Consultations

Written by Alfons Hubmann. Posted in Consultations Commission

Consultation Activities 2010

EFLEVA CONSULTATION ACTIVITIES 2010

     written by Barry Plumb

The EFLEVA consultations group has continued its activities in providing

responses to EASA NPAs and CRDs on behalf of EFLEVA and its

membership associations throughout 2010 This has been a particularly

busy year.

Most of the EASA NPAs issued during 2010 have not required a response

from EFLEVA since their content related aircraft types or operations

outside the EFLEVA sphere of interest. However the year has been populated by several important

EASA CRDs, which relate to NPAs issued in 2008 and 2009, and these were very important

matters for EFLEVA. Responses have been prepared and issued either directly to EASA or via our

aviation partners in EAS. We have also been involved in European Airspace issues. At national level

coordination meetings have been held jointly with NAA’s to progress specific interests.

  • NPA 2008-17 relates to Pilot Licensing and Medicals. EFLEVA were heavily involved in providing
  • reaction to the EASA response documents on these crucially important issues. The situation
  • regarding medicals is particularly important as the proposed LAPL medical standards were
  • revised between the issue of the NPA and the CRD. This was as a result of over influential
  • interference by European Aviation Medical Examiners, resulting, potentially in a considerable
  • increase in medical interference in our chosen sport. The muddle over licensing privileges and
  • currency between EASA and National licenses (for Annex II aircraft) has still to be resolved,
  • but EFLEVA are working tirelessly to achieve a satisfactory outcome from this badly
  • conceived situation.
  • NPA 2008-07 relates to the “ELA process” and “standard changes and repairs”, and is generally
  • the distilled remnants of the outcome from the EASA MDM 032 working group. Unfortunately

most of the beneficial output from MDM 032 had been washed away prior to the issue of the

  • NPA. However EFLEVA have been very active in responding to the NPA and its subsequent CRD,
  • with particular reference to the proposed ELA process, and the potential introduction of an LSA
  • framework within Europe. This has also involved extensive consultation with other aviation
  • bodies such as EMF and EPFU, as well as our colleagues at EAS.
  • As a separate work stream to progress the LSA category EFLEVA is part of an EAS working
  • group together with EMF and EPFU to promote the European LSA category. It is the groups’
  • intent to ensure the Commission is lobbied to establish LSA as an identified category as soon
  • as possible and probably as a clear and separate one (outside ELA process). The background
  • to this with 19 World states operation such a category the delay to Europe is unacceptable
  • given commitments made to sustain the future of GA and the economic loss to Europe when
  • they are a major producer of LSA aircraft.
  • NPA 2008-22 relates to the “Authority and Organisational Requirements. EFLEVA interest
  • here is in relation to the requirements for training organisations. EFLEVA have responded
  • to this consultation process in order to minimise the over-burden of regulation.
  • EFLEVA member organisations continue to work in detail with their National Authorities to
  • ensure that Pan-European arrangements for free passage of our sporting aircraft are
  • maintained or improved.
  • No power flying can take place without an assured supply of suitable fuels, and EFLEVA
  • member representatives have been heavily involved with an EASA research programme
  • carried out by the University of Aachen, relating to the Safety of Bio-Fuels in Aviation
  • resulting in a detailed report available through EASA. Work continues on this theme,
  • in association with European propulsion manufactures, on the production of safety
  • information data to be promulgated through EGAST.
  • EFLEVA has attended and contributed to a number of EASA General Consultation
  • meetings – notable being the Hawk Study workshop where the findings of a study
  • on ELA, LSA and VLA were discussed. The importance of this lies in the demonstrated
  • safety regime of such activities around the world which helps ensure proportionality
  • in future EASA decisions/proposals in this area. We expect this to lead to the
  • planned related Basic Regulation review
  • Single European Rules of the Air (SERA) has been a significant item to address in
  • 2010. Initial proposals were damaging to our interests and EFLEVA has had
  • significant input to address this.
  • EFLEVA continues to be active in various working groups, notably: EASA non
  • Commercial Operations (Non Complex power Aircraft) and ASTM F37  Light Sport.

Barry Plumb

EFLEVA VP Consultation

January 2011

 

 
EFLEVA Tabel of NPAs

EFLEVA.

TABLE OF NPAs, DATES AND DEADLINES FOR CONSULTATIONS PROGRESS MONITORING.

 

(UPDATED 16/10/10)

EFLEVA Comments

Not Posted

Comments

Posted on CRT

N/A to EFLEVA

 EFLEVA Action Outstanding

 

 

NPA No.

Subject

EASA Issue

Date

Response

Deadline

Initial

Notification

Issued

Response

Issued for

Discussion

Response

Added to

CRT

2008-15

Essential Requirements for Civil Aviation

Environmental Protection

15/11/2008

15/11/2008

12/11/2008

 

LAA UK

Response only

2008-16

"Fuel Tank Safety"

 

11/7/2008

N/A to

EFLEVA

N/A to

EFLEVA

N/A to

EFLEVA

2008-17

Implementing Rules for Pilot Licensing 
 A. Explanatory Note and Appendices 
 B. Part-FCL 
 C. Part-Medical

5/6/2008

28/02/2009

12/11/2008

17/02/2009

26/02/2009

2008-18

Access through bulkheads

 

13/09/2008

N/A to

EFLEVA

N/A to

EFLEVA

N/A to

EFLEVA

2008-19

"Fuel Tank Flammability Reduction"

 

18/10/2008

N/A to

EFLEVA

N/A to

EFLEVA

N/A to

EFLEVA

2008-20

Flight Testing

29/8/2008

31/01/2009

12/11/2008

21/11/2008

30/1/2009

2008-21

Review and Analysis of Certification Noise Levels for Subsonic Jet and Heavy Propeller-driven Aeroplanes

14/10/2008

14/01/2009

N/A to

EFLEVA

N/A to

EFLEVA

N/A to

EFLEVA

2008-22

Authority and Organisation Requirements

A. Explanatory Note and Appendices

B. Authority Requirements (Part-AR)

C. Organisation Requirements (Part-OR)

D. CS-FSTD(A)

E. CS-FSTD(H)

F. RIA FCL

31/10/2008

28/05/2009

12/11/2008

 

Deadline

Missed.

 

Comments

Issued

Via EAS

2009-01

“Operational Suitability Certificate” and “Safety Directives”

 

16/01/2009

30/06/2009

5/2/09

N/A to

EFLEVA

N/A to

EFLEVA

2009-02

Implementing Rules for Air Operations of Community Operator

A. Explanatory Note and Appendices
B. Draft Opinion and Decision Part-OPS
C. Draft Opinion and Decision Part-OR (Subpart OPS)
D. Draft Opinion and Decision Part-AR (Subpart GEN, OPS and CC)
E. Draft Opinion and Decision Part-CC and Supplement to Draft Opinion Part-MED
F. Cross-Reference Tables

30/1/2009

31/7/2009

2/4/09

22/6/09

31/7/2009

2009-03

Update to European Technical Standard Order ETSO-C119b

13/03/2009

24/04/2009

N/A to

EFLEVA

N/A to

EFLEVA

N/A to

EFLEVA

2009-04

Airworthiness Approval and Operational Criteria for onboard equipment related to Area Navigation for Global Navigation Satellite System approach operation to Localiser Precision with Vertical guidance minima using Satellite Based Augmentation System

23/3/2009

23/06/2009

N/A to

EFLEVA

N/A to

EFLEVA

N/A to

EFLEVA

2009-05

Appendix 1 – Aircraft type ratings for Part-66 aircraft maintenance licence

 

13/08/2009

16/5/2009

N/A to

EFLEVA

N/A to

EFLEVA

2009-06

Composites

 

13/10/2009

15/8/2009

N/A to

EFLEVA

N/A to

EFLEVA

2009-07

Security related design standards

 

16/10/2009

N/A to

EFLEVA

N/A to

EFLEVA

N/A to

EFLEVA

2009-08

Activation of ice protection system and update of ETSO C16 for electrically heated pitot and pitot-static tubes

 

01/10/2009

N/A to

EFLEVA

N/A to

EFLEVA

N/A to

EFLEVA

2009-09

De-Icing/Anti-Icing

3/9/2009

02/12/2009

N/A to

EFLEVA

N/A to

EFLEVA

N/A to

EFLEVA

2009-10

Cabin Air Quality onboard Large Aeroplanes

28/09/2009

8/1/2010

N/A to

EFLEVA

N/A to

EFLEVA

N/A to

EFLEVA

2009-11

Systematic review and transposition of existing FAA TSO standards for parts and appliances into EASA ETSO

20/10/2009

20/1/2010

N/A to

EFLEVA

N/A to

EFLEVA

N/A to

EFLEVA

2009-12

Avionics

03/12/2009

3/3/2010

N/A to

EFLEVA

N/A to

EFLEVA

N/A to

EFLEVA

2010-01

Other party supplier control

22/01/2010

23/4/2010

N/A to

EFLEVA

N/A to

EFLEVA

N/A to

EFLEVA

2010-02

Improvement of GM to 21A.101

17/3/2010

17/06/2010

17/3/10

N/A to

EFLEVA

N/A to

EFLEVA

2010-03

Introduction of ACAS II software version 7.1

26/03/2010

7/5/2010

N/A to

EFLEVA

N/A to

EFLEVA

N/A to

EFLEVA

2010-04

Damage Tolerance and Fatigue Evaluation of Composite Rotorcraft Structures

29/04/2010

29/7/2010

1/7/2010

N/A to

EFLEVA

N/A to

EFLEVA

2010-05

Appendix 1 Aircraft type ratings for Part-66 aircraft maintenance licence

26/05/2010

26/8/2010

1/7/2010

N/A to

EFLEVA

N/A to

EFLEVA

2010-06

Damage Tolerance and Fatigue Evaluation of Metallic Rotorcraft Structures

27/05/2010

27/8/2010

N/A to

EFLEVA

N/A to

EFLEVA

N/A to

EFLEVA

2008-17b

Part-FCL

CRD Issued by EASA

13/5/10

4/6/2010

 

14/5/2010

Reactions

To EASA

3/6/2010

2008-17c

 

Part Med

CRD Issued by EASA

1/7/2010

23/8/2010

1/7/2010

 

Reactions

To EASA

23/8/10

2009-02e

Part Med

CRD Issued by EASA

1/7/2010

23/8/2010

1/7/2010

 

Reactions

To EASA

23/8/10

2008-07a

“ELA process” and “standard changes and repairs” and for introducing an Executive Director Decision on certification specifications and acceptable means of compliance, for Light Sport Aeroplanes
(« CS-LSA »)CRD Issued by EASA

15/07/2010

15/09/2010

2/8/2010

6/9/2010

Reactions

To EASA

15/9/2010

2010-07

Amend AMC M.A.706(e) to cover additional cases for the competent authority to accept that the nominated post holder in the operator/Part-M Subpart G organisation be employed by the contracted Part-145 organisation

19/07/2010

19/10/2010

N/A to

EFLEVA

N/A to

EFLEVA

N/A to

EFLEVA

2010-08

Control of contracted maintenance personnel

19/07/2010

19/10/2010

N/A to

EFLEVA

N/A to

EFLEVA

N/A to

EFLEVA

2010-09

Contracting of continuing airworthiness management activities

30/07/2010

30/10/2010

N/A to

EFLEVA

N/A to

EFLEVA

N/A to

EFLEVA

2010-10

Alignment of Regulation (EC) No 2042/2003 with Regulation (EC) No 216/2008 and with ICAO Annex 6 requirement for human factor principles to be observed in the design and application of the aircraft maintenance programme

10/8/2010

10/11/2010

11/8/2010

 

N/A to

EFLEVA

N/A to

EFLEVA

2010-11

Passenger emergency exits, emergency features and escape routes – Harmonisation with FAA

08/09/2010

08/12/2010

N/A to

EFLEVA

N/A to

EFLEVA

N/A to

EFLEVA

2010-12

Vibration Health Monitoring. Large Rotorcraft

15/10/2010

15/1/2011

N/A to

EFLEVA

N/A to

EFLEVA

N/A to

EFLEVA