EASA CRT application

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Title	Revised Part-M requirements for aircraft not used in Commercial Air Transport and Pilot owner maintenance
NPA Number	2007-08

SAMA Swiss Aircraft Maintenance Association (samuel.wenger@svfb.ch) has placed 5 unique comments on this NPA:

Cmt#	Segment description	Page	Comment
9	(General Comments)	0	SAMA greatly welcomes the efforts of EASA to adapt and propose rules for non complex and not commercially operated aircraft, GA. The majority of our members are small organisations working exclusively or primarily in this sector, and application of the existing EASA rules on them is a heavy, unproportional burden with very questionable safety benefit. A-NPA 14-2006: In fall 2006, EASA collected opinions on a 'concept for better regulation for General Aviation'. We are surprised now to see proposals mainly covering the same subject, but without reference to results of A-NPA 14-2006 or even a related CRD. Considering also some other NPAs and current tasks at EASA, it appears that the process of creating a proportional set of rules for GA is very fragmented and confusing. The concept of deriving 'light' from 'large' regulations might even be a start from the wrong end, as this visibly does not lead to concise, easily understandable and thus proportional rules, even if in their apparent meaning, the proposals aim at easing the conditions for complying with the rule. We suggest that EASA defines rulemaking for GA (continuing) airworthiness as one project instead of a sucession of changes and clarifications. This would also help the NAAs to solve the dilemma of "having to impose, for the sake of compliance" rules/conditions which are likely to be relaxed, changed or withdrawn shortly after. Deadline 28.08.2008: Even without integrating upcoming conclusions of other NPAs and tasks, it is obvious that the rulemaking timescale will not allow final decisions in time for them to be complied with on September 28, 2008. This conclusion has been emphasized also at the Cologne workshop 4/5.7.2007. EASA has put priority on regulating airworthiness of large aircraft, for obvious reasons. There was no expression of a safety concern to delay the definition of rules for GA, as every member state has such rules in place. If, for reasons escaping our own considerations, the original 'end of opt-out date' can not be changed, its meaning should be changed to say: "it is the date at which the NAAs must present an implementation plan for GA airworthiness rules". The plan shall foresee a start of implementation not before EASA has finalized an agreed and proportional set of rules. A rather minor editorial remark, which can have a considerable impact on the use of English language in member states: to my knowledge, aircraft in plural has no s.
10	A. Explanatory Note - IV. Content of the draft opinions and the draft decision - A) Background information	5 - 6	Section 12: The reasons for rejecting a separate "Part M light" are rather formal, rulemaking considerations. SAMA thinks that rules - partcularily safety related ones - should first of all be easy to understand by the adressees. This is an essential precondition for their meaningful application by personnal, organisations and NAAs, even more important in the case of GA, where generally less capacity can be dedicated to formalities. Although SAMA agrees that rules should not be duplicated, the concept proposed leads to the fact that everyone has to consider both versions of the rule, irrespective of the sector he is working in. The proposal may perhaps be easier to handle by the rulemakers, but it is in no way easy(er) to understand by the adressees. We ask EASA to reconsider this proposal, also under the 'impact on safety' aspect.
11	A. Explanatory Note - IV. Content of the draft opinions and the draft decision - B) Envisaged changes resulting from Task M-017	7 - 13	Section 15, definition of complex aircraft: we do not have a strong view on whether a reasonable definition/weight limit would be 2730 or 2000 Kg MTOM, although we think that there are non complex aircraft even above 2730 Kg. The important point, from the point of view of undestandability/practicability, is that the same limit shall be used in all respects (e.g. also MDM.032, licences, etc). Section 18: It is helpful to clarify that (airworthiness) responsibilities are not necessarily limited to the classic NAAs, that other competent bodies may be designated. The argument must be competence. Particularily in smaller states, it is neither reasonable nor possible for the NAA to have all competences in-house and current, particularily if a specific competence is only sporadicly needed. The principle that available competences outside of the administration may/shall be used should be more strongly ported by EASA. The same remark will be valid for operational and other regulatory sectors. Sections 52 and 53: The arguments to reject acceptance of FAA AC 43-13 and FAA 8130-3 are formal considerations, not safety concerns. At the same time, EASA proposes to create equivalents or simplifications at a later time. Under these circumstances, it would be helpful to state that, until such equivalents are in force, existing national regulations and procedures are accepted.
12	A. Explanatory Note - IV. Content of the draft opinions and the draft decision - C) Envisaged changes resulting from Task M-005	14 - 20	Pilot owner maintanance, general: We agree with the given considerations and proposals, except for the following aspect: A self-assessment as postulated under section 60, second dot, is likely to be effective and sufficient within group/shared ownership, namely for sailplanes and balloons, where such practices exist. It is less obvious that an individual self assessment, with only maintenance program approval and periodic airworthiness review as 'failure detectors', would prevent safety critical results. We therefore recommend that the approval of a maintenance program for engine driven aircraft with Pilot owner maintanance shall be dependent on the assessment of the capabilities by a licensed person. The assessment could easily follow the basic principles given in section 60.
13	B. Draft Rules - II. Draft Opinion (EC) No 2042/2003 - M.A.901 Aircraft airworthiness review	54 - 56	M.A.901(a), proposed addition: .. "For aircraft of 2730 Kg MTOM and below, that are not used in commercial air transport, the validity is two years." Justification: For decades, the airworthiness review interval for GA aircraft in Switzerland has been two years, in some cases longer. There is no evidence that an interval of two years instead of one might pressent a safety risk in this category, or that a one year interval increases safety.