Transcript Diapositive 1 - European Aviation Safety Agency

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
4 September 2007
United Kingdom
European Aviation Safety Agency
Contents of the presentation
General presentation of the A-NPA
Useful definitions in the context of
the A-NPA
Background
Working method
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European Aviation Safety Agency
Contents of the presentation
The concept:
aviation
The concept:
The concept:
The concept:
4 September 2007
state of play in general
principles
description
discussion points
A concept for better regulation in general aviation
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European Aviation Safety Agency
Contents of the presentation
The next steps
Summary and conclusions
Attachment 1:
EASA: general
Attachment 2:
The concept: discussion points
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European Aviation Safety Agency
General presentation of the ANPA
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.
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European Aviation Safety Agency
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;
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European Aviation Safety Agency
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;
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European Aviation Safety Agency
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.
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European Aviation Safety Agency
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.
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European Aviation Safety Agency
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.
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European Aviation Safety Agency
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
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European Aviation Safety Agency
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
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European Aviation Safety Agency
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
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European Aviation Safety Agency
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
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European Aviation Safety Agency
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
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European Aviation Safety Agency
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)

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European Aviation Safety Agency
The concept: description
Continuing airworthiness and maintenance:
Adjusting Part-M to the need of aircraft
other than complex-motor-poweredaircraft:

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.
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European Aviation Safety Agency
The concept: description
Air operations:
Develop a set of light implementing rules
and acceptable means of compliance
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European Aviation Safety Agency
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.
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European Aviation Safety Agency
The concept discussion points
7 questions were asked to help
defining the follow-up of the concept.
They are detailed in Attachment 2
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European Aviation Safety Agency
The next steps
Comment response document:
3200 replies generating more than 7250
comments
CRD to be published July 2007
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European Aviation Safety Agency
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.
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European Aviation Safety Agency
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
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European Aviation Safety Agency
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
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European Aviation Safety Agency
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
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European Aviation Safety Agency
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
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European Aviation Safety Agency
Summary and conclusions
Comprehensive concept
Important rulemaking activities
Still significant amount of work to do!
Thank you for your attention:
Questions are welcome
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European Aviation Safety Agency
Attachment 1
EASA general
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European Aviation Safety Agency
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.
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European Aviation Safety Agency
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)
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European Aviation Safety Agency
EASA: present regulations
structure
Basic Regulation
Regulation (EC) 1592/2002 of 15 July 2002
Regulation (EC) 1702/2003 on
Airworthiness and Environmental
Certification
Annex II : Excluded Aircraft
Regulation (EC) 2042/2003
on Continuing Airworthiness
Section A: Application
Requirements
Annex (Part 21)
Annex I : Essential Requirements
for Airworthiness
Section B: administrative
Procedures
Appendices: EASA forms
Annex I (Part-M):
Continuing Airworthiness
Requirements
Section A: Technical
Requirements
Annex II (Part-145):
Maintenance Organisation
Approvals
Appendices: EASA forms
Agency
Opinion
Agency
Opinion
Section B: Administrative
Procedures
Annex III (Part-66):
Certifying Staff
Annex IV (Part-147):
Training Organisation
Requirements
Guidance
Material
Part 21
Parliament and Council
European Commission
EASA
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Certification
Specifications
AMC
20
AMC
21
CS 25
CS 34
CS 36
CS E
CS P
CS
APU
CS AWO
CS ETSO
CS Definitions
CS
CS
CS
CS
CS
CS
22
23
27
29
VLA
VLR
AMC &
Guidance
Material
Part M,
145,66,147
A concept for better regulation in general aviation
Agency
CS ,
AMC &
GM
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European Aviation Safety Agency
Attachment 2
The concept: discussion points
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European Aviation Safety Agency
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
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European Aviation Safety Agency
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
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European Aviation Safety Agency
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?
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European Aviation Safety Agency
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
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European Aviation Safety Agency
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.

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European Aviation Safety Agency
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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