EASA operational support to engineering tasks (i.a. processing of STCs)

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EASA operational support to engineering tasks
(i.a. processing of STCs)

• Vincent De Vroey
• Vincent.De.Vroey_at_aea.be
• www.aea.be
• 4th EASA-Industry Meeting
• Cologne, 17th November 2005

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Background

• On 23rd May 2005, the AEA wrote to EASA,
  expressing concerns about increasing difficulties
  faced with processing Supplemental Type
  Certificate (STC) applications under EASA Design
  Organisation Approval (DOA).
• The AEA was in particular concerned that if not
  resolved these difficulties could put the EU
  industry at a competitive disadvantage in the
  international modification market.
• The AEA met with the EASA Certification Director
  on 7th July to explore practical solutions for
  the problems raised. Various actions and
  commitments to improve the process were agreed.

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Lack of clear procedures is a key problem

• 1)Lack of written procedures and standardisation
  for STC applications and processing
• EASA internal working-procedures are still not
  detailed enough and have resulted in a lot of
  confusion on how to apply and make progress with
  applications.
• ?Clear procedures are needed now!
• EASA agreed to develop standards/policies and to
  put certain conditions (i.a. maximum number of
  hours) in contracts with NAAs (who act on behalf
  of EASA).
• ? Status?

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DOA privileges

• 2) Some NAAs acting on behalf of EASA continue to
  check 100 of the data, which is not in line with
  DOA privileges
• EASA committed themselves to provide training
  for PCMs and to set up a working-group to develop
  more guidance on the scope of the DOA privileges
• In the mean time, some NAAs continue to check
  100 of the data, with no signal from EASA to
  them that this should not be the case.
  Implications in term of costs and delays are
  significant.
• ? Status?

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List of persons in charge and central
applications office

• 3) No list of persons allowing direct contact
  for STC and AMOC applications and investigations.
  This is particularly important during the STC
  pre-application phase.
• Still no list published. Up to 6 weeks delay
  between application letter and contact with the
  PCM.
• ? Clearly unacceptable.
• EASA confirmed, that it has the intention to
  create a central office for applications.
• ? Status?

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Late acknowledgement of STC applications

• 4) Late acknowledgement of STC applications
• EASA has the objective in the future to
  acknowledge applications within 10 days. This
  will include information on the team which has
  been allocated and will include contact details
  of the person in charge.
• However, this objective has not been yet met
  since airlines continue to be faced with
  unacceptable late acknowledgement (up to 6
  weeks).
• ? Solution needed now to avoid serious distress
  to the EU repair industry!

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Delays technical VISA/issuing STC

• 5) Important delays between the TV (technical
  visa) and the issuing of the STC. Furthermore,
  the use of Article 10.3 to release the aircraft
  based on the TV is not always possible (e.g.
  registration NAA different from the TV NAA).
• EASA has a clear objective of a maximum 1 day
  between the technical visa and the issuance of
  the STC,
• ? Delays are still important (up to 6 weeks).
• Furthermore, this may still not be sufficient in
  all cases (e.g. aircraft awaiting release to
  service after final flight test).
• ? Legal status should be given to the TV, in
  order to allow the aircraft release to service
  immediately after the TV issuance (as compared to
  FAA process!), pending final STC issuance.

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STC applications based on FAA STCs

• 6) Timeframes for processing STC applications
  based upon FAA STCs too important. (FAA responds
  very quickly)
• EASA undertook to look for improvement.
• ? Problems continue to be faced. Urgent
  improvements needed

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EASA problems related to FAA STCs

• 7)Complicated and time consuming EASA processes
  for EU Airlines importing used airplanes with
  multiple FAA approved non-TC holder STCs
• Unless it can be demonstrated that the STCs have
  been approved by any of the EU NAAs prior to cut
  in of the EASA system (Sept 28, 2003), EASA
  review and approval of the STCs is required.
  Typically this may take 3-5 months, occasionally
  even longer.
• Some holders of these US STCs are no longer
  conducting business. Thus, there are no legal
  applicants who can process STC approval
  applications to EASA!
• ? A general EASA acceptance of all FAA STCs
  approved and installed on airplanes prior to Sept
  28, 2003 seems a pragmatic solution.

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Fees Charges

• 8) EASA fees charges payment conditions result
  in further delays for administrative reasons and
  may result of aircraft grounding
• ? Some improvement noted but need consistency for
  all applicants!

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Other issues EASA AD Process

• Subscription service on AD notification
• EASA notification system (by e-mail) is needed
  on all changes to the EASA website (including and
  specifically on AD items).
• ? When and at which cost?
• EASA AD Process
• Lack of procedures on who to be contacted with
  regard to technical content of EASA ADs. Even the
  Project Certification Manager/EASA AD Focal Point
  does not know necessarily to whom he should
  address a question related to the technical
  content of an Airworthiness Directive.
• ? Clarification/procedures needed