Does EASA require us to keep current a registry of aircraft?
All relevant operator information, including the aircraft used for flights under the TCO authorisation, is required to be kept up-to-date during the initial application and for as long as the TCO authorisation is valid. This is normally done by the operator, using the TCO web-interface. In most circumstances, provided the information was uploaded prior to using the new aircraft, no prior approval by EASA is required for an aircraft of the same type and variant to be added to an already-authorised fleet. Should you wish to add a new aircraft type or variant (as identified by a different ICAO type designator), then prior approval from EASA must be obtained. This request needs to be submitted 30 days before the planned date of first use of the new aircraft type (TCO.315). It is at the discretion of EASA to allow selected Business Aviation operators to start operation with a new fleet without having to wait for prior approval. These operators will receive specifications for so-called “TCO Business Aircraft”, which combine aircraft of different types as long as they all meet specified criteria. Details are explained in the Annex to the TCO authorisation of the affected operators.
In general, all changes that require EASA to issue a new authorisation document or new technical specifications associated to the TCO authorisation will require prior approval by EASA.
Can EASA issue a TCO authorisation in the absence of any aircraft compliant with the applicable standards of the Annexes to the Chicago Convention?
No, if an applicant for a TCO authorisation does not declare at least one aircraft compliant with all applicable technical standards of the Annexes to the Chicago Convention, EASA will not issue a TCO authorisation and will mark the aircraft as ‘Not authorised’ in the online TCO web-interface.
My aircraft is not fitted with a reinforced cockpit door. Can I use it for flights to the EU?
Annex 6 to the Chicago Convention chapter 13.2.2 is fully applicable in the EU:
“From 1 November 2003, all passenger-carrying aeroplanes of a maximum certificated take-off mass in excess of 45 500 kg or with a passenger seating capacity greater than 60 shall be equipped with an approved flight crew compartment door that is designed to resist penetration by small arms fire and grenade shrapnel, and to resist forcible intrusions by unauthorised persons. This door shall be capable of being locked and unlocked from either pilot’s station”.
If your aircraft falls under the aforementioned criteria for a reinforced cockpit door but it is not equipped with one, it cannot be used for commercial air transport operations to the EU.
Can EASA issue a TCO authorisation to an operator with open SAFA ramp inspection findings?
Yes. However, Commission Regulation (EU) No 452/2014 (the ‘TCO Regulation’) stipulates that the Agency shall take into account ramp inspections, as well as other recognised information on safety aspects with regards to third country operators. Open SAFA findings may indicate systemic non-compliances and warrant further focused assessments to be performed by EASA. If evidence gathered during such an assessment confirms a non-compliance with an ICAO standard, EASA may raise a separate finding under Part-TCO. This finding will need to be closed before issuance of a TCO authorisation.
Can EASA issue a TCO authorisation in the absence of having one or more aircraft, or fleets (aircraft types), compliant with the applicable standards of the Annexes to the Chicago Convention?
Yes, as long as at least one aircraft is compliant with the applicable standards of the Annexes to the Chicago Convention applicable to air operators, EASA will issue a TCO authorisation. Any non-compliant aircraft and/or fleet will be marked as ‘Not authorised’ in the online TCO web-interface.
Are there recognised industry standards or third-party audit programmes (e.g., ISO 9001, IOSA, IS-BAO, Air Charter Safety Foundation IAS, etc.) that, if accomplished, may ease the assessment process for operators requesting authorisation?
Conformity with industry standards (when fulfilling the requirements set out in TCO.200 and to the extent that they cover the scope defined in TCO.200(a)(1) and in the absence of safety concerns) may result in a certain bonus rating in the TCO risk-based approach. However, conformity with an industry standard does not substitute for the demonstration of compliance with specific international aviation safety (ICAO) standards by the operator, and does not replace a TCO assessment performed by EASA.