Bericht die Entwicklungen bei der EASA, Luftsport und EASA Bericht die Entwicklungen bei der EASA, über Part M, Gebühren und mehr… von Werner “micro” Scholz, Sprecher der European Sailplane Manufacturers Tagung Technik des BWLV, Stuttgart 5.4.2008

über den Vortrag und den Vortragenden: Auszug aus den Berichten für die Europäischen Segelflugzeughersteller “Mer könnet alles nua koi Hochdeutsch – deshalb Folien in Neudeutsch Werner “micro” Scholz: Segelflieger seit 1980 Akaflieg Stuttgart Icaré Solar-Motorsegler Rolladen-Schneider STZ-AFL – Sprecher der Hersteller kein Prüfer……

über den Vortrag und den Vortragenden:

über den Vortrag und den Vortragenden:

EASA – the most important topics in 2007/08: new Fees & Charges regulation Part M – maintenance / continuing airworthiness Part 66 – maintenance staff MDM.032 – simple rules for small aviation new / closed topics since 2005: Certification of sailplane equipment crashworthiness of glider cockpits

EASA – regulations system:

new EASA Fees & Charges regulation EASA committee (all member states) voted positively for new F&C regulation on 16.4.07 still the “political will” is: certification shall be paid by the industry EASA certification costs approx. 45 Mio. € per year most 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 !!

new EASA basic regulation 0216/2008: published in the European Journal on 19.3.2008 and will enter into force 20 days later EASA 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 Europe definition of “commercial activities” clarification of Annex II definitions

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 until 28.9.2008 this 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

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 20.000 gliders in Europe new organisations / new procedures needed ill fitting to inspections by free-time personnel

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 / CAMO mostly 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 glider issuance of ARC based on paperwork not necessarily on physical inspection

Part M – maintenance / cont. airworthiness (cont.) most problematic aspects for small aviation: the role of existing inspectors / inspection organisations is still unclear repair 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 there member states have nevertheless already changed national training / licensing systems everyone is waiting for the big bang in September ´08

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 existing manufacturers also have to apply if they want to conduct maintenance on their own products contrary opinions in supervising NAA about possible combination within organisation manuals EASA fees & charges do normally not apply for European maintenance organisations but set a very high example of possible fees

Part M – maintenance / cont. airworthiness (cont.) most problematic aspects for small aviation: complexity of Part M and related regulations text is full of abbreviations / cross-references making it difficult to read official translations are sometimes inconsistent important AMC material only available in English due to ongoing rulemaking activities (see next slide) nobody knows what will be the basis after 28.9.2008

Part M – maintenance / cont. airworthiness (cont.) resulting Rulemaking activities: M.005 “Pilot-owner maintenance”; looks into Annex VIII of Part M M.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 there what are the results right now?

Part M – maintenance / cont. airworthiness (cont.) Comment Response Document (CRD) “Part M”: Notice of proposed amendment NPA 2007-08 published 28.6.2007 end of comment phase on 13.10.2007 with 661 comments from 149 National Aviation Authorities, organisations and persons CRD lists ALL comments plus regarding EASA “answers” CRD only available in English language contains furthermore general comments and explanations, time schedule AND: proposed new regulation … including complete Part M “new” comment period until 6.5.2008 after that EASA will issue an “opinion” EC commission will issue regulations change based on this opinion

Part M – maintenance / cont. airworthiness (cont.) Comment Response Document (CRD) “Part M”: transition provisions grandfathering of continuing airworthiness management organisations (= CAMO) for 1 year grandfathering of maintenance organisations approvals (= Subpart F) for 1 year issuance of ARC possible by competent authority and by existing organisations for 1 year existing national certifying staff will be able to continue all excluding commercial air transport

Part M – maintenance / cont. airworthiness (cont.) Comment Response Document (CRD) “Part M”: issuance of ARC below 2730 kg MTOM a CAMO with regarding approval might issue the ARC directly alternatively 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

Part M – maintenance / cont. airworthiness (cont.) Comment Response Document (CRD) “Part M”: approval of maintenance program by the competent authority by a CAMO via a so called “indirect approval procedure” approved by the competent authority

Part M – maintenance / cont. airworthiness (cont.) Comment Response Document (CRD) “Part M”: Pilot-owner maintenance the 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

Part M – maintenance / cont. airworthiness (cont.) Comment Response Document (CRD) “Part M”: Introduction of ELA system relaxation 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)

Part 66 – maintenance / certifying staff NPA 2008-03 “Part 66”: new (maintenance) licenses for light aviation today national rules are valid for sailplanes and balloons new 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 until 28.6.2008 thereafter internal consultation, CRD, opinion,…

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 2005 rather big working group with strong representation of sporting organisations long 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

MDM.032 – simple rules for small aviation (cont.) MDM.032 has to look into all aspects: initial / continuing airworthiness, licensing, operations A-NPA 14/2006 resulted in over 4000 answers EASA encouraged “creative brainstorming” but then limited possible alternative paths possible delegation of tasks to non-authority organisations low control level (in maintenance, in licensing, for medicals) based on the small risk level for third parties is not accepted by EASA / EC regarding NPA is expected soon

New topics since 2005: Sailplane equipment changes in AMC material of Part 21 and Part M have been introduced and are published typical equipment counts as “standard part” and therefore no Form One is needed nevertheless still a minor change… …and therefore the installation still has to be approved some NAA doubt the legal basis (“only AMC”) EASA has acted upon the initiative of the sailplane manufacturers – one positive example

Quintessenz zum Schluß: Es bleibt spannend EASA beginnt immerhin zu erkennen, dass es auch ein (Flieger-)Leben vor EASA gab!!! Vielen Dank !!!