Aviation Regulation Latest Developments and Their Impact for Industry Neil Williams Section Leader Technical Support Section Chief Surveyor s Office Safety Regulation Group Civil Aviation Authority Slide 1
Contents UK position on implementation of EU continued airworthiness regulations Latest regulatory developments in continued airworthiness for aircraft subject to EASA regulation What s happening with regulations for non-easa aircraft Slide 2
European Continuing Airworthiness Management Structure Part M Part 147 Approved Training Organisation Part 66 Certifying Staff Commercial Air Transport & All Large Aircraft & multi-engine Helicopters Part 145 Maintenance Organisation Part M Subpart G Continuing Airworthiness Management Organisation (M)Subpart F Maintenance Org EASA Part M Subparts C, D, E & I Licensed Aircraft Engineer Owner / Lessee Continuing Airworthiness (M. Subpart C ) Management Non Commercial Air Transport Aircraft below 5700 Kg & single-engine Helicopters Non-Expiring Airworthiness Certificate Validated by An Airworthiness Review Certificate All Commercial Air Transport Aircraft Obligatory All Large aircraft & multi-engine Helicopters Light Aircraft below 5700 Kg and single engined helicopters used for Non Commercial Air Transport Alternatives Non-Expiring Airworthiness Certificate Validated by An Airworthiness Review Certificate
Did it leave you feeling like this? It certainly did me! Slide 4
The UK s Part M Implementation Progress The current position: All aircraft qualifying for an EASA Certificate of Airworthiness will need to have their continued airworthiness requirements addressed and be maintained in accordance with EC Regulation 2042/2003 Annex 1 Part M by 28 September 2008 For aircraft operated for Commercial Air Transport (CAT) this is not a problem as the regulation has been in effect since 2003 For aircraft not operated for commercial air transport there is still a lot of work to do between now and the end of September Slide 5
For Non Commercial Operators and Organisations supporting these activities this will entail: Organisations: Obtaining Maintenance Approvals in accordance with Part 145 or Part M Subpart F Obtaining Continuing Airworthiness Management Organisation (CAMO) approval in accordance with Part M Subpart G Owners/operators: Obtaining a non-expiring Certificate of Airworthiness and an Airworthiness Review Certificate (ARC) for their aircraft Re-approval of the aircraft maintenance programmes in accordance with M.A.302 Slide 6
For Individuals: Licensed aircraft engineers maintaining aircraft with a Maximum Take Off Weight Authorised of < 5700Kgs will need to obtain a Part 66 licence with the appropriate aircraft type rating (if located within the EU) Individuals maintaining gliders and balloons will only be able to do so as part of a Part M subpart F organisation Changes to scope of authorised pilot maintenance tasks Slide 7
So What s New There Then? Well nothing! However, things are often not as simple as they first appear! Its time to look into the crystal ball... Slide 8
The Next 12 Months or so - Part 145 (1) Existing changes and means of compliance: Implementation of ED decision 2007/001/R Fuel Tank Safety Initiatives Training is required for all staff involved in aircraft fuel system maintenance of large aircraft Level 1 (basic awareness) training to be completed by end March 2008 Level 2 (detailed) training to be completed by 2010 The CAA will shortly publish a letter clarifying the situation in response to the many questions regarding the contents of the decision Revised EASA decision expected during the second quarter of 2008 Slide 9
The Next 12 Months or so - Part 145 (2) EASA Notice of Proposed Amendments: NPA 2007-09 Single and multiple release to service comment response document, revised NPA and opinion to Commission expected Future rulemaking activity: Safety critical maintenance tasks Slide 10
The Next 12 Months or so - Part M Subpart G/F (1) Existing changes / means of compliance: ED decision 2007/002/R Implementation of fuel system safety decisions by training staff, changing organisational procedures, amending aircraft maintenance programmes, developing means to track compliance with fuel system design limitations Obtaining approval Subpart G/F - if not already held Slide 11
The Next 12 Months or so - Part M Subpart G/F (2) For Subpart G organisations already approved: Obtain the privilege to recommend and/or issue Airworthiness Review Certificates in accordance with M.A.711(b) For UK based organisations the ARC privilege may be granted when competence has been demonstrated However The privilege cannot be used on UK registered aircraft until 28 September 2008. It may be used for aircraft registered in other EU Member States where Part M Subpart I has been fully implemented (e.g. Ireland) Slide 12
The Next 12 Months or so - Part M Subpart G/F (3) NPA 2007-08 Amendment to Part-M for aircraft not used in Commercial Air Transport NPA comment response period is now closed. NPA proposes changes to ease the burden of Part M on the general aviation community Over 600 comments have been received by EASA in response to the NPA The timing of the NPA, its contents and effect on the GA community has caused the Agency to rethink its implementation strategy A phased implementation of the revised regulation is currently being considered Slide 13
The Next 12 Months or so - Part M Subpart G/F (4) Likely to consist of the following measures: Nationally-issued maintenance approvals used for non commercial air transport issued before 28 September 2008 will be deemed to have been issued in accordance with subpart F for a period of one year (after 28 September 2008), during which time level 2 findings addressing the difference between the national regulation and the EASA regulation must be resolved. Certificates of release to service made under national regulations and considered equivalent to those issued under Subpart F. Delay the implementation of M.A.201(i) for a further year for aircraft operated for aerial work or similar purposes that are not classified as a large aircraft. Slide 14
The Next 12 Months or so - Part M Subpart G/F (5) Aircraft maintenance programmes approved under national regulations would be given a further year to be re-formatted and re-approved as EASA-compliant programmes The continued acceptance of aircraft components maintained in the USA and Canada outside existing bilateral arrangements to be allowed for a further year (e.g. acceptance of FAA 8130-3 or TCCA 24-0078 component releases from organisations not holding a Part 145 approval issued under the existing bilateral arrangements) Slide 15
The Next 12 Months or so - Part M Subpart G/F (6) Allow for the continued use of nationally qualified certifying staff (non Part 66) for a further year Not a a big issue in the UK as transition to Part 66 licenses is well advanced (however it may allow some national licence holders to continue to exercise overhaul privileges (such as piston engine overhaul) Allowing NAAs to issue ARCs with a validity period of greater than one year (on a once only basis) to ease NAA workload and allow time for a sufficient number of CAMOs to be established Slide 16
In Summary: The European Commission if they allow these alleviations will provide time for a revised Part M regulation to pass through the legislative process and allow the Member States and regulated organisations to implement the revised legislation within reasonable timescales Slide 17
What about the development of Part M for Commercial Air Transport Operators? EASA has formed working group MDM 014 to consider alternative arrangements for contracting out continued airworthiness management tasks by Air Operator Certificate (AOC) holders. Current arrangements allow operators to contract out a limited number of continued airworthiness tasks, but do not allow responsibility for their proper accomplishment to pass to another organisation New arrangements are being considered that would enable AOC holders to contract approved Continuing Airworthiness Management Organisations (e.g. Airbus, Boeing, Rolls Royce, etc) to manage the continued airworthiness of their fleets on their behalf Slide 18
What s Happening With Non EASA (State and Annex II) Aircraft? These aircraft are currently excluded from EASA regulation, even if the aircraft s design is an EASA type certified product (e.g. an MD 900 used for police operations or an Annex II aircraft used for CAT, such as a DH Dove) The UK doesn t currently have up to date national regulations for such aircraft, so a new national regulation is required (likely to be BCAR A8-23) The new approvals should be easy to obtain, as it is envisaged that most applicants will already be approved under existing EC regulations. The number of differences will therefore be kept to a minimum to ease the burden on the CAA and approved organisations In most cases just a few procedural differences will be necessary where it is not possible to fully conform with the EU Regulations Slide 19
Thank You for Listening Email: neil.williams@caa.co.uk Slide 20