Präsentation zum Thema: "Bericht über die Arbeit des Verbands deutscher Segelflugzeughersteller"— Präsentation transkript:
1 Bericht über die Arbeit des Verbands deutscher Segelflugzeughersteller Segelfliegen und EASABericht über die Arbeit des Verbands deutscher Segelflugzeugherstellerüber Part M, Gebühren und mehr…vonWerner “micro” Scholz, Sprecher derEuropean Sailplane ManufacturersAERO, Friedrichshafen
2 über den Vortrag und den Vortragenden: Auszug aus dem Bericht 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: new Fees & Charges regulationPart M – maintenance / cont. airworthinessMDM.032 – simple rules for small aviationnew / closed topics since 2005:Certification of sailplane equipmentcrashworthiness of glider cockpits
6 new Fees & Charges regulation EASA committee (all member states) voted positively for new F&C regulation on 16.4.still 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)
7 new Fees & Charges regulation (cont.) all fees are higher now (by a factor of at least 1.5)changes on geometry and/or power-plant are charged as new designsfees for non-turbine engines are much higher than those for sailplanes/motorglidersprice for 1 EASA working hour: 225 €
8 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
9 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
10 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
11 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
12 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
13 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
14 Part M – maintenance / cont. airworthiness (cont.) ongoing 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 thereso what is in discussion right now?
15 Part M – maintenance / cont. airworthiness (cont.) possible relaxations from the rulemaking groups:issuance of ARCbelow a certain weight limit excluding commercial air transport the CAMO making the inspection might issue the ARC directlytherefore no obligation to go the competent authority or to contract the responsibility to a CAMOBig question: do the NAA (= competent authorities) whish to delegate the ARC issuing?
16 Part M – maintenance / cont. airworthiness (cont.) possible relaxations from the rulemaking groups:approval of maintenance programthe CAMO making the inspection might approve also the according maint. programperhaps it could be possible to shortcut this approval as long as the “normal” maintenance documents are been usedBig question again: do the NAA (= competent authorities) whish to delegate the approvals of the maint. programs?
17 Part M – maintenance / cont. airworthiness (cont.) possible relaxations from the rulemaking groups:Pilot-owner maintenancethe lists of possible pilot-owner maintenance tasks in Annex VIII are been adapted to different types of aircraft (in the moment only fitting to small motor aeroplanes)
18 Part M – maintenance / cont. airworthiness (cont.) possible relaxations from the rulemaking groups:general aspects of possible alterationsdue to the specified rulemaking process (ToR > Working Group > RIA > NPA > Working Group > CRD > EASA opinion > Commission Decision) changes will be published “in the last second” (not before spring/summer 2008)therefore any action by owners / manufacturers / maintenance organisation / authorities is more guessing instead of planningEASA / European Commission is been urged to relax the time limit
19 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 organisations … but no representative of industry?!long ongoing debate about possible “candidates for EASA” which now belong to Annex II (= fall under national law)even longer debate about the definition of “non-commercial activities” for which the simple rules will be limited
20 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 pathsdelegation of tasks to non-authority organisations will not be pushed by EASA – it is doubtful if the member states will do thislow control level (in maintenance, in licensing, for medicals) based on the small risk level for third parties is not accepted by EASA / EC
21 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…some NAA doubt the legal basis (“only AMC”)EASA has acted upon the initiative of the sailplane manufacturers – one positive example
22 New topics since 2005 (cont.): – crashworthiness of glider cockpitsEASA agreed to use existing structure within gliding movement (= sailplane development panel of OSTIV) for rulemaking activityresults of discussion within rulemaking activity:existing OSTIV airworthiness standards use higher levels of acceleration for crash landing casestest results of several German research programs were analyzed and incorporatedhigher (static) load levels by a factor of 1.5 proposedno dynamic tests required for certificationparticipation of industry, authorities, research organisations within the activityactual statistics and accidents show need for adequate crashworthiness
23 New topics since 2005 (cont.): Bio-Fuel – Ethanol in automotive gasolineseveral member states allow / enforce addition of ethanol into automotive gasolinepossible technical problems:vapor lock due to higher volatilitycorrosion due to water solved within the alcoholchemical attack upon tanks, fuel lines, seals, etc. by the ethanol or other additivesreduced lubrication within two-stroke engines using pre-mixed fuelneither EASA nor national authorities have shown much interest into solving / researching the problemsin the moment the responsibility is with the pilot and the TC holder…
24 Quintessenz zum Schluß: Es bleibt spannendEASA beginnt immerhin zu erkennen, dass es auch ein (Flieger-)Leben vor EASA gab!!!Vielen Dank !!!