Presentation on theme: "EASA operational support to engineering tasks (i.a. processing of STCs) Vincent De Vroey 4 th EASA-Industry Meeting."— Presentation transcript:
EASA operational support to engineering tasks (i.a. processing of STCs) Vincent De Vroey Vincent.De.Vroey@aea.be www.aea.be 4 th EASA-Industry Meeting Cologne, 17 th November 2005
Background On 23rd May 2005, the AEA wrote to EASA, expressing concerns about increasing difficulties faced with processing Supplemental Type Certificate (STC) applications under EASA Design Organisation Approval (DOA). The AEA was in particular concerned that if not resolved these difficulties could put the EU industry at a competitive disadvantage in the international modification market. The AEA met with the EASA Certification Director on 7th July to explore practical solutions for the problems raised. Various actions and commitments to improve the process were agreed.
Lack of clear procedures is a key problem 1)Lack of written procedures and standardisation for STC applications and processing EASA internal working-procedures are still not detailed enough and have resulted in a lot of confusion on how to apply and make progress with applications. Clear procedures are needed now! EASA agreed to develop standards/policies and to put certain conditions (i.a. maximum number of hours) in contracts with NAAs (who act on behalf of EASA). Status?
DOA privileges 2) Some NAAs acting on behalf of EASA continue to check 100% of the data, which is not in line with DOA privileges EASA committed themselves to provide training for PCMs and to set up a working-group to develop more guidance on the scope of the DOA privileges In the mean time, some NAAs continue to check 100% of the data, with no signal from EASA to them that this should not be the case. Implications in term of costs and delays are significant. Status?
List of persons in charge and central applications office 3) No list of persons allowing direct contact for STC and AMOC applications and investigations. This is particularly important during the STC pre-application phase. Still no list published. Up to 6 weeks delay between application letter and contact with the PCM. Clearly unacceptable. EASA confirmed, that it has the intention to create a central office for applications. Status?
Late acknowledgement of STC applications 4) Late acknowledgement of STC applications EASA has the objective in the future to acknowledge applications within 10 days. This will include information on the team which has been allocated and will include contact details of the person in charge. However, this objective has not been yet met since airlines continue to be faced with unacceptable late acknowledgement (up to 6 weeks). Solution needed now to avoid serious distress to the EU repair industry!
Delays technical VISA/issuing STC 5) Important delays between the TV (technical visa) and the issuing of the STC. Furthermore, the use of Article 10.3 to release the aircraft based on the TV is not always possible (e.g. registration NAA different from the TV NAA). EASA has a clear objective of a maximum 1 day between the technical visa and the issuance of the STC, Delays are still important (up to 6 weeks). Furthermore, this may still not be sufficient in all cases (e.g. aircraft awaiting release to service after final flight test). Legal status should be given to the TV, in order to allow the aircraft release to service immediately after the TV issuance (as compared to FAA process!), pending final STC issuance.
STC applications based on FAA STCs 6) Timeframes for processing STC applications based upon FAA STCs too important. (FAA responds very quickly) EASA undertook to look for improvement. Problems continue to be faced. Urgent improvements needed
EASA problems related to FAA STCs 7)Complicated and time consuming EASA processes for EU Airlines importing used airplanes with multiple FAA approved non-TC holder STCs Unless it can be demonstrated that the STCs have been approved by any of the EU NAAs prior to cut in of the EASA system (Sept 28, 2003), EASA review and approval of the STCs is required. Typically this may take 3-5 months, occasionally even longer. Some holders of these US STCs are no longer conducting business. Thus, there are no legal applicants who can process STC approval applications to EASA! A general EASA acceptance of all FAA STCs approved and installed on airplanes prior to Sept 28, 2003 seems a pragmatic solution.
Fees & Charges 8) EASA fees & charges payment conditions result in further delays for administrative reasons and may result of aircraft grounding Some improvement noted but need consistency for all applicants!
Other issues: EASA AD Process Subscription service on AD notification: EASA notification system (by e-mail) is needed on all changes to the EASA website (including and specifically on AD items). When and at which cost? EASA AD Process: Lack of procedures on who to be contacted with regard to technical content of EASA ADs. Even the Project Certification Manager/EASA AD Focal Point does not know necessarily to whom he should address a question related to the technical content of an Airworthiness Directive. Clarification/procedures needed