The EASA General Aviation (GA) Roadmap was initiated 5 years ago. It commits to progress towards lighter, simpler and better regulation for General Aviation. In the past 3 years, EASA has worked relentlessly on the action items enumerated in the GA Roadmap, delivering in accordance with its commitments and close to completing the original list of rulemaking activities.
We are further striving to incorporate our 6 GA strategic principles.* We have also been able to achieve several of our strategic key objectives (namely, to develop the use of industry standards for CS-23 reorganisation to allow and promote the introduction of new technology, and the Standard Changes and Repairs Process). Following the rule changes, we have to work hand-in-hand with the Member States to ensure swift implementation: simpler certification process; simplify and reduce aircraft maintenance costs – Part-M Light, Part-CAO; allow training for private pilot outside Approved Training Organisation – Part-DTO; and facilitate access to IFR flying.
Let us give you a brief update and insight into these actions. Some of them have entered or will soon enter the implementation phase.
* 6 GA principles: One size does not fit all; use rules when it is the only or the best way to reach the safety objectives; adopt a risk-based approach; protect ‘what shows to work well’ unless there are demonstrable and statistically significant safety reasons against doing so; apply EU smart regulation principles; make the best use of available resources and expertise.
A new way of thinking: reaching milestones in Maintenance and Certification
First experiences with the new CS-23
One of the highlights last year was the new CS-23: smart and flexible rules that support innovation and are a true game-changer. The latest amendment (n°5) of CS-23 - certification specifications providing the technical requirements for certification of small aeroplanes – has been effective since 15 August 2017. EASA published the AMC/GM (Acceptable Means of Compliance & Guidance Material) in December of the same year including a first set of accepted consensus standards.
Since then, 5 new Type Investigations, including an eVTOL (electric vertical take-off and landing) aircraft have been using the new rule as certification basis. We now can confirm a greater agility in accommodating innovation and stronger focus on desired safety performance. Sometimes this is reflected in more decisions to be taken at project level. This aspect, together with the integration of the VTOL requirements and the full harmonization with FAA are the challenges we are working on.
Continued Airworthiness (Maintenance) update
EASA had a favourable vote for the proposed text on B2L and L aircraft maintenance licenses by the EASA Committee in April 2018 and expects the further adoption as EU-regulation by the Commission within the following 9 months. That means that National Aviation Authorities could start issuing the new licenses in 2019 and converting existing national licenses in 2020.
In detail, the B2L aircraft maintenance licence applies for avionics and electrical systems; and for aircraft other than those in the group of complex aircraft (Group 1). It is based on system ratings and considered as progressive (eventually leading to a full B2, if appropriate). The licence holder can increase the privileges by adding new system ratings at any time.
The L aircraft maintenance licence refers to airframe, power-plant, mechanical and electrical systems, radio, ELT, transponders and limited avionics. It is intended for sailplanes, powered-sailplanes, balloons, airships and ELA1 aeroplanes. The L-license does not require training but an examination by a National Aviation Authority (NAA), Part-147 organisation or anywhere agreed with the relevant NAA. It will replace at a certain point the current national qualifications. Current certifying staff under national rules will obtain the L-licence with the same privileges by conversion.
Part-ML will be applicable to private and commercial (except CAT) operations of aeroplanes (if they are not complex motor-powered aircraft) up to 2730 Kg, as well as other ELA2 aircraft and helicopters up to 4 occupants and 1200 Kg. It allows more attributions to the pilot (deferment of certain defects) and certifying staff/maintenance organisations (airworthiness reviews). Its maintenance programme will not require any authority approval.
Part-CAO will be applicable to organisations for maintenance & maintenance management of non-complex non-CAT aircraft (some aircraft will follow Part-M and others Part-ML). It combines the privileges of a Subpart-F maintenance organisation and a CAMO (Continuing Airworthiness Maintenance Organisation). They will continue with the current Quality System (or organisational reviews if the organisation is small), so no SMS (Safety Management System) will apply. Last but not least, Part-CAO introduces simplified requirements.
An alleviation from EASA Form 1 for certain parts is expected in the medium future.
The regulatory activity is aiming towards installing some spare parts during maintenance without a Form 1. The proposal of this concept is already included in the text of NPA 2017-19. This text, which has already received some positive comments from the GA community, is scheduled to be proposed to the Commission for end of 2018. It will be applicable only for not-safety-critical parts, as identified by the aircraft manufacturer (or by EASA, in special cases), and is particularly interesting for light aircraft.
The concept of standard changes and repairs – CS-STAN
All changes and repairs are subject to approval (under Part 21, Subparts D + M) but since a few years Part-21 also allows to derogate for standard changes and repairs. The specifications are laid down in CS-STAN: a set of provisions allowing the embodiment of simple changes or repairs to GA aircraft without a dedicated approval process, provided that specific conditions are met.
The purpose for allowing standard changes/repairs is to:
- Reduce the regulatory burden for embodiment of simple changes and repairs
- Facilitate introduction of more modern and safer equipment
As CS-STAN evolves, certain topics will be covered in its next issue, such as: new standard changes for balloons; installation of flight time counters; replacement of starter batteries; installation of attachments / brackets for various purposes; headset exchange; clock replacement; repainting of composite aircraft acrylic; installation of weather warning functionality for VFR a/c; improvement/ extension of existing provisions; etc.
The existing AMC/GM to Part-21 are written mainly for large aircraft and companies. In particular, the Product Organisation approval (POA) lacks scalable alternative means of compliance. In addition, there is a split foreseen in the rules between approvals of design and production organisations, and also maintenance organisation, which for small companies - who work in small, consolidated teams - is not natural; and Part-21 Section B (Procedures for competent authorities) mandates a process-oriented approach, which may not necessarily be the best approach for small companies.
We know that innovation is the future for GA and new ideas and players on the market should be encouraged and supported. Today’s rules for design and production are challenging for start-up organisations. Therefore, the “Part 21 proportionality” project is intended to change this in 2 steps.
In a first step, we are developing a proposal for a set of alternative acceptable means of compliance (AMC), which may be used by companies designing or producing ELA (European Light Aircraft), aiming at complementing the existing AMC with more flexible and scalable AMC.
The second step is to develop new or alternative rules within Part-21, in line with the new toolbox available under the new Basic Regulation.
Another breakthrough towards simpler and lighter rules: Air operations and Licensing
Balloon & Sailplane Regulations
The air operations Regulation (EU) No 965/2012 contains about 1900 pages of rules and associated soft law (the AMC/GM material). But only around 120 pages apply to balloons, and even less to sailplanes.
The way forward is to extract the applicable rules for balloons and also for sailplanes from the Regulation, making them simpler and proportionate. The new rules separate Balloon and Sailplane in two different ones.
The first rule completed is Regulation (EU) 2018/395 for balloons. At present, it includes Annex I with Definitions and Annex II (Part-BOP,*, Air OPS). Annex III (Part BFCL* Licensing) will follow.
The Balloon Rule Book is already available on the EASA website. Its main chapters refer to Air Operations, Licensing, Continuing and Initial Airworthiness. This consolidated version contains all information a balloon pilot or operator needs to know in the form of an easy-to-read rule book. A similar one for sailplanes is foreseen to be published in the first half of 2019.
*BOP = Balloon Air Operations
*BFCL = Balloon Flight Crew Licensing
Aircrew: further landmarks in sight
New rules for balloon & sailplane pilot licences are currently under development.
These new parts of the balloon & sailplane regulations are named Part-BFCL (Balloon Flight Crew Licensing) and Part-SFCL (Sailplane Flight Crew Licensing) respectively and will form part of the new balloon and sailplane regulations as described in the Chapter above. Requirements for balloon and sailplane pilot licensing have been revised to be more proportionate to GA. The Opinion is planned to be published by 31 October 2018.
The publication of the Opinion on the Basic Instrument Rating (BIR) is expected on the same date. With the BIR, it is proposed to introduce into Part-FCL a new rating for flying IFR (Instrument Flight Rules), tailored to the needs of leisure pilots, with a full competency-based training in modules, a revised theory syllabus and, in return for numerous alleviations, limitations for approach minima.
In the past, the requirements applicable to Approved Training Organisations (ATOs) were found too demanding for small GA training providers. That’s why EASA developed new and lighter rules: Part-DTO (Declared Training Organisations). Part-DTO (a new Annex VIII to Regulation (EU) No 1178/2011) contains provisions for a new type of training organisation for leisure pilots for aeroplanes, helicopters, sailplanes and balloons. DTOs will not have to undergo the same comprehensive certification process as the ATOs which provide training for obtaining commercial pilot licences. The transition for existing training organisations will be easy. Publication of Part-DTO is expected for July 2018.
The concept of a modular light aircraft pilot license LAPL(A) is currently under revision, and a concrete proposal under development. This revised concept considers the option for LAPL training delivered in modules, and these modules would be determined by each Member State. After the last comments and criticism received, the opt-out for LAPL is extended until April 2020, in order to have more time to develop the concept of modular LAPL.
Furthermore, EASA has proposed to amend requirements for the LAPL to include seaplane privileges in Opinion 05/2017.
Communication, Safety Promotion, cooperation
We created or proposed light and flexible rules for General Aviation that in some cases have already been implemented. Where there are delays it is usually due to the adoption discussions and process in the EU Commission.
The next phase is however coming closer, where we support implementation and monitor the intended effects of our simplification of the regulatory system. For this we need to better understand the current and intended future of GA. This is one of the reasons why we need a common vision and strategy for GA involving all players. If put in place, the new regulatory framework will support and strengthen General Aviation in Europe.
As the rules become lighter, Communication and Safety Promotion have to take up speed. EASA is taking a leading and more proactive role in Safety Promotion, which has become one of the Agency’s priorities. Current successful activities in GA safety promotion are: the start of a GA Community Site for exchange of information, sharing of experiences and discussion around GA topics; the Sunny Swift cartoons on mitigating risks while flying, completely produced by EASA colleagues in 24 European languages; the publication of the European Airspace Infringement Campaign with several short videos and additional materials on the subject, looking at different national specificities as well.
In order to replace or also to strengthen rules, good and effective Safety promotion is best done in cooperation and exchange. National contributions and support of the European campaigns and efforts are crucial. So is the sharing of data and research. This is the way we can work on a vision together, reach out to future pilots, support new technologies and continue our successful path in General Aviation.