EASA Regulation Amendment of Implementing Rule 2042/2003

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1 EASA Regulation Amendment of Implementing Rule 2042/2003 Dated : 13/01/2012 Version : Version 1 Written by : Approved by : Antoine BLIN & Christophe CUBIERES Consultants Jean-Pierre BATIGNE Technical Director 1 TOB 22/12/AB

2 Table of Contents 1 FUTURE ALIGNMENT WITH THE EVOLUTION OF EASA REGULATIONS Alignment with the BR 216/ Alignment with the new EASA Regulation structure 8 2 ANALYSIS OF THE LAST AMENDMENT OF 2042/ Introduction Privileges of B1 and B2 maintenance licences Licence B Type and group ratings Type training Impact of the last amendment of 2042/2003 on BV activities 15 2 TOB 22/12/AB

3 Glossary ADR AMC ANS AOC AR ATCO ATFM ATM ATO AUR BR CAT CC CMPA COM CRD FC GEN GM HoT IR MED MPSC MS NCC N-CMPA NCO OPS OR OSD SERA SPA SPO TCO TR TRT Aerodromes Acceptable Means of Compliance Air Navigation Service Provider Air Operator Certificate Authority Requirement Licensing and medical certification of air traffic controllers Air Traffic Flow Management Air Traffic Management Approved Training Organisations Common airspace usage requirements and operating procedures Basic Regulation Commercial Air Transport Cabin Crew Complex Motor-Powered Aircraft Commercial other than CAT Comment Response Document Flight Crew General Guidance Material Hold-Over Time Implementing Rule Medical Maximum Passenger Seating Configuration Member States Non-commercial with CMPA Non-Complex Motor-Powered Aircraft Non commercial other than CMPA Operations Organisation Requirement Operational Suitability Data Standardised European Rules of the Air Specific Approvals (ETOPS, PBN etc ) Specialised Operations (aerial work) Third Country Operators Type Rating Type Rating Training 3 TOB 22/12/AB

4 1 FUTURE ALIGNMENT WITH THE EVOLUTION OF EASA REGULATIONS Note : The part provides information about the future evolution of the 2042/2003 and especially the Part- M. At this stage, these future evolutions have not been adopted and therefore the aim of this part is just to provide information about the direction of the future evolution, in order to anticipate. 1.1 Alignment with the BR 216/2008 Why is alignment needed? According to the BR regulation, the requirements regarding continuing airworthiness and their applicability should be based on the following classifications and definitions: Commercial Operation means any operation of an aircraft, in return for remuneration or other valuable consideration, which is available to the public or, when not made available to the public, which is performed under a contract between an operator and a customer, where the latter has no control over the operator; Commercial Air Transport means the transport of passengers, cargo or mail for remuneration or hire. Complex-Motor-Powered Aircraft (CMPA) means: (i) An aeroplane o With a maximum certificated take-off mass exceeding 5,700kg or; o Certificated for a maximum passenger seating configuration of more than nineteen, or o Certificated for operation with a minimum crew of at least two pilots, or o Equipped with (a) turbojet engine (s) or more than one turboprop engine, (ii) A helicopter o Certificated with a maximum certificated take-off mass exceeding 3,175kg or; o For a maximum passenger seating configuration of more than nine or o Certificated for operation with a minimum crew of at least 2 pilots; or (iii) A tilt rotor aircraft; However, the current requirements are based on the following classifications and definitions: large aircraft, which is defined in Regulation (EC) No 2042/2003 article 2(g) as : an aircraft, classified as an aeroplane with a maximum take-off mass of more than 5700kg, or a multiengined helicopter. In fact, according to the current requirements, continuing airworthiness of large aircraft shall be managed by a CAMO. (M.A.201 (f)) and maintenance of large aircraft shall be performed by a Part-145 approved organisation. (M.A.201(g)) Currently regulation (EC) 2042/2003 does not contain a definition of Commercial Air Transport. However article 1(3) states that the provisions of the Regulation related to CAT are applicable to licensed air carriers. According to the current 4 TOB 22/12/AB

5 2042/2003 will be amended to incorporate the concepts of: CMPA and, Commercial Operations and Commercial Air Transport. What will be the differences? Difference between CMPA and Large classifications: Replacing large aircraft by CMPA in Part-M results in: Continuing airworthiness of CMPA shall be managed by a CAMO. Maintenance of CMPA shall be performed by a Part-145 organisation. Those CMPA which currently do not fall into the category of large aircraft will be required to contract a CAMO and a Part-145 for those types of operations where it is not already required. For aeroplanes, the relation between large and CMPA can be depicted as follow: Complex Motor Powered Aircraft/Aeroplane Large Aircraft/Aeroplanes Ex: Eclipse EA500 MTOW: 2722 kg (< 5700 Kg) OTHER THAN LARGE AIRCRAFT Engines : 2 PWC PW610 CMPA Conversely, multi-engined helicopters with MTOM <3175 kg, which are currently considered large aircraft, will not be considered as CMPA. No obligation to contract neither a CAMO nor a Part-145 unless the type of operation requires it. For helicopters, the relation between large and CMPA can be depicted as follow: Complex Motor Powered Aircraft/Helicopter Including single engined helicopter with MTOM > 3,175kg Multi engined Helicopter with MTOM > 3,175kg Large Aircraft/Helicopter Including multi engined helicopter with MTOM < 3,175kg 5 TOB 22/12/AB

6 Ex: Eurocopter EC135 Engines: 2 PW 206 B LARGE AIRCRAFT MTOW: 2835 kg (<3175) Max passenger: 6 Minimun Flight crew:1 OTHER THAN CMPA Difference between COM and CAT classifications The following graph shows the differences between COM and CAT classifications and illustrates the distinction between operations using CMPA or NON-CMPA aircrafts. The requirements applicable to CAT operations are not taking into account the complexity of the aircraft (no distinction between CMPA and NON-CMPA). 6 TOB 22/12/AB

7 Summary Table COM CAT Requirements for Continuing Classifications Airworthiness Management 1)Local CAT operators Operator shall: obtain CAMO approval, or contract a CAMO 2)ELA1 and Balloons Operator shall: obtain CAMO approval, or contract a CAMO Requirements for aircraft maintenance Part-M Subpart-F or Part- 145 Part-M Subpart-F or Part )non-Community CAT operators Operator shall: obtain CAMO approval, or contract a CAMO Part-145 4) Other than 1), 2),3) Operator shall obtain CAMO approval, CAMO linked to the AOC Part-145 COM other than CAT including COM ATO CMPA Other than CMPA Operator shall: obtain CAMO approval, or contract a CAMO Operator shall: obtain CAMO approval, or contract a CAMO NON-COM CMPA Operator shall: obtain CAMO approval, or contract a CAMO Part-145 Part-M Subpart-F or Part- 145 Part-145 Other than CMPA CAMO is NOT required Independent certifying staff, pilot owner maintenance, Part-M Subpart-F, Part TOB 22/12/AB

8 1.2 Alignment with the new EASA Regulation structure Once the new regulation is published (Air Operations, ATC/ATM, Aerodromes ), EASA will amend the implementing rules 1702/2003 and 2042/2003 to reorganize them and align them with the new regulation structure. This will ensure consistency between the implementing rules toward the total system approach. According to the EASA Rulemaking programme, this alignment should be effective by the end of Q2, 2012 for the Implementing rule 2042/2003. For more information about the new EASA regulation structure, please consult EASA new regulation on Air Operations v2, available on the network using the following address: S:\04-Direction Technique\Veille règlementaire\réorganisation règlements EASA\Flight Standard\Air Operations\Analyse DT 8 TOB 22/12/AB

9 2 ANALYSIS OF THE LAST AMENDMENT OF 2042/ Introduction The 21st of October 2011 was published the Commission Regulation (EU) No 1149/2011, which is the last amendment of Commission Regulation (EC) No 2042/2003. No consolidated version has been published since this amendment, the text of the amendment is available through EASA website: The main changes are made in the Annex III Part-66 and are in relation with the following subjects: Privileges of B1 and B2 aircraft maintenance licence; New aircraft maintenance licence category for non-complex aircraft: Licence B3; Type and group ratings; Type rating training. These changes in Part-66 imply changes in the associated requirements of Part 145 and 147 and relevant AMC & GM. This Regulation apply from the 22 nd of July 2012, except for the requirements regarding the Entry into force laid down in Article 7. 9 TOB 22/12/AB

10 2.2 Privileges of B1 and B2 maintenance licences Introduction Feedback received by the Agency from stakeholders and national authorities suggested that the B2 licensed personnel privileges are too restricted. Regarding licence privileges, additional feedback indicated that the current regulation does not clearly define what an electrical system is and what an avionic system is. Furthermore, the current AMCs and Guidance Material do not seem sufficient to clarify which avionic tasks can be performed by a B1 licence holder and what is a simple test. The amendment aims to clarify the points listed above. Definition of the new privileges The changes made regarding certification privileges are laid down in article 66.A.20 Privileges They mainly concern privileges of licences category B1 and B2, which are amended as follow: A category B1 aircraft maintenance licence shall permit the holder to issue certificates of release to service and to act as B1 support staff following: o maintenance performed on aircraft structure, powerplant and mechanical and electrical systems, o work on avionic systems requiring only simple tests to prove their serviceability and not requiring troubleshooting. Category B1 includes the corresponding A subcategory. A category B2 aircraft maintenance licence shall permit the holder: o to issue certificates of release to service and to act as B2 support staff for following: maintenance performed on avionic and electrical systems, and electrical and avionics tasks within powerplant and mechanical systems, requiring only simple tests to prove their serviceability; and o to issue certificates of release to service following minor scheduled line maintenance and simple defect rectification within the limits of tasks specifically endorsed on the certification authorisation referred to in point 145.A.35 of Annex II (Part-145). This certification privilege shall be restricted to work that the licence holder has personally performed in the maintenance organisation which issued the certification authorisation and limited to the ratings already endorsed in the B2 licence. The category B2 licence does not include any A subcategory. Impact on the training Regarding category B2 certifying staff, the release of electrical and avionics tasks performed within powerplant and mechanical systems have been included in their privileges. As a consequence, Appendixes I, II and III have been revised for the applicable systems in order to increase the knowledge/training level for category B2 to match that of category B1 and to add new questions to the respective examinations 10 TOB 22/12/AB

11 2.3 Licence B3 Introduction A significant number of stakeholders expressed their concern about the fact that the current licensing system was not adapted to the lower complexity of small General Aviation aircraft. Therefore, the amendment introduces a new B3 licence, similar to the B1.2, but with simplified requirements adapted to the lower complexity of light General Aviation piston-engine aeroplanes. Definition of the new licence category The new licence category is introduced in article 66.A.3(c) Licence categories, as follow: Category B3 is applicable to piston-engine non-pressurised aeroplanes of kg MTOM and below. The privileges related to this new licence are defined in article 66.A.20(a).4. Privileges as follow: A category B3 aircraft maintenance licence shall permit the holder to issue certificates of release to service and to act as B3 support staff for: maintenance performed on aeroplane structure, powerplant and mechanical and electrical systems, work on avionic systems requiring only simple tests to prove their serviceability and not requiring troubleshooting. Training and experience requirements According to 66.A.25 Basic knowledge requirements, the basic knowledge requirements are defined in Appendix I to Part-66. The basic experience requirements (see 66.A.30 Experience requirements ) are the same than for the subcategories B1.2 and B1.4. For this new category B3, the relevant rating is piston-engine non-pressurised aeroplanes of kg MTOM and below as stated in 66.A.45 Endorsement with aircraft ratings. 11 TOB 22/12/AB

12 2.4 Type and group ratings Introduction Currently in Part-66, for the purpose of endorsing aircraft type ratings on the aircraft maintenance licences, aircraft are classified as: Aircraft for which licence holders must have an individual aircraft type rating endorsed on the licence. This includes all large aircraft and complex. For these aircraft, type training is required. Aircraft for which licence holders have the possibility of either having an individual aircraft type rating endorsed on the licence, or having an appropriate group rating or manufacturer group rating. In this case type training is not required. The amendment aims to clarify when an aircraft is considered complex and clarify the classifications of aircrafts for the purpose of group rating or manufacturer group ratings. Definition of the aircraft groups A new article is introduced in the Part-66 : 66.A.5 Aircraft groups. According to this article, the groups are defined as follow: For the purpose of ratings on aircraft maintenance licences, aircraft shall be classified in the following groups: Group 1: complex motor-powered aircraft [CMPA, as defined in 216/2008] as well as multiple engine helicopters, aeroplanes with maximum certified operating altitude exceeding FL290, aircraft equipped with fly-by-wire systems and other aircraft requiring an aircraft type rating when defined so by the Agency. Group 2: aircraft other than those in Group 1 belonging to the following subgroups: o sub-group 2a: single turbo-propeller engine aeroplanes o sub-group 2b: single turbine engine helicopters o sub-group 2c: single piston engine helicopters. Group 3: piston engine aeroplanes other than those in Group 1. Impact on the type ratings Based on the groups and sub-groups defined in article 66.A.5 Aircraft groups, EASA has introduced in point 66.A.45 Endorsement with aircraft ratings to Part-66 different possibilities for licence endorsement in accordance with the licence category A table will be introduced in the Guidance Material (GM 66.A.45) in order to summarize all the options and associated requirements. 12 TOB 22/12/AB

13 This table will be similar to the following one but will also include the new licence B3: 13 TOB 22/12/AB

14 2.5 Type training Introduction Currently, aircraft type rating (TR) shall be granted following satisfactory completion of the relevant category B1, B2 or C aircraft type rating training (TRT). In addition, according to current regulation and AMCs, category B1 and B2 approved type training shall include theoretical and practical elements which must comply with Appendix III to Part-66. A programme of structured On the Job Training (OJT) may be prepared to satisfy the practical training requirement. However, cases have been reported where the same training course varies in level, length and content regarding theoretical, practical training/ojt/practical experience. The aim of the amendment is to clarify the type training requirements. Definition of the new requirement Based on the groups and sub-groups defined in point 66.A.5 Aircraft groups, EASA has introduced in point 66.A.45 Endorsement with aircraft ratings different possibilities for licence endorsement together with the corresponding training/examination/experience requirements. The type rating training (TRT) and the OJT are now described separetly, respectively in point 66.A.45(b) and in point 66.A.45(c): b) The endorsement of aircraft type ratings requires the satisfactory completion of the relevant category B1, B2 or C aircraft type training. (c) In addition to the requirement of point (b), the endorsement of the first aircraft type rating within a given category/sub-category requires satisfactory completion of the corresponding On the Job Training, as described in Appendix III to Annex III (Part-66). Impact on the type training For more details, please consult 66.A.45 Endorsement with aircraft ratings and Appendix III to Part TOB 22/12/AB

15 2.6 Impact of the last amendment of 2042/2003 on BV activities Training BV trainer to update their knowledge and analyze the impact of the amendment Amendment of the training materials & modules (Part 66, Part 147, Part 145, Part M) to be realized Consulting & Audit (ASA) BV expert to update their knowledge and analyze the impact of the amendment Amendment of the relevant procedures and checklists 15 TOB 22/12/AB

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