Repair Data Acceptance Presented by W. Schulze-Marmeling

1. Repair Data AcceptancePresented byW. Schulze-Marmeling

2. 1st Meeting February 10-12, 2003 in Braunschweig Attendees from Minutes, mutually agreed, are available

3. Terms of Referenceas of 07.11.2002 Specific tasks and interface issues (Deliverables): FAA and JAA representatives will meet and examine FAA and JAA/NAA system for classification, approval, and documentation of repairs. The authorities will identify systems differences and potential methods to mitigate these differences.

4. Terms of Reference(cont‘d)as of 07.11.2002 The authorities will make a determination whether a system of reciprocal acceptance can be established. The authorities will draft procedures and internal guidance to streamline reciprocal acceptance of repairs. These documents will cover the classification, approval, documentation and accomplishment of repairs.

5. Terms of Reference(cont‘d)as of 07.11.2002 Develop and deliver a training to the appropriate authority and industry personnel affected by the agreement prior to implementation. Recommend any changes to be considered for future reciprocal agreements between Europe and US. The Subgroup tasked to finalize the Repair Design Approval Sheet will provide the outcome of their work to the Full Group.

6. 1st Meeting Chairmen: Mr. Frank Steffens and Mr. Kevin Kendall Discussion of ToRs Accomplishment of repairs sufficiently covered by JAR-/FAR-145 Focus on • general comparison of FAA- and JAA-systems of classification approval and documentation of repair • identify and evaluate of system differences • identify potential methods to mitigate system differences as necessary

7. 1st Meeting (cont‘d) Discussion of ToRs (cont’d) • determine whether a system of reciprocal acceptance of repairs can be established and make corresponding proposals to the CST and the FAA management for endorsement finalize the existing JAA draft repair design approval sheet to enablemutual acceptance • draft the necessary procedures and internal guidance for reciprocal acceptance of repairs • recommend provisions for future bilateral agreements between the US and Europe for the reciprocal acceptance of repairs Training: cannot be accomplished within the time frame given

8. 1st Meeting (cont‘d) Subgroups nominated to deal with specific areas • FAA field approval process vs. JAA repair data approval process FAA DER authorizations vs. ASI authorizations  FAA definition of acceptable data vs. approved data FAA system of classification major/minor repairs (121 operators process vs. other processes) • FAA designee system vs. JAA DOA system Qualification of JAA DOA staff Approval / Oversight of JAA DOAs  Conformity of repair data with importing country’s TC-basis Repair development for products for which the NAA is not the state of design Connection between repair designer and TC / STC-holder  Language of approvals and documentation of repairs Mutually acceptable repair approval sheet

9. 1st Meeting (cont‘d) Basic guideline Both the FAA and the NAA BAAs/BASAs and IPAs have previously accepted each other’s system as described in the individual agreements. This has to be respected to the maximum possible extent. General objectives • Seek equivalency / sufficient similarity to enable mutual acceptance with a minimum of changes (keep in mind what is current practice) • Identify extent or possible limitations of mutual acceptance (safety aspects first, legal aspects not to be forgotten) • Identify best practice (secondary objective) • Identify procedures and guidance for mutual acceptance where necessary (second step)

10. Amendments to Terms of References 1. Accomplishment of repairs deleted, sufficiently covered by JAR/FAR 145 2. Development of training material, postponed 3. Delivery of the report, extended until end of August 2003

11. 2nd Meeting April 28-29 in HoofddorpReview of specific areas as defined during 1. Meeting

12. 2nd Meeting FAA field approval process vs. JAA repair data approval process (Subgroup 1) Draft Conclusion: FAA field approval process provides an equivalent level of airworthinesscompared to JAR-21 subpart M approvalprocess Action: Clarification why the field approval process is not always applicable(Part 121 Air Carrier aircraft are not generally eligible)

13. 2nd Meeting Comparison FAA DER Authorisation vs. ASI Authorisation (Subgroup 1) Draft Conclusion: both authorisations provide an acceptable level of confidence

14. 2nd Meeting FAA definition of acceptable data vs. approved data (Subgroup 2) Draft Conclusion: the FAA system provides an equivalent level of airworthiness comparable to what JAR-21subpart M requires

15. 2nd Meeting FAA system of classification major / minor repairs (Subpart 2) Draft Conclusion: the classification and processing of data provide an equivalent level of airworthiness compared to what JAR-21 subpart M requires Action: Delivery of background information, why the classification is granted as a specific privilege to operators and repair stations, and the benefit of this privilege.

16. 2nd Meeting FAA designee system vs. JAA DOA system (Subgroup 3) Draft Conclusion: the approval of repair data by the FAA‘s designee and delegated organisation system should be given the same validity as those made directly by the FAA. Action: future changes of the FAA delegated organisation / designee (ODA) system to be included in the final report.

17. 2nd Meeting Qualification of JAA DOA staff (Subgroup 3) Draft Conclusion: A sufficient level of technical competence is provided

18. 2nd Meeting Approval / Oversight of JAA DOAs(Subgroup 3) Draft Conclusion: The JAA approval and oversight procedures for DOAs are acceptable to the FAA

19. 2nd Meeting Conformity of repair data with importing country‘s TC basis(Subgroup 4) Draft Conclusion: compliance with the TC basis of the State of Design is acceptable, unless repair data are technically incompatible with the configuration of the a/c or product to be repaired

20. 2nd Meeting Repair development for products for which the NAA is not the Authority of the State of Design (Subgroup 4) Draft Conclusion: both Systems (FAA‘s and JAA‘s) provide a sufficient level of airworthiness irrespective of the State of Design of the product repaired.

21. 2nd Meeting Cooperation between the repair designer and the TC/STC-holder Draft Conclusion: FAA system ensures that basic product data are available at the repair designer • however, engine critical parts are exempted from this conclusion due to specific JAR-21 requirements • helicopter critical parts still under discussion Note: Currently, the FAA is evaluating the subject with regard to engine critical parts; change of the FAA system might take place in future.

22. 2nd Meeting Language of approvals and documentation of repairs (Subgroup 5) Draft Conclusion: for mutually acceptable repairs the English language should be required

23. 2nd Meeting Approval Sheet(Subgroup 5) Status: most of the changes proposed up to now are editorial. The minimum data to accept a repair (reference to TC, STC, limitations etc.) have to be filled in Action: AECMA agreement, to be provided

24. Next steps 1. Next meeting in the United States July 14-18 2. Final meeting in the United Kingdom July 28-29 3. Report to be submitted End of August 2003