The Future of Maintenance in General Aviation

1
The Future ofMaintenance in General Aviation

• The perspective from the European sailplane
  manufacturers
• by
• Werner Scholz, Spokesman of the
• European Sailplane Manufacturers

2
Contents

• Introduction
• Basic comments regarding Part M
• Comparison of Part M with old status
• Summary and assessment of Part M

3
IntroductionWho are we - whom do we represent?

• The European sailplane manufacturers are
  represented by two associations
• Verband deutscher Segelflugzeughersteller,
  Germany
• European Glider Manufacturers and Suppliers
  association, East Europe
• Together they include 13 companies (representing
  more than 1000 employees) in Austria, Czech
  Republic, Germany, Lithuania, Slovenia.
• Further members of the sailplane industry
• other European sailplane manufacturers
• manufacturers of glider-typical avionics
• manufacturers of trailers and equipment
• glider maintenance facilities

4
IntroductionWho are we - whom do we represent?

• In total the European sailplane industry
  represents
• more than 20 sailplane manufacturers
• more than 30 manufacturers of gliding equipment
• more than 90 of world-wide sailplane
  production(over 400 new aircraft per year)
• more than 3000 employees at the manufacturers and
  associated companies

5
IntroductionWho are we - whom do we represent?

• The European sailplane maintenance industry
  sector represents
• much more than 100 sailplane maintenance
  shops(perhaps even more than 200 - no central
  association existent)
• certainly hundreds of employees
• several hundred approved inspectors according to
  national rules conducting airworthiness reviews
  on a honorary basis (in their free time) within
  the national gliding federations
• The European gliding community in Europe
  includes
• more than 20.000 registered sailplanes
• more than 70.000 pilots flying gliders and
  powered sailplanes

6
IntroductionWho are we - whom do we represent?

• The European sailplane manufacturers do not claim
  that they can represent all stakeholders of the
  gliding community in Europe.
• BUT
• the manufacturers know their market ( the
  operators the maintenance sector) very well
  since more than 50 years
• they know how continuing airworthiness is been
  handled until now as some work also as
  maintenance organisations
• they know as TC holders that there is no general
  safety problem due to a lack of proper
  maintenance
• they know that more complicated regulations will
  lead towards loss of much more pilots due to
  frustration and increased costs
• they already experience the effects of a slowly
  shrinking gliding scene

7
Basic comments regarding Part M Motivation of
Part M

• Obviously the basic idea of Part M is to have a
  common regulation for continuing airworthiness
  within all EASA member states.
• The claimed benefits for stakeholders should be
• standardised rules valid in all member states
• common safety standards regarding maintenance
  procedures
• common minimum standards regarding maintenance
  personnel
• avoidance of duplication at national / European
  level
• facilitation of a free movement of goods and
  services within Europe ( to alleviate the
  selling of aircraft between member states and to
  ease cross-border maintenance of aircraft)
• promotion of cost-efficiency in the regulatory
  process
• So how does this all fit to the gliding
  community? - See later.....

8
Basic comments regarding Part M Part M is a
very complex regulation

• Part M is by far too complex and difficult to
  read and understand.
• This regulation will be a must read at least
  for all maintenance organisations manufacturers
  inspectors ( many persons not having a legal /
  academic background).
• format with many cross-references within Part M
  and towards other regulations
• language with many abbreviations
• partition into regulation and AMC material
• This problem is even made worse as the official
  translations offered by the authorities are
  sometimes wrong and/or not directly fitting to
  the English original wording.

9
Basic comments regarding Part M Part M will
not allow simple continuation

• EASA officials have verified that Part M is
  introduced
• not to cure a pressing safety deficit but to
  standardise maintenance in Europe
• with the idea that basically most national
  maintenance procedures within light aviation
  should be possible to be continued.
• Nevertheless the competent authorities ( the NAA
  responsible now to implement Part M in the member
  states) have already started to change rules
  regarding continuing airworthiness to implement
  Part M. This is definitively not a continuation
  of well established maintenance procedures!

10
Comparison of Part M with old status Basis of
the comparison

• Based on the experience in the member states of
  more than 50 years of sailplane maintenance, a
  comparison between the old status quo and the
  new Part M procedures has been made.
• Data for this comparison has been accumulated by
• the European sailplane manufacturers
• the European Gliding Union (EGU) representing the
  gliding sectors of the national sporting
  federations
• by a large number of European maintenance
  organisations(traditional repair shops and also
  federations / clubs conducting glider
  maintenance)
• This comparison is primary valid for gliding but
  organisation within light aviation (e.g.
  ballooning, small aeroplanes) have already
  signalled similar conclusions!

11
Comparison of Part M with old status Regular
physical survey / issuance of ARC

• The fundamental cornerstone of glider maintenance
  until now
• A physical survey of the aircraft on a regular
  basis directly resulting into issuance of the ARC
  for continuing flight operations until the next
  survey (or a maintenance/repair event).
• This might be likened to a basic maintenance
  philosophy similar to the operation of a private
  owned car
• maintenance is been conducted on a on need
  basis
• the showing of streetworthiness is only
  required in certain intervals and/or after
  special maintenance/repair events
• operations of the car allowed immediately after
  completion of the physical survey without further
  registration/certification by authorities

12
Comparison of Part M with old status Regular
physical survey / issuance of ARC

• Within Part M this will be in the future
• A physical survey of the aircraft on a regular
  basis resulting into issuance of the ARC either
  by the competent authority or a CAMO and
  introduction of a certificate of release to
  service after every maintenance event.
• This certainly stems from the maintenance
  philosophy of the maintenance and operation of
  commercial air transport airplanes
• maintenance is been conducted on a procedural
  basis
• the aircraft is owned by the technical/maintenan
  ce organisation and can only operated after a
  release to service
• maintenance operations only possible with consent
  of the authorities based on regulated procedures
  and approved personnel

13
Comparison of Part M with old status Regular
physical survey / issuance of ARC

• The introduction of the additional step for the
  issuance of the ARC by the competent authority /
  CAMO and the obligatory release to service
  certificate will
• increase the number of administrative steps
  until the glider will be back in service
• this translates into time delays (remember more
  than 20.000 gliders!)
• this also means increased costs for the owners
• this does nothing to improve the actual physical
  survey
• this does therefore also not increase safety

14
Comparison of Part M with old status
Airworthiness survey introduction of
maintenance programs

• Until now the check of the technical
  documentation for each particular glider was made
  parallel to the physical survey and typically
  included
• review of the logbook of the glider / engine /
  propeller
• review of the findings report for this glider
  before start of the maintenance
• check against procedures described in the
  maintenance manual issued by the manufacturer
• check against existing service bulletins /
  airworthiness directives
• entry of all findings during the physical review
  against a check list provided by the maintenance
  manual or (if not provided) against a check list
  suitable for gliders / motor gliders
• All was done together with the inspector during
  the physical survey.

15
Comparison of Part M with old status
Airworthiness survey introduction of
maintenance programs

• Now the check of the technical documentation will
  be THE central point for the airworthiness review
  of each particular glider and is not necessarily
  coupled to the physical survey.
• Additionally now every individual aircraft needs
  to have an maintenance program with an approval
  of the competent authority.
• These maintenance programs will in most cases not
  give more information than the already existing
  information supplied by the manufacturer as
  (contrary to commercial air transport) the
  maintenance organisations do typically not
  develop own procedures. Even this standard
  maintenance program now will need approval!
• Issuance of the ARC will be done typically by
  persons not seeing the actual aircraft but based
  on the accompanying paperwork!

16
Comparison of Part M with old status
Airworthiness survey introduction of
maintenance programs

• This new system can only work if ALL
  participating partners
• are familiar with the new administrative
  procedures (this implies the need for training
  thousands of persons)
• have suitable background (excluding the
  experienced worker-type maintenance people)
• have the additional time for the new additional
  administrative steps (making the work for the
  honorary / free-time inspectors even more
  difficult as their time per glider inspection is
  limited)
• Therefore the following results seem to be
  (again)
• time delays
• cost increase
• loss of maintenance workforce
• with resulting degradation of safety....

17
Comparison of Part M with old status
Maintenance personnel - certifying staff

• Until now the maintenance personnel in gliding
  consisted of
• the owners/operators conducting the lion share of
  typical regular maintenance tasks (often referred
  to as winter overhaul)
• the inspectors within the gliding federations
  conducting the regular airworthiness reviews on a
  honorary basis (in their free time) or at least
  on a at cost price
• the personnel within maintenance organisations
  and/or the manufacturers with detailed knowledge
  for special systems and/or repairs and major
  maintenance tasks
• Typically some form of approval was required for
  inspectors - this was granted under supervision /
  directly from the NAA.
• BUT Besides the minimum technical expertise
  required the maintenance personnel was not
  excessively regulated.

18
Comparison of Part M with old status
Maintenance personnel - certifying staff

• Regarding maintenance personnel and inspectors
  (now identified as certifying staff) the
  situation will be more complicated after
  introduction of Part M
• regarding certifying staff Part M refers to Part
  66
• Part 66 defines categories of qualifications for
  aeroplanes and helicopters and components
  (excluding gliders)
• for all other aircraft (e.g. sailplanes) Part 66
  refers to relevant member states regulations
  (resulting into a return to existing systems
  regarding maintenance personnel/certifying staff
• This raises two questions
• why this complicated introduction if nothing
  changes?
• what happens if some NAA will simply delete their
  national regulation in favour of Part M / Part 66
  thereby forgetting gliders?

19
Comparison of Part M with old status
Maintenance organisations approvals

• Until now a typical maintenance organisation
  typically had to show
• compliance to national rules written in the
  national language and based on the particular
  local experience
• some form of certification for the organisation
  audited by the local authorities
• some minimum requirements regarding the
  qualification of the workers
• some approved qualification for the inspectors
  (issued directly or under supervision by the NAA)
• Normally this meant
• one single approval for the maintenance
  organisation
• individual approvals for the inspectors

20
Comparison of Part M with old status
Maintenance organisations approvals

• Now a typical maintenance organisation needs
• compliance to EASA rules written in a complicated
  language (sometimes not improved by the official
  translation) plus additional national rules
  fitting more or less to Part M
• one certification for the maintenance tasks
  (Subpart F)
• one certification for the inspections tasks
  (Subpart G) - now referred to as Continuing
  Airworthiness Management Organisation (CAMO)
• compliance - if applicable - with Part 66 / Part
  145 if the tasks performed fall outside the pure
  glider world / outside of Part M
• still a regular auditing by the competent
  authority but now based on a much more
  complicated regulation system
• introduction of quality assurance systems into
  their organisations as the new organisations
  approvals require

21
Comparison of Part M with old status
Maintenance organisations approvals

• This already means
• small maintenance organisations (read repair
  shops) do not know if approval under Subpart F
  and G will be feasible for them
• some existing maintenance workforce will be lost
  as they cannot afford this step towards the new
  approvals
• air-sport federations acting as maintenance
  organisations face new and unfamiliar approval
  processes (mainly with managers working in their
  free time and/or under quite limited working time
  constrains)
• manufacturers offering maintenance tasks beside
  their production process face additional approval
  processes to continue these maintenance tasks
• the owner will finally pay for all this
  application processes without any safety benefit
  for his glider and his personal flying....

22
Summary and assessment of Part M Motivation of
Part M - revisited

• Obviously the basic idea of Part M is to have a
  common regulation for continuing airworthiness
  within all EASA member states.
• The claimed benefits for stakeholders should be
• standardised rules valid in all member states
• common safety standards regarding maintenance
  procedures
• common minimum standards regarding maintenance
  personnel
• avoidance of duplication at national / European
  level
• Especially for gliders the rules about
  maintenance / certifying staff will still be
  based on national rules.
• This does not necessarily needs to be a
  disadvantage as those rules already work very
  good.
• BUT the additionally regulations / administrative
  procedures as required by Part M will make
  maintenance in gliders much more complicated and
  expensive .... without discernible safety
  benefit!

23
Summary and assessment of Part M Motivation
of Part M - revisited

• Obviously the basic idea of Part M is to have a
  common regulation for continuing airworthiness
  within all EASA member states.
• The claimed benefits for stakeholders should be
• facilitation of a free movement of goods and
  services within Europe ( to alleviate the
  selling of aircraft between member states and to
  ease cross-border maintenance of aircraft)
• promotion of cost-efficiency in the regulatory
  process
• The alleviation regarding selling a glider in
  Europe will only work if the NAA will be
  accepting the rules by the other NAA - which was
  historically not the case until now - so why
  should this function now?
• Therefore cross-border maintenance still will be
  difficult.
• And within the gliding community no one has been
  heard to foresee ANY cost benefit due to the
  introduction of Part M ......

24
Summary and assessment of Part M Where are
we standing now?

• The concept one regulation that fits all sectors
  of aviation is not working regarding maintenance
  of gliders.
• Either Part M needs some fundamental changes or
  extensive changes are needed in the AMC material
  of Part M / Part 66.
• The basic idea of rulemaking task MDM.032 has
  been claimed to be simple regulations for light
  aviation - this is of course linked toPart M
  and directly influences future of maintenance for
  GA.(But ONLY for non-commercial activities!!)
• The tasks M.005 (pilot-owner maintenance) and
  M.017 (review of NPA 7/2005 after Part M
  regulatory impact assessment) must result into
  important changes very fast (in order to stay
  within the time scale as EU 2042/2003 gives
  28.9.2008 as final introduction date).

25
Summary and assessment of Part M Where to
go?

• Today there is no one claiming a basic safety
  problem regarding maintenance / continuing
  airworthiness for gliders (or for General
  Aviation).
• Therefore only change when there is a need for
  change!
• If a common regulation is really envisaged then a
  simpler regulation is needed than Part M (and
  Part 66) and then it really must be standardised
  in all member states.
• If the Agency / EU commission / EU parliament
  feels national regulation to be sufficient then
  make a mini Part M only approving existing
  national regulations (as existing now) as valid
  in all member states.
• Therefore a clear decision between European /
  national rules!
• And Extend the time schedule to avoid quick
  fixes and chaos!

26

• Thank you -
• any questions?