STEINBEIS TRANSFERZENTRUM AERODYNAMIK FLUGZEUG- UND LEICHTBAU

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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
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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

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über den Vortrag und den Vortragenden
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über den Vortrag und den Vortragenden

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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

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EASA regulations system
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new EASA Fees Charges regulation

• EASA committee (all member states) voted
  positively for new FC regulation on 16.4.07
• still the political will iscertification
  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 !!

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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

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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

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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

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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

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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

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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

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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

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Part M maintenance / cont. airworthiness (cont.)

• resulting Rulemaking activities
• M.005 Pilot-owner maintenancelooks into Annex
  VIII of Part M
• M.017 review NPA 7/2005looks into possible
  relaxations of Part M for small aviation
  possible results range fromtotal new Part M
  Light to amended AMC
• MDM.032 simpler rules for small aviationnot
  only focused on maintenance but will have
  possibly strong impact there
• what are the results right now?

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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 ANDproposed 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

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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

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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

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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

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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

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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)

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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 B3coming from the
  sophisticated side, complex
• new license especially designed for light
  aviationELA basic ELA fullcoming from
  existing air sport definitions, simpler
• NPA published, open for comments until 28.6.2008
• thereafter internal consultation, CRD, opinion,

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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

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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

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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

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Quintessenz zum Schluß

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