Presentation on theme: "The Future of Maintenance in General Aviation"— Presentation transcript:
1The Future of Maintenance in General Aviation The perspective from the European sailplane manufacturersbyWerner Scholz, Spokesman of theEuropean Sailplane Manufacturers
2Contents: Introduction Basic comments regarding Part M Comparison of Part M with old statusSummary and assessment of Part M
3Introduction „Who are we - whom do we represent?“ The European sailplane manufacturers are represented by two associations:Verband deutscher Segelflugzeughersteller, GermanyEuropean Glider Manufacturers and Suppliers association, East EuropeTogether they include 13 companies (representing more than 1000 employees) in Austria, Czech Republic, Germany, Lithuania, Slovenia.Further members of the sailplane “industry”:other European sailplane manufacturersmanufacturers of glider-typical avionicsmanufacturers of trailers and equipmentglider maintenance facilities
4Introduction „Who are we - whom do we represent?“ In total the European sailplane industry represents:more than 20 sailplane manufacturersmore than 30 manufacturers of gliding equipmentmore than 90% of world-wide sailplane production (over 400 new aircraft per year)more than 3000 employees at the manufacturers and associated companies
5Introduction „Who are we - whom do we represent?“ The European sailplane maintenance industry sector represents:much more than 100 sailplane maintenance shops (perhaps even more than no central association existent)certainly hundreds of employeesseveral hundred approved inspectors according to national rules conducting airworthiness reviews on a honorary basis (in their free time) within the national gliding federationsThe European gliding community in Europe includes:more than registered sailplanesmore than pilots flying gliders and powered sailplanes
6Introduction „Who are we - whom do we represent?“ The European sailplane manufacturers do not claim that they can represent all stakeholders of the gliding community in Europe.BUT:the manufacturers know “their market” (= the operators & the maintenance sector) very well since more than 50 yearsthey know how continuing airworthiness is been handled until now as some work also as maintenance organisationsthey know as TC holders that there is no general safety problem due to a lack of proper maintenancethey know that more complicated regulations will lead towards loss of much more pilots due to frustration and increased coststhey already experience the effects of a slowly shrinking “gliding scene”
7Basic comments regarding Part M „Motivation of Part M“ Obviously the basic idea of Part M is to have a common regulation for continuing airworthiness within all EASA member states.The claimed benefits for stakeholders should be:standardised rules valid in all member statescommon safety standards regarding maintenance procedurescommon minimum standards regarding maintenance personnelavoidance of duplication at national / European levelfacilitation of a “free movement of goods and services” within Europe (= to alleviate the selling of aircraft between member states and to ease cross-border maintenance of aircraft)promotion of cost-efficiency in the regulatory processSo how does this all fit to the gliding community? - See later.....
8Basic comments regarding Part M „Part M is a very complex regulation“ Part M is by far too complex and difficult to read and understand.This regulation will be a “must read” at least for all maintenance organisations & manufacturers & inspectors (= many persons not having a legal / academic background).format with many cross-references within Part M and towards other regulationslanguage with many abbreviationspartition into regulation and AMC materialThis problem is even made worse as the official translations offered by the authorities are sometimes wrong and/or not directly fitting to the English original wording.
9Basic comments regarding Part M „Part M will not allow simple continuation“ EASA officials have verified that Part M is introducednot to cure a pressing safety deficit but to standardise maintenance in Europewith the idea that basically most national maintenance procedures within light aviation should be possible to be continued.Nevertheless the competent authorities (= the NAA responsible now to implement Part M in the member states) have already started to change rules regarding continuing airworthiness to implement Part M. This is definitively not a continuation of well established maintenance procedures!
10Comparison of Part M with old status „Basis of the comparison“ Based on the experience in the member states of more than 50 years of sailplane maintenance, a comparison between the “old status quo” and the new Part M procedures has been made.Data for this comparison has been accumulated bythe European sailplane manufacturersthe European Gliding Union (EGU) representing the gliding sectors of the national sporting federationsby a large number of European maintenance organisations (traditional repair shops and also federations / clubs conducting glider maintenance)This comparison is primary valid for gliding but organisation within light aviation (e.g. ballooning, small aeroplanes) have already signalled similar conclusions!
11Comparison of Part M with old status „Regular physical survey / issuance of ARC“ The fundamental cornerstone of glider maintenance until now:A physical survey of the aircraft on a regular basis directly resulting into issuance of the ARC for continuing flight operations until the next survey (or a maintenance/repair event).This might be likened to a basic “maintenance philosophy” similar to the operation of a private owned car:maintenance is been conducted on a “on need basis”the showing of “streetworthiness” is only required in certain intervals and/or after special maintenance/repair eventsoperations of the car allowed immediately after completion of the physical survey without further “registration/certification” by authorities
12Comparison of Part M with old status „Regular physical survey / issuance of ARC“ Within Part M this will be in the future:A physical survey of the aircraft on a regular basis resulting into issuance of the ARC either by the competent authority or a CAMO+ and introduction of a certificate of release to service after every maintenance event.This certainly stems from the “maintenance philosophy” of the maintenance and operation of commercial air transport airplanes:maintenance is been conducted on a “procedural basis”the aircraft “is owned by” the technical/maintenance organisation and can only operated after a release to servicemaintenance operations only possible with consent of the authorities based on regulated procedures and approved personnel
13Comparison of Part M with old status „Regular physical survey / issuance of ARC“ The introduction of the additional step for the issuance of the ARC by the competent authority / CAMO+ and the obligatory release to service certificate will:increase the number of administrative “steps” until the glider will be back in servicethis translates into time delays (remember: more than gliders!)this also means increased costs for the ownersthis does nothing to improve the actual physical surveythis does therefore also not increase safety
14Comparison of Part M with old status „Airworthiness survey & introduction of maintenance programs“ Until now the check of the technical documentation for each particular glider was made parallel to the physical survey and typically included:review of the logbook of the glider / engine / propellerreview of the findings report for this glider before start of the maintenancecheck against procedures described in the maintenance manual issued by the manufacturercheck against existing service bulletins / airworthiness directivesentry of all findings during the physical review against a check list provided by the maintenance manual or (if not provided) against a check list suitable for gliders / motor glidersAll was done together with the inspector during the physical survey.
15Comparison of Part M with old status „Airworthiness survey & introduction of maintenance programs“ Now the check of the technical documentation will be THE central point for the airworthiness review of each particular glider and is not necessarily coupled to the physical survey.Additionally now every individual aircraft needs to have an maintenance program with an approval of the competent authority.These maintenance programs will in most cases not give more information than the already existing information supplied by the manufacturer as (contrary to commercial air transport) the maintenance organisations do typically not develop own procedures. Even this “standard maintenance program” now will need approval!Issuance of the ARC will be done typically by persons not seeing the actual aircraft but based on the accompanying paperwork!
16Comparison of Part M with old status „Airworthiness survey & introduction of maintenance programs“ This new system can only work if ALL participating partnersare familiar with the new administrative procedures (this implies the need for training thousands of persons)have suitable background (excluding the experienced “worker-type” maintenance people)have the additional time for the new additional administrative steps (making the work for the honorary / free-time inspectors even more difficult as their time per glider inspection is limited)Therefore the following results seem to be (again)time delayscost increaseloss of maintenance workforcewith resulting degradation of safety....
17Comparison of Part M with old status „Maintenance personnel - certifying staff“ Until now the maintenance personnel in gliding consisted of:the owners/operators conducting the lion share of typical regular maintenance tasks (often referred to as “winter overhaul”)the inspectors within the gliding federations conducting the regular airworthiness reviews on a honorary basis (in their free time) or at least on a “at cost price”the personnel within maintenance organisations and/or the manufacturers with detailed knowledge for special systems and/or repairs and major maintenance tasksTypically some form of approval was required for inspectors - this was granted under supervision / directly from the NAA.BUT: Besides the minimum technical expertise required the maintenance personnel was not excessively regulated.
18Comparison of Part M with old status „Maintenance personnel - certifying staff“ Regarding maintenance personnel and inspectors (now identified as certifying staff) the situation will be more complicated after introduction of Part M:regarding certifying staff Part M refers to Part 66Part 66 defines categories of qualifications for aeroplanes and helicopters and components (excluding gliders)for all other aircraft (e.g. sailplanes) Part 66 refers to relevant member states regulations (resulting into a return to existing systems regarding maintenance personnel/certifying staffThis raises two questions:why this complicated introduction if nothing changes?what happens if some NAA will simply delete their national regulation in favour of Part M / Part 66 thereby “forgetting” gliders?
19Comparison of Part M with old status „Maintenance organisations approvals“ Until now a typical maintenance organisation typically had to show:compliance to national rules written in the national language and based on the particular local experiencesome form of certification for the organisation audited by the local authoritiessome minimum requirements regarding the qualification of the workerssome approved qualification for the inspectors (issued directly or under supervision by the NAA)Normally this meant:one single approval for the maintenance organisationindividual approvals for the inspectors
20Comparison of Part M with old status „Maintenance organisations approvals“ Now a typical maintenance organisation needs:compliance to EASA rules written in a complicated language (sometimes not improved by the official translation) plus additional national rules fitting more or less to Part Mone certification for the maintenance tasks (Subpart F)one certification for the inspections tasks (Subpart G) - now referred to as Continuing Airworthiness Management Organisation (CAMO)compliance - if applicable - with Part 66 / Part 145 if the tasks performed fall outside the pure glider world / outside of Part Mstill a regular auditing by the competent authority but now based on a much more complicated regulation systemintroduction of quality assurance systems into their organisations as the new organisations approvals require
21Comparison of Part M with old status „Maintenance organisations approvals“ This already means:small maintenance organisations (read: repair shops) do not know if approval under Subpart F and G will be feasible for themsome existing maintenance workforce will be lost as they cannot afford this step towards the new approvalsair-sport federations acting as maintenance organisations face new and unfamiliar approval processes (mainly with managers working in their free time and/or under quite limited working time constrains)manufacturers offering maintenance tasks beside their production process face additional approval processes to continue these maintenance tasksthe owner will finally pay for all this application processes without any safety benefit for his glider and his personal flying....
22Summary and assessment of Part M „Motivation of Part M - revisited“ Obviously the basic idea of Part M is to have a common regulation for continuing airworthiness within all EASA member states.The claimed benefits for stakeholders should be:standardised rules valid in all member statescommon safety standards regarding maintenance procedurescommon minimum standards regarding maintenance personnelavoidance of duplication at national / European levelEspecially for gliders the rules about maintenance / certifying staff will still be based on national rules.This does not necessarily needs to be a disadvantage as those rules already work very good.BUT the additionally regulations / administrative procedures as required by Part M will make maintenance in gliders much more complicated and expensive .... without discernible safety benefit!
23Summary and assessment of Part M „ Motivation of Part M - revisited“ Obviously the basic idea of Part M is to have a common regulation for continuing airworthiness within all EASA member states.The claimed benefits for stakeholders should be:facilitation of a “free movement of goods and services” within Europe (= to alleviate the selling of aircraft between member states and to ease cross-border maintenance of aircraft)promotion of cost-efficiency in the regulatory processThe alleviation regarding selling a glider in Europe will only work if the NAA will be accepting the rules by the other NAA - which was historically not the case until now - so why should this function now?Therefore cross-border maintenance still will be difficult.And within the gliding community no one has been heard to foresee ANY cost benefit due to the introduction of Part M
24Summary and assessment of Part M „ Where are we standing now?“ The concept “one regulation that fits all sectors of aviation” is not working regarding maintenance of gliders.Either Part M needs some fundamental changes or extensive changes are needed in the AMC material of Part M / Part 66.The basic idea of rulemaking task MDM.032 has been claimed to be “simple regulations for light aviation” - this is of course linked to Part M and directly influences future of maintenance for GA. (But ONLY for non-commercial activities!!)The tasks M.005 (pilot-owner maintenance) and M.017 (review of NPA 7/2005 after Part M regulatory impact assessment) must result into important changes very fast (in order to stay within the time scale as EU 2042/2003 gives as final introduction date).
25Summary and assessment of Part M „ Where to go?“ Today there is no one claiming a basic safety problem regarding maintenance / continuing airworthiness for gliders (or for General Aviation).Therefore: only change when there is a need for change!If a common regulation is really envisaged then a simpler regulation is needed than Part M (and Part 66) and then it really must be standardised in all member states.If the Agency / EU commission / EU parliament feels national regulation to be sufficient then make a “mini Part M” only approving existing national regulations (as existing now) as valid in all member states.Therefore: a clear decision between European / national rules!And: Extend the time schedule to avoid “quick fixes” and chaos!