Segelfliegen und EASA Bericht über die Arbeit des Verbands deutscher Segelflugzeughersteller

1. Segelfliegen und EASA Bericht über die Arbeit des Verbands deutscher Segelflugzeughersteller über Part M, Gebühren und mehr… von Werner “micro” Scholz, Sprecher der European Sailplane Manufacturers AERO, Friedrichshafen 21.4.2007

2. über den Vortrag und den Vortragenden: • Auszug aus dem Bericht 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……

3. über den Vortrag und den Vortragenden:

4. über den Vortrag und den Vortragenden:

5. EASA – the most important topics in 2007: • new Fees & Charges regulation • Part M – maintenance / cont. airworthiness • MDM.032 – simple rules for small aviation • new / closed topics since 2005: • Certification of sailplane equipment • crashworthiness of glider cockpits

6. new Fees & Charges regulation • EASA committee (all member states) voted positively for new F&C regulation on 16.4. • still the “political will” is:certification 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)

7. new Fees & Charges regulation (cont.) • all fees are higher now (by a factor of at least 1.5) • changes on geometry and/or power-plant are charged as new designs • fees for non-turbine engines are much higher than those for sailplanes/motorgliders • price for 1 EASA working hour: 225 €

8. Part 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

9. Part M – maintenance / cont. airworthiness (cont.) • 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 most problematic aspects for small aviation:

10. Part M – maintenance / cont. airworthiness (cont.) • 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 most problematic aspects for small aviation:

11. Part M – maintenance / cont. airworthiness (cont.) • 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 most problematic aspects for small aviation:

12. Part M – maintenance / cont. airworthiness (cont.) • 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 most problematic aspects for small aviation:

13. Part M – maintenance / cont. airworthiness (cont.) • 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 most problematic aspects for small aviation:

14. Part M – maintenance / cont. airworthiness (cont.) • ongoing Rulemaking activities: • M.005 “Pilot-owner maintenance”;looks into Annex VIII of Part M • M.017 “review NPA 7/2005”;looks into possible relaxations of Part M for small aviation – possible results range from“total new Part M Light” to “amended AMC” • MDM.032 “simpler rules for small aviation”;not only focused on maintenance but will have possibly strong impact there • so what is in discussion right now?

15. Part M – maintenance / cont. airworthiness (cont.) • issuance of ARC • below a certain weight limit excluding commercial air transport the CAMO making the inspection might issue the ARC directly • therefore no obligation to go the competent authority or to contract the responsibility to a CAMO • Big question: do the NAA (= competent authorities) whish to delegate the ARC issuing? possible relaxations from the rulemaking groups:

16. Part M – maintenance / cont. airworthiness (cont.) • approval of maintenance program • the CAMO making the inspection might approve also the according maint. program • perhaps it could be possible to shortcut this approval as long as the “normal” maintenance documents are been used • Big question again: do the NAA (= competent authorities) whish to delegate the approvals of the maint. programs? possible relaxations from the rulemaking groups:

17. Part M – maintenance / cont. airworthiness (cont.) • Pilot-owner maintenance • the lists of possible pilot-owner maintenance tasks in Annex VIII are been adapted to different types of aircraft (in the moment only fitting to small motor aeroplanes) possible relaxations from the rulemaking groups:

18. Part M – maintenance / cont. airworthiness (cont.) • general aspects of possible alterations • due to the specified rulemaking process(ToR > Working Group > RIA > NPA > Working Group > CRD > EASA opinion > Commission Decision)changes will be published “in the last second”(not before spring/summer 2008) • therefore any action by owners / manufacturers / maintenance organisation / authorities is more guessing instead of planning • EASA / European Commission is been urged to relax the time limit possible relaxations from the rulemaking groups:

19. MDM.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… but no representative of industry?! • long ongoing debate about possible “candidates for EASA” which now belong to Annex II (= fall under national law) • even longer debate about the definition of “non-commercial activities” for which the simple rules will be limited

20. MDM.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 • delegation of tasks to non-authority organisations will not be pushed by EASA – it is doubtful if the member states will do this • low control level (in maintenance, in licensing, for medicals) based on the small risk level for third parties is not accepted by EASA / EC

21. New 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… • some NAA doubt the legal basis (“only AMC”) • EASA has acted upon the initiative of the sailplane manufacturers – one positive example

22. New topics since 2005 (cont.): • 22.004 – crashworthiness of glider cockpits • EASA agreed to use existing structure within gliding movement (= sailplane development panel of OSTIV) for rulemaking activity 22.004 • results of discussion within rulemaking activity: • existing OSTIV airworthiness standards use higher levels of acceleration for crash landing cases • test results of several German research programs were analyzed and incorporated • higher (static) load levels by a factor of 1.5 proposed • no dynamic tests required for certification • participation of industry, authorities, research organisations within the activity • actual statistics and accidents show need for adequate crashworthiness

23. New topics since 2005 (cont.): • Bio-Fuel – Ethanol in automotive gasoline • several member states allow / enforce addition of ethanol into automotive gasoline • possible technical problems: • vapor lock due to higher volatility • corrosion due to water solved within the alcohol • chemical attack upon tanks, fuel lines, seals, etc. by the ethanol or other additives • reduced lubrication within two-stroke engines using pre-mixed fuel • neither EASA nor national authorities have shown much interest into solving / researching the problems • in the moment the responsibility is with the pilot and the TC holder…

24. Quintessenz zum Schluß: • Es bleibt spannend • EASA beginnt immerhin zu erkennen, dass es auch ein (Flieger-)Leben vor EASA gab!!! Vielen Dank !!!