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GA Road Map: Working towards

GA Roadmap update

GA Roadshow in Switzerland

Boudewijn DEUSS Senior Regulations Officer ‐ Initial Airworthiness & GA Roadmap Manager

26 October 2017

Motivation and problem

26 October 2017 2GA Roadmap Project

Necessary to adopt a specific new approach for GA in order to assure a sustainable development of the sector in Europe

Avert a dramatic loss of activity as a result of complex and disproportionate rules

The cornerstones of the GA Roadmap

Founded on: 1. Agreed risk hierarchy2. Agreed strategic principles3. Cooperation of all stakeholders4. Commitment at all levels

26 October 2017 GA Roadmap Project 3

Risk hierarchy

4GA Roadmap Project

Active application of risk hierarchy

Better, more effective rules

More protection

More freedom

26 October 2017

GA Roadmap Project

Strategic direction ‐ six principles

P1: One size does not fit all (reduce cliff‐effect)

P2: Philosophy of minimum necessary rules

P3: Adopt a risk‐based approach (risk‐hierarchy)

P4: Protect “grandfather rights”

P5: Apply EU “Smart Regulation Principles”

P6: Make best use of available resources/expertise

526 October 201726 October 2017

Cooperation of stakeholders

Success when all partners

work togetherMember States GA users/industry

GA Roadmap Project 626 October 2017

Commitment at all levels

Steering committee

Task Force

EASA project team & GA Focal Points

NAA/EC group Stakeholders group


GA Roadmap

Simpler, lighter and better rules to stimulate GARegulate only when needed and use other means when possibleHand responsibilities back to people/organisations that are able to take that responsibilityAvoid automatic use of “CAT logic” to GA


Simpler, lighter, better rules for GA

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o Changes to the Basic Regulation: 2018: On‐going

o Part M Light: Opinion published in May 2016

o Facilitate access to IFR (holistic approach across domains): NPA published in November 2016

o Aircraft changes and repairs made easy (CS‐STAN): Amendment 2 published in April 2017

o More options for pilot training outside ATO (DTO): NPA published in December 2016

o Air Operations and licence Balloon Rule Book: Opinion published in January 2016

o Air Operations and licence Gliders Rule Book: Rulemaking task on‐going

o LAPL Medical Certificate: Done (Needs Safety Promotion)

o Modular LAPL: Opinion 08/2017o Simpler Certification (Part 21

proportionality – manufacturer approval): AMC planned for Q/4 2017

o Reorganisation of CS‐23 using Industry standards: April 2017

We are delivering in accordance with our commitmentsGA Roadmap Project26 October 2017

Simpler, lighter, better rules for GA

10

o Changes to the Basic Regulation: 2018: On‐going*

o Part M Light: Opinion published in May 2016*

o Facilitate access to IFR (holistic approach across domains): NPA published in November 2016*

o Aircraft changes and repairs made easy (CS‐STAN): Amendment 2 published in April 2017

o More options for pilot training outside ATO (DTO): Opinion published in September 2016

o Air Operations and licence Balloon Rule Book: Opinion published in January 2016 – voted on 28 June 2017*

o Air Operations and licence Gliders Rule Book: Rulemaking task on‐going

o LAPL Medical Certificate: Done (Needs Safety Promotion)

o Modular LAPL: Opinion 08/2017o Simpler Certification (Part 21

proportionality – manufacturer approval): AMC planned for Q4/2017

o Reorganisation of CS‐23 using Industry standards: April 2017

GA Roadmap Project

*Commission’s process in progress26 October 2017

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Changes to the Basic Regulation

BR change status

Council, Parliament and Commission (Trilogue) are discussing their proposals with the aim to find a compromiseIn general the attitude towards GA is positive. But there are still some open items ‐ one of them is the scope of Annex I of the New BRAdoption of the new BR is expected by end of 2017 and enter into force in 2018


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Simpler CertificationPart 21 Proportionality

Part 21 Proportionality

Objective:Introduce flexibility and simplification in Part‐21 certification for small organisations designing simple products (Gliders manufacturers, LSA, small CS23…)Practically combine different approvals (DOA/POA/MOA) for these small companiesMake sure it can be adjusted since no company in GA is alike


Challenges to the initiative

The current system; rules & culture are suitable for large organisations and aircraftE.g Oversight aims at compliance to the rules (checking procedures) instead of risk/safety objectives

Combining POA, DOA and MOA means putting NAA/EASA responsibilities and different rules togetherThis is a shift in culture, processes and cooperation between all stakeholders


What is going on?

A Task Force is working on:• (Phase 1) Development of documents (Draft AMC) that show how the current Part‐21 can be made workable for smaller companies (2017 Q3)

• (Phase 1A) Test this in a pilot project (2017 Q3/Q4)• (Phase 2) Proposing a fundamentally new Part‐21L consisting of objective rules supported by flexibility in the AMC (Start 2017 Q4)*

* Depending on the Basic Regulation changes and progress


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Reorganisation of CS‐23

using Industry standards

Reorganisation of CS‐23/Part 23

EASA and FAA have worked on a similar change to CS‐23/Part 23 in a rulemaking cooperation pilot project

objective based rulesSupported by consensus standards providing technical detailsaiming to reach harmonisation

Result so far:CS‐23 amdt 5 published and replacing current CS‐23/CS‐VLA67 objective requirements replacing the 377 detailed requirementsNew AMC to CS‐23 amendment 5 coming soonNot yet fully harmonised, but work is ongoing


The CS‐23/CS‐VLA New Concept

CS‐23 Amdt 5 “static”AMC Regular updates with innovation

GA Roadmap Project 19

CS‐23 Amdt 4

CS‐VLA Amdt 1

CS‐23 Amdt 5Objective rules &Safety level definitions

AMCRef to CS‐23 Amdt 4*Ref to CS‐VLA Amdt 1*Ref to ASTM F44 Standards

26 October 2017

What does it mean for certification

A stable CS‐23 certification basis with amendments in AMC level Harmonised requirementsConsensus standards reviewed and accepted as AMC by EASA and FAA (timing and content!)Existing CS‐23 and CS‐VLA will be maintained as AMC to the reorganised CS‐23The process and training on the use of the reorganised Part‐23/CS‐23 are being developed by the FAA and will be reviewed for mutual useEASA is working on example test‐cases applying the new CS‐23 (based on NPA) and draft consensus standards


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Aircraft changes and repairs made easy (CS‐STAN)

CS‐STAN GOALS

support GA in Europe promote GA safety

By:

allowing certain modifications and repair, if they

are designed and performed in accordance with

CS‐STAN provisions.


CS‐STAN Roadmap

GA Roadmap Project 23

July 2015, CS‐STAN issue 1

Mar 2017, CS‐STAN issue 2

Regular updating iawToR RMT.0690 (*)

(*) stakeholders can submit proposals for new or existing SC/SR by means of the following reporting system available @ EASA webportal:https://www.easa.europa.eu/contact‐us#CS‐stan

26 October 2017

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Validation of Basic STC(EU/US‐bilateral)

Administrative process for validation of FAA STCs classified as Basic

Validation is a problem when the US (basic) STC holder does not apply for validationEASA introduced an administrative process for single serial number aircraft, applied for by the CAMO or the aircraft owner/operatorUsing the options of the Technical Implementation Procedures (TIP) between EASA and FAA (3.5.3.2)The scope is limited to second hand aircraft and installed engines, if applicable, in the following categories:

> 2 000 kg ≤ 5 700 kg MTOWELA1/ELA2

Application form can be found on the EASA website


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New Part‐ML (Light Part‐M) and Part‐CAO

•27

13 April 2016: Opinion 05/2016 was published.Proposes a Light Part-M (Part-ML) and a new “Combined Airworthiness Organisation” (Part-CAO)

Currently under Comitology process

Opinion 05/2016

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Applicable to private and commercial operations of: aeroplanes up to 2730 Kg, other ELA2 aircraft and helicopters up to 4 occupants and 1200 Kg.

if they are not complex motor-powered aircraft.

Not applicable to Commercial Air Transport (in the sense of licensed air carriers per Regulation (EC)1008/2008).

NOTE: This means that Part-ML covers all sailplanes and balloons, even if the carry passengers (they are excluded from (EC) 1008/2008)

Light Part-M (Part-ML)

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Declaration/approval of Maintenance Programme (AMP): Not possible to have the AMP approved by the NAA.

For aircraft managed by a CAMO or CAO (mandatory for commercial operations): The CAMO or CAO approves the AMP. Justifications to deviations from manufacturer

recommendations must be provided to the owner.

For aircraft not managed by a CAMO or CAO (only possible for non-commercial operations): The AMP is declared by the owner. No justification for deviations needed.

Light Part-M (Part-ML)

•30

“Combined Organisation Approval” (Part-CAO)

•31

Proposes a new “Combined AirworthinessOrganisation” (Part-CAO) for General Aviation:

Applicable to non-complex non-CAT aircraft (some aircraft will follow Part-M and others Part-ML)

Combines the privileges of a Subpart-F maintenance organisation and a CAMO.

No SMS: They will continue with the current Quality System (or organisational reviews if the organisation is small).

Introduces simplified requirements.

Part-CAO

•32

Simplifications introduced: Combined privileges for maintenance, continuing

airworthiness management, airworthiness reviews, permit to fly. Single exposition for all activities. Simplified approval certificate (no aircraft types, just

categories) More privileges for the organisation to manage changes: Approval by the NAA only required for:

aeroplanes above 2730Kg, helicopters of more than 1200 Kg or 4 occupants and workshop maintenance of complete turbine engines.

Other aircraft and components can be introduced inthe scope of work by the organisation (with approvedprocedure)

Changes to facilities, tooling, equipment, etc, can bemanaged by the organisation (with approved procedure)

Part-CAO

•33

New structure of the Regulation

•34

New structure

PROPOSED RULE STRUCTURE Non‐CAT CATNon‐CMPA CMPA Non‐CMPA CMPA

Part‐M Applicable only to non‐Light aircraft (Light aircraft must follow

Part‐ML)

Applicable

Subpart F May still be used for 2 years after new Regulation. It

disappears later.

N/A N/A N/A

Subpart G (CAMO) Disappears (transferred to Part‐CAMO)

Part‐145 ApplicablePart‐66 ApplicablePart‐147 ApplicablePart‐T (Third country aircraft dry‐leased by EU AOC holders)

N/A N/A Applicable Applicable

Part‐ML Applicable to Light aircraft

N/A N/A N/A

Part‐CAMO (with SMS) Applicable

Part‐CAO (without SMS) Applicable N/A N/A N/A

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Future steps

GA Roadmap

Complete rulemaking tasks in 2018Focus on implementation and cultural aspectsFocus on safety promotion


Summary/conclusions

The GA Roadmap project is founded on agreed principles and has broad supportTopics from various area, certification, maintenance, operation, licensing etc. are addressedThe work is done in close cooperation with all stakeholders. EC, Industry, Competent Authorities (NAA) and EASAOpen communication supports this project that is aiming to support a healthy GA environment


Many thanks for your attention!

To find out more!

Simply go and visit the EASA website:

GA Road Map: http://easa.europa.eu/ga


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