STEINBEIS TRANSFERZENTRUM AERODYNAMIK FLUGZEUG- UND LEICHTBAU

1
Segelfliegen und EASA Bericht über die Arbeit
des Verbands deutscher Segelflugzeughersteller übe
r Part M, Gebühren und mehr von Werner micro
Scholz, Sprecher der European Sailplane
Manufacturers AERO, Friedrichshafen 21.4.2007
2
über den Vortrag und den Vortragenden

• Auszug aus dem Bericht 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

3
über den Vortrag und den Vortragenden
4
über den Vortrag und den Vortragenden

5
EASA the most important topics in 2007

• new Fees Charges regulation
• Part M maintenance / cont. airworthiness
• MDM.032 simple rules for small aviation
• new / closed topics since 2005
• Certification of sailplane equipment
• crashworthiness of glider cockpits

6
new Fees Charges regulation

• EASA committee (all member states) voted
  positively for new FC regulation on 16.4.
• 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)

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 designs
• fees for non-turbine engines are much higher than
  those for sailplanes/motorgliders
• price 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 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

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 20.000 gliders in Europe
• new organisations / new procedures needed
• ill 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 / 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

11
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

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 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

13
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

14
Part M maintenance / cont. airworthiness (cont.)

• ongoing 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
• so what is in discussion right now?

15
Part M maintenance / cont. airworthiness (cont.)
possible relaxations from the rulemaking groups

• issuance of ARC
• below a certain weight limit excluding commercial
  air transport the CAMO making the inspection
  might issue the ARC directly
• therefore no obligation to go the competent
  authority or to contract the responsibility to a
  CAMO
• Big 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 program
• the CAMO making the inspection might approve also
  the according maint. program
• perhaps it could be possible to shortcut this
  approval as long as the normal maintenance
  documents are been used
• Big 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 maintenance
• the 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 alterations
• due to the specified rulemaking process(ToR gt
  Working Group gt RIA gt NPA gt Working Group gt CRD gt
  EASA opinion gt 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 planning
• EASA / 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 2005
• rather 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, operations
• A-NPA 14/2006 resulted in over 4000 answers
• EASA encouraged creative brainstorming but then
  limited possible alternative paths
• delegation of tasks to non-authority
  organisations will not be pushed by EASA it is
  doubtful if the member states will do this
• low 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 published
• typical equipment counts as standard part and
  therefore no Form One is needed
• nevertheless 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.)

• 22.004 crashworthiness of glider cockpits
• EASA agreed to use existing structure within
  gliding movement ( sailplane development panel
  of OSTIV) for rulemaking activity 22.004
• results of discussion within rulemaking activity
• existing OSTIV airworthiness standards use higher
  levels of acceleration for crash landing cases
• test results of several German research programs
  were analyzed and incorporated
• higher (static) load levels by a factor of 1.5
  proposed
• no dynamic tests required for certification
• participation of industry, authorities, research
  organisations within the activity
• actual statistics and accidents show need for
  adequate crashworthiness

23
New topics since 2005 (cont.)

• Bio-Fuel Ethanol in automotive gasoline
• several member states allow / enforce addition of
  ethanol into automotive gasoline
• possible technical problems
• vapor lock due to higher volatility
• corrosion due to water solved within the alcohol
• chemical attack upon tanks, fuel lines, seals,
  etc. by the ethanol or other additives
• reduced lubrication within two-stroke engines
  using pre-mixed fuel
• neither EASA nor national authorities have shown
  much interest into solving / researching the
  problems
• in the moment the responsibility is with the
  pilot and the TC holder

24
Quintessenz zum Schluß

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