Bordeaux

1
EASA presentation Various Update

• EAMTC - Bordeaux
• 06/07 October 2009
• Jean-Pierre Arnaud / EASA Rulemaking Directorate

2

• Content

3
Content

• 1. 2nd extension of EASA remit
• 2. CRD to NPA 2007-07
• 3. CRD to NPA 2008-03 B3 license and L license
• 4. List of Type rating training (TRT)
• 5. OSC / CS-MCS NPA 2009-01
• 6. European Question Data Bank
• 7. Rulemaking programme

4

• 1. 2nd extension of EASA remit

5
1. 2nd extension of EASA remit

• Regulation 3641/09 was adopted on 07/09/2009 and
  amends regulation (EC) No 216/2008 with a view to
  improving the safety of aerodromes, air traffic
  management and air navigation services.
• The regulation extends EASA's competences to
  cover the safety of aerodromes, air
  traffic-management and air navigation services.
• In particular, the EASA's new tasks will cover
  rule-making and standardisation inspections.
• In addition, as far as air traffic management and
  air navigation services are concerned, it will be
  necessary to coordinate the common safety rules
  properly with the new Single European Sky
  regulation and the related implementing rules.
• The regulation repeals Council directive 06/23/EEC

6

• 2. CRD to NPA 2007-07

7
CRD to NPA 2007-07

• 3 rulemaking tasks gave birth to NPA 2007-07.
• 66.006 - Privileges of B1 and B2 Aircraft
  maintenance licence
• 66.009- Type and group ratings
• 66.011 - Type training

8
CRD to NPA 2007-07

• 440 comments to NPA 2007-07 were received
• CRD ready for public consultation today
• Please read and comment there are so numerous
  changes your help is welcome
• The following slides reflects the main changes
  introduced after the NPA.

9
CRD to NPA 2007-07

• Privileges of B1 and B2 Aircraft maintenance
  licence

10
CRD to NPA 2007-07

• 66.A.20(a)3(i) has been amended in order to
  extend the privileges of the B2 licence to
  maintenance on electrical and avionics parts
  within powerplant and mechanical systems,
  requiring simple tests to prove their
  serviceability (not only on air conditioning
  systems, fire warning systems, ice rain
  protection systems and fuel system indications as
  was proposed in the NPA).
• Appendixes I, II and III have been amended in
  order to introduce an increase of knowledge,
  training and examination requirements and the B2
  basic course duration has been increased to 2400
  hours from the 2000 hours proposed in the NPA.

11
CRD to NPA 2007-07

• AMC 66.A.20(a) has been amended in order to
  further clarify the concepts of Electrical
  System, Avionics System, Simple Test and
  Troubleshooting. Definitions are given
• AMC 66.A.45(b) has been introduced to provide
  further guidance for the additional privilege of
  the B2 licence holder to perform minor scheduled
  line maintenance and simple defect rectification
  (see 66.A.20(a)3(ii) and 66.A.45(b)).

12
CRD to NPA 2007-07

• 66.009 - Type and group ratings

13
CRD to NPA 2007-07

• 66.009 - Type and group ratings
• In fact, this task is dedicated to the licensing
  system and is for the NAAs
• Read GM 66.A.45 in order to better understand new
  66.A.45
• Read 66.B.125 in order to transfer the current
  system into the new one

14
CRD to NPA 2007-07

• 66.011 - Type rating training

15
CRD to NPA 2007-07

• What Type Rating Training means
• The type rating training is always composed of
• Theoretical portion
• Practical portion.
• For consistency reasons with forthcoming
  rulemaking task 21.039 (Operational Suitability
  Certificate the minimum syllabus provided by
  the TCH will be limited to the theoretical and
  the practical elements), the OJT is not
  considered to be part of the type rating
  training.
• The OJT will only be mandatory and additional in
  the case of the first type training in an AML
  (sub) category in addition to the practical
  training, so that the mechanic can gain
  experience in addition to the practical portion
  of the type rating training.

16
CRD to NPA 2007-07

• The OJT is training that is in addition to the
  practical portion of the type rating training and
  shall remain under the supervision of a
  supervisor it means that a programme shall be
  set up only by an approved maintenance
  organisation and imparted under the oversight of
  a designated supervisor
• In addition this OJT leads to an assessment. All
  these elements shall be acceptable to the
  Competent Authority responsible for the type
  rating training endorsement.

17
CRD to NPA 2007-07

• When OJT is compulsory, on which aircraft type is
  it permitted to be carried out?
• The OJT can only be performed on the relevant
  aircraft type and not on any aircraft type
  relevant to the AML (sub) category being sought
• Reason this Part-66 requirement is the basis for
  granting that particular type rating on the AML
  of a holder who does not so far have experience
  in this (sub) category. It is not the basis for
  the certifying staff authorisation within a
  maintenance organisation.

18
CRD to NPA 2007-07

• AMC 145.A.35(a) the issuance of the
  authorisation to the certifying staff on a
  specific aircraft type (in addition to the passed
  type rating training) within the maintenance
  organisation should be based on criteria
  including the assessment of the competency such
  as
• The attitude
• The general practical experience (that may differ
  from the practical portion imparted during the
  type rating training)
• The knowledge of procedures applicable to the
  maintenance organisation and the operator /
  customer
• the need for differences training between the
  generic aircraft type rating training that the
  person has received and the aircraft
  configuration of the aircraft to be maintained
• the variant difference training (training
  required to cover the identified differences
  between variants within an aircraft type rating
  when the type rating training that the person has
  received does not cover (a) variants)
• the needs for additional specialised training
  which are not part of the typical type rating
  training such as in depth trouble shooting,
  rigging, engine run-up, extensive structural
  repair or specialised inspection etc
• AMC 66.A.20 (b)3 achieves the same goal.

19
CRD to NPA 2007-07

• Theoretical portion of the type rating training
  minimum duration
• The concept of the duration for the theoretical
  portion of the type rating training has been well
  perceived by the readers even if it does not
  solve all the difficulties as already explained
  in the explanatory note of the NPA, the
  stakeholders have correctly understood that the
  outcome of NPA 2009-01 (Operational suitability
  certificate) will bring more solutions to that
  concern. Therefore the principles have been kept
  and improved.
• There are now 3 categories
• Below 5.7T
• Between 5.7T and 30T
• Above 30T

20
CRD to NPA 2007-07

• Flexibility provisions and training needs
  analysis
• All type rating training courses will have to be
  approved in accordance with these new
  requirements at the latest 18 months after its
  publication in the Official Journal of the
  European Union.
• After that date, these courses must fully comply
  with the requirements of this Regulation
  amendment, except that there is no need to
  produce a TNA for courses where the duration is
  already above the minimum duration described in
  Appendix III to Part-66.
• A Training Needs Analysis (TNA) has been proposed
  as a GM for courses below the minimum duration.

21
CRD to NPA 2007-07

• Maximum number of training hours per day
• For the sake of training efficiency, the number
  of tuition hours per day for the theoretical
  training shall not exceed 8 hours, which shall be
  performed during regular office hours in
  exceptional cases, deviation from this standard
  may be envisaged when justified. This maximum
  number of hours is also applicable for the
  combination of theoretical and practical
  training, when they are performed at the same
  time.
• The resulting text has been adjusted in Part-66
  appendix III (type training) and will become
  mandatory for all type training provided by a
  Part-147 organisation or in the case of a direct
  approved course).
• For consistency, an AMC has been added to
  147.A.200(f) (basic training course)

22
CRD to NPA 2007-07

• Attendance (policy in the case of absenteeism)
• Minimum participation time is at least 90 percent
  of the tuition hours for the theoretical training
  course. If this criterion is not met, the
  certificate of recognition shall not be issued.
  Additional training may be given by the training
  organisation in order to meet the minimum
  participation time.
• The resulting text has been adjusted in Part-66
  appendix III (type training) and will become
  mandatory for all type training provided by a
  Part-147 organisation or in the case of a direct
  approved course).
• For consistency, the Agency recommends to add the
  same minimum attendance criterion to the basic
  knowledge training in a Part-147 environment (see
  new AMC 147.A.200 (f)).

23
CRD to NPA 2007-07

• Miscellaneous 66.O11 (TRT)
• The examination process has been reviewed
• Correspondence between the theoretical and the
  practical tables please check consistency
• Run-up is not part of the TRT
• Practical training AMC recommends the the
  minimum duration to be 2 weeks for complex
  motor-powered aircraft.

24

• 3. CRD to NPA 2008-03 B3 license and ELA license

25
CRD to NPA 2008-03 B3 license and ELA license

• Category B3 is applicable to piston-engine
  non-pressurized aeroplanes of 2000 Kg MTOM and
  below.
• duration now 1000h instead of 900h.
• Category L is applicable to any of the following
  aircraft
• Sailplanes, powered sailplanes and aeroplanes
  with MTOM less than 1000 Kg
• Balloons
• Hot-air airships
• Manned gas airships meeting certain criteria.
• Note A helicopter is not considered to be an
  aeroplane

26
CRD to NPA 2008-03 B3 license and ELA license

• In NPA 2008-03 a conversion of national
  qualifications to L and B3 licences was not
  envisaged for the following reasons
• B3 licence It was expected that all the eligible
  persons had already been converted to B1.2.
• L licence It was expected to be very complicated
  to establish an adequate conversion report and in
  any case, the training required for the L licence
  was not large.
• Based on the significant number of comments
  received from NAAs and Industry, the CRD now
  specifies that conversion will be possible
  following 66.A.70.
• It is anticipated that difficulties may arise to
  establish adequate conversion reports

27
CRD to NPA 2008-03 B3 license and ELA license

• CRD of NPA 2008-03 for "Licenses for non-complex
  aircraft maintenance engineers" (B3 license and
  ELA license) was published on 17 September
  2009. It is now open for consultation on EASAs
  website until 16 November 2009.
• The tasks is now called B3 and L license
• See http//hub.easa.europa.eu/crt/docs/viewcrdpdf
  /id_28
• To place comments please logon at
  http//hub.easa.europa.eu/crt/

28

• 4. List of Type rating training (TRT)

29
List of Type rating training (TRT)

• Appendix I to Part 66 Aircraft type ratings for
  Part-66 Aircraft Maintenance Licences
• Current decision 2008/03
• Next one in progress
• NPA 2009-05 was issued on 4 May 2009.
• Will follow the full rulemaking process (3 month
  consultation)
• Frequency once a year (neither ToR nor RIA)
• New structure (see example)
• MTOs are expected to use this taxonomy use of
  the Data sheet designation (in order to avoid any
  reference to the commercial designation)

30
List of Type rating training (TRT)

• 121 comments received.
• CRD of NPA-2009-05 "Appendix 1 Aircraft type
  ratings for Part-66 aircraft maintenance licence"
  is now open for consultation on EASA website
  until 25 Nov 2009.
• See http//hub.easa.europa.eu/crt/docs/viewcrdpdf
  /id_76
• To place comments please logon at
  http//hub.easa.europa.eu/crt/
• Resulting text all changes from current Decision
  2008-03 are tracked.

31
Minimum syllabus of training

• 5. NPA 2009-01
• (OSC concept)
• CS-MCS
• (Certification specification- Maintenance
  certifying staff)

32
Minimum syllabus of training

• NPA 2009-01 (OSC concept)
• Issued 15 January 2009 public consultation
  extended until 30 June 2009
• 1011 comments received.
• Timing
• CRD to be issued for late summer 2010
• Opinion to MDM.039 (OSC - NPA 2009-01) should be
  published by mid-2011 so that the respective
  Commission regulations can be adopted by April
  2012.

33
Minimum syllabus of training

• First review of the comments.
• The OSC (Operational Suitability Certificate) may
  be treated in a way similar to the Instructions
  for Continuing Airworthiness (ICA) and therefore
  it could be called OSD (Operational Suitability
  Data).
• Therefore there will be no additional certificate
  provided by the TCH.
• Catch-up for existing aircraft type still under
  discussion.
• Safety directives still under discussion.

34
Minimum syllabus of training

• CS-MCS (Certification specification- Maintenance
  certifying staff)
• The review of the comments for the OSC has no
  impact there will always a need for developing
  the certification specifications relative to the
  maintenance certifying staff.
• 5th meeting was in June 09 and next meeting will
  be held in November 2009.
• The core group for the OSD has agreed for a
  definition of minimum syllabus for pilots and
  this might inspire maintenance
• I will update you at the next EAMTC conference.
• http//www.easa.eu.int/ws_prod/c/c_flightstandards
  _OEB_final_report.php

35
QDB

• 6. European Question Data Bank
• (QDB)

36
QDB

• During summer 2009, a call for tender was issued
  in order to select the company responsible for
  the development of multiple-choice questions
• for theoretical examinations in the field of
  flight crew licensing (10000) and
• For aircraft maintenance licenses including the
  B3 license (20000).
• You may access the study from Lplus, where the
  methodology of how to produce a MCQ and a QDB is
  described at the following URL
  http//www.easa.europa.eu/ws_prod/r/r_research.php
  

37

• 7. Rulemaking programme

38
Rulemaking programme

• Regarding the timeframe, Member States expressed
  their concerns that with the current approach it
  will be difficult to meet the deadlines of
  Regulation (EC) No 216/2008 (8 April 2012 at the
  latest).
• A clear prioritisation in all rulemaking tasks
  was requested.
• Member States suggested
• that the NPA related to operations and pilot
  licensing are to be treated first,
• whereas the NPA related to operational
  suitability certificate (OSC), third country
  operators (TCO), simple design aircraft,
  authority and organisation requirements (AOR),
  SAFA implementing rules and leisure flights could
  be dealt with at a later stage.

39
Rulemaking programme

• On 15/09/09, the EASA management board with the
  blessing of the EU commission reviewed the
  Rulemaking Programme.
• All EASA opinions related to the first extension
  will be published by mid-2011 (OPS, FCL etc) so
  that the respective Commission regulations can be
  adopted by April 2012.
• The implementing rules for the second extension
  shall be adopted by the end of 2012 (Air Traffic
  Management/Navigation Services) and 2013
  (Aerodromes) respectively.
• Transition phases of 1-2 years will allow Member
  States and industry to better adapt to the new
  rules.

40
Rulemaking programme

• Here after some of the consequences for Part 66 /
  147.
• MDM.055 new structure for regulation EC
  n2042/2003 and SMS embodiment following the OPS
  structure Opinion to be ready in 2012-01 instead
  of 2011.01
• MDM.039 (OSC - NPA 2009-01) should be published
  by mid-2011 so that the respective Commission
  regulations can be adopted by April 2012.
• CS-MCS minimum syllabus for maintenance
  Opinion to be approved 2012-02

41
Rulemaking programme

• Regarding awaiting Opinions and NPAs in
  progress

42
Rulemaking programme

• The following package shall be approved by the
  Parliament and Council on Nov 2009
• Opinion 06/2005 (editorial changes)
• Opinion 04/2006 (Officially recognised standard)
• Opinion 05/2006 (Principal place of business)
• Opinion 04/2007 (Permit to fly)
• Opinion 04/2008 (EWIS)
• Opinion 06/2008 (EASA Form 1)
• The following opinions should be approved before
  the end of 2010 for
• NPA 2007-07 (B1/B2 privileges, type rating
  training, licensing system)
• NPA 2008-03 (B3 license and L license)
• Opinion 05/2008 (Time limit for demonstrating
  compliance with basic knowledge and experience)
• 66.027 B4 license NPA starts 2011

43
Rulemaking programme

• Other rulemaking tasks
• MDM.047 (updating of EC n2042/2003 with EC
  n216/2008) no impact for Part 66/147. Opinion
  to be ready in 2011-02 instead of 2010-01
• MDM.056 review of the ICA NPA planned in 2011.
• MDM-059 Miscellaneous of Parts 66, 147 / start
  2013 / end 2016
• 66.014 66.A.200 develop requirement for
  component certifying staff and for aircraft other
  than aeroplanes and helicopters no schedule
• 66.013 alcohol and drug testing / may start
  2013.01
• 66.018 (Avoiding the splitting of examination for
  the basic knowledge module) a new option for the
  ToR aiming at limiting the splitting should be
  proposed / no schedule

44
Miscellaneous

• SSCC meeting 09 June 09
• Election of the EM vice-chair
• Frank Kabuth is elected as vice-chairman of the
  sub SSCC Engineering and Maintenance.

45

• If you have any questions on this presentation
  please contact Jean-pierre.arnaud_at_easa.europa.eu
  
• END