Transcript EGU Presentation
The European Gliding Union and the Harmonisation of European Regulations in Aviation by the EASA Swedish Gliding Conference Skövde 19 November 2005
European Gliding Union
what is/does the EGU?
the EGU was founded in 1993 in Strasbourg the EGU represents the European glider pilots on the European level the EGU deals only with regulations, not with sports issues the EGU is independent of the FAI and its International Gliding Commission (IGC) the EGU co-operates with Europe Air Sports the EGU counts 17 members national gliding associations (Sweden involved from the beginning!)
the 17 EGU member countries (70,000 pilots 22,000 gliders)
Roland Stuck (FR) President Mathias Borgmeier (DE) Vice President Emil Blumer (CH) Secretary General Jannes Neumann (DE) TO Maintenance Fransois van Haaff (NL) TO Airspace David Roberts (GB) Vice President Patrick Pauwels (BE) Treasurer Mathias Borgmeier (DE) TO Operations Meike Müller (DE) TO Licensing
European Aviation Safety Agency (EASA)
In July 2002 the EU Council and Parliament have decided to apply common rules to aviation and to establish EASA.
The basic regulation of EASA is Regulation (EC) 1592/2002 (scope initially restricted to airworthiness and environmental compatibility but will be extended to licensing and operations) The Annex 2 of this regulation lists the types of aircraft excluded from European regulation EASA regulations are not converted into national laws and apply directly.
EASA is located in Cologne.
Tasks of EASA
Licensing Operations Certification Maintenance long term: Airport Operations long term: Air Traffic Services
Procedures for Rulemaking
Rules are prepared by the Rulemaking Directorate ( Director C. Probst) Two kind of regulations: Essential Requirements (ER) adopted by the Parliament and Implementing Rules (IR) adopted by the Commission All regulations are published on www.easa.eu.int For any change a Notice per Amendment (NPA) must be issued Stakeholders must be consulted Evaluation of the answers by an independant task group
Procedures for Rulemaking
A Comment Response Document (CRD) is issued The EASA then submits an Opinion to the Commission If the Commission agrees the Essential Requirements are submitted to the Parliament If they are adopted they are published Implementing rules are written by a group of experts Implementing Rules are submitted to the Commission If they are adopted they are published
EASA has been tasked to propose Essential Requirements for licensing and operations in May 2004 EASA has published the NPA 2/2004, with basic regulations and 15 questions to the ‘stakeholders‘ Only few of these questions concerned air sports: For which categories of aircraft shall the pilots licences be regulated?
Shall only Essential Requirements (ER) be written or also Implementing Rules (IR)?
What kind of Medical shall apply?
The EGU proposal
After discussion, the EGU has proposed two types of licences: 1. A EU-licence that allows free movement across Europe. Air sports organisations should be allowed to issue this licence. Medical standard may be different from the ICAO Class 2 Standard. Assessment by General Practitioner. 2. An ICAO -licence that allows flight outside the EU and that is issued by the national authorities.
(requires a ICAO Class 2 Medical)
Reaction of EASA
End of November 2004 EASA has published the Comment Response Document CRD 2/2004:
EASA is ready to introduce a "Restricted PPL" for air sports.
They are ready to introduce medical standards different of those of ICAO for this RPPL.
In this case General Practitioners (GP) could be suitable examiners via Implementing Rules.
However flight in airspace with a high traffic density could be restricted.
EGU has objected to such airspace restrictions related to the RPPL and to the name „restricted“ EASA Opinion transmitted to the Commission
Answer from the Commission
„The proposed Regulation would therefore introduce a new category of licence, the „recreational pilot licence“, tailored more closely to this category of airspace users. This license would be issued by assessment bodies approved by the Agency or by the competent national authority. Sports federations could for example fulfil this function“ „In the case of pilots involved in recreational operations, the medical certificate may be issued by a general medical practitioner“ This proposal for modifying Regulation 1592 will now be submitted to the Parliament
In NPA 2/2004 EASA has also published Essential Requirements on Operations EGU has asked EASA to lay down no Implementing Rules for gliding EASA has accepted to keep the IRs at high level ( JAR Ops 0) for all air sports EGU studies a harmonisation of the most important gliding procedures (EGU-internal recommendation) EGU is also collecting statistics on accident
Operations EGU accident statistics
Operations EGU accident statistics
The Regulation (EC) 1702/2003 for certification is already in force.
According to Annex 2 of (EC) 1592/2002 all gliders of more than 80 kg empty mass (single seaters) oder 100 kg (two-seaters) must be certified by EASA.
The approval regulations for gliders has been copied directly (JAR 22 = CS 22 ).
Engines and propellers of SSG and SLG remain in CS 22 An EGU request to have light gliders treated as microlights has been declined
EASA Part 21
According to Part 21 all instruments installed in a glider must have an EASA Form 1 This is a problem for some instruments (variometers, GPS, PDA’s) EGU has asked EASA to reconsider this requirement EASA has accepted to consider these equipments as standard parts not requiring a form 1 NPA to be issued soon
Maintenance is controlled by Regulation (EG) 2042/2003, which is already partly in force for commercial aviation.
Will be valid for sports aviation per 28 September 2008.
Annex 1, called Part M described the technical requirements and the procedure for Competent Authorities Based on the concept of continuous airworthiness maintenance Part M is complex and difficult to read
Overview of Part M (1)
The owner is responsible that the aircraft is maintained in airworthy condition. He may also delegate this responsibility to a Continuing Airworthiness Management Organisation A Pilot-Owner is allowed to perform all maintenance tasks except those defined in appendix VII A Pilot-Owner is allowed to issue a release to service after limited owner maintenance listed in Appendix VIII
Overview of Part M (2)
Every aircraft shall be maintained in accordance with a maintenance programme approved by the Competent Authority Repairs shall be carried out using data approved by the EASA or by an approved design organisation (DOA) The Certificate of Airworthiness is not time limited if associated with a valid Airworthiness Review Certificate (ARC) All certifying staff or airworthiness staff involved in maintenance has to be qualified according to Part 66 (not valid for gliding)
Subparts F and G Organisations
A Maintenance Organisation (Subpart F Organisation or MOA) is allowed to perform all maintenance tasks and to issue a release to service A Continuing Airworthiness Management Organisation (Subpart G Organisation or CAMO) is allowed to manage the continuing airworthiness of aircraft under contract, to approve maintenance programmes and to perform an airworthiness review including a physical survey A CAMO + is allowed to issue an Airworthiness Review Certificate (ARC) in case of a controlled environment
The owner is responsible for the continuing airworthiness. Maintenance task except those defined in appendix VII can be done by the Pilot Owner Tasks listed in appendix VIII can be released by the Pilot-Owner The owner can also delegate all maintenance to a MOA Once a year an airworthiness review including a physical survey has to be done by a CAMO The CAMO can only issue a recomendation to the Competent Authority to issue the ARC
The owner has a contract with a CAMO + to delegate the responsibility of the continuing maintenance He has to report the flight hours on a regular basis The CAMO+ will issue written orders for maintenance tasks according to the approved programm. Tasks can be fulfilled by a MOA or the pilot owner Once a year the CAMO+ performs an airworthiness review. This can be done twice on a document basis and the validity of the ARC can be extended Every 3 years the CAMO+ issues a new ARC after a physical survey
Most gliding federations have a broad delegation for the maintenance of their fleet This has proven to be pragmatic, cheap and safe!
Will they be allowed to continue in the framework of Part M ?
In principle : Yes (controlled environment) How ? One single Subpart F/G or one per club ?
More paperwork, more costs ?
Need of a maintenance programm for each glider ?
Maintenance more complicated in the uncontrolled environment ( 2 procedures instead of one)
RIA on Part M
EASA has mandated an independent consultant (Air Euro Safe) to conduct a Regulatory Impact Assessment (RIA) of Part M EGU answered this consultation Meeting with EASA in Frankfurt (disapointing) EASA has issued NPA 07-05 in June: Only few changes concerning gliding were accepted Meeting EAS-EASA in Cologne: some windows were opened EGU has prepared comments to answer the NPA (sent out to the members for approval) Deadline for answering: 24 November!
In 2003 Eurocontrol was given a mandate by the EU to harmonise the airspace structure in Europe ( Project Single European Sky) in the future there will only be 3 categories of airspace: I(ntended), K(nown) and U(nknown), later I and U only The EGU was involved in the discussions and has sent a position paper Upper Division Level: FL 195. According to ENPRM 05-0012 the airspace above FL 195 is Class C in most countries (i.e open to VFR flying) Lower Division Level (FL Z): decided on national basis => Status Quo
After discussion with the EGU and other parties Eurocontrol has also published an interesting report on the detection and recognition of light aircraft. The EGU made recommendations about: Low power transponders, Transponder Mandatory Zones (TMZ)
The EGU has requested FAI to submit to ICAO a request to consider the abolishement of the requirement for VFR-VFR traffic information 8.33 KHz is still not for the lower airspace but EGU has reminded Eurocontrol of the consequences the implementation would have The EGU Airspace Working Group has agreed upon an airspace survey paper
The EGU is active and well organised The EGU is recognised by EASA as a competent partner The EGU must speak with one single voice!
The EGU needs your support!
More info on: www.egu-info.org