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United Kingdom

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United Kingdom. A concept for better regulation in general aviation. Part-M Workshop ' ... Contents of light' implementing rules are still to be defined ... – PowerPoint PPT presentation

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Title: United Kingdom


1
A concept for better regulation in general
aviation
  • Part-M Workshop Revised Part-M requirements for
    aircraft not involved in commercial air
    transport.
  • Juan Anton
  • Frederic Knecht

2
Contents of the presentation
  • General presentation of the A-NPA
  • Useful definitions in the context of the A-NPA
  • Background
  • Working method

3
Contents of the presentation
  • The concept state of play in general aviation
  • The concept principles
  • The concept description
  • The concept discussion points

4
Contents of the presentation
  • The next steps
  • Summary and conclusions
  • Attachment 1
  • EASA general
  • Attachment 2
  • The concept discussion points

5
General presentation of the A-NPA
  • An A-NPA is a tool to gather views before
    starting actual rulemaking
  • A-NPA 14-2006
  • Published on 16 August 2006
  • Open for comments until 16 October 2006
  • Structure of the A-NPA
  • Main body describing the concept
  • Appendix providing useful links relative to
    industry standards
  • 5 attachments 4 Regulatory Impact Assessments
    and one list of studies used.

6
Useful definitions in the context of the A-NPA
  • General aviation
  • means all non-commercial activities of aircraft
    other than complex-motor-powered aircraft
  • Commercial activities
  • means a remunerated aeronautical activity covered
    by a contract between an operator and a customer,
    where the customer is not, directly or
    indirectly, an owner of the aircraft used for the
    purpose of this contract and the operator is not,
    directly or indirectly, an employee of the
    customer

7
Useful definitions in the context of the A-NPA
  • Complex-motor-powered aircraft means
  • (i) an aeroplane
  • with a maximum certificated take-off mass
    exceeding 5,700kg or
  • with a maximum approved passenger seating
    configuration of more than 9 or
  • certificated for operation with a minimum crew of
    at least 2 pilots or
  • equipped with (a) turbojet engine (s) or
  • (ii) a helicopter
  • with a maximum certificated take-off mass
    exceeding 3,175kg or
  • with a maximum approved passenger seating
    configuration of more than 5 or
  • certificated for operation with a minimum crew of
    at least 2 pilots or
  • (iii) a tilt rotor aircraft

8
Useful definitions in the context of the A-NPA
  • Assessment body
  • means an approved body which may assess
    conformity of legal or natural persons with the
    rules established to ensure compliance with the
    essential requirements laid down in this
    Regulation and issue the related certificate.
  • Industry standard
  • Standards established or published by an official
    body whether having legal personality or not,
    which are widely recognised (by consensus) by the
    aviation community as constituting good practices
  • Important Note
  • These definitions are included into the
    legislative proposal to extend the EASA scope and
    were a given for the work.

9
Background
  • Legislative proposal to extend the EASA scope
    (COM (2005) 579)
  • Propose the creation of a new pilot licence
  • Propose general operating rules
  • Contacts with general Aviation stakeholders and
    National Authorities
  • Show that a full review of airworthiness
    regulations was urgently needed.

10
Working method
  • A rulemaking group was set-up
  • Composition Europe-Air-sport ECOGAS, IAOPA,
    National Authorities and EASA
  • The approach taken by the group
  • Brainstorming beyond the limits of conventional
    approaches.
  • Elaborate a complete concept by proposing and
    selecting options using regulatory impact
    assessments and a review of relevant studies.

11
The concept state of play in general aviation
  • Outline of the General Aviation
  • 80000 aircraft 300000 pilots excluding Annex II
  • Only 25 of the USA
  • Decline except micro-lights
  • Stakeholders feels that there is a correlation
    between heaviness of rules and level of activity
  • However safety regulation can not be blamed for
    everything
  • Before embarking on relaxation of regulatory
    framework, need to look at safety data

12
The concept state of play in general aviation
  • Safety data
  • Major fatality risks are CFIT and loss of control
  • Design related failures very low
  • Human performance and weather are contributing
    factors
  • Incapacitation marginal
  • Third party risk not statistically
    significant

13
The concept state of play in general aviation
  • Conventionally regulated sector versus less
    regulated sector
  • Do not show significant difference
  • CAA General Aviation regulatory review identify
    some difference but recommend further study

14
The concept state of play in general aviation
  • Conclusion from the state of play supports a new
    concept in the light of
  • The stagnating, difficult economic prospects of
    General Aviation in Europe
  • The apparent growth of certain segments of
    General Aviation
  • The nature and extent of the safety risks
  • Desire of the stakeholders to ensure the
    continued existence, and hopefully growth
  • The recognition that General Aviation forms an
    important part of the lives of many European
    citizens
  • The general drive in the European Community to
    reduce the burden of regulation

15
The concept principles
  • Proportionality
  • Level of regulation appropriate and proportionate
    to risk
  • General aviation well informed of risk justify
    lower level of regulation
  • Target regulation to bring greater safety
    benefits
  • Participation
  • Bringing regulation closer to stakeholders makes
    them more responsible

16
The concept description
  • Initial Airworthiness
  • No change proposed for aircraft above 2000Kg
  • 3 options for aircraft below 2000Kg
  • Relaxation of the current system
  • Industry monitoring
  • Industry monitoring with self declaration (below
    750 kg)

17
The concept description
  • Initial Airworthiness below 2000kg
  • Relaxation of the current system differences
    with present system are
  • Design capability simplified requirements,
    including the one-man organisation, to grant the
    current designers privileges,
  • Basis for Type Certificate (TC) or Supplemental
    Type Certificate (STC) approved by EASA on the
    basis of a simplified Certification Specification
    adopted by EASA
  • Approval of design changes and repairs TC or STC
    holder independently of their nature (major or
    minor)
  • Production capability simplified requirements
    including the one-man organisation, to grant the
    current manufacturers privileges,
  • Approval of Aircraft Flight Manual and
    Instructions for Continuing Airworthiness TC or
    STC holder
  • Activities relative to continuing airworthiness
    of design TC or STC holder
  • Body issuing Airworthiness directives EASA in
    consultation with TC holder

18
The concept description
  • Initial Airworthiness below 2000kg
  • Industry monitoring it differs from the current
    situation as follows
  • Design capability compliance with an Industry
    Standard checked by an approved Assessment Body.
  • Basis for Type Certificate or Supplemental Type
    Certificate defined by an approved designer
    using an Industry Standard
  • Body issuing the TC approved Assessment Body
  • Certification basis for changes and repairs TC
    or STC holder based on Industry Standard.
  • Approval of design changes and repairs TC or STC
    holder
  • Production capability compliance with an
    Industry Standard checked by an approved
    Assessment Body
  • Body issuing Airworthiness directives EASA or
    EASA following recommendation of an approved
    Assessment Body.

19
The concept description
  • Initial Airworthiness below 2000kg
  • Industry monitoring with self declaration (below
    750 kg) differences with the previous option
    are
  • Body issuing the TC approved designer
  • Body issuing Airworthiness directives EASA in
    consultation with TC holder

20
The concept description
  • Continuing airworthiness and maintenance
  • Adjusting Part-M to the need of aircraft other
    than complex-motor-powered-aircraft
  • If appropriate for ease of use, such revision of
    Part M could take the form of a specific stand
    alone light Part M.
  • Creating a new level of licence for maintenance
    engineers in charge with General Aviation
  • Establishing new privileges for approved
    maintenance organisations.

21
The concept description
  • Continuing airworthiness and maintenance
  • Adjusting Part-M?
  • To extend pilot owner maintenance
  • To allow the Airworthiness Review Certificate
    (ARC) to be issued by organisation approved in
    accordance with Part-M Subpart G (continuing
    airworthiness management organisation) or by
    Competent Authorities
  • To study the possibility of using assessment
    bodies
  • To review the Competent Authority concept
  • To review Part-M Subpart B (accountability)
  • To consider the possibility to have proportionate
    rules according to the mass and kind of aircraft
  • To develop standard modifications and repairs
    (such as the Federal Aviation Administration
    Advisory Circular AC 43-13)
  • To consider the use of industry standards

22
The concept description
  • Air operations
  • Develop a set of light implementing rules and
    acceptable means of compliance

23
The concept description
  • Pilot licensing
  • Create a European private pilot licence issued by
    Authorities or assessment bodies
  • covering the full scope of aircraft other founded
    on a stepwise approach and on competence based
    training.
  • This licence would be built around a basic common
    licence to which ratings for different categories
    of aircraft, operations and specific
    authorisations would be attached, including
    simplified instrument rating and instructor
    rating.
  • No arbitrary restrictions on access to airspace
    and airports built into the licensing rule.
  • Medical requirements based on risk assessment and
    consideration to allowing general practitioners
    to issue medical certificates based for example
    on an assessment following a self-declaration
    signed by the pilot.
  • Commercial flying schools should have the
    possibility to train to RPPL.
  • Finally a bridge with the standard FCL-PPL should
    be established.

24
The concept discussion points
  • 7 questions were asked to help defining the
    follow-up of the concept.
  • They are detailed in Attachment 2

25
The next steps
  • Comment response document
  • 3200 replies generating more than 7250 comments
  • CRD to be published July 2007

26
The next steps
  • Initial Airworthiness
  • MDM.032 group draft the NPA reflecting option 1
    of the A-NPA Target date for NPA publication
    July-August 2007
  • Simplification of present Part 21 for aircraft
    below 2000 Kg maximum take-off mass (MTOM)
  • Alternative procedures for DOA between 1000 and
    2000kg
  • Combined design, production and maintenance
    approval
  • European new light aircraft categories
    simplified certification system for all aircraft
    below 1000kg MTOM except Very Light Rotorcraft
  • Demonstration of capability done via
    certification programme
  • Rely on Qualified Entities
  • Simplified subpart-G for production
  • Possibility to use Industry standards when found
    acceptable.

27
The next steps
  • Continuing airworthiness
  • Option 1 (adjusting Part-M and creating a new
    level of licence for maintenance engineers in
    charge of general aviation) seems supported
  • Tasks performed by another group (M.017) in close
    coordination with MDM.032
  • Comments received have been passed to them for
    their consideration
  • No light Part-M but around 40 modifications to
    Part-M are proposed
  • NPA for Part-M issued on 25 June. NPA also
    include the work on pilot-owner maintenance
    (M.005).
  • NPA for Part-66 scheduled for 3rd quarter 2007

28
The next steps
  • Licensing
  • New private pilot licence
  • Sub-group created to draft the elements for an
    NPA for a New PPL aiming at initially below
    2000kg (MTOM to be refined depending of aircraft
    category) and addressing medical requirements in
    a first phase.
  • In a second phase adjust requirements based on
    weight criteria agreed by the legislator and
    define how medical requirements are assessed.
  • Target date for the elements of an NPA July 2007

29
The next steps
  • Operations
  • General operating rules
  • Below 2000KG no implementing rule but direct
    implementation of essential requirements except
    for equipment and fuel reserves
  • Above 2000kg Implementing Rules (OPS-0)
  • Target date for elements of an NPA July 2007

30
The next steps
  • Administrative actions
  • Revised TOR and TOR for FCL and OPS to AGNA and
    SSCC for information/ comments and ask for
    nominations from AGNA and SSCC for the FCL
    sub-group
  • TOR and composition of the groups are published
  • EASA to inform the GA Community by putting a
    message on the web-site
  • Done

31
Summary and conclusions
  • Comprehensive concept
  • Important rulemaking activities
  • Still significant amount of work to do!
  • Thank you for your attention
  • Questions are welcome

32
Attachment 1
  • EASA general

33
EASA general
  • EASA is an European Union Agency Based in Cologne
    (Germany)
  • It is established by EU regulation 1592/2002 that
    defines
  • Objectives principal objective is to establish
    and maintain a high uniform level of civil
    aviation safety in Europe
  • Basic principles for Aviation safety and
    essential requirements to be complied by
    aircraft, products and parts
  • A clear sharing of roles between the Agency, the
    Member States and the Commission
  • Define the Agency and its tasks e.g. issues Type
    Certificates for Aircraft.

34
EASA remit
  • Currently the Regulation 1592/2002 establishes
    Community competency only for the regulation of
    the airworthiness and environmental compatibility
    of products
  • Work is being done to extend the scope of this
    regulation to air operations and flight crew
    licensing (Late 2007/early 2008 and implementing
    rules end 2008/ early 2009)
  • Ultimately it could also cover the safety
    regulation of airport operations (2011) and air
    traffic control services (2012)

35
EASA present regulations structure
Agency Opinion
Annex I Essential Requirements for
Airworthiness Annex II Excluded Aircraft
Basic Regulation Regulation (EC) 1592/2002 of 15
July 2002
Agency Opinion
Regulation (EC) 2042/2003 on Continuing
Airworthiness
Regulation (EC) 1702/2003 on Airworthiness and
Environmental Certification
Annex I (Part-M) Continuing Airworthiness
Requirements
Section A Technical Requirements
Section B Administrative Procedures
Section A Application Requirements
Annex II (Part-145) Maintenance Organisation
Approvals
Appendices EASA forms
Section B administrative Procedures
Annex (Part 21)
Appendices EASA forms
Annex III (Part-66) Certifying Staff
Annex IV (Part-147) Training Organisation
Requirements
Guidance Material Part 21
Certification Specifications
Agency CS , AMC GM
AMC Guidance Material Part M, 145,66,147
AMC 20 AMC 21 CS 25 CS 34 CS 36 CS E CS P CS APU
CS 22 CS 23 CS 27 CS 29 CS VLA CS VLR
CS AWO CS ETSO CS Definitions
Parliament and Council
European Commission
EASA
36
Attachment 2
  • The concept discussion points

37
The concept discussion points
  • General questions
  • General balance of the concept
  • Possibility to use assessment bodies
  • Certificate they issue is the official
    certificate
  • Need to be approved by EASA or Authority
  • Examples already exist
  • Liability issue

38
The concept discussion points
  • Initial airworthiness
  • The Agency believe that the options called
    Industry monitoring and Industry monitoring
    with self declaration (below 750 kg) are more
    promising
  • Comments welcome on which option to follow and on
    in that context on weight limits

39
The concept discussion points
  • Continuing airworthiness and maintenance
  • Additional orientations are needed on specific
    points
  • Should assessment bodies be involved in the
    oversight of continuing airworthiness, such as
    ARCs renewal
  • What should be the role of NAAs in this field?
  • Should continuing airworthiness requirements be
    adapted to the size/type of aircraft? How should
    this be done?
  • Is it worth developing standards modifications
    and repairs that could be embodied without the
    need for further approvals? Which bodies should
    do so?
  • Is it possible to develop Industry Standards to
    be used in continuing airworthiness processes?
    Which bodies should be in charge?

40
The concept discussion points
  • Air operations
  • Contents of light implementing rules are still
    to be defined
  • Comments are requested on the contents of the
    light implementing rules

41
The concept discussion points
  • Pilot Licensing
  • Proposed contents and privileges are very
    ambitious
  • Opinion of stakeholders is requested in
    particular on
  • Type of aircraft and need for an upper limit
  • Ratings that could be attached
  • How to perform medical assessment and possible
    role of general practitioners.

42
The concept discussion points
  • Scope of common rule
  • In COM (2005) 579 the Commission expressed the
    view
  • that consideration should be given to aircraft
    with a low maximum take-off mass, with increased
    performance might be better regulated at
    Community level.
  • No proposals to change Annex II at this stage
  • Comments are requested on the possibility to
    remove certain aircraft from Annex II if the
    proposed concepts were implemented.
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