permit to fly

PtF

Permit to Fly

PtF Slide 2

European Aviation Safety Agency

Permit to Fly

- Some major principles of the new rules

- Frequently asked questions- Discussion / Questions

PtF Slide 3

European Aviation Safety Agency

Old rules

Permit to Fly Until 28 March 2007 21A.174(d) Application21A.185 Issue of permits to fly

NAA issue PtF after:Agency found that aircraft can perform safe flight (with restrictions)

But: 1702/2003 article 2.11: NAA makes findings until 28-3-07

PtF Slide 4

European Aviation Safety Agency

Permit to Fly

Some important principles:Different types of PtF all covered by one ruleshared responsibility: Agency – NAAOld national PtF grandfatheredApplicable to EU registered aircraftValid in all member statesPrivileges for DOA and POA Maintenance rules in flight conditionsSeparate Subpart P: Permit to Fly

PtF Slide 5

European Aviation Safety Agency

Different types of PtF all in one rule

Complicating factor for drafting Existing (R) C of A temporarily invalid

unapproved changeUnrepaired damage(long) due maintenance

Pre C of ATC not yet issued (Production) Flight testing

C of A or Restricted C of A not appropriate or not possible

Air racing / record breakingSome orphan aircraft

PtF Slide 6

European Aviation Safety Agency

Shared responsibility Agency-NAA

Complicating factor for drafting: shared responsibility: Agency – NAA

Agency: All design issues

NAA: Conformity (production) C of A issuance and oversight Permit to Fly issuance Implementation of maintenance rules

Permit to Fly: often deviation from approved design: Agency involvement

PtF Slide 7

European Aviation Safety Agency

PtF Grandfathering

Principle:All PtF or other certificate grandfathered until first expiry date or 28-3-08 maximumFor “permanent” PtF: flight conditions are grandfathered indefinitely (until need for change),unless Agency determines insufficient level of safety

(Reg 1702/2003 art. 2.e)

PtF Slide 8

European Aviation Safety Agency

PtF applicability

PtF rules applicable only to aircraft registered in EU; orUnregistered when identification marking prescribed by MS

(Reg 1702/2003 art. 2.2)

Result: PtF rules do not cover validation of foreign PtF: use national rulesUnder new BR need to develop IR for this

PtF Slide 9

European Aviation Safety Agency

PtF validity

PtF issued in accordance with new rules are valid in all Member States:No additional national conditions / limitations Holder must comply with other local operational rules outside scope of PtFNational rules should not obstruct free circulation

PtF Slide 10

European Aviation Safety Agency

DOA/POA privileges

DOA (possible) privileges:Approve flight conditions for all PtF except 21A.701(a)(15)Issue PtF when configuration controlled by DOA

POA (possible) privileges:Approve flight conditions and issue PtF for aircraft it produced when design is approved

In previous draft: privilege for CAMO: this is subject of Opinion 4/2007

PtF Slide 11

European Aviation Safety Agency

Maintenance rules for PtF

According to 2042/2003 art. 3.3 aircraft under PtF are exempted from Part MIn stead: maintenance rules are defined in the flight conditionsIn most cases they can refer to Part M

PtF Slide 12

European Aviation Safety Agency

Separate Subpart P

Initial drafts were amendments to Subpart H (airworthiness certificates)Due to complexity decided to create new subpartAs a consequence all references to PtF are deleted from subpart H

PtF Slide 13

European Aviation Safety Agency

FAQ

Q: Must a PtF be applied for when one of the purposes mentioned in 21A.701 is applicable?A: No, only when the (R-) CoA is invalid or not yet issued

PtF Slide 14

European Aviation Safety Agency

FAQ

Q: Can an aircraft on a PtF do commercial operationsUnder EU-OPS it is impossible (without exemption)For the future IR-OPS it is not excluded by definition but in practice most PtF will have the limitation that no passengers may be carried

PtF Slide 15

European Aviation Safety Agency

FAQ

Q: where is the PtF validA: the PtF is valid in all EU within the limitations on the PtF. Outside EU there is a need to ask for validation of the PtF by the countries overflown

PtF Slide 16

European Aviation Safety Agency

FAQ

Q: Does EASA have 24/7 service for approval of flight conditions?A: No, however NAAs have the Agency emergency phone number.NAAs can always use article 14.4 for urgent operational needs

PtF Slide 17

European Aviation Safety Agency

FAQ

Q: Who is the holder of the PtFA: The applicant will become the holder when the PtF is issuedE.g. If a modifier uses the aircraft of an operator to demonstrate compliance this modifier is expected to apply for the necessary PtF; and will also be the holder

PtF Slide 18

European Aviation Safety Agency

FAQ

Q: can a PtF be applied for using approved flight conditions which were not applied for by the same applicant?A: Yes, the applicant for PtF and applicant for approval of flight conditions do not necessarily have to be the same person

PtF Slide 19

European Aviation Safety Agency

FAQ

Q: can the DOA privilege be used for aircraft that are not under the control of the DOA?A: Yes, the privilege to approve flight conditions can be used for any aircraft; as long as it is within the scope of the approvalThe privilege to issue PtF is limited to aircraft under the control of the DOA

PtF Slide 20

European Aviation Safety Agency

FAQ

Q: if the approval of flight conditions contains design and not-design related issues, who should the approve the flight conditions?A: An interpretation could be that you would need approval by the Agency of the design related and by the NAA of the non-design related; however to avoid undue burden the Agency will accept to approve both as one package

PtF Slide 21

European Aviation Safety Agency

END