Not according to a letter in the latest ALAE tech log from Mr. McKenna (head of CAA Engineering)they won't.
A number of engineers have lodged reports raising concerns on the manner in which other States are implementing the requirements in JAR-66. Lacking clear evidence to support these we cannot comment directly on these claims. There are undoubtedly difficulties
associated with the adoption of JAR-66 in all States arising from the variety of National practices that were previously in place. This does not mean that the
practices being adopted are giving any person an edge over another.
It is wrong to compare the practice of one State directly with that in another. There are many reasons for saying this. Some countries have a well established and comprehensive licensing system. Other States rely heavily upon approved maintenance organisations to determine the knowledge and experience standard, for their staff. You are well aware that the 'JK itself uses a complex mix of both these systems. On top of this, there are varying levels of support for maintenance training through State education systems with formal apprenticeships and academic
qualifications being readily available to individuals.
Each State has agreed its implementation policy with the JAA through the JAR-66 Review Board process. This sets the standard for examination questions and the basis upon which the existing qualifications can be transferred to a JAR-66 licence. An important part of this process is how the prevailing mixture of qualifications compare against the JAR-66 syllabus and experience requirements. The latter, maintenance experience, is easy to reconcile against the three or five years set by the JAR's. It is far more difficult to judge from the outside how each authority has analysed the syllabus, made its comparisons and
demonstrated its intended policy to the JAA. The key issue that we have been trying to reinforce all along is that until all States have largely transferred the existing population to the new JAR scheme there will be an element of variability.
To your specific points. Holland uses a company authorisation system for large aircraft qualifications. Licences are only available for light aircraft. As such,
individual companies were responsible for determining the competence of individuals. The manner in which this was done is subject to oversight of the RLD (Dutch Authority) as part of the monitoring of the company approval. This is exactly the same as the BCAR A8-13 principles used in the UK. UK practice was however to base such authorisations on the Section L LWTR. We cannot state what policy the Dutch put in place to cater for foreign i.e. non Dutch Nationals, seeking employment and authorisation in Holland. It is unlikely that the applicant you highlight in your letter declared his failure at the CAA exams to the company or the RLD. This is the critical issue and can really only be answered by the RLD.
You are wrong in assuming that just because someone holds a licence he or she has an automatic entitlement to be authorised. JAR 145.30 clearly requires that the individual must be determined as competent by the company. The licence is an additional element to the qualification process for authorisations issue. You may be correct that below minimum standards ay be being adopted by certain organisations or JAA-NAAs. The system adopted by the JAA will however gradually eliminate these anomalies in the longer term. The JAR-66 Review Board process determines the intended policy of the relevant JAA-NAA. The Maintenance
Approval Standardisation Team visits to the JAA-NAA and sample organisations determines how well the JAA-NAA is implementing and adhering to that policy. We must assume that the system works and will detect any shortfalls until proven otherwise.
If you have firm evidence, from your members, that some JAA-NAAs have adopted questionable standards or individuals are being authorised or licensed without meeting the requirements, please bring it to our
attention and that of the JAA. You have access to the JAA Maintenance Sectorial Team meetings through AEI and if you feel there is cause for concern in a particular case you should raise the matter with Mr Bruggemann as a potential agenda item.
The CAA alone cannot manage Europe, that is a function for the JAA to look at collectively. You should however remember that each State has its own sovereign responsibility and legislative system. One State cannot interfere in the activities of another.
Accordingly, not withstanding your concerns, the CAA must look to its own standards and this means that we will continue to set and implement appropriate standards that mean a UK licence holder can be proud of the licence they have worked hard to obtain. We will not compromise our standards and fail to discharge our responsibilities to UK Government and ICAO.
[This message has been edited by spannersatcx (edited 24 May 2001).]