460 likes | 1.05k Views
EASA presentation Various Update . EAMTC - Bordeaux 06/07 October 2009 Jean-Pierre Arnaud / EASA Rulemaking Directorate. Content. Content. 1. 2 nd extension of EASA remit 2. CRD to NPA 2007-07 3. CRD to NPA 2008-03 B3 license and “L” license 4. List of Type rating training (TRT)
E N D
EASA presentation Various Update EAMTC - Bordeaux 06/07 October 2009 Jean-Pierre Arnaud / EASA Rulemaking Directorate EAMTC
Content EAMTC / Bordeaux
Content • 1. 2nd extension of EASA remit • 2. CRD to NPA 2007-07 • 3. CRD to NPA 2008-03 B3 license and “L” license • 4. List of Type rating training (TRT) • 5. OSC / CS-MCS: NPA 2009-01 • 6. European Question Data Bank • 7. Rulemaking programme EAMTC / Bordeaux
1. 2nd extension of EASA remit EAMTC / Bordeaux
1. 2nd extension of EASA remit • Regulation 3641/09 was adopted on 07/09/2009 and amends regulation (EC) No 216/2008 with a view to improving the safety of aerodromes, air traffic management and air navigation services. • The regulation extends EASA's competences to cover the safety of aerodromes, air traffic-management and air navigation services. • In particular, the EASA's new tasks will cover rule-making and standardisation inspections. • In addition, as far as air traffic management and air navigation services are concerned, it will be necessary to coordinate the common safety rules properly with the new Single European Sky regulation and the related implementing rules. • The regulation repeals Council directive 06/23/EEC EAMTC / Bordeaux
2. CRD to NPA 2007-07 EAMTC / Bordeaux
CRD to NPA 2007-07 3 rulemaking tasks gave birth to NPA 2007-07. • 66.006 - Privileges of B1 and B2 Aircraft maintenance licence • 66.009- Type and group ratings • 66.011 - Type training EAMTC / Bordeaux
CRD to NPA 2007-07 • 440 comments to NPA 2007-07 were received • CRD ready for public consultation today • Please read and comment: there are so numerous changes; your help is welcome • The following slides reflects the main changes introduced after the NPA. EAMTC / Bordeaux
CRD to NPA 2007-07 Privileges of B1 and B2 Aircraft maintenance licence EAMTC / Bordeaux
CRD to NPA 2007-07 • 66.A.20(a)3(i) has been amended in order to extend the privileges of the B2 licence to maintenance on electrical and avionics parts within powerplant and mechanical systems, requiring simple tests to prove their serviceability (not only on air conditioning systems, fire warning systems, ice & rain protection systems and fuel system indications as was proposed in the NPA). • Appendixes I, II and III have been amended in order to introduce an increase of knowledge, training and examination requirements and the B2 basic course duration has been increased to 2400 hours from the 2000 hours proposed in the NPA. EAMTC / Bordeaux
CRD to NPA 2007-07 • AMC 66.A.20(a) has been amended in order to further clarify the concepts of “Electrical System”, “Avionics System”, “Simple Test” and “Troubleshooting”. Definitions are given • AMC 66.A.45(b) has been introduced to provide further guidance for the additional privilege of the B2 licence holder to perform minor scheduled line maintenance and simple defect rectification (see 66.A.20(a)3(ii) and 66.A.45(b)). EAMTC / Bordeaux
CRD to NPA 2007-07 66.009 - Type and group ratings EAMTC / Bordeaux
CRD to NPA 2007-07 66.009 - Type and group ratings In fact, this task is dedicated to the licensing system and is for the NAAs • Read GM 66.A.45 in order to better understand new 66.A.45 • Read 66.B.125 in order to transfer the current system into the new one EAMTC / Bordeaux
CRD to NPA 2007-07 66.011 - Type rating training EAMTC / Bordeaux
CRD to NPA 2007-07 What Type Rating Training means The type rating training is always composed of: • Theoretical portion; • Practical portion. For consistency reasons with forthcoming rulemaking task 21.039 (Operational Suitability Certificate – the minimum syllabus provided by the TCH will be limited to the theoretical and the practical elements), the OJT is not considered to be part of the type rating training. The OJT will only be mandatory and additional in the case of the first type training in an AML (sub) category in addition to the practical training, so that the mechanic can gain experience in addition to the practical portion of the type rating training. EAMTC / Bordeaux
CRD to NPA 2007-07 The OJT is training that is in addition to the practical portion of the type rating training and shall remain under the supervision of a supervisor: it means that a programme shall be set up only by an approved maintenance organisation and imparted under the oversight of a designated supervisor In addition this OJT leads to an assessment. All these elements shall be acceptable to the Competent Authority responsible for the type rating training endorsement. EAMTC / Bordeaux
CRD to NPA 2007-07 When OJT is compulsory, on which aircraft type is it permitted to be carried out? • The OJT can only be performed on the relevant aircraft type and not on any aircraft type relevant to the AML (sub) category being sought • Reason: this Part-66 requirement is the basis for granting that particular type rating on the AML of a holder who does not so far have experience in this (sub) category. It is not the basis for the certifying staff authorisation within a maintenance organisation. EAMTC / Bordeaux
CRD to NPA 2007-07 AMC 145.A.35(a): the issuance of the authorisation to the certifying staff on a specific aircraft type (in addition to the passed type rating training) within the maintenance organisation should be based on criteria including the assessment of the competency such as: • The attitude; • The general practical experience (that may differ from the practical portion imparted during the type rating training) • The knowledge of procedures applicable to the maintenance organisation and the operator / customer; • the need for differences training between the generic aircraft type rating training that the person has received and the aircraft configuration of the aircraft to be maintained • the variant difference training (training required to cover the identified differences between variants within an aircraft type rating when the type rating training that the person has received does not cover (a) variant[s]) • the needs for additional specialised training which are not part of the typical type rating training such as in depth trouble shooting, rigging, engine run-up, extensive structural repair or specialised inspection etc… AMC 66.A.20 (b)3 achieves the same goal. EAMTC / Bordeaux
CRD to NPA 2007-07 Theoretical portion of the type rating training: minimum duration The concept of the duration for the theoretical portion of the type rating training has been well perceived by the readers; even if it does not solve all the difficulties as already explained in the explanatory note of the NPA, the stakeholders have correctly understood that the outcome of NPA 2009-01 (Operational suitability certificate) will bring more solutions to that concern. Therefore the principles have been kept and improved. There are now 3 categories: • Below 5.7T • Between 5.7T and 30T • Above 30T EAMTC / Bordeaux
CRD to NPA 2007-07 • Flexibility provisions and training needs analysis • All type rating training courses will have to be approved in accordance with these new requirements “at the latest 18 months after its publication in the Official Journal of the European Union”. • After that date, these courses must fully comply with the requirements of this Regulation amendment, except that there is no need to produce a TNA for courses where the duration is already above the minimum duration described in Appendix III to Part-66. • A Training Needs Analysis (TNA) has been proposed as a GM for courses below the minimum duration. EAMTC / Bordeaux
CRD to NPA 2007-07 • Maximum number of training hours per day • For the sake of “training” efficiency, the number of tuition hours per day for the theoretical training shall not exceed 8 hours, which shall be performed during regular office hours; in exceptional cases, deviation from this standard may be envisaged when justified. This maximum number of hours is also applicable for the combination of theoretical and practical training, when they are performed at the same time. • The resulting text has been adjusted in Part-66 appendix III (type training) and will become mandatory for all type training provided by a Part-147 organisation or in the case of a direct approved course). • For consistency, an AMC has been added to 147.A.200(f) (basic training course) EAMTC / Bordeaux
CRD to NPA 2007-07 • Attendance (policy in the case of absenteeism) • Minimum participation time is at least 90 percent of the tuition hours for the theoretical training course. If this criterion is not met, the certificate of recognition shall not be issued. Additional training may be given by the training organisation in order to meet the minimum participation time. • The resulting text has been adjusted in Part-66 appendix III (type training) and will become mandatory for all type training provided by a Part-147 organisation or in the case of a direct approved course). • For consistency, the Agency recommends to add the same minimum attendance criterion to the basic knowledge training in a Part-147 environment (see new AMC 147.A.200 (f)). EAMTC / Bordeaux
CRD to NPA 2007-07 • Miscellaneous 66.O11 (TRT) • The examination process has been reviewed • Correspondence between the theoretical and the practical tables; please check consistency • Run-up is not part of the TRT • Practical training: AMC recommends the the minimum duration to be 2 weeks for complex motor-powered aircraft. EAMTC / Bordeaux
3. CRD to NPA 2008-03 B3 license and “ELA” license EAMTC / Bordeaux
CRD to NPA 2008-03 B3 license and “ELA” license Category B3 is applicable to piston-engine non-pressurized aeroplanes of 2000 Kg MTOM and below. • duration now 1000h instead of 900h. Category L is applicable to any of the following aircraft: • Sailplanes, powered sailplanes and aeroplanes with MTOM less than 1000 Kg • Balloons • Hot-air airships • Manned gas airships meeting certain criteria. Note: A helicopter is not considered to be an aeroplane EAMTC / Bordeaux
CRD to NPA 2008-03 B3 license and “ELA” license • In NPA 2008-03 a conversion of national qualifications to L and B3 licences was not envisaged for the following reasons: • B3 licence: It was expected that all the eligible persons had already been converted to B1.2. • L licence: It was expected to be very complicated to establish an adequate conversion report and in any case, the training required for the L licence was not large. • Based on the significant number of comments received from NAAs and Industry, the CRD now specifies that conversion will be possible following 66.A.70. • It is anticipated that difficulties may arise to establish adequate conversion reports EAMTC / Bordeaux
CRD to NPA 2008-03 B3 license and “ELA” license • CRD of NPA 2008-03 for "Licenses for non-complex aircraft maintenance engineers" (B3 license and “ELA” license)was published on 17 September 2009. It is now open for consultation on EASA’s website until 16 November 2009. • The tasks is now called “B3” and “L” license • See: http://hub.easa.europa.eu/crt/docs/viewcrdpdf/id_28 • To place comments please logon at http://hub.easa.europa.eu/crt/ EAMTC / Bordeaux
4. List of Type rating training (TRT) EAMTC / Bordeaux
List of Type rating training (TRT) • Appendix I to Part 66: Aircraft type ratings for Part-66 Aircraft Maintenance Licences • Current decision: 2008/03 • Next one in progress: • NPA 2009-05 was issued on 4 May 2009. • Will follow the full rulemaking process (3 month consultation) • Frequency: once a year (neither ToR nor RIA) • New structure (see example) • MTOs are expected to use this taxonomy – use of the Data sheet designation (in order to avoid any reference to the commercial designation) EAMTC / Bordeaux
List of Type rating training (TRT) • 121 comments received. • CRD of NPA-2009-05 "Appendix 1 Aircraft type ratings for Part-66 aircraft maintenance licence" is now open for consultation on EASA website until 25 Nov 2009. • See: http://hub.easa.europa.eu/crt/docs/viewcrdpdf/id_76 • To place comments please logon at http://hub.easa.europa.eu/crt/ • Resulting text: all changes from current Decision 2008-03 are tracked. EAMTC / Bordeaux
Minimum syllabus of training • 5. NPA 2009-01 (OSC concept) • CS-MCS • (Certification specification- Maintenance certifying staff) EAMTC / Bordeaux
Minimum syllabus of training • NPA 2009-01 (OSC concept) • Issued 15 January 2009; public consultation extended until 30 June 2009 • 1011 comments received. • Timing • CRD to be issued for late summer 2010 • Opinion to MDM.039 (OSC - NPA 2009-01) should be published by mid-2011 so that the respective Commission regulations can be adopted by April 2012. EAMTC / Bordeaux
Minimum syllabus of training First review of the comments. • The OSC (Operational Suitability Certificate) may be treated in a way similar to the Instructions for Continuing Airworthiness (ICA) and therefore it could be called OSD (Operational Suitability Data). • Therefore there will be no additional certificate provided by the TCH. • Catch-up for existing aircraft type: still under discussion. • Safety directives: still under discussion. EAMTC / Bordeaux
Minimum syllabus of training • CS-MCS (Certification specification- Maintenance certifying staff) • The review of the comments for the OSC has no impact: there will always a need for developing the certification specifications relative to the maintenance certifying staff. • 5th meeting was in June 09 and next meeting will be held in November 2009. • The core group for the OSD has agreed for a definition of “minimum syllabus” for “pilots” and this might inspire “maintenance” • I will update you at the next EAMTC conference. • http://www.easa.eu.int/ws_prod/c/c_flightstandards_OEB_final_report.php EAMTC / Bordeaux
QDB 6. European Question Data Bank (QDB) EAMTC / Bordeaux
QDB During summer 2009, a call for tender was issued in order to select the company responsible for the development of multiple-choice questions • for theoretical examinations in the field of flight crew licensing (10000) and • For aircraft maintenance licenses including the B3 license (20000). • You may access the study from Lplus, where the methodology of how to produce a MCQ and a QDB is described at the following URL: http://www.easa.europa.eu/ws_prod/r/r_research.php EAMTC / Bordeaux
7. Rulemaking programme EAMTC / Bordeaux
Rulemaking programme • Regarding the timeframe, Member States expressed their concerns that with the current approach it will be difficult to meet the deadlines of Regulation (EC) No 216/2008 (8 April 2012 at the latest). • A clear prioritisation in all rulemaking tasks was requested. • Member States suggested • that the NPA related to operations and pilot licensing are to be treated first, • whereas the NPA related to operational suitability certificate (OSC), third country operators (TCO), simple design aircraft, authority and organisation requirements (AOR), SAFA implementing rules and leisure flights could be dealt with at a later stage. EAMTC / Bordeaux
Rulemaking programme • On 15/09/09, the EASA management board with the blessing of the EU commission reviewed the Rulemaking Programme. • All EASA opinions related to the first extension will be published by mid-2011 (OPS, FCL etc) so that the respective Commission regulations can be adopted by April 2012. • The implementing rules for the second extension shall be adopted by the end of 2012 (Air Traffic Management/Navigation Services) and 2013 (Aerodromes) respectively. • Transition phases of 1-2 years will allow Member States and industry to better adapt to the new rules. EAMTC / Bordeaux
Rulemaking programme • Here after some of the consequences for Part 66 / 147. • MDM.055: new structure for regulation EC n°2042/2003 and SMS embodiment following the OPS structure: Opinion to be ready in 2012-01 instead of 2011.01 • MDM.039 (OSC - NPA 2009-01) should be published by mid-2011 so that the respective Commission regulations can be adopted by April 2012. • CS-MCS : minimum syllabus for maintenance – Opinion to be approved 2012-02 EAMTC / Bordeaux
Rulemaking programme • Regarding awaiting Opinions and NPA’s in progress… EAMTC / Bordeaux
Rulemaking programme • The following package shall be approved by the Parliament and Council on Nov 2009: • Opinion 06/2005 (editorial changes) • Opinion 04/2006 (Officially recognised standard) • Opinion 05/2006 (Principal place of business) • Opinion 04/2007 (Permit to fly) • Opinion 04/2008 (EWIS) • Opinion 06/2008 (EASA Form 1) • The following opinions should be approved before the end of 2010 for: • NPA 2007-07 (B1/B2 privileges, type rating training, licensing system) • NPA 2008-03 (B3 license and “L” license) • Opinion 05/2008 (Time limit for demonstrating compliance with basic knowledge and experience) • 66.027: B4 license – NPA starts 2011 EAMTC / Bordeaux
Rulemaking programme • Other rulemaking tasks • MDM.047 (updating of EC n°2042/2003 with EC n°216/2008): no impact for Part 66/147. Opinion to be ready in 2011-02 instead of 2010-01 • MDM.056: review of the ICA – NPA planned in 2011. • MDM-059: Miscellaneous of Parts 66, 147 / start 2013 / end 2016 • 66.014: §66.A.200 develop requirement for component certifying staff and for aircraft other than aeroplanes and helicopters: no schedule • 66.013: alcohol and drug testing / may start 2013.01 • 66.018 (Avoiding the splitting of examination for the basic knowledge module): a new option for the ToR aiming at “limiting the splitting” should be proposed / no schedule EAMTC / Bordeaux
Miscellaneous • SSCC meeting 09 June 09 • Election of the E&M vice-chair • Frank Kabuth is elected as vice-chairman of the sub SSCC Engineering and Maintenance. EAMTC / Bordeaux
If you have any questions on this presentation please contact:Jean-pierre.arnaud@easa.europa.eu END EAMTC / Bordeaux