1. June 200219 th FAA/JAA International Conference1 Repair/Alteration Data Developed by JAA-Maintenance Organizations by Werner Luehmann, Lufthansa Technik, Germany Members of AEA: Adria Airways, Aer Lingus, Air France, Air Malta, Alitalia, Austrian Airlines, British Airways plc, BMI British Midland, Cargolux Airlines International, Croatia Airlines, CSA Czech Airlines, Cyprus Airways, Finnair, Iberia, Icelandair, JAT Yugoslav Airlines, KLM Royal Dutch Airlines, Deutsche Lufthansa AG, Luxair, Malev Hungarian Airlines, Meridiana, Olympic Airways, SAS- Scandinavian Airlines System, Spanair, SWISS, TAP Air Portugal, Tarom, Turkish Airlines

2. June 200219 th FAA/JAA International Conference2 The Data Supplemental Type Certificates -> major alterations/modifications/repairs for JAA and FAA JAA-minor changes/modifications/alterations classified as FAA-major, or classified as FAA-minor JAA-minor repairs classified as FAA-major, or classified as FAA-minor FAA-DER approved modification/repair data -> acceptable to JAA authorities ?

3. June 200219 th FAA/JAA International Conference3 Two Systems - One Goal

4. June 200219 th FAA/JAA International Conference4 The Problem (1) Airplanes move from one register to another Overhauled/repaired components cross borders 10+ years after the original approval of the data Mostly not covered by existing bilateral agreements Additional approvals cause are waste of resources, beause of –duplication of effort and cost –loss of aircraft utilization –no added value

5. June 200219 th FAA/JAA International Conference5 The Problem (2) Unsolved differences in the definition of major/minor classification between Certification and Maintenance (FAA): (1) Major: FAR-1.1 FAR-21.93(a) = JAR-21.91 FAR-43, Appendix A (2) Minor: FAR-43.13 (a) and (b) NOT (1) ? In terms of performing maintenance JAA does neither make a distinction between major and minor (only in JAR-21), nor between approved and accepted

6. June 200219 th FAA/JAA International Conference6 Where do we stand? Slow (if at all) mutual FAA / JAA acceptance progress JAA adoption of NPA 21-8 and 21- 17 and publication under JAR-21, Subpart M per 1 May 2002, includes extensive ACJ material US-German BASA IPA STC process for almost three years can be considered essentially mature We have a set of approval concepts in both systems with DER/DAS + FAA in the US and DOA + JAA-NAA in the Europe FAAs position to AEA is not clear

7. June 200219 th FAA/JAA International Conference7 The Solution (1) A commitment is needed to proceed for data for minor changes/repairs (majority of of cases) We need reciprocal acceptance of each others concepts, because –a reciprocal acceptance looks more realistic and less time consuming than full harmonization –of experience from large airplane certification discussions –Maintenance MIPs and Certification IPAs with several European countries are a good example

8. June 200219 th FAA/JAA International Conference8 The Solution (2) Documentation issues (e.g. use of FAA Form 337 for FAA- majors) have to be solved We need a simple and quick validation procedures for import of used products Day to day problems of operators and maintenance organizations doing international business demand a quick, economical solution Lets start NOW.