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Thanks,
Luc
The EMF General Conference agreed unanimously to respond to A-NPA 14/2006 as below .
Question 1. The Agency is interested in knowing the opinion of stakeholders on the general balance of the envisaged concept, as well as any suitable comment on its content not covered by the following questions.
EMF Note: This is not a particularly important question and is almost impossible to answer from the information given in the A-NPA. However, the answer below will be fine.
EMF Answer 1. Although the general balance of the A-NPA gives cause for optimism there is a long way to go from here and much opportunity to get things wrong on the way.
Question 2. The Agency is interested in knowing the opinion of stakeholders, in particular potential assessment bodies, on introducing the possibility for approved assessment bodies to issue and administer approvals, certificates or licences, as a means to relax the regulatory framework applicable to General Aviation. It is also interested by comments about having one-man assessment bodies similar to the American system of designees.
EMF Answer 2. The introduction of approved assessment bodies is strongly supported and the use of one-man assessment bodies should certainly be considered.
Question 3. The Agency is interested in knowing the opinion of stakeholders on which of the options described here above they think is the most suitable for regulating General Aviation initial airworthiness. In such a context comments on the weight limits envisaged are welcome.
EMF Answer 3. Option 3 is the preferred. In particular it is essential that there is a separate weight category for aircraft with a MTOM of below 750 kg (or similar - 850 kg was also suggested)
Question 4. The Agency is interested in knowing the opinion of stakeholders on the following points:
a) Should assessment bodies be involved in the oversight of continuing airworthiness, such as ARCs’ renewal;
b) What should be the role of NAAs in this field?
c) Should continuing airworthiness requirements be adapted to the size/type of aircraft? How should this be done?
d) Is it worth developing standards modifications and repairs that could be embodied without the need for further approvals? Which bodies should do so?
f) Is it possible to develop Industry Standards to be used in continuing airworthiness processes? Which bodies should be in charge?
EMF Answer 4.
a. Yes, assessment bodies should be involved in the oversight of continuing airworthiness
b. None, there is no role envisaged for the NAAs
c. Yes, continuing airworthiness should be adapted to the size/type of aircraft, with aircraft categorised by weight and complexity and continuing airworthiness left in the hands of assessment bodies
d. Yes, it is worth developing standard modifications and repairs and the assessment bodies should do this.
e. Yes, it is possible to develop Industry Standards and the assessment bodies should be in charge of this.
Question 5. The Agency is interested in knowing the opinion of stakeholders on what they think should be the content of the “light” implementing rules for air operations.
EMF Answer 5. While "light" sounds good it is not at all clear what it means in this context. As far as possible the implementing rules should be aligned to international (ICAO) standards with minimal requirements dictated by the complexity and mode of operation of the aircraft.
Question 6. The Agency is interested in knowing the opinion of stakeholders on what they think should be the conditions and privileges of a European Private Pilot Licence, with particular emphasize on:
a) The type of aircraft it would allow flying and in particular whether an upper weight limit would be appropriate? If so, what it could be?
b) The ratings that could be attached to such a licence;
c) The way medical assessments could be done and the possible role of general practitioners.
EMF Answer 6.
a. There seems to be no reason why the EPPL could not extend to all aircraft covered by this A-NPA up to 5700 kg.
b. Any rating that could be possible for the aircraft covered by the A-NPA should be available for the EPPL.
c. Medical assessments for the EPPL should be by self-declaration supported by the general practitioner.
Question 7. The Agency is interested in knowing whether stakeholders think possible to remove certain aircraft from Annex II if the envisaged concept (in particular with options 2 or 3 for initial airworthiness) were implemented?
EMF Answer 7. With regard to paragraph e in the Regulation (EC) No 1592/2002 of 15 July 2002, proposed to be amended (Com 579), NO aircraft should be removed from Annex II.
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