Why is my small rotorcraft charged as medium rotorcraft under F&C?
Commission Regulation (EU) No. 319/2014 establishes the EASA Fees and Charges and defines in Part V point (2) the following categories of Rotorcraft Products for this purpose (only):
- Large Rotorcraft refers to CS 29 and CS 27 cat A;
- Small Rotorcraft refers to CS 27 with Maximum Take Off Weight (MTOW) below 3 175 Kg and limited to 4 seats, including pilot;
- Medium Rotorcraft refers to other CS 27
According to EASA TCDS R.008, the AS350 rotorcraft is a CS27 rotorcraft with MTOW below 3 175kg and a seating capacity of 6, including the pilot. Hence it must be classified as Medium Rotorcraft as per the above definition.
According to EASA TCDS R.146, the AS355 rotorcraft is a CS27 rotorcraft with MTOW below 3 175kg and a seating capacity of 6 (or 7, if an optional two-place seat is installed), including the pilot. Hence it shall be classified as Medium Rotorcraft as per the above definition.
See in particular the EASA Product List – Rotorcraft.
What does the Rotorcraft MTOW 50% rule mean?
For all post-TC design applications the applicable F&C category is based on the type level and corresponds to that category in which more or equal to 50% of the models are within a given type.
This change was introduced by the EASA F&C regulation (Commission Regulation (EU) 319/2014) as of April 2014 and changed the previously applicable rule that the highest weight category was applicable, even though it might have been only connected to one of the models.
In accordance with PART V/Explanatory Note (4) of EASA F&C regulation, the MTOW of the initial TC and subsequently of the majority of the related models covered by this Type Certificate (i.e. more than 50 %) determines the applicable MTOW category.
Should the number of models in both the higher and the lower MTOW categories being equal, the higher MTOW category applies. Once the MTOW category has been determined at the product type level, it is to be consequently applicable for all related applications, e.g. for minor changes, STCs, etc.