EGU Presentation

Report
The European Gliding Union and
the Harmonisation of European
Regulations in Aviation by the
EASA
Swedish Gliding Conference
Skövde
19 November 2005
European Gliding Union
what is/does the EGU?






the EGU was founded in 1993 in Strasbourg
the EGU represents the European glider pilots on
the European level
the EGU deals only with regulations, not with
sports issues
the EGU is independent of the FAI and its
International Gliding Commission (IGC)
the EGU co-operates with Europe Air Sports
the EGU counts 17 members national gliding
associations (Sweden involved from the beginning!)
the 17 EGU member countries
(70,000 pilots 22,000 gliders)
Roland Stuck (FR)
President
Mathias Borgmeier (DE)
Vice President
Emil Blumer (CH)
Secretary General
Jannes Neumann (DE)
TO Maintenance
Fransois van Haaff (NL)
TO Airspace
David Roberts (GB)
Vice President
Patrick Pauwels (BE)
Treasurer
Mathias Borgmeier (DE)
TO Operations
Meike Müller (DE)
TO Licensing
European Aviation Safety
Agency (EASA)





In July 2002 the EU Council and Parliament have
decided to apply common rules to aviation and to
establish EASA.
The basic regulation of EASA is Regulation (EC)
1592/2002 (scope initially restricted to
airworthiness and environmental compatibility but
will be extended to licensing and operations)
The Annex 2 of this regulation lists the types of
aircraft excluded from European regulation
EASA regulations are not converted into national
laws and apply directly.
EASA is located in Cologne.
Tasks of EASA

Licensing

Operations

Certification

Maintenance

long term: Airport Operations

long term: Air Traffic Services
Procedures for Rulemaking






Rules are prepared by the Rulemaking
Directorate ( Director C. Probst)
Two kind of regulations: Essential Requirements
(ER) adopted by the Parliament and Implementing
Rules (IR) adopted by the Commission
All regulations are published on www.easa.eu.int
For any change a Notice per Amendment (NPA)
must be issued
Stakeholders must be consulted
Evaluation of the answers by an independant task
group
Procedures for Rulemaking
(continued)







A Comment Response Document (CRD) is issued
The EASA then submits an Opinion to the
Commission
If the Commission agrees the Essential
Requirements are submitted to the Parliament
If they are adopted they are published
Implementing rules are written by a group of
experts
Implementing Rules are submitted to the
Commission
If they are adopted they are published
EASA Licensing






EASA has been tasked to propose Essential
Requirements for licensing and operations
in May 2004 EASA has published the NPA
2/2004, with basic regulations and 15 questions
to the ‘stakeholders‘
Only few of these questions concerned air sports:
For which categories of aircraft shall the
pilots licences be regulated?
Shall only Essential Requirements (ER) be written
or also Implementing Rules (IR)?
What kind of Medical shall apply?
The EGU proposal
After discussion, the EGU has proposed two
types of licences:
1. A EU-licence that allows free movement across
Europe. Air sports organisations should be
allowed to issue this licence. Medical standard
may be different from the ICAO Class 2
Standard. Assessment by General Practitioner.
2. An ICAO -licence that allows flight outside the
EU and that is issued by the national authorities.
(requires a ICAO Class 2 Medical)
Reaction of EASA
End of November 2004 EASA has published the
Comment Response Document CRD 2/2004:






EASA is ready to introduce a "Restricted PPL" for
air sports.
They are ready to introduce medical standards
different of those of ICAO for this RPPL.
In this case General Practitioners (GP) could be
suitable examiners via Implementing Rules.
However flight in airspace with a high traffic
density could be restricted.
EGU has objected to such airspace restrictions
related to the RPPL and to the name „restricted“
EASA Opinion transmitted to the Commission
Answer from the Commission



„The proposed Regulation would therefore
introduce a new category of licence, the
„recreational pilot licence“, tailored more closely
to this category of airspace users. This license
would be issued by assessment bodies approved by
the Agency or by the competent national
authority. Sports federations could for example
fulfil this function“
„In the case of pilots involved in recreational
operations, the medical certificate may be issued
by a general medical practitioner“
This proposal for modifying Regulation 1592 will
now be submitted to the Parliament
EASA Operations





In NPA 2/2004 EASA has also published Essential
Requirements on Operations
EGU has asked EASA to lay down no Implementing
Rules for gliding
EASA has accepted to keep the IRs at high level (
JAR Ops 0) for all air sports
EGU studies a harmonisation of the most
important gliding procedures (EGU-internal
recommendation)
EGU is also collecting statistics on accident
Operations
EGU accident statistics
Operations
EGU accident statistics
EASA Certification





The Regulation (EC) 1702/2003 for certification is
already in force.
According to Annex 2 of (EC) 1592/2002 all gliders
of more than 80 kg empty mass (single seaters)
oder 100 kg (two-seaters) must be certified by
EASA.
The approval regulations for gliders has been
copied directly (JAR 22 = CS 22 ).
Engines and propellers of SSG and SLG remain in
CS 22
An EGU request to have light gliders treated as
microlights has been declined
EASA Part 21





According to Part 21 all instruments installed in a
glider must have an EASA Form 1
This is a problem for some instruments
(variometers, GPS, PDA’s)
EGU has asked EASA to reconsider this
requirement
EASA has accepted to consider these equipments
as standard parts not requiring a form 1
NPA to be issued soon
EASA Maintenance





Maintenance is controlled by Regulation (EG)
2042/2003, which is already partly in force for
commercial aviation.
Will be valid for sports aviation per 28
September 2008.
Annex 1, called Part M described the technical
requirements and the procedure for Competent
Authorities
Based on the concept of continuous
airworthiness maintenance
Part M is complex and difficult to read
Overview of Part M (1)



The owner is responsible that the aircraft is
maintained in airworthy condition. He may also
delegate this responsibility to a Continuing
Airworthiness Management Organisation
A Pilot-Owner is allowed to perform all
maintenance tasks except those defined in
appendix VII
A Pilot-Owner is allowed to issue a release to
service after limited owner maintenance listed in
Appendix VIII
Overview of Part M (2)




Every aircraft shall be maintained in accordance
with a maintenance programme approved by the
Competent Authority
Repairs shall be carried out using data approved
by the EASA or by an approved design
organisation (DOA)
The Certificate of Airworthiness is not time
limited if associated with a valid Airworthiness
Review Certificate (ARC)
All certifying staff or airworthiness staff
involved in maintenance has to be qualified
according to Part 66 (not valid for gliding)
Subparts F and G Organisations



A Maintenance Organisation (Subpart F
Organisation or MOA) is allowed to perform all
maintenance tasks and to issue a release to
service
A Continuing Airworthiness Management
Organisation (Subpart G Organisation or CAMO)
is allowed to manage the continuing airworthiness
of aircraft under contract, to approve
maintenance programmes and to perform an
airworthiness review including a physical survey
A CAMO + is allowed to issue an Airworthiness
Review Certificate (ARC) in case of a controlled
environment
Uncontrolled Environment






The owner is responsible for the continuing
airworthiness.
Maintenance task except those defined in appendix
VII can be done by the Pilot Owner
Tasks listed in appendix VIII can be released by
the Pilot-Owner
The owner can also delegate all maintenance to a
MOA
Once a year an airworthiness review including a
physical survey has to be done by a CAMO
The CAMO can only issue a recomendation to the
Competent Authority to issue the ARC
Controlled Environment






The owner has a contract with a CAMO + to
delegate the responsibility of the continuing
maintenance
He has to report the flight hours on a regular basis
The CAMO+ will issue written orders for
maintenance tasks according to the approved
programm.
Tasks can be fulfilled by a MOA or the pilot owner
Once a year the CAMO+ performs an airworthiness
review. This can be done twice on a document basis
and the validity of the ARC can be extended
Every 3 years the CAMO+ issues a new ARC after a
physical survey
Our Problems








Most gliding federations have a broad delegation
for the maintenance of their fleet
This has proven to be pragmatic, cheap and safe!
Will they be allowed to continue in the framework
of Part M ?
In principle : Yes (controlled environment)
How ? One single Subpart F/G or one per club ?
More paperwork, more costs ?
Need of a maintenance programm for each glider ?
Maintenance more complicated in the uncontrolled
environment ( 2 procedures instead of one)
RIA on Part M







EASA has mandated an independent consultant
(Air Euro Safe) to conduct a Regulatory Impact
Assessment (RIA) of Part M
EGU answered this consultation
Meeting with EASA in Frankfurt (disapointing)
EASA has issued NPA 07-05 in June: Only few
changes concerning gliding were accepted
Meeting EAS-EASA in Cologne: some windows
were opened
EGU has prepared comments to answer the NPA
(sent out to the members for approval)
Deadline for answering: 24 November!
Airspace




In 2003 Eurocontrol was given a mandate by the
EU to harmonise the airspace structure in
Europe ( Project Single European Sky) in the
future there will only be 3 categories of
airspace: I(ntended), K(nown) and U(nknown),
later I and U only
The EGU was involved in the discussions and has
sent a position paper
Upper Division Level: FL 195. According to
ENPRM 05-0012 the airspace above FL 195 is
Class C in most countries (i.e open to VFR flying)
Lower Division Level (FL Z): decided on national
basis => Status Quo
Airspace



After discussion with the EGU and other
parties Eurocontrol has also published an
interesting report on the detection and
recognition of light aircraft. The EGU made
recommendations about:
Low power transponders,
Transponder Mandatory Zones (TMZ)
Airspace



The EGU has requested FAI to submit to ICAO a
request to consider the abolishement of the
requirement for VFR-VFR traffic information
8.33 KHz is still not for the lower airspace but
EGU has reminded Eurocontrol of the
consequences the implementation would have
The EGU Airspace Working Group has agreed
upon an airspace survey paper
Conclusions

The EGU is active and well organised
The EGU is recognised by EASA as a competent
partner
The EGU must speak with one single voice!
The EGU needs your support!

More info on:



www.egu-info.org

similar documents