6th part-66 and part-147 meeting (12.10.2010) · cologne, 12 october 2010 6th easa part-66/part-147...
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Cologne, 12 October 2010 6th EASA Part-66/Part-147 Standardisation Meeting
6th Part-66 and Part-147 Meeting (12.10.2010)
Introduction (Thomas Mickler)
Opening (Mark Kieft)
Issue 1 –Transfer of Part-66 files (Peter Udsen)
Issue 2 – Additional Requirements (Andrea Bandieri)
Issue 3 – Third Country Part-66 Applicants (Ludwig Hessler)
Issue 4 – Use of Part-66 for National Privileges (Bram van Driel)
Cologne, 12 October 2010 6th EASA Part-66/Part-147 Standardisation Meeting
66thth EASA PartEASA Part--66/Part66/Part--147 147 StandardisationStandardisation MeetingMeeting
Welcome
&
Introduction
by
Thomas MicklerHead of Standardisation Department
Cologne, 12 October 2010 6th EASA Part-66/Part-147 Standardisation Meeting
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Head ofStandardisation
Head ofStandardisation
Air OperationsG. Rebender
Air OperationsG. Rebender
Accreditation J. Müller
Accreditation J. Müller
Flight Crew LicensingG. De Crescenzo
Flight Crew LicensingG. De CrescenzoAirworthiness
M. KieftAirworthiness
M. Kieft
Deputy HoDM. Kompare
Deputy HoDM. Kompare
SecretariatSecretariat
Standardisation Department (October 2010)
DevelopmentC. Trevisan
DevelopmentC. Trevisan
ATM/ANSN.N.
ATM/ANSN.N.
IAWIAW CAWCAW
Cologne, 12 October 2010 6th EASA Part-66/Part-147 Standardisation Meeting
66thth EASA PartEASA Part--66/Part66/Part--147 147 StandardisationStandardisation MeetingMeeting
A balanced Standardisation Strategy (3 Pillars)
Pillar No 1: Standard. Inspections (reactive)Pillar No 2: Proactive Measures
- Standardisation Meetings - Technical Training of NAA Inspectors - Information Sharing Tool (Sinapse) - Participation of NAA inspectors as team members - Consultation mechanism for NAAs, etc.
Pillar No 3: Evaluation of Impact of Regulations (feedback mechanism)
Evolution towards risk based CMA
Cologne, 12 October 2010 6th EASA Part-66/Part-147 Standardisation Meeting
66thth EASA PartEASA Part--66/Part66/Part--147 147 StandardisationStandardisation MeetingMeeting
Have a successful meeting…….
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European Aviation Safety Agency
Welcome
Reorganisation
Who we are
What we will discuss
How we will do this
General rules
The future
What’s new
The social event
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European Aviation Safety Agency
This is YOUR meeting
This is your chance to
Share best practices
Explain your situation
Learn from others
Discuss the interpretation of the rule
Highlight problems to EASA
Provide constructive feedback
Come to a common understanding
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European Aviation Safety Agency
Reorganisation
Continuing Airworthiness Standardisation Manager
(since April)
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European Aviation Safety Agency
ReorganisationAll 1702 and 2042 scope in one section
To reduce the number of sections ready for the extension of standardisation to ATM/ANS and ADM
To create a dedicated accreditation section
To reduce the inspection burden
To be in line with ICAO USOAP
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European Aviation Safety Agency
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S 1 – Standardisation Department Team
Standardisation Coordination Assistants:
Laurence Blasch-Roussel Javadian Agnes Gabriele Klar Susan Schulien
Standardisation Secretaries:
Kathryn Dowling
PenelopeMamopoulou
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European Aviation Safety Agency
Head of
Standardisation Department Thomas Mickler
Deputy Head of
Standardisation Department Marcel Kompare
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European Aviation Safety Agency
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S.1.1 - Airworthiness Section
STL Luis Pires
Manager MarkKieft
STL Tore
Sandbu
STL Bram
van Driel
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European Aviation Safety Agency
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S.1.1 - Airworthiness Section
STL Ludwig Hessler
STL Gian Andrea
Bandieri
STL Peter
Gernandt
STL Chris van Lieshout
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European Aviation Safety Agency
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S.1.1 - Airworthiness Section
STL Stefano
Bernardini
STL Jean-Luc Rieni
STL Carmen Chirita
STL Peter Udsen
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European Aviation Safety Agency
Agenda – flexible!
DAY 1 Tuesday 12 October 2010 13:15 Opening and Welcome
13:30 GENERAL INTRODUCTION
14:30 ISSUE 1 – Transfer of 66 licenses
15:00 Coffee break
15:30 ISSUE 2 – Criminal records and health certificates
16:00 ISSUE 3 – Applications for 66 from outside the EU
16:30 ISSUE 4 – National privileges on a 66 license
17:00 WRAP-UP OF THE DAY
19:30 Social Event
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European Aviation Safety Agency
Agenda – flexible!DAY 2 Wednesday 13 October 2010
09:00 Arrival
09:15 Rulemaking update
09:45 ISSUE 5 – Type training before basic license
10:15 ISSUE 6 – Web based training
11:00 Coffee break
11:30 ISSUE 7 – General Aviation training and examination
12:15 Team member qualification and currency
12:30 Questions and answers
13:00 CONCLUSIONS OF THE MEETING
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European Aviation Safety Agency
General Organisation
Mobile Phones – “Mute/Off” Please complete the list of participants (check contact details
– phone/e-mail etc) Business cards in tray – 1x is enough. We will copy to all
participants after the meeting Questions to be asked – at any timeWe welcome your opinions – at any time Moderator of the meeting – time management is important Everybody can talk and ask – but not all at the same time... Final publication of the MoM and presentations on SINAPSE Breaks – flexible Please complete the feedback questionnaire
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European Aviation Safety Agency
Mutual expectations during a standardisation inspection
We are working on a document, which will be provided prior to an inspection
Clarifies what is expected of an NAA, and what an NAA can expect of us
Covers all 5 phases of an inspection
Gives advice to the NAA on how best to manage an inspection, and the inspection team
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European Aviation Safety Agency
Inspections – what we expect
During the planning phase – timely information
During the visiting phase – excellent understanding
During the reporting phase – proof-reading and comments
During the follow-up phase – an action plan
During the closure phase – timely evidence of action plan implementation
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European Aviation Safety Agency
Inspections – what we expect
During the planning phase – timely information
During the visiting phase – excellent understanding
During the reporting phase – proof-reading and comments
During the follow-up phase – an action plan
During the closure phase – timely evidence of action plan implementation
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European Aviation Safety Agency
Inspections – what we expect
During the planning phase – timely information
During the visiting phase – excellent understanding
During the reporting phase – proof-reading and comments
During the follow-up phase – an action plan
During the closure phase – timely evidence of action plan implementation
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European Aviation Safety Agency
Inspections – what we expect
During the planning phase – timely information
During the visiting phase – excellent understanding
During the reporting phase – proof-reading and comments
During the follow-up phase – an action plan
During the closure phase – timely evidence of action plan implementation
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European Aviation Safety Agency
Inspections – what we expect
During the planning phase – timely information
During the visiting phase – excellent understanding
During the reporting phase – proof-reading and comments
During the follow-up phase – an action plan
During the closure phase – timely evidence of action plan implementation
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European Aviation Safety Agency
What is an acceptable action plan?
Following an inspection final report2 weeks to present a CAP for class D findings10 weeks to present a CAP for class C findings16 weeks to gain an agreement of the CAP
Many cases exist of the CAP being inadequate
Following the inspection, we expect the NAA to carry out a root-cause analysis of the finding – before submitting a CAP
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European Aviation Safety Agency
What is an acceptable action plan?
The CAP should indicate the root-cause analysis, including indicating whether the finding was a one- off, or a systemic error
The CAP should correct the immediate situation (e.g. the certificates will be re-issued), and prevent re- occurrence (e.g. procedure changed)
The CAP should indicate a timeframe by which actions will be completed (these timeframes should be in the future)
The CAP should be simple to understand, simple to implement, and simple to verify implementation
The CAP should only fix the finding’s root-cause, and not all the problems in the NAA
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European Aviation Safety Agency
What is an acceptable action plan?
My team will do everything possible to support the NAAs in perfecting the CAP, but cannot –Do the root-cause analysisPropose actions or datesGive any extensions to the acceptance
timeframes
Non-acceptable CAPs after 16 weeks can only lead to a supplementary report!
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European Aviation Safety Agency
Inspections – what we expect
During the planning phase – timely information
During the visiting phase – excellent understanding
During the reporting phase – proof-reading and comments
During the follow-up phase – an action plan
During the closure phase – timely evidence of action plan implementation
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European Aviation Safety Agency
Other AIR standardisation meetings this year
M and 145 on 31 May – 1 JuneM and 145 on 3/4 November21 POA on 2/3 December
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European Aviation Safety Agency
How many standardisation meetings a year?
This year, we have 4 standardisation meetings
Is this the right amount?
Is this the best way to split the regulations?
Would it be better to have 1 or 2 ‘super’ AIR meetings a year?
Will be consulting you on how best to cover the AIR scope at future meetings
Your ideas would be welcomed!
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European Aviation Safety Agency
5th POA Standardisation MeetingStandardisation plan 2011
Plan is approved Now arranging specific datesSome inspections over 2 weeksAll combined inspectionsAll with POA includedContribution of team members has been
requested – once finalised, will be set in stone
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European Aviation Safety Agency
NEW THIS TIME – “Conclusions”
We used to use the term “Agreed Practices”
The term was not liked
Now called “conclusions”
Same intent
Not legally binding, but mutually desiredTo achieve a common understanding“agreed” method of application
Near future - Will go into rulemaking- machine to become AMC
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European Aviation Safety Agency
NEW THIS TIME – proposed conclusion
We want to come to a conclusion on each topic, as this allows you to take something concrete home
However, it is unfair to discuss a topic without you knowing where we are heading
Therefore we have sent the proposed conclusions in advance
Hopefully this will allow you to have better arguments ready at the discussion phase
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European Aviation Safety Agency
NEW THIS TIME – Best practices form
In your folder, there are ‘Best Practices Forms’
These are to collect your ideas related to each topic – not enough time to discuss everything today
We will briefly discuss tomorrow
And will minute in the MoM
Please complete best practices forms to share your knowledge!
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European Aviation Safety Agency
Finally
Proactive is better than reactive….So please -participate in, learn from, and enjoy the discussions
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European Aviation Safety Agency
6th Part-66 and Part-147 Standardisation Meeting – Cologne 12 and 13 October 2010
ISSUE 1: Transfer of Part-66 licences from one MS to another MS
ISSUE 1: Transfer of Part-66 licences from one MS to another MS
Peter Udsen Standardisation Team Leader
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European Aviation Safety Agency
6th Part-66 and Part-147 Standardisation Meeting – Cologne 12 and 13 October 2010
ISSUE 1: Transfer of Part-66 licences from one MS to another MS
Description of the problem Proposed conclusionHighlights of the relevant regulations Summary Discussion Final conclusion
Items
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European Aviation Safety Agency
6th Part-66 and Part-147 Standardisation Meeting – Cologne 12 and 13 October 2010
ISSUE 1: Transfer of Part-66 licences from one MS to another MS
Description of the problemA person who has his first AML issued by the
Member State of residence, and then later moves to another Member State. e.g. do to personal reasons.
He wants to change his AML, and wants of course the change be done by the Competent Authority in his new country.But the regulation does not allow this.
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European Aviation Safety Agency
6th Part-66 and Part-147 Standardisation Meeting – Cologne 12 and 13 October 2010
ISSUE 1: Transfer of Part-66 licences from one MS to another MS
Proposed conclusionCan a Member State extent an AML issued in an
another Member State?
No!
The regulation clearly states that any change to the AML shall be done by the Member State of first issue.
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European Aviation Safety Agency
6th Part-66 and Part-147 Standardisation Meeting – Cologne 12 and 13 October 2010
ISSUE 1: Transfer of Part-66 licences from one MS to another MS
Any Questions?
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European Aviation Safety Agency
6th Part-66 and Part-147 Standardisation Meeting – Cologne 12 and 13 October 2010
ISSUE 1: Transfer of Part-66 licences from one MS to another MS
Any Questions?
Can Article 14 be used?
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European Aviation Safety Agency
6th Part-66 and Part-147 Standardisation Meeting – Cologne 12 and 13 October 2010
ISSUE 1: Transfer of Part-66 licences from one MS to another MS
Any Questions?
Can Article 14 be used?
Will there be changes to the regulation in the future ?
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European Aviation Safety Agency
6th Part-66 and Part-147 Standardisation Meeting – Cologne 12 and 13 October 2010
ISSUE 1: Transfer of Part-66 licences from one MS to another MS
Regulation - Part 6666.A.10 Application
(a) An application for an aircraft maintenance licence or change to such licence shall be made on an EASA Form 19 in a manner established by the competent authority and submitted thereto.
(b) An application for the change to an aircraft maintenance licence shall be made to the competent authority of the Member State that first issued the aircraft maintenance licence.
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European Aviation Safety Agency
6th Part-66 and Part-147 Standardisation Meeting – Cologne 12 and 13 October 2010
ISSUE 1: Transfer of Part-66 licences from one MS to another MS
Regulation - Part 6666.A.10 Application(e) Where the applicant for change of the basic categories qualifies for such change via the procedure referred to in point 66.B.105 in a Member State other than the Member State in which he/she first qualified, the maintenance organisation approved in accordance with Annex II (Part-145) shall send the aircraft maintenance licence together with the EASA Form 19 to the competent authority of the Member State of first qualification for Member State stamp and signature of the change or reissue of the licence.
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European Aviation Safety Agency
6th Part-66 and Part-147 Standardisation Meeting – Cologne 12 and 13 October 2010
ISSUE 1: Transfer of Part-66 licences from one MS to another MS
Can Article 14 be used?
In extreme situation where a need can be justified, it is possible to diverge from the regulation, by the use of article 14 in the basic regulation.
But one basic principle stands:
An AML holder can only have one license.
Therefore the condition for the transfer must be:1. The two Member States should agree and cooperate.2. The new Member State becomes the Member State of first issue3. The new Member State shall accept to take duties and
responsibility as Member State of first issue.4. The files of the AML holder shall be transferred to the new
Member State of first issue.5. The new Member State shall issue a new license replacing the
former license.6. The License shall be issued in accordance with Part-66.B.100. 7. The former license shall be accepted as part of the applicants'
knowledge and experience.8. The former Member State shall cancel the former license.
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European Aviation Safety Agency
6th Part-66 and Part-147 Standardisation Meeting – Cologne 12 and 13 October 2010
ISSUE 1: Transfer of Part-66 licences from one MS to another MS
Proposed change to Part 66There are proposal for changes in Part-66 to
allow the transfer of a license between Member States. Member States
Within a year this change will be enforced.
So until further, follow the current regulation!
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European Aviation Safety Agency
6th Part-66 and Part-147 Standardisation Meeting – Cologne 12 and 13 October 2010
ISSUE 1: Transfer of Part-66 licences from one MS to another MS
Summary The regulation does not allow the transfer of a
license between Member States.
Article 14 can only be used in special cases.
Change to Part 66 might change to the favour of this issue.
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European Aviation Safety Agency
6th Part-66 and Part-147 Standardisation Meeting – Cologne 12 and 13 October 2010
ISSUE 1: Transfer of Part-66 licences from one MS to another MS
Final ConclusionFollow the regulations!
Do not use Article 14, excepted in extreme situation.
Hold your hoses, and wait for the change of the regulation.
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European Aviation Safety Agency
6th Part-66 and Part-147 Standardisation Meeting – Cologne 12 and 13 October 2010
ISSUE 2: Additional National Requirements
ISSUE 2: ADDITIONAL NATIONAL REQUIREMENTS
Gian Andrea BandieriStandardisation Team Leader
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European Aviation Safety Agency
6th Part-66 and Part-147 Standardisation Meeting – Cologne 12 and 13 October 2010
ISSUE 2: Additional National Requirements
Situation
During recent inspections it was found that some NAAs are requiring applicants for Part- 66 Licences to fulfil additional national requirements
These may include:Statement of no criminal recordsHealth certificateEvidence of no abuse of alcohol or drugs
The good intention is evident, however in this case only EU law needs to be complied with
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European Aviation Safety Agency
6th Part-66 and Part-147 Standardisation Meeting – Cologne 12 and 13 October 2010
ISSUE 2: Additional National Requirements
Proposed conclusions
Imposition of additional national requirements (e.g.: Certificate of no criminal records, Health certificate, compliance with national criminal law in
respect of the abuse of alcohol and drugs)
for the issue of a Part-66 Licence is considered a violation of the European Legislation.
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European Aviation Safety Agency
6th Part-66 and Part-147 Standardisation Meeting – Cologne 12 and 13 October 2010
ISSUE 2: Additional National Requirements
Legal considerations (1)
Recital (10) of Basic Regulation must be read together with art. 2
In order to achieve Community objectives as regards the freedom of movement of goods, persons and services, as well as those of the common transport policy, Member States should, without further requirements or evaluation, accept products, parts and appliances, organisations or persons certified in accordance with this Regulation and its implementing rules.
Article 2 Objectives1. …2. Additional objectives are, in the fields
covered by this Regulation, as follows:..(f) to provide a level playing field for
all actors in the internal aviation market.
3. The means of achieving the objectives set out in paragraphs 1 and 2 shall be:
d) the uniform implementation of all necessary acts by the national aviation authorities and the Agency within their respective areas of responsibility.
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European Aviation Safety Agency
6th Part-66 and Part-147 Standardisation Meeting – Cologne 12 and 13 October 2010
ISSUE 2: Additional National Requirements
Legal considerations (2)
Aircraft maintenance licences can only be issued in accordance with Part-66
Only Part-66 requirements need to be fulfilled to issue an Aircraft maintenance licence
66.B.100 is the only applicable requirement:a) On receipt of EASA Form 19 and any supporting documentation,
the competent authority shall verify EASA Form 19 for completeness and ensure that the experience claimed meets the requirement of this Part.
b) The competent authority shall verify an applicant's examination status and/or confirm the validity of any credits to ensure that all required modules of Appendix I have been met as required by this Part.
c) When satisfied that the applicant meets the standards of knowledge and experience required by this Part, the competent authority shall issue the relevant aircraft maintenance licence to the applicant. The same information shall be kept on competent authority file.
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European Aviation Safety Agency
6th Part-66 and Part-147 Standardisation Meeting – Cologne 12 and 13 October 2010
ISSUE 2: Additional National Requirements
Legal considerations (3)
To receive an Aircraft maintenance licences the applicant needs only to comply with the standards of knowledge and experience defined in Part-66
NO MORE
NO LESS
As a citizen he has to comply with all other national regulations in force in the country where he works, but a preventative compliance cannot be required by the NAA
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European Aviation Safety Agency
6th Part-66 and Part-147 Standardisation Meeting – Cologne 12 and 13 October 2010
ISSUE 2: Additional National Requirements
Conclusions
In order to issue a Part-66 Licence, only Part-66 requirements are applicable
Adding national requirements for the issue of a Part-66 Licence violates EU legislation
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European Aviation Safety Agency
6th Part-66 and Part-147 Standardisation Meeting – Cologne 12 and 13 October 2010
ISSUE 2: Additional National Requirements
Discussion
Do you have any national additional requirements to be fulfilled at the time of application for a Part-66 Licence? If so can you provide us with some example?
Is there any particular reason for linking them to the issue of a Part-66 licence?
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European Aviation Safety Agency
6th Part-66 and Part-147 Standardisation Meeting – Cologne 12 and 13 October 2010
ISSUE 2: Additional National Requirements
Final conclusions
Do not impose additional national requirements to issue a Part-66 Licence
Requiring: Certificate of no criminal records, Health certificate, compliance with national criminal law (e.g. in
respect of the abuse of alcohol and drugs)
is considered a violation of the European Legislation.
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European Aviation Safety Agency
6th Part-66 and Part-147 Standardisation Meeting – Cologne 12 and 13 October 2010
Issue 3: Part-66 Third Country Applicants
ISSUE 3: Part-66 Third Country Applicants
Ludwig Heßler Standardisation Team Leader
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European Aviation Safety Agency
6th Part-66 and Part-147 Standardisation Meeting – Cologne 12 and 13 October 2010
Issue 3: Part-66 Third Country Applicants
Description of the problemProposed conclusionHighlights of the relevant
regulationsSummary DiscussionFinal conclusion
Items
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European Aviation Safety Agency
6th Part-66 and Part-147 Standardisation Meeting – Cologne 12 and 13 October 2010
Description of the problemSituation: Mechanics from third countries apply
for a Part-66 licence in Member States in order to:o either work in an organisation approved by the
Member States on EU registered aircrafto or work in EASA approved organisations on EU
registered aircraft which have premises in the Member state.
Problems: EASA Form 19 are not used, certificates issued by 147 approved organisations are not recognised
Issue 3: Part-66 Third Country Applicants
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European Aviation Safety Agency
6th Part-66 and Part-147 Standardisation Meeting – Cologne 12 and 13 October 2010
Proposed conclusion
Treat applicants equal to applicants from a Member State (EASA Form 19 etc.).
Accept training certificates issued by Part- 147 organisations.
Issue 3: Part-66 Third Country Applicants
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European Aviation Safety Agency
6th Part-66 and Part-147 Standardisation Meeting – Cologne 12 and 13 October 2010
Highlights of the relevant regulations
66.A.10 Application
(a) An application for an aircraft maintenance licence or change to such licence shall be made on an EASA Form 19 in a manner established by the competent authority and submitted thereto.
Issue 3: Part-66 Third Country Applicants
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European Aviation Safety Agency
6th Part-66 and Part-147 Standardisation Meeting – Cologne 12 and 13 October 2010
Highlights of the relevant regulations
66.A.25 Basic knowledge requirements(a) An applicant for an aircraft maintenance
licence or the addition of a category or subcategory to such an aircraft maintenance licence shall demonstrate, by examination, a level of knowledge in the appropriate subject modules in accordance with Appendix I to this Part.
The basic knowledge examinations shall be conducted by a training organisation appropriately approved under Part-147 or by the competent authority.
Issue 3: Part-66 Third Country Applicants
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European Aviation Safety Agency
6th Part-66 and Part-147 Standardisation Meeting – Cologne 12 and 13 October 2010
Summary
Procedures used for applications shall follow the rules.
Issue 3: Part-66 Third Country Applicants
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European Aviation Safety Agency
6th Part-66 and Part-147 Standardisation Meeting – Cologne 12 and 13 October 2010
Discussion
How many (percentage) applications from non-EU mechanics did you have in the past?
How did you handle these applications?
Issue 3: Part-66 Third Country Applicants
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European Aviation Safety Agency
6th Part-66 and Part-147 Standardisation Meeting – Cologne 12 and 13 October 2010
Final conclusion
Treat applicants equal to applicants from a Member State (EASA Form 19 etc.).
Accept training certificates issued by Part- 147 organisations.
Issue 3: Part-66 Third Country Applicants
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European Aviation Safety Agency
6th Part-66 and Part-147 Standardisation Meeting – Cologne 12 and 13 October 2010
Issue 4: Part-66 AML and national privileges
/22
Issue 4: Use of Part-66 AML in case of national privileges
Bram van Driel Standardisation Team Leader
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European Aviation Safety Agency
6th Part-66 and Part-147 Standardisation Meeting – Cologne 12 and 13 October 2010
Issue 4: Part-66 AML and national privileges
/22
Introduction Proposed conclusionQuestions to be answered Highlights of the relevant regulations EvaluationDiscussion Summary Final conclusion
Items
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European Aviation Safety Agency
6th Part-66 and Part-147 Standardisation Meeting – Cologne 12 and 13 October 2010
Issue 4: Part-66 AML and national privileges
/22
Introduction Part-66 (form-26) has an optional annex to the AML for
national privileges.
What are the rules or restrictions to use this annex?
Part-66 Appendix VI limits the use of the annex to privileges outside the scope of part-66, covered by national legislation in force prior to Part-66
(nov 2003*).
Different interpretations exist.* Depending opt-out.
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European Aviation Safety Agency
6th Part-66 and Part-147 Standardisation Meeting – Cologne 12 and 13 October 2010
Issue 4: Part-66 AML and national privileges
/22
Proposed conclusion
NAA’s are free in the use of the annex.
Use national legislation and procedures for the annex.
Use is irrespective of entry into force of national regulation. (Appendix VI to be amended)
Use is irrespective of the date the privilege was first issued.
National privileges cannot cover part-66 privileges.
National privileges can go beyond Part-66 sub-categories.
The Annex shall not be issued with an empty part-66 AML.
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European Aviation Safety Agency
6th Part-66 and Part-147 Standardisation Meeting – Cologne 12 and 13 October 2010
Issue 4: Part-66 AML and national privileges
/22
Questions to answer…Are National privileges in the optional annex:
limited to the the scope of part-66 AML?
limited to type ratings?
limited to conversion?
limited to exisiting regulation?
limited to exisiting privileges?
What is relation to Certification authorisation?
Is national privilege additional burden to holder?
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European Aviation Safety Agency
6th Part-66 and Part-147 Standardisation Meeting – Cologne 12 and 13 October 2010
Issue 4: Part-66 AML and national privileges
/22
Highlights of relevant regulations (Part-66 Appendix VI)
‘Aircraft Maintenance Licence (Part-66 AML)
11. The annex to EASA Form 26 is optional and may only be used to include national privileges not covered by Part-66, where such privileges were covered by the national regulation in force prior to the implementation of Annex III (Part-66).’
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European Aviation Safety Agency
6th Part-66 and Part-147 Standardisation Meeting – Cologne 12 and 13 October 2010
Issue 4: Part-66 AML and national privileges
/22
Highlights of relevant regulations
‘Aircraft Maintenance Licence (Part-66 AML)
11. The annex to EASA Form 26 is optional and may only be used to include national privileges not covered by Part-66, where such privileges were covered by the national regulation in force prior to the implementation of Annex III (Part-66).’
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European Aviation Safety Agency
6th Part-66 and Part-147 Standardisation Meeting – Cologne 12 and 13 October 2010
Issue 4: Part-66 AML and national privileges
/22
Highlights of relevant regulations
‘Aircraft Maintenance Licence (Part-66 AML)
11. The annex to EASA Form 26 is optional and may only be used to include national privileges not covered by Part-66, where such privileges were covered by the national regulation in force prior to the implementation of Annex III (Part-66).’
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European Aviation Safety Agency
6th Part-66 and Part-147 Standardisation Meeting – Cologne 12 and 13 October 2010
Issue 4: Part-66 AML and national privileges
/22
Highlights of relevant regulations
Aircraft Maintenance Licence (Part-66 AML)
11. The annex to EASA Form 26 is optional and may only be used to include national privileges, where such privileges are covered by the national regulation outside the scope of Annex III (Part-66).
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European Aviation Safety Agency
6th Part-66 and Part-147 Standardisation Meeting – Cologne 12 and 13 October 2010
Issue 4: Part-66 AML and national privileges
/22
Highlights of relevant regulations
Part-66 Appendix VI
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European Aviation Safety Agency
6th Part-66 and Part-147 Standardisation Meeting – Cologne 12 and 13 October 2010
Issue 4: Part-66 AML and national privileges
/22
Evaluation (1)
The intention of the Annex is to allow
- on one licensing document –
both privileges following Part-66 and
privileges not covered by Part-66.
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European Aviation Safety Agency
6th Part-66 and Part-147 Standardisation Meeting – Cologne 12 and 13 October 2010
Issue 4: Part-66 AML and national privileges
/22
Evaluation (2)The Annex to Part-66 (Form 26) may be used
for any national privilege,
as defined by national regulations
provided:
The scope of the national privileges is clear.
The national licences clearly do not cover privileges under EU jurisdiction.
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European Aviation Safety Agency
6th Part-66 and Part-147 Standardisation Meeting – Cologne 12 and 13 October 2010
Issue 4: Part-66 AML and national privileges
/22
Evaluation (3) Beware of frequent changes in Scope of Part-66:
Opt-out expires (GA)New (sub) categories (“L”) EASA type certificates (prototype) Annex II aircraft (DC 4)
National privileges can go beyond Part-66 sub-categories. Limitations. Types outside the scope of part-66. Covered by national legislation.
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European Aviation Safety Agency
6th Part-66 and Part-147 Standardisation Meeting – Cologne 12 and 13 October 2010
Issue 4: Part-66 AML and national privileges
/22
Evaluation (4) Validity of national privileges:
As defined by national and international regulations.
Never applicable to privileges covered by EASA.
Aircraft maintenance of nationally registered aircraft ….around the world.
Possible mutual recognition. (bilateral agreements etc)
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European Aviation Safety Agency
6th Part-66 and Part-147 Standardisation Meeting – Cologne 12 and 13 October 2010
Issue 4: Part-66 AML and national privileges
/22
Evaluation (5) The Annex is open for any national privilege. Examples:
Basic rating and/or Aircraft type rating for
EASA aircraft within opt-out period
Annex II aircraft (Vintage, gliders, Balloons etc)
State aircraft
Military aircraft
Component Maintenance Licences Specialised services Ground support licences Etc.
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European Aviation Safety Agency
6th Part-66 and Part-147 Standardisation Meeting – Cologne 12 and 13 October 2010
Issue 4: Part-66 AML and national privileges
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Evaluation (6) National privilege for Annex II aircraft (some examples):
Aircraft maintenance Gyrocopters
Airframe Breguet 904
Airworthiness inspection
Electrical systems All piston engine a/c
Hydraulics
Nav/com All a/c
Radio ARC 192
Turbine engines PT6
B1.2 Piston engined annex II a/c
National privileges for aircraft engaged in military, customs, police or similar services:
Aircraft maintenance Police helicopters Bo105
Airframe Beech 1900 coastguard
Other National privilege examples:
Workshops (Hydraulics, Electrics, Nav/com, etc)
Specific components (ARC 192, PT6, Wheels, etc)
Radio communication on the ground
87
European Aviation Safety Agency
6th Part-66 and Part-147 Standardisation Meeting – Cologne 12 and 13 October 2010
Issue 4: Part-66 AML and national privileges
/22
Evaluation (7) To be combined with any Part-66 AML:
A3
B1.1 Line maintenance certifying technician - mechanical - Turbine Aeroplanes.
(Bombardier) Learjet 23 (GE CJ610)(Hawker Beechcraft) Beech 200 Series (PWC PT6)(Hawker Beechcraft) Beech 390 (Williams FJ44)(Hawker Beechcraft) Beech 90 Series (PWC PT6)(Hawker Beechcraft) Beech 99/100 Series (PWC PT6)
B1.4 Line maintenance certifying technician - mechanical - Piston Helicopters.
All Single piston helicopters in group 13.
88
European Aviation Safety Agency
6th Part-66 and Part-147 Standardisation Meeting – Cologne 12 and 13 October 2010
Issue 4: Part-66 AML and national privileges
/22
Evaluation (8)
No Part-145 and M/subpart-F authorisation for aircraft CRS based on annex.
NAA free to base national authorisation on Part-66 AML (Sub category and group ratings).
89
European Aviation Safety Agency
6th Part-66 and Part-147 Standardisation Meeting – Cologne 12 and 13 October 2010
Issue 4: Part-66 AML and national privileges
/22
Evaluation (9)
Annex to EASA Form 26XIII. NATIONAL PRIVILEGES outside the scope of Part-66,
in accordance with ‘ministerieel besluit V&W/dcr/123’. (valid only in the Netherlands)
Radio Licence Privileges:Radio operator valid on ground only
Maintenance of Annex II aircraft:Airframe Breguet 904
Example:
EASA Form 26 Issue 2
90
European Aviation Safety Agency
6th Part-66 and Part-147 Standardisation Meeting – Cologne 12 and 13 October 2010
Issue 4: Part-66 AML and national privileges
/22
Discussion Does your country use this Annex?
Does your country have restrictive use?Within sub-category of Part-66 ratings. No new privileges.
Would you wish to restrict the use to old privileges?
Does your country use Part-66 as basis for national privileges?
91
European Aviation Safety Agency
6th Part-66 and Part-147 Standardisation Meeting – Cologne 12 and 13 October 2010
Issue 4: Part-66 AML and national privileges
/22
SummaryAnswers to the questions
National privileges in the optional annex:
Can be independent of the scope of part-66 AML.
Are not limited to type ratings.
Are not limited to conversion.
Are not limited to existing national regulation.
Are not limited to existing national privileges.
Have no effect on Certification Authorisations requiring Part- 66 AML.
National privileges may not add requirements to Part-66.
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European Aviation Safety Agency
6th Part-66 and Part-147 Standardisation Meeting – Cologne 12 and 13 October 2010
Issue 4: Part-66 AML and national privileges
/22
Final conclusion
NAA’s are free in the use of the annex.
Use national legislation and procedures for the annex.
Use is irrespective of entry into force of national regulation. (Appendix VI to be amended)
Use is irrespective of the date the privilege was first issued.
National privileges can go beyond Part-66 sub-categories.
National privileges cannot cover part-66 privileges.
The Annex shall not be issued with an empty part-66 AML.
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