenance / cont. airworthiness (cont.) Comment Response Document (CRD) “Part M”:approval of maintenance programby the competent authorityby a CAMO via a so called “indirect approval procedure” approved by the competent authority
20 Part M – maintenance / cont. airworthiness (cont.) Comment Response Document (CRD) “Part M”:Pilot-owner maintenancethe lists of possible pilot-owner maintenance tasks in Annex VIII has been adapted to different types of aircraft (in the moment only fitting to small motor aeroplanes)these new lists are now part of the Accepted Means of Compliance (AMC) material of Part M
21 Part M – maintenance / cont. airworthiness (cont.) Comment Response Document (CRD) “Part M”:Introduction of ELA systemrelaxation of certain rules for aircraft below 2000 kg not used in commercial air transport “ELA 2”even more relaxed regulation for aircraft below 1000 kg not used in commercial air transport “ELA 1”ELA 1 / 2 will not be an new aircraft class (like e.g. the LSA class in the USA) but describe the less stringent regulations for small aircraft in Europe (Rulemaking activity MDM.032)
22 Part 66 – maintenance / certifying staff NPA “Part 66”:new (maintenance) licenses for light aviationtoday national rules are valid for sailplanes and balloonsnew license which is defined according to existing Part 66 licenses: B3 “coming from the sophisticated side, complex”new license especially designed for light aviation: ELA basic & ELA full “coming from existing air sport definitions, simpler”NPA published, open for comments untilthereafter internal consultation, CRD, opinion,…
23 MDM.032 – simple rules for small aviation EASA agreed that regulations are too stringent for small and recreational aviation and therefore started MDM.032 task in 2005rather big working group with strong representation of sporting organisationslong ongoing debate about possible change of Annex II (= not EASA but under national law)even longer debate about the definition of “non-commercial activities” for which the simple rules will be limited
24 MDM.032 – simple rules for small aviation (cont.) MDM.032 has to look into all aspects: initial / continuing airworthiness, licensing, operationsA-NPA 14/2006 resulted in over 4000 answersEASA encouraged “creative brainstorming” but then limited possible alternative pathspossible delegation of tasks to non-authority organisationslow control level (in maintenance, in licensing, for medicals) based on the small risk level for third parties is not accepted by EASA / ECregarding NPA is expected soon
25 New topics since 2005: Sailplane equipment changes in AMC material of Part 21 and Part M have been introduced and are publishedtypical equipment counts as “standard part” and therefore no Form One is needednevertheless still a minor change……and therefore the installation still has to be approvedsome NAA doubt the legal basis (“only AMC”)EASA has acted upon the initiative of the sailplane manufacturers – one positive example
26 Quintessenz zum Schluß: Es bleibt spannendEASA beginnt immerhin zu erkennen, dass es auch ein (Flieger-)Leben vor EASA gab!!!Vielen Dank !!!