We are moving on!
EASA established a few years ago some commitments about better and lighter regulation for General Aviation. There was an urgent need for a change on the GA community.
Aiming to ease the GA segment of unnecessary regulatory burden, and in taking a proportionate and risk-based approach to rules, we can now present a number of tangible results in various topics from the last 3 years:
1) Flying schools & private pilot training:
The requirements applicable to Approved Training Organisations (ATO) have been found too demanding for small GA training providers mainly run by private flying clubs or even private individuals. EASA has taken these concerns on board and has developed new rules to make life easier for training organisations in GA.
In accordance with the new Part-DTO (Declared Training Organisation), training providers for Light Aircraft Pilot Licence (LAPL) and Private Pilot Licence (PPL) will no longer need a prior approval of their training organisations. Instead of this, they will just need to declare the establishment of the training organisation to the competent authority. Operations and training manuals, as known from approved training organisations (ATOs), will not be needed.
The new Part-DTO will grant significant alleviations for the GA training domain and is expected to enter into force by April 2018.
2) Instrument Flying Rules (IFR)
Easier access of General Aviation pilots to Instrument Flying Rules (IFR) flying is considered a high priority measure that will improve safety and utility of GA flying. The NPA (Notice of Proposed Amendment) 2016-14 was published in November 2016 and proposes the introduction of a ‘Basic Instrument Rating (BIR)’, which is a qualification to fly in Instrument Flight Rules (IFR), but based on more proportionate requirements when compared to the traditional instrument rating. EASA is aiming for a modular – less prescriptive - training for GA pilots and the BIR is tailored to their needs.
3) Balloons and Sailplanes
Air operations with balloons and sailplanes, commercial and non-commercial, were initially addressed by the Air OPS Regulation (Air Operations Regulation (EU) N° 965/2012). Affected EASA stakeholders highlighted the complexity of the regulatory framework. Consequently, EASA took those parts back to the drawing board with the aim of working together with the two communities in order to produce stand-alone regulations for commercial or non-commercial operations of balloons or sailplanes. The draft Regulation on air operations with balloons has been finalised and is currently undergoing the adoption process. The work on the Regulation covering air operations with sailplanes was started in 2016 and EASA plans to publish its Opinion by mid-2017.
4) Aerial Work (SPO) in Europe
On 21 April 2017, European rules addressing aerial work (or so-called specialised operations - SPO) with aeroplanes and helicopters came into effect in all 32 EASA states (28 EU Member States plus Iceland, Lichtenstein Norway and Switzerland).
Specialised operations (SPO) or Aerial work means any operation other than commercial air transport (CAT) where the aircraft is used for specialised activities such as: agriculture, construction, photography, surveying, observation and patrol, aerial advertisement, etc.
Part-SPO applies to all commercial specialised air operations with aeroplanes and helicopters with complex and non-complex aircraft. It also applies to non-commercial specialised air operations with complex aeroplanes and complex helicopters.
For most specialised operations there is no need for a prior approval from the competent authority. Instead the operator only needs to declare its activity to the competent authority in the Member State in which they have their principal place of business. After declaring the activity, the SPO operator can immediately start operation. A prior authorisation from the competent authority is only foreseen for some high-risk commercial specialised operations. Therefore, Member States will have to provide an information on which specialised operations are considered to be high-risk.
5) Part-M Light
Owners of light aircraft can get prepared for the improvements – Part-M Light in its full extent (Phase 1 and 2) has already been voted favourably by the European Member States and is currently undergoing the adoption process by the European Commission, expected to be completed by the end of 2017.
Key deliverables are:
- Based on the Minimum Inspection Programme (MIP), owners of light aircraft (aeroplanes up to 2730 Kg, other ELA2 - European Light Aircraft – planes and helicopters up to 4 occupants and 1200 Kg) can write their own maintenance programme.
- There is no need to have the maintenance programme reviewed by your Civil Aviation Authority or by a Continuing Airworthiness Management Organisation (CAMO).
- Any independent EASA-licensed engineer can do the annual inspection.
- Possibility for the pilot / owner to defer defects.
- Guidance for Time Between Overhaul (TBO) extensions.
- Combined approval (Part CAO) for small organisations to manage (former CAMO) and do maintenance (replacement of Part-M subpart F) within one approval.
Part-M Light simplifies existing maintenance rules, and offers a less prescriptive and burdensome approach to maintenance programmes, airworthiness reviews, defects deferments and TBO extensions. It also provides more privileges for pilot, owner, independent mechanics and small maintenance organisations.
6) Standard changes & repairs (CS-STAN)
The Agency issued the first set of standard changes and repairs (CS-STAN) with ED Decision 2015/016, reducing maintenance and operating costs for the following aircraft:
- Aeroplanes of 5 700 kg Maximum Take-Off Mass (MTOM) or less,
- Rotorcraft of 3 175 kg MTOM or less,
- Sailplanes, powered sailplanes, balloons and airships as defined in ELA1 or ELA2 (European Light Aircraft categories).
CS-STAN makes changes, repairs and upgrades of and to light aircraft easier, quicker and less costly since there is no approval required. The safety catch for these changes and repairs is the release and involvement of the appropriately licensed mechanic. In some cases, CS-STAN allows the fitting of non-certified equipment to certified aeroplanes.
CS-STAN will be further regularly amended on the basis of lessons learnt and proposals submitted by affected stakeholders, as well as industry technological innovations which can bring safety benefits in a cost-efficient manner.
7) Industry Standards: the re-organisation of CS-23
EASA NPA (Notice of Proposed Amendment) 2016-05, introducing objective rules supported by consensus standards, was published in June 2016. It follows the same logic as the new Federal Aviation Administration Part-23 rule that was published in December 2016.
The EASA Certification Specifications will be replaced by objective and design-independent requirements for CS-23 aircraft: The new CS-23 concept – with more involvement by industry - will cover the current CS-23 scope and that of CS-VLA simple two-seater aeroplanes
- Therefore new designs would not be hampered by detailed prescriptive rules
- The design-specific details for both CS-23 and CS-VLA will be captured in industry standards that will become Acceptable Means of Compliance (AMC) to CS-23
- Introduction of new technologies or safety-enhancing features becomes part of the industry standards development, and therefore will not be subject to the current slow rulemaking process. Results:
- Lower certification costs for applicants
- Better up-to-date industry standards
8) Simplified entry levels for small low risk aircraft
It is the intention to drastically simplify the airworthiness system for the low end of GA with small aircraft and low risk operation by developing simplified entry levels into the EASA system in a 2 phased approach:
- On the long term, it is foreseen to apply a risk based approach and to use qualified entities and user organisations for oversight, or practically combine organisational approvals while relying on industry standards endorsed by EASA.For these changes to happen, more flexibility for GA needs to be allowed in the Basic Regulation. Part-21 - which contains the airworthiness procedures - can only be changed when the Basic Regulations has been amended.
- On the short term, in spring 2017, new acceptable means of compliance (AMC) for small companies applying for a Production Organisation Approval (POA) are being developed by EASA. These AMC focus on showing that the actual produced aircraft, engine or propeller are in accordance with the approved design. There will be less procedures and organisational checks. The AMC will be accompanied by specific templates facilitating an easier and faster certification process.
9) EASA administrative validation of the FAA Basic Specific Type certificate (STC)
What exactly is an EASA administrative validation of FAA Basic STCs? It is a simplification of the EASA validation process for those cases where the US STC Holder of a FAA STC classified as Basic is unwilling or unable (orphaned STC) to apply for EASA validation. This new approach foresees that an application can be made by the owner/operator of the aircraft to EASA and that the validation will be limited to a single specific serial number applied for by the CAMO (Continuing Airworthiness Maintenance Organisation) or the aircraft owner/operator.