IMPACT OF EASA ON MAINTENANCE ORGANISATIONS IN THE USA

1. IMPACT OF EASA ON MAINTENANCE ORGANISATIONSIN THE USA Julian Hall EASA

2. Introduction • Significant changes within the European Aviation • Regulatory framework have been brought about by • the introduction of new European Aviation • Regulations. • In particular Regulation (EC) No 1592/2002 of the • European Parliament and of the Council, which • established the European Aviation Safety Agency • (EASA).

3. Regulations Regulations • In addition Commission Regulation (EC) No • 2042/2003 entered into force on 28 November 2003. • Annex II to Commission regulation (EC) No • 2042/2003 is Part-145. This implementing Rule • deals with the approval of maintenance • organisations and is derived from the former JAR • 145 requirement. • There are relatively few changes between the former • JAR 145 and EASA Part-145.

4. Regulations Annex I : Essential Requirements for Airworthiness Annex II : Excluded Aircraft Basic Regulation Regulation (EC) 1592/2002 of 15 July 2002 Agency Opinion Regulation (EC) 2042/2003 on Continuing Airworthiness Regulation (EC) 1702/2003 on Airworthiness and Environmental Certification Agency Opinion Section A: Application Requirements Annex I (Part-M): Continuing Airworthiness Requirements Section A: Technical Requirements Annex (Part 21) Section B: administrative Procedures Section B: Administrative Procedures Appendices: EASA forms Annex II (Part-145): Maintenance Organisation Approvals Appendices: EASA forms Annex III (Part-66): Certifying Staff Certification Specifications AMC 20 AMC 21 CS 25 CS 34 CS 36 CS E CS P CS APU CS AWO CS ETSO CS Definitions CS 22 CS 23 CS 27 CS 29 CS VLA CS VLR Guidance Material Part 21 Annex IV (Part-147): Training Organisation Requirements AMC & Guidance Material Part M, 145,66,147 Agency CS , AMC & GM Parliament and Council EuropeanCommission EASA

5. Legislative level - Council and Parliament - Establishing the legal framework Executive level - Commission - Agency - Member States - Industry - Setting standards - Conformity assessment Judicial level -National Courts - Court of Justice - Enforcement / remedial actions Responsibilities

6. The Agency is responsible in accordance with Article 15.2 of Regulation 1592/2002 to: (a) conduct, itself or through national aviation authorities or qualified entities, inspections and audits of the organisations it certifies(b) issue and renew the certificates of:(i) design organisations; or(ii) production organisations located inside the territory of the Member States, if requested by the Member State concerned; or(iii) production and maintenance organisations located outside the territory of the member states Requirements for organisations

7. EASA Structure Executive Director Assistants Safety Analysis & Research Communication Manager Q&S Director Administrative Director Finance & Procurement Manager Standardisation Manager Human Resources Manager Quality Manager Legal Manager Rulemaking Director Technical Training Manager IT Manager Certification Director Products Safety DeputyDirector Environmental Protection Flight Standards Head of Programmes Certification International Cooperation Head of Products Support Head of Organisations

8. The Organisations Department Head of Organisations Department Wilfred Schulze Secretariat Production Organisations Manager Allaert Kalshoeven Maintenance/Training Organisations Manager Julian Hall Design Organisations Manager Roger Simon MOA Assistant Hasna Agharas

9. Bilateral Agreements If any co-operation aims at creating obligations on Member States or the Community or at allowing deviations from Community law, it shall be established by means of a formal agreement concluded by the Community itself (article 9.1 of the EASA Regulation). Working Arrangements If the co-operation only commits the Agency for the execution of its certification tasks, it may be established by means of a working arrangement concluded by the Agency (article 18.2 of the EASA Regulation). Current state of play

10. Existing bilateral agreements remain in force in accordance with Article 9 to Regulation (EC) No 1592/2002 or until such time as a new bilateral is concluded by the European Community which would supersede the existing agreements. This means the existing BASA MIPs between the USA, France, Germany and Ireland respectively remain in force. (BASA= Bilateral Aviation Safety Agreement) (MIP= Maintenance Implementation Procedures) Current state of play

11. The Community has declared its intention to ensure a smooth transition aiming at maintaining: current partnerships for certification / validation existing harmonisation arrangements essential to the continuing flow of aviation products and services. Transition

12. November 28th 2004 was the end of a transition period (specified in Article 4 to Regulation (EC) 2042/2003 )whereby all ‘grandfathered’ former JAR- 145 approvals had to be transitioned into EASA Part- 145 approvals. After November 28th 2004 a JAR 145 acceptance is no longer valid. For the Agency this meant all the ‘grandfathered’ foreign JAR 145 and JAR 147 approvals had to be given EASA Part-145 and Part-147 approvals respectively. The transition

13. A) US Bilateral Aviation Safety Agreement/ MIP TOTAL 1256 Part-145 organisations B) Canadian Administrative Arrangement on Maintenance TOTAL 135 Part-145 organisations C) Foreign non –bilateral Part-145 approvals TOTAL 270 Part-145 organisations D) Foreign non –bilateral Part-147 approvals TOTAL 10 Part-147 organisations EASA approved organisations

14. All these 1671 organisations are subject to a full technical review every 2 year period to ensure “continuation”. (This approximates to 16 “continuations” per week). In addition foreign CAMO and subpart F applications are being received from applicants. These are new codes so the total volume of activity has yet to be determined. Continuation activity

15. In order to maintain continuity the MIP-Guidance (MIP-G) has been developed in conjunction with the FAA and is available on the EASA web site at: www.easa.eu.int All US located Part-145 organisations must now adhere to the MIP-G as publsihed on the EASA web site. Maintaining Continuity

16. All EASA Part-145 certificates are issued without a time limitation. Renewal process will be changed to “continuation.” Address and contact details changed to reflect EASA in Cologne. Inclusion of the EASA Fees and Charges Regulation. Revised special conditions introduced. Main procedural changes

17. New agreements or arrangements with the Community’s major foreign partner countries are envisaged for the future. EASAshall bedesignatedunder the Agreement as a/the certification body competentfor some tasks,as well as NAAs, depending onthe internal sharing of roles. EASA is in particular competentto agree on the certification basis and detailed implementation procedures. The future

18. The new agreement should contain two main parts: the core agreement itself including general provisions and a set of annexes covering the implementation procedures. The whole document should be negotiated after appropriate reciprocal confidence has been established and implementation processes have been developed. The future

19. The European Commission is currently working with the FAA and the EASA in order to produce a new Bilateral Aviation Safety Agreement which would be applicable to the USA and to all EU Member States. This will reduce redundant regulatory oversight and also facilitate market access. The future

20. We are currently in a transition period and we are embarking on a learning curve. It is essential that the FAA, the EASA and Industry continue to work together in order to ensure that we maintain the highest levels of safety for the Aviation sector. We look forward to working with you and thank you for your continued cooperation. Conclusion