Title: STEINBEIS TRANSFERZENTRUM AERODYNAMIK FLUGZEUG- UND LEICHTBAU
1Luftsport und EASA Bericht die Entwicklungen bei
der EASA, über Part M, Gebühren und
mehr von Werner micro Scholz, Sprecher
der European Sailplane Manufacturers Tagung
Technik des BWLV, Stuttgart 5.4.2008
2über den Vortrag und den Vortragenden
- Auszug aus den Berichten für die Europäischen
Segelflugzeughersteller - Mer könnet alles nua koi Hochdeutsch deshalb
Folien in Neudeutsch - Werner micro Scholz
- Segelflieger seit 1980
- Akaflieg Stuttgart
- Icaré Solar-Motorsegler
- Rolladen-Schneider
- STZ-AFL Sprecher der Hersteller
- kein Prüfer
3über den Vortrag und den Vortragenden
4über den Vortrag und den Vortragenden
5EASA the most important topics in 2007/08
- new Fees Charges regulation
- Part M maintenance / continuing airworthiness
- Part 66 maintenance staff
- MDM.032 simple rules for small aviation
- new / closed topics since 2005
- Certification of sailplane equipment
- crashworthiness of glider cockpits
6EASA regulations system
7new EASA Fees Charges regulation
- EASA committee (all member states) voted
positively for new FC regulation on 16.4.07 - still the political will iscertification
shall be paid by the industry - EASA certification costs approx. 45 Mio. per
year - most fees are now flat fees (not charged on an
hourly basis which has been set to 225) - Anmerkung nicht zu verwechseln mit kommender
neuer LuftKostV !!
8new EASA basic regulation 0216/2008
- published in the European Journal on 19.3.2008
and will enter into force 20 days later - EASA will be also responsible for operations
(OPS) and licenses (FCL) - basic rules for OPS and FCL (e.g. medicals will
not be dropped completely, language proficiency,
etc.) - adoption of ICAO rules in Europe
- definition of commercial activities
- clarification of Annex II definitions
9Part M maintenance / cont. airworthiness
- Part M is published and in use since
2003,nevertheless the member states opted to use
national regulation for operations excluding
commercial air transport until 28.9.2008 - this date is still fixed it is written in
2042/2003 and can therefore only be changed by
the European Commission (not EASA) - EASA stated always that Part M was written to
let existing maintenance continue - nevertheless EASA has already accepted that the
regulation is too onerous for small aviation
10Part M maintenance / cont. airworthiness (cont.)
most problematic aspects for small aviation
- the renewal (now Airworthines Review
Certificate ARC) will not be issued directly
after the physical inspection but by the
competent authority or by an organisation which
is responsible for continuing airworthiness (CAMO
/ controlled environment) - many administrative steps ( delays expected!)
- difficult for more than 20.000 gliders in Europe
- new organisations / new procedures needed
- ill fitting to inspections by free-time personnel
11Part M maintenance / cont. airworthiness (cont.)
most problematic aspects for small aviation
- the aircraft maintenance documentation (now
maintenance program) has to be approved by the
competent authority / CAMO - mostly the maint. programs are consisting of
manufacturers information plus individual
inspection reports nevertheless approval is
needed! - some member states already ask for separate
maint. programs (30 pages and thicker!) - inspectors will spend more time with paper
instead of checking the glider - issuance of ARC based on paperwork not
necessarily on physical inspection
12Part M maintenance / cont. airworthiness (cont.)
most problematic aspects for small aviation
- the role of existing inspectors / inspection
organisations is still unclear - repair shops and gliding federations are unsure
if they should apply for Subpart F (maintenance)
and/or Subpart G (CAMO) - the Part 66 about maintenance inspection (now
certifying staff) does not apply for gliders
national rules apply there - member states have nevertheless already changed
national training / licensing systems - everyone is waiting for the big bang in September
08
13Part M maintenance / cont. airworthiness (cont.)
most problematic aspects for small aviation
- multitude of organisation approvals
- full service can be offered only if Subpart F
G plus eventually Part 145 approval is existing - manufacturers also have to apply if they want to
conduct maintenance on their own products - contrary opinions in supervising NAA about
possible combination within organisation manuals - EASA fees charges do normally not apply for
European maintenance organisations but set a very
high example of possible fees
14Part M maintenance / cont. airworthiness (cont.)
most problematic aspects for small aviation
- complexity of Part M and related regulations
- text is full of abbreviations / cross-references
making it difficult to read - official translations are sometimes inconsistent
- important AMC material only available in English
- due to ongoing rulemaking activities (see next
slide) nobody knows what will be the basis after
28.9.2008
15Part M maintenance / cont. airworthiness (cont.)
- resulting Rulemaking activities
- M.005 Pilot-owner maintenancelooks into Annex
VIII of Part M - M.017 review NPA 7/2005looks into possible
relaxations of Part M for small aviation
possible results range fromtotal new Part M
Light to amended AMC - MDM.032 simpler rules for small aviationnot
only focused on maintenance but will have
possibly strong impact there - what are the results right now?
16Part M maintenance / cont. airworthiness (cont.)
Comment Response Document (CRD) Part M
- Notice of proposed amendment NPA 2007-08
- published 28.6.2007
- end of comment phase on 13.10.2007 with 661
comments from 149 National Aviation Authorities,
organisations and persons - CRD lists ALL comments plus regarding EASA
answers - CRD only available in English language
- contains furthermore general comments and
explanations, time schedule ANDproposed new
regulation including complete Part M new - comment period until 6.5.2008 after that EASA
will issue an opinion - EC commission will issue regulations change based
on this opinion
17Part M maintenance / cont. airworthiness (cont.)
Comment Response Document (CRD) Part M
- transition provisions
- grandfathering of continuing airworthiness
management organisations ( CAMO) for 1 year - grandfathering of maintenance organisations
approvals ( Subpart F) for 1 year - issuance of ARC possible by competent authority
and by existing organisations for 1 year - existing national certifying staff will be able
to continue - all excluding commercial air transport
18Part M maintenance / cont. airworthiness (cont.)
Comment Response Document (CRD) Part M
- issuance of ARC
- below 2730 kg MTOM a CAMO with regarding approval
might issue the ARC directly - alternatively the competent authority can issue
the ARC upon recommendation by a CAMO not having
this approval or upon request by the owner or in
case of a safety threat
19Part M maintenance / cont. airworthiness (cont.)
Comment Response Document (CRD) Part M
- approval of maintenance program
- by the competent authority
- by a CAMO via a so called indirect approval
procedure approved by the competent authority
20Part M maintenance / cont. airworthiness (cont.)
Comment Response Document (CRD) Part M
- Pilot-owner maintenance
- the lists of possible pilot-owner maintenance
tasks in Annex VIII has been adapted to different
types of aircraft (in the moment only fitting to
small motor aeroplanes) - these new lists are now part of the Accepted
Means of Compliance (AMC) material of Part M
21Part M maintenance / cont. airworthiness (cont.)
Comment Response Document (CRD) Part M
- Introduction of ELA system
- relaxation of certain rules for aircraft below
2000 kg not used in commercial air transport ELA
2 - even more relaxed regulation for aircraft below
1000 kg not used in commercial air transport ELA
1 - ELA 1 / 2 will not be an new aircraft class (like
e.g. the LSA class in the USA) but describe the
less stringent regulations for small aircraft in
Europe(Rulemaking activity MDM.032)
22Part 66 maintenance / certifying staff
NPA 2008-03 Part 66
- new (maintenance) licenses for light aviation
- today national rules are valid for sailplanes and
balloons - new license which is defined according to
existing Part 66 licenses B3coming from the
sophisticated side, complex - new license especially designed for light
aviationELA basic ELA fullcoming from
existing air sport definitions, simpler - NPA published, open for comments until 28.6.2008
- thereafter internal consultation, CRD, opinion,
23MDM.032 simple rules for small aviation
- EASA agreed that regulations are too stringent
for small and recreational aviation and therefore
started MDM.032 task in 2005 - rather big working group with strong
representation of sporting organisations - long ongoing debate about possible change of
Annex II ( not EASA but under national law) - even longer debate about the definition of
non-commercial activities for which the simple
rules will be limited
24MDM.032 simple rules for small aviation (cont.)
- MDM.032 has to look into all aspects initial /
continuing airworthiness, licensing, operations - A-NPA 14/2006 resulted in over 4000 answers
- EASA encouraged creative brainstorming but then
limited possible alternative paths - possible delegation of tasks to non-authority
organisations - low control level (in maintenance, in licensing,
for medicals) based on the small risk level for
third parties is not accepted by EASA / EC - regarding NPA is expected soon
25New topics since 2005
- Sailplane equipment
- changes in AMC material of Part 21 and Part M
have been introduced and are published - typical equipment counts as standard part and
therefore no Form One is needed - nevertheless still a minor change
- and therefore the installation still has to be
approved - some NAA doubt the legal basis (only AMC)
- EASA has acted upon the initiative of the
sailplane manufacturers one positive example
26Quintessenz zum Schluß
- Es bleibt spannend
- EASA beginnt immerhin zu erkennen, dass es auch
ein (Flieger-)Leben vor EASA gab!!! - Vielen Dank !!!