EASA Rulemaking Update Continuing Airworthiness Juan Anton Continuing

EASA Rulemaking Update (Continuing Airworthiness) Juan Anton Continuing Airworthiness Manager Rulemaking Directorate EASA 11 December 2012 E&M Sub-SSCC 1

Current tasks Part-M General Aviation (Phase I): NPA 2012 -17 published for comments until 29 January 2013. Workshop was performed on 06 November 2012 explaining its content. Covers proposals related to: Maintenance Programmes Airworthiness Reviews 11 December 2012 27/10/2011 E&M Sub-SSCC Part-M General Aviation Workshop 2 2

Current tasks Proposal Scope Possibility for the owner to contract the development and approval processing of the MP to a Part-145 or M. A. Subpart F maintenance ELA 2 aircraft organisation, being also possible for this organisation to use the not involved in 1 indirect approval procedure (if approved by the competent commercial authority). operations* NOTE: The contracted maintenance organisation must be under the oversight of the State of Registry of the aircraft. Possibility for the owner to issue a declaration for his/her own aircraft’s MP. 2 NOTE: In this case, the owner takes full responsibility for its content and any deviations from the Design Approval Holder recommendations. ELA 1 aircraft not involved in commercial operations Introduction of “Minimum Inspection Programmes” (Appendix IX to Part-M) which may be used by the owner as the basis for the declared MP. Applicable to: 3 ELA 1 aeroplanes not involved in commercial operations ELA 1 sailplanes and ELA 1 powered-sailplanes not involved in commercial operations ELA 1 balloons not involved in commercial operations 11 December 2012 E&M Sub-SSCC See left column 3

Current tasks Proposal Scope All aircraft except Introduction of a template which may be used in order to prepare a 4 complex motor customised MP for a particular aircraft registration. -powered aircraft Possibility for a Part-145 or M. A. Subpart F maintenance organisation to perform the airworthiness review and issue the corresponding ARC (airworthiness review certificate) at the same ELA 1 aircraft not involved in 5 time they perform the annual inspection contained in the “Minimum commercial Inspection Programme” operations NOTE: A new Form 15 c (ARC) has been introduced to cover this case. All aircraft Clarification that, depending on the scope of work, the organisation maintained by 6 may not need to have a hangar available and may use alternative M. A. Subpart F suitable facilities (AMC M. A. 605(a)). MOs Introduction of guidance related to the use of the indirect approval 7 procedure by a CAMO in order to introduce new type ratings to All aircraft their scope of work (AMC M. B. 703) 11 December 2012 E&M Sub-SSCC 4

Current tasks Task M. 014 “Contracting of continuing airworthiness management activities” ò NPA 2010 -09 published in July 2010 ò Highly controversial task (total support from Industry, significant rejection from certain NAAs). ò Review Group after NPA agreed to continue with the task and presented a report to the management of EASA. ò EASA decided, in view of the divergent comments to the NPA, that it was needed more debate on the subject: § A letter and a questionnaire was sent on 14 March 2012 to stakeholders and NAAs in order to obtain feedback on the subject. § A workshop was performed on 28 June 2012 in order to discuss the issue and the feedback received. ò Based on the result of the actions above the Agency is preparing a final outcome for the task. 11 December 2012 E&M Sub-SSCC 5

Current tasks Task MDM. 047 “Alignment of EC 2042/2003 with the Basic Regulation” òOpinion 06/2012 was published on 27 November 2012. 11 December 2012 E&M Sub-SSCC 6

Current tasks Task MDM. 038 “Guidance on TBO limits” ò NPA 2011 -15 published on 16 September 2011 (3 month consultation). ò Covers all type of components installed on non-powered and piston engine aircraft other than complex motorpowered aircraft, when not used for Commercial Air Transport. ò Very detailed guidance on the inspection procedure to extend the TBO of a piston engine. ò CRD expected beginning 2013. 11 December 2012 E&M Sub-SSCC 7

Current tasks Q Task MDM. 020 “Critical tasks” ò NPA published on 12 June 2012. ò Agency is currently reviewing the comments. CRD expected 2 Q 2013. Q Task 66. 027 “Avionic licence for general aviation and licence for sailplanes, balloons, airships and ELA 1 aeroplanes” ò NPA 2012 -15 published for comments until 04 January 2013. ò Workshop was performed on 06 November 2012 explaining its content. Q Task M. 027 “Guidance for Aircraft Continuing Airworthiness Monitoring (ACAM)” ò Opinion expected 1 Q 2013. 11 December 2012 E&M Sub-SSCC 8

Current tasks Q Task 145. 017 “Control of suppliers for components, parts and appliances” ò Clarify the requirements and produce guidance on how to evaluate component suppliers. ò Evaluate the possibility to use industry standards and accreditation programmes in order to reduce the auditing burden when a supplier is used by many maintenance organisations. ò NPA 2012 -03 published on 12 April 2012. ò CRD expected 2 Q 2013. 11 December 2012 E&M Sub-SSCC 9

Current tasks Q Task MDM. 097 “Maintenance check flights” (previous task M. 009 + Operational issues) ò NPA 2012 -08 published. Comment period ended 30 October 2012. 11 December 2012 E&M Sub-SSCC 10

Current tasks Q Task MDM. 056 “Instructions for Continuing Airworthiness” ò Task started at the end of 2009. ò A working group of 24 members had 3 meetings during 2010. However, the CMT meeting (December 2010) showed parallel activities with FAA and TCCA. ò EASA, FAA and TCCA decided in a meeting held in April 2011 the following: § The scope of the task was too large. § To split the task in subjects of common interest to the 3 authorities, which should be harmonised, and other subjects, which will be dealt separately by each authority. ò Coordination with FAA, TCCA in order to identify issues of common interest and harmonize approaches. ò Status report issued last October 2012 (published on the EASA website together with the To. R of the task) 11 December 2012 E&M Sub-SSCC 11

Current tasks Q Task MDM. 076 “Technical records” ò 5 meetings already took place. ò NPA expected 4 Q 2013. ò The objective is to clarify the following: § Inconsistency in the use of terms such as “Life Limited Parts” and “Service Life Limited Parts” § Which components require EASA Form 1 and which documents are equivalent. § Whether “Back to birth traceability” is needed. § Guidance on the use of electronic signature, the acceptability of scanned record copies and the use of new technology such as RFID (Radio Frequency Identification). § Harmonisation with FAA requirements. § Address Safety Recommendation UNKG-2007 -091 (to keep maintenance and overhaul records until the aircraft or component has been destroyed or permanently removed from service). 11 December 2012 E&M Sub-SSCC 12

Current tasks Q Task 145. 024 “Functions and responsibilities of B 1 and B 2 support staff” ò 2 meetings already took place ò NPA expected 2 Q 2013. ò The objective is to clarify the following: § How the organisation evaluates the complexity of each task and assign it to personnel authorised to “sign-off” or to nonauthorised personnel under supervision. § Who can be authorised to “sign-off”, under which qualification and under which authorisation process. § What is the role of the “sign-off” personnel and the “B 1 and B 2 support staff”. § How are recorded the actions taken by “sign-off personnel” and “B 1 and B 2 support staff”. 11 December 2012 E&M Sub-SSCC 13

Current tasks Q Task MDM. 048 “CS for standard changes and repairs” (similar to AC 43 -13) ò To. R published on 28 July 2011. ò Applicable to aeroplanes up to 5700 Kg MTOM, rotorcraft up to 3175 Kg MTOM, sailplanes , balloons and airships. ò To be performed in phases depending on the different aircraft categories. ò Agency task with support of industry associations. ò It is linked to the Opinion issued as a result of task MDM. 032. 11 December 2012 E&M Sub-SSCC 14

Current tasks Q Task MDM. 055 “SMS embodiment and alignment with AR/OR requirements” ò NPA expected December 2012. ò Workshop to be performed on 13 December 2012. 11 December 2012 E&M Sub-SSCC 15

Future tasks (Starting in 2013) Q Task MDM. 075 “Specialized tasks” ò Currently, the Part-145 approval ratings only cover the specialized task of NDT (D 1 rating). ò This task covers additional tasks such as welding, plating, etc. 11 December 2012 E&M Sub-SSCC 16

Future tasks (Starting in 2013) Q Task MDM. 078 “Importing of aircraft from other regulatory systems” Q Task M. 029 “CAMO and Part-145 responsibilities” 11 December 2012 E&M Sub-SSCC 17