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British Gliding Association

British Gliding Association. EASA – Potential Impact on Clubs and the BGA November 2003 David Roberts BGA Chairman. Background. EASA was sprung upon us Regulation 1592 /2002 Scope of Regulation Development of Essential Requirements Airworthiness – design, test, manufacture

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British Gliding Association

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  1. British Gliding Association EASA – Potential Impact on Clubs and the BGA November 2003 David Roberts BGA Chairman

  2. Background • EASA was sprung upon us • Regulation 1592 /2002 • Scope of Regulation • Development of Essential Requirements Airworthiness – design, test, manufacture Type certification Original C of A (not renewal) Maintenance

  3. EASA – Structure of Rules Structure EU Regulation 1592 Essential Requirements Airworthiness Licensing Operations Implementing Rules Implementing Rules Implementing Rules AMC & GM AMC & GM AMC & GM

  4. Airworthiness • Detailed rules covering the issue of type certificates • Issue of original C of A • Modifications approvals • Competent Authority – the UK CAA • Where does the BGA fit ? • Since 1949 the BGA has issued glider original C of A for UK all gliders. Type certificates endorsed • BGA has been unregulated in this activity

  5. Part 21 • EU law from 28 Sept 2003 - applies to gliders • BGA has negotiated three month delay whilst review of impact of Part 21 conducted by BGA • Purpose of review is to establish if BGA existing methods provide an equivalent level of safety • Will present findings to Dept for Transport Jan 04 • Aim is for derogation under Article 10 (5) Regulation 1592

  6. Impact if no derogation • All new gliders would be subject to CAA approval in terms of type certificate and original C of A • CAA one-off fees for the above plus EASA fees cascaded through CAA • CAA registration for both new and, probably existing gliders – G registrations • Identification schemes debate – comp numbers etc • Additional layer of bureaucracy with no obvious safety gain

  7. If achieve derogation Part 21 Best Case ? • BGA is delegated competent authority status • Glider register remains BGA under delegation • Registration letters ? • BGA determines type certificate compliance • BGA issues original C of A for UK registered gliders • Fees by BGA – possible increase due to CAA delegation / audit fee

  8. Impact on Owners • CAA registration • Time scales for registration / clearance of type • Time scale for issue of original C of A • Modification approval – Gatwick or Brussels? • Costs of compliance for new gliders • Costs for importing S/H gliders? • Gliders from non-mainstream manufacturers or sources outside the EU? • Grandfather rights – present fleet? • Pre JAR22 gliders – determination by 03/07

  9. Safety ? • No safety case made by the EU for this change • Majority of EU gliding nations have state registration and C of A • UK the odd man out ! • No consultation. No scrutiny by Euro Parliament

  10. Glider Maintenance • Draft IR-M • Successfully lobbied to get deferral and major review • IR-M deferred to March 2005 earliest…..? • More work to do in Brussels • If not changes, could have significant impacts on UK maintenance practice • Again – no safety case. Rules not evidence based on need

  11. Sample of Impacts – IR-M • Qualifications for glider engineers – degree? Experience? Catch 22 • Instruments – part released and type approved • Approved items of pilot maintenance prescribed • Workshops – standards. M3 only? • Paperwork processes – may not be too bad • Managed environment for maintenance • Maybe 3 year C of A renewal if glider under approved maintenance organisation supervision

  12. The Next Chapters • Licensing (2004?) and Operations (2004-5?) • Licensing – ICAO based? • Key issue will be means of ascertaining medical fitness to fly • Self declaration – GP endorsement • BGA position on medicals • European Gliding Union role and Europe Air Sports

  13. Summary • Times are a-changing • We have been forced into this without proper process or Regulatory Impact Assessments • Support from the CAA and Dept. for Transport for our position, generally, but……CAA and DFT have to comply with the (EU) law. It’s how they interpret it and allow flexibility under the provisions….. • The BGA is fighting to retain as much freedom as it can and to achieve maximum delegation whilst benefiting from the positive aspects of EASA

  14. Questions? I’ll try to answer them !

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