European Aviation Safety Agency

AGENDA European Aviation Safety Agency Part-66 Part-147 Workshop Cologne, 26 April 2005 I. Objectives, regulatory framework and scope of competence of the Agency III. Part-66 Part-147, main activities for the future 28/04/2005 Part-66 Part-147 2 AGENDA Objectives of the Agency I. Objectives, regulatory framework and scope of compence of the Agency III. Part-66 Part-147, main activities for the future establish and maintain a high uniform level of aviation safety in Europe, ensure a high uniform level of environmental protection, promote cost efficiency in the regulatory process, assist Member States in fulfilling their ICAO obligations promote Community views through co-operation with third countries and international organisations. 28/04/2005 Part-66 Part-147 3 28/04/2005 Part-66 Part-147 4 Regulatory Framework: the Basic Regulation The Parliament and the Council define the Scope of Powers transferred from the Member States to the Community They adopt the Essential Requirements specifying the objectives to be met Basic Regulation Regulation (EC) 1592/2002 of 15 July 2002 Annex I : Essential Requirements for Airworthiness Annex II : Excluded Aircraft Regulatory framework: the Implementing Rules The Commission adopts standards for implementing the essential requirements Regulation (EC) 1702/2003 on Airworthiness and Environmental Certification Annex (Part 21) Section A: Application Requirements Section B: Administrative Procedures Appendices: EASA forms Regulation (EC) 2042/2003 on Continuing Airworthiness Annex I (Part-M): Continuing Airworthiness Requirements Annex II (Part-145): Maintenance Organisation Approvals Annex III (Part-66): AML Section A: Technical Requirements Section B: Administrative Procedures Appendices: EASA forms Annex IV (Part-147): Training Organisation Requirements 28/04/2005 Part-66 Part-147 5 28/04/2005 Part-66 Part-147 6

28/04/2005 Part-66 Part-147 7 Regulatory framework: the Agency s soft law The Agency adopts non binding standards for implementing the essential requirements Guidance Material Part 21 AMC 20 AMC 21 CS 25 CS 34 CS 36 CS E CS P CS APU Certification Specifications CS AWO CS ETSO CS Definitions CS 22 CS 23 CS 27 CS 29 CS VLA CS VLR AMC & Guidance Material Parts M, 145, 66, 147 The Agency s Rulemaking Procedure Rulemaking procedure : Decision of the Management Board MB/7/03 of 27 June 2003 Rulemaking activities shall be initiated in accordance with the rulemaking priorities set out in the rulemaking programme This Decision prescribes the procedure for the development of and issuing of: Opinions addressed to the Commission Certifications Specifications Guidance Material 28/04/2005 Part-66 Part-147 8 Scope of Competence of the Agency EASA WORKSHOP Currently Regulation 1592/2002 establishes Community competence only for the regulation of the initial and continuing airworthiness and environmental compatibility of products Work has being done to extend the scope of this Regulation to air operations and pilot licensing (Opinion 3/2004) The Commission will publish before the summer a communication related to the future competences of EASA (airport operations and air traffic control services) 28/04/2005 Part-66 Part-147 9 I. Objectives, regulatory framework and scope of competence of the Agency III. Part-66 Part-147, main activities for the future 28/04/2005 Part-66 Part-147 10 EASA Structure The ates The ates Executive P. GOUDOU Safety Analysis Communications Risk Management Organisational Chart The Management Board Rulemaking C. PROBST Certification N. LOHL Quality & Standardisation F. BANAL Administrative M. JUNKKARI Environmental Protection Programmes Standardisation Finance & Budget International Cooperation Products Quality Assurance Human Resources The Board of Appeal Flight Standards Organisations Technical Training Legal Service Product Safety ICT & Tech. Services 28/04/2005 Part-66 Part-147 11 28/04/2005 Part-66 Part-147 12 Last update : 21 April 2005

28/04/2005 Part-66 Part-147 13 Executive P. GOUDOU Certification ate N. LOHL Deputy F. COPIGNEAUX Certification Manager R. ERCKMANN Policy Officers P. SØRENSEN L. BODOSSIAN S. BRAIN Programmes W. SCHULZE-MARMELING Products A. LEROY Organisations W. SCHULZE Applications J. NOVAK Large Aeroplanes P. MEDAL Design R. SIMON Risk Management Safety Analysis & Research J. VINCENT Communications D. HÖLTGEN Programme Managers F. STEFFENS General Aviation R. HARDY Rotorcraft / Balloons / Airships M. MAZZOLETTI Production A. KALSHOVEN Continuing Airworthiness J. HALL Propulsion K. BÖWING Parts & Appliances M. GÖRNEMANN Flight Standards E. NIELSEN Environmental Protection G. READMAN Last update : 21 April 2005 Last update : 19 January 2005 28/04/2005 Part-66 Part-147 14 Rulemaking ate Quality & Standardisation ate Process Support A. TZIOLAS C. PROBST F. BANAL ate Assistant Environmental Protection W. FRANKEN Flight Standards Product Safety Y. MORIER International Cooperation T. SULOCKI Standardisation F. JANVIER Flight Crew Licensing Initial Airworthiness P. CORBEEL Technical Training M. KOMPARE Initial Airworthiness Coordination Continuing Airworthiness Coordination E. BOHLAND Quality Assurance J. MÜLLER Operations Continuing Airworthiness E. SIVEL ATM / Airport Safety Last update : 19 January 2005 28/04/2005 Part-66 Part-147 15 Last update : 19 January 2005 28/04/2005 Part-66 Part-147 16 Administrative ate Mission of ates Finance & Budget J. CARREIRA M. JUNKKARI Planning & Development C. HOLGATE-ROMANOV Human Resources ICT & Tech. Services Legal Service F. KAMPFE Rulemaking Assist the European Commission and in preparing legislation, (Opinions) and support the Member States and industry in putting the legislation into effect Adopt our own certification specifications and guidance material Certification Conduct technical inspections and issue certificates where centralised action is more efficient Quality & Standardisation Assist the European Commission in monitoring the application of European Community legislation regarding aviation safety Quality assurance function to monitor the Agency procedures Last update : 19 January 2005 28/04/2005 Part-66 Part-147 17 28/04/2005 Part-66 Part-147 18

28/04/2005 Part-66 Part-147 19 The Management Board The Board of Appeal is composed of one representative per Member State, plus one representative of the Commission deals exclusively with administrative matters: work programme and priorities, budget, staffing, financial regulation, working methods (rulemaking procedure) appoints the members of the Board of Appeal appoints the Executive and the s acts as a first administrative instance to verify the legality of the acts of the Agency is created on an ad hoc basis: the chairperson and the other members shall be appointed by the Management Board from a list established by the Commission its members shall be independent its decisions are binding on the Agency an appeal may be brought before the Court of Justice of the European Union against decisions of the Board of Appeal 28/04/2005 Part-66 Part-147 20 Conclusions EASA WORKSHOP EASA is operational, growing in strength and expanding its scope EASA is built on a strong legal basis which provides certainty to stakeholders EASA is the principal civil aviation authority in Europe, with clearly established lines of roles, tasks and responsibilities relationships with other countries are key to ensure the highest level of safety worldwide EASA is the European interlocutor for civil aviation safety I. Objectives, regulatory framework and scope of competence of the Agency III.Part-66 Part-147, main activities for the future 28/04/2005 Part-66 Part-147 21 28/04/2005 Part-66 Part-147 22 Part 66 & Part-147 Main activities TOR 66.004 Time Limit TOR.66.004 Time limit for demonstrating compliance with knowledge and experience requirements TOR. 66.007 Question databank TOR.66.008 Re-issuance of the aircraft maintenance licence TOR. 66.011 Type training TOR. 147.005 Records of instructors, examiners and assessors Issue: authorities are of the opinion that the period during which compliance with knowledge and experience requirements has to demonstrated, should be limited. There should be a limit in the time a person can take to pass all the modules. It is felt by many that an applicant that spends too much time to obtain a license has difficulties with the knowledge requirements. Such a limitation existed in the past in some national systems. Objective: Requirements for gaining a licence should be met in a proper time frame in order to keep a high level of knowledge and safety. Specific task: Development of an opinion to change paragraph 66.A.10 and/or a decision to change its related AMC/GM. Time Scale: Work starts in July 2005. NPA to be published by December 2006. Opinion to be issued by October 2007. 28/04/2005 Part-66 Part-147 23 28/04/2005 Part-66 Part-147 24

28/04/2005 Part-66 Part-147 25 TOR 66.007 QDB TOR 66.008 Re-issuance of the aircraft maintenance licence Issue: Stakeholders are asking for a question databank for Part-66. Such a databank would standardize the examination level for a Part-66 license in all Member States. Work on a Part-66 question databank was already started by JAA. It has to be decided whether this databank will be the only source of questions. In this case Appendix I of Part-66 should be amended to require only the use of the databank. Specific task: Development of an opinion, as appropriate, to change Appendix I of Part-66 and possible development of a question databank Working methods: Drafting carried out by the Agency. The Agency is studying how to develop the data bank. Time Scale: NPA to be published by June 2006. Opinion to be issued by April 2007, depending of the result of the study above. Issue: Part-66 only requires the licence to be reissued every 5 years without any controls. Some NAAs criticise that this should be reviewed to allow more controls by the competent authority of the actual compliance of the holder with licensing and type rating requirements. Objective: Part-66 only requires the licence to be reissued every 5 years without any controls. Some NAAs criticise that this should be reviewed to allow more controls by the competent authority of the actual compliance of the holder with licensing and type rating requirements. Specific task: Development of an opinion to change paragraphs 66.A.40 and 66.B.120. Time scale: Work starts in March 2005.NPA to be published by December 2006. Opinion to be issued by October 2007. 28/04/2005 Part-66 Part-147 26 TOR 66.011 Type Training TOR 147.005 Records of instructors, examiners and assessors Issue: Presently, the only elements towards designing type training are contained in Part-66 Appendix III. These elements although quite extensive do not seem to be detailed enough to address all the specificities of each different aircraft type. The feedback received by EASA seems to indicate that too much room is left for interpretation and cases of unequal treatment have been reported such as the same training course varying from 2 days to 2 weeks. The development of an AMC should give guidance in this respect. Objective: Equal treatment and timeframe of type training courses. Specific task: Development of a decision to change the AMC to paragraph 66.A.40. Time scale: Work starts in July 2005.NPA to be published by September 2006.Opinion to be issued by June 2007. Issue: In the same way Part-145 AMC 145.A.35(j) asks for detailed records of certifying staff that release aircraft after maintenance, Part-147 organisations should hold a record of instructors, examiners and assessors that evaluate students after training. Objective: Harmonisation of record keeping between different parts. Specific task:development of a decision to introduce AMC to paragraph 147.A.110 Time scale:npa to be published by December 2005. Decision to be issued by October 2006. 28/04/2005 Part-66 Part-147 27 28/04/2005 Part-66 Part-147 28 Fees and charges levied by EASA: the MTOA EASA WORKSHOP Commission Regulation No 488/2005 of 21 March 2005 shall apply to the fees and charges levied by EASA as compensation for the services it provides Point XIII of its Annex establishes that fees are levied for the issue of a Maintenance Training Organisation Approval and for surveillance thereof All new applications for a MTOA attract the fixed fee of EUR 12 000 multiplied by the coefficient indicated for the corresponding fee category for the organisation in question I. Objectives and regulatory framework and scope of competence of the Agency III. Part-66 Part-147, main activities for the future 28/04/2005 Part-66 Part-147 29 28/04/2005 Part-66 Part-147 30

28/04/2005 Part-66 Part-147 31 Part-66 Appendix I Component certifying staff Question Data Bank: The Agency is studying how to develop the data bank Work planned to start as of 2008. Opinion for question data bank: NPA planned for 2 nd quarter 2006 Opinion to be published in 2 nd quarter 2007 One data base=appendix I shall be repealed The result of the working group is not yet known and EASA is waiting for final result. 28/04/2005 Part-66 Part-147 32 Multiple licences Type rating issues In the EU a person may hold a licence in each Member State and each Member State is responsible of the licence it has issued. A Form 19 asks the applicant to confirm that he has not and has never had a licence issued by another Member State. If not the case statement should be crossed out. There are provisions in Section B and the Basic Regulation for communications between Member States. NPA 1/2005 proposes to transfer the list of types ratings to the EASA website. The Agency has proposed to the Commission to extend scope of activities to the approval of type rating content. Once this is done the Agency will start work on this issue (TOR 66.008) this year. With a common QDB and Type ratings defined by the Agency, standardisation will be simplified. 28/04/2005 Part-66 Part-147 33 28/04/2005 Part-66 Part-147 34 Conversion of Licences Scope of the licence Any person holding certification privileges accepted by a Member State is entitled to be issue by that Member State with a license reflecting the above certification privileges. There seem to be differences in the conversion process between Member States. These differences exist as the preexisting systems were sometimes very different. It is not possible to eliminate them. By September 2006 no one may release a commercial aircraft unless holding a Part-66 license. From then on the national differences will have been eliminated. The scope of privileges that can be given to a licence holder is dependent on the type of aircraft maintained. The type should be taken into account by the maintenance organisation when issuing certification privileges. Detailed guidelines cannot cover all situations. 28/04/2005 Part-66 Part-147 35 28/04/2005 Part-66 Part-147 36

28/04/2005 Part-66 Part-147 37 Recent experience Revocation, suspension or limitation of the AML Recent experience requirement are placed both in Part-66 and Part-145 as they are the responsibility of both the license holder and the maintenance organisation issuing certification privileges. Both cases require 6 months of relevant experience. This is more developed in Part-145 and it is clearly not the intent to require such experience on each aircraft type. What is understood as 6 months experience is detailed in Part-145.A.35(c) and the related AMC. In the case of isolated certifying staff, the requirement is more stringent as we only have the Part-66.A.20(b)(2) since there is no system to accompany the certifying staff. National law of each Member State shall determine which is the Competent Authority that shall suspend, limit or revoke the aircraft maintenance licence. In case of conflict regarding the 8 activities specified in 66.B.500, the Courts of Justice will clarify the interpretation of each activity. 28/04/2005 Part-66 Part-147 38 Examiners and assessors Structure of a MTO Today 147.A.105(e) allows the combination of the roles of the instructors, examiners and assessors. They therefore do not need to be independent. As some stakeholders feel that this independence is crucial the Agency has placed this issue on the Rulemaking plan as action 147.003. For the qualification of this personnel, they must be qualified to standards accepted by the Member State. In the same way as for other approvals there is no obligation to structure the MTO in a particular manner. Some basic principles must be followed such as: accountable manager Management Assessors, examiners and trainers 28/04/2005 Part-66 Part-147 39 28/04/2005 Part-66 Part-147 40 Scope of the MTO approval Examination standards The scope is defined in 147.A.145. Basic training to all or part of the Part-66 syllabus. Aircraft type task training. Examinations. As AMC 66.A.45(d) authorises the practical elements of the type training course to be carried out by a Part-145 organisation it is possible for a Part-147 MTO to be approved only for theoretical training. For basic training, there is a 90 days period after a module has been failed before the exam can be taken again. There is no such limit for type training. Item 66.012 of the Rulemaking plan has been created to remedy this. Work will start in the 3 rd quarter 2006. 28/04/2005 Part-66 Part-147 41 28/04/2005 Part-66 Part-147 42

28/04/2005 Part-66 Part-147 43 Validity of the responses Open Questions The status of the answers given during this event is for information purposes only. They do not constitute any formal commitment on behalf of the European Aviation Safety Agency. Interpretation of the rules constituting Community law is carried out by National Courts and the European Court of Justice. Please feel free to ask any question that were not addressed in the summary above 28/04/2005 Part-66 Part-147 44 THANK YOU FOR YOUR ATTENTION www.easa.eu.int 28/04/2005 Part-66 Part-147 45