09/09/2020 ToR RMT.0731 - New air mobility
Introduction of new designs, technologies, and types of operation for which regulatory updates are needed. The current continuing airworthiness rules only cover traditional aircraft and therefore they need to be amended to cover also ‘new air mobility’ aircraft.
08/09/2020 TOR RMT.0726 - Rotorcraft occupant safety in the event of a bird strike
The specific objective of this rulemaking task is to improve rotorcraft occupant safety in the event of a bird strike. This objective can be achieved by introducing a new risk-based certification specification to prevent windshield penetration on small rotorcraft (CS-27) with higher passenger capacities; the specification may be similar to CS 29.631 for safe landing, but would only be applicable to the windshield; (Subtask 1); and if assessed to be necessary, through a proportionate retroactive application of bird strike certification specifications to the existing rotorcraft fleets and/or to the future production of already type-certified rotorcraft (Subtask 2).
07/09/2020 Product Certification Consultations
EASA has received applications proposing design changes that would allow the transportation of cargo instead of passengers, in the passenger cabin of (CS-25) Large Aeroplane beyond the use permitted by the operational rules of the already existing designated areas/volumes such as overhead bins, galleys or stowage compartments.
The proposed designs will change the passenger compartment to allow carriage of cargo in the passenger cabin, instead of passengers, in a cabin area that was not designed as a cargo compartment. The certification specifications in CS-25 address the design of cargo compartments (ref. CS 25.855 and CS 25.857).
01/09/2020 Design & Certification Newsletter
EASA has issued the latest edition of its newsletter
17/08/2020 ED Decision 2020/012/R
The specific objective of this Decision is to introduce amendments to the Certification Specifications for Master Minimum Equipment List (CS-MMEL) and for the Generic Master Minimum Equipment List (CS-GEN-MMEL) following the selection of non-complex, non-controversial and mature subjects.
01/07/2020 CRD 2020-05
The CRD has been issued in response to NPA 2019/01 which proposed to mitigate the potential effects of cybersecurity threats on safety. Such threats could be the consequences of intentional unauthorised acts of interference with aircraft on-board electronic networks and systems.
The NPA proposed amendments to CS-23, CS-25, CS-27, CS-29, CS-E, CS-ETSO, CS-P, and, as applicable to their related acceptable means of compliance (AMC)/guidance material (GM), together with AMC-20. The amendments would introduce cybersecurity provisions into the relevant certification specifications (CSs), taking into account the existing special conditions (SCs) and the recommendations of the Aviation Rulemaking Advisory Committee (ARAC) regarding aircraft systems information security/protection (ASISP).
287 comments were made by 32 stakeholders, including individuals, national aviation authorities (NAAs) or organisations as well as industry companies and associations. The commentators are in general supportive of the proposed amendments to the certification specifications (CSs) and the creation of a new AMC-20 to address cybersecurity. They also appreciate the regulatory harmonisation effort with the Federal Aviation Administration (FAA). Further to the comments received, the text proposed in the NPA has been modified in some parts, for improvement or clarification purposes. The individual comments and the responses to them are provided in Chapter 2 of the CRD.
24/06/2020 ED Decision 2020/006/R
The objective of this Decision is to mitigate the potential effects of cybersecurity threats on safety. Such threats could be the consequences of intentional unauthorised acts of interaction with the aircraft on-board electronic networks and systems.
This Decision issues amendments to CS-25, CS-27, CS-29, CS-APU, CS-E, CS-ETSO, CS-P, and to the related acceptable means of compliance (AMC) and/or guidance material (GM), together with AMC-20, AMC/GM to CS-23 and AMC/GM to Part 21. The aim of the amendments is to introduce cybersecurity provisions into the relevant certification specifications taking into account:
- The existing special conditions (SCs), and
- The recommendations of the Aircraft Systems Information Security/Protection (ASISP) Working Group of the Aviation Rulemaking Advisory Committee (ARAC)
by following a proportional approach.
27/04/2020 Part 21 Regulation updated by Commission Delegated Regulation (EU) 2020/570
Regulation (EU) No 748/2012 was amended and corrected as regards the alignment of rules for continuing airworthiness of aircraft and aeronautical products, parts and appliances with Regulation (EU) No 1321/2014.
- Commission Regulation (EU) No 1321/2014 has been amended to establish more flexible requirements for the maintenance of light aircraft and to add safety risk management for organisations that manage the continuing airworthiness of aircraft operated by holders of an air operator certificate. As a consequence of that amendment the measures to be taken to ensure the continuing airworthiness of an aircraft, which were previously laid down in Annex I (Part-M) of Regulation (EU) No 1321/2014, are now laid down in Annex I (Part-M), Annex Vb (Part-ML), Annex Vc (Part-CAMO) and Annex Vd (Part-CAO) of that Regulation, in accordance to the type of aircraft and operation thereof
- Since the provisions relating to certificates of airworthiness, repair design approvals and permits to fly, laid down in Annex I (Part 21) to Commission Regulation (EU) No 748/2012, only refer to Annex I (Part-M) to Regulation (EU) No 1321/2014, that Annex I (Part-21) to Commission Regulation (EU) No 748/2012 should be amended to adapt its provisions to the new structure of the Annexes to Regulation (EU) No 1321/2014
- Point (b) of point 21.A.604 of Annex I to Regulation (EU) No 748/2012 may be understood that for the approval of design changes to Auxiliary Power Unit for applicants who do not hold a European Technical Standard Order Authorisation, as regards changes classified as minor, Subpart E of Annex I to Regulation (EU) No 748/2012 should be applied instead of Subpart D of Annex I to that Regulation. Therefore, Regulation (EU) No 748/2012 should be corrected to clarify that in those cases Subpart D of Annex I to that Regulation applies
- The requirements related to the production cut-off standard for aeroplane CO2 emissions in point 21.A.165 of Subpart G of Annex I to Regulation (EU) No 748/2012 are not clearly stated and aligned with the same requirements in Subpart F of Annex I to that Regulation. Regulation (EU) No 748/2012 should therefore be corrected
- The provision in letter (c) of point 21.A.93 of Annex I to Regulation (EU) No 748/2012 refers to ‘type-certificates or restricted type-certificates’, whereas it should refer to ‘changes to type-certificates or restricted type-certificates’. Regulation (EU) No 748/2012 should therefore be corrected.
07/04/2020 TOR RMT.0725
Certification specifications (CS) 27.1337(e) and 29.1337(e) require the installation of chip detectors to detect particles of ferromagnetic material that are released by elements of rotor drive systems as a result of damage or wear. Additionally, chip detectors are frequently identified, and accepted, as one of the compensating provisions for hazardous or catastrophic failures in the design assessment (refer to CS 29.917(b)). However, there is no explicit provision in the CSs, nor any detailed AMC, for consistently demonstrating that chip detectors perform their intended function.
In-service experience shows that there have been occurrences where the chip detection system was not capable of indicating the presence of wear or degradation of elements of rotorcraft gearboxes, even if resulting particles were present in the system for some time before a failure occurred. Therefore, the specific objective of this proposal is to ensure that an acceptable minimum level of effectiveness is achieved by the chip detection systems installed in rotorcraft drive systems.
16/03/2020 NPA 2020-06
The objective of this Notice of Proposed Amendment (NPA) is to align the European Union (EU) regulations and the associated acceptable means of compliance (AMC) and guidance material (GM) with the International Civil Aviation Organization (ICAO) Standards and Recommended Practices (SARPs) and guidance on environmental protection.
The ICAO Committee on Aviation Environmental Protection (CAEP) agreed in February 2019 on a new non-volatile particulate matter (nvPM) emissions standard, and proposed improvements to the existing noise, aircraft engine emissions, and aeroplane CO2 emissions standards.
Thus, this NPA proposes to amend accordingly Article 9 ‘Essential requirements’ of Regulation (EU) 2018/1139, Annex I (Part 21) to Commission Regulation (EU) No 748/2012 as well as the AMC and GM to Annex I (Part 21), CS-34, CS-36, and CS-CO2.
06/03/2020 Tyre Pressure Monitoring
NPA 2020-05 is open for comments with the objective of reducing a hazardous or catastrophic tyre failure as a result of inadequate tyre inflation pressure.
It proposes to amend CS-25 to require applicants to provide a means to ensure that no tyre is below its minimum serviceable inflation pressure during operation. This can be achieved either by providing a task in the instructions for continued airworthiness (ICA) that requires operators to perform tyre pressure checks at a suitable time interval (i.e. daily or at another substantiated interval), or by installing a tyre pressure monitoring system that alerts the flight crew in the case of a tyre with an unsafe pressure. It also proposes to amend Part-26 and CS-26 to require the same objective to be implemented by operators of large aeroplanes, i.e. either by including in the AMP tyre inflation pressure checks at a suitable time interval, or by installing a tyre pressure monitoring system.
The proposed changes are expected to increase safety without any significant economic impact, and with no environmental or social impact.
The timeline for this rulemaking activity is open for public consultation until 6th June 2020, when the drafting of the amendments will take place. It is then expected that an Opinion will be released in Q1 of 2021, with adoption by the European Commission in Q3 of 2022.
05/03/2020 Soft law regular update
EASA, as necessary, issues AMC and GM to Part-21 to illustrate means to establish compliance with the Regulation or to illustrate the meaning of a requirement. These AMC or GM require regular amendments to take specific safety issues into consideration and introduce new acceptable means of compliance or procedures.
The objective of NPA 2020-04 is to:
- address a safety recommendation following an accident that occurred in Norway on 29 April 2016;
- resolve certain recurrent implementation issues by improving the text of the AMC and GM to Part 21;
- leave no room for misinterpretation of the Regulation, as noticed during design organisation approval (DOA) holder initial investigation and surveillance activities, by including clarifications;
- align the means of compliance with the current industry practice; and
- remove unnecessary guidance material and correct typographical errors. The proposed amendments are expected to increase the efficiency of implementing Part 21 and ensure alignment with the current industry practices.
DAH and NAA’s are expected to engage with the consultation and provide their feedback to EASA by 5th May 2020 to align the overall milestone plan of a decision in Q2 this year.
05/03/2020 Vibration Health Monitoring - VHM
Rulemaking task RMT.0711 has been launched on the use of vibration health monitoring (VHM) systems. The aim is to monitor the condition of critical rotor and rotor drive components which has been demonstrated to improve incipient fault detection capabilities by adding to those provided by traditional inspection techniques. However, the current CS and the associated AMC are deemed not sufficient to ensure that these systems can be used to optimise maintenance interventions for certain rotorcraft systems.
An amendment of the CS and the associated AMC for large rotorcraft will clarify the means for establishing compliance with CS 29.1465 where VHM applications are used as a compensating provision for the rotor and rotor-drive system. In addition, this RMT will consider providing guidance to support the certification of VHM applications for on-condition maintenance of critical components. This should help to promote the development of VHM systems with improved fidelity and reliability.
This change to the design code is expected to bring improved design for safety through
- defining criteria for the acceptance of VHM systems as an airworthiness approved means for enabling the possibility for on-condition maintenance;
- defining high-level objectives to be achieved for VHM applications for on-condition maintenance (credit) purposes, and providing additional considerations regarding the characteristics to be demonstrated for elements of the rotor and rotor drive system and their failure modes that are being monitored for this purpose;
- establishing appropriate principles concerning the definition of adequate targets for controlled service introduction phases, taking into consideration the intended use of the different VHM system indicators, and additionally, clarifying the requirements for the performance assessment of VHM systems during these phases;
- clarifying the intent of VHM trend monitoring and the objectives of its implementation;
- defining advanced anomaly detection techniques, the scope of their application as part of VHM monitoring and provide associated guidance material for certification;
- defining recommended criteria for evaluating the performance of health indicators and the associated thresholds;
- improving the guidance material on alert management, taking into account relevant VHM best-practice guides; and
- clarifying the depth of initial and controlled service introduction (CSI) investigations expected for elements of the VHM system, such as ground stations, product support, and recommendations for training.
It is expected that a public consultation will be launched next year in Q1 in the form of a NPA with the decision expected a short time after in Q3.
We encourage design approval holders of CS-29 type rotorcraft to engage wit the rulemaking activity.
20/01/2020 Regular update of Design code for large aeroplanes
NPA 2020-01 has been published to update CS-25 to, amongst other reasons, improve the harmonisation with the FAA regulations. The other areas it reviews are:-
- Item 1: Go-around handling qualities and performance (NPA 2017-06);
- Item 2: Minimum control speeds;
- Item 3: Fuel tank and system lightning protection;
- Item 4: Cabin safety (various topics);
- Item 5: Electronic AFMs – computation of misleading primary information;
- Item 6: On-board weight and balance systems;
- Item 7: Air conditioning systems;
- Item 8: Flight guidance systems;
- Item 9: Primary flight displays during unusual attitude and declutter modes;
- Item 10: Lightning protection and electrical bonding and protection against static electricity; and
- Item 11: Operation without normal electrical power.
These changes have little to no impact on the social or environmental aspects, but do provide moderate safety and economic benefits by streamlining the certification process.
The NPA is open for comments via the EASA Comment Response Tool until the 20th April 2020.
13/01/2020 Design improvements to mitigate the risk of runway excursions
EASA has released Decision 2020/001/R revising CS-25 to amendment 24, which affects Design Approval Holders and TC and STC applicants of large aeroplanes. The objectives of this decision are to:
- reduce the number of runway excursions during landings of large aeroplanes by providing design-related means to support the flight crew in identifying and managing the risk of a longitudinal runway excursion; and
- clarify and standardise specifications and acceptable means of compliance related to large aeroplanes safety assessments of critical systems, flight control systems, and aeroelastic stability.
NPA 2018-12, CRD 2018-12 and CRD 2014-02 are all related to this rulemaking activity.
18/12/2019 Instructions for continued airworthiness
EASA has published the Comment Response Document (CRD2017-19) and Opinion 07/2019 relating to NPA 2017-19 (CRD 2018-01 / NPA 2018-01 also refers) which aims to mitigate the risks linked to the uncertainty of the status of the instructions for the ICA’s and, therefore, to avoid leaving room for interpretation in the rules, leading to differences in the use of ICA.
There are some key points noted in the CRD relating to the classification of critical parts along with the DO-PO relationship, reporting to EASA and other topics covered on the NPA.
This Opinion proposes changes to Part-21, Part-M, Part-ML and Part-145. The full details around the sections relating to material can be found in the Draft Annex of the Opinion. We therefore recommend all DO’s, PO’s, CAMO’s and AMO’s to familiarise themselves with the proposed new regulation.
13/11/2019 Flight recorders
EASA has published NPA 2019-12 which it states it’s objective is to improve the availability and the quality of data recorded by flight recorders in order to better support safety investigations of accidents and incidents.
This NPA proposes to enhance the CS’s and AMC for the installation of flight recorders on board large aeroplanes and large rotorcraft. It aims to address the following subjects:
- Data link recording;
- The serviceability of flight recorders; and
- The quality of recording of cockpit voice recorders.
It also analyses the issue reported after some occurrences (on large aeroplanes) in which the end of the recording was missing from the flight data recorder data due to the loss of normal electrical power. It also considers the option of mandating an alternate power source as a solution. The conclusion recommends no regulatory change.
EASA re-iterates that the proposed changes to CS-25 and CS-29 are expected to increase safety (by addressing some safety recommendations, and overall contributing to facilitating investigations of accidents and incidents), to help operators to ensure the serviceability of recorders, to ease the certification process for recorders for EASA and design organisations, and thereby bring an economic benefit for these stakeholders.
The consultation period for this NPA is open until February 13th 2020. We recommend all DO’s and Operators of large aeroplanes and rotorcraft to review and comment on this NPA through the EASA comment response tool.
28/08/2019 Alignment of Part-21 with the Basic Regulation – Proportionate rules for GA
Rulemaking Task RMT.0727 has been launched by EASA to conduct a comprehensive review of Part-21 with a view to aligning them with the Basic Regulation. It will be achieved by amending the existing requirements in Part-21, where there were changes from the old to new Basic Regulations.
In particular, this RMT will:
- revisit whether the existing rules correspond to the nature and the risk levels of the activities, and if not and where appropriate, allow the application of a proportionate approach to the approval of airworthiness products, parts and equipment. This aspect will, in particular, take into account the various risk levels that exist in General Aviation (GA) in the initial airworthiness process, and it is intended to reduce the administrative burden and its associated costs, while at the same time support innovation in GA;
- define the scope, conditions and process for the certification of ‘non-installed equipment’ (NIE), while ensuring a proportionate approach to the certification of this type of equipment that takes into consideration the safety risk;
- implement any necessary changes to the environmental certification of aircraft and their engines, propellers, parts and NIE; and
- consider revisiting other conceptual, regulatory or wording changes that stem from the Basic Regulation.
Design and Production Organisation holders along with National Competent Authorities are recommended to participate in this rulemaking activity.
28/08/2019 Soft law for Part-21 Level of Involvement, PtF and CO2 emissions
These activities specifically relate to
- the embodiment of level of involvement (LoI), the introduction of the possibility for new privileges for approved design organisations and other amendments to Part 21 that were proposed by EASA in its Opinion No 07/2016 ‘Embodiment of level of involvement requirements into Part-21’;
- the new ICAO aeroplane CO2 standard and the aircraft engine non-volatile particulate matter (nvPM) emissions standard, and the introduction of references to the updates of existing noise and engine emission standards in ICAO Annex 16, as proposed by EASA in its Opinion No 09/2017 ‘Implementation of the CAEP/10 amendments on climate change, emissions and noise’; and
- the need for the issuance of a permit to fly (PtF) for certain maintenance check flights (MCFs), as proposed by EASA in its Opinion No 01/2017 ‘Maintenance check flights’.
We recommend Design organisations fully familiarise themselves with these Decisions to amend their processes and documentation accordingly.
01/08/2019 CAEP/10 Output on Emissions, Noise and Fuel Venting
EASA has published 3 decisions, namely ED Decision 2019/014/R, ED Decision 2019/015/R and ED Decision 2019/016/R that lay out the requirements for amending CS-34 for aircraft emissions and fuel venting, CS-36 for aircraft noise and new AMC/GM for CS-CO2 emissions.
All three of these Decisions aim to provide a high level of uniformity for environmental protection in the EU and is in compliance with ICAO Annex 16 Volume III.
We recommend all design and production organisations, design approval holders and national competent authorities familiarise themselves with these publications.
31/07/2019 Prevention of CFiT for helicopters (TAWS)
Data shows that terrain and obstacle conflict is the second priority key risk area for helicopter offshore operations (HOFO), although equipment is now fitted to helicopters that conduct these operations will significantly mitigate the risk of this outcome. Obstacle collisions is the second most common accident outcome in the helicopter commercial air transport (CAT) domain. This highlights the challenges of helicopter emergency medical service (HEMS) operations and their limited selection and planning for landing sites. Terrain and obstacle conflict is the most common risk for specialised operations (SPO).
This RMT intends to mitigate these risks by establishing the conditions to install and use helicopter terrain awareness and warning systems (HTAWSs) and other CFIT prevention means.
The following aspects will be considered:
- HTAWS and any related functions derived from aeroplane TAWS, including any helicopter terrain awareness warning (H-TAW) and helicopter flight envelope warning (H-FEW) functions.
- Other technologies focusing on increasing the situational awareness of the pilot, including moving maps with obstacle databases.
- Improve situational awareness by enabling the use of NVIS by non-CAT operators.
- Training elements, related to the adoption of such technologies, or as a substitute to their adoption, may also be considered.
Affected stakeholders such as Helicopter operators, designers and manufacturers, NCA’s and those involved in the manufacture of avionic and electronic components and software are recommended to be involved in this rulemaking activity.
16/07/2019 Regular Update to CS-25
EASA has published Appendix 2 to ED Decision 2019/013/R in the form of CRD 2018-05. The NPA was discussing items related to-
- full and unrestricted movement of cockpit controls,
- flap and slat interconnection,
- quantity of available oxygen, and
- ashtrays in the lavatories.
We recommend DAH for large aeroplanes take a look at the changes.
16/07/2019 Certification aspects for the installation and maintenance of data recorders
EASA has published Appendix 1 to ED Decision 2019/013/R which revises the design codes for large aeroplanes and large rotorcraft and aims to enhance the certification specifications for flight recorders on both. This is in response to NPA 2018-03 and summarised in the Comment Response Document (CRD 2018-03).
A number of investigations have found that power to the units could have been interrupted prematurely and therefore changes are made to ensure that the recorders continue to record after the interruption of normal electrical power. A number of other changes are related to start-stop logic, combination recorders, deployable recorders and performance specifications and to better align with the FAR equivalent requirement.
We recommend TC holders, applicants for TC or STC and design organisations for large aeroplanes and rotorcraft to read more specific details which can be found by reviewing the Decision in full by clicking here.
03/06/2019 New regulation amending Initial Airworthiness – (EU) 2019/897
EASA has published Commission Delegated Regulation (EU) 2019/897 which impacts Design Organisations who are applying for TCs, Changes to TCs and STCs and EASA’s Level of Involvment(LOI) during the certification process.
LOI is the selection of the compliance demonstration items (CDI) that EASA will investigate and the depth of those investigations. It is founded on a “risk-based” approach, which can be illustrated as follows:
This important development means that industry must (in the Certification Plan) do the Risk Assessment and propose the LOI based on a meaningful grouping of “Compliance Demonstration Items”.
DOA’s are strongly advised to review their Handbooks to ensure that they remain in compliance with this change to the regulation.
22/05/2019 Regular Update of CS-ETSO
NPA 2019-06, Regular update of CS-ETSO, proposes to introduce new or updated standards for parts. In particular, EASA states that it proposes to:
· modify a number of ETSOs in order to harmonise them with the corresponding FAA TSOs;
· introduce one new ETSO (Index 1) which is, where possible, technically similar to the corresponding FAA TSO; and
· introduce some new ETSOs (Index 2), which either do not exist in the FAA TSO series, or which contain significant technical differences from the corresponding FAA TSOs.
EASA states that the proposed amendments will extend the possibilities of ETSO authorisations for EU applicants and to align CS-ETSO with the state of the art and with European operational requirements.
They further state that these changes will ensure a level playing field for European manufacturers, and will increase the cost-effectiveness of compliance demonstrations.
We recommend all production organisations involved with the manufacture of parts to review this NPA and comment where necessary prior to the closing date of the 7th August 2019 to ensure your voices are heard.
30/04/2019 Provision of airworthiness requirements in support of global performance-based navigation operations
EASA has published the Comment Response Document for the Provision of airworthiness requirements in support of global performance-based navigation operations – Namely CRD 2018-02. This CRD relates to ED Decision 2019/011/R discussed above.
The consultation phase started with the publication of NPA 2018-02 on 22 February 2018 and finished on 31 May 2018, after an extension of approximately one month, upon request of some interested stakeholders. During the consultation period, 537 comments were submitted by the interested parties.
30/04/2019 Amended CS for the Provision of airworthiness requirements in support of global performance-based navigation (PBN)
ED Decision 2019/011/R amends the Initial Issue of the certification specifications for Airborne Communications, Navigation and Surveillance (CS-ACNS). Issue 2 of CS-ACNS incorporates a new section on PBN within Subpart C – Navigation (NAV) and includes minor amendments to part of the existing requirements. This Decision also simplifies the number and structure of the existing EASA references for PBN type certification by including all the PBN certification requirements in CS-ACNS and cancelling AMC 20-4A, AMC 20-5, AMC 20-12, AMC 20-26, AMC 20-27A and AMC 20-28 for new applications. With regard to RNAV 1, JAA TGL 10 Rev 1 is no longer recognised by EASA for any type certification applications after CS-ACNS Issue 2 enters into force.
The objective of this Decision is to provide up-to-date certification specifications so as to permit aircraft to be certified to the appropriate airworthiness standards and fly performance-based navigation based on any of the ICAO recognised RNP navigation specifications, namely RNP 4, RNP 2, RNP 1, A-RNP, RNP APCH, RNP AR, and RNP 0.3. The new certification specifications will permit aircraft to benefit from the global implementation of PBN routes and approach procedures and, in particular, those specified in airspace usage requirements regulation.
The PBN requirements in CS-ACNS are expected to facilitate the processes that are followed by the applicants to obtain their certificates, as one single certification process could be used to demonstrate compliance with several navigation specifications and the necessary functionalities. CS-ACNS will contribute to transparency and reduce the use of certification review items (CRIs) or special conditions (SCs) as the whole set of recognised ICAO RNP specifications is now addressed. In addition, and although area navigation (RNAV) specifications are not specifically addressed, CS-ACNS considers the possibility of granting airworthiness certification for the RNAV specifications when applying for RNP certification, provided that certain criteria are met.
17/04/2019 Embodiment of safety management system (SMS) requirements into Part 21
With reference to Rulemaking Task (RMT).0251 Phase, NPA 2019-05 proposes amendments to Part-21 and Part-145, in order to:
- introduce safety management principles that implement ICAO Annex 19; and
- foster an organisational culture for effective safety management and effective occurrence reporting in accordance with Commission Regulation (EU) No 376/2014.
Note 1: Phase I of RMT.0251 was limited to the introduction of safety management requirements into Part-CAMO (see our previous articles relating to Opinion No 06/2016).
Note 2: The review of the occurrence reporting system was governed by RMT.0681, but certain additional changes are proposed through this RMT, in light of the principles of ICAO Annex 19, Chapter 5.
This NPA proposes to consider the applicability of safety management systems to Part-145 approved maintenance organisations, as well as to production and design organisations that are approved in accordance with Subparts G and J of Part 21.
By doing so, safety will be enhanced through:
- the establishment of safety policies and objectives that are associated with sufficient resources;
- the systematic identification of hazards, and a risk management system;
- the safety assurance system, including giving consideration to safety performance; and
- safety promotion.
The RMT also aims to streamline the procedures for oversight, and introduce a set of new, common management system requirements for competent authorities to increase their efficiency.
NPA 2019-05 is divided into three parts.
NPA 2019-05 (A) includes:
- the procedural information pertaining to the regulatory proposal;
- the explanatory note to the proposed amendments;
- the regulatory impact assessment; and
- a detailed summary of the proposed amendments (see Chapter 7 ‘Appendices’).
NPA 2019-05 (B) proposes:
- the draft implementing acts (IAs) as well as the draft AMC and GM for Part 21.
NPA 2019-05 (C) proposes:
- the draft implementing acts (IAs) as well as the draft AMC and GM for Part-145.
This significant rulemaking is aligning thinking around the management of safety and integrating it into the normal business of Design, Production and Maintenance organisations. It will align regulatory requirements with CAMO’s and Operators, driving towards the Integrated Management System. It is strongly recommended that all DO, PO and MO’s review this NPA and submit comments through the Comment Response Tool prior to the deadline of 17th July 2019.
04/04/2019 CRD 2018-10 published relating to CS-STAN - Issue 3
EASA has published CRD 2018-10 summarising the outcome of the consultation for NPA 2018-10 as part of the regular update for CS-STAN. It has amended repairs and changes as well as introducing new changes. ED Decision 2019/010/R discussed above details the specific changes.
04/04/2019 CS-STAN is now at Issue 3
ED Decision 2019/010/R introduces the following amendments to CS-STAN:
· it provides additional clarification in Subpart A ‘General’ regarding the use of CS-STAN;
· it introduces new standard changes and updates some existing ones; and
· it introduces new standard repairs and updates some existing ones.
The amendments introduced by this Decision are based on lessons learned during the utilisation of CS-STAN, proposals submitted by stakeholders, and on technological innovations that came from the industry, which can bring safety benefits or allow the implementation of the latest technologies in a cost-efficient manner.
These amendments are expected to provide economic benefits to the general aviation (GA) community by reducing the regulatory burden for the embodiment of changes and repairs in certain aircraft when applying the acceptable methods, techniques and practices included in CS-STAN. These amendments are not expected to have any significant social or environmental impacts.
03/04/2019 CRD 2017-20 Embodiment of the level of involvement acceptable means of compliance and guidance material in Part 21
As a number of changes have been introduced to the text proposed by EASA in Opinion 07/2016, some AMC/GM need to be amended in order to remain aligned with Part 21. NPA 2019-03 contains the proposed amendments to the affected AMC/GM.
After the public consultation of NPA 2019-03, EASA will issue a decision that contains amendments to the AMC/GM to Part 21.
03/04/2019 Embodiment of the level of involvement acceptable means of compliance and guidance material in Part 21
The objective of NPA 2019-03 is to complement NPA 2017-20 ‘Embodiment of level of involvement acceptable means of compliance and guidance material to Part-21’ that was released in December 2017 in supporting the embodiment of level of involvement (LoI) and other amendments to Part 21 that were proposed by EASA in its associated Opinion of May 2016.
At the time of publication of that earlier NPA, the proposals for the amendment of Part 21 that were made in the Opinion were still under review by the European Commission. In the meantime, the European Commission has developed a draft regulation, based on the EASA Opinion.
As a number of the changes that have been introduced alter the text that was proposed by EASA in Opinion No 07/2016, some of the AMC and GM that were proposed are no longer aligned with the amendment of Part 21 and need to be amended. Other points in Part 21 now require new AMC/GM that were not proposed previously.
The specific objective of this NPA is therefore to enable consultation to take place on those amended or new AMC/GM to Part 21.
We strongly recommend that design approval holders in the EASA system fully familiarise themselves with the amendments and the content of this NPA against previous rulemakings.
01/03/2019 Potential uncontrollable fires in cargo compartments
EASA has published NPA2019-02 on the subject of Class D compartments of large aeroplanes used for CAT to address the issue of potential uncontrollable fires. This includes the fires that result from thermal runaways of lithium batteries.
It proposes, through an amendment of Part-26/CS-26, to require operators, whose in-service large aeroplanes used for CAT contain Class D cargo or baggage compartments, to apply to those aircraft:
- the standards applicable to Class C compartments, if the aeroplanes are involved in the transport of passengers, or
- the standards applicable to either Class C or Class E compartments, if the aeroplanes are only involved in all-cargo operations.
If a regulation is introduced to amend Part-26 to require these changes, the resulting conversions of the Class D compartments would need to be performed within three years of the entry into force of that regulation. It is understood that this could affect up to 500 large aeroplanes in operation within EASA member states.
EASA expects that the proposed changes will increase safety by mitigating the risk of uncontrollable fires in Class D cargo or baggage compartments, and improve harmonisation with the FAA.
This NPA is open for comment until the 1st June 2019. We recommend POA holders and operators to review this NPA in detail and comment as required.
27/02/2019 ED Decision – Additional Airworthiness Requirements – CS26 Issue 2
Regulation (EU) 2019/133 was issued earlier this year. It introduces additional airworthiness requirements for operations applicable to certain large aircraft that are newly produced on the basis of a design which has already been certified by EASA. Some of those requirements are also applicable to certain large aeroplanes that are already in service.
The new requirements that are introduced into Part-26 are intended to address the issues of the:
- crashworthiness of passenger and cabin crew seats (16-g seats);
- flame propagation and flame penetration resistance characteristics of thermal or acoustic insulation materials; and
- replacement of halon in lavatory waste receptacles and handheld (portable) fire extinguishers for use in cabins and crew compartments.
This Decision amends CS-26 by providing means to comply with the new requirements
22/02/2019 Aircraft Cybersecurity NPA
NPA 2019-01 relating to Aircraft Cybersecurity has been published on the EASA website. EASA state that the objective is to mitigate the potential effects of cybersecurity threats on safety. Such threats could be the consequences of intentional unauthorised acts of interference with aircraft on-board electronic networks and systems.
This NPA proposes amendments to a range of Certification Specifications (CS’s) and, as applicable to their related AMC/GM, together with AMC-20. The amendments would introduce cybersecurity provisions into the relevant CS’s, taking into account the existing special conditions (SC’s) and the recommendations of the Aviation Rulemaking Advisory Committee (ARAC) regarding aircraft systems information security/protection (ASISP).
The proposed amendments are expected to contribute to updating the EASA CS’s to reflect the state of the art of protection of products and equipment against cybersecurity threats. They are also expected to improve harmonisation with the FAA regulations.
The consultation period for this rulemaking is now open until the 22nd May 2019, so we recommend TC/STC/ETSO applicants to fully engage with the process.
22/02/2019 CRD for In-flight recording for light aircraft
EASA has published the Comment Response Document relating to NPA 2017-03 on the subject of In-flight recording for light aircraft. In all there were 108 comments received from 20 commentators with the vast majority coming from NCA’s.
22/02/2019 CRD for Non-ETOPS operations for aircraft of 19 seats or less
EASA has published the Comment Response Document relating to NPA 2017-15 on the subject of Non-ETOPS operations using performance class A aeroplanes with a maximum operational passenger seating configuration of 19 or less. In all there were 23 comments received from 10 commentators with the vast majority coming from NCA’s.
22/02/2019 CRD for aeroplane performance requirements
EASA has published the Comment Response Document relating to NPA 2016-11 on the subject of aeroplane performance for CAT. In all there were 357 comments received from 39 commentators with the vast majority coming from OEM’s and organisations. Operators, NCA’s and individuals made up the balance.
13/02/2019 Soft Law update to Part-21 - ELA
EASA has published their Decision, ED Decision 2019/003/R It introduces new Acceptable Means of Compliance (AMC) for Part-21 production and design organisation approvals, which complement the existing AMC. They state that the objective is to provide a more proportionate approach for small, non-complex organisations that produce lower-risk products and the parts installed on these products.
The new AMC shifts the focus of both the applicant and the competent authority onto the effects on the output of the process, instead of the focus being on the detailed step-by-step documentation of the process. This is a more product-oriented approach. It also provides for more proportionality for the affected organisations, without, they predict, having any impact on the level of safety. It is avoiding an over-burdensome and disproportionate administrative application of regulations for these small and simple organisations.
The AMC can also serve as the baseline when a means of compliance with the Subpart G and J requirements needs to be developed outside the applicability of the AMC. In that case, EASA recommend that coordination is needed between the applicant and the competent authority to review and, when necessary, to complement the baseline with more stringent or detailed processes or procedures so as to provide a consistent and acceptable result.
The AMC can be used by small companies that design and produce low-risk general aviation (GA) aircraft within the current Part-21. The AMC also allows experience to be gained for a possible future combined (design and production) company approval. It is anticipated that it will be used until amendments to Part-21, based on the changes brought about by the new Basic Regulation (Regulation (EU) 2018/1139), allow for new concepts for a more proportionate regulatory system. At that point, the current AMC may need to be revisited.
Any Design, production and maintenance approval holders and owners of ELA / simple aircraft are recommended to review these changes to see how they may be affected.
17/12/2018 Design Code amendments for rotorcraft
EASA has published decision ED Decision 2018/015/R that amends the design codes for CS-27, CS-29 and CS-VLR.
They state that the objective is to provide cost-efficient rules in the field of rotorcraft certification and thereby at the same time maintain a high level of safety. This Decision creates new or amends existing AMC to the CSs for very light, small and large rotorcraft that deal with the following topics:
- External Loads
- Flight and navigation instruments
- Certification of rotorcraft avionics equipment
- Guidance for rotorcraft Night Vision Imaging System (NVIS) aircraft lighting systems
- Guidance on analysing an Advanced Flight Controls (AdFC) System
- Guidance on creating a system level Functional Hazard Assessment (FHA)
- Installation of Automatic Flight Guidance and Control Systems (AFGCS) in rotorcraft.
The amendments are expected to improve harmonisation through greater alignment with the latest versions of the equivalent FAA ACs 27 -1B and 29-2C. Where necessary, an EASA-specific AMC has been developed in order to align with EASA's interpretation of the CSs to which the AMC relates.
We recommend rotorcraft manufacturers review these latest changes as they became effective in late December.
14/12/2018 CS-E Amendment 5
The objective is to maintain a high level of safety for aircraft engines and ensure that it reflects current technology and the latest status of the Certification Specifications for Engines (CS-E). This amendment, amendment 5, aims to improve the ability of aeroplane turbine engines to cope with the ingestion of birds that can reasonably be expected to be experienced during the service life of an engine. In addition, it includes the incorporation or improvement of the CSs and the related acceptable means of compliance (AMC) for:
- a ‘30-Minute Power’ rating;
- the fireproofing of engine mounts;
- ignition and relighting in flight;
- engine casing strength;
- transient fuel icing conditions;
- rain and hail ingestion;
- compressor and turbine blade failures; and
- compressor, fan and turbine shafts.
Overall, it is expected that this will improve safety and maintain harmonisation with the US FAA Part 33 regulations.
We recommend all engine manufacturers to familiarise themselves with this update.
26/11/2018 Additional easy access rules for Initial Airworthiness
EASA has published further support to facilitate stakeholders access to eRules for Initial Airworthiness by publishing the Easy Access Rules in the following eight categories:
- Light Sport Aeroplanes (CS-LSA)
- Propellers (CS-P)
- Very Light Aeroplanes (CS-VLA)
- Very Light Rotorcraft (CS-VLR)
- Engines (CS-E)
- European Technical Standard Orders (CS-ETSO)
- Large Aeroplanes (CS-25)
- Acceptable Means of Compliance for Airworthiness of Products, Parts and Appliances (AMC-20)
These Easy Access Rules include all amendments and are displayed in a consolidated, easy-to-read format with advanced navigation features through links and bookmarks, and are available for free download from the EASA website.
09/11/2018 Unintended or inappropriate rudder usage
In summary EASA received 52 comments from 14 stakeholders. The commentators included aeroplane manufacturers (Airbus, Boeing, Bombardier, Dassault, Embraer, Gulfstream, Textron), one flight test organisation (DGA Essais en vol), national aviation authorities (DGAC France, LBA Germany, TCCA Canada, CAA UK), Eurocontrol, and one individual (Professor at the Hochschule Osnabrück, Germany).
The most substantial comments came from some aeroplane manufacturers (Textron, Embraer, Airbus, Dassault, and Bombardier) who repeated their position with regard to the proposed new yaw manoeuvre load condition, i.e. recommending a single rudder pedal doublet instead of the double rudder pedal doublet proposed in NPA 2017-18. Boeing and Gulfstream did not object to the EASA position, as was also the case during the consultation of the equivalent EASA Special Condition at the end of 2015. The comments received did not bring any new element that would justify a change of the EASA position, therefore EASA maintains the new CS 25.353 that includes a double rudder pedal doublet condition.
Other comments were aimed at clarifying or improving the proposed changes, or at supporting the NPA.
EASA also liaised with the FAA, and this has led to a few additional changes to improve the regulatory text while seeking for harmonisation, without changing its essence.
07/11/2018 Reduction of runway excursions
Last month we reported on NPA 2018-12 with the objective to address the safety issue of runway excursions that occur during landings. This NPA proposes to require the installation of a runway overrun awareness and alerting system on new large aeroplane designs (CS-25), and on certain new large aeroplanes operated in commercial air transportation (CAT), and manufactured after a predetermined date (Part-26/CS-26).
EASA has extended the deadline for comments until 25th January 2019.
25/10/2018 Evidence Based Training – NPA 2018/07 – consultation period extended
Further to our article on this subject from July this year, EASA has extended the consultation period of both Sub-NPA 2018/07(A) and Sub-NPA 2018/07(B) until the 14th November 2018. We recommend organisations approved to or national competent authorities with oversight of Part-ORO, Part-ARO, Part-FCL and Part-ARA make use of these extra few days to review and submit their comments prior to the new deadline.
15/10/2018 Reduction of runway excursions
For the last few decades, runway excursions have been recognised as major contributors to accidents worldwide, and as significant risks to aviation safety. Recently, on-board systems have been developed that are able to significantly contribute to reducing the number of those events that occur, and in particular, those that occur longitudinally during landings (as statistically, around 80 % of the reported runway excursions occur during landings). These systems, can be installed on new designs of large aeroplanes, and also on existing already certified designs of large aeroplanes. In flight, such a system is typically able to provide a timely alert to the flight crew if the calculated stopping point is beyond the end of the runway.
After touch-down, the system is able to provide a timely alert to the flight crew if the measured deceleration is not sufficient to bring the aeroplane to a safe stop before the end of the runway. This NPA proposes certification standards for such systems, and their mandatory installation on new designs and all newly produced large aeroplanes to be operated in commercial air transport. For more detailed analysis of the issues addressed by this proposal, please refer to Section 4.1. of the RIA, ‘Issues to be addressed’
EASA has published a Notice of Proposed Amendment (NPA 2018-12) with the objective to address the safety issue of runway excursions that occur during landings. This NPA proposes to require the installation of a runway overrun awareness and alerting system on new large aeroplane designs (CS-25), and on certain new large aeroplanes operated in commercial air transportation (CAT), and manufactured after a predetermined date (Part-26/CS-26).
EASA states that the proposed changes are expected to increase safety by supporting the flight crew during the landing phase in identifying and managing the risk of a runway excursion. This should reduce the number of runway excursions that occur during landings.
15/10/2018 Rotorcraft designs - Enhancement of the safety assessment processes
The safety assessment of the design of rotorcraft systems and equipment is used to identify the presence of hazards in the design, and also to help rotorcraft designers to put in place means to eliminate the identified hazards or mitigate the associated safety risks. Technology and techniques have evolved since the inception of formal safety assessment processes and their introduction into the CSs, and it is, therefore, necessary to maximise the probability that potential safety issues are identified during the development of a new design, in accordance with state-of-the-art safety assessment processes.
The European specifications for safety assessment for rotorcraft are currently contained in CS 27.1309 and CS 29.1309, and their associated Acceptable Means of Compliance (AMC).
Industry has developed extensive recommended practices for development assurance and safety assessment such as ED-79A/ARP4754A and ARP4761. ED-79A/ARP4754A is today recognised by the FAA in AC 20-174. The AMC to CS 27.1309 and CS 29.1309 do not, however, reference ED-79A/ARP4754A as an acceptable method for establishing a development assurance process. This results in additional effort for industry and EASA during the certification phase to identify and manage the safety risks, and to finally ensure that rotorcraft designs reach a minimum and acceptable safety level.
In December 2016, following the publication of CS-27/CS-29 Amendment 4, the safety assessment provisions contained in CS 27/29.1309 and the associated AMC (including the references to standards) were fully aligned with FAR 27 and 29 (and FAA AC 27-1B and 29-2C).
Since then, the FAA has published a Policy Statement entitled ‘Safety Continuum for Part 27 Normal Category Rotorcraft Systems and Equipment’ that provides a graduated scale of safety objectives for normal (small) rotorcraft. The FAA Policy Statement defines lower safety objectives than those currently contained in FAA AC 27-1B in order to facilitate the introduction of new technology, and thus it improves overall safety by defining new sub-classes for normal category rotorcraft. These sub-classes are used for establishing the certification standards for systems and equipment. The criteria for defining these subclasses are based on the aircraft weight, the engine type and count, and the maximum number of occupants. During the development of the changes to CS 27/29.1309, any potential difference in the regulatory systems between the FAA and EASA will need to be carefully considered and coordinated to avoid an increase in the validation effort required to certify rotorcraft between certification partners, and to avoid the need for any subsequent changes to the type design.
The FAA has also developed and proposed changes to Part 27/29.1309, which were published as a Notice of Proposed Rulemaking (NPRM) in November 2017. The changes proposed by the FAA are intended to allow more flexibility in the types of assessments that the applicant can provide to show compliance, to remove the distinction between category A and category B rotorcraft since the technologies and associated failure effects are similar across both categories, and to reflect the fact that equipment and systems installed in Part 27 rotorcraft are now complex and highly integrated systems.
EASA states that these changes, if implemented as proposed, will create significant standard differences between the EASA and FAA CSs, and are likely to result in a lower level of regulatory efficiency. This RMT is intended to review these changes and to maximise harmonisation.
The associated NPA is expected to be published in Q3 2019 with a decision planned for Q1 2020.
All Rotorcraft Design and Manufacturing organisations are recommended to review this important rulemaking activity.
12/09/2018 Soft Law for certifying staff type rating training
EASA has published NPA 2018-11 relating to the Certification Specifications (CS) and Guidance Material (GM) for maintenance certifying staff type rating training with the objective of improving the level of safety related to the minimum syllabus of maintenance certifying staff (MCS) type rating training (TRT), enabling design approval holders (DAHs) that comply with Part 21 to identify the technical elements necessary to be addressed for the purpose of training of maintenance certifying staff involved in the maintenance of their products.
In addition, EASA state the intent is to ensure an adequate minimum syllabus standard at organisations that comply with Part-147.
This NPA proposes:
- the first issue of Certification Specification on MCS data (CS-MCSD) and the associated Guidance Material (GM);
- the amending text for the GM to Part 21 applicable to Operational Suitability DATA (OSD)-MCSD that establishes guidance for the classification of changes to OSD-MCSD in accordance with Part 21.A.
EASA expects that these proposals will enhance safety and mitigate risk related to maintenance errors due to inadequate training and to establish a TRT minimum standard.
We recommend TCH’s, Restricted TCH’s, STCH’s, Part-147 Organisations, regulators and Part-66 licence holders to review this NPA and comment through the Comment Response Tool prior to the deadline of 18th December 2018.
11/09/2018 Regular update of CS-STAN
NPA 2018-10 has been released relating to the latest update to the Certification Specifications for standard changes & standard repairs. It is now at Issue 3. There are numerous changes and repairs either introduced or amended. Due to the number of amendments and new changes, we recommend those involved in the maintenance of or operation of GA aircraft take a look at the NPA in detail so that comments can be submitted prior to the deadline of 11th December 2018.
05/09/2018 Standardised criteria for aeroplane level safety assessments
It also contains the draft resulting CS-25 text.
Compared to the NPA 2014-02 proposal, several changes have been made to the proposed CS/AMC 25.1309 (system safety assessment) and CS/AMC 25.671 (flight control systems) to clarify various elements based on the comments received while keeping the main elements of the NPA proposal. Some provisions have also been added to address controllability during ditching with no engine power. Concerning the changes to the domain of structure, the proposed amendments to CS 25.629(b), AMC 25.629 and Appendix K are withdrawn; however, the proposed amendments to CS 25.629(d) are maintained. Finally, the proposed amendments concerning reversing systems in CS/AMC 25.933 are maintained.
Stakeholders are invited to review the draft resulting text (Appendix B) and provide reactions, if any.
EASA will then prepare the next amendment of CS-25, taking into account the reactions received, if any.
Reactions are to be submitted via the Comment Response Tool prior to 5th November 2018.
31/08/2018 Human Factors in rotorcraft design
Human factors may contribute either directly or indirectly to aircraft accidents and incidents, and the design of a flight deck and its systems can strongly influence the performance of the crew and the potential for crew errors.
Currently, the certification specifications (CSs) for rotorcraft do not contain any specific provisions for a human factors assessment to be carried out. New generation helicopters are characterised by having a high level of integration of cockpit equipment, displays, controls and automation. It is also likely that future rotorcraft projects, embodying, for instance, fly-by-wire technology flight controls that include enhanced piloting control laws, will pose new and additional challenges from a human factors perspective.
Large transport aircraft have benefited from human factors assessments of the design of their flight decks and their associated systems. The purpose of this RMT (RMT.0713) is to deliver an effective and proportionate set of CS amendments that address human factors in rotorcraft design.
The availability of CSs for human factors in the design of new rotorcraft cockpits is expected to reduce the probability of human factors and pilot workload issues that could lead to an accident or incident.
27/08/2018 Integrated Modular Avionics – Comment Response Document
Further to last years NPA 2017-11, EASA has published the Comment Response Document (2017-11) detailing all comments received along with their responses. All in all, 135 unique comments were received from 19 stakeholders. In general, the commentators were supportive of the proposed amendments to CS-ETSO.
For full details of all comments, please refer to CRD 2017-11
Appendix to ED Decision 2018/008/R provides full details of the changes to CS-ETSO amendment 14 and AMC20 amendment 15.
24/08/2018 EASA and FAA harmonisation – AMC20 & FAA AC-20
NPA 2018-09 is a joint proposal by EASA and the FAA to harmonise both the EASA AMC-20 and FAA AC-20 documents, as follows:
- create a new EASA AMC 20-152A, amend the FAA AC 20-152, and create a new FAA AC 00-72, on the development of airborne electronic hardware (AEH);
- create a new EASA AMC 20-189, new FAA AC-20-189 and AC 00-71, on the management of open problem reports (OPRs).
Both EASA and the FAA say that the proposed changes to the documents would significantly increase the harmonisation, have no safety, social or environmental impacts, and provide economic benefits by streamlining the certification process.
Any organisations involved in the design and/or the manufacture of AEH and associated equipment are recommended to familiarise themselves with these proposed changes and submit their comments via the EASA Comment Response Tool by the deadline of 5th October 2018.
22/08/2018 Regular Update of CS-MMEL and CS-GEN-MMEL
EASA has published a regular update to the Certification Specifications for the development of the MMEL for CMPA and other-than-CMPA. This regular update through the publication of NPA 2018-08
In particular, this NPA proposes amendments to the following items:
- Item 1: Generic safety methodology for the development of MMEL candidate items
- Item 2: Quantitative assessment criteria for aircraft certified against requirements other than CS 25/29.1309.
- Item 3: Engine time limited dispatch (TLD) update
- Item 4: Updated guidance for items involved in non-normal and emergency procedures
- Item 5: Clarification of the applicable MMEL operational suitability certification basis.
- Item 6: Additional and updated definitions
- Item 7: Updated and new items in MMEL ITEMS GUIDANCE BOOK (CS-MMEL)
- Item 8: Editorial corrections to CS-MMEL
- Item 9: Update of CS-GEN-MMEL and CS-MMEL applicability.
EASA expects that the proposed amendments will contribute to updating CS-MMEL and CS-GEN-MMEL to reflect the state of the art of MMEL certification. Overall, they expect the changes will provide a moderate safety benefit, have no social or environmental impacts, and are expected to provide some economic benefits by streamlining the certification process.
We recommend those organisations involved with the design of or changes to CMPA and other-than-CMPA to fully review the NPA and submit comments via the EASA Comment Response Tool prior to the submission deadline of 22nd October 2018.
13/07/2018 All Weather Operations (AWO) NPA
NPA 2018-06 has been issued to modernise the EU aviation regulatory framework applicable to all-weather operations (AWOs). It is intended to address in a coordinated manner all relevant disciplines: initial airworthiness, air operations, flight crew licensing and aerodromes. It proposes a performance- and risk-based approach, as much as feasible, considering also the appropriate balance between performance-based and prescriptive principles (depending on the type of air operations (CAT, NCC, NCO, and SPO).
This NPA proposes to update the AWO-relevant rules in many aviation domains such as airworthiness, air operations, aircrew and aerodromes. The main aim has been to allow for a better integration of the regulatory requirements related to the operational use of new, advanced technology — either developed already or to be developed in the future — such as, for example, enhanced flight vision system (EFVS), as well as the application of some advanced new operational procedures, which may support AWOs.
Significant focus has been invested in developing resilient rules, which are not technology-dependent. A particular attention was paid to the development of requirements enabling the use of EFVS to the maximum extent possible (e.g. use of EFVS for landing). A new concept of ‘light operational credits’ for EFVS 200 operations, not requiring the use of specific low-visibility procedures (LVPs), has also been introduced.
EASA expects that the proposed changes will maintain safety, reduce the regulatory burden, increase cost-effectiveness, improve harmonisation (e.g. with the Federal Aviation Administration (FAA)), and achieve as much as feasible alignment with the ICAO SARPs.
NPA 2018-06 is divided in four parts.
- sub-NPA(A) – the procedural information pertaining to the regulatory proposal
- sub-NPA(B) – initial airworthiness (CS-AWO);
- sub-NPA(C) – air operations and aircrew; and
- sub-NPA(D) – aerodromes.
We recommend that Air Operators, Design Approval Holders, Maintenance Organisations, Approved Training Organisations, Aerodrome Operators and ATM/ANS thoroughly review these documents to make informed comments via the EASA Comment Response Tool prior to the closing date for comments which is 15th October 2018.
25/06/2018 Soft Law updates for CS-27/29
EASA has published its revised soft law, through Amendment 5 to CS and AMC for CS-27 and CS-29. The decision amends both CS-27 and CS-29. EASA says that it:
- Improves the probability of survival for occupants in the event of either a helicopter ditching or a survivable water impact. This is achieved by introducing a new flotation stability certification methodology that takes into account the sea conditions for which certification is requested. In addition, the structural ditching provisions have been refined and the physical requirements for emergency exits and seating have been improved to enable occupants to make their escape in the event of either a ditching or a capsize as a result of a survivable water impact. Furthermore, the provisions for emergency flotation systems (EFSs), emergency and survival equipment, and emergency locator transmitters have been enhanced; Comment Response Document 2016-01 refers.
- clarifies the CSs for external loads that are applicable to personnel-carrying device systems (PCDSs) by clearly differentiating between simple and complex PCDSs, and that only complex PCDSs require certification. Furthermore, it provides AMC for external loads, and includes a definition of complex PCDSs and guidance on the appropriate methodology for applicants to certify simple PCDSs if they elect to include simple PCDSs within the scope of type certification;
- Improves the safety assessment of pressurised lubrication systems and the certification and development testing specifications for the ‘loss of lubrication’ condition in order to substantiate a maximum period of continued operation which can be included in the rotorcraft flight manual (RFM) emergency procedures Comment Response Document 2017-07 refers.
Rotorcraft manufacturers and offshore operators are recommended to review these revisions and update procedures and processes as required.
25/06/2018 Helicopter ditching CRD
EASA has published the Comment Response Document 2016-01 in relation to Heli ditching and water impact occupant survivability. In response to NPA 2016-01 reported on here in March 2016, numerous comments were received by EASA which led to some changes to the CSs that were proposed. An explanation of how the comments affected the final text of the CSs and associated AMC can be found here. The comments that were received can be summarised into the following areas:
Proportionality for rotorcraft that only require emergency flotation systems
Some commenters stated that the proposed requirements for specific load requirements and for the water entry behaviour of the rotorcraft to be substantiated for an emergency flotation system (EFS) (not full ditching certification) were excessive for rotorcraft that would only fly over non-hostile sea areas and that there was a need for greater proportionality. Furthermore, it was pointed out that the use of FAA AC material (MG10) as AMC to set certification requirements was inappropriate.
Irregular wave testing specification
Comments were received from industry relating to uncertainty as to how to implement the probabilistic capsize resistance test specification in practice.
Post-capsize survivability features
A significant number of comments were received during the consultation of NPA 2016-01 regarding the ‘post-capsize survivability features’. Some stakeholders considered that the proposed amendment was too prescriptive, as the only identified means of compliance in the AMC was the provision of an ‘air pocket’, and another design (emergency breathing systems) was specifically ruled out.
Some stakeholders also challenged the technical feasibility of providing an ‘air pocket’ through the enhancement of the EFS. A number of technical challenges were identified, and these include the potential for:
- inadvertent deployment of the modified EFS, resulting in a catastrophic event (e.g. flotation units needing to be closer to the main rotor to achieve the required floating attitude);
- hot exhaust gases acting upon the flotation units’ stowage location(s), setting unachievable standards for material selection;
- aerodynamic disturbance in the complex area close to the main rotor due to the protruding volume for the higher-mounted stowed flotation units;
- the need to design for potential damage to a high-mounted flotation unit by the main rotor immediately after inflation and before the main rotor has stopped turning.
In their comments, helicopter designers expressed serious concerns about the above items, and particularly in regard to the introduction of an additional catastrophic hazard. The main concern related to the potential for the inadvertent deployment of a high-mounted flotation unit close to the main rotor. Helicopter manufacturers stated that the technical challenge posed by needing to design a device with high integrity to prevent any inadvertent deployment in the vicinity of the main rotor was excessive.
Definitions and terminology
Comments were received on the definition of a ditching itself. Comments were also received requesting to clarify the use of the term ‘ditching emergency exit’. This term has existed for many years in CS-27 and CS-29, and is used when specifying the additional exit requirements for rotorcraft certified with ditching provisions.
A significant number of comments were received on the ability to interpret the structural ditching provisions and the terminology that was proposed.
Comments were received on the appropriateness of a CS provision for under-fuselage chevrons on all rotorcraft certified for emergency flotation or full ditching. Some commenters proposed that this should be a helicopter offshore operations (HOFO) operational requirement within the Air OPS Regulation.
25/06/2018 Rotorcraft gearbox loss of lubrication
The comments that were received during the consultation period were, in general, supportive of the proposed amendments. More detailed comments from stakeholders were taken into account to improve the certification specifications and AMC through changes in the structure of the text and additional clarifications. These included clarification of which gearboxes should be considered and refinement in the means to determine the maximum period of operation following loss of lubrication. In response the CS-29 text and associated acceptable means of compliance was restructured to be more logical and improve the readability of the document. In addition, the methodology for the determination of the maximum period of operation following loss of lubrication was further refined based upon the comments that were received.
22/06/2018 Initial Airworthiness Easy Access Rules
EASA has released a range of Easy Access Rules relating to environmental issues such as
- CS-36 Aircraft Noise,
- CS-34 Engine Emissions,
- CS-29 Large Rotorcraft,
- CS-27 Small Rotorcraft,
- CS-23 Utility, Aerobatic and Commuter Aeroplanes
- CS-22 Sailplanes and Powered Sailplanes
For full details and to view these documents, click here
18/06/2018 Regular Update of CS-25
EASA states that the specific objective of this NPA is to propose amendments to CS-25 following the selection of non-complex, non-controversial and mature subjects.
In particular, itproposes amendments to the following items:
Item 1: Full and unrestricted movement of cockpit controls. It is proposed to create a new AMC 25.777(c) to clarify the intent of CS 25.777(c) requiring that flight crew of different stature be able to adequately and simultaneously command full differential brakes and full rudder in the same direction.
Item 2: Flap and slat interconnection. It is proposed to amend AMC 25.701(d) to correct the reference to FAA AC 25-14, ‘High Lift and Drag Devices’ as an acceptable means of compliance with CS 25.701(d).
Item 3: Ventilation. It is proposed to fully harmonise CS 25.831(a) with FAA FAR 25.831(a), and to amend AMC 25.831(a) to add acceptable means of compliance for operations without air conditioning.
Item 4: Quantity of available oxygen. It is proposed to amend CS 25.1441(c) by introducing an exception applicable to oxygen chemical generators or small sealed, one-time use, gaseous oxygen bottles. A new AMC 25.1441(c) is also proposed regarding the design and maintenance of these sources of oxygen supply to ensure that oxygen is actually available.
Item 5: ashtrays in the lavatories. It is proposed to amend CS 25.853(g) and harmonise it with FAA FAR 25.853(g), i.e. by deleting the requirement to install ashtrays inside lavatories. The proposed amendments are expected to contribute to updating CS-25 (Book 1 and Book 2) to reflect the state of the art of large aeroplane certification and improve the harmonisation of CS-25 with the Federal Aviation Administration (FAA) regulations. Overall, this would provide a moderate safety benefit, would have no social or environmental impacts, and would provide some economic benefits by streamlining the certification process.
For a full detailed understanding of these proposed changes, we encourage design organisations of large aeroplanes to review NPA 2018-05 and submit your views through the EASA CRT by the deadline of 18th September 2018
23/04/2018 ICA’s - Instructions for Continued Airworthiness
Further to our article published in January relating to NPA 2018-01 aimed at mitigating the risks linked to the uncertainty of the status of instructions for continued airworthiness (ICA), EASA has extended the consultation period by a month until May 30th 2018.
If you haven’t had the opportunity to review the NPA yet, we recommend that you do as soon as possible and submit your comments via EASA’s Comment Response Tool by the end of May.
09/04/2018 Regular Update of CS-MMEL
This rulemaking task (RMT) aims to update the CS and GM for Master Minimum Equipment List (CS-MMEL) and related CS-GEN-MMEL and SC-CS-GEN-MMEL-H in order to reflect the state of the art and best practices.
On a regular basis, EASA will:
- select subjects meeting the criteria of the objectives above;
- publish an NPA proposing an amendment to CS-MMEL and related CS-GEN-MMEL and SC-CS-GENMMEL-H whenever enough subjects are available;
- prepare a Comment-Response Document (CRD); and
- publish the CRD together with an ED Decision amending CS-MMEL and related CS-GEN-MMEL and SC-CS-GEN-MMEL-H.
We encourage all design organisations of CMPA and other design organisations dealing with changes or supplemental type certificates to these aircraft to review the latest information and how it may affect their compliance obligations.
27/03/2018 Specification improvements of Flight Data Recorders
NPA 2018-03 has been published which EASA say aims to improve the availability and the quality of data recorded by flight recorders, in order to better support safety investigations of accidents and incidents.
This NPA proposes to enhance and modernise the specifications for the installation of flight recorders on board large aircraft, and addresses the following subjects:
- cockpit voice recorder (CVR) power supplies;
- automatic stopping of the recording after a crash;
- combination recorders;
- deployable recorders; and
- performance specifications for flight recorders.
EASA states that the proposed changes are expected to:
- increase the level of safety;
- address safety recommendations;
- save costs;
- transpose International Civil Aviation Organization (ICAO) standards into EU rules; and
- achieve greater harmonisation with Federal Aviation Administration (FAA) regulations.
A second NPA that provides a proposal for further issues identified in the Terms of Reference (ToR) for rulemaking task (RMT).0249 will be published at a later stage.
This consultation period is open until 27th June 2018. EASA encourage you to submit your comments on this rulemaking using the EASA comment response tool.
27/03/2018 CS-25 Revision 21
EASA has issued ED Decision 2018/005/R relating to CS-25. This is amending the Certification Specifications and Acceptable Means of Compliance for Large Aeroplanes. Specifically, CS-25 is amended to implement the outcome of two rulemaking tasks:
- RMT.0647 – ‘Loss of control or loss of flight path during go-around or other flight phases’:
- The objective of this rulemaking task is to mitigate the safety risk for large aeroplanes of a loss of the normal go-around (G/A) flight path, or a loss of control of the aeroplane during G/A or other flight phases executed at low-speed, ensuring that:
- the design of large aeroplanes is such that the G/A procedure with all engines operating (AEO) can be safely conducted by the flight crew without requiring exceptional piloting skill or alertness;
- the risk of excessive crew workload and the risk of the somatogravic illusion must be carefully evaluated, and
- design mitigation measures must be put in place if those risks are too high;
- the design of large aeroplanes provides adequate longitudinal controllability and authority during G/A and other flight phases (focusing on low-speed situations).
- RMT.0673 – ‘Regular update of CS-25’:
The objective of this rulemaking task is to reflect the state of the art of large aeroplane certification and improve the harmonisation of CS-25 with the FAA Part 25 regulations.
Various paragraphs of CS-25 Book 1 and Book 2 are amended to:
- introduce the content of generic certification review items (topics: landing in abnormal configurations, indication that engine anti-icing systems are functioning, oxygen fire hazards in gaseous oxygen systems, non-magnetic standby compass, engine cowl retention);
- harmonise with FAR 25 rules (topics: fuel tank vent fire protection, flight crew seats, security requirements);
- add some clarifications identified during certification projects (topics: flight instrument external probe de-icing test, engine ETOPS capability);
- make editorial corrections.
EASA expects that this Amendment will provide a fair safety benefit against an acceptable cost impact for large aeroplane manufacturers, and to have no social or environmental impacts. They continue to say that the changes stemming from the regular update should also provide some economic benefits by streamlining the certification process.
29/01/2018 ICA’s - Instructions for Continued Airworthiness
EASA has published NPA 2018-01 aimed at mitigating the risks linked to the uncertainty of the status of instructions for continued airworthiness (ICA) and therefore to avoid there being too much room for interpretation in the rules and standards, leading to differences and possible safety risks.
This NPA proposes to amend the Initial Airworthiness regulation to clarify that ICA are part of the type certificate (TC), and to develop the related AMC and GM. It also merges the requirements related to record keeping, manuals and ICA in the various subparts into a single requirement for each of these aspects in Subpart A (new points 21.A.5, 6 and 7).
The proposed changes are expected to improve the harmonisation of ICA among the design approval holders (DAHs) in relation to the identification, approval, formatting and availability of ICA to the end users.
The deadline for submitting your comments is April 30th 2018.
16/12/2017 Part-21 AMC/GM update relating to LFTE
The objective of this Decision is to amend the AMC and GM to Part-21 as follows:
- Introduce into the text of GM 21.A.101 the amendments developed by the Continuous Improvement Team (CIT)
- Update various AMC references to Flight Test Operations Manual (FTOM), and create a new AMC No 3 to Appendix XII to introduce new means for test organisations (part of a design organisation approval (DOA)/production organisation approval (POA)) to demonstrate the compliance of a lead flight test engineer (LFTE) based on a previous title (i.e. a holder of a national licence or a person already nominated as an LFTE by another organisation).
EASA expects that the amendments will improve harmonisation with the FAA and TCCA and to reduce the regulatory burden for design organisations.
15/12/2017 Part-21 Level of Involvement AMC & GM
EASA has published NPA 2017-20 to support the embodiment of level of involvement (LoI) and other changes into Part 21 as proposed by EASA Opinion No 07/2016 (Phase I). The NPA (Phase II) proposes to amend the related AMC/GM to Part-21.
Opinion No 07/2016 proposed to introduce in the product certification process the safety management principles contained in ICAO Annex 19. With said Opinion, the first step for the embodiment of LoI into Part-21 has been completed. As a second step, this NPA proposes to reflect in the related AMC/GM the amendments proposed by the Opinion. Additionally, new AMC/GM have been created and included in this NPA to cover the new elements introduced by the Opinion.
This NPA proposes AMC to support an applicant’s proposal for EASA’s LoI in certification projects, as well as EASA’s determination of its LoI. Furthermore, GM is proposed not only on the application of a risk-based approach for determining EASA’s LoI, but also on the process used. Furthermore, the GM proposed in the NPA provides guidance on the application of the new privileges for certain major changes, major repairs, and supplemental type certificates (STCs). Finally, the NPA includes new or amended AMC/GM based on the amendments to Part-21; in particular, it proposes to also relocate the guidance on those Part-21 requirements that have been moved from Section A to Section B.
The proposed changes are expected to support the implementation of the amendments to Part-21 proposed by Opinion No 07/2016. This will improve the effectiveness, efficiency, transparency, and predictability of the certification process, allowing for a better planning of the process with fewer delays as well as for a better allocation of both EASA’s and the applicant’s certification staff resources. In addition, compliance with ICAO Annex 19 will be achieved through the introduction of safety management system (SMS) elements into the certification process.
The NPA is open for consultation and will close for comments on 15th March 2018. We highly recommend Part-21J design organisations to review the NPA and comment using the EASA CRT prior to the 15th March 2018.
14/12/2017 Regular update of the AMC and GM to Part-21
Issue 2 Amendment 7 of the soft law for Part-21 has been published through ED Decision 2017/024/R. The main objectives of this update is to introduce into the text of GM 21.A.101 the amendments developed by the Continuous Improvement Team (CIT) and update the AMC to 21.A.143, 21.A.243, 21.A.14(b), 21.A.112B(b) and 21.A.432B(b) Flight Test Operations Manual (FTOM), and create a new AMC No 3 to Appendix XII to introduce new means for test organisations (part of a design organisation approval (DOA)/production organisation approval (POA)) to demonstrate the compliance of a lead flight test engineer (LFTE) based on a previous title (i.e. a holder of a national licence or a person already nominated as an LFTE by another organisation).
EASA expects that the amendments will improve harmonisation with the Federal Aviation Administration (FAA) and Transport Canada Civil Aviation (TCCA) and to reduce the regulatory burden for design organisations.
14/12/2017 EASA Form 1 or equivalent
EASA has published NPA 2017-19 with the aims to introduce more proportionate and efficient requirements in the airworthiness field, in particular to introduce commensurate manufacturing requirements for new spare parts and appliances. The requirement mandates that parts and appliances to be installed during maintenance need to be accompanied by a EASA Form 1 to attest manufacturing in accordance with Part 21, which is considered, in certain cases, disproportionate.
The so-called commercial parts are an example of that. Since these parts are often not designed exclusively for aviation use, parts manufacturers are not necessarily interested in achieving manufacturing recognition in accordance with Part 21 manufacturing standards (e.g. POA). Not only for commercial parts, but also for other parts and appliances a release certificate other than an EASA Form 1 may also be sufficient to guarantee adequate manufacturing quality.
In order to ease the manufacturing requirements for some of the parts, this NPA proposes to assign a criticality level (CL) for each part based on the safety consequences should the part fail to meet its design standards.
It proposes that only the design holder (for instance, the type certificate holder) can establish the CL for each part, with the default option of assigning the most stringent CL to all parts. In certain cases, the possibility to assign CLs is also given to EASA. It also establishes minimum manufacturing and release certificate requirements based on industry standards depending on the CL assigned to each part. Different marking requirements also apply for each part depending on its assigned CL.
Once the implementing rule and related AMC/GM are in place, by alleviating the effective requirements for the manufacture of parts not being critical, the manufacturing costs would decrease without affecting the safety of the air operations. The requirements proposed may very positively impact on general aviation (GA), since often certain parts of the aircraft have not been designed with an aviation intent and not manufactured by a POA.
The NPA is open for consultation and will close for comments on 14th March 2018. We highly recommend those involved in operations, manufacture, design, maintenance and airworthiness management to review the NPA and comment using the EASA CRT prior to the 14th March 2018.
27/11/2017 Unintended or inappropriate rudder usage
EASA has published NPA 2017-18 with the objective to mitigate the safety risk stemming from pilots of large aeroplanes applying inappropriate rudder control inputs, in particular pedal reversals, which may create structural loads that exceed limit loads or even ultimate loads. This may lead to the failure of primary structure and/or flight controls and then to a catastrophic loss of control of the aeroplane.
This NPA proposes to amend CS-25 to:
- create a new CS 25.353 yaw manoeuvre condition, consisting of a two-pedal doublet manoeuvre, and related AMC 25.353, and
- clarify CS 25.1583(a)(3) regarding manoeuvring speed limitation statements in the aeroplane flight manual, amend the related AMC 25.1581 and create a new AMC 25.1507.
EASA expects that the proposed changes will ensure that large aeroplanes are designed with features protecting the structure against rudder control pedal reversals like the ones demonstrated in several reported occurrences. This proposal would thus ensure an increased level of safety, while creating little or no economic impact in most of the cases.
Those stakeholders in the Large aeroplane design organisations are recommended to review these proposed changes.
08/11/2017 Amendments on climate change, emissions and noise
EASA has published its Opinion 09/2017, relating to response document, CRD 2017-01 which discusses the changes to Part-21 and the Basic Regulation as a result of CAEP/10 amendments on climate change, emissions and noise.
The main objective of this Opinion is to reduce aviation’s climate change and local air quality impact by introducing the new ICAO aeroplane CO2 standard and aircraft engine non-volatile particulate matter (nvPM) emissions standard into EU legislation. Additional amendments are aimed at making the implementation of existing standards for noise and engine emissions more robust by introducing the respective updates from the ICAO Annex 16 standards into EU legislation.
The amendments to ICAO Annex 16 Volume I address technical implementation issues with noise certification standards (SARPs). The amendments to ICAO Annex 16 Volume II implement a new non-volatile PM emissions standard and address various technical implementation issues. The purpose of the1st Edition of ICAO Annex 16 Volume III is to implement the new aeroplane CO2 emissions standard.
24/10/2017 Update of AMC 20-115C Airborne Software development
EASA has published its decision (ED Decision 2017/020/R) relating to generic AMC, and more specifically AMC 20-115C which detail the applicable airworthiness regulations with regard to the software aspects of airborne systems and equipment for product certification or ETSO authorisation.
EASA expects that the amendments will significantly increase harmonisation with the FAA, having no safety, social or environmental impacts, and will provide economic benefits by streamlining the certification process.
15/10/2017 Update of Technical Implementation Procedures (TIP) to revision 6.
The Technical Implementation Procedures (TIP) for the EU-USA Bilateral Aviation Safety Agreement (BASA) has been revised to revision 6. Unfortunately, there is no summary of the changes from Revision 5, and therefore requires some study to identify the actual differences. Baines Simmons is reviewing the impact of these changes and will be looking to assist those interested through various means in the coming months, before the changes take effect in spring 2018. In brief, and after our initial analysis, the topics that will be affected relate to repairs, PMA, TSO/ETSO articles, as well as an array of other Validating Authority (VA) and Certificating Authority (CA) topics. Ultimately, the changes are expected to streamline processes to benefit both the regulators and industry.
Watch this page for future information on what the implications are to us all.
09/10/2017 Engine bird ingestion
Further to our article in May of this year, EASA has published the Notice of Proposed Rulemaking in relation to CS-E, Engine bird ingestion.
The objective of EASA through the publication of NPA 2017-16 is to improve the ability of aeroplane turbine engines to cope with the ingestion of birds that can reasonably be expected to be experienced during the service life of the engine.
This NPA proposes to amend the certification specifications for engines (CS-E) aeroplane turbine engine bird ingestion demonstration provisions in CS-E to include an additional requirement to continue to operate following the ingestion of a medium-sized bird into the engine core with a fan speed that is representative of the climb condition (or approach condition if no bird material is ingested into the engine core during the test).
EASA expects that as a result of this rulemaking there will be improvements in safety and alignment with FAA Part 33.
15/09/2017 Regular Update of CS-25
Further to our article in July this year relating to NPA2017-12, the cut-off date for comments has been extended to 16th October 2017.
We recommend that if you haven’t already submitted your responses, you do so at your earliest convenience, but no later than the 16th October.
11/09/2017 Regular Update of rotorcraft AMC
The EASA rotorcraft certification specifications (CS-VLR, CS-27 and CS-29) are unique in the EASA regulatory framework in which the acceptable means of compliance (AMC) contained in Book 2 of the certification specifications (CS-VLR, CS-27 and CS-29) directly refer to the respective FAA Advisory Circulars (ACs). The FAA regularly reviews and updates the advisory circular (AC) material to maintain their relevance and improve the certification process. There is a need for EASA to keep abreast of these changes in order to ensure that they can be accepted as AMC in Book 2 of the CS’s.
The specific objective of this proposal is to improve efficiency between the FAA and EASA by minimising the differences between the relevant AMC and the FAA ACs. EASA expect that this will be achieved by:
- reducing the gap between the AMC to EASA CS-VLR, CS-27 and CS-29 AMC and the latest version of the published FAA ACs; and
- minimising any future differences by directly participating to the development of new material for inclusion in the FAA ACs.
This task also aims to clearly stipulate what EASA considers to be AMC and amend any AMC that has been found during certification activities to be either incomplete, misleading, outdated or not reflect the latest accepted certification practices. This will have the benefit of providing clarity to industry of what is expected from them during the certification of rotorcraft products.
The task does not cover AMC developed in association with new or revised provisions in Book 1 of the CSs. These will be developed under separate and distinct rulemaking activities. However, once developed, any AC/AMC material may be included in the update to the AMC contained in Book 2 of the CSs or possibly in AC 27-1B and AC 29-2C.
09/08/2017 Regular Update of CS-23
EASA reorganised CS-23 ‘Certification Specifications for Normal-Category Aeroplanes’, by replacing it with objective requirements and by moving prescriptive and technical details to the related AMC/ GM to CS-23. This AMC/GM will be annexed to a decision and published as a separate document. While EASA expects that the objective requirements are to remain unchanged, the more detailed AMC/GM will require regular amendments in order to take arising safety issues into consideration, keep the pace with constantly evolving technologies, and introduce new methods for showing compliance.
Regular updates are issued when relevant data is available following an update of industry standards or feedback from certification activities or minor issues raised by stakeholders. Therefore, this rulemaking task (RMT) is initiated to provide for the frequent updates to the technically detailed AMC/GM to CS-23. If needed, amendments to the objective requirements will also be proposed, to cover non-controversial issues. Depending on the need for consultation, either the standard or a special rulemaking procedure will be used.
If this is an area of interest for you, we recommend familiarising yourselves with the full details of this rulemaking task.
24/07/2017 Regular Update of CS-25
The specific objective of this Notice of Proposed Amendment (NPA 2017-12) is to propose amendments to CS-25 following the selection of non-complex, non-controversial and mature subjects. In particular, this NPA proposes amendments to the following items:
- Landing in abnormal configurations
- Fuel tank vent fire protection
- Indication that engine anti-icing systems are functioning
- Oxygen fire hazards in gaseous oxygen systems
- Flight instrument external probe de-icing test
- Flight crew seats
- Non-magnetic standby compass
- Security requirements
- Engine ETOPS capability
- Engine cowl retention
- Editorial corrections
EASA expects that the proposed amendments will contribute to updating CS-25 (Book 1 and Book 2) to reflect the state of the art of large aeroplane certification and improve the harmonisation of CS-25 with the FAA regulations. Overall, EASA say that this would provide a moderate safety benefit, would have no social or environmental impacts, and would provide some economic benefits by streamlining the certification process.
We recommend that if you are involved in initial airworthiness, then log-on to the EASA comment response tool to submit your comments. The consultation period is open until 25th September 2017.
21/07/2017 Integrated Modular Avionics - IMA
EASA has published a Notice of Proposed Amendment (NPA 2017-11) relating to the certification of the use of Integrated Modular Avionics. This is part of the rulemaking task RMT.0456 (which combines RMT.0621 and RMT.0622). This proposed amendment proposes to:-
- offer to integrators of aircraft functions on already-authorised IMA platforms the possibility to obtain ETSO authorisations, independent from any aircraft on which the platforms might be installed (covered in ETSO-2C516);
- provide guidance for the incremental certification of IMA, starting from platform modules, culminating with the installation of the IMA on an aircraft, and covering all the related aspects (in AMC 20-170).
EASA expects that the proposed changes will contribute to more efficient and transparent certification processes, while bringing positive impacts, in particular with their economic, social and environmental benefits.
We recommend that if you are involved in this area of initial airworthiness of IMA, then log-on to the EASA comment response tool to submit your comments. The consultation period is open until 29th September 2017.
12/07/2017 SMS requirements for Production Organisations
EASA has published the Terms of Reference (ToR) to RMT.0251(b) Issue 1 relating to the embodiment of safety management systems requirements into EASA Part-21 Production Organisations. ICAO Annex 19 introduced standards for ‘Safety Management’ based on a framework for the implementation and maintenance of a State Safety Programme (SSP) by States and of SMS by service providers. The specific objective of this proposal is to further increase aviation safety by introducing safety management in the scope of Part-21 design and manufacturing. This will be achieved through the publication of and NPA with draft implementing rules, AMC and GM.
22/06/2017 AMC-20 Update
NPA 2017-09 has been published relating to the AMC-20 – General AMC for Airworthiness Products, Parts and Appliances. This particular NPA proposes to:
- amend AMC 20-1, 20-2 and 20-3 to harmonise across them the criteria for safety assurance and software development;
- create a new AMC 20-30 on lead-free soldering as well as amend AMC 21.A.608; and
- create a new AMC 20-19 on in-flight entertainment (IFE) systems, as well as amend or create relevant AMC to Part-ORO and Part-CAT for the operation of these systems.
EASA expect that these changes reflect industry state of the art technologies, facilitating the certification process, bringing safety, environmental and economic benefits.
Click here to review the NPA. The closing date for comments is 22nd September 2017.
22/06/2017 Regular Update of CS-ETSO
Further harmonisation of CS-ETSO is progressing with the publication of NPA 2017-08 which highlights a number of ETSO’s and how they will be closer to the corresponding FAA TSO’s.
Click here to review the NPA. The closing date for comments is 31st August 2017.
31/05/2017 Rotorcraft gearbox loss of lubrication
EASA has published a Notice of Proposed Amendment (NPA 2017-07) relating to the loss of lubrication on rotorcraft gearboxes. EASA states that the objective of this NPA is to address a safety issue related to the ability of Category A rotorcraft to continue safe flight for an extended duration after suffering a loss of oil from a gearbox that is reliant on a pressurised lubrication system to provide lubrication and cooling of rotating components.
They state that the specific objective is to reduce the level of risk associated with loss of lubrication of rotorcraft gearboxes and to implement recommendations arising from the Joint Certification Team (JCT) review of rotorcraft gearbox certification specifications. This aims to both reduce the potential for lubrication system failures from occurring and to mitigate the consequences of any failure.
EASA expects that the objective shall be achieved by improving the safety assessment of pressurised lubrication systems, and by improving the certification and development testing specifications for the ‘loss of lubrication’ condition in order to substantiate a maximum period of continued operation which can be included in the rotorcraft flight manual (RFM) emergency procedures. More specifically, this NPA proposes to amend CS 29.917(a) to include rotor drive system gearbox lubrication systems in the definition of the rotor drive system. CS 29.927(c) on ‘loss of lubrication’ has been completely revised and replaced by a more objective-based CS that requires substantiation of the gearbox ability to continue safe operation (for at least 30 minutes) after a loss of lubrication to be followed by a safe landing. This is supported by substantial changes to the associated AMC. Finally, CS 29.1521 has also been amended to include an additional power plant limitation that describes how the RFM emergency procedures should reflect the test evidence relating to a loss of lubrication.
EASA expects that the proposed changes will provide an increase in the safety level of rotorcraft operations.
The consultation period is now open for review and comment, with the deadline being 31st July 2017. EASA then expects the decision on the soft law to be published by Q3 2017.
30/05/2017 Rudder reversals - Rulemaking
EASA has launched a rulemaking task, RMT.0397 that aims to address inadvertent and erroneous rudder inputs. Evidence suggests that applying inappropriate rudder inputs may exceed that structural limits of the aircraft, the worst-case scenario being similar to that of American Airlines A300-600 in November 2001.
The specific aim of this proposal is to mitigate the safety risk created by such unintentional or inappropriate movements.
A NPA is expected to be published before the end of 2017, with an expected decision affecting CS-25 within a year from then.
Those organisations and personnel involved with the design of large aircraft are recommended to keep abreast of developments.
30/05/2017 Tyre pressure monitoring system
EASA has launched a rulemaking task, RMT.0586 that aims to improve safety around improper tyre pressures. Improper tyre pressure, in particular underinflation, remains a major contributing factor to tyre- and wheel failure-related accidents or incidents. These kinds of occurrences continue to occur regularly despite a number of regulatory changes established over the last 40 years.
It is widely recognised that ensuring correct aircraft tyre inflation pressure is the most important factor for safe tyre operations.
The specific objective of this rulemaking task is to propose a regulatory change to ensure that the tyres’ inflation pressures of large aeroplanes remain within the pressure specifications defined by the aircraft manufacturer.
This Rulemaking task is expected to result in changes to CS-25, CS-26, Part-26 and Part-M, but not before the NPA has been issued in mid to late 2018.
Baines Simmons will keep an eye on these developments and we encourage those with an interest in the above Part’s to also be aware of the task.
30/05/2017 Engine Bird Ingestion
EASA has published a new rulemaking (RMT.0671) relating to Engine bird ingestion. This will have implications on CS-E in so much that the specifications will be evaluated to consider the need to improve the ability of aircraft engines to be able to cope with the ingestion of birds that can reasonably be expected during the service life of the engine. The rulemaking will consider demonstrating the ability of the engine to continue operating following ingestion of small to medium sized birds. It will also look into the effects of ‘large-flocking-bird ingestion’ on certain sized engines.
The associated NPA is expected mid-2017, with a decision being reached prior to year-end 2017.30
15/05/2017 Regular Update of CS-25
Further to our article on this topic in July last year when EASA published NPA 2016-07, EASA has published CRD 2016-07, it’s rulemaking on the regular update of CS-25. 58 comments were received by EASA from a wide variety of stakeholders. There was some resistance to the development assurance processes as a ‘safety objective’ as they were deemed to be ‘controversial’ by some responders. As a result, the proposed new text under this chapter has been withdrawn. Generally, other comments accepted the proposal or comments for improvement were accepted and adopted into the text.
For those involved in Initial Airworthiness, then please review the CRD to familiarise yourselves with the material.
12/05/2017 VIP/Business interiors for large aeroplanes - CS-25 Amndt 19
EASA has identified the need to address ageing aircraft issues, which includes in its scope current ageing aircraft and future aircraft designs. It is evident to the industry that with the increased use, longer operational lives, and experience from in-service aircraft, there is a need for a programme to ensure a high level of structural integrity and maintain it in the future for all aircraft, in particular, those in the large aeroplane category.
Therefore, CS-25 needs to be amended to upgrade damage tolerance and fatigue evaluation of structure. CS 25.571 and Appendix H are amended, a new AMC 25.571 is created, while further guidance is provided in an amended AMC 20-20.
Certification specifications (CS) for large aeroplanes have been drafted taking into account large transport aeroplanes, featuring cabin interiors equipped for the commercial carriage of relatively high numbers of passengers. These specifications are not always adequate for cabin interiors installed in so-called business aeroplanes, i.e. those having lower-density interiors that offer a greater level of comfort and amenities, and sometimes being non-commercially operated. Numerous certification review items (CRIs) are issued for each certification project involving these aeroplanes. They address repetitive issues like access to emergency exits, width of aisles, heat release, and smoke density properties of materials, interior doors, etc.
EASA decided to create rulemaking task RMT.0264 with the objective to introduce in CS-25 a set of common requirements and intended interpretations (in the form of AMCs) that will establish a level playing field for all applicants with regard to the specificities of business aeroplanes, while continuing to provide an acceptable level of safety.
The three listed NPA’s all provide updated information relating to this subject and those organisations involved with the certification and design of large aeroplanes are advised to review and familiarise themselves with this decision.
11/05/2017 NPA - Loss of control or flight path during go-around
EASA has opened for consultation NPA 2017-06 that looks to mitigate the safety risk of loss of the normal go-around (G/A) flight path, or loss of control of the aircraft during G/A or other flight phases executed at low-speed.
EASA states that this NPA proposes to amend CS-25 to ensure that:
- the design of large aeroplanes is such that the G/A procedure with all engines operating (AEO) can be safely conducted by the flight crew without requiring exceptional piloting skills or alertness. Risk of excessive crew workload and risk of somatogravic illusion must be carefully evaluated, and design mitigation measures must be put in place if those risks are too high;
- the design of large aeroplanes provides an adequate longitudinal controllability and authority during G/A and other flight phases (focusing on low speed situations).
EASA expects that the proposed changes will provide a fair safety benefit against an acceptable cost impact for large aeroplane manufacturers.
The deadline for comments is 11th August 2017. It is recommended that those involved with the design of large aeroplanes (CS-25) and operators engage with this rulemaking process.
28/04/2017 IMRBPB – Issue Paper release
The International Maintenance Review Board Policy Board (IMRBPB) has published a range of Issue Papers (IP). These papers, IP162 through to IP175, cover a range of topics from MRBR and IP revision Policy and Procedures, to HUMS, CPCP, electronic signatures, MSG-3 analysis for Engines/APU’s/Propellers, and Structural Analysis for landing gears.
For a full view of the information and to access the documents, click here.
Those involved in Maintenance Programmes and certification of aircraft, it is worthwhile reading through the papers.
31/03/2017 Comment Response Document issued for CS-STAN Regular Update
EASA has published its final deliverable for CS-STAN in the form of CRD 2016-17. The nature of the comments received ranges from specific technical aspects, to comments aiming to improve the wording of the proposed amendments.
Several comments were accepted or partially accepted, thus leading to substantial amendments of the proposed text which, in certain elements, has been significantly improved.
A summary of the comments that EASA wants to highlight is provided here:-
Differences between CS-STAN and FAA AC-43 ‘Acceptable Methods, Techniques, and Practices - Aircraft Inspection and Repair’ - Some commentators asked for a complete transposition of FAA AC 43-13 into CS-STAN.
Release to service by pilot owner - Some commentators asked to increase the number of tasks which can be performed by pilot owners sometimes referring to the provisions already included in Appendix VIII of Part-M.
Overlap between CS-SC052 and CS-SC057 - Many commentators stated that the proposed CS-SC057 was partially overlapping the existing CS-SC052 without clear indications of the specific differences and related benefit.
Substantial change of CS-SR804 ‘use of alternative adhesive for repairs of wood and wooden mixed structures’ - Many commentators submitted comments and proposals for improvement of this new Standard Repair.
Clarifications on ETSO/JTSO/TSO references, this covers also SCs which were not included in the NPA - Some stakeholders commented on the incomplete references to ETSO authorised equipment.
Acceptance of FAA STC by means of CS-STAN - Some stakeholders proposed to establish new provisions in the CS-STAN in order to allow for the acceptance of FAA STCs on general aviation aircraft without the need of a formal application of the US STC holder.
Proposals for new standard changes/repairs - Some stakeholders submitted comments asking for new Standard Changes or Standard Repairs to be added in the CS-STAN.
Further information relating to these issues as well as the full list of individual comments for this CRD can be found here.
28/03/2017 TIP Revision 5 Amendment 1
The Technical Implementation Procedures Revision 5 have been amended to update the information contained in paragraph 2.4, Evaluation of Operational and/or Maintenance Aspects. This system includes approval of data that are considered necessary for the safe operation of an aircraft, called the Operational Suitability Data (OSD). These data once approved, are attached to the type certificate (TC) through a reference in the TC data sheet. To review the full amendment, click here.
We recommend all maintenance organisations that hold an FAA Repair Station Approval to familiarise themselves with the latest changes.
21/03/2017 On-ground icing events
EASA has received a number of safety recommendations relating to the reduction of safety margins and reduction of manoeuvrability/controllability due to airframe ground icing contamination or inadequate de-/anti-icing operations. They note that accidents and incidents have been caused by the degradation of aircraft aerodynamic performances due to this icing effect. Terms of Reference for this rule making task RMT.0118 (25.074) has been issued.
In this respect, EASA has proposed to review the existing certification specifications and acceptable means of compliance. They state that the objective of this task is to mitigate the risk of loss of control of an aeroplane (in particular during, but not limited to, the take-off phase), and the risk of runway excursion after an aborted take-off at high speeds. They expect that to achieve this objective, it shall be considered whether there is a need for amending the existing specifications and/or to introduce new certification specifications and acceptable means of compliance into CS-23 and CS-25 requiring the applicant of a type certificate to perform an assessment of the effect of contaminated aerodynamic surfaces on aircraft performances, handling qualities, and controllability. In addition, they say it shall also be considered whether such requirement could be imposed on certain already certified large aeroplanes through an amendment of Part-26/CS-26.
We recommend that aircraft manufacturers and operators familiarise themselves and subsequently get involved in this rulemaking activity.
07/03/2017 New CO2 emission standards
The ICAO Council has adopted a new aircraft CO2 emissions standard which it says will reduce the impact of aviation greenhouse gas emissions. They comment that air transport is the first industry sector globally to adopt a CO2 emissions design certification standard. EASA has led the technical work on the development of this CO2 standard for the past six years.
Contained in a new Volume III to Annex 16 of the Chicago Convention on Environmental Protection, the Standard will apply to new aircraft type designs from 2020, and to aircraft type designs already in production as of 2023. Those in-production aircraft which by 2028 do not meet the standard will no longer be able to be produced unless their designs are sufficiently modified.
EASA is in the middle of the process to implement the Annex 16 amendments agreed at ICAO’s Committee on Aviation Environmental Protection (CAEP/10) into European legislation. NPA 2017-01 is currently out for comment and the EASA Opinion is expected to be delivered this summer.
We highly recommend those organisations and personnel involved in Initial Airworthiness and the Competent Authorities to review these requirements.
19/12/2016 EASA-TCCA Rulemaking update
EASA and TCCA have released information updating the important relationship between the two rulemaking bodies to further enhance the harmonisation and clarity around the interface requirements. Three documents have been updated
- EASA-TCCA Technical Implementation Procedures for airworthiness and environmental certification (TIP) - Revision 2
- Rulemaking Cooperation Guidelines for the TCCA and the EASA
- Interim procedure for the approval of OSD Operational elements
We recommend all parties involved in collaborating with TCCA should familiarise themselves with these recent changes.
16/12/2016 CS-ETSO Amendment
EASA states that this Decision
- Modifies a number of ETSOs in order to harmonise them with the corresponding FAA TSOs;
- introduces new ETSOs which are technically similar to existing FAA TSOs; and
- deletes obsolete ETSOs which are no longer used by industry.
The changes introduced by Amendment 12 are expected to reduce regulatory burden for installation of FAA TSO parts and appliances by EASA and vice versa, to increase cost-effectiveness, and to align CS-ETSO to the state of the art. The affected stakeholders include Certification Authorities, Manufacturers of parts and appliances.
This Decision also contains only subjects considered as non-complex, non-controversial, and mature.
We recommend all stakeholders from Competent Authorities to Industry to make themselves aware of Amendment 12.
15/12/2016 Regular Update of AMC/GM to Part-21
The complexity of Part-21 requires regular updates to the soft law. These are issued when relevant data is available following an update of industry standards or feedback from certification activities or minor issues raised by the stakeholders.
Terms of Reference for rulemaking task RMT.0031 Issue 1 are now available here and on the EASA website.
All those involved in the Design and Production of products are recommended to update their information accordingly.
07/12/2016 Regular update of CS-STAN
The Agency has published NPA 2016-17 with the specific objective to propose amendments to CS-STAN. Their ultimate goal is to support the operation of the affected aircraft in Europe, reducing the regulatory burden for the embodiment of simple changes and repairs in certain aircraft when fulfilling the acceptable methods, and promoting safety.
This NPA proposes to:
- provide additional explanations on the use of CS-STAN;
- introduce new standard changes and update some existing ones; and
- introduce new standard repairs and update some existing ones
The changes introduced by this NPA are based on lessons learnt and proposals submitted by affected stakeholders, as well as technological innovations from the industry, which can bring safety benefits in a cost-efficient manner.
Overall, EASA expects that this NPA would bring a moderate safety benefit, would have no social or environmental impacts, and may provide major economic benefits by reducing the regulatory burden for the embodiment of simple changes and repairs in certain aircraft when fulfilling the acceptable methods, techniques and practices included in CS-STAN. EASA expects to release a decision on this by the end of Q1 2017.
We recommend that the affected stakeholders, such as Operators other than airlines, MOs, and maintenance engineers or mechanics familiarise themselves with this update.
01/12/2016 Harmonisation of CS-27
EASA has published its Decision relating to CS-27. EASA states that it addresses a number of safety and regulatory harmonisation issues that are currently not or are only partially addressed in the current CS-27.
The specific objective is to update the certification specifications for small rotorcraft in order to maintain a high level of safety and to provide cost-efficient rules harmonised with those of international partners.
This Decision proposes the following main changes:
- To amend AMC 27.351 to reflect certification experience and ensure a consistent and safe approach to establishing structural substantiation.
- To adopt AC 27-1B — Change 4, published by FAA in May 2014. Most changes adopted in this Advisory Circular were previously developed jointly by FAA and EASA however some minor differences remain.
- To create new Certification Specifications on HIRF (CS 27.1317) and lightning (CS 27.1316). This will better reflect existing certification practice and will replace reliance on ageing JAA interim policies. AMC material associated with these new rules has previously been published by EASA in AMC-20.
- To create a new rule related to volcanic ash (CS 27.1593). This will ensure that design organisations undertake an assessment of their product’s susceptibility to volcanic cloud hazards as part of type certification, and establish limitations and/or provide information for their safe operation.
EASA expects that the proposed changes will increase safety and cost-effectiveness, reduce regulatory burden and constitute an improvement in terms of harmonisation with other certification authorities.
We recommend those involved with the design, production or certification of small rotorcraft to review the changes.
23/11/2016 ICA’s relating to CMR’s consultation period extended
EASA has extended the consultation period relating to NPA 2016-15. This NPA addresses a regulatory coordination issue related to harmonisation of the current EASA CS-25 and AMC 25-19 with the FAA AC 25-19A in relation to the Certification Maintenance Requirements (CMRs).
The specific objective is to mitigate the risks linked to different CMR documents with different identification means and follow-up procedures because of the lack of harmonisation between the FAA AC and the EASA AMC.
This NPA proposes an amendment to CS-25, which includes a revision of AMC 25-19, with a result that the amendments are expected to clarify the CMRs.
The revise deadline for submitting comments is now 10th Feb 2017.
10/10/2016 Ageing Aircraft Structure – Opinion 2016/12
This Opinion addresses safety risks related to ageing phenomena in the structures of large aeroplanes. These risks include fatigue of the basic type design, widespread fatigue damage (WFD), corrosion, fatigue of changes and repairs, and continued operation with unsafe levels of fatigue cracking.
EASA expects that the proposal ensures that these safety risks are mitigated for both the existing and future fleets of large aeroplanes.
The opinion proposes to:
- amend and include new requirements in Part-26 — ‘Additional airworthiness requirements for operations’;
- amend Part-21 ‘Certification of aircraft and related products, parts and appliances, and of design and production organisations’;
- amend Part-M;
The proposal will ensure that Design Approval Holders (DAHs), or applicants for Type Certificates (TCs), Supplemental Type Certificates (STCs), design changes and repair approvals, will produce the necessary data, procedures, instructions and manuals related to ageing structure failures due to corrosion and fatigue and make them available to those who need to comply with them (operators).
Additionally, operators will be required to incorporate these data items into their maintenance programmes while addressing the adverse effects of changes and repairs on each airframe and its associated maintenance requirements.
The proposal is largely harmonised with the Federal Aviation Administration (FAA) requirements on this subject.
For those involved in the initial and continuing airworthiness of ageing aircraft, we recommend that you familiarise yourselves with the content and changes to these requirements.
06/10/2016 Open Rotor engine and installation
The Terms of Reference for rulemaking task RMT.0384 (MDM.092) are published relating to Open Rotor engine and installation.
This concept is being proposed to power future large transport aircraft as a means of improving aircraft fuel burn and emissions. This concept is known as the ‘open rotor engine’. The objective of this task is to identify and recommend harmonised draft certification specifications and acceptable means of compliance for CS-E, 14 CFR Part 33, CS-25 and 14 CFR Part 25 to address the novel features inherent in open rotor engine designs and their integration with the aircraft.
EASA expects that these new provisions and associated AMC material should ensure that the safety levels of open rotor engine installations are consistent with those of the existing turbofan fleet. These new provisions should also take into consideration the effect of the open engine rotor concept on existing bird ingestion provisions. Harmonisation with 14 CFR Part 25 and 33 (and/or Special Conditions) is also an objective of this rulemaking task.
The objective of the working group is to identify and recommend EASA/FAA harmonised
draft provisions and advisory material for respectively engine (14 CFR Part 33/CS-E) and aircraft (14 CFR Part 25/CS-25) and/or Special Conditions to address the novel features inherent in Open Rotor engine designs and their integration with the aircraft.
It is expected that consideration should also be given for the creation of new provisions to provide the required safety objectives based on the unique nature of the open rotor configuration. These new provisions and associated AMC material should ensure that the safety levels of Open Rotor engine installations are consistent with those of the existing turbofan fleet.
The expected deliverables from this RMT are in two phases, with Phase 1 being focussed on engine design features and engine integration, and Phase 2 around bird ingestion.
We recommend that those involved with CS-E and CS-25 click on this link for a full picture of this RMT.
07/09/2016 Import of A/C from other regulatory system
As a result of rulemaking tasks, NPA 2016-08 has been issued relating to the importing of aircraft form other regulatory system and Part-21 Subpart H review.
This NPA proposes amendments to Part-21 and Part-M in order to guarantee their consistency with regard to the issuance of a CofA and an ARC for aircraft being imported from other regulatory systems.
EASA expects that the proposed changes will eliminate difficulties encountered by stakeholders and Member States in the process of obtaining/issuing a CofA and ARC under these circumstances while ensuring alignment with ICAO.
Part-21 is also amended to establish consistency in the case of newly manufactured foreign aircraft.
We recommend that all parties concerned with both Part-21 and Part-M familiarise themselves with this NPA, and submit their comments by the deadline of 7th December 2016.
02/08/2016 Opinion reached on Halon Fire Extinguishers
EASA has published its Opinion relating to the use of Halon in lavatory waste receptacles and portable handheld extinguishers for large aeroplanes (CS-25) and large rotorcraft (CS-29)
It is linked with amendments to ICAO Annex 6, but not yet transposed into EU rules:
- Amendment 35 to Part I (International Commercial Air Transport — Aeroplanes);
- Amendment 30 to Part II (International General Aviation — Aeroplanes); and
- Amendment 16 to Part III (International Operations — Helicopters).
The specific objective of this Opinion is to gradually mitigate the environmental impact that halon extinguishing agents in firefighting equipment have on the atmosphere and climate change, and to progressively achieve a ‘halon-free’ aviation, which balances the environmental concerns with safety-enhancing and cost-efficient rules.
It proposes an amendment to the Additional airworthiness regulation (Part-26), laying out the framework for the replacement of halon in lavatories and in handheld fire extinguishers on newly produced aircraft (i.e. ‘forward fit’) based on existing type certificates (TCs).
Although the dates for halon replacement proposed are later than those of ICAO Annex 6, the proposed changes are expected to ensure compliance therewith in the long term.
We recommend all involved in CS-25 and CS-29 familiarise themselves with the requirements and dates specified in this Opinion
01/08/2016 EASA publishes Decision relating to CS-ETSO
It addresses an economic and harmonisation issue related to the regular update of European Technical Standard Orders (ETSOs) due to new or updated and improved standards for parts and appliances.
More specifically, the main objectives of this Decision are to:
- modify a number of ETSOs in order to harmonise them with the corresponding FAA TSOs;
- introduce new ETSOs (Index 1) which are, where possible, technically similar to existing FAA TSOs; and
- introduce a new ETSO (Index 2), not existing in the FAA TSO series (i.e. ETSO-2C515 Aircraft halocarbon Clean Agent — Handheld fire extinguisher).
EASA expects that the proposed changes will reduce the regulatory burden for validation of FAA TSO authorisations by EASA and vice versa, increase cost-effectiveness, and align CS-ETSO to the state of the art.
For those that are affected by CS-ETSO, we recommend that you familiarise yourselves with the decision.
27/07/2016 CS-25 Regular Update. NPA 2016-07
This NPA is based on the ‘systematic rulemaking projects’. This concept aims at improving the efficiency of the EASA rulemaking process.
The specific objective here is to propose an amendment to CS-25 following the selection of non-complex, non-controversial and mature subjects. The ultimate goal is to increase safety. It proposes to:
- amend CS 25.1309 and AMC 25.1309 in order to clarify the provisions related to the exception of cabin safety equipment from CS 25.1309(b); and
- amend AMC 25.1309 in order to reflect the current aircraft and systems development practices that make use of development assurance levels (DALs) assignments; the proposal introduces the relationship between the severity of a failure condition and the DAL.
EASA expects that the proposed changes will to contribute to updating CS-25 (Book 1 and Book 2) to reflect the available state of the art and facilitate the certification process. Overall, EASA expects this proposal to bring a moderate safety benefit, whilst it would have no social or environmental impacts, and may provide some minor economic benefits by streamlining the certification process.
The deadline for submission of comments is 27th September 2016. We recommend those involved in to submit their comments in good time through EASA’s Comment Response Tool.
12/07/2016 CS-STAN Update
Further to our article last month on this topic, EASA has published more information in the context of the EASA General Aviation Roadmap. There is an effort to simplify the certification of aircraft and modifications. EASA believe that this should lead to a noticeable reduction in cost and effort to certify a new product or modify an existing one. In turn, the Agency believes it should enable manufactures to develop modern and safe products and operators to retrofit modern equipment at cost affordable to the pilots. There are three ways through which all the above will be achieved:
- Simplified Airworthiness Procedures
- Standard Changes and Repairs (CS-STAN)
- CS-23/Part 23 reorganisation and International Harmonisation
We recommend those persons or organisations involved in these areas of Initial airworthiness to review this.
23/06/2016 CS-25 / Amendment 18
New CS and AMC for certification of CS-25 for flight in icing conditions were issued with earlier amendments of CS-25. This included a new Appendix O environmental standard representing Supercooled Large Drop (SLD) icing conditions. The AMC material will enable the applicant to use and take credit from a previous similar type design that has been proven to safely operate in SLD icing conditions. The aim is to facilitate the demonstration of compliance with the specifications and to eliminate the need for performing testing in natural or simulated SLD conditions.
These new CS-25 provisions (including a dedicated paragraph in AMC 25.1420) are now included in CS-25. This will provide better assurance for applicants on the conditions required for acceptance of a comparative analysis and facilitate the certification process.
In addition to these provisions for SLD conditioins, CS-25 is amended in order to:
- clarify the intent of CS 25.810(a)(1)(iv) on emergency egress assisting means, with regard to the demonstration of performance with the engine running at ground idle;
- update the references to the FAA Flight Test Guide (AC 25-7C);
- clarify the structure of CS 25.143(l) on ‘Electronic flight control systems’;
- correct an inaccuracy in the tables of CS 25.397(d)(1) on ‘Limit pilot forces for aeroplanes equipped with side stick controls’;
- introduce the content of the Certification Memorandum on ‘Respecting Brake Energy Qualification Limits’ into AMC 25.735(a);
- clarify the applicability of CS 25.729 on ‘Retracting mechanism’ to both retracting and extending mechanisms of the landing gear; and
- make typographic improvements.
We recommend all interested parties make themselves fully aware with these revised specifications.
09/06/2016 Regular update of CS-STAN
Further to previous articles relating to CS-STAN, EASA has published their regular update
EASA intends to regularly amend CS-STAN, taking into account the principles of efficiency and proportionality. The regular amendments will be on the basis of lessons learnt and proposals submitted by affected stakeholders, as well as industry technological innovations, which are intended to bring safety benefits in a cost-efficient manner. This includes introducing new standard changes and repairs, updating the scope of some of the existing standard changes or repairs, or removing some standard changes and repairs, as necessary.
Because of the generic nature of this RMT, this ToR remains open and has no end date. Each individual NPA will, however, provide the specific timescales of the subsequent deliverables (e.g. the intended ED decision publication date).
We recommend those organisations affected by CS-STAN, to keep abreast of the latest changes by reviewing the requirements in full.
23/05/2016 EASA have published their Opinion to address a systemic issue of introduction of safety management principles into Part-21
The main objective of this Opinion (07/2016) is to further strengthen the Part-21 certification processes performance in general, and the verification part of these processes by EASA. This will be achieved by introducing into Part-21 the new rules accommodating a risk-based approach to compliance verification through embodiment of the concept of level of involvement (LoI) of the Agency in the certification process. The risk-based LoI concept is in line with the safety risk management standards of ICAO, and will enable EASA to better identify the areas of product certification more prone than others to risk with regard to safety and environmental protection.
This will allow EASA to focus its certification resources primarily on these areas that need a direct and high LoI in order to thoroughly verify that compliance has been demonstrated by applicants. In other certification areas, where the risk to product safety or environmental protection is assessed lower, EASA, when justified by their adequate performance, rely on approved design organisations. Moreover, this proposal will further enhance the oversight system of design organisations to become ‘performance-based’. Some design organisations may obtain new design organisation approval (DOA) privileges to certify certain major changes to type-certificates (TCs), supplemental type-certificates (STCs), and/or major repair designs without EASA’s involvement, but only in technical domains where they demonstrate their satisfactory experience and performance in compliance assurance.
The present opinion is the first step towards transposing the ICAO Annex 19 ‘Safety Management’ standards into Part-21. A further proposal to amend Part-21 in accordance with the ICAO safety management system (SMS) standards for design and production organisations, State Safety Programme (SSP) standards, and critical elements of a safety oversight system for the competent authorities (CAs), including the Agency, is being established by the Agency in a separate rulemaking task (RMT).
We recommend all affected owners, operators and equipment manufacturers make themselves fully aware with this Opinion.
17/05/2016 Rotorcraft gearbox - loss of lubrication
The Certification Specifications for large rotorcraft currently requires a test to be performed to demonstrate that any failure that results in a loss of oil pressure to any normal use lubrication system will not impair the capability of the rotorcraft to operate under autorotative conditions for 15 minutes (Category B), or for continued safe flight for at least 30 minutes (Category A), unless such failures are extremely remote. Recent experience has shown that the use of the ‘extremely remote’ clause can be challenging due to unforeseen variables and complexity associated with predicting potential failure modes and their associated criticality and frequency of occurrence.
It has also been recognised that there is a discrepancy between the test objective and the pilots’ perception of a rotorcraft’s endurance following loss of Main Gearbox (MGB) oil and can lead to unrealistic expectations.
One of the underlying root causes contributing to loss of lubrication is related to the lubrication system currently falling outside the rotor drive system design assessment of CS 29.917(b). The lubrication system is an integral part of the rotor drive system and is necessary to achieve continued safe operation of the rotor drive system.
In response to a fatal accident, TCCA, the FAA and EASA created a Joint Cooperation Team (JCT) to conduct a review of the current design standard and Guidance Material relating to the certification of helicopter MGBs, specifically with respect to loss of lubrication. The JCT’s recommendations will be considered by the rulemaking group during this rulemaking exercise.
The objective of the exercise is to implement the recommendations of the JCT and to strengthen the existing CS-29 provisions pertaining to rotor drive system lubrication.
This task proposes a harmonised action to address gaps identified in the existing requirements, clarify the intent of the rule and redefine test requirements to meet the intended safety standards. This will both reduce the potential for lubrication system failures from occurring and mitigate the consequences of any failure, if this should happen.
We recommend all affected owners, operators and equipment manufacturers engage fully with this rulemaking task either directly or through their applicable trade association.
17/05/2016 EASA Launches rulemaking task on Aircraft cybersecurity
The reasoning for this regulatory change (ToR RMT.0648) is that aircraft systems designs are evolving from simple, proprietary and isolated architecture communicating via unidirectional point-to-point databuses to more complex ones using standardised protocols and common platforms whose technical documentation is easily accessible. Communication between systems is widely using switched Ethernet technology. These systems may also be connected to the ground worldwide internet through satellite communication. This can also affect Aircraft maintenance communication functions which are connected to the operator’s servers for long-distance data loading.
The interconnections are susceptible to new threats, which may potentially have catastrophic effects on the safety of air transport. Those threats are caused by unauthorised electronic interaction that can be triggered by human action either intentionally or unintentionally. Such threats have the potential to affect the airworthiness of the aircraft due to unauthorised access, use, disclosure, denial, disruption, modification or destruction of electronic information or electronic aircraft system interfaces.
All recently designed large aeroplanes are known to be potentially sensitive to those airworthiness-related security threats due to the interconnectivity features of some of their avionics systems. Moreover, some recent avionics modifications may also render legacy aeroplanes sensitive to this risk.
Today, cybersecurity is addressed as part of the certification activities of new large aeroplane type designs and supplemental type certificates through the special condition called ‘Security Assurance Process to isolate or protect the Aircraft Systems and Networks from internal and external Security Threats’. The special condition requires that aircraft systems and networks be assessed against potential failure caused by information security threats in order to evaluate their vulnerabilities to these threats.
In February 2015, the FAA assigned a new task to the Aviation Rulemaking Advisory Committee (ARAC) to provide recommendations regarding Aircraft Systems Information Security/Protection (ASISP) rulemaking, policy, and guidance on best practices. EASA is participating in the ASISP working group. One of the assigned subtasks is to consider EASA requirements and guidance material for regulatory harmonisation.
The specific objective of this task is to mitigate the safety effects stemming from cybersecurity risks due to acts of unlawful interference with the aircraft on-board electronic networks and systems. To achieve this objective, it is proposed to introduce in CS-25 new cybersecurity provisions taking into account the special condition mentioned above and the recommendations of the groups. The need to include similar provisions such as CS-29, CS-27, CS-23, CS-E, CS-ETSO, and CS-P will also be considered.
EASA is expected to publish a NPA by the end of 2016.
We recommend all affected owners, operators and equipment manufacturers engage fully with this rulemaking task either directly or through their applicable trade association.
26/04/2016 AMC/GM to Part-21 - Changes to operational suitability data (OSD)
The objective of OSD is to ensure that certain data, necessary for the safe operation of aircraft by an EU operator, is made available to and used by the operators, training organisations, and manufacturers of flight simulator training devices. This data is considered specific to an aircraft type and should, therefore, be produced by the designer of that aircraft type. It consists of:
- a minimum syllabus for pilot type rating training;
- aircraft reference data to support the qualification of simulators;
- a minimum syllabus for type rating training of maintenance certifying staff MCS;
- type-specific data for cabin crew training; and
- a master minimum equipment list (MMEL).
The OSD proposed by the designer will be approved by the Agency as part of the TC.
Once approved, the core of the OSD must be used by operators and training organisations when establishing their customised training courses and minimum equipment lists (MELs).
The OSD contributes to bridging the gap between airworthiness (AW) and air operations (OPS) and, therefore, to improving safety. Furthermore, the OSD provides the basis to enable greater standardisation in the EU for type training and MEL.
The latest AMC/GM relating to these changes is now available from EASA’s website
19/04/2016 Reduction of runway excursions
EASA has released Issue 2 to ToR RMT.0570 with the specific objective to increase the level of safety by reducing the number of runway excursions. To achieve this, it was proposed to mandate existing technologies on large aeroplanes (new designs and newly produced) to be operated in commercial air transport.
Due to the nature of the comments received on NPA 2013-09 (refer to CRD 2013-09), and further to a focused consultation organised in October 2014, EASA has decided to publish a new NPA on the subject. The proposal in the new NPA would put more emphasis on the safety objectives against the risk of runway excursions, while providing for more flexibility in terms of design solutions. The means to achieve these objectives would be provided in a technical standard developed jointly by industry and national aviation authorities with the support of an international standardisation body.
It is expected that the deliverables from this RMT will be
- A notice of proposed amendment (NPA) on the issue of runway excursions, proposing an amendment to CS-25 and possibly to Part/CS-26,
- A comment-response document (CRD) providing responses to the comments received on the NPA;
- An Executive Director (ED) decision amending CS-25;
- Possibly an EASA opinion amending Part-26 and a related ED decision amending CS-26.
23/03/2016 Helicopter ditching and water impact occupant survivability
EASA have issued NPA 2016-01 which aims to address safety issues related to helicopters certified for ditching and performing overwater operations.
Previous studies and accident investigations into helicopter ditching and water impact events have highlighted inadequacies in the existing certification specifications as well as in the rules governing offshore operations. In particular, it has been established that in an otherwise survivable water impact, most fatalities occurred as a result of drowning because the occupants were unable either to rapidly escape from a capsized and flooded cabin, or to survive in the sea for sufficient time until rescue. Furthermore, the testing environment in which helicopters are type-certified for ditching bears little resemblance to the sea conditions experienced in operation.
In order to thoroughly address these and other ditching-related issues, and due to the nature of ditching-related hazards, this rulemaking task has taken a holistic approach to the problem, which crosses traditional airworthiness/operational boundaries. A detailed risk assessment has been undertaken that reflects both certification and operational experience and builds upon data extracted from accident reports and previous studies. The result is a list of identified interventions related to helicopter design, certification, operations, and ditching equipment, all of which could contribute to improving safety. In the case of operations, the Rulemaking Group has interfaced with other Rulemaking tasks to ensure a consistent set of rules.
The specific objective of this NPA, however, is to propose changes to CS-27 and CS-29 to mitigate helicopter design-related risks to new helicopter types. Recommendations for safety improvements in other areas have been made by the RMG for subsequent action to be taken under this rulemaking task, other rulemaking tasks or through alternative means. Retroactive rules are to be considered in a second phase of this RMT.
This NPA proposes changes to many CS-27/29 provisions that relate to ditching. However, the primary change proposed aims to establish a new ditching certification methodology by which a target probability of capsize following a ditching can be determined based on the level of capsize mitigation applied to the design. This target probability of capsize is then verified in sea conditions chosen by the applicant, by following a defined tank test specification using irregular waves. For CS-29 and CS-27 Cat A rotorcraft, enhanced capsize mitigation must be provided to relieve the time pressure on occupants to escape. Water impact events are accounted for implicitly within the new ditching methodology. Additional changes are proposed to maximise the likelihood of occupant egress and subsequent survivability.
EASA expects that the proposed changes will increase safety.
We recommend all affected parties to fully review with this NPA either directly or through their applicable trade association and submit your comments using the automated comment response tool (CRT) on the agencies website.
27/01/2016 EASA revises Terms of Reference for CVR/FDR rulemaking task
CS-23, CS-25, CS-27 and CS-29 contain certification specifications (CS XX.1457 and CS XX.1459) which are related to the installation of Cockpit Voice Recorders (CVRs) and Flight Data Recorders (FDRs), when their carriage is required by the Air Operations rules.
The present Terms of Reference address several issues regarding the certification specifications for cockpit voice recorders (CVRs) and flight data recorders (FDRs). Some of these issues were initially identified by the following Rulemaking Tasks (RMTs) (refer to EASA’s 4-year Rulemaking Programme):
- 0268 (MDM.068) ‘Revision of FDR and CVR certification specifications’;
- 0249 (MDM.051) ‘CVR recording quality’;
- 0402 (OPS.091(a)) ‘Requirements for combination recorders (FDR/CVR)’; and
- 0402 (OPS.091(b)) ‘Requirement for combination recorders (FDR/CVR)’.
The above-mentioned RMTs have been merged in the course of time into one single task, namely RMT.0249 (MDM.051) (refer to EASA’s 4-year Rulemaking Programme). The issues and reasoning associated with the rulemaking task, detailed in the Terms of Reference, cover the following:
- FDR and CVR power supply
- Specifications for data link recording
- Means to automatically stop the recording after an accident
- Provisions for ensuring serviceability of flight recorders
- Quality of recordings of CVRs
- Performance specifications for flight recorders
- Specifications for combination recorders
- Specifications for deployable recorders
RMT deliverables are as follows:
- Notice of Proposed Amendment (NPA) proposing as necessary, changes to Part-CAT, CS-25, CS-29, AMC/GM to Part-CAT, Part-SPA Part-NCC or AMC/GM to Part-21;
- Comment-Response Document (CRD),
- Opinion proposing an amendment to Part-CAT of Commission Regulation (EU) No 965/2012
- Decision(s) amending CS-25, CS-29, AMC/GM to Part-CAT, Part-SPA Part-NCC or AMC/GM to Part-21.
We recommend all affected owners, operators and equipment manufacturers engage fully with this rulemaking task either directly or through their applicable trade association.
13/01/2016 Easy Access Rules for Initial Airworthiness
Easy Access Rules for Part-21, Airworthiness and Environmental Certification, issued November 2015.
This document includes the Implementing Rules (IR) and the Acceptable Means of Compliance/Guidance Material (AMC/GM) in a merged, easy-to-read format. It will be updated within a certain time period after each substantial change to the IR and/or AMC&GM.
06/01/2016 Commission adopts latest ICAO environmental protection standards
The Basic Regulation requires products, parts and appliances to comply with the environmental protection requirements contained in Volumes I and II of Annex 16 to the Chicago Convention as applicable on 17 November 2011, except for the Appendices to that Annex. ICAO amended Volumes I and II of Annex 16 in 2014, by introducing new noise standards, and therefore the Basic Regulation and its Implementing Rules needed to be amended accordingly.
Commission Regulation 2016/4 now amends Article 6 of the Basic Regulation by adopting the new requirements in Amendment 11-B of Volume I and in Amendment 8 of Volume II of Annex 16 except for the Appendices to Annex 16.
Commission Regulation 2016/5 amends point 21.A.18(a) of Part-21 of the Initial Airworthiness Regulation , by specifying the revised requirements:
"The applicable noise requirements for the issue of a type certificate for an aircraft are prescribed according to the provisions of Chapter 1 of Annex 16, Volume I, Part II to the Chicago Convention and:
- for subsonic jet aeroplanes, in Volume I, Part II, Chapters 2, 3, 4 and 14, as applicable;
- for propeller-driven aeroplanes, in Volume I, Part II, Chapters 3, 4, 5, 6, 10 and 14, as applicable;
- for helicopters, in Volume I, Part II, Chapters 8 and 11, as applicable;
- for supersonic aeroplanes, in Volume I, Part II, Chapter 12, as applicable; and
- for tilt-rotors, in Volume I, Part II, Chapter 13, as applicable."
EASA has also issued Amendment 5 to Issue 2 of the AMC and GM to Part-21, through its Decision 2016/003/R, incorporating CAEP/9 amendments to ensure compliance with the latest ICAO SARPs on aircraft noise and aircraft engine emissions.
10/11/2015 EASA revises AMC and GM to Part-21 – Flight Testing
Further to our article, dated 01/07/2015, the European Commission adopted Commission Regulation (EU) 2015/1039 in June 2015 on flight testing, which amends the Initial Airworthiness Regulation (EU). EASA has now supported that amendment by new acceptable means of compliance (AMC) and guidance material (GM).
Decision 2015/026/R addresses a level playing field as well as a harmonisation and safety issue related to flight testing. The specific objective is to harmonise the flight test crew qualification requirements, as well as to increase safety by requiring the organisations involved in flight testing to develop a flight test operations manual (FTOM).
EASA’s Decision provides the AMC with the FTOM requirement and the GM with respect to the lead flight test engineer (LFTE) and flight test categories. Additionally, the GM on the competence and experience of pilots performing Category 3 and 4 flight tests, as well as a detailed AMC on the training course for LFTEs, are part of this Decision.
This Decision also includes AMC detailing the conditions for the appointment of LFTEs from a medical fitness perspective.
Organisations performing or considering performing flight test activities are recommended to review this material in conjunction with the Regulatory changes previously published, and develop such policy, procedures, documentation, and training syllabi, etc. to reflect the new and revised requirements.
01/10/2015 EASA proposes enhanced flammability requirements for Thermal/Acoustic insulation materials
In its NPA 2015-15, EASA addresses a safety and harmonisation issue related to flame propagation and flame penetration resistance characteristics of thermal/acoustic insulation material.
EASA’s specific objective is to improve the protection of occupants of large aeroplanes operated in Commercial Air Transport (CAT) by improving certain characteristics of the insulation material installed in the fuselage: their capability to resist propagation of flame and to resist penetration of flame through the material (burn through).
The NPA proposes to amend Part-26 and CS-26 by introducing specifications on flammability standards for thermal/acoustic insulation material, which are based on CS 25.856 (a) and (b), and are applicable to already type-certified large aeroplanes used for CAT.
EASA expects the proposed changes are to increase safety of large aeroplanes operated in CAT by preventing or reducing the risk of fire propagation or penetration into the aeroplane fuselage.
The proposed changes will also improve harmonisation with the FAA on this subject.
We recommend that CAT operators of large aeroplanes review the proposals in liaison with applicable design approval holders to verify if and how currently installed materials meet the proposed standards. Comments to EASA should be made using the CRT by 08 January 2016.
20/08/2015 EASA proposes AMC and GM for OSD requirements
In its NPA 2015-12, EASA proposes Acceptable Means of Compliance (AMC) and Guidance Material (GM) to facilitate the implementation of the rules related to the approval of changes to Operational Suitability Data (OSD).
The purpose of the draft AMC/GM is to reduce the administrative burden on applicants for the approval of a change. The proposed guidance should allow these applicants to come easily to a decision with regard to:
- whether a design change impacts on OSD or not;
- the classification of changes to OSD as minor or major;
- the certification basis for the OSD change;
- the use of their Design Organisation Approval (DOA) for OSD changes.
Design organisations, operators, and training organisations are recommended to review the content of the NPA in full, including the changes to terminology, etc. and comment to EASA using the automated Comment-Response Tool (CRT) before 20 October 2015.
15/07/2015 EASA updates its TSOA/ETSOA Frequently Asked Questions (FAQ)
TSOA/ETSOA reciprocal acceptance is the process by which the importing authority will accept the exporting authority’s approval of a TSO article without the importing authority issuing an approval. In plain language, this means the FAA will accept an EASA ETSOA for an article from the European Union (EU) and the FAA will no longer issue a Letter of TSO Design Approval, per the current procedure. Likewise, EASA will accept the FAA’s TSOA for an article from the United States without issuing an ETSOA.
A number of associated questions are answered on this page.
We recommend authorisation holders and users of (E)TSO articles familiarise themselves with the information including the stated timescales for implementation.
08/07/2015 EASA concludes Standard Changes and Repairs rules (Phase 1)
Further to our Initial Airworthiness Article, dated 08/10/2014, EASA has now considered the comments made in response to NPA 2014-24, published its CRD and its resulting Decision.
This rulemaking activity addresses a proportionality issue: it will allow a simpler process for the design and embodiment of some changes and repairs when applicable to certain aircraft (aeroplanes up to 5 700 kg MTOM, rotorcraft up to 3 175 kg MTOM, most sailplanes, balloons and airships) and when in compliance with CS-STAN.
The concept of Standard Changes and Standard Repairs was introduced with through Part-21 of the Initial Airworthiness Regulation (paragraphs 21A.90B and 21A.431B). In order to use these concepts, EASA had to publish the related Certification Specifications (CS-STAN). The package now released is the first phase of this rulemaking activity (see ToR RMT.0245 (MDM.048) Issue 2) and contains a first Decision for the initial issue of CS-STAN with additional AMCs, mainly to Part-M.
In the future, CS-STAN will be further supplemented (Phase 2) based on experience and with new proposals provided by the affected stakeholders.
EASA expects the proposed changes to reduce the regulatory burden for the embodiment of simple changes and repairs in certain aircraft when fulfilling the acceptable methods, techniques and practices included in CS-STAN. It is expected that this will have a positive impact on the operation of the affected aircraft in Europe, thus promoting general aviation. Additionally, a simplified procedure for the embodiment of Standard Changes and Standard Repairs could limit the illegal practices of some owners who have not followed the applicable rules when modifying the aircraft and may encourage the installation of safety equipment.
The CRD contains the comments received on NPA 2014-24 (published on 6 October 2014) and the responses provided thereto by the Agency.
We recommend that all owners, Design Organisations, CAMOs, and maintenance organisations involved with applicable categories of aircraft familiarise themselves with the CS and the new Part-21, Part-M and Part-145 soft rule material. Procedures should be developed to control the development and embodiment of Standard Changes and Repairs.
01/07/2015 Commission adopts amending Regulation on Flight Testing
The Commission has now adopted Regulation (EU) 2015/1039 amending the Initial Airworthiness Regulation as regards flight testing, amongst other matters, for the following reasons:
- Further to EASA’s Opinion 07/2013 ,the Initial Airworthiness Regulation should be amended in order to regulate, as part of the flight conditions, the competence and experience for pilots and for lead flight test engineers, depending on the complexity of the flight tests performed and of the aircraft, with a view to increasing safety and enhancing the harmonisation of the competency and experience requirements for flight test crew members within the Union.
- Requirements for production and design organisations conducting flight testing, a requirement to have a Flight Test Operations Manual (FTOM) defining the organisation's policies and the necessary procedures in relation to flight test should also be introduced, so as to promote the safe conduct of flight testing. That manual should include policies and procedures for crew composition and competence, presence on board of persons other than crew members, risk and safety management, identification of instruments and equipment required to be carried.
- The Continuing Airworthiness Regulation has been recast in the interest of clarity. Since the EASA Form 15a, as laid down in the Part 21, refers to the repealed Regulation, it is necessary to update that reference.
- It is necessary to provide sufficient time for the aeronautical industry and the Member States to adapt to those requirements. Therefore, appropriate transitional provisions should be provided for. For certain amendments, however, a specific deferred application date should be provided in light of the nature of those amendments.
Flight Test Operations Manual requirements apply from 01 January 2016, whereas crew competence requirements apply from 01 January 2018. At the time of writing, EASA had yet to issue its Decision containing AMC and GM in relation to this new Regulation.
We recommend all Design and Production organisations, as well as existing aircraft operators who do or plan to provide aircraft for the purposes of Flight Tests, become familiar with the requirements laid out in the Regulation and the applicable AMC and GM, upon publication. Design and production Organisations involved in Flight Testing should define their policy, procedures, etc. and submit their FTOMs to their Competent Authority for approval within the dates specified.
03/06/2015 EASA/FAA/TCCA review guidance for “Changed Product Rule”
EASA has collaborated with the Federal Aviation Administration (FAA) and Transport Canada (TCCA) on the further improvement of the guidance on the implementation of the ‘Changed Product Rule’ (Part 21.A.101). With this rule, EASA establishes the type-certification basis for changes to Type Certificates (TCs) and Supplemental Type Certificates (STCs).
For efficiency reasons, EASA and TCCA have decided to rely fully on the FAA consultation process. Therefore, EASA solicits input from the EU aviation industry by inviting them to submit their comments directly to the FAA.
The draft FAA AC 21.101-1B: Establishing the Certification Basis of Changed Aeronautical Products is available at http://www.faa.gov/aircraft/draft_docs/ac/
For more information, please refer to EASA’s Notice of Availability of Proposed Draft FAA Advisory Circular AC 21.101-1b for Comments.
We recommend TC holders, STC Holders, and other design approval holders review the draft FAA AC and comment as described therein, noting the expiration date for comments is 06/07/2015.
16/04/2015 UK CAA sets up new POA technical group
As advised at the recent Production Airworthiness Seminar, the UK CAA is seeking to establish a working group with the production sector where manufacturing organisations and the regulator can raise and discuss areas of mutual interest and the most effective means by which these can be managed.
The intent is that this group will be open to membership from both the Prime Contractors and the Small/Medium Engineering tiers of the approved production community so that issues affecting all levels can be considered. The Production Technical Group (PTG) will be chaired by UK CAA Head of Airworthiness and this will provide a common point with the UK Operators Technical Group (UKOTG) which provides a similar function for the airlines.
It is likely that where specific issues arise that require detailed work, the PTG will establish ad-hoc working groups to investigate and report on the recommended actions, and that these groups could be chaired either by UK CAA or Industry. The outcomes from the Technical Group will then be used to inform UK CAA Policy and discussions with EASA.
We recommend all approved organisations within the UK manufacturing community to join this group and become involved in influencing UK and EASA policy. Interested organisations should in the first instance refer to the UK CAA’s Information Notice IN–2015/032 for further information and make contact with the UK CAA by 29 May 2015.
26/03/2015 EASA Committee progresses rulemaking on flight recorders, etc.
At its last meeting (20-21 January 2015), the EASA Committee held a discussion on the proposal on flight recorders, underwater locating devices and aircraft tracking systems. The latest developments on aircraft tracking and flight recorders since the last meeting were presented. The main changes and the relationship between the ICAO concept of operations and the draft rules were highlighted. EASA also informed that it was ready to start the focussed consultation process on the related Acceptable Means of Compliance through its advisory bodies.
Member States were supportive of the content of the proposal and of the objective. It was announced and agreed to postpone the vote after the discussions that would be held at ICAO, within the Air Navigation Commission and during the High Level Safety Conference (HLSC). Member States stressed the importance of consistency with ICAO rules.
We recommend aircraft and equipments design organisations and aircraft operators remain vigilant to the impending changes to the requirements, in the light of the loss of MH370 and other related accidents.
12/12/2014 EASA proposes adoption of CAEP/9 amendments on Aircraft Emissions
EASA has published its Opinion 05/2014 addressing an environmental issue related to aircraft noise and aircraft engine emissions. It is linked to the adoption of Amendments 11 and 8 to (ICAO) Annex 16, Volume I and II respectively.
The specific objective is to provide a high uniform level of environmental protection in the European Union as well as a level playing field for all actors in the aviation market by aligning European Union legislation with the latest ICAO Standards and Recommended Practices (SARPs) and Guidance Material on aircraft noise and aircraft engine emissions. The new amendments to these SARPs and Guidance Material were adopted by ICAO in March 2014.
Amendment 11 introduces a new Noise Standard for jet and propeller-driven aeroplanes (Chapter 14) and upgrades the current guidance for the noise certification of tilt-rotors (Chapter 13).
Amendment 8 addresses various technical issues arising from the application of the SARPs and related guidance for aircraft engine emissions certification, but there are no changes to the emissions limits.
This Opinion proposes the incorporation of these amendments into Article 6 of the Basic Regulation and Part-21, to ensure compliance with the latest ICAO SARPs on aircraft noise and aircraft engine emissions, and to provide a level playing field for all actors in the aviation market.
We recommend that aircraft and aircraft engine manufacturers, as well as design organisations involved in modifications that may affect aircraft noise consider these proposals carefully and remain vigilant to their legal adoption, for which there is currently no published comitology time line.
18/11/2014 EASA proposes reducing future reliance on Halon
EASA has published its Notice of Proposed Amendment (NPA) 2014-26 addressing an environmental issue related to the replacement of halon in fire protection systems in aircraft cargo compartments, engine and Auxiliary Power Unit (APU) compartments, lavatory waste receptacles and in portable handheld fire extinguishers for use in cabins and crew compartments. It applies to large aeroplanes (CS-25) and large rotorcraft (CS-29).
The rulemaking task takes into account amendments to ICAO Annex 6, applicable as from 15 December 2011, but not yet transposed into common EU rules:
- Amendment 35 to Part I (International Commercial Air Transport — Aeroplanes);
- Amendment 30 to Part II (International General Aviation — Aeroplanes); and
- Amendment 16 to Part III (International Operations — Helicopters).
The specific objective is to progressively mitigate the environmental impact that halon extinguishing agents in fire fighting equipment have on the atmosphere and the climate change and to progressively achieve ‘halon-free’ aviation, which balances the environmental needs with safe and cost-efficient rules. EASA’s Regulatory Impact Assessment (RIA) demonstrates that for cargo and engine/APU compartments the most appropriate option at the present moment is to ‘do nothing’.
Therefore, EASA proposes to develop an Opinion, to amend Part-26 (Additional Airworthiness Requirements), and a Decision, to amend CS-26 (Additional Airworthiness Specifications for Operations), laying out the framework for the replacement of halon in lavatories and in handheld fire extinguishers on newly produced aircraft (i.e. ‘forward fit’) based on existing Type Certificates (TCs); as from 31 December 2015 in lavatories and as from 31 December 2018 in handheld fire extinguishers. These dates constitute a difference in respect of ICAO Annex 6, but no ‘retrofit’ on the aircraft currently in the fleet is proposed.
The proposed changes are expected to maintain safety, improve harmonisation and ensure compliance, albeit with some delay, with ICAO Standards.
A second NPA is planned to cover some CS-23 aeroplanes and some CS-27 rotorcraft often used in international air navigation.
We recommend aircraft manufacturers, design organisations, and operators understand the implications of what is being proposed and comment via the CRT before 18 February 2015.
06/10/2014 EASA proposes Phase 1 of Standard Changes and Repairs (CS-STAN)
Industry and operators have suggested that the regulatory framework for general aviation (e.g. CS 23) aircraft has become too heavy creating a regulatory burden for the owners of these aircraft and, thus, discouraging the development of this sector of aviation. To address one particular aspect, the Commission introduced (via Regulation (EU) No 748/2012) the concept of “Standard” Changes/Repairs which permit, under certain conditions and for certain aircraft types, the modification of the design of an aircraft without following the design approval process described in 21.A.95, 21.A.97 and 21.A.437. These “Standard” changes and repairs do not require a design approval by EASA or a DOA. However, for this to work, EASA needs to promulgate the adoption of Certification Specifications for Standard Changes and Standard Repairs (CS-STAN), which apply to:
- aeroplanes of 5 700 kg Maximum Take-Off Mass (MTOM) or less;
- rotorcraft of 3 175 kg MTOM or less; and
- sailplanes, powered sailplanes, balloons and airships as defined in ELA1 or ELA2.
In its NPA 2014-24, EASA proposes changes to:
- Part 21 (i.e. GM 21.A.90B and GM 21.A.431B) to reference the newly proposed certification basis CS-STAN; and
- Part M (i.e. GM M.A.801), which allows the release to service under Part M and Part 145, and places the responsibility for that design and its incorporation on the person releasing the aircraft back into service, via a newly proposed EASA Form123.
NPA 2014-24 also includes the first revision of CS-STAN, which consist (for now) of:
- a Preamble with information on how to use/understand the CS and Guidance Material to Part-M in respect of eligibility of parts, installer responsibility, amendment of aircraft manuals, records, etc.;
- a Subpart A for Standard Changes to the following groups of systems:
- Communication (VHF, Mode S, Audio Selectors and Amplifiers, Antennas)
- Electrical (Anti Collision lights, Position lights and Landing & Taxi lights by LED type lights)
- Avionics/NAV/Instruments (FLARM, Moving Maps, Radio Marker Receivers, DMA, ADF and VOR)
- Cabin (ELT)
- Survival (Headrests, alternative foams in seats, safety belts)
- Powerplant (Instruments, Avgas, engine pre-heater)
- Flight (AoA indicator)
- Miscellaneous (Basic flight instruments, “sailplane equipment”)
- a Subpart B for Standard Repairs, including:
- Repairs using FAA AC43-13-1B; and
- Repair of Sailplanes Powered Sailplanes, LSA and VLA
Upon our initial review, we feel this will assist the GA community considerably, but also feel that changes to Part-145 may well also be required in respect to the certification of such maintenance within a Part-145 Maintenance Organisation. We also found it interesting that there appears to be no restriction on using such changes and repairs on aircraft used for Commercial Air Transport.
Owners and operators, together with maintenance organisations (Part-M Subpart F and Part-145) involved with the categories of aircraft referenced are recommended to review the NPA in full and comment upon its contents using the CRT by 06/01/2015.
16/09/2014 EASA rules on fuel tank FRM retrofit requirements
In its Decision 2014/024/R (published 21/07/2014), related to fuel tank flammability requirements for already certified large aeroplanes, EASA concludes that no amendment to existing rules nor additional rules, can be justified in accordance with the results of the RIA, and terminates the rulemaking action related to this subject.
CS-25 requires the installation of Flammability Reduction Means (FRM) in large aeroplanes with a high flammability exposure. These requirements are contained in Appendix M of CS-25, and are, therefore, applicable to new large aeroplane types for which the application for TC was made after 6 July 2009 and to some significant changes to older types. New deliveries of already certified types are also equipped with FRM (‘production cut-in’).
The specific objective of rulemaking task RMT.0075 (26.008) was to consider further improving the protection of occupants on board large aeroplanes operated in commercial air transport (CAT) by reducing the risk of fuel tank explosion. This improvement could be reached by applying the same standards that are applicable to new types also to the existing in-service fleet (‘retrofit’).
The Regulatory Impact Assessment (RIA) compared the option for a mandatory retrofit to the default option of ‘no regulatory change’. The ‘no regulatory change’ option would create no additional rules. Since CS-25 was amended several years ago and the production cut-in is effective, the progressive phase-out of ‘old’ aeroplanes would gradually remove the risk from the fleet.
The RIA also showed that a mandatory retrofit of FRM would have a limited safety benefit. On the other hand, the economic burden ensuing from such a retrofit is significant. Therefore, the retrofit is considered disproportionate and not cost-effective in relation to the possible safety benefit.
26/08/2014 UK CAA explains changes to “grandfathered” parts and appliances
In its Information Notice IN-2014/142 the UK CAA withdraws the ‘grandfather provisions’ for design changes to European Aviation Safety Agency (EASA) Equipment, Parts and Appliances as (originally) advised by in its letter of 27 June 2005, as a result of changes in the regulatory basis for approval of organisations and equipment, parts and appliances; specifically, the signing of the Bilateral Agreements between the European Union (EU) and the United States (US).
It is now therefore necessary for all design changes to be approved by EASA in accordance with the current Part-21 approval processes. This can be achieved by various means, including:
- the TC Holder using the parts in their product;
- direct application to EASA for a minor change;
- approval of the change via another DOA; or
- the organisation obtaining a Part-21 DOA themselves.
It is important to remember that this Information Notice only applies to changes to design data. Where the design data is unchanged and the parts/appliance approval was granted by a member state and valid on 28 September 2003, Article 6 of Commission Regulation (EU) No. 748/2012 provides for the continued validity of that certification and then the data may continue to be used for manufacture under Part-21 Subpart G, as under Article 6 the design data is considered as having been issued in accordance with the EU Regulations.
We recommend that all affected UK manufacturers/design approval holders review the content of this Information Notice and satisfy themselves that current policy and procedures are fully compliant with Part-21 in their own right, rather than by previously “grandfathered” rights.
30/07/2014 EASA concludes volcanic ash ingestion in turbine engines consulation
Following the disruption caused by the last major volcanic eruption in Europe (Iceland's Eyjafjallajokull volcano, 2010), EASA published on 28 November 2012 its Advanced NPA, A-NPA 2012-21, soliciting industry views on possible courses of action for EASA to address the issue of ‘Volcanic ash ingestion in turbine engines’.
That consultation has now ended and EASA has published a combined Explanatory Note and Comment-Response Document (CRD) containing the comments received on its A-NPA together with a summary of its conclusions and proposed future activities.
The feedback provided during the consultation showed that stakeholders considered that there was no rationale to depart from the current ICAO operator-centric approach and that the concept of avoiding operations in visible ash clouds remained a strongly supported principle.
Based on stakeholders’ views and taking into account available knowledge, reports and evidence, EASA has concluded that there is no safety case that would justify an immediate and general rulemaking action to introduce a new volcanic ash airworthiness requirement for turbine engines.
EASA will continue to monitor and assess volcanic ash related risks and to encourage further research activities that can contribute to a better understanding of volcanic hazards.
28/07/2014 EASA issues rulemaking ToR for CS and GM for maintenance certifying staff type rating training
The recently adopted Regulation (EU) 69/20141 requires that Operational Suitability Data (OSD) be included in the application for a type-certificate or restricted type certificate for an aircraft.
This operational suitability data includes, among other data, the minimum syllabus of maintenance certifying staff type rating training, including the determination of type rating.
Consequently, there is a need to develop the Certification Specification for Maintenance Certifying Staff Data (CS-MCSD), whilst there is also a need to develop guidance for classification of changes to the MCSD in accordance with Part 21.A.91.
EASA’s main objective is to improve the level of safety by requiring the applicant for a type certificate (or restricted type-certificate) for an aircraft to identify the minimum syllabus of maintenance certifying staff type rating training, including the determination of type rating.
This will enable the Part-21 Design Approval Holder (DAH) to identify the technical elements necessary to be addressed for the purpose of training of maintenance certifying staff involved in the maintenance of their products.
This minimum syllabus, together with the requirements contained in Part-66, will form the basis for the development and approval of Part-66 type training courses.
The rulemaking group, consisting of representatives from Agusta Westland, Austro Control, British Airways, Airbus, Textron Aviation, EASA, Dassault Aviation, and Boeing is scheduled to deliver an NPA by the end of 2015.
We recommend that design approval holders, as well as operators, maintenance organisations, trade associations, and maintenance training organisations make a maintain contact with relevant members of the group in order to monitor progress and influence the content of the NPA.
23/07/2014 UK CAA reports on EASA rulemaking progress
In its Information Notice, IN–2014/124, the UK CAA reports from the EASA Committee Meeting (8-9 July 2014) on a number of rulemaking subjects, including:
The draft Commission Regulation amending Regulation (EU) 748/2012, as regards flight testing (based on EASA Opinion 7/2013) was discussed and voted upon.
EASA advised that there was industry consultation until the end of May, which resulted in revisions by the Legal service but no fundamental changes to the content of the draft regulation. There followed some queries about to whom this regulation applies. EASA advised that this is only for design and production organisations conducting flight tests under a permit to fly.
The Committee voted in favour of the adoption of this draft Commission Regulation.
Additional requirements for operations (“Part-26”)
The draft Commission Regulation on additional airworthiness requirements for operations (Part-26) as well as amending the Air Operations Regulation as regards airworthiness requirements (based on EASAOpinion 8/2013) was discussed and voted upon
Several Member States raised concerns about obtaining certificated data from older aircraft as the information is simply not available. There was also a request to extend the transition period to 3 years to enable compliance, but the Commission made it clear that the transition period would be 2 years. EASA will review the guidance material to include how to comply in those cases where the certificated data is not available.
The Committee voted in favour of the adoption of this draft Commission Regulation.
13/06/2014 EASA launches Applicant Portal
As part of a range of improvements designed to ensure that applicants receive an efficient and consistent service, EASA has launched the EASA Applicant Portal, what it hopes to prove to be a convenient gateway allowing applicants to prepare and submit applications online. It also allows applicants to view and monitor the status of their applications, and to manage their own contact details and user credentials.
EASA believes that applying online will bring extensive benefits to the application process. Its guided interface will simplify applying for certification tasks, save applicants time and effort, minimise delays caused by validation issues and make the entire process more transparent. In short, the EASA envisages the overall efficiency of the application process will be improved, reducing administrative transactions and thus helping EASA schedule certification work in a timely manner.
The Portal has a user guide for information on how to register to use of the Applicant Portal, view and filter your applications, view and edit contact persons associated with your EASA applicant account, provide credentials for application management users and, last but not least, on how to register and submit applications.
Initially, aimed at Design Organisation Approval holders, it will be possible to submit applications for the following certification tasks online:
- Major Change
- Major Repair
- Minor Change
- Minor Repair
- Supplemental Type Certificate – Initial
- Supplemental Type Certificate – Major Change
- ETSOA – Initial
- ETSOA – Minor Change
However, EASA states that further application types will be gradually introduced in future updates of the Applicant Portal.
We would be interested in hearing from any organisations using the Portal about how useful it proves in use. The Applicant Portal may be found at:
16/04/2014 EASA proposes minimum syllabus for maintenance certifying staff type ratings
EASA has proposed to issue a Certification Memorandum on ‘Type rating determination and minimum syllabus considerations for maintenance certifying staff type rating training in light of Operational Suitability Data requirements’ (EASA Proposed CM-MCSD-001 Issue 01). The related document is available for public consultation on the EASA website.
The purpose of the Certification Memorandum is to provide specific guidance for compliance with certification requirements as stipulated by Annex I Part-21 to Commission Regulation (EU) No 748/2012 in 21.A.15(d)3, coupled with regulatory proviso 21.A.16A and 21.A.16B. It describes how the TC Holder should perceive the Part-21 regulatory requirements regarding the OSD element for Maintenance Certifying Staff Data (MCSD). This Certification Memorandum presents a series of considerations that should guide the TC Holder regarding EASA’s approach in preparation of the Special Condition which will be included in the operational suitability data certification basis to address the OSD-MCSD.
It is neither the role nor the intent of this Certification Memorandum to be understood or used as a substitute for the CS-MCSD (which is under development, and not expected until 2018, at the time of release of this Certification Memorandum).
It should be understood that any TC reference in this Certification Memorandum is generic in nature and should be considered as being also applicable/valid to/for restricted type certificates (RTC) and supplemental type certificates (STC) as well as changes to TC, RTC or STC.
We recommend that Design Organisation approval holders review these proposals and actively participate in EASA’s consultation process.
Furthermore, we recommend that all Part-145, Part-M Subpart F, and Part-147 organisations consider how they might use this information in training courses, etc. Those organisations may also consider it appropriate to participate in the consultation process and the end-users of such data in the future.
09/02/2014 EASA issues its airworthiness and operational considerations for Electronic Flight Bags (EFBs)
EASA has published its General AMC 20-25 detailing airworthiness and operational considerations for Electronic Flight Bags (EFBs).
The introduction of AMC 20-25, replacing and modernising JAA TGL 36 (published in 2004) is expected to increase safety, operational flexibility, and economic efficiency of Commercial Air Transport (CAT) operators by following the latest developments of the state of the art concerning EFB.
The radical changes in respect to TGL 36 are:
- supported by the reactions to CRD 2012-02;
- endorsed during the ‘focused consultation’, held in the form of a Workshop in April 2013; and
- harmonised with parallel ICAO and FAA developments.
It is considered an acceptable means of complying with the requirements contained in CAT.GEN.MPA.180 concerning carriage of electronic documents and manuals, Commission Regulation (EC) 2042/2003 and Commission Regulation (EU) 748/2012.
The AMC is intended to be used by:
- Commercial Air Transport operators of aeroplanes or helicopters;
- applicants or holders of an aircraft Type Certificate (TC) or Supplemental TC; and
- applicants or holders of ETSO authorisations covering software applications hosted in EFBs.
It does not contain additional or double set requirements to those already contained in the operational requirements for the basic information, documentation and data sources that would need to be carried on board. The operator remains responsible for ensuring the accuracy of the information used and that it is derived from verifiable sources.
The evaluation of an EFB may have both airworthiness and operational aspects depending on the category/type of EFB/application used and, therefore, where necessary, to make a complete evaluation of an EFB system, there is a need for close coordination between the two processes.
A separate Decision is planned to introduce ETSO-C165a into CS-ETSO.
CAT operators and EFB/software application design organisations are recommended to review this document in relation to current and under consideration EFB-related projects.
28/01/2014 Commission adopts OSD Regulation
The European Commission has adopted Regulation (EU) 69/2014 introducing requirements relating to Operational Suitability Data (OSD).
The Basic Regulation was extended to include the elements of operational suitability evaluation into the implementing rules for type-certification.
EASA found that it was necessary to amend Regulation (EU) 748/2012 in order to allow it to approve operational suitability data as part of the type-certification process and so prepared draft implementing rules on the concept of operational suitability data, published as its Opinion 07/2011.
In addition and in order to avoid confusion and legal uncertainty with regard to a number of requirements in the cover regulation and Part-21, it is necessary to replace a number of references to ‘airworthiness codes’ with ‘certification specifications’ and a number of references to ‘type design’ with ‘type-certificate’.
This Regulation amends Regulation (EU) 748/2012 accordingly with compliance required by December 2015.
EASA has also published:
- ED Decision 2014/007/R providing the supporting AMC and GM to the new requirements in Part-21;
- ED Decision 2014/008/R providing the Certification Specification – Flight Crew Data (CS-FCD);
- ED Decision 2014/006/R providing the Certification Specification – Cabin Crew Data (CS-CCD); and
- ED Decision 2014/004/R providing the Certification Specification – MMEL (CS-MMEL)
- ED Decision 2014/005/R providing the Certification Specification - Generic Master Minimum Equipment List (CS-GEN-MMEL)
22/08/2013 EASA publishes Opinion on Flight Testing
EASA has published its Opinion (07/2013) addressing flight test safety improvement issues with the specific objective to focus on defining and harmonising the flight test crew qualifications and achieve a smooth transition to the introduced requirements. The Opinion proposes the introduction of a flight test operations manual defining the organisation’s policies and procedures in relation to flight test.
Additionally, Part 21 is proposed to be amended to include a new Appendix XII applicable for CS-23 aircraft with a MTOM above 2 000 kg, and all CS-25, CS-27 and CS-29 aircraft. This appendix focuses on the following topics:
- Definition of flight tests.
- Flight test categories.
- Qualification of pilots for flight testing categories 3 and 4.
- Definition and qualification for lead flight test engineer.
EASA proposes grandfather rules as well as transitional measures to support further potential work on the topic of licensing for lead flight test engineer (LFTE). A separate A-NPA (2013-16) gathers additional data and information and will open the discussion on the creation of a licensing scheme for what is defined as an LFTE (refer to our article of 13/08/2013 for further information).
EASA states that a Decision introducing AMCs and GMs to Part 21 (to provide further guidance on the subjects addressed within this document) will be published in due course.
We recommend that POA holders and other organisations involved in aircraft flight testing review the content of the Opinion, regardless of whether they have commented upon the original NPA or reacted to the CRD (2008-20), as well as the A-NP referenced above.
13/08/2013 EASA explores the need for a Lead Flight Test Engineer (LFTE) licence
In its Advance Notice of Proposed Amendment (A-NPA 2013-16) EASA examines the need for a lead flight test engineer (LFTE) licence. The competence and experience requirements for LFTE have been already addressed by CRD 2008-20 and will be reflected into an Opinion on Part-21 on Flight Testing.
The comments EASA received on the LFTE licensing topic during the consultation period of NPA 2008-20 ‘Flight Testing’ and during the reaction time period to CRD 2008-20, were divergent. Different opinions were also noted when the issue was debated during the dedicated rulemaking group discussions. As a result EASA considers that it is necessary to receive a wider input from the stakeholders, who are strongly invited to comment on this issue and expects to receive focussed feedback on the pros and cons arguments for an LFTE licence.
Additionally, the questionnaire gives EASA’s direct input on the magnitude of the LFTE issue for the current projects and future developments. Stakeholders are asked to choose one of the two options proposed. Based on the input received, a Decision will conclude on the way forward on the LFTE licensing.
We echo EASA’s view and strongly recommend that Production Organisation Approval holders, and individual lead flight test engineers, to consider the proposals in the A-NPA and comment accordingly using the CRT by 13 November 2013.
31/07/2013 EASA publishes CRD on EFB approvals
EASA has published CRD 2012-02 relating to their proposed airworthiness and operational criteria for the approval of Electronic Flight Bags (EFBs)
The original NPA 2012-02 proposed:
- new AMC 20-25 on the airworthiness and operational criteria of Electronic Flight Bags (EFBs) used by Commercial Air Transport (CAT) operators;
- a new version of ETSO-2C165a on Airport Moving Map Display (AMMD); and
- a draft Opinion to amend the Regulation on air operations in relation to EFBs.
Based on the 913 comments received from 45 commentators and the individual responses to each of them, the Agency concludes that no stakeholder objected that Option 2 (i.e. enhance material in JAA TGL 36 to align with the state of the art) is the preferred one.
The CRD reports that stakeholders proposed major modifications to AMC 20-25, which are incorporated in the resulting text, concerning in particular EFB Hardware Taxonomy (EFBs is either ‘installed’ or ‘portable’), EFB Software Application Types (AMMD converted into Type B) and new guidance material for Performance applications, EFB administrator and risk assessment. There is no explicit mention of either operational approval or evaluations by the Agency in the resulting text. Stakeholders also requested to publish ETSO-C165a in index 1 (i.e. technically equivalent to the corresponding FAA TSO) and not in index 2 of CS-ETSO.
In total, the majority of the received comments has been accepted or partially accepted.
The above has been endorsed during a focussed consultation: Workshop at the level of Regulatory Advisory Group (RAG) and Safety Standards Consultative Committee (SSCC) held on 18 April 2013.
The Workshop in addition recommended:
- to open the possibility of requesting the evaluation service by the Agency (on a voluntary basis) not only to authorities and manufacturers, but also to aircraft operators and EFB system suppliers;
- to accelerate RMT.0601 to produce an Opinion for more comprehensive rules on EFB in Commission Regulation (EU) No 965/2012 in line with the amendment to ICAO Annex 6 expected in 2014; and
- to explore, the possibility for the Agency to promote exchange of experiences on EFB and to host a database (e.g. suitable models of portable EFB; suitable batteries; etc.).
EASA intends to adopt AMC 20-25 and ETSO-C165a in the revised text attached to the CRD, after two months given to stakeholders to react to this CRD if their comments were misinterpreted or not fairly taken into account (reaction period closes 01 October 2013).
We encourage operators, which use or intend to use EFBs, and designers and manufacturers of EFBs, to study the content of the CRD and its attachments carefully to ensure the equipment they use, design or make meets the criteria in AMC 20-25 and that future designs meet the revised ETSO criteria.
28/06/2013 EASA extends NPA 2013-07 comment period
Further to our article of 23/04/2013 “EASA proposes new rules relating to ageing aircraft structures in large aeroplanes”, EASA has since announced an extension of the comment period for NPA 2013-07from 23 July 2013 to 23 October 2013.
The proposed changes will affect aircraft design organisations as well as operators of large aeroplanes.
Learning from our own experience we recommend that would-be commentators compile and submit their comments as soon as possible, rather than leaving it too late and missing the opportunity.
14/06/2013 EASA publishes Amendment 13 of CS-25
EASA has published Amendment 13 of its Certification Specification for Large Aeroplanes (CS-25) incorporating generic Special Conditions (SC), AMC Certification Requirements Items (CRIs) and addressing Volcanic ash, through its Decision ED Decision 2013/010/R.
Retaining generic and mature special conditions and/or guidance material, means of compliance in Certification Review Items (CRIs) has been deemed not in compliance with the Basic Regulation and does not facilitate transparent and open regulation. The Agency therefore decided to incorporate these generic CRIs in CS-25 after consultation of stakeholders; this was performed under rulemaking task RMT.0067 (25.070).
In addition, the Agency has determined that following recent experiences with volcanic activity and forecast widespread airspace contamination, there is a need to strengthen regulations in order to maintain continued flight safety while minimising the likelihood and severity of disruptions to normal flight operations in any future volcanic events.
The Basic Regulation already place an obligation on design organisations to provide operators with limitations and other information necessary to ensure that no unsafe condition will occur from exposure to environmental hazards. While this can be understood as meaning all environmental hazards, detailed certification specifications related to volcanic cloud hazards have not been previously addressed in the Certification Specifications. Amendment 13 introduces a new certification specification and acceptable means of compliance into CS-25 to ensure that design organisations undertake an assessment of their products’ susceptibility to volcanic cloud hazards as part of type certification, and establish limitations and/or information for their safe operation. The applicability of the certification specification is aligned with the operational need for a management system.
10/05/2013 IMRBPB - a timely reminder
The International Maintenance Review Board Policy Board (IMRBPB) is envisioned as a system for the continuing development of policies, procedures and guidance for the use of personnel operating under the purview of various Maintenance Review Boards (MRBs). In addition to promoting harmonisation with other regulatory authorities, the IMRBPB advocates the standardisation of MRB policy and procedures. The IMRBB also provides a structured forum for discussions leading to the development of national and international policy regarding all MRB activities.
Membership currently includes the regulatory authorities of Australia, Brazil, Canada, China, EU, Hong Kong, Japan, Russia, Singapore, and the USA, as well as all the major manufacturers.
Whilst the group is focussed upon MRB practice, much of the information published on the EASA IMRBPB website should be of use to those personnel involved in Maintenance Programme management within CAMOs, particularly those involving Large Aeroplanes.
23/04/2013 EASA proposes new rules relating to ageing aircraft structures in large aeroplanes
EASA has published its proposed changes to current rules and standards to address a safety issue related to ageing aircraft structures for large aeroplanes.
NPA 2013-07 proposes changes to the Implementing Rules, certification specifications, Acceptable Means of Compliance and Guidance Material in order to ensure that the safety risks associated with the ‘ageing aircraft’ issues are mitigated.
With the increased use and longer operational lives of ageing aircraft, there has long been a need for a programme to ensure a high level of structural integrity and furthermore to maintain it in the future. The initial rulemaking task on the ‘Development of an ageing aircraft structure plan’ was divided into three different tasks. This NPA addresses only large aeroplanes and the subsequent tasks will establish if there is a need to develop continuing structural integrity programmes for other classes of aircraft as well as addressing concerns over the change of the operational use.
To address the existing large aeroplane fleet and to protect the future fleet of large aeroplanes the NPA proposes the implementation of the following changes:
- amend Part-21 (initial airworthiness requirements);
- amend Part-26 (Additional airworthiness requirements for operations and the corresponding Certification Specification CS-26);
- amend CS-25 (Certification Specifications and the corresponding AMC for large aeroplanes);
- amend AMC 20-20 (Continuing Structural Integrity Programme); and
- amend AMC to Part-M ‘Continuing Airworthiness Requirements’.
This expansive document (over 200 pages) provides a wealth of background information that we consider useful to a range of organisations. However the new requirements being proposed will also have an impact upon those organisations as well, and so we recommend that design approval holders, design organisations generally, competent authorities, and operators, CAMOs and maintenance organisations involved with large aeroplanes review and consider the implications of the proposals.
We would be happy to discuss the subject matter with such organisations.
Comments should be made to EASA using the CRT by 23 July 2013.
06/03/2013 Rulemaking on Operational Suitability Data (OSD)
The UK CAA reports in its Information Notice IN-2013/035, having examined some further, the Commission proposed texts from the Agency, suggesting a few amendments and identifying areas to be clarified. The Commission would discuss further with the Agency and then present its formal proposals at a future Committee meeting.
09/01/2013 Environmental protection requirements formally revised
The European Parliament and Council has now formally revised the environmental protection requirements laid down in the Basic Regulation ((EC) 216/2008) through the adoption of Regulation(EU) 6/2013, in response to EASA Opinion 06/2011.
Products, parts, and appliances must now comply with the environmental protection requirements contained in Amendment 10 of Volume I and in Amendment 7 of Volume II of Annex 16 to the Chicago Convention, as applicable on 17 November 2011, except for the Appendices to Annex 16.
The Regulation includes transitional arrangements allowing member States to exempt manufacturers under specified condition until the end of 2016.
The Implementing Rules relating to design and production in Regulation (EU) 748/2012 have also been revised through the adoption of Regulation (EU) 7/2013.
20/12/2012 Progress on Regulations for Operational Suitability Data (OSD)
Further to our previous article on the subject, dated 13/12/2011, the UK CAA reports in its Information Notice IN-2012/204 that EASA updated the EASA Committee on further discussions with industry which had led it to propose to the Commission further amendments to the recommended regulations relating to Operational Suitability Data (OSD). As the Committee had not seen the latest text, members’ comments focused on ensuring that transitional arrangements, catch-up periods and various processes would be realistic and proportionate.
No timescales were proposed for the publication of the Regulation or the associated Certification Specifications.
28/11/2012 EASA invites industry to comment upon volcanic ash contamination in engines
The ICAO International Volcanic Ash Task Force (IVAFT), set-up in response to the Eyjafjallajökull eruption in April 2010 to review guidance for flight operations in volcanic ash, has now largely completed its tasking and has been disbanded. This international effort has contributed to a better understanding of the hazards to aviation posed by volcanoes, has generated greater awareness of the impacts resulting from flight operations in volcanic ash clouds, and has recommended changes to operational procedures, the implementation of which will reduce the potential disruption to flight operations in future volcanic events. This approach has been embraced by EASA and ongoing rulemaking activities will embed the recommendations into operational rules.
The IVAFT recommendations retain the underlying principle of avoiding flight in visible ash. This brings with it some uncertainties as to the robustness of the approach, as a clear definition of visible ash that can be used in all environments (e.g. at night and in IMC) does not currently exist, and ash can be difficult to distinguish from normal clouds, smoke, haze, etc. Furthermore, there is a view that the avoidance principle may be overly conservative, and that safe, robust procedures, that significantly enhance operational flexibility, could be established in the future if aircraft were permitted to operate into a known ash environment. Such an approach would require airworthiness standards and acceptable means of compliance to be established. Chief amongst these will be a focus on turbine engines, due to their susceptible to volcanic ash, and the significant implications to engine performance, environmental impacts and economic consequences, if such an approach were to be adopted.
EASA has produced Advanced NPA (A-NPA) 2012-21 to gather information from stakeholders on the concept of moving towards airworthiness certification of turbine engines. It proposes a number of options that could be followed and outlines the various pros and cons. Stakeholders are asked to comment on these options and, in particular, to respond to various questions embedded in the A-NPA by 28 February 2013.
30/10/2012 EASA issues consolidated AMC and GM for Part-21
EASA has published a new issue (issue 2) of the Acceptable Means of Compliance and Guidance Material to Part-21 (AMC and GM to Part-21), through the issue of Decision 2012/020/R.
This new issue incorporates:
- all the amendments issued since the initial issue of AMC and GM to Part-21 (Decision No 2003/01/RM),
- the changes that are linked to the four Agency Opinions which were included in Commission Regulation (EU) No 748/20122, and
- other changes which are necessary to align it with the new regulation and remove any known errors, incorrect cross-references, editorials etc.,
Approved organisations, including, but not limited to:
- DOA holders;
- POA holders;
- CAMOs; and
- Maintenance organisations
are strongly recommended to review the document for the newly introduced material as well as becoming familiar with the revised format, etc.
15/03/2012 EASA proposes approval criteria for Electronic Flight Bags (EFB)
After over five years since the inception of the working group and its ToR, EASA has now published NPA 2012-02, which proposes:
- a new AMC 20-25 on the airworthiness and operational approval criteria of Electronic Flight Bags (EFB) used by Commercial Air Transport (CAT) operators by aeroplanes or by helicopters,
- an associated new version of ETSO-2C165a on Airport Moving Map Display (AMMD), and
- a draft Opinion to amend the forthcoming Regulation on Air operations in relation to EFBs.
The NPA considers three major aspects:
- Improved definitions of EFB classes and types to make them more precise and objective, i.e. better delimiting the boundary between what has to be considered as part of the on-board avionics and the ‘non-avionics’ part of the flight crew compartment,
- Proposed data connectivity between EFBs and avionics, and
- Redefinition of the roles and responsibilities of the competent authorities at national level, and of the Agency, taking into account the provisions of the Basic Regulation and the related imminent Implementing Rules, in particular for air operations and for Operational Suitability Data (OSD).
EASA is aware that the EFB issue can be controversial, but also considers that:
- the improper use of EFBs may cause safety concerns,
- continuous progress of Information Technology on the commercial market outside aviation, leading to increasing use and requests for EFB applications, requires rulemaking initiative from the Agency in the earliest possible time, and
- an NPA is the proper tool to consult the stakeholders’ community on important issues, even if controversial.
In closing, EASA considers that the currently proposed mix of design and operational domains in one document makes it difficult to define clear boundaries between the obligations of the aircraft operators and those of the aircraft manufacturer, so it intends, in the future, to separate the regulatory material on EFB into two or more different documents:
- one (or more) AMC attached to the Air Operations Regulation, and
- a revised AMC 20-25 limited to the Airworthiness aspects.
We recommend that operators and manufacturers of both the affected hardware and software consider these proposals carefully and comment on the NPA by 18 June 2012.
29/02/2012 EASA addresses shortfalls in Executive Aeroplane interior design codes
CS-25 is applicable to large aeroplanes powered with turbine engines and, as most of those aeroplanes are used by airlines, CS-25 is clearly written with high density Commercial Air Transport aeroplanes in mind. However, executive aeroplanes are often in the CS-25 category, but with interiors completely different from the airliners, and carrying passengers who are often quite familiar with air transport.
When an aeroplane submitted to CS-25 is being customised as an executive aeroplane, CS-25 does not always provide appropriate rules for its interior design, and implementation is a significant source of burden to the Type Certificate (TC) and Supplemental Type Certificate (STC) applicants, as well as to the Authorities. In addition, EASA is concerned that there is risk that the rule, being inadequate, will not be consistently interpreted and implemented by all the interested parties.
Up to now, Special Conditions, Equivalent Levels of Safety (ELoS) and Interpretations are being issued by the Agency through the Certification Review Item (CRI) process. Issued on a case by case basis with the intent of better addressing executive interiors in large turbine powered aeroplanes, they are mostly repetitive from one application to another.
EASA is therefore proposing to establish alternative criteria and interpretations that may be used voluntarily to complement CS-25 and will thoroughly address the specificities of executive interiors, while providing an equivalent safety level to what is required by the current CS-25 and associated CRI process.
Even though these special conditions and interpretations provide a better coverage for executive interiors, there are still unaddressed areas where the absence of adequate guidance is a source of discussions and undue resource consumption. Moreover, the absence of adequate guidance generates a risk of inconsistent implementation of the rule.
The overall objective of the ToR is the mitigation of the diverging interpretation of safety requirements on interior designs for aeroplanes with executive interiors. This is to ensure a common understanding of measures with an acceptable level of safety similar to current CS-25 requirements when applied to commercial airliners and to avoid time-consuming activities on repetitive certification issues.
The NPA shall establish Executive Interior design specifications that will amend and/or complement CS-25 by introducing new provisions and associated AMC/GM, taking into account the compensating factors offered by such interiors and their utilisation.
23/02/2012 EASA invites you to Part 21 Design Organisation Approval (DOA) Implementation Workshop
EASA has invited interested parties to attend a “Part 21 Design Organisation Approval (DOA) Implementation Workshop” to be held at Köln, Germany on 30th – 31st May 2012.
The objective of the workshop is to give to Authorities staff involved in EASA DOA an update on EASA Design Organisation (DO) Section internal working procedures. It will also specifically focus on several subjects of significance to be shared equally between Authorities staff and EASA Staff working in a DO environment. The format of the workshop will allow the participants to have more time for discussions and questions and answers.
EASA expects and encourages lively discussions during the workshop and to determine the “hot topics”, participants were invited to submit their proposals.
22/12/2011 UK CAA advises of impending recast for Initial Airworthiness regulation
Amendments to both Regulations (EC) 1702/2003 and 2042/2003 to introduce provisions relating to European Light Aircraft (ELA 1 and ELA 2) were agreed in principle at the EASA Committe meeting held 6-8 December 2012, with the new regulations likely to come into force in June/July 2012.
The text for formal agreement relating to Regulation (EC) 1702/2003 will take the form of a complete recast of the regulation involving regrouping existing provisions and the amendments plus deletion of obsolete text. This will result in a new regulation, with a new number.
13/12/2011 EASA publishes its Opinion on Operational Suitability Data (OSD)
EASA has now published it Opinion (07/2011) proposing changes to several implementing rules to introduce the concept of Operational Suitability Data (OSD). The OSD concept has been introduced in the Basic Regulation as part of the 1st extension package.
The new rules will ensure that certain data, necessary for safe operation, is available to, and used by the operators. This data is considered specific to an aircraft type and must therefore be produced by the designer of that type. It consists of:
- the minimum syllabus of pilot type rating training,
- the aircraft reference data to support the qualification of simulators,
- the minimum syllabus of maintenance certifying staff type rating training,
- type specific data for cabin crew training, and
- the master minimum equipment list (MMEL).
The OSD proposed by the designer will be approved by the EASA along with the airworthiness certification and, once approved, the OSD must be used by operators and training organisations when establishing their customised training courses and MEL.
EASA expects OSD to contribute to closing the gap between airworthiness and operations, so operators, and design, continuing airworthiness management, maintenance, and maintenance training organisations are encouraged to review the wide-ranging proposed changes to assess their impact.
17/10/2011 CRD to NPA 2011-08 Implementation of CAEP/8 amendments
Further to our article dated 16/05/2011, EASA has now published the CRD to NPA 2011-08 relating to the certification of engines, particularly updating the Basic Regulation and affected Certification Specifications to reflect Amendement 8 of the Committee on Aviation Environmental Protection (CAEP).
22/09/2011 EASA moves to address Volcanic Ash issues at the design level
The eruption of the Eyafjallajokull volcano in Iceland in April 2010 severely affected air traffic in Europe and globally. As a response to this event, ICAO created the International Volcanic Ash Task Force (IVATF) in July 2010 in order to assess the global aviation needs in relation to volcanic events.
One of the sub-groups of the IVATF (AIR04) has developed a proposal to States for a globally applicable process to facilitate operations into, or avoidance of, areas known or forecast to contain volcanic clouds. The approach is based on a safety risk assessment that must be performed by the operator and accepted by the State of the Operator.
EASA has recently published is proposals for changes to design standards (Certification Specifications) in relation to Volcanic Ash in support of the approach adopted within the AIR04 proposal. NPA 2011-17 intends to aid its application by mandating the supply of relevant information from manufacturers to support operators in developing their safety risk assessment.
We encourage operators to review the Agency's proposals and consider how effective they would be in meeting this objective.
Comments should be made using the CRT by 23 December 2011.
26/08/2011 AMC & GM Part 21/8 - classification of changes in relation to environmental protection
EASA has published ED Decision 2011/006/R amending the AMC & GM to Part-21 aimed at clarifying the classification of changes to products in relation to environmental protection standards.
Based on practical experience in the past years, when handling applications for a change to a type design, EASA came to the conclusion that it would be useful to provide specific examples. These examples of changes are intended to clarify and to illustrate what changes might cause an appreciable change in the product’s environmental characteristics, i.e. lead to a change to the environmental protection certification levels.
It has to be emphasised that the examples given are not intended by EASA to introduce any new practice; but they are intended to simply describe current practice.
The Decision and an Explanatory Note may be found on the AMC & GM page of the EASA website.
28/07/2011 EASA announces Terms of Reference for Certification Specifications for standard aircraft changes and repairs (PHASE 1)
Based on reactions to the CRD for the NPA 2007-08 on “Revised Part-M requirements for aircraft not used in Commercial Air Transport and Pilot owner maintenance”, a number of persons and organisations, mainly representing light aircraft owners or federations, requested to directly accept the use of the FAA Advisory Circulars AC 43.13-1 and 43.13-2 for changes and repairs.
These FAA documents have been used in light aircraft maintenance for a number of decades in the absence of, for example Structural Repair Manuals and/or Standard Practices Manuals, which are generally available for larger aircraft types. Early in the development of the current regulations on initial and continuing airworthiness, it became clear that use of these FAA documents could not be accepted on legal grounds, but this does not appear to have made the need for their use, or indeed their use, diminish in the absence of viable alternatives.
Recent Opinion 01/2011 (refer to our entries dated 21/03/2011) proposed introducing a similar concept and supporting reference documents in Europe to aid industry and private owners in meeting their regulatory responsibilities.
This ToR has now been published and we encourage light aircraft owners, continuing airworthiness management organisations, and maintenance organisations to participate in the drafting of the proposed Certification Specification, which is due to apply in 3 stages:
PHASE 1: create CS for standard changes and repairs applicable to
- balloons and airships as defined in ELA 1
- sailplanes and powered sailplanes as defined in ELA 1
- LSA / VLA / ELA 1 aeroplanes (day VFR only).
PHASE 2: amend CS to add standard changes and repairs applicable to
- ELA 2 aircraft,
- aircraft other than ELA 1/ELA 2 up to 2730 kg MTOM, excluding those addressed in PHASE 1.
PHASE 3: amend CS to add standard changes and repairs applicable to
- aeroplanes up to 5 700 kg MTOM,
- rotorcraft up to 3 175 kg MTOM, excluding those addressed in PHASES 1 and 2.
The respective Decisions are scheduled to be issued in 2014-2015.
15/07/2011 NPA 2011-12 Systematic review and transposition of existing FAA TSO standards for parts and appliances into EASA ETSO
European Technical Standard Orders (ETSO) are defined by Article 1.2(g) of EASA Part-21 as detailed airworthiness specifications, issued by the Agency to ensure compliance with the requirements of Part-21 as minimum performance standards (MPS) for specified articles.
EASA has published this NPA, which proposes to:
- introduce new ETSO specifications that are, where possible, technically similar to existing Federal Aviation Administration (FAA) TSOs, and
- publish the set of ETSOs proposed herein on the web, as individual documents, ordered according to their number (not as part of a large document titled “CS-ETSO” and covering several very diversified subjects) as currently used by the FAA in the USA.
Comments should be submitted by 18 October 2011.
28/06/2011 NPA 2011-11 Certification Specification for Master Minimum Equipment Lists (CS-MMEL) - (UPDATED 23/08/2011)
EASA has published NPA2011-11, introducing CS-MMEL following the introduction of the Operational Suitability Data concept in Part 21 mandating the development of a Master Minimum Equipment List (MMEL) for all types. CS-MMEL contains the Certification Specifications for establishing the MMEL for motor-powered aircraft, and has been derived from existing JAA reference documents in the field.
The two main areas of change from the existing JAA material is the introduction of a Certification Specification with relation to quantitative analysis, reflecting the ARAC ASAWG recommendations, in particular when it is needed to support the qualitative assessment, and to what level in relation to type design Certification Specifications requirements might be considered as achieving an acceptable level of safety. The second area is the transfer of MEL policy from JAA TGL 26 into MMEL in the form of an MMEL Guidance Book, introduced to allow for a standardised and harmonised level of relief for common items as appropriate. This guidance is based on TGL 26 and to allow comparison previous TGL 26 relief is listed in this NPA, where applicable, but will be removed from the final decision.guidance material. Both of these changes are covered in this NPA by Regulatory Impact Assessments.
As a result, changes have been introduced in relation to quantitative safety assessments . Also
According to EASA, "The proposed text takes into account the proposed amendments to Part-21 related to Operational Suitability Data and the future air operations implementing rules, and ensures harmonisation with the applicable rules of Federal Aviation Administration (FAA) and Transport Canada (TCCA)."
Whilst this NPA and the proposed CS is aimed at Type and Supplemental Type Design Organisations, aircraft operators are also affected as it will affect how they generate their MEL and relief that can be obtained against Operational Regulations for all aircraft regsitered in Member States. National authorities which have used TGL 26 as guidance in the MEL approval process in the past are also affected.
We would therefore recommend that the following organisations review this NPA, assess its impact on their activities and comment accordingly to EASA:
- Operators involved in commercial operations, regardless of aircraft size or complexity,
- Operators of complex motor powered aircraft, regardless of use (commercial or non-commercial), and
- Continuing Airworthiness Management Organisations managing commercially operated or complex motor powered aircraft.
Comments should be made using the CRT by 31 October 2011, extended from the original 28 September 2011.
06/06/2011 NPA 2011-10 Certification Specification - Cabin Crew
EASA has published NPA 2011-10 and, contrary to first thoughts, this document is not the detailed design requirements for a member of Cabin Crew, but rather it comprises information related to the type specific elements for cabin crew, as required under the Operational Suitability Data concept discussed in NPA and subsequently CRD 2009-01 (refer below).
The Certification Specifications include the proposal of the following:
- A uniform process and criteria for determination of a new type and a variant for cabin crew operation. The determination process is based on the comparison of candidate and base aircraft and assessment of similarity of the type specific elements related to aircraft configuration, doors and exits, aircraft systems and normal and emergency operations.
- Provision of aircraft type specific data for development of training programmes for cabin crew. The mandatory provision of data, necessary for the development of type specific and differences training programmes, relates to aircraft description, flight crew compartment, cabin compartment and aircraft systems including associated equipment. The voluntary provision represents supplementary data the applicant may elect to provide to support the development of training programmes.
Comments should be received by the Agency before 6 September 2011.
28/05/2011 NPA 2011-09 Incorporation of generic SC and AMC CRIs in CS-25
EASA has puiblished NPA2011-09 incorporating generic Special Conditions (SC) and Certification Review Items (CRI) into Certification Specification 25 (Large Aeroplanes).
This NPA proposes an upgrade of CS-25 by introducing generic CRI (Certification Review Items) containing Special Conditions and/or Guidance Material, Means of Compliance.
The intent is to reflect the current certification practices and to facilitate future certification projects.
The following items are addressed:
Lithium-Ion battery installation, Stalling speeds for structural design, Design manoeuvre requirements, Design dive speed, Side stick controls, Towbarless towing, Steep approach and landing, Protection of Essential Systems and Equipments in Class E Cargo Compartments, Removal of Need for Stretchers to Comply with CS 25.562, Inclusion of Engines at Ground Idle when Assessing Escape Slide Performance in Wind, Oxygen outlets in the galley work areas, Fireproofness of engine cowlings, Flight envelope protection, Reduced and derated take-off thrust, Go-around performance.
Comments should be submitted by 31 August 2011.
16/05/2011 NPA 2011-08 Implementation of CAEP/8 amendments
EASA has published NPA 2011-08 relating to the certification of engines, particularly updating the Basic Regulation and affected Certification Specifications to reflect Amendement 8 of the Committee on Aviation Environmental Protection (CAEP).
It implements the rulemaking tasks:
- BR.008 — Implementation of CAEP/8 amendments;
- 34.002 — Update of CS-34 to refer to the Environmental Technical Manual on emissions certification as amended after CAEP/8; and
- 36.006 — Update of CS-36 to refer to the Environmental Technical Manual on noise certification as amended after CAEP/8.
and incorporates the following documents into the EU certification regime:
- Amendment 10 to ICAO Annex 16, Volume I
- Amendment 7 to ICAO Annex 16, Volume II
- ICAO Doc 9501 — Environmental Technical Manual, Volume I — Procedures for the Noise Certification of Aircraft
- ICAO Doc 9501 — Environmental Technical Manual, Volume II — Procedures for the Emissions Certification of Aircraft Engines
- The NOx production cut-off requirement and the exemption process
The NPA can be viewed and dowloaded from the NPA website and comments are invited, using the CRT, by 16 August 2011.
13/05/2011 CRD 2009-01 (Operational Suitability Certificate and Safety Directives)
The purpose of the original NPA 2009-01, released 16 January 2009, was to consult on the draft Opinion of the Agency for a regulation amending the Initial Airworthiness requirements of Commission Regulation (EC) No 1702/2003 of 24 September 2003, to introduce the concept of operational suitability and additional airworthiness specifications for operations. The scope of this rulemaking activity is outlined in the Terms of Reference (ToR) 21.039.
By the extended closing date of 30 June 2009, EASA had received 1011 comments from 80 National Aviation Authorities, professional organisations, and private companies.
In order to handle these comments, EASA established a comment review group composed of members of the drafting group and two additional experts from manufacturing industry, operators associations, aviation personnel associations, EASA and national aviation authorities. The issues outlined below were extensively discussed in the group and even though full consensus on all issues could not be achieved, EASA has drafted this CRD and the resulting text taking into account all the views of the individual experts.
- Operational Suitability Certificate (OSC) Concept
- OSC a a separate certificate
- Use by operators of minimum syllabi for type training
- Master Minimum Equipment List (MMEL)
- Applicability to small aircraft
- Cabin Crew
- Flight Simulators
- OSD for engine TC