This NPA aims at the simplification of the way to comply with the requirements — laid down in Part-ORA — for non-complex approved training organisations (ATOs) by providing more focussed detailed information, specific alleviations and more detailed guidance on safety risk management and compliance monitoring in a format of either dedicated new or adequately amended AMCs and GMs. In order for this to be achieved, the amendment of ED Decision 2012/007/R ‘Acceptable Means of Compliance and Guidance Material to Part-ORA’ is proposed.
Said amendment is stemming on the one hand from the consultation of rulemaking task FCL.001 during which stakeholders expressed concerns about the level of complexity of the requirements to be complied with in case of ATOs representing the non-commercial sector and providing training mainly for the LAPL and the other non-commercial licences, as well as the associated ratings and certificates, and on the other hand from the recommendations made in the context of the General Aviation (GA) roadmap.
The Agency addressed most of these concerns by simplifying the criteria to meet the intent of the requirements in Section II — Management of Subpart GEN and Section I — General of Subpart ATO of Part-ORA. In Subpart GEN, topics as organisation and accountability, safety policy and safety risk management, and in Subpart ATO issues like the training programme, the training manual and the aircraft and FSTDs used for training are affected. By including this rulemaking task RMT.0421 (FCL.014) in its Rulemaking Programme, the Agency fulfilled the commitment to improve ‘proportionality’ of the rules concerning non-complex ATOs.