European Aviation Safety Agency Slide show for rulemaking task M.017

European Aviation Safety Agency

Slide show for rulemaking task M.017

Last update: 29 November 2006


M.017: Comment review of NPA 7/2005 and implementation of further changes to Part-M, AMC/GM amendment following regulatory impact assessment Attendants:

Pierre Bernard, DGAC France Guiseppe Guido Recchia, ENACRobert Schuegraf, EAS GEHoward Torode, EAS UK Chair of the groupHelge Hald, EASGunnar Ljungberg, SCAA Sweden,Juan Anton, EASAEric Sivel, EASA Frederic Knecht EASA Secretary of the group

Drafting task M.017



The purpose of M.017 working group is: to make the responses to the Comment made by NAA, individuals and general aviation bodies after the regulatory impact assessment on Part-M and the issuance of NPA 7/2005;issue additional NPAs or extend the NPA 7/2005 to additional changes with changes to AMC/GM material as the review of the comments to NPA 07/2005 involves additional issues to be addressed.

Drafting task M.017



6th meeting held on November 27th and 28th On the 6th meeting: almost all comments were responded on a total of 455, addressing to some changes in the rules.

Changes in the rule identified at this stage (not final text) :

M.A.302 maintenance programmes: the current wording of M.A. 302 and the Appendix I to AMC M.A. 302 has created confusion especially when small aircraft are involved and has been reviewed , the changes intend to clarify and/or modify the purpose of a maintenance programme, its content, its approval, what are maintenance data to be used, when a reliability programme is need or not;

Completion of M.A.401 “maintenance data” and M.A.502 “Component maintenance” to include guidance material published by the agency ,

M.A.606 Personnel requirement – modification of the phrasing of the experience requirement (separately considered in 66-008)

Drafting task M.017



Changes in the rule identified at this stage

(cont’d): M.A.711 M.A.901 and M.B.901 Due to some

confusion created by the additional privilege of a CAMO which allows in a non controlled environment to issue a “recommendation” for the issuance of an ARC by the authority as per M.A.711(b), the wording has been modified to remove such privilege. In such case the ARC would be issued by the authority. The only issuance of a “recommendation” by a CAMO would be reserved for the import of an aircraft as required by Part-21;

Drafting task M.017



Changes in the rule identified at this stage (cont’d):

The definition of “controlled environment” has been modified accordingly to read: “aircraft managed by an M.A. Subpart G approved CAMO and maintained by approved maintenance organisations ”

AMC M.1. is modified to enlarge the definition of a competent authority: “a ministry, an aviation national authority, or any aviation body designated by the Member State”

Drafting task M.017




In M.A.712 the possibility to use an organisational review instead of a quality system has been extended to read: “In the case of a small M.A. subpart G organisation, the quality system can be replaced by performing organisational reviews on a regular basis except when the organisation issues airworthiness review certificates for aircraft above 2730 Kg MTOW“

Drafting task M.017




In M.A.801, to avoid confusion created by the requirement for “holding a valid ICAO aircraft maintenance licence”, in the unforseen case where an aircraft is grounded at a location … the one-off certification authorisation could be granted to any person not less than 3 years maintenance experience and holding the rated proper qualifications to maintain the aircraft according to subpart D and release it.

Drafting task M.017



Changes in the AMCs identified at this stage (cont’d):

M.A.302 to support the change made in the rule

M.A.304 to cover the adoption of AC 43-13 as an interim measure until a European standard of repairs and modifications are issued.

M.A.401 to support the change made in the rule

M.A.502 (same reason)M.A.607 and 610 (same reason)

Drafting task M.017



Changes in the AMC identified at this stage (cont’d):

M.A.707: to clarify the requirements for the Airworthiness Review Staff,

M.A.708, 711 and 712 (to support the change made in the rule)

M.A.801 and 901 (same reason and to clarify the wording “qualifications” and “regulations” mentioned)

M.B.901 and 902 (same reason)M.1 (same reason)

Drafting task M.017



M.017: Comment review of NPA 7/2005 and implementation of further

changes to Part-M, AMC/GM amendment following RIA

The group will have to consider additional actions which would be decided by the group MDM 032 when they are related to airworthiness and maintenance;

among those actions are already decided:to set a sub-group to take on board a

drafting of Part-66 for “light aircraft”

Drafting task M.017



M.017: Comment review of NPA 7/2005 and implementation of further changes to Part-M, AMC/GM amendment following RIA

Next actions: By beginning of December submit the Terms of

Reference for a sub-group to work on the light-Part-66.

by end of 2006 submit the CRD with comments resulting from NPA 7/2005 and start working on changes to the AMCs,

by January 2007 take into account the actions requested by MDM 032 resulting from the A-NPA 14-2006

by March 2007 submit a new NPA with a draft Opinion and a draft Decision for changes in Parts and changes in AMCs,

in January 2007 start composition of new sub-group and start working on a light Part-66.

Publish an NPA for Part-66 by mid 2007.

Drafting task M.017

Documents

European Aviation Safety Agency Slide show for rulemaking task M.017