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Permit to Fly

Permit to Fly. Permit to Fly. Some major principles of the new rules Frequently asked questions Discussion / Questions. Old rules. Permit to Fly Until 28 March 2007 21A.174(d) Application 21A.185 Issue of permits to fly NAA issue PtF after:

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Permit to Fly

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  1. Permit to Fly PtF

  2. Permit to Fly • Some major principles of the new rules • Frequently asked questions • Discussion / Questions PtF

  3. Old rules Permit to Fly Until 28 March 2007 • 21A.174(d) Application • 21A.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

  4. Permit to Fly Some important principles: • Different types of PtF all covered by one rule • shared responsibility: Agency – NAA • Old national PtF grandfathered • Applicable to EU registered aircraft • Valid in all member states • Privileges for DOA and POA • Maintenance rules in flight conditions • Separate Subpart P: Permit to Fly PtF

  5. Different types of PtF all in one rule Complicating factor for drafting • Existing (R) C of A temporarily invalid • unapproved change • Unrepaired damage • (long) due maintenance • Pre C of A • TC not yet issued • (Production) Flight testing • C of A or Restricted C of A not appropriate or not possible • Air racing / record breaking • Some orphan aircraft PtF

  6. 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

  7. PtF Grandfathering Principle: • All PtF or other certificate grandfathered until first expiry date or 28-3-08 maximum • For “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

  8. PtF applicability PtF rules applicable only to • aircraft registered in EU; or • Unregistered when identification marking prescribed by MS (Reg 1702/2003 art. 2.2) • Result: PtF rules do not cover validation of foreign PtF: use national rules • Under new BR need to develop IR for this PtF

  9. 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 PtF • National rules should not obstruct free circulation PtF

  10. 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

  11. Maintenance rules for PtF • According to 2042/2003 art. 3.3 aircraft under PtF are exempted from Part M • In stead: maintenance rules are defined in the flight conditions • In most cases they can refer to Part M PtF

  12. Separate Subpart P • Initial drafts were amendments to Subpart H (airworthiness certificates) • Due to complexity decided to create new subpart • As a consequence all references to PtF are deleted from subpart H PtF

  13. 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

  14. FAQ • Q: Can an aircraft on a PtF do commercial operations • Under 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

  15. FAQ • Q: where is the PtF valid • A: 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

  16. 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

  17. FAQ • Q: Who is the holder of the PtF • A: The applicant will become the holder when the PtF is issued • E.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

  18. 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

  19. 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

  20. 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

  21. END PtF

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