Part-ARA - NLF

Your safety is our mission.

Part-ARA

General Aviation seminar 17th November 2012, Gardermoen

Helena Pietilä / EASA Rulemaking - FCL

Authority Requirements

ARA.GEN contains the general provisions :

• competent authority’s organisation and management system

• initial certification and oversight of approved organisations, the qualification of FSTDs and the attestation of Cabin Crew

ARA.FCL contains specific requirements relating to flight crew licencing applicable to competent authorities

ARA.ATO contains specific requirements relating to approved training organisations applicable to competent authorities

GENERAL

CR Article 4

MS to ensure CAs have proper oversight

capabilities

ARA.GEN.115

CAs to provide staff with required oversight &

technical documentation

ARA.GEN.120

transparency and standardisation regarding the

alternative means of compliance process

ARA.GEN.125

cooperation and the exchange of information between authorities and the Agency, as well as

between the authorities themselves

ARA.GEN - Flexibility

ARA.GEN.120 Means of compliance

Agency shall develop AMCs. When the AMCs are complied with, the related requirements of the IRs are met

Alternative Means of compliance may be used as well

The CA shall establish a system of constantly evaluating these AltMC used by itself or by organisations

When the CA find that AltMC are in accordance with IRs:

- notify the applicant

- notify the Agency (content, all relevant documentation)

- inform other MS

If CA uses AltMC itself it shall make them available for organisations and notify the Agency

ARA.GEN - Flexibility

Organisations may use alternative means to those established in the AMC issued by the Agency:

An organisation must apply to their competent authority and demonstrate that an equivalent level of safety can be reached

Other organisations wishing to use the same altMOC must apply to their Competent Authority

NOTE: Authorities will notify other Member States and the Agency of the alternative means they have approved for their organisations.

MANAGEMENT SYSTEM

ARA.GEN.200

CAs to establish management systems

including compliance monitoring:

Internal audit & safety risk management

ARA.GEN.205

Procedures for allocation of tasks to qualified

entities

(control of contractors)

ARA.GEN.210

Management of changes in the management

system and information to the Agency

ARA.GEN.220

Record keeping requirements:

Storage, accessibility and traceability

Register of approved organisations

OVERSIGHT, CERTIFICATION, ENFORCEMENT

ARA.GEN.300(c)

Scope of oversight to consider safety priorities

(as per SSP – EASP)

ARA.GEN.300(e)

CA may agree to “share” audits when the activity

of an organisation involves more than one

Member State

General ARs - HIGHLIGHTS

ARA.GEN.305 Oversight programme

Standard oversight planning cycle of 24 months, may be extended to 36 months, provided that:

• risks are properly managed

• changes are controlled

•no level 1 findings have been issued

•all corrective actions have been implemented on time

Further extension to 48 months possible provided that ATO has an established and the authority accepted effective reporting system on safety performance and regulatory compliance

General ARs – HIGHLIGHTS

ARA.GEN.350 Findings and corrective actions

Standard definitions for level 1 and level 2 findings

• Level 1:

• lowers safety or seriously hazards flight safety,

• lack of accountable manager,

• failure to grant access to the competent authority,

• falsification of evidence, malpractice or fraud

• Level 2: could lower safety or hazard flight safety

Level 2 findings: corrective action implementation within 3 months, may be extended subject to satisfactory corrective action plan.

Specific ARs for FCL – HIGHLIGHTS

• Oversight Programme to be developed

• for the conduct and

• for the performance of examiners

• Competent authority shall have a list of examiners updated and published regularly

• Authority shall develop procedures to designate examiners for skill tests

ARA.FCL.205 Monitoring of examiners


ARA.FCL.215 Validity period

• Applicant may be allowed to exercise his privileges for 8 weeks after successful completion of an examination – pending the endorsement on the licence

• procedures to be developed by the competent authority


ARA.FCL.300 Theoretical knowledge examinations

• Procedures by competent authority

• Questions for MPL, CPL, IR and ATPL examinations shall be from European Central Question Bank (ECQB)

ARA.ATO.105 – already presented

ARA.ATO.105 Oversight programme

Shall include the monitoring of course standards, including the sampling of training flights with students, if appropriate to the aircraft used.

AMC1-ARA.ATO.105 (detailed)

- Checking facilities for compliance

- Interviewing personnel

- Sampling relevant training courses

- Specific audit or inspection items (see text p. 32)

ARs for ATOs - HIGHLIGHTS

EASA Form 143 – ATO certificate

•Attachment:

• TRAINING COURSE APPROVAL

• including list of training courses and FSTDs (“user approval”)

Member States shall replace the certificates with certificates complying with the format laid down the Air Crew Regulation by 08 April 2017 at the latest.

Helena Pietilä / EASA Rulemaking Flight Standards - Flight Crew Licensing Section

Your safety is our mission.

Rulemaking tasks FCL.008 and FCL.014

Rulemaking task FCL.008

Qualifications for flying in Instrument Meteorological Conditions (IMC)

Comment Response Document (CRD 2011-16) was published 26th October 2012

2 months reaction period -> open until 26th December

Resulting text includes proposed changes into Part-FCL rule and into AMCs of Part-FCL, Part-ARA and Part-ORA

includes responses to comments received during NPA commenting phase


CRD 2011-16 proposes same new ratings and courses as NPA 2011-16

En-route instrument rating EIR

Sailplane cloud flying rating SCFR

And competency-based training course for instrument rating IR(A)


New proposals compared to NPA

Day only IFR

EIR Monitoring Board

Some theory and flight training hours reduced

Several clarifications: EIR operations, creditings, training records, recency requirements, etc

The Agency wishes NAAs and industry to comment on CRD!

Competence based training route to instrument rating

Privileges same as for traditional IR

Training includes theory and flight training

Theory min 80 hours

Flight training min 40 hours instrument time under instruction, of which min 10 hours at an ATO in an aeroplane

Total dual min 25 hours

FNPTs and FFS are allowed

ME course -> total min 45 hours


Part of the flight training can be flown with ‘free floating’ instructor (FI or IRI)

Training record to be fulfilled

Pre-assessment at an ATO -> additional training hours at ATO if needed

Recommendation to IR skill test by ATO

Earlier IFR flight experience and IFR training can be credited

Based on ICAO Annex I instrument rating or national IFR rating

Amount of hours vary


Possible to fly also with high performance complex aircraft

HPA course need to be performed

Modified theory examination since learning objectives have been decreased compared to traditional IR

Same IR skill test as for traditional IR

To guarantee same level of skills


Privileges to fly only en-route phase under IFR

Departure, approach and arrival have to be flown according to VFR and in VMC

EIR holder shall not, during departure or arrival, operate in IMC below 1 000 feet above the highest obstacle within 5 NM of the aerodrome reference point

Transitions to and from IFR via Y and Z flight plans


Theory

same as for competency-based IR

min 80 hours

Flight training

SE minimum 15 hours, ME minimum 16 hours

Similar principles as in competency-based training (outside ATO, crediting previous experience)

Max 5 hours (ME 6) outside an ATO

EIR skill test

Sailplane cloud flying rating SCFR

Privileges to fly near and in clouds

Theory course -> no minimum hours

Flight training hours reduced to 2 hours, at least 1 hour in sailplane

Touring Motor Glider (TMG) can be used during the training and checking in simulated IMC conditions

Privileges of the rating can be used only in a sailplane or powered sailplane (except TMG)


AMC/GM for small training organisations

Agency task, just started

Experts from general aviation organisations are participating the drafting

Aim is to

review the AMC and GM material to Part-ORA regulation to clarify the requirements for small organisations and

improve ‘proportionality’ of the rules

concerning non-complex ATOs


Main emphasize will be on management system, training courses and training aircrafts

Timetable according to Terms of Reference:

Start: 2012/Q1

NPA: 2012/Q3 (not published yet)

CRD: 2013/Q1

Decision: 2013/Q2

Thank you for your attention ! Questions – Comments ?

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Part-ARA - NLF

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