GotTheTshirt
31st Jan 2006, 12:36
Well here is an interesting article on EASA !
From a US investor group
THE SMART MONEY GUYS and GALS HAVE BEEN SAYING FOR YEARS THAT EXPORTING A LARGE USED AIRCRAFT TO “EURO-LAND” ─%COULD BE BAD FOR YOUR HEALTH and ALSO YOUR POCKETBOOK . . . . The JAA & EASA with their Harmonization and Bilateral Airworthiness Agreements haven’t made it any easier. As the EASA matures, new regulations and decisions are being published. For example, JAR-OPS MAINTENANCE has been DELETED ― Annex I – Part M has replaced it. The original document was 7 pages ― Part M has 45 pages. There are a lot of interesting new items and a re-emphasis on some older ones. NOTE: The Airworthiness Review Process appears to be EASA’s 3 method of determining that the aircraft conforms to type design and is in condition for safe operation.
Your “Sending an Aircraft to Europe Checklist” should begin with ― Audit your Maintenance Records to verify you have the data listed in M.A. 305 - Aircraft Continuing Airworthiness Record System. Based on our experiences we estimate there is a 99.9% probability you don’t have them all!
When you have completed your Records Audit ― items 1 thru 9 following ― approach the airplane, with your eyes wide open, and continue with item “C”. NOTE: I have added the underlining and bold emphasis of some text.
Subpart I ― AIRWORTHINESS REVIEW CERTIFICATE ― M.A.901 ― Aircraft airworthiness review must be carried out before the aircraft can be placed in service. The review itself is accomplished in accordance with M.A.710.
(a) To satisfy the requirement for an M.A.902 airworthiness review of an aircraft a full documented review of the aircraft records shall be carried out by the approved continuing airworthiness management organisation in order to be satisfied that:
1. airframe, engine and propeller flight hours and associated flight cycles have been properly recorded, and;
2. the flight manual is applicable to the aircraft configuration and reflects the latest revision status, and;
3. all the maintenance due on the aircraft according to the approved maintenance programme has been carried out, and;
4. all known defects have been corrected or, when applicable, carried forward in a controlled manner, and;
5. all applicable airworthiness directives have been applied and properly registered, and;
6. all modifications and repairs applied to the aircraft have been registered and are approved according to Part-21, and;
7. all service life limited components installed on the aircraft are properly identified, registered and have not exceeded their approved service life limit, and;
8. all maintenance has been released in accordance with this Part, and;
9. the current mass and balance statement reflects the configuration of the aircraft and is valid, and;
10. the aircraft complies with the latest revision of its type design approved by the Agency.
4
(b) The approved continuing airworthiness management organisation’s airworthiness review staff shall carry out a physical survey of the aircraft. For this survey, airworthiness review staff not appropriately qualified to Part-66 shall be assisted by such qualified personnel.
(c) Through the physical survey of the aircraft, the airworthiness review staff shall ensure that:
1. all required markings and placards are properly installed, and;
2. the aircraft complies with its approved flight manual, and;
3. the aircraft configuration complies with the approved documentation, and;
4. no evident defect can be found that has not been addressed according to M.A.404, and;
5. no inconsistencies can be found between the aircraft and the paragraph (a) documented review of records.
(d) By derogation to M.A.902(a) the airworthiness review can be anticipated by a maximum period of 90 days without loss of continuity of the airworthiness review pattern, to allow the physical review to take place during a maintenance check.
(e) An M.A.902 airworthiness review certificate (EASA Form 15b) or a recommendation is issued by appropriately authorized M.A.707 airworthiness review staff on behalf of the approved continuing airworthiness management organization when satisfied that the airworthiness review has been properly carried out.
(f) A copy of any airworthiness review certificate issued or extended for an aircraft shall be sent to the Member State of Registry of that aircraft within 10 days.
(g) Airworthiness review tasks shall not be sub-contracted.
(h) Should the outcome of the airworthiness review be inconclusive, the competent authority shall be informed.
If your background in Aircraft Maintenance had its beginning in General Aviation you will recognize the preceding requirement ― the same as AN ANNUAL INSPECTION ― which is performed by a “special person” ― an FAA Airframe and Powerplant Mechanic with an Inspection Authorization. Air Carrier Inspectors are not authorized to perform, in their role as such, Annual Inspections. They are trained and qualified to perform their tasks in accordance with their Air Carrier’s various Maintenance and Policy & Procedures Manuals. They confirm that tasks were performed in accordance with Company documents, by which, while the document may address an Airworthiness Directive or Manufacturer’s Service Bulletin, they only determine that their document was accomplished properly, not that the document complied with the SB or A/D task. 5
How does this relate to the items listed in M.A. 710? Go back to item (a) 5 ― Airworthiness Directives (A/Ds); if the airline uses an Engineering Order (or whatever name they use for the equivalent) to comply with an A/D, they should have Applied for and received an FAA Alternate Means of Compliance (AMOC) if there is any difference between the “airline document” and the A/D, or its referenced document. Granted, the difference may be MINOR ― which we discuss with the next item. . . . M.A. 710(a)6 ― all modifications and repairs applied to the aircraft have been registered and are approved according to (EASA) Part-21, and;
EASA’s Part 21 differs in several areas from the FAA’s Part 21. The most significant is the difference in the Approval of Major and Minor Alterations OR Repairs. Minor tasks under FAA Part 21 are accomplished in accordance with FAA Acceptable Data. Major tasks are accomplished with FAA Approved Data. Any Alterations or Repairs ― MAJOR or MINOR ― accomplished or embodied in or on an EASA product (Aircraft, Engine, Propeller or Component thereof) must have been accomplished in Accordance With Approved Data. NOTE: At the moment it appears that FAA DER Approvals that were not Accepted by one of the National Authorities before September 28, 2003 are still not acceptable to the EASA.
We will cover EASA’s Part 21 next month ― but to warm you up to the impact of not having Approved Data for the unknown, but soon to be discovered Major or Minor Alterations or Repairs allow us to introduce you to Commission Regulation (EC) No 488/2005 of 21 March 2005 ― on the fees and charges levied by the European Aviation Safety Agency.
This new, almost 18 page document, informs you that there is no free lunch. You have to pay for everything. For example the Charge to File an Appeal (deposit) can range from 1,000 to 100,000 EUROS. I say charge deposit because if you are successful in your Appeal the Charge is refunded.
Now let’s take a quick look at the 1,000 minor (non Part 21) Approved alterations or repairs that may be discovered during the Airworthiness Review Inspection. They will cost you (for large aircraft or its parts) 750 Euros each (plus whatever cost you incur in documenting and obtaining third party Approval of the task). That comes to 750,000 Euros .
Now they will look at your 1,000 (another very conservative number) Major (non Part 21 Approved) Alterations or Repairs to your large aircraft or its parts. They will cost you 1,925 Euros each (plus whatever cost you incur in documenting the task and obtaining third party (like TC or STC holder) Approval of the tasks.) Check my arithmetic but that looks like 1,925,000 Euros. In both cases you may have an out-of-service airplane while you wait for the Approvals. It appears that if you require an EASA Approved STC for the Aircraft the fee begins at 3,400 Euros plus 495 Euros per Euro staff manhour ― and related travel related expenses (including time spent traveling).
We have noted the savvy aircraft traders with mid to high time aircraft avoid EU countries ─ . . . . this probably pleases the EUROs as well.
:mad:
From a US investor group
THE SMART MONEY GUYS and GALS HAVE BEEN SAYING FOR YEARS THAT EXPORTING A LARGE USED AIRCRAFT TO “EURO-LAND” ─%COULD BE BAD FOR YOUR HEALTH and ALSO YOUR POCKETBOOK . . . . The JAA & EASA with their Harmonization and Bilateral Airworthiness Agreements haven’t made it any easier. As the EASA matures, new regulations and decisions are being published. For example, JAR-OPS MAINTENANCE has been DELETED ― Annex I – Part M has replaced it. The original document was 7 pages ― Part M has 45 pages. There are a lot of interesting new items and a re-emphasis on some older ones. NOTE: The Airworthiness Review Process appears to be EASA’s 3 method of determining that the aircraft conforms to type design and is in condition for safe operation.
Your “Sending an Aircraft to Europe Checklist” should begin with ― Audit your Maintenance Records to verify you have the data listed in M.A. 305 - Aircraft Continuing Airworthiness Record System. Based on our experiences we estimate there is a 99.9% probability you don’t have them all!
When you have completed your Records Audit ― items 1 thru 9 following ― approach the airplane, with your eyes wide open, and continue with item “C”. NOTE: I have added the underlining and bold emphasis of some text.
Subpart I ― AIRWORTHINESS REVIEW CERTIFICATE ― M.A.901 ― Aircraft airworthiness review must be carried out before the aircraft can be placed in service. The review itself is accomplished in accordance with M.A.710.
(a) To satisfy the requirement for an M.A.902 airworthiness review of an aircraft a full documented review of the aircraft records shall be carried out by the approved continuing airworthiness management organisation in order to be satisfied that:
1. airframe, engine and propeller flight hours and associated flight cycles have been properly recorded, and;
2. the flight manual is applicable to the aircraft configuration and reflects the latest revision status, and;
3. all the maintenance due on the aircraft according to the approved maintenance programme has been carried out, and;
4. all known defects have been corrected or, when applicable, carried forward in a controlled manner, and;
5. all applicable airworthiness directives have been applied and properly registered, and;
6. all modifications and repairs applied to the aircraft have been registered and are approved according to Part-21, and;
7. all service life limited components installed on the aircraft are properly identified, registered and have not exceeded their approved service life limit, and;
8. all maintenance has been released in accordance with this Part, and;
9. the current mass and balance statement reflects the configuration of the aircraft and is valid, and;
10. the aircraft complies with the latest revision of its type design approved by the Agency.
4
(b) The approved continuing airworthiness management organisation’s airworthiness review staff shall carry out a physical survey of the aircraft. For this survey, airworthiness review staff not appropriately qualified to Part-66 shall be assisted by such qualified personnel.
(c) Through the physical survey of the aircraft, the airworthiness review staff shall ensure that:
1. all required markings and placards are properly installed, and;
2. the aircraft complies with its approved flight manual, and;
3. the aircraft configuration complies with the approved documentation, and;
4. no evident defect can be found that has not been addressed according to M.A.404, and;
5. no inconsistencies can be found between the aircraft and the paragraph (a) documented review of records.
(d) By derogation to M.A.902(a) the airworthiness review can be anticipated by a maximum period of 90 days without loss of continuity of the airworthiness review pattern, to allow the physical review to take place during a maintenance check.
(e) An M.A.902 airworthiness review certificate (EASA Form 15b) or a recommendation is issued by appropriately authorized M.A.707 airworthiness review staff on behalf of the approved continuing airworthiness management organization when satisfied that the airworthiness review has been properly carried out.
(f) A copy of any airworthiness review certificate issued or extended for an aircraft shall be sent to the Member State of Registry of that aircraft within 10 days.
(g) Airworthiness review tasks shall not be sub-contracted.
(h) Should the outcome of the airworthiness review be inconclusive, the competent authority shall be informed.
If your background in Aircraft Maintenance had its beginning in General Aviation you will recognize the preceding requirement ― the same as AN ANNUAL INSPECTION ― which is performed by a “special person” ― an FAA Airframe and Powerplant Mechanic with an Inspection Authorization. Air Carrier Inspectors are not authorized to perform, in their role as such, Annual Inspections. They are trained and qualified to perform their tasks in accordance with their Air Carrier’s various Maintenance and Policy & Procedures Manuals. They confirm that tasks were performed in accordance with Company documents, by which, while the document may address an Airworthiness Directive or Manufacturer’s Service Bulletin, they only determine that their document was accomplished properly, not that the document complied with the SB or A/D task. 5
How does this relate to the items listed in M.A. 710? Go back to item (a) 5 ― Airworthiness Directives (A/Ds); if the airline uses an Engineering Order (or whatever name they use for the equivalent) to comply with an A/D, they should have Applied for and received an FAA Alternate Means of Compliance (AMOC) if there is any difference between the “airline document” and the A/D, or its referenced document. Granted, the difference may be MINOR ― which we discuss with the next item. . . . M.A. 710(a)6 ― all modifications and repairs applied to the aircraft have been registered and are approved according to (EASA) Part-21, and;
EASA’s Part 21 differs in several areas from the FAA’s Part 21. The most significant is the difference in the Approval of Major and Minor Alterations OR Repairs. Minor tasks under FAA Part 21 are accomplished in accordance with FAA Acceptable Data. Major tasks are accomplished with FAA Approved Data. Any Alterations or Repairs ― MAJOR or MINOR ― accomplished or embodied in or on an EASA product (Aircraft, Engine, Propeller or Component thereof) must have been accomplished in Accordance With Approved Data. NOTE: At the moment it appears that FAA DER Approvals that were not Accepted by one of the National Authorities before September 28, 2003 are still not acceptable to the EASA.
We will cover EASA’s Part 21 next month ― but to warm you up to the impact of not having Approved Data for the unknown, but soon to be discovered Major or Minor Alterations or Repairs allow us to introduce you to Commission Regulation (EC) No 488/2005 of 21 March 2005 ― on the fees and charges levied by the European Aviation Safety Agency.
This new, almost 18 page document, informs you that there is no free lunch. You have to pay for everything. For example the Charge to File an Appeal (deposit) can range from 1,000 to 100,000 EUROS. I say charge deposit because if you are successful in your Appeal the Charge is refunded.
Now let’s take a quick look at the 1,000 minor (non Part 21) Approved alterations or repairs that may be discovered during the Airworthiness Review Inspection. They will cost you (for large aircraft or its parts) 750 Euros each (plus whatever cost you incur in documenting and obtaining third party Approval of the task). That comes to 750,000 Euros .
Now they will look at your 1,000 (another very conservative number) Major (non Part 21 Approved) Alterations or Repairs to your large aircraft or its parts. They will cost you 1,925 Euros each (plus whatever cost you incur in documenting the task and obtaining third party (like TC or STC holder) Approval of the tasks.) Check my arithmetic but that looks like 1,925,000 Euros. In both cases you may have an out-of-service airplane while you wait for the Approvals. It appears that if you require an EASA Approved STC for the Aircraft the fee begins at 3,400 Euros plus 495 Euros per Euro staff manhour ― and related travel related expenses (including time spent traveling).
We have noted the savvy aircraft traders with mid to high time aircraft avoid EU countries ─ . . . . this probably pleases the EUROs as well.
:mad: