aei annual congress, iceland. october 2016 - … · aei and easa working together licensed...
TRANSCRIPT
Julian HALL Head of Maintenance and Production Department
AEI Annual Congress, Iceland.
October 2016
Reykjavik, 13.10.2016 AEI Annual Congress
Overview
EASA organisational structure.
EASA Regulations update.
AEI and EASA working together.
Bilateral agreements.
Future challenges.
Conclusions.
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Flight Standards Directorate
Ricardo Génova GALVÁN Director
Julian HALL Maintenance and Production
Department
Maintenance & Production Standardisation Section
FS.1.1 Mark Kieft acting
Maintenance Regulations Section
FS.1.2 Juan Anton
Production Organisations Section
FS.1.3 Jiri Novy
Continuing Airworthiness Organisation Section
FS.1.4 Karl Specht
Maintenance Review Board Section
FS.1.5 Mark Kieft
Claudio TREVISAN Air Operations Department
Air Operations Standardisation
Section
FS.2.1 Francesco Gaetani
Air Operations Regulations
Section
FS.2.2 Eduard Ciofu
Third Country Operators (TCO) Section
FS.2.3 Sascha Schott
Safety Assessment of Foreign Aircraft (SAFA) Section
FS.2.4 Jeroen Jansen (acting)
Georges REBENDER Air Crew & Medical
Department
Air Crew & Medical Standardisation Section
FS.3.1 Kerry Booth
Air Crew & Medical Regulations Section
FS.3.2 Daan Dousi (acting)
Approved Training Organisation & Aero-Medical Centres Section
FS.3.3 Hans Kristian Birkholm
Flight Crew Training Section
FS.3.4 Herbert Meyer
Wilfried SCHULZE ATM/ANS & Aerodromes
Department
ATM/ANS Standardisation &
Oversight Section
FS.4.1 Manfred Dieroff
ATM/ANS Regulations Section
FS.4.2 Gernot Kessler
Aerodromes Regulations Section
FS.4.3 Giulio De Crescenzo
Thaddée SULOCKI
Policy & Planning Department
Wilfried SCHULZE
Deputy Director
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Maintenance & Production Department
The EASA Maintenance & Production Department (FS1) lies within the EASA Flight Standards Directorate, and consists of:
FS1.1 -Standardisation of Member States in the Initial and Continuing Airworthiness domains;
FS1.2 -Development of Regulatory Material in the Continuing Airworthiness domain;
FS1.3 -Approval and surveillance of Part-21 (POA) organisations located outside the European Union (EU), as well as Part 21 (POA) organisations within the EU upon request;
FS1.4 -Approval and surveillance of Part-M, Part-145, Part-147 located outside the European Union (EU)
FS1.5 -Delivery of all continuing airworthiness activities and services related to MRB (Maintenance Review Board).
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Maintenance & Production Department
In practical terms the EASA FS1 Department is responsible for;
approving more than 2000 organisations in the continuing airworthiness and production domains
standardising 28 Member States, plus Associate States and Bilateral Agreements,
managing over 30 rulemaking tasks
managing over 80 MRB projects.
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EASA System and engineer licensing
In continuing airworthiness there is split competence between EASA and NAAs.
EASA is only responsible for issuing foreign CAW approvals outside of the EU (exception in production).
EASA is not a competent authority for issuing engineer licenses under Part 66.
EASA is responsible for issuing technical opinions on airworthiness rules (including part 66)
EASA is responsible for standardising Member State NAAs.
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AEI and EASA working together
Licensed Engineers are a robust safety barrier, and one of the foundation blocks on which the EASA CAW system is built.
Part 66 must be supported by appropriate Part 147 requirements.
Part 145 must give clarity to Certifying staff functions and responsibilities.
Standardised implementation of EU rules not just in the EU, but outside is essential.
Licensed engineer role-reporting within the system.
Licensed engineers must exercise their responsibilities within the system, and provide feedback.
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Rulemaking participation by AEI
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RMT.0217 “CAMO and Part-145 responsibilities”:
Responsibilities linked to the planning, coordination and release of maintenance.
Contractual arrangements between operators, maintenance organisations and subcontracted organisations.
RMT.0097 “B1 and B2 support staff”
Qualification, privileges, responsibilities and level of involvement of the different maintenance personnel, including:
Sign-off staff
B1 and B2 support staff (base maintenance)
Certifying staff
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Rulemaking participation by AEI
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RMT.0547 “Part-M General Aviation Task Force”:
Simplification of the continuing airworthiness requirements (Part-ML and Part-CAO)
Development of associated AMC/GM.
NOTE: In addition, it may be necessary to involve AEI in:
On-going RMT.0106 “CS-MCSD for the Minimum Syllabus of maintenance certifying staff”
Upcoming tasks for the review of Part-66 (RMT.0255) and the review of Part-147 (RMT.0544)
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AEI and EASA working together
EASA has developed new advisory board structures to consult stakeholders on the rulemaking priorities of the Agency.
The new Stakeholder Technical Committee (STeB) for engineering and maintenance has AEI representation.
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Part 147 and 66
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In the EASA Committee of 17/18 February 2016, the Member States unanimously agreed on the following:
New B2L and L Part-66 licences (ref. Opinion 05/2015).
B2L: Avionics licence for non-complex aircraft.
L licence: Licence for sailplanes, balloons and ELA1 aeroplanes.
Limitation of the Part-147 privileges related to stand-alone basic examinations (ref. Opinion 07/2015).
In order to prevent fraud when performing basic examinations not linked to the delivery of the basic training course.
Applicability calendar (once adopted by the Commission):
B2L licence: 6 months after adoption.
L-licence: 01 October 2018 (obligation for NAAs to start issuing them) and 01 October 2019 (obligation for all certifying staff to have it).
Limitation of the Part-147 privileges related to stand-alone basic examinations: Immediate effect after adoption.
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Part-CAMO (with SMS requirements)
for continuing airworthiness management of aircraft
• operated by licenced air carriers and/or
• CMPA (twin-turboprops < 5700 kg MTOM ‘exempted’)
CAMOs in this segment represent an estimated 65 % of all currently approved EASA CAMOs.
In Phase I only Part-CAMO will have SMS requirements (not Part-CAO, nor Part-145).
Part-CAMO can also be used for aircraft other than those operated by licenced air carriers and/or CMPA.
Opinion 06/2016 issued by EASA in May 2016 introducing SMS requirements in Part-CAMO:
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Bilateral agreements in CAW
Unites States
Canada
Brazil
China
Japan
Other developments…..EASA global footprint.
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Future challenges
Introduction of SMS and the move towards a more predictive risk based environment (data collection and analysis).
Changes in the regulatory framework; Basic Regulation changes, impact on EASA and industry/AEI.
New business model concepts.
Bilateral agreements, EASA global footprint.
Resource challenges in EASA, NAAs and industry.
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Future challenges
New technologies 3D printing, electric aircraft etc.
Cyber security in maintenance and production
RPAS-impact on maintenance and production
Insufficient technical expertise for future growth.
Change management.
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Conclusions
EASA believes AEI is a key stakeholder and can provide an invaluable input to the EASA processes.
The role of the licensed engineer is an essential element of the EASA CAW model.
New business models, limited resources, complexity, will all make change management a challenge for all parties, at all levels.
We must strive together to keep the system as simple as possible.
Key driver is always safety.
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CAW regulations updates
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Change in the structure of the continuing airworthiness
regulations
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CAW regulations updates
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Issues driving this future change in the structure of the Continuing Airworthiness rules:
Need to simplify the rules for General Aviation:
Opinion 05/2016 published in April 2016:
Part-M “Light” (Part-ML)
Combined airworthiness Organisation (Part-CAO), without SMS.
Need to introduce a Safety Management System for organisations and the corresponding requirements for competent authorities, in a proportionate and scalable approach:
Opinion 06/2016 published in May 2016:
Introduction of SMS for CAMO (Part-CAMO)
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Opinions 05/2016 and 06/2016 issued by EASA in April and May 2016 covering the following:
Simplification of the continuing airworthiness rules for General Aviation.
Introduction of Safety Management System for organisations and the corresponding requirements for competent authorities, in a proportionate and scalable approach (No SMS for General Aviation organisations).
New regulation structure proposed:
Part-ML applicable to the lighter aircraft not used in CAT.
Part-M applicable to all the other aircraft.
Part-CAO organisation with combined privileges for maintenance and continuing airworthiness management.
For non-complex aircraft not used in CAT.
No SMS requirements.
Will replace the Subpart F maintenance organisation (after 2 years transition)
Part-CAMO (will replace the Subpart G CAMO approval):
Can be used for all aircraft (not required for non-complex aircraft not used in CAT, since they can use Part-CAO organisations)
Contains SMS requirements.
New structure of the CAW regulations
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Opinion 05/2016 issued by EASA in April 2016 covering the following:
Part-ML (Part-M Light):
Applicable to aeroplanes up to 2730 Kg, other ELA2 aircraft and helicopters up to 4 occupants and 1200 Kg.
Applicable to private and commercial operations but not to Commercial Air Transport (in the sense of licensed air carriers per (EC)1008/2008).This means that Part-ML still covers all sailplanes and balloons, even if the carry passengers.
Combined simplified organisation approval (Part-CAO) for General Aviation (for all non-complex non-CAT aircraft)
Combines the privileges of a maintenance organisation and a CAMO.
Introduces simplified requirements.
No SMS requirements will be introduced for GA organisations.
They will continue with the current Quality System (or organisational reviews if the organisation is small).
Part-ML and Part-CAO
Reykjavik, 13.10.2016 AEI Annual Congress