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The Future of Maintenance in General Aviation

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Title: 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?
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