CertificationMaintenance Session

1
Implementation of Design Approval Holder Rules

• Certification/Maintenance Session

2
DAH Rule Implementation

• DAH rules are a new approach for facilitating
  timely implementation of certain complex,
  fleet-wide safety initiatives.
• DAH rules rely on a proactive, program management
  approach.
• Requirements for compliance plans and draft
  data/document submittals, in addition to final
  data/documents

3
FAA DAH Rules

• The FAA has issued two final rules containing DAH
  requirements
• Enhanced Airworthiness Program for Airplane
  Systems (EAPAS)
• Final Rule published November 8, 2007
• Aging Aircraft Safety Rule (AASR)
• Final Rule published December 12, 2007
• The FAA expects to issue the Widespread Fatigue
  Damage (WFD) and Flammability Reduction Means
  final rules this year.

4
Coordination FAA/TCCA/EASA/ANAC

• The FAA, TCCA, EASA, and ANAC have been in close
  coordination since early 2005 to
• Share draft rulemaking and guidance documents to
  facilitate harmonization
• Develop a joint Design Approval Holder (DAH) rule
  implementation strategy
• Define a plan to support each others aging
  aircraft rule implementation program
• TCCA, EASA, and ANAC intend to issue similar
  rules.

5
FAA DAH Rule Implementation

• To support the implementation of these DAH rules,
  we took the following actions
• Pre-rule issuance
• Issued an FAA Order and Advisory Circular
• Formed teams for compliance and standardization
  activities within the FAA
• Developed and conducted internal
  training/workshops on the technical and program
  management aspects of these rules
• This material was also offered to TCCA, EASA and
  ANAC
• Coordinated with TCCA, EASA and ANAC

6
FAA DAH Rule Implementation

• To support the implementation of these DAH rules,
  we took the following actions (cont)
• Post-rule issuance (to-date)
• Issued letters to affected DAHs
• informed them of the rule issuance
• offered training materials
• requested a meeting
• Conducted familiarization meetings with DAHs
• reviewed rule requirements and compliance
  expectations
• emphasized need for close coordination
  throughout program
• Worked closely with DAHs, EASA, TCCA, and ANAC
  during compliance plan development activity

7
FAA EAPAS Rule Summary

• EAPAS Requirements
• New and revised safety standards for design,
  installation, and maintenance programs related to
  electrical wiring systems.
• DAHs to develop enhanced maintenance actions by
  December 10, 2009.
• Supporting requirements
• Compliance plans due March 10, 2008
• Draft data/documents due October 10, 2009
• Operators to incorporate those actions into their
  maintenance programs by March 11, 2011.

8
FAA EAPAS Rule Status

• Compliance plans due 3/10/08
• Status Almost 100 of required plans submitted
  (1700)
• We are actively working to obtain compliance from
  the few DAHs who have not yet completed this
  requirement
• We are reviewing compliance plans and formally
  responding to DAHs
• FAA will continue to closely coordinate with
  DAHs, TCCA, EASA, and ANAC as DAHs develop their
  draft and final data/documents.

9
FAA AASR Rule Summary

• AASR Requirements
• DAHs to develop damage tolerance (DT) based
  inspections by June 30, 2009.
• Supporting requirements
• Compliance plans (TC Holders) due April 10, 2008
• Compliance plans (STC Holders) due July 9, 2008
• List of Fatigue Critical Baseline Structure (TC
  Holders) due July 9, 2008
• List of Fatigue Critical Alteration Structure
  (STC Holders) due January 5, 2009
• Draft DT based inspections due April 30, 2009
• Repair Evaluation Guidelines (TC Holders) due
  December 30, 2009
• Operators to incorporate those DT based
  inspections into their programs by December 20,
  2010.

10
FAA AASR Rule Status

• Compliance plans (TC Holders) due April 10, 2008
• Status 100 of required plans submitted (40)
• We are reviewing compliance plans and plan to
  formally respond to DAHs by the end of May
• FAA is actively working with STC holders to
  prepare for the 3000 plans to be submitted by
  July 9, 2008.
• FAA will continue to closely coordinate with
  DAHs, TCCA, EASA, and ANAC as DAHs develop their
  draft and final data/documents.

11
TCCA Regulatory Plan

• To propose change to CAR 521 (DAH rules) and CAR
  605 (operating rules)
• per CARAC working group report approved Oct 4/07
• to be technically similar to FAA, EASA and ANAC
• action now to proceed through regulatory process
• estimate 2012 timeframe for new rules
• In short term, coordinated with FAA/EASA/ANAC,
  TCCA will use existing Canadian requirements,
  where applicable.

12
EASA Cooperation with Other Authorities

• Very good cooperation with ANAC, FAA and TCCA
  both in rulemaking and certification fields
• Rulemaking
• In the context of the rulemaking cooperation
  procedures with FAA and TCCA.
• Monthly teleconferences
• Certification
• EASA is providing assistance to FAA to implement
  the AASR and EAPAS rules.
• Workshop organised in 14 December 2007
• Regular (bi-weekly) teleconferences

13
EASA Rulemaking Framework for Aging Aircraft
Activities

• Design Approval Holder rules
• Long term included in the Basic Regulation
  216/2008
• Revised article 5 request to create provisions
  into Part-21 with regard to
• Syllabus for Maintenance certifying staff type
  rating training, syllabus of pilot type rating
  training, MMEL, additional airworthiness
  specifications for a given type of operations
• Task 21.039 of rulemaking programme
  Incorporation of operational issues in Type
  certificate.
• NPA scheduled 4 quarter 2008
• Opinion scheduled 3 quarter 2009.
• One of the options under consideration for DAH
  rule would be a concept of Safety Enhancement
  Directive

14
EASA Rulemaking Framework for Aging Aircraft
Activities

• Design Approval Holder rules
• In the meantime for Aging Systems
• Use of Paragraph 21A.3B (c) (1) that broadly
  says
• When an airworthiness directive has to be issued
  by the Agency, the DAH shall propose the
  appropriate corrective actions or required
  inspections and submit details of these proposals
  to the agency for approval.
• The Agency would sent letters to request review
  of ICA to incorporate results of EZAP by DAH
  holders.
• Airworthiness Directives would be issued only in
  case of non-cooperation by a DAH.
• When ICA are amended by DAH, Operators are
  required by Part-M to incorporate them into their
  maintenance programmes.
• TCDS will record compliance to EWIS ICA
  provisions (Appendix H.25.5)

15
EASA Rulemaking Framework for Aging Aircraft
Activities

• In the meantime for Aging Systems
• Pending modification of TCDS, generic special
  conditions quoting the relevant paragraphs of
  CS-25 as modified by the EWIS NPA will be
  systematically issued for approvals of
  modifications affecting EWIS when application is
  after the amendment to CS-25 (June 2008)

16
EASA Rulemaking Framework for Aging Aircraft
Activities

• Maintenance rules
• Maintenance programmes
• Part-M M.A.302 requires maintenance programmes to
  be based on data produced by TC holders, STC
  holders or organisations required to by Part-21
• (f) The maintenance programme must be subject to
  periodic reviews and amended when necessary. The
  reviews will ensure that the programme continues
  to be valid in light of operating experience
  whilst taking into account new and/or modified
  maintenance instructions promulgated by the Type
  Certificate holder.
• (g) The maintenance programme must reflect
  applicable mandatory regulatory requirements
  addressed in documents issued by the Type
  Certificate holder to comply with Part 21A.61.
• Anything else requires the approval by the
  competent authority. In the case of ALIs this is
  EASA.

17
EASA Rulemaking for Aging Systems

• NPA 2007/01 EWIS
• (Electrical Wiring Interconnection Systems)
• Published February 2007
• CRD published March 2008
• Expected final rule June 2008
• Technically equivalent to FAA rules
• Vehicle for retroactive application different
  (see previous slides)
• Both TC holders and STC applications after final
  rule date will be addressed
• Dates will be aligned with FAA
• TC holder to gain approval of enhanced ICAs by 10
  Dec. 2009 (7 June 2010 for future STC)
• Operator implementation by 10 Dec. 2010 according
  to M.A.302 (7 June 2011)

18
EASA Rulemaking for Aging Systems

• CS-25
• New CS-25 Subpart H containing all wiring related
  requirements in one place, titled Electrical
  Wiring Interconnect System (EWIS).
• Amendments to existing CS-25 requirements that
  are necessary due to the creation of the new
  subpart H.
• Amendment to appendix H of CS-25 Instructions for
  Continued Airworthiness with associated AMC.
• Creation of new Advisory Material in CS-25 book 2
  to support the new Subpart H and CS 25.1357(f).

19
EASA Rulemaking for Aging Systems

• Others
• Amendment to part M to revise
• AMC.M.A.302 for maintenance programmes, and
• M.A.706 for training requirements
• Amendment to Part 66 syllabus module 7.7 to
  reflect EWIS training recommendations
• Introduction of three new AMC 20 leaflets
• AMC 20-21 EZAP
• AMC 20-22 EWIS Training Programme
• AMC 20-23 Electrical Standard Wiring Practises
  Manual

20
EASA Rulemaking for Aging Structure

• Development of an aging aircraft structure plan
• Rulemaking group MDM.028 put in place in October
  2007 with FAA participation.
• Three main tasks
• Large aeroplanes
• NPA 3rd quarter 2008
• Opinion/ Decision 3nd quarter 2009
• Other aircraft
• NPA 4th quarter 2008
• Opinion/ Decision 4th quarter 2009
• Change of operational use.
• NPA 4th quarter 2008
• Opinion/ Decision 4th quarter 2009

21
EASA Rulemaking for Aging Structure

• Large aeroplanes Develop the technical elements
  for a plan (I)
• Review the 5 ageing aircraft issues
• Corrosion prevention and Control
• Damage tolerance based inspections for all
  structure including repairs and modifications
• Widespread fatigue damage
• Service bulletins review
• Mandatory Modification Programmes
• Identify options for implementation to both the
  existing and future fleet. Consideration should
  be given to both mandatory and non-mandatory
  actions and to which aircraft and operations
  these actions would be applicable.

22
EASA Rulemaking for Aging Structure

• Large aeroplanes Develop the technical elements
  for a plan (II)
• Select options and justify proposed actions
  through development of a Regulatory Impact
  Assessment.
• For issues deemed to be mandatory, develop the
  following points, based on the technical work and
  recommendations previously established
• The actions needed to be accomplished by the
  TC/STC holder and operators and the timescales
  necessary for compliance
• Rule and AMC material for incorporation into
  maintenance requirements
• New standards to be included in the CSs as
  necessary.

23
EASA Rulemaking for Aging Structure

• Other aircraft
• Develop a Regulatory Impact Assessment (RIA) for
  identifying the need to go beyond large
  aeroplanes
• Based on the results of the RIA, develop
  comparable technical elements for a plan in a
  comparable manner as for task 1.
• Review and develop AMC 20-11, to reflect its
  wider applicability, as necessary
• Change of operational use
• Amend xx.1529 to add a requirement on the TCH to
  publish key assumptions used in the structural
  analysis.
• Propose compatible changes to Part M as necessary
  to ensure operators observe these assumptions.

24
Summary

• Early coordination between the FAA, TCCA, EASA,
  and ANAC helped
• maximize harmonization of rules and guidance
• support standardized rule implementation
• define a plan for mutual support of our
  respective aging aircraft rules and
  implementation programs
• Our proactive program management and
  collaboration has facilitated timely DAH
  compliance with requirements.
• We look forward to our continued partnership with
  Civil Aviation Authorities and industry to ensure
  compliance with these important safety
  initiatives.