2. Rulemaking update Neil Williams Policy Lead - Airworthiness
8th December 2016

3. Continuing Airworthiness Rules recently adopted by the Commission
Rulemaking Update
Continuing Airworthiness
Rules recently adopted by the Commission
John Holding: Principal Airworthiness
Chris Gabay: Principal Airworthiness
Garry Lathey: Q-Pulse Subject Matter Expert
Matt Bennett: Web Analyst

4. Rules recently adopted
Regulation (EU) 1536/2015
Replaces the term “large aircraft” by “complex motor-powered aircraft” (see next slide)
Introduces requirements for error capturing methods in the case of critical tasks.
Applicable since 25 August 2016.

5. Rules recently adopted
Impact on some aircraft:
Twin-turboprop aeroplanes below 5700 kg MTOM (and a small number of other aeroplanes) were not “large aircraft” but they are “complex motor-powered aircraft”. (MORE STRINGENT REQUIREMENTS APPLY)
Twin-engine helicopters below 3175 Kg MTOM were “large aircraft” but they are not “complex motor-powered aircraft”. (LESS STRINGENT REQUIREMENTS APPLY)

6. Rules recently adopted
Consequences for the Twin-turboprop aeroplanes below 5700 Kg MTOM:
Obligation to:
Contract a CAMO
Perform maintenance in a Part-145 organisation.
Release base maintenance with Part-66 Cat. C certifying staff.
Measures to mitigate the impact:
Member States were notified by EASA that they can grant Article 14
exemptions allowing twin turboprop aeroplanes below 5700 Kg MTOM to
apply the rules of non-complex motor-powered aircraft.
These exemptions should not go beyond 01 January 2020.
In parallel, the Commission will adopt a new regulation exempting those
aircraft from the requirement to contract a CAMO and a Part-145
Maintenance organisation until 01 January 2020 (since it is expected
that the new Basic Regulation currently being discussed will change the
concept of complex motor-powered aircraft).

7. Operational Suitability Data (OSD)
The principle behind Operational Suitability Data (OSD), is that aircraft OEMs are required to establish certain data that is considered important for the safe operation of the aircraft type. This data will be approved by the Agency under the type certificate procedure and will then used by operators and training organisations.
With respect to a Part 147 training organisation, the OSD outlines the minimum content for the development of a course Training Needs Analysis(TNA). The OSD actually identifies the content that must be included in the training, it can also stipulate how this training is delivered.
If the new design has no new or novel/unique features it may be that there are no OSD requirements.
At the moment there is only one aircraft type, the Dassault Falcon 2000EX Easy,  for which such elements were developed (as a “trial” phase) and approved by the Agency.
This is applicable to aircraft for which type certification was applied for after January 2015.

8. Rules pending adoption by the Commission

9. Pending adoption by the Commission (already voted)
In the EASA Committee of 17/18 February 2016, the Member States unanimously agreed on the following:
New B2L and L Part-66 licences (ref. Opinion 05/2015).
Limitation of the Part-147 privileges related to stand-alone basic Examinations (ref. Opinion 07/2015).
The applicability calendar will be the following:
B2L licence: 6 months after adoption.
L-licence: 01 October 2018 (obligation for NAAs to start issuing them) and 01 October 2019 (obligation for all certifying staff to have it).
Limitation of the Part-147 privileges related to stand-alone basic examinations: Immediate effect after adoption.

10. “Review of Part-66”

11. RMT.0544 “Review of Part-147”& RMT.0255
2 surveys launched on 2 December2016 and are open for contributions until 28
The scope of the task will depend on the feedback received (to be defined in the Terms of Reference). ToR planned 2017.
Includes (among other issues):
Actions to supplement the provisions introduced as a result of the urgent Opinion 07/2015 related to Part-147 Basic Examinations.
Type rating requirements for legacy aircraft.
Simplification of the Part-66 licensing system for non-complex aircraft.
The need for C licenced personnel
Will include the participation of expert groups.

12. EASA --- STOP PRESS 02/12/2016

13. Part 66 and Part 147 Survey History:
The Commission Regulations (EC) No 2024/ were adopted in November 2003 in order to establish the requirements for P66 and P147.
Since this time the Part 66 requirements have been continuously updated to build a comprehensive system; whereas the Part 147 requirements have, more or less remained unchanged. (13 years!)
Article 24.3 of Regulation (EC) 216/20084 requires the Agency to periodically monitor the application of the rules and assess the impact of the implementation of the rules.
With this objective the Agency is launching an evaluation on how effective the implementation of Part 66 and Part 147 has been; identifying problems , recommendations (solutions) fitting the maintenance licensing needs in a fast- evolving world.

14. Scope of the Survey
In order to evaluate the future needs of Maintenance licensing and Maintenance Training Organisations, EASA is launching a survey addressed to the European competent authority (EASA Member States and any :
Part 147 organisation or associations representing the Part 147 organisations;
Part 145 organisation or associations representing the Part 145 organisations;
Private individuals
Aircraft Maintenance licence ( AML) holders
Associations of AML holders and other stake holders .

15. Scope of the Survey
The survey is intended to collect , among other things , the following issues :
interpretation
implementation
effectiveness
improvements
standardisation issues
level playing fields
oversight
omissions or inconsistencies
undue administration burdens
needs for safety promotion or any other Agency actions
structure of the rules

16. Scope of the Survey The survey is in three parts:
Part 1 : General information about the respondent
Part 2 Specific information regarding Part 66 and Part 147
Part 3 Any other comments .
Important Note :
Your inputs should not be limited to the description of the issues they should also include suggestions on how to address the issues raised .

17. Questions?